Air Individual Permit Major Amendment 01700002-101 for

Air Individual Permit

Major Amendment

01700002-101 Permittee: Sappi Cloquet LLC

Facility name: Sappi Cloquet LLC 2201 Avenue B Cloquet, MN 55720-2155 Carlton County

Operating permit issuance date: March 13, 2012 Expiration date: March 13, 2017 * All Title I Conditions do not expire Major Amendment: June 30, 2017 Stage 1 issuance date – Authorization to Construct and Operate: June 15, 2017 Stage 2 issuance date – Major Amendment: June 30, 2017 Permit characteristics: Federal; Part 70/ Major for NSR; NSR Authorization * The Permittee may continue to operate this facility after the expiration date of the permit, per the provision under Minn. R. 7007.0450, subp. 3. (Title V Reissuance Application was received 6/15/16.) The emission units, control equipment and emission stacks at the stationary source authorized in this permit amendment are as described in the Permit Applications Table. The conditions included in Stage 1 of this permit action are effective on the Stage 1 Issuance Date shown above. Stage 1 conditions authorize construction and modification of the facility and the operation of the modified emissions units at the address listed above until final action is taken on Stage 2. Air Emission Permit No. 01700002-015 remains effective until the Stage 2 Issue Date. Beginning on the Stage 2 Issue date Air Emission Permit No. 01700002-101 supersedes Air Emission Permit No. 01700002-015 and authorizes the Permittee to operate and modify the stationary source at the address listed above unless otherwise noted in the permit. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R. 7007.1150 to 7007.1500. Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into the SIP under 40 CFR § 52.1220 and as such are enforceable by U.S. Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act.

Stage 1 Issuance Approval:

Signature: Jared LaFave This document has been electronically signed. for the Minnesota Pollution Control Agency

for Don Smith, P.E., Manager Supervisor, Air Quality Permits Unit 3 Air Quality Permits Section Industrial Division

Stage 2 Issuance Approval:

Signature: Jared LaFave This document has been electronically signed. for the Minnesota Pollution Control Agency

for Don Smith, P.E., Manager Supervisor, Air Quality Permits Unit 3 Air Quality Permits Section Industrial Division

Table of Contents

Page

1. Permit applications table ............................................................................................................................................. 4 2. Where to send submittals ............................................................................................................................................ 5 3. Facility description ....................................................................................................................................................... 6 4. Summary of subject items ........................................................................................................................................... 9 5. Limits and other requirements .................................................................................................................................. 17 6. Submittal/action requirements ............................................................................................................................... 160 7. Appendices ............................................................................................................................................................... 190

Appendix A. Insignificant Activities and General Applicable Requirements .......................................................... 190 Appendix B: Stack Parameters Relied Upon in Modeling ...................................................................................... 193 Appendix C: Road Segment Speed Limit and Silt Load Test Areas ......................................................................... 235 Appendix D: Performance Test Recordkeeping Items and Testing Schedule ........................................................ 236 Appendix E: Fugitive Emission Control Plan........................................................................................................... 240

Permit issued: June 30, 2017 01700002-101 Permit expires: March 13, 2017 Page 4 of 243

1. Permit applications table

Subsequent permit applications: Title description Application receipt date Action number Part 70 Reissuance 12/06/2011 01700002- 014 Administrative Amendment 09/21/2011 01700002- 014 Major Amendment 11/15/2011 01700002- 014 Reopening 08/03/2012 01700002- 015 Reopening 02/27/2013 01700002- 015 Administrative Amendment 04/25/2013 01700002- 015 Administrative Amendment 12/09/2013 01700002- 015 Reopening 12/10/2013 01700002- 015 Major Amendment 10/22/2014 01700002- 015 Supplemental Information 02/06/2015 01700002- 015 Reopening NA 01700002- 101 Administrative Amendment 05/06/2016 01700002- 101 Major Amendment 09/30/2016 01700002- 101


2. Where to send submittals

Send submittals that are required to be submitted to the U.S. EPA regional office to: Chief Air Enforcement Air and Radiation Branch EPA Region V 77 West Jackson Boulevard Chicago, Illinois 60604

Each submittal must be postmarked or received by the date specified in the applicable Table. Those submittals required by Minn. R. 7007.0100 to 7007.1850 must be certified by a responsible official, defined in Minn. R. 7007.0100, subp. 21. Other submittals shall be certified as appropriate if certification is required by an applicable rule or permit condition.

Send submittals that are required by the Acid Rain Program to:

U.S. Environmental Protection Agency Clean Air Markets Division 1200 Pennsylvania Avenue NW (6204N) Washington, D.C. 20460

Send any application for a permit or permit amendment to:

Fiscal Services – 6th Floor Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Also, where required by an applicable rule or permit condition, send to the Permit Document Coordinator notices of:

a. Accumulated insignificant activities b. Installation of control equipment c. Replacement of an emissions unit, and d. Changes that contravene a permit term

Unless another person is identified in the applicable Table, send all other submittals to:

AQ Compliance Tracking Coordinator Industrial Division Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, Minnesota 55155-4194

Or Email a signed and scanned PDF copy to: [email protected] (for submittals related to stack testing) [email protected] (for other compliance submittals) (See complete email instructions in “Routine Air Report Instructions Letter” at http://www.pca.state.mn.us/nwqh472.)

mailto:[email protected]


http://www.pca.state.mn.us/nwqh472


3. Facility description

The Sappi Cloquet LLC (Facility) is located at 2201 Avenue B in Cloquet, MN, Carlton County, Minnesota. Sappi Cloquet, LLC (Sappi) is an existing pulp and paper mill which manufactures kraft paper pulp, specialized cellulose pulp (SC), and fine coated paper. The pulp-making procedure starts with wood being delivered onsite, debarked, and chipped. The wood chips are then fed into ten batch digesters where they are cooked with white liquor and steam. Exhaust gases from the digestion process are collected by the non-condensable gas systems (NCG), which consist of VOCs and odorous total reduced sulfur compounds (TRS) including hydrogen sulfide, methyl mercaptan, dimethyl sulfide, and dimethyl disulfide. The NCGs are vented to and controlled by the Incinerator-Quencher-Scrubber (IQS) system. The incinerator thermally oxidizes VOC, HAP, and TRS compounds from the gas stream to produce carbon dioxide (CO2), sulfur dioxide (SO2), and water vapor. The scrubber portion of the IQS controls SO2. After being discharged from the digesters the spent cooking liquor and pulp must be separated. The pulp is sent on to be washed, bleached, dried, sheeted. The spent cooking liquor and pulp wash water are combined to make weak black liquor solids (BLS). The weak BLS are concentrated in evaporators to make strong BLS, which can then be combusted in the recovery boiler. NCGs from the evaporators are vented to the IQS. In the recovery boiler, the organic portion of the BLS is burned and provides steam for electricity or heat for other processes at the plant. The cooking chemicals collect as molten smelt at the bottom of the boiler. The recovery boiler is a primary source of all criteria pollutant emissions, as well as sulfuric acid (H2SO4), TRS, and Hazardous Air Pollutants (HAPs). Particulate matter emissions from the recovery boiler are controlled by a high-efficiency electrostatic precipitator (ESP). The smelt from the recovery boiler is collected and dissolved in process water in the smelt dissolving tank (SDT) to make green liquor which is a mixture of sodium carbonate and sodium sulfide. The SDT emits particulate matter, sulfur dioxide (SO2), volatile organic compounds (VOC), TRS, and HAPs. Emissions from the SDT are controlled by a Spray Tower and a Venti-Rod Scrubber operated in series. The green liquor is then fed to the causticizers with slaked lime which reacts to produce white liquor. The white liquor is then returned to the fiberline to produce more pulp. Calcium carbonate (lime mud) is the byproduct of this reaction. The lime mud is sent to the Lime Kiln where it undergoes a calcination reaction to reproduce lime (CaO) and CO2 . The lime kiln is a source of all criteria pollutants, in addition to H2 SO4 , TRS, and HAPs. Particulate matter emissions are controlled by a high-efficiency ESP. Other major sources of emissions are from the three power boilers #7, #8, and #9. Boilers #7 and #9 are permitted to burn distillate oil, natural gas, wood waste, and sludge, and are also used as backup controls for NCGs. Particulate matter emissions from boiler #7 and #9 are controlled by multiclones and high-efficiency ESPs at each boiler. Power boiler #8 combusts natural gas and distillate oil. All three boilers are used to produce steam for electrical generation for use on site and for process heat. Other emission sources include the bleach plant, paper machines #4 and #12, a coater, a market pulp machine, an emergency generator, a fire pump, a cooling tower, a research and development (R&D) boiler, and fugitive particulate matter sources such as dust from wood piles, paved and unpaved roads, track-out, a fuel yard, ash handling, and a landfill. The bleach plant consists of a chlorine dioxide plant and a bleach line. Chlorine dioxide emissions from the bleach plant and chlorine dioxide plant are controlled by a gas scrubber and a packed tower scrubber; the bleaching system is also a significant source of carbon monoxide (CO) and VOC emissions.


Permit 01700002 014 The Permittee was seeking to modify the pulp mill to manufacture chemical cellulose pulp (CCP), also known as dissolving pulp. The only pollutant subject to PSD review was ozone which was subject to Prevention of Significant Deterioration (PSD) requirements at any increase greater than zero. The project consisted of the installation of a new ozone bleaching system. The specific changes related to the project included the following: Upgrade to the wood room. Installation of two additional digesters. This was necessary because of the lower yield and longer cook time needed during production of CCP compared to Kraft pulp. Increase in the production of Black Liquor Solids (BLS) and an increase in the utilization of the Recovery Boiler. The annual throughput limit of 904,200 tons of BLS was maintained. Increase in utilization of the Smelt Dissolving Tank and Lime Kiln. Addition of an ozone stage to the existing Bleach Plant. This resulted in a small actual decrease in VOC emissions, and an increase in ozone emissions. Market Pulp Machine (MPM) forming and press sections needed to be modified to accommodate the physical characteristics of CCP. Increase in weak black liquor production and a corresponding increase in the throughput of the evaporators, and thus the IQS, and a possible increase in concentrations of organics and reduced sulfur compounds in the feed streams, which resulted in a corresponding decrease in natural gas combustion. Increase in steam usage at the digesters, evaporator, bleach plant, and market pulp machine. With the increase in black liquor solids produced, it was expected that the recovery boiler would be able to provide the necessary steam for the changes identified. Two percent increase in paper production at the paper machines and coater on an annual basis. Changes to the truck traffic and routes. Permit 01700002 015 Sappi proposed to increase the daily permitted capacity of the Lime Kiln from 440 ton Calcium Oxide (CaO) per day to 500 ton CaO per day and the annual permitted throughput limit from 146,000 ton CaO per year to 175,000 ton CaO per year. The project is a major modification under PSD for particulate matter smaller than 10 microns in size (PM10) and particulate matter smaller than 2.5 microns in size (PM2.5) emissions. As part of the PSD permitting process, Sappi underwent a Best Available Control Technology (BACT) analysis and determined that the existing Electrostatic Precipitator is BACT for PM10 and PM2.5 emissions. Sappi also proposed to install a low Nitrogen Oxides (NOx) burner on the Lime Kiln. The Lime Kiln has existing emission limits of 11.8 pounds per hour (lb/hr) for particulate matter (PM) and PM10 and 11.1 lb/hr for PM2.5. This permit action increased these emission limits to 13.6 lb/hr for PM and PM10 and 12.8 lb/hr for PM2.5. Sappi proposed to reduce the NOx emission limit from 62.2 lb/hr to 38.9 lb/hr, and to establish a new NOx limit of 120 ppmvd at 10% O2. The low NOx burner will reduce emissions to avoid a major modification under PSD for NOx emissions. Currently, the there is a physical constraint on the amount of lime mud that can be sent to the Lime Kiln on a daily basis. To increase the capacity to the desired 500 ton CaO/day, Sappi will modify the Lime Kiln to handle the increased throughput. This permit authorizes modification of the Lime Kiln. Permit 01700002-101 This permit action authorizes construction of a Chip Pre-Steaming Bin (EQUI 316) prior to the digesters. The chip bin will help increase annual pulp production by reducing chip fill times and improving digester cycle times by pre-steaming the chips. The addition of the Chip Bin is one of several changes Sappi will make towards the overall goal of being able to produce 100% SC pulp at the annual capacity of the plant. Currently the pulp production rate for SC pulp (which results in more BLS than kraft pulp) is limited by the BLS throughput rate. A recent engineering analysis of the recovery boiler concluded that the maximum capacity of the boiler was 1,027,475 tons BLS per year (5.63 million pounds BLS per day), in contrast to the current permitted-limited capacity of 904,200 ton BLS per year (4.95 million pounds BLS per day). If Sappi produces paper up to the increased capacity of the recovery boiler (assuming a ratio of 5,000 pounds BLS per ton of pulp) they will be able to produce 410,990 tons of pulp per year, up from 361,000 tons of pulp annually.


The increase in pulp production and BLS creation will result in increased utilization of other processes at the plant. The affected units are the bleach plant, the smelt dissolving tank, the lime kiln, the market pulp machine, the IQS system, and paved roads (from additional transport of wood chips). No utilization increase will be needed from the power boilers because the additional steam from the recovery boiler will be used to steam the chips in the chip bin and for the increase in steam demand for pulp production.


4. Summary of subject items

SI ID: Description

Relationship Type

Related SI ID: Description

ACTV19: All IAs COMG1: Fuel limits: #7, #8 and #9 Boilers

has members

EQUI2, EQUI4, EQUI18

COMG2: NCG System has members

EQUI15, EQUI17, EQUI20, EQUI24, EQUI28, EQUI49, EQUI204, EQUI295, EQUI296, EQUI297, EQUI300, EQUI303, EQUI305, EQUI306, EQUI307, EQUI308, EQUI309, EQUI310, EQUI312, EQUI313, EQUI314, STRU30, STRU40, STRU41, TREA30, TREA31

COMG3: Process Condensates

has members

EQUI15, EQUI17, EQUI20, EQUI24, EQUI28, EQUI204, EQUI295, EQUI296, EQUI297, EQUI300, EQUI303, EQUI305, EQUI306, EQUI307, EQUI308, EQUI309, EQUI310, EQUI312,

SI ID: Description

Relationship Type

Related SI ID: Description EQUI313, EQUI314

COMG7: 40 CFR pt. 63, subp. DDDDD Requirements

has members

EQUI2, EQUI4, EQUI18, EQUI290

EQUI107: Power Boiler #9 - CO

sends to EQUI63: RegPerfect

EQUI108: Rotary Lime Kiln - Opacity


EQUI109: RB #10 - SDT - Scrubber Flow

sends to EQUI65: Process Information System

EQUI110: RB#10 CO2 EQUI112: Power Boiler #8 - NOx

EQUI113: Recovery Boiler #10 - Opacity


EQUI114: Recovery Boiler #10 - NOx


EQUI115: Recovery Boiler #10 - SO2


EQUI116: Recovery Boiler #10 - TRS


EQUI117: Recovery Boiler #10 - CO


EQUI118: Recovery Boiler #10 - O2


EQUI119: Power Boiler #7 - SO2


EQUI120: Rotary Lime Kiln - TRS


EQUI121: Rotary Lime Kiln - O2


EQUI122: Power Boiler #7 - O2




EQUI127: RB #10 - SDT - Pressure Drop


EQUI129: Bleach Plant - sends to EQUI65:


SI ID: Description

Relationship Type


pH Process Information System

EQUI130: Bleach Plant - Flow


EQUI131: Bleach Plant - Fan


EQUI132: ClO2 Plant - Flow


EQUI133: IQS - Temp sends to EQUI65: Process Information System

EQUI134: IQS - Flow sends to EQUI65: Process Information System

EQUI135: Power Boiler #7 - Opacity




EQUI137: Power Boiler #9 - NOx



EQUI15: Digester Relief sends to STRU30: Incinerator Quencher Scrubber

EQUI15: Digester Relief sends to STRU40: Power Boiler #7

EQUI15: Digester Relief sends to STRU41: Power Boiler #9

EQUI15: Digester Relief is controlled by

TREA30: Incinerator for TRS on IQS

EQUI15: Digester Relief is controlled by

TREA31: SO2 Scrubber for IQS

EQUI17: Condensate sends to STRU30:

SI ID: Description

Relationship Type


Stripper Incinerator Quencher Scrubber

EQUI17: Condensate Stripper

sends to STRU40: Power Boiler #7




is controlled by



is controlled by


EQUI18: Power Boiler #8 is monitored by


EQUI18: Power Boiler #8 is monitored by


EQUI18: Power Boiler #8 sends to EQUI63: RegPerfect

EQUI18: Power Boiler #8 sends to STRU28: Power Boiler #8

EQUI204: Black Liquor / 155000 / EU047

is controlled by



is controlled by


EQUI20: Brownstock Washers

sends to STRU30: Incinerator Quencher Scrubber






is controlled by



is controlled by


EQUI23: Black Liquor Tanks (Washers)

sends to STRU30: Incinerator Quencher


SI ID: Description

Relationship Type

Related SI ID: Description Scrubber






is controlled by



is controlled by


EQUI24: Digester Air Evacuation







is controlled by



is controlled by


EQUI261: Methanol / 14600 / EU017

EQUI28: Recovery Boiler #10 - Salt-Cake Mix Tank







is controlled by



is controlled by


EQUI290: R&D Boiler sends to STRU37: R&D Boiler

EQUI291: Power Boiler #7 - Stack Flow

SI ID: Description

Relationship Type



EQUI293: Recovery Boiler #10 - Stack Flow

EQUI294: Digesters (10) is controlled by


EQUI294: Digesters (10) is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by


EQUI298: #4 Paper Machine

sends to STRU49: #4 Paper Machine

EQUI299: #12 Paper Machine

sends to STRU50: #12 Paper Machine

EQUI2: Power Boiler #7 (Spreader Stoker - Bark)

is monitored by



is monitored by



is monitored by



is monitored by


EQUI2: Power Boiler #7 is monitored EQUI291:


SI ID: Description

Relationship Type


(Spreader Stoker - Bark) by Power Boiler #7 - Stack Flow




sends to STRU27: Power Boiler #7 Bypass




is controlled by

TREA11: Power Boiler #7 - Multiclones


is controlled by

TREA15: Power Boiler #7 ESP

EQUI300: Evaporator Vacuum







is controlled by



is controlled by


EQUI301: Chlorine Dioxide Plant

is monitored by

EQUI132: ClO2 Plant - Flow




sends to STRU43: Chlorine Dioxide Plant


is controlled by

TREA16: ClO2 Plant Scrubber

EQUI302: 140' Clarifier (covered)

sends to STRU29: IA stack (140' Clarifier)

EQUI303: Oxygen Delignification System


SI ID: Description

Relationship Type







is controlled by



is controlled by


EQUI304: #13 Coater sends to STRU51: #13 Off-Machine Coater

EQUI305: Turpentine System







is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



SI ID: Description

Relationship Type



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by



is controlled by


EQUI315: Emergency Diesel Fire Water Pump

sends to STRU60: Emergency Fire Pump Stack

EQUI316: Chip Presteaming Bin

sends to STRU59: Chip Presteaming Bin Stack


is controlled by


EQUI317: Black Liquor / is controlled TREA31: SO2

SI ID: Description

Relationship Type


315000 / EU045 by Scrubber for IQS

EQUI38: I&I Emergency Generator

sends to STRU31: I&I Emergency Generator

EQUI42: Ozone bleaching system

sends to STRU44: Bleach Plant

EQUI49: IQS - Incinerator is monitored by

EQUI133: IQS - Temp


EQUI134: IQS - Flow

EQUI49: IQS - Incinerator sends to EQUI65: Process Information System


EQUI72: IQS - pH

EQUI49: IQS - Incinerator sends to STRU30: Incinerator Quencher Scrubber

EQUI49: IQS - Incinerator sends to STRU40: Power Boiler #7

EQUI49: IQS - Incinerator sends to STRU41: Power Boiler #9

EQUI49: IQS - Incinerator is controlled by


EQUI49: IQS - Incinerator is controlled by


EQUI4: Power Boiler #9 (Bark)

is monitored by



is monitored by



is monitored by



is monitored by





SI ID: Description

Relationship Type



is monitored by



is monitored by





is controlled by



is controlled by


EQUI50: Market Pulp Machine - Pressing Equipment

EQUI51: Smelt Dissolving Tank for RB #10

is monitored by

EQUI109: RB #10 - SDT - Scrubber Flow


is monitored by

EQUI127: RB #10 - SDT - Pressure Drop


is monitored by

EQUI70: RB #10 - SDT - Supply Pressure


is monitored by

EQUI77: RB #10 - SDT - VRS Pressure Drop


sends to STRU47: Smelt Dissolving Tank for RB#10


is controlled by

TREA12: Smelt Dissolving Tank - Spray Tower


is controlled by

TREA6: Recovery Boiler #10 - Ventri-Rod Scrubber

EQUI52: Rotary Lime Kiln - Kiln

is monitored by

EQUI108: Rotary Lime Kiln - Opacity


is monitored by

EQUI120: Rotary Lime Kiln - TRS


is monitored by

EQUI121: Rotary Lime Kiln - O2

SI ID: Description

Relationship Type





sends to STRU38: Lime Kiln


is controlled by

TREA21: Rotary Lime Kiln ESP

EQUI53: Recovery Boiler #10

is monitored by

EQUI110: RB#10 CO2


is monitored by

EQUI113: Recovery Boiler #10 - Opacity


is monitored by

EQUI114: Recovery Boiler #10 - NOx


is monitored by

EQUI115: Recovery Boiler #10 - SO2


is monitored by

EQUI116: Recovery Boiler #10 - TRS


is monitored by

EQUI117: Recovery Boiler #10 - CO


is monitored by

EQUI118: Recovery Boiler #10 - O2


is monitored by

EQUI293: Recovery Boiler #10 - Stack Flow




sends to STRU42: Recovery Boiler #10


is controlled by

TREA20: Recovery Boiler #10 ESP

EQUI63: RegPerfect EQUI65: Process Information System

EQUI70: RB #10 - SDT - Supply Pressure



SI ID: Description

Relationship Type




EQUI72: IQS - pH sends to EQUI65: Process Information System


EQUI77: RB #10 - SDT - VRS Pressure Drop

EQUI7: Bleach Plant is monitored by

EQUI129: Bleach Plant - pH


EQUI130: Bleach Plant - Flow


EQUI131: Bleach Plant - Fan

EQUI7: Bleach Plant sends to EQUI65: Process Information System

EQUI7: Bleach Plant sends to STRU44: Bleach Plant

FUGI11: Track-out FUGI2: Existing Cooling Tower - zFugative

FUGI3: Fuel Yard FUGI5: Landfill FUGI6: Paved Roads FUGI7: Unpaved Roads FUGI8: Fly Ash Handling FUGI9: Wood Chip Pile STRU10: Waste Treatment Office

STRU11: Building 10 - Clarifier Lift Station

STRU12: Building 159 - HD Storage and Pumphouse

STRU13: Building 156 - Turpentine Storage

STRU14: Building 129 -

SI ID: Description

Relationship Type


Construction Warehouse No. 3 STRU15: Building 153 - Evaporator Cooling Tower

STRU16: Building 168 - Peroxide Unloading Building

STRU17: Building 166 - New Bleach Plant

STRU18: Building 142 - Warehouse #3

STRU1: Causticizing Building

STRU20: Building 78 - Bleached Hardwood MD Tower

STRU21: OOS #10 Digester Blow Steam Acumulator Tk

STRU24: Building 30 - ClO2 Storage

STRU25: Building 31 - ClO2 Generator

STRU27: Power Boiler #7 Bypass

STRU28: Power Boiler #8 STRU29: IA stack (140' Clarifier)

STRU2: Building 62 - Old Chlorine Evap Building

STRU30: Incinerator Quencher Scrubber

STRU31: I&I Emergency Generator

STRU37: R&D Boiler STRU38: Lime Kiln STRU40: Power Boiler #7 STRU41: Power Boiler #9 STRU42: Recovery Boiler #10

STRU43: Chlorine Dioxide Plant

STRU44: Bleach Plant


SI ID: Description

Relationship Type


STRU47: Smelt Dissolving Tank for RB#10

STRU49: #4 Paper Machine

STRU4: Lime Kiln North Building

STRU50: #12 Paper Machine

STRU51: #13 Off-Machine Coater

STRU59: Chip Presteaming Bin Stack

STRU5: Building 162 - No. 4 Turbine Generator

STRU60: Emergency Fire Pump Stack

STRU6: Building 169 - Soap Skimmer

STRU7: PURR Offices STRU8: Heavy Liquor Pumphouse

STRU9: Lime Kiln South Building

TFAC6: Sappi Cloquet LLC TREA11: Power Boiler #7 - Multiclones

is controlled in series by



SI ID: Description

Relationship Type



TREA16: ClO2 Plant Scrubber

TREA17: Bleach Plant Scrubber





TREA20: Recovery Boiler #10 ESP

TREA21: Rotary Lime Kiln ESP





TREA6: Recovery Boiler #10 - Ventri-Rod Scrubber



TREA8: Catalytic Converter


5. Limits and other requirements

Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation TFAC 6 01700002 Sappi Cloquet

LLC

5.1.1 Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendix A: Insignificant Activities Required to be Listed, Appendix C: Road Segment Speed Limit and Silt Load Test Areas, Appendix D: Performance Test Recordkeeping Items and Testing Schedule, and Appendix E: Fugitive Control Plan. Modeling parameters in Appendices B: Stack Parameters Relied Upon in Modeling are included for reference only as described elsewhere in this permit. [Minn. R. 7007.0800, subp. 2]

5.1.2 Modeled Parameters for CO, NO2, PM, PM10, PM2.5, and SO2: The parameters used in PM and SO2 modeling completed in 1995, CO, NO2, and PM10 modeling completed in 2012, and PM2.5 modeling completed for permit number 01700002-015 are listed in Appendix B of this permit. The parameters describe the operation of the facility at maximum permitted capacity. The purpose of listing the parameters in the appendix is to provide a benchmark for future changes. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.3 Changes to Modeled Parameters for CO, NO2, PM, PM10, PM2.5, and SO2: Any permit amendment that affects any modeled parameter or emission rate for CO, NO2, PM, PM10, PM2.5, and SO2 listed in Appendix B must be a major amendment. Any addition to the information documented in Appendix B requires a major amendment. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.4 Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Required) for CO, NO2, PM, PM10, PM2.5, and SO2: Changes that affect any modeled parameter or emission rate listed in Appendix B, or an addition to the information documented in Appendix B, trigger the EBD Modeling Submittal requirement. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.5 EBD Modeling Submittal for CO, NO2, PM, PM10, PM2.5, and SO2: For changes meeting the criteria in the EBD Modeling Triggers (Modeling Required) requirement, the Permittee shall submit an EBD modeling submittal in accordance with the current version of the MPCA Air Dispersion Modeling Guidance and shall wait for written approval (in the form of an issued permit amendment) before making such changes. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

5.1.6 EBD Modeling Submittal Content for CO, NO2, PM, PM10, PM2.5, and SO2: The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats, and, if applicable, locations and dimensions of


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation nearby buildings. For non-stack/vent sources, this includes the source emission rate, location, size and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensions and adjacent building heights. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subps. 2&4, Minn. R. 7007.3000, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

5.1.7 Outdated EBD Baseline Modeling for CO, NO2, PM, PM10, PM2.5, and SO2: Prior to conducting the EBD analysis, the Permittee shall use the current version of the MPCA Air Dispersion Modeling Guidance to determine if the Baseline Modeling (the most recent refined modeling demonstration) is outdated. If the Baseline Modeling is outdated, the Permittee shall update the Baseline Modeling to be consistent with the current version of the MPCA Air Dispersion Modeling Guidance. The updated modeling will become the new Baseline Modeling. This requirement does not require the Permittee to complete a new refined modeling demonstration using the revisions made for the EBD demonstration. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subps. 2&4, Minn. R. 7007.3000, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

5.1.8 EBD Modeling Results for CO, NO2, PM, PM10, PM2.5, and SO2: The dispersion characteristics due to the revisions of the information in Appendix B must be equivalent to or better than the dispersion characteristics modeled September 25, 1995 (PM and SO2), March 5, 2012 (CO, NO2, and PM10 and 2017 (PM2.5). The Permittee shall demonstrate this equivalency in the proposal. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subp. 2&4, Minn. R. 7007.3000, Minn. R. 7009.0010-0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

5.1.9 Computer Dispersion Modeling Triggers for CO, NO2, PM, PM10, PM2.5, and SO2: The Permittee shall conduct a refined remodeling analysis in accordance with the Computer Dispersion Modeling requirements of this permit and the current version of the MPCA Air Dispersion Modeling Guidance if: (1) the results of the EBD modeling analysis do not demonstrate equivalent or better dispersion characteristics; (2) a conclusion cannot readily be made about the dispersion, or (3) the criteria in the EBD Modeling Triggers requirement are met and the Permittee has previously conducted three successive EBD analyses using the same Baseline Modeling. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

5.1.10 Computer Dispersion Modeling Protocol: due 180 days after receipt of written MPCA request for CO, NO2, PM, PM10, PM2.5,


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation and/or SO2 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. The protocol must be based on projected operating conditions under the next permit term. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. 9, Minn. Stat. 116.07, subds. 4a, Title I Condition: 40 CFR 52.21(k)]

5.1.11 Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the submitted protocol for CO, NO2, PM, PM10, PM2.5, and/or SO2 modeling. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

5.1.12 Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for CO, NO2, PM, PM10, PM2.5, and/or SO2. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. (4a), Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

5.1.13 All stacks listed in Appendix B must be vertical, with an unobstructed release point. No rain caps, rain hats, horizontal release, or tilted stacks are allowed. There are no exceptions to this. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.1.14 Inspection and Maintenance: Inspect the fencing and gates established for access control once per year. All repairs and maintenance to the fence and gates shall be completed as soon as possible but no later than 60 days after the Permittee observes the need for repair or maintenance or after the MPCA notifies the Permittee of the need for repair or maintenance. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.1.15 Access Control: All gates installed at access points shall be kept closed unless: 1. A guard is present controlling access at a gate; or 2. Authorized persons are entering or leaving the property through a gate. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.1.16 PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation Subject to the limitations of Minn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements prior to or at the time of permit issuance. [Minn. R. 7007.1800, (A)(1)-(2), Minn. R. 7007.1800, C(2)]

5.1.17 Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and recordkeeping specified in the control plan in Appendix E. The Plan shall describe methods that the Permittee will use to control fugitive emissions from the property, including from paved and unpaved roads and from the Sappi Industrial Solid Waste landfill. The plan may be amended by the Permittee as needed, and the most recent version shall be maintained on site. If the Commissioner determines the Permittee is out of compliance with Minn. R. 7011.0150, this requirement, or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner. [Minn. R. 7007.0100, Minn. R. 7007.0800, subp. 2, Minn. R. 7009.0020, Minn. R. 7011.0150, Minn. Stat. 116.07, subd. 4a]

5.1.18 Visual Inspection Training: The Permittee shall provide annual training to its employees that are directly involved in the loading operations for the coating department and pulp mill lime silos and ash silo. The training shall include instructions on procedures for making visual inspections of the silos, including transport lines. The person making the inspection shall be trained to look for accumulation of dust or particulate matter, as well as excess emissions or high opacity from the loading operations. The employees shall be trained on procedures to be followed if there are any problems observed from such things as line ruptures or spills which may result in dust accumulations or high opacity. The Permittee shall retain records of the training given. [Minn. Stat. 116.07, subd. 4a, Minn. R. 7007.0800, subp. 2]

5.1.19 These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists that a proposed project, analyzed using the actual-to-projected-actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not be part of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is no RP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.21(r)(6)(vi)(b). Even though a particular modification is not subject to New Source


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation Review (NSR), or where there isn't a RP that a proposed project could result in a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R. 7007.1150 - 7007.1500. [Minn. R. 7007.0800, subp. 2, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.20 Preconstruction Documentation -- Before beginning actual construction on a project, the Permittee shall document the following: 1. Project description 2. Identification of any emission unit whose emissions of an NSR pollutant could be affected 3. Pre-change potential emissions of any affected existing emission unit, and the projected post-change potential emissions of any affected existing or new emission unit. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, including the baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the emission unit could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. The Permittee shall maintain records of this documentation. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7007.1200, subp. 4, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.21 The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using the ATPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actual and potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, for a period of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.22 The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ from the preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain: a. The name and ID number of the Facility, and the name and


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation telephone number of the Facility contact person. b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. [Minn. R. 7007.0800, subps. 4-5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

5.1.23 The Permittee shall submit a Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the protocol for PM10 and PM2.5 modeling that is required to be submitted by 9/13/2025. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

5.1.24 Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol for PM10 and PM2.5 that is required to be submitted by 9/13/2025. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

5.1.25 The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-7009.0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

5.1.26 Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R. 7011.0020]

5.1.27 Air Pollution Control Equipment: Operate all pollution control equipment required by the permit whenever the corresponding process equipment and emission units are operated. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2]

5.1.28 Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation the only) corrective actions to be taken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)]

5.1.29 The O&M Plan shall include information for the following control equipment: TREA 6, TREA11, TREA12, TREA15-21, TREA30, TREA31, and the IQS (EQUI49). At a minimum, the O&M Plan shall include, for each pollution control equipment: - The parameters to be monitored and the parameter ranges to be used; - Corrective action procedures to be followed to return the control equipment to within specified range(s); - Corrective action procedures to be followed in the event of a malfunction or breakdown; and - A description of inspection procedures to be followed; and records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 2]

5.1.30 Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R. 7019.1000, subp. 4]

5.1.31 Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. [Minn. R. 7011.0150]

5.1.32 Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R. 7030.0010-7030.0080]

5.1.33 Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). [Minn. R. 7007.0800, subp. 9(A)]

5.1.34 The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. [Minn. R. 7007.0800, subp. 16]

5.1.35 Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in this permit. [Minn. R. ch. 7017]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.1.36 Performance Test Notifications and Submittals

Performance Tests are due as outlined in this permit. Performance Test Notification (written): due 30 days before each Performance Tet Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R. 7017.2018. [Minn. R. 7017.2018, Minn. R. 7017.2030, subps. 1-4, Minn. R. 7017.2035, subps. 1-2]

5.1.37 Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7017.2025, subp. 3]

5.1.38 Monitoring Equipment Calibration - The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or 2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies, procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R. 7007.0800, subp. 4(D)]

5.1.39 Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R. 7007.0800, subp. 4(D)]

5.1.40 Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). [Minn. R.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 7007.0800, subp. 5(C)]

5.1.41 Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]

5.1.42 If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R. 7007.1200, subp. 4]

5.1.43 Recordkeeping: For each storage vessel as specified in 40 CFR 60.110b(a), the Permittee shall keep readily accessible records showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel. These records will be kept for the life of the source. [40 CFR 60.116b(a) and (b)]

5.1.44 Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. [Minn. R. 7019.1000, subp. 3]

5.1.45 Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R. 7019.1000, subp. 2]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.1.46 Notification of Deviations Endangering Human Health or the

Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R. 7019.1000, subp. 1]

5.1.47 Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R. 7019.1000, subp. 1]

5.1.48 Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new or amended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3. The preceding sentence does not apply if the effective date of the requirement is later than the date on which the permit is due to expire. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 - 7007.1500]

5.1.49 Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). The Permittee may apply for an administrative amendment to extend a test deadline in a permit up to 365 days if the agency finds that the extension is needed to allow the Permittee to test at worst case conditions as required by Minn. R. 7017.2025, subp. 2, provided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H). [Minn. R. 7007.1400, subp. 1(H)]

5.1.50 Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation form approved by the Commissioner. [Minn. R. 7019.3000-7019.3100]

5.1.51 Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005-7002.0095]

5.1.52 The Permittee is not required to submit a Risk Management Plan (RMP) under 40 CFR pt. 68; no regulated substances are present above the threshold quantity. Each owner or operator of a stationary source, at which a regulated substance is present above a threshold quantity in a process, shall design and implement an accidental release prevention program. An initial RMP must be submitted no later than the latest of the following dates: 1) June 21, 1999; 2) Three years after the date on which a regulated substance is first listed under 40 CFR Section 68.130; or 3) The date on which a regulated substance is first present above a threshold quantity in a process. A full update and resubmission of the RMP is required at least once every five years. The five-year anniversary date is reset whenever the Permittee fully updates and resubmits their RMP. If required, RMPs shall be submitted to the Risk Management Plan Reporting Center, P.O. Box 1515, Lanham-Seabrook, Maryland 20703-1515. RMP information may be obtained at http://www.epa.gov/swercepp or by calling 1-800-424-9346. [40 CFR pt. 68]

5.1.53 For changes that do not require a permit amendment: - The Permittee shall submit a Part 1 MACT application within 30 days of startup of any 112(j) affected source. The application shall meet the requirements of 40 CFR Section 63.53(a). - The Permittee shall submit a Part 2 MACT application within 90 days of startup of any 112(j) affected source. The application shall meet the requirements of 40 CFR Section 63.53(b). 112(j) affected source is defined in 40 CFR Section 63.51. [40 CFR 63.52(b)(1), 40 CFR 63.52(e)(1)]

5.1.54 This permit contains many of the requirements from 40 CFR pt. 63, subps. A, S, MM, JJJJ, and DDDDD. Some of the requirements may be paraphrased in this permit. If there is a conflict between a permit term and the regulation, then the regulation takes precedence. [Minn. R. 7007.0800, subp. 2]

5.1.55 At all times the Permittee shall operate and maintain the emission unit subject to the MACT standard and its associated air pollution control equipment in a manner consistent with good air pollution control practices for minimizing emissions to at least the levels required by all relevant standards.. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(e)(1)(i), Minn. R. 7011.7000]

5.1.56 Startup, Shutdown, and Malfunction (SSM) plan: Develop a written


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation plan as described in 40 CFR 63.6(e)(3) for each of the emission units subject to MACT standards that contains specific procedures for operating and maintaining the source during periods of SSM, and a program of corrective action for process malfunction and control systems used to comply with the standards. The SSM Plan must be located at the plant site and must be kept updated. When the SSM Plan is updated, the Permittee must keep all previous versions of the SSM Plan for a period of 5 years. The Permittee must submit the SSM Plan when required. In addition, the plan must include the following requirements: - Procedures to determine and record the cause of an operating parameter exceedance and the time the exceedance began and ended; - Corrective actions to be taken in the event of an operating parameter exceedance, to correct the malfunctioning process as quickly as practicable, including procedures for recording the actions taken to correct the exceedance. - A maintenance schedule for each control technique that is consistent with, but not limited to, the manufacturer's instructions and recommendations for routine and long-term maintenance; and - An inspection schedule for each CMS required under 40 CFR 63.864 to ensure, at least once in each 24-hour period, that each CMS is properly functioning. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(e)(3), 40 CFR 63.866(a), Minn. R. 7011.7000, Minn. R. 7011.7700]

5.1.57 Malfunctions must be corrected as soon as practicable after their occurrence. To the extent that an unexpected event arises during a startup, shutdown, or malfunction, the Permittee must comply by minimizing emissions during such a startup, shutdown, and malfunction event consistent with safety and good air pollution control practices. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(e)(1)(ii), Minn. R. 7011.7000]

5.1.58 The Permittee shall maintain files of all information required by this part in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. [40 CFR 63.10(b)(1), Minn. R. 7019.0100, subp. 2(B)]

5.1.59 The Permittee shall maintain, at a minimum, the following information in the files, as applicable to each standard: 1. The occurrence and duration of each startup, shutdown, or malfunction of operation; 2. The occurrence and duration of each malfunction of the air


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation pollution control equipment; 3. All maintenance performed on the pollution control equipment; 4. Actions taken during periods of startup, shutdown, and malfunction when such actions are different from the procedures specified in the affected source's SSM Plan. In this case, the Permittee shall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5. All information necessary to demonstrate conformance with the affected source's SSM Plan and actions taken in accordance with SSM Plan; 6. Each period during which a Continuous Monitoring System (CMS) is malfunctioning or inoperative; 7. All required measurements needed to demonstrate compliance with a relevant standard; 8. All results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9. All measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 10. All CMS calibration checks; 11. All adjustments and maintenance performed on CMS; 12. Any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 13. All documents supporting initial notifications and notifications of compliance status. [40 CFR 63.10(b)(2), Minn. R. 7019.0100, subp. 2(B)]

5.1.60 Startup, shutdown, and malfunction reports shall be submitted only if there is an occurrence of startup, shutdown, or malfunction during the reporting period and shall be delivered or postmarked by the 30th day following the end of each calendar half year. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.10(d)(5)(i), Minn. R. 7019.0100, subp. 2(B)]

5.1.61 If the Permittee deviates from the startup, shutdown, and malfunction plan (SSM Plan) the Permittee shall record the actions taken for that event and report such actions within 2 working days after commencing actions inconsistent with the plan, followed by a letter within 7 working days after the end of the event. The report must contain name, title, and signature of a responsible official who is certifying its accuracy, explaining the circumstances of the event, the reasons for not following the SSM Plan, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.10(d)(5)(ii), 40 CFR 63.6(e)(3)(iv), Minn. R. 7011.7000, Minn. R. 7019.0100, subp. 2(B)]

5.1.62 Prior to construction or reconstruction of an "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit. [40 CFR 63.5(b)(3), Minn. R.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 7011.7000]

5.1.63 MACT Requirements: This facility is subject to all pertinent requirements of the MACT, 40 CFR pt. 63, subp. S (NESHAPs from the Pulp and Paper Industry). [40 CFR pt. 63, subp. S, Minn. R. 7011.7700]

5.1.64 Standards for Enclosures and Closed-vent Systems: Each enclosure shall maintain negative pressure at each enclosure or hood opening as demonstrated by procedures specified in 40 CFR 63.457(e). Each enclosure or hood opening closed during the initial performance test specified in 40 CFR 63.457(a) shall be maintained in the same closed and sealed position as during the performance test at all times except when necessary to use the opening for sampling, inspection, maintenance, or repairs. Each component of the closed-vent system used to comply with 40 CFR Sections 63.443(c) and 63.445(b) that is operated at positive pressure and located prior to a control device shall be designed for and operated with no detectable leaks as indicated by an instrument reading of less than 500 ppm by volume above background, as measured by the procedures in 40 CFR 63.457(d). Each bypass line in the closed-vent system that could divert vent streams containing HAP to the atmosphere without meeting the emission limitations in 40 CFR Section 63.443 or 63.445 shall comply with either of the following requirements: 1. On each bypass line, the owner or operator shall install, calibrate, maintain and operate according to manufacturer's specifications, a flow indicator that provides a record of the presence of gas stream flow in the bypass line at least once every 15 minutes. The flow indicator shall be installed in the bypass line in such a way as to indicate flow in the bypass line; or 2. For bypass line valves that are not computer controlled, the owner or operator shall maintain the bypass line valve in the closed position with a car seal or a seal placed on the valve or closure mechanism in such a way that the valve or closure mechanism cannot be opened without breaking the seal. [40 CFR 63.450(b), Minn. R. 7011.7700]

5.1.65 Monitoring Requirements for Enclosure and Closed-vent Systems: 1. For each enclosure opening, a visual inspection of the closure mechanism specified in 40 CFR 63.450(b) shall be performed at least once every month to ensure the opening is maintained in the closed position and sealed. 2. Each closed-vent system required by 40 CFR 63.450(a) shall be visually inspected at least once every month with at least 21 days between inspections, and at other times as required by the Administrator. The visual inspection shall include inspection of ductwork, piping, enclosures and connections to covers for visible evidence of defects. 3. For positive pressure closed-vent systems or portions of closed-vent systems, demonstrate no detectable leaks as specified in 40 CFR 63.450(c) measured initially and annually by the procedures in


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 40 CFR 63.457(d). 4. Demonstrate initially and annually that each enclosure opening is maintained at negative pressure as specified in 40 CFR 63.457(e). 5. The valve or closure mechanism specified in 40 CFR 63.450(d)(2) shall be inspected at least once every month with at least 21 days between inspections, to ensure that the valve is maintained in the closed position and the emission point gas stream is not diverted through the bypass line. 6. If an inspection required by paragraphs 1 through 5 of this section identified visible defects in ductwork, piping or enclosure or connections to covers required by 40 CFR 63.450, or if an instrument reading of 500 ppm by volume or greater above background is measured, or if enclosure openings are not maintained at negative pressure, then the following corrective actions shall be taken as soon as practicable: i. A first effort to repair or correct the closed-vent system shall be made as soon as practicable but no later than 5 calendar days after the problem is identified. ii. The repair or corrective action shall be completed no later than 15 calendar days after the problem is identified. [40 CFR 63.453(k), Minn. R. 7011.7700]

5.1.66 Site-Specific Inspection Plan: The Permittee shall prepare and maintain a site-specific inspection plan for each applicable enclosure opening, closed-vent system, and closed collection system. The Plan shall include a drawing or schematic of the components of applicable affected equipment. The Permittee shall record the information described in 40 CFR 63.454(b) for each inspection. [40 CFR 63.454(b), Minn. R. 7011.7700]

5.1.67 The Permittee must maintain records of any occurrence when corrective action is required under 40 CFR 63.864(k)(1), and when a violation is noted under 40 CFR 63.864(k)(2). [40 CFR 63.866(b), Minn. R. 7011.7700]

5.1.68 In addition to the general records required by 40 CFR 63.10(b)(2), maintain records of the following information: - Records of dry virgin black liquor solids firing rates in units of tons/day for all recovery furnaces; - Records and documentation of supporting calculations for compliance determinations made under 40 CFR 63.865(a)-(d); - Records of monitoring parameter ranges established for each process unit. [40 CFR 63.866(c), Minn. R. 7011.7700]

5.1.69 The owner or operator of any affected source or process unit must submit the applicable notifications from 40 CFR pt. 63 subp. A, as specified in Table 1 of 40 CFR pt. 63 subp. MM. [40 CFR 63.867(a), Minn. R. 7011.7700]

5.1.70 Excess emissions report: submit a report quarterly if measured parameters meet any of the conditions specified in 40 CFR 63.864(k)(1) or (2). The report must contain the information specified in 40 CFR 63.10(c), as well as the number and duration of occurrences when the conditions in in 40 CFR 63.864(k)(1) or (2) were met or exceeded. Reporting excess emissions below the


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation violation thresholds of 40 CFR 63.864(k) does not constitute a violation of the applicable standard. When no exceedances of parameters have occurred, submit a semiannual report stating that no excess emissions occurred during the reporting period. Excess emissions and/or summary reports for the mill for requirements of subpart MM or subpart S may be combined into one report. [40 CFR 63.867(c), Minn. R. 7011.7700]

5.1.71 The Permittee shall not have engines that meet section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section 1068.30 in one location within the stationary source for more than 12 consecutive months. A location is any single site at a building, structure, facility, or installation. Any engine, or engines, that replaces an engine at a location and that is intended to perform the same or similar function as the engine it replaced will be included in calculating the consecutive time period. [40 CFR 1068.30]

5.1.72 For a nonroad engine that is excluded from any requirements of 40 CFR Part 1068 because it is a stationary engine, the Permittee may not move it or install it in any mobile equipment, except as allowed by the provisions of 40 CFR Part 1068. The Permittee may not circumvent or attempt to circumvent the residence-time requirements of Section (2)(iii) of the Nonroad Engine definition at 40 CFR Section 1068.30. [40 CFR 1068.101(b)(3)]

5.1.73 The Permittee shall keep records of all engines on-site that meet section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section 1068.30. This applies to nonroad engines that are owned by the Permittee, or rented and operated by the Permittee, or brought onsite and operated by a vendor or contractor. The records shall include the following: 1) Date that the nonroad engine is brought onsite 2) Date that the nonroad engine is taken offsite and/or moved to a different location. 3) Identification number. 4) Rated capacity of the nonroad engine. 5) The model year and date of manufacture (as defined by the applicable nonroad engine rule). 6) Which nonroad provision that the nonroad engine is certified under. 7) Rental company information. 8) Function of the nonroad engine (e.g. compressor, welder). 9) Location of the engine within the stationary source. 10) Statement that the nonroad engine has not been located in a single location for 12 consecutive months, and movement between locations has not been for purposes of circumvention of residence time requirements of section (2)(iii) under the definition of Nonroad Engine at 40 CFR Section 1068.30. [40 CFR 1068.30(nonrd engn)(1)(iii), Minn. R. 7007.0800, subps. 4-5]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.1.74 A nonroad engine ceases to be a nonroad engine and becomes a

new stationary engine if: 1. At any time, it meets the criteria specified in section (2)(iii) under the definition of Nonroad Engine in 40 CFR Section 1068.30. For example, a portable generator engine ceases to be a nonroad engine if it is used or will be used in a single specific location for 12 months or longer. If the Administrator or the Permitting authority determines that an engine will be or has been used in a single specific location for 12 months or longer, it ceased to be a nonroad engine when it was placed in that location. OR 2. It is otherwise regulated by a federal New Source Performance Standard promulgated under section 111 of the Clean Air Act (42 U.S.C. 7411). [40 CFR 1068.31(e)]

COMG 1 GP008 Fuel limits: #7,

#8 and #9 Boilers

5.2.1 All requirements under this subject item apply to EQUI 2 and EQUI 4 (Power Boilers #7 and #9) only, unless otherwise noted in the requirement below. See Subject Items EQUI 2, EQUI 4, and EQUI 18 for additional requirements. [Minn. R. 7007.0800, subp. 2]

5.2.2 Fuel burned: limited to following fuel types: wood (including railroad ties); mill waste (including knots and screen rejects, CDF (combustible derived fuel, which consists of office paper, cardboard, scrap pallets, scrap lumber, press trials prints, waste lap pulp or other non-food product wood-based wastes generated at the Cloquet mill), and bark, peat and/or sawdust used to clean up oil and chemical spills); fuel oil; natural gas; and wastewater treatment plant sludge. Non-condensible gas (NCG) is also burned in Power Boilers #7 and #9. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

5.2.3 Fuel Usage <= 500000 tons per year 12-month rolling sum, on a wet basis (WOOD AND MILL WASTE USAGE LIMIT). The wood and mill waste usage limit includes railroad ties, CDF, knots and screen rejects and bark, peat and/or sawdust used to soak up oil and chemical spills. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

5.2.4 Fuel Usage <= 4.0 million gallons per year 12-month rolling sum (#2 FUEL OIL USAGE LIMIT). The limit for #2 fuel oil is 4,000,000 gallons/year for a combined basis for #7, #8, and #9 boilers (EQUI2, EQUI18, and EQUI4) on a 12-month rolling sum basis. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

5.2.5 Sulfur Content of Fuel <= 0.05 percent by weight for #2 fuel oil.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.2.6 Fuel Usage <= 38220 tons per year 12-month rolling sum on a dry basis (WASTEWATER TREATMENT PLANT SLUDGE USAGE LIMIT). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.2.7 Vendor Certifications: For all fuel oil burned in Power Boiler #7 (EQUI2) and Power Boiler #9 (EQUI4), maintain oil vendor information on site that documents oil sulfur content in percent by weight, to verify that the fuel oil sulfur content limit of 0.05% is being met. Copies of the sulfur content certification or analysis shall be obtained from the vendor for each delivery of fuel oil and must give the sulfur content of the fuel oil. This information shall be maintained on site. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2)& Minn. R. 7007.3000]

5.2.8 Recordkeeping: By the 15th day of each month, record the wood and mill waste (including railroad ties, knots and screen rejects, bark, peat, and/or sawdust used to soak up oil and chemical spills) usage for the previous month, and the previous 12 months (12-month rolling sum). [Minn. R. 7007.0800, subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

5.2.9 Recordkeeping: By the 15th day of each month, record the fuel oil usage for the previous month and the previous 12 months (12-month rolling sum). [Minn. R. 7007.0800, subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

5.2.10 Recordkeeping: By the 15th day of each month, record the sludge usage for the previous month and the previous 12 months (12-month rolling sum). [Minn. R. 7007.0800, subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

COMG 2 GP003 NCG System 5.3.1 HAPs - Total <= 20 parts per million by volume, corrected to 10%

oxygen on a dry basis. [40 CFR 63.443(a)(1)(i), 40 CFR 63.443(d)(2), Minn. R. 7011.7700]

5.3.2 HAP Control: Gases from the LVHC, HVLC, and Stripper Off Gas systems shall be combusted in the Incinerator-Quencher-Scrubber (IQS), or Boiler #7 or #9 as backup. When gases are burned in the IQS, the Total HAPs limit applies, and the temperature of the IQS is to be monitored as described under TREA 30 (Incinerator for TRS on IQS). When the gases are burned in the backup (Boilers #7 or #9), the HAP emission stream shall be introduced with the primary fuel or into the flame zone. [40 CFR 63.443(a)(1)(i), 40 CFR 63.443(d)(2), Minn. R. 7011.7700]

5.3.3 Enclosures and Venting: All equipment listed in this group shall be enclosed and vented into a closed-vent system meeting the requirements specified in 40 CFR Section 63.450 and as described


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation in the Total Facility subject item. [40 CFR 63.443(c), 40 CFR 63.450, Minn. R. 7011.7700]

5.3.4 TRS Control: Gases from the NCG sources shall be combusted in the IQS (EQUI49), or power boilers #7 and #9 as backup, and shall be subjected to a minimum temperature of 1200 degrees Fahrenheit for at least 0.5 second. This requirement always applies, but is generally less stringent than the MACT requirement (40 CFR 63.443) which also applies. [40 CFR 60.283(a)(1)(iii), Minn. R. 7007.0800, subp. 2, Minn. R. 7011.2450]

5.3.5 The Permittee is not subject to 40 CFR Section 60.284(b)(1) or 40 CFR Section 60.284(d)(3)(ii) and is protected by the permit shield provision of Minn. R. 7007.1800 from any expectation to comply with these requirements. The requirement to continuously monitor and record the combustion temperature in the power boilers does not apply since #7 and #9 power boilers (EQUI2 and EQUI4) used to combust the NCG gases are not incinerators, because according to the fourth revision to NSPS Subpart BB, EPA "...deletes the requirement to monitor the combustion (51 FR 18538) temperature in lime kilns, power boilers, or recovery furnaces." In addition, since continuous monitoring is not required, the facility is not required to submit semi-annual excess emissions reports to EPA for periods in excess of 5 minutes and their duration which the combustion temperature at the point of incineration is less than 1200 degrees Fahrenheit. [40 CFR 60.284(b)(1), 40 CFR 60.284(d)(3)(ii), Minn. R. 7007.1800(A)(2), Minn. R. 7011.2450]

COMG 3 GP004 Process

Condensates

5.4.1 Pulping Process Condensates: Pulping process condensates as listed in 40 CFR Section 63.446(b) shall be conveyed in a closed collection system that is designed and operated to meet the requirements specified in 40 CFR Section 63.446(d)(1)-(2). [40 CFR 63.446(d), Minn. R. 7011.7700]

5.4.2 HAPs - Total >= 11.1 pounds per ton of ODP of pulping process condensates from equipment systems listed in 40 CFR Section 63.446(b)(1)-(b)(5) shall be collected. [40 CFR 63.446(c)(3), Minn. R. 7011.7700]

5.4.3 The Permittee shall reduce HAPs - Total >= 92 percent by weight. The pulping process condensates shall be: - Treated to reduce or destroy the total HAPs by 92% or more by weight; or - Recycled to an equipment system specified in 40 CFR Section 63.442(a); or - Treated by removing 10.2 lbs/ton of ODP or achieving a total HAP concentration of 330 ppm or less by weight at the outlet of the control device. [40 CFR 63.446(e), Minn. R. 7011.7700]

5.4.4 Monitoring: Permittee shall install, calibrate, certify, operate, and maintain continuous monitoring systems as required by 40 CFR


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation Section 63.453. [40 CFR 63.453, Minn. R. 7011.7700]

COMG 7 GP015 40 CFR pt. 63,

subp. DDDDD Requirements

5.5.1 COMG 7 contains requirements from 40 CFR pt. 63, subp. DDDDD that apply to all the emission units subject to DDDDD: EQUI 2 (Power Boiler #7), EQUI 4 (Power Boiler #9), EQUI 18 (Power Boiler #8), and EQUI 290 (R&D Boiler). Further requirements that apply specifically to each boiler can be found at the EQUI level. [Minn. R. 7007.0800, subp. 2]

5.5.2 40 CFR pt. 63 General Provisions: 40 CFR pt. 63, subp. DDDDD, Table 10 shows which parts of the General Provisions in 40 CFR Sections 63.1-63.15 apply. [40 CFR 63.7565, Minn. R. 7011.7050]

5.5.3 At all times, the Permittee must operate and maintain any affected source (as defined in 40 CFR Section 63.7490), including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. [40 CFR 63.7500(a)(3), Minn. R. 7011.7050]

5.5.4 General Compliance Requirements. The Permittee must be in compliance with the emission limits, work practice standards, and operating limits in 40 CFR pt. 63, subp. DDDDD. These limits apply at all times the affected unit is operating, except during periods of startup and shutdown during which time the Permittee must comply only with 40 CFR pt. 63, subp. DDDDD, Table 3. [40 CFR 63.7500(f), 40 CFR 63.7505(a), Minn. R. 7011.7050]

5.5.5 General Compliance Requirements. The Permittee must demonstrate compliance with all applicable emission limits using performance stack testing, fuel analysis, or CMS, including a CEMS, COMS, CPMS, or PM CPMS, where applicable. The Permittee may demonstrate compliance with the applicable emission limit for HCl, mercury, or TSM using fuel analysis if the emission rate calculated according to 40 CFR Section 63.7530(c) is less than the applicable emission limit. (For gaseous fuels, the Permittee may not use fuel analyses to comply with the TSM alternative standard or the HCl standard.) Otherwise, the Permittee must demonstrate compliance for HCl, mercury, or TSM using performance testing, if subject to an applicable emission limit listed in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR 63.7505(c), Minn. R. 7011.7050]

5.5.6 General Compliance Requirements - Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with 40 CFR pt. 63, subp. DDDDD. Such concealment includes, but is not limited to:


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation - the use of diluents to achieve compliance with 40 CFR pt. 63, subp. DDDDD based on the concentration of a pollutant in the effluent discharged to the atmosphere; or - the use of gaseous diluents to achieve compliance with 40 CFR pt. 63, subp. DDDDD for visible emissions. [40 CFR 63.4(b), Minn. R. 7011.7000]

5.5.7 General Compliance Requirements. Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section 63.6(f)(2). The Permittee many use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section 63.6(f)(2)(iii). [40 CFR 63.6(f)(2), Minn. R. 7011.7000]

5.5.8 Finding of Compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with a non-opacity emission standard upon obtaining all the compliance information required by 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(f)(3), Minn. R. 7011.7000]

5.5.9 Finding of Compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with an opacity or visible emission standard upon obtaining all the compliance information required by 40 CFR pt. 63, subp. DDDDD and any information available needed to determine whether proper operation and maintenance practices are being used. [40 CFR 63.6(h)(8), Minn. R. 7011.7000]

5.5.10 If the Commissioner or the Administrator finds that the affected source is in compliance with all relevant standards for which initial performance tests were conducted, but during the time such performance tests were conducted fails to meet any relevant opacity emission standard, the Permittee may petition the Administrator to make appropriate adjustment to the opacity emission standard for the affected source. Until the Administrator notifies the Permittee, the relevant opacity emission standard remains applicable. [40 CFR 63.6(h)(9), Minn. R. 7011.7000]

5.5.11 The Permittee may establish the use of an alternative non-opacity emission standard by following the procedure specified in 40 CFR Section 63.6(g). [40 CFR 63.6(g), Minn. R. 7011.7000]

5.5.12 Methods for Determining Compliance. Compliance with opacity emission standards shall be determined by using the results from the COMS. [40 CFR 63.6(h)(2), Minn. R. 7011.7000]

5.5.13 The Administrator may grant an extension of compliance with an emission standard, as specified in 40 CFR Section 63.6(i). [40 CFR 63.6(i), Minn. R. 7011.7000]

5.5.14 Until an extension of compliance has been granted by the Administrator, the Permittee shall comply with all applicable requirements of 40 CFR pt. 63, subp. A. [40 CFR 63.6(i)(1), Minn. R. 7011.7000]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.5.15 The Permittee must meet the work practice standard according to

40 CFR pt. 63, subp. DDDDD, Table 3. During startup and shutdown, the Permittee must only follow the work practice standards according to 40 CFR pt. 63, subp. DDDDD, Table 3, Items 5 and 6. [40 CFR 63.7530(h), Minn. R. 7011.7050]

5.5.16 For each boiler that is required or that the Permittee elects to demonstrate compliance with any of the applicable emission limits in 40 CFR pt. 63, subp. DDDDD, Table 2 through performance testing, the initial compliance requirements include all the following: - Conduct performance tests according to 40 CFR Section 63.7520 and 40 CFR pt. 63, subp. DDDDD, Table 5. - Conduct a fuel analysis for each type of fuel burned in the boiler according to 40 CFR Section 63.7521 and 40 CFR pt. 63, subp. DDDDD, Table 6, except as specified in 40 CFR Section 63.7510(a)(2)(i)-(iii). - Establish operating limits according to 40 CFR Section 63.7530 and 40 CFR pt. 63, subp. DDDDD, Table 7. - Conduct CMS performance evaluations according to 40 CFR Section 63.7525. [40 CFR 63.7510(a), Minn. R. 7011.7050]

5.5.17 For existing affected sources (as defined in 40 CFR Section 63.7490) that have not operated between the effective date of 40 CFR pt. 63, subp. DDDDD and January 31, 2016, the Permittee must complete an initial tune-up by following the procedures described in 40 CFR Section 63.7540(a)(10)(i)-(vi) no later than 30 days after the re-start of the affected source and complete the one-time energy assessment specified in 40 CFR pt. 63, subp. DDDDD, Table 3, no later than the compliance date specified in 40 CFR Section 63.7495. [40 CFR 63.7510(j), Minn. R. 7011.7050]

5.5.18 Following the date on which the initial compliance demonstration is completed or is required to be completed under 40 CFR Sections 63.7 and 63.7510, whichever date comes first, operation above the established maximum or below the established minimum operating limits shall constitute a deviation of established operating limits listed in 40 CFR pt. 63, subp. DDDDD, Table 4 except during performance tests conducted to determine compliance with the emission limits or to establish new operating limits. Operating limits must be confirmed or reestablished during performance tests. [40 CFR 63.7540(a)(1), Minn. R. 7011.7050]

5.5.19 The Permittee must report each instance in which the Permittee did not meet each emission limit and operating limit in 40 CFR pt. 63, subp. DDDDD, Tables 2-4 that apply. These instances are deviations from the emission limits or operating limits, respectively, in 40 CFR pt. 63, subp. DDDDD. These deviations must be reported according to the requirements in 40 CFR Section 63.7550. [40 CFR 63.7540(b), Minn. R. 7011.7050]

5.5.20 The Permittee 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


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation operating limits for each boiler have not changed or provide documentation of revised operating limits established according to 40 CFR Section 63.7530 and 40 CFR pt. 63, subp. DDDDD, Table 7, as applicable. The reports for all subsequent performance tests must include all applicable information required in 40 CFR Section 63.7550. [40 CFR 63.7515(f), Minn. R. 7011.7050]

5.5.21 For affected sources that have not operated since the previous compliance demonstration and more than one year has passed since the previous compliance demonstration, you must complete the subsequent compliance demonstration, if subject to the emission limits in 40 CFR pt. 63, subp. DDDDD, Table 2, no later than 180 days after the re-start of the affected source and according to the applicable provisions in 40 CFR Section 63.7(a)(2) as cited in 40 CFR pt. 63, subp. DDDDD, Table 10. The Permittee must complete a subsequent tune-up by following the procedures described in 40 CFR Section 63.7540(a)(10)(i)-(vi) and the schedule described in 40 CFR Section 63.7540(a)(13) for units that are not operating at the time of their scheduled tune-up. [40 CFR 63.7515(g), Minn. R. 7011.7050]

5.5.22 The Permittee must conduct tune-ups of boilers demonstrate compliance as specified below: - As applicable, inspect the burner, and clean or replace any components of the burner as necessary (the Permittee may delay the burner inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months from the previous inspection. At units where entry into a piece of process equipment or into a storage vessel is required to complete the tune-up inspections, inspections are required only during planned entries into the storage vessel or process equipment; - Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available; - Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (the Permittee may delay the inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 36 months from the previous inspection; - Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any NOx requirement to which the unit is subject; - Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. [40 CFR 63.7540(a)(10)(i)-(v), Minn. R. 7011.7050]

5.5.23 Maintain on-site and submit, if requested by the Administrator, a


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation report containing the information below: - The concentrations of CO in the effluent stream in parts per million by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler; - A description of any corrective actions taken as a part of the tune-up; and - The type and amount of fuel used over the 12 months prior to the tune-up, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel used by each unit. [40 CFR 63.7540(a)(10)(vi), Minn. R. 7011.7050]

5.5.24 Stack Tests and Procedures. The Permittee must conduct all performance tests according to 40 CFR Section 63.7(c), (d), (f), and (h). The Permittee must also develop a Site-Specific Test Plan according to the requirements in 40 CFR Section 63.7(c). The Permittee shall conduct all performance tests under such conditions as the Administrator specifies based on the representative performance of each boiler for the period being tested. Upon request, the Permittee shall make available to the Administrator such records as may be necessary to determine the conditions of the performance tests. [40 CFR 63.7520(a), Minn. R. 7011.7050]

5.5.25 Stack Tests and Procedures. The Permittee must conduct each performance test according to the requirements in 40 CFR pt. 63, subp. DDDDD, Table 5. [40 CFR 63.7520(b), Minn. R. 7011.7050]

5.5.26 Stack Tests and Procedures. The Permittee must conduct each performance test under the specific conditions listed in 40 CFR pt. 63, subp. DDDDD, Tables 5 and 7. The Permittee 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 the Permittee 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, the Permittee must comply with the operating limit for operating load conditions specified in 40 CFR pt. 63, subp. DDDDD, Table 4. [40 CFR 63.7520(c), Minn. R. 7011.7050]

5.5.27 Stack Tests and Procedures. The Permittee must conduct a minimum of three separate test runs for each performance test required in 40 CFR Section 63.7520, as specified in 40 CFR Section 63.7(e)(3). Each test run must comply with the minimum applicable sampling times or volumes specified in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR 63.7520(d), Minn. R. 7011.7050]

5.5.28 Stack Tests and Procedures. To determine compliance with the emission limits, the Permittee must use the F-Factor methodology and equations in Sections 12.2 and 12.3 of EPA Reference Method 19 to convert the measured PM concentrations that result from the performance test to pounds per million Btu heat input


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation emission rates. [40 CFR 63.7520(e), Minn. R. 7011.7050]

5.5.29 Stack Tests and Procedures. Except for a 30-day rolling average based on CEMS data, if measurement results for any pollutant are reported as below the method detection level, the Permittee must use the method detection level as the measured emissions level for that pollutant in calculating compliance. The measured result for a multiple component analysis may include a combination of method detection level data and analytical data reported above the method detection level. [40 CFR 63.7520(f), Minn. R. 7011.7050]

5.5.30 Stack Tests and Procedures. To conduct a performance test for filterable PM, the Permittee must collect a minimum of 2 dry standard cubic meters of sample gas per run. [40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.5.31 Stack Tests and Procedures. To conduct a performance test for filterable PM, the Permittee must: - Select sampling ports location and the number of traverse points using Method 1 at 40 CFR pt. 60, Appendix A-1; - Determine velocity and volumetric flow-rate of the stack gas using Method 2, 2F, or 2G at 40 CFR pt. 60, Appendix A-1 or A-2; - Determine oxygen or carbon dioxide concentration of the stack gas using Method 3A or 3B at 40 CFR pt. 60, Appendix A-2, or ANSI/ASME PTC 19.10-1981; - Measure the moisture content of the stack gas using Method 4 at 40 CFR pt. 60, Appendix A-3; - Measure the PM emission concentration using Method 5 or 17 at 40 CFR pt. 60, Appendix A-3 or A-6; and - Convert emissions concentration to lb per MMBtu emission rates using Method 19 F-factor methodology at 40 CFR pt. 60, Appendix A-7. [40 CFR pt. 63, subp. DDDDD(Table 5), Minn. R. 7011.7050]

5.5.32 Site-Specific Test Plan. Before conducting a required performance test, the Permittee shall develop and, if requested by the Commissioner or the Administrator, shall submit a Site-Specific Test Plan for approval in accordance with the requirements of 40 CFR Section 63.7(c)(2). [40 CFR 63.7(c)(2), Minn. R. 7017.2015]

5.5.33 Site-Specific Test Plan. The Administrator will notify the Permittee of approval or intention to deny approval of the Site-Specific Test Plan (if review of the Site-Specific Test Plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days after receipt of any supplementary information. [40 CFR 63.7(c)(3), Minn. R. 7017.2015]

5.5.34 Performance Testing Facilities. The Permittee, at the request of the Commissioner or the Administrator, shall provide performance testing facilities as specified in 40 CFR Section 63.7(d). [40 CFR 63.7(d), Minn. R. 7017.2015]

5.5.35 Conduct of Performance Tests. Performance tests shall be conducted and data shall be reduced in accordance with the test methods and procedures set forth in 40 CFR Section 63.7(e), in 40 CFR pt. 63, subp. DDDDD, and, if required, in applicable


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation appendices of 40 CFR parts 51, 60, 61. The Commissioner has delegation to approve a minor or intermediate modification (if validated by Method 301) to a reference method or specified monitoring procedure as allowed for in 40 CFR Section 63.7(e)(2)(i) and (ii). [40 CFR 63.7(e)(2), Minn. R. 7017.2015]

5.5.36 Conduct of Performance Tests. Unless otherwise specified in 40 CFR pt. 63, subp. DDDDD or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specified in 40 CFR pt. 63, subp. DDDDD. For the purpose of determining compliance with 40 CFR pt. 63, subp. DDDDD, the arithmetic mean of the results of the three runs shall apply, unless otherwise approved in accordance with provisions of 40 CFR Section 63.7(e)(3). [40 CFR 63.7(e)(3), Minn. R. 7017.2015]

5.5.37 Data Analysis, Recordkeeping, and Reporting. Unless otherwise specified in 40 CFR pt. 63, subp. DDDDD or test method, or as otherwise approved by the Commissioner or Administrator in writing, results of a performance test shall include the analysis of samples, determination of emissions, and raw data. A performance test is "completed" when field sample collection is terminated. The Permittee shall report the results of the performance test to the Commissioner or Administrator before the close of business on the 60th day following the completion of the performance test, unless specified otherwise in 40 CFR pt. 63, subp. DDDDD or as approved otherwise in writing. The results of the performance test shall be submitted as part of the notification of compliance status required under 40 CFR Section 63.9(h) to the appropriate permitting authority. [40 CFR 63.7(g), Minn. R. 7017.2015]

5.5.38 Waiver of Performance Tests. Until a waiver of a performance testing requirement has been granted by the Commissioner or the Administrator under 40 CFR Section 63.7(h), the Permittee remains subject to the requirements of 40 CFR Section 63.7(h). [40 CFR 63.7(h), Minn. R. 7017.2015]

5.5.39 Conduct of Opacity or Visible Emission Observations. For initial compliance, opacity or visible emission observations shall be conducted concurrently with the initial performance test unless otherwise specified in 40 CFR Section 63.6(h)(5)(A) and (B). [40 CFR 63.6(h)(5), Minn. R. 7011.7000]

5.5.40 General Fuel Analysis Requirements. The Permittee must conduct fuel analyses for chloride and mercury according to the procedures in 40 CFR Section 63.7521(b)-(e) and 40 CFR pt. 63, subp. DDDDD, Table 6, as applicable. The Permittee is not required to conduct fuel analyses for fuels used for only startup, unit shutdown, and transient flame stability purposes. The Permittee is required to conduct fuel analyses only for fuels and units that are subject to emission limits for mercury or HCl in 40 CFR pt. 63, subp. DDDDD, Table 2. Gaseous and liquid fuels are exempt from the sampling requirements in 40 CFR Section 63.7521(c) and (d) and 40 CFR pt. 63, subp. DDDDD, Table 6. [40 CFR 63.7521(a), Minn. R. 7011.7050]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.5.41 Site-Specific Fuel Monitoring Plan. The Permittee must develop a

Site-Specific Fuel Monitoring Plan according to the procedures and requirements in 40 CFR Section 63.7521(b)(1) and (2). [40 CFR 63.7521(b), Minn. R. 7011.7050]

5.5.42 Site-Specific Fuel Monitoring Plan. If the Permittee intends to use an alternative analytical method other than those required by 40 CFR pt. 63, subp. DDDDD, Table 6, the Permittee must submit the fuel analysis plan to the Administrator for review and approval no later than 60 days before the date that the Permittee intends to conduct the initial compliance demonstration described in 40 CFR Section 63.7510. [40 CFR 63.7521(b)(1), Minn. R. 7011.7050]

5.5.43 Site-Specific Fuel Monitoring Plan. The Permittee must include the information below in the fuel analysis plan. - The identification of all fuel types anticipated to be burned in each boiler; - For each anticipated fuel type, the notification of whether the Permittee or a fuel supplier will be conducting the fuel analysis; - For each anticipated fuel type, a detailed description of the sample location and specific procedures to be used for collecting and preparing the composite samples if the procedures are different from 40 CFR Section 63.7521(c) or (d). Samples should be collected at a location that most accurately represents the fuel type, where possible, at a point prior to mixing with other dissimilar fuel types; - For each anticipated fuel type, the analytical methods from 40 CFR pt. 63, subp. DDDDD, Table 6, with the expected minimum detection levels, to be used for the measurement of chlorine or mercury; - If the Permittee requests to use an alternative analytical method other than those required by 40 CFR pt. 63, subp. DDDDD, Table 6, the Permittee must also include a detailed description of the methods and procedures that the Permittee is proposing to use. Methods in 40 CFR pt. 63, subp. DDDDD, Table 6 shall be used until the requested alternative is approved; and - If the Permittee will be using fuel analysis from a fuel supplier in lieu of site-specific sampling and analysis, the fuel supplier must use the analytical methods required by 40 CFR pt. 63, subp. DDDDD, Table 6. [40 CFR 63.7521(b)(2), Minn. R. 7011.7050]

5.5.44 Fuel Analysis Procedure. At a minimum, the Permittee must obtain three composite fuel samples for each fuel type according to the procedures in 40 CFR Section 63.7521(c)(1) or (2), or the methods listed in 40 CFR pt. 63, subp. DDDDD, Table 6, or use an automated sampling mechanism that provides representative composite fuel samples for each fuel type that includes both coarse and fine material. [40 CFR 63.7521(c), Minn. R. 7011.7050]

5.5.45 Fuel Analysis Procedure. If sampling from a belt (or screw) feeder, the Permittee must collect fuel samples according to the requirements below. - Stop the belt and withdraw a 6-inch wide sample from the full


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation cross-section of the stopped belt to obtain a minimum two pounds of sample. The Permittee must collect all the material (fines and coarse) in the full cross-section. The Permittee must transfer the sample to a clean plastic bag. - Each composite sample will consist of a minimum of three samples collected at approximately equal one-hour intervals during the testing period for sampling during performance stack testing. For monthly sampling, each composite sample shall be collected at approximately equal 10-day intervals during the month. [40 CFR 63.7521(c)(1), Minn. R. 7011.7050]

5.5.46 Fuel Analysis Procedure. If sampling from a fuel pile or truck, the Permittee must collect fuel samples according to the requirements below. - For each composite sample, the Permittee must select a minimum of five sampling locations uniformly spaced over the surface of the pile. - At each sampling site, the Permittee must dig into the pile to a uniform depth of approximately 18 inches. The Permittee must insert a clean shovel into the hole and withdraw a sample, making sure that large pieces do not fall off during sampling; use the same shovel to collect all samples. - The Permittee must transfer all samples to a clean plastic bag for further processing. [40 CFR 63.7521(c)(2), Minn. R. 7011.7050]

5.5.47 Fuel Analysis Procedure. The Permittee must prepare each composite sample according to the procedures below. - The Permittee must thoroughly mix and pour the entire composite sample over a clean plastic sheet; - The Permittee must break large sample pieces (e.g., larger than 3 inches) into smaller sizes; - The Permittee must make a pie shape with the entire composite sample and subdivide it into four equal parts; - The Permittee must separate one of the quarter samples as the first subset; - If this subset is too large for grinding, the Permittee must repeat the procedure in 40 CFR Section 63.7521(d)(3) with the quarter sample and obtain a one-quarter subset from this sample; - The Permittee must grind the sample in a mill; and - The Permittee must use the procedure in 40 CFR Section 63.7521(d)(3) to obtain a one-quarter subsample for analysis. If the quarter sample is too large, subdivide it further using the same procedure. [40 CFR 63.7521(d), Minn. R. 7011.7050]

5.5.48 Fuel Analysis Procedure. The Permittee must determine the concentration of pollutants in the fuel (mercury and/or chlorine) in units of pounds per million Btu of each composite sample for each fuel type according to the procedures in 40 CFR pt. 63, subp. DDDDD, Table 6, for use in Equations 7, 8, and 9 of 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.7521(e), Minn. R. 7011.7050]

5.5.49 Mercury Fuel Analysis. To conduct a fuel analysis for mercury, the Permittee must:


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation - Collect fuel samples using the procedure in 40 CFR Section 63.7521(c) or ASTM D5192, or ASTM D7430, or ASTM D6883, or ASTM D2234/D2234M (for coal) or EPA 1631 or EPA 1631E or ASTM D6323 (for solid), or EPA 821-R-01-013 (for liquid or solid), or ASTM D4177 (for liquid), or ASTM D4057 (for liquid), or equivalent; - Composite fuel samples using the procedure in 40 CFR Section 63.7521(d) or equivalent; - Prepare composited fuel samples using EPA SW-846-3050B (for solid samples), EPA SW-846-3020A (for liquid samples), ASTM D2013/D2013M (for coal), ASTM D5198 (for biomass), or EPA 3050 (for solid fuel), or EPA 821-R-01-013 (for liquid or solid), or equivalent; - Determine heat content of the fuel type using ASTM D5865 (for coal) or ASTM E711 (for biomass), or ASTM D5864 (for liquids and other solids), or ASTM D240 or equivalent; - Determine moisture content of the fuel type using ASTM D3173, ASTM E871, or ASTM D5864, or ASTM D240, or ASTM D95 (for liquid fuels), or ASTM D4006 (for liquid fuels), or ASTM D4177 (for liquid fuels) or ASTM D4057 (for liquid fuels), or equivalent; - Measure mercury concentration in fuel sample using ASTM D6722 (for coal), EPA SW-846-7471B (for solid samples), or EPA SW-846-7470A (for liquid samples), or equivalent; - Convert concentration into units of pounds of mercury per MMBtu of heat content using Equation 8 in 40 CFR Section63.7530; and - Calculate the mercury emission rate from the boiler in units of pounds per million Btu using Equations 10 and 12 in 40 CFR Section 63.7530. [40 CFR pt. 63, subp. DDDDD(Table 6), Minn. R. 7011.7050]

5.5.50 HCl Fuel Analysis. To conduct a fuel analysis for HCl, the Permittee must: - Collect fuel samples using the procedure in 40 CFR Section 63.7521(c) or ASTM D5192, or ASTM D7430, or ASTM D6883, or ASTM D2234/D2234M (for coal) or ASTM D6323 (for coal or biomass), ASTM D4177 (for liquid fuels) or ASTM D4057 (for liquid fuels), or equivalent; - Composite fuel samples using the procedure in 40 CFR Section 63.7521(d) or equivalent; - Prepare composited fuel samples using EPA SW-846-3050B (for solid samples), EPA SW-846-3020A (for liquid samples), ASTM D2013/D2013M (for coal), or ASTM D5198 (for biomass), or EPA 3050 or equivalent; - Determine heat content of the fuel type using ASTM D5865 (for coal) or ASTM E711 (for biomass), ASTM D5864, ASTM D240 or equivalent; - Determine moisture content of the fuel type using ASTM D3173 or ASTM E871, or D5864, or ASTM D240, or ASTM D95 (for liquid fuels), or ASTM D4006 (for liquid fuels), or ASTM D4177 (for liquid fuels) or ASTM D4057 (for liquid fuels) or equivalent;


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation - Measure chlorine concentration in fuel sample using EPA SW-846-9250, ASTM D6721, ASTM D4208 (for coal), or EPA SW-846-5050 or ASTM E776 (for solid fuel), or EPA SW-846-9056 or SW-846-9076 (for solids or liquids) or equivalent. - Convert concentrations into units of pounds of HCl per MMBtu of heat content using Equation 7 in 40 CFR Section 63.7530; and - Calculate the HCl emission rate from the boiler in units of pounds per million Btu using Equations 10 and 11 in 40 CFR Section 63.7530. [40 CFR pt. 63, subp. DDDDD(Table 6), Minn. R. 7011.7050]

5.5.51 General Compliance Requirements: If the Permittee demonstrates compliance with any applicable emission limit through performance testing and subsequent compliance with operating limits (including the use of CPMS), or with a CEMS, or COMS, the Permittee must develop a Site-Specific Monitoring Plan according to the requirements in 40 CFR Section 63.7505(d)(1)-(4) for the use of any CEMS, COMS, or CPMS. This requirement also applies if the Permittee petitions the EPA Administrator for alternative monitoring parameters under 40 CFR Section 63.8(f). [40 CFR 63.7505(d), Minn. R. 7011.7050]

5.5.52 Site-Specific Monitoring Plan. For each CMS required in 40 CFR Section 63.7505 (including CEMS, COMS, or CPMS), the Permittee must develop, and submit to the Administrator for approval upon request, a Site-Specific Monitoring Plan that addresses design, data collection, and the quality assurance and quality control elements outlined in 40 CFR Section 63.8(d) and the elements described below: - Installation of the CMS sampling probe or other interface at a measurement location relative to each affected process unit such that the measurement is representative of control of the exhaust emissions (e.g., on or downstream of the last control device); - Performance and equipment specifications for the sample interface, the pollutant concentration or parametric signal analyzer, and the data collection and reduction systems; and - Performance evaluation procedures and acceptance criteria (e.g., calibrations, accuracy audits, analytical drift). [40 CFR 63.7505(d)(1), Minn. R. 7011.7050]

5.5.53 Site-Specific Monitoring Plan. The Permittee must submit this Site-Specific Monitoring Plan, if requested, at least 60 days before the initial performance evaluation of the CMS. This requirement to develop and submit a Site-Specific Monitoring Plan does not apply to affected sources with existing CEMS or COMS operated according to the performance specifications under 40 CFR pt. 60, Appendix B and that meet the requirements of 40 CFR Section 63.7525. Using the process described in 40 CFR Section 63.8(f)(4), the Permittee may request approval of alternative monitoring system quality assurance and quality control procedures in place of those specified in 40 CFR Section 63.7505(d)(1) and, if approved, include the alternatives in the Site-Specific Monitoring Plan. [40 CFR 63.7505(d)(1), Minn. R. 7011.7050]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.5.54 Site-Specific Monitoring Plan. In the Site-Specific Monitoring Plan,

the Permittee must also address the items below: - Ongoing operation and maintenance procedures in accordance with the general requirements of 40 CFR Section 63.8(c)(1)(ii), (c)(3), and (c)(4)(ii); - Ongoing data quality assurance procedures in accordance with the general requirements of 40 CFR Section 63.8(d); and - Ongoing recordkeeping and reporting procedures in accordance with the general requirements of 40 CFR Section 63.10(c) (as applicable in 40 CFR pt. 63, subp. DDDDD, Table 10), (e)(1), and (e)(2)(i). [40 CFR 63.7505(d)(2), Minn. R. 7011.7050]

5.5.55 Site-Specific Monitoring Plan. The Permittee must conduct a performance evaluation of each CMS in accordance with the Site-Specific Monitoring Plan. [40 CFR 63.7505(d)(3), Minn. R. 7011.7050]

5.5.56 Site-Specific Monitoring Plan. The Permittee must operate and maintain the CMS in continuous operation according to the Site-Specific Monitoring Plan. [40 CFR 63.7505(d)(4), Minn. R. 7011.7050]

5.5.57 Monitoring Data. the Permittee must monitor and collect data according to 40 CFR Section 63.7535 and the Site-Specific Monitoring Plan required by 40 CFR Section 63.7505(d). [40 CFR 63.7535(a), Minn. R. 7011.7050]

5.5.58 Monitoring Data. The Permittee must operate the monitoring system and collect data at all required intervals at all times that each boiler is operating and compliance is required, except for periods of monitoring system malfunctions or out of control periods, and required monitoring system quality assurance or control activities, including, as applicable, calibration checks, required zero and span adjustments, and scheduled CMS maintenance as defined in the Site-Specific Monitoring Plan. A monitoring system malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring system to provide valid data. Monitoring system failures that are caused in part by poor maintenance or careless operation are not malfunctions. The Permittee is required to complete monitoring system repairs in response to monitoring system malfunctions or out-of-control periods and to return the monitoring system to operation as expeditiously as practicable. [40 CFR 63.7535(b), Minn. R. 7011.7050]

5.5.59 Monitoring Data. The Permittee may not use data recorded during monitoring system malfunctions or out-of-control periods, repairs associated with monitoring system malfunctions or out-of-control periods, or required monitoring system quality assurance or control activities in data averages and calculations used to report emissions or operating levels. The Permittee must record and make available upon request results of CMS performance audits and dates and duration of periods when the CMS is out of control to completion of the corrective actions necessary to return the


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation CMS to operation consistent with the Site-Specific Monitoring Plan. The Permittee must use all the data collected during all other periods in assessing compliance and the operation of the control device and associated control system. [40 CFR 63.7535(c), Minn. R. 7011.7050]

5.5.60 Monitoring Data. Except for periods of monitoring system malfunctions, repairs associated with monitoring system malfunctions, and required monitoring system quality assurance or quality control activities (including, as applicable, system accuracy audits, calibration checks, and required zero and span adjustments), failure to collect required data is a deviation of the monitoring requirements. In calculating monitoring results, do not use any data collected during periods when the monitoring system is out of control as specified in the Site-Specific Monitoring Plan, while conducting repairs associated with periods when the monitoring system is out of control, or while conducting required monitoring system quality assurance or quality control activities. The Permittee must calculate monitoring results using all other monitoring data collected while the process is operating. The Permittee must report all periods when the monitoring system is out of control in the annual report. [40 CFR 63.7535(d), Minn. R. 7011.7050]

5.5.61 Notification Requirements. The Permittee must meet the notification requirements in 40 CFR Section 63.7545 according to the schedule in 40 CFR Section 63.7545 and in 40 CFR pt. 63, subp. A. Some of the notifications must be submitted before the Permittee is required to comply with the emission limits and work practice standards in 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.7495(d), Minn. R. 7011.7050]

5.5.62 General Notifications. The Permittee must submit to the Administrator all of the notifications in 40 CFR Sections 63.7(b) and (c), 63.8(e), (f)(4) and (6), and 63.9(b)-(h) that apply by the dates specified. [40 CFR 63.7545(a), Minn. R. 7011.7050]

5.5.63 Notification of Intent. The Permittee must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin. [40 CFR 63.7545(d), 40 CFR 63.9(e), Minn. R. 7011.7050, Minn. R. 7019.0100]

5.5.64 Notification of Solid Waste Combustion. If the Permittee intends to commence or recommence combustion of solid waste, the Permittee must provide 30 days prior notice of the date upon which the Permittee will commence or recommence combustion of solid waste. The notification must identify: - The name of the Permittee, the location of the source, the boiler(s) that will commence burning solid waste, and the date of the notice. - The currently applicable subcategories under 40 CFR pt. 63, subp. DDDDD. - The date on which the Permittee became subject to the currently applicable emission limits. - The date upon which the Permittee will commence combusting


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation solid waste. [40 CFR 63.7545(g), Minn. R. 7011.7050]

5.5.65 Notification of Fuel Switch or Physical Change. If the Permittee has switched fuels or made a physical change to the boiler and the fuel switch or physical change resulted in the applicability of a different subcategory, the Permittee must provide notice of the date upon which the Permittee switched fuels or made the physical change within 30 days of the switch/change. The notification must identify: - The name of the Permittee, the location of the source, the boiler(s) that have switched fuels, were physically changed, and the date of the notice; - The currently applicable subcategory under this subpart; and - The date upon which the fuel switch or physical change occurred. [40 CFR 63.7545(h), Minn. R. 7011.7050]

5.5.66 Notification of Performance Test. - The Permittee must notify the Commissioner and the Administrator of their intention to conduct a performance test at least 60 calendar days before the performance test is initially scheduled to begin. - In the event the Permittee is unable to conduct the performance test on the date specified due to unforeseeable circumstances, the Permittee must notify the Commissioner and the Administrator as soon as practicable and without delay prior to the scheduled performance test date and specify the date when the performance test is rescheduled. [40 CFR 63.7(b), Minn. R. 7017.2015]

5.5.67 Notification of Opacity or Visible Emission Observations. The Permittee shall notify the Commissioner and the Administrator in writing of the anticipated date for conducting opacity or visible emission observations in accordance with 40 CFR Section 63.9(f). [40 CFR 63.6(h)(4), Minn. R. 7011.7000]

5.5.68 Notification of Opacity or Visible Emission Observations. The Permittee shall notify the Commissioner and the Administrator in writing of the anticipated date for conducting opacity or visible emission observations. The notification shall be submitted with the notification of the performance test date, or if no performance test is required or visibility or other conditions prevent the opacity or visible emission observations from being conducted concurrently with the initial performance test. The Permittee shall deliver or postmark the notification not less than 30 days before the opacity or visible emission observations are scheduled to take place. [40 CFR 63.9(f), Minn. R. 7019.0100]

5.5.69 Change in Information Already Provided. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to the Commissioner and the Administrator in writing within 15 calendar days after the change. [40 CFR 63.9(j), Minn. R. 7019.0100]

5.5.70 Compliance Status Report Content. A compliance report must contain:


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation - Information required in 40 CFR Section 63.7550(c)(1)-(5); - If there are no deviations from any emission limitation (emission limit and operating limit) that applies and there are no deviations from the requirements for work practice standards in 40 CFR pt. 63, subp. DDDDD, Table 3 that apply, a statement that there were no deviations from the emission limitations and work practice standards during the reporting period. If there were no periods during which the CMSs, including CEMS, COMS, CPMS, were out-of-control as specified in 40 CFR Section 63.8(c)(7), a statement that there were no periods during which the CMSs were out-of-control during the reporting period; - If the Permittee has a deviation from any emission limitation (emission limit and operating limit) where the Permittee is not using a CMS to comply with that emission limit or operating limit, or a deviation from a work practice standard during the reporting period, the report must contain the information in 40 CFR Section 63.7550(d); and - If there were periods during which the CMSs, in including CEMS, COMS, CPMS, were out-of-control as specified in 40 CFR Section 63.8(c)(7), or otherwise not operating, the report must contain the information in 40 CFR Section 63.7550(e). [40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

5.5.71 Compliance Status Report Content. A compliance report must contain the following information: - Company and Facility name and address; - Process unit information, emissions limitations, and operating parameter limitations; - Date of report and beginning and ending dates of the reporting period; and - The total operating time during the reporting period. [40 CFR 63.7550(c)(5)(i)-(iv), Minn. R. 7011.7050]

5.5.72 Compliance Status Report Content. A compliance report must contain the monitoring equipment manufacturer(s) and model numbers and the date of the last CMS certification or audit. [40 CFR 63.7550(c)(5)(v), Minn. R. 7011.7050]

5.5.73 Compliance Status Report Content. A compliance report must contain the total fuel use by each individual boiler subject to an emission limit within the reporting period, including, but not limited to, a description of the fuel, whether the fuel has received a non-waste determination by the EPA or the basis for concluding that the fuel is not a waste, and the total fuel usage amount with units of measure. [40 CFR 63.7550(c)(5)(vi), Minn. R. 7011.7050]

5.5.74 Compliance Status Report Content. If the Permittee is conducting performance tests once every 3 years consistent with 40 CFR Section 63.7515(b) or (c), a compliance report must contain the date of the last 2 performance tests and a statement as to whether there have been any operational changes since the last performance test that could increase emissions. [40 CFR 63.7550(c)(5)(vii), Minn. R. 7011.7050]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.5.75 Compliance Status Report Content. A compliance report must

contain a statement indicating that the Permittee burned no new types of fuel in an individual boiler subject to an emission limit. Or, if the Permittee did burn a new type of fuel, the Permittee must submit the calculation of HCl emission rate using Equation 16 of 40 CFR Section 63.7530 that demonstrates that the source is still meeting the emission limit for HCl emissions and the calculation of mercury emission rate using Equation 17 of 40 CFR Section 63.7530 that demonstrates that the source is still meeting the emission limit for mercury emissions. [40 CFR 63.7550(c)(5)(viii), Minn. R. 7011.7550]

5.5.76 Compliance Status Report Content. If the Permittee wishes to burn a new type of fuel in an individual boiler subject to an emission limit and cannot demonstrate compliance with the maximum chlorine input operating limit using Equation 7 of 40 CFR Section 63.7530 or the maximum mercury input operating limit using Equation 8 of 40 CFR Section 63.7530, the Permittee must include in the Compliance Report a statement indicating the intent to conduct a new performance test within 60 days of starting to burn the new fuel. [40 CFR 63.7550(c)(5)(ix), Minn. R. 7011.7050]

5.5.77 Compliance Status Report Content. A compliance report must contain a summary of any monthly fuel analyses conducted to demonstrate compliance according to 40 CFR Sections 63.7521 and 63.7530 for individual boilers subject to emission limits, and any fuel specification analyses conducted according to 40 CFR Sections 63.7521(f) and 63.7530(g). [40 CFR 63.7550(c)(5)(x), Minn. R. 7011.7050]

5.5.78 Compliance Status Report Content. If there are no deviations from any emission limits or operating limits in 40 CFR pt. 63, subp. DDDDD that apply, a compliance report must contain a statement that there were no deviations from the emission limits or operating limits during the reporting period. [40 CFR 63.7550(c)(5)(xi), Minn. R. 7011.7050]

5.5.79 Compliance Status Report Content. If there were no deviations from the monitoring requirements including no periods during which the CMSs, including CEMS, COMS, and CPMS, were out of control as specified in 40 CFR Section 63.8(c)(7), a compliance report must contain a statement that there were no deviations and no periods during which the CMS were out of control during the reporting period. [40 CFR 63.7550(c)(5)(xii), Minn. R. 7011.7050]

5.5.80 Compliance Status Report Content. If a malfunction occurred during the reporting period, the compliance report must include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must also include a description of actions taken by the Permittee during a malfunction of a boiler or associated air pollution control device or CMS to minimize emissions in accordance with 40 CFR Section 63.7500(a)(3),


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation including actions taken to correct the malfunction. [40 CFR 63.7550(c)(5)(xiii), Minn. R. 7011.7050]

5.5.81 Compliance Status Report Content. A compliance report must contain the date of the most recent burner inspection if it was not done annually and was delayed until the next scheduled or unscheduled unit shutdown. [40 CFR 63.7550(c)(5)(xiv), Minn. R. 7011.7050]

5.5.82 Compliance Status Report Content. For each reporting period, the Compliance Reports must include all of the calculated 30 day rolling average values based on the daily CEMS and CPMS data. [40 CFR 63.7550(c)(5)(xvi), Minn. R. 7011.7050]

5.5.83 Compliance Status Report Content. A compliance report must contain a statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. [40 CFR 63.7550(c)(5)(xvii), Minn. R. 7011.7050]

5.5.84 Compliance Status Report Content. For each deviation from an emission limit or operating limit in 40 CFR pt. 63, subp. DDDDD that occurs at an individual boiler where the Permittee is not using a CMS to comply with that emission limit or operating limit, the Compliance Report must additionally contain the information required in 40 CFR Section 63.7550(d)(1)-(3). - A description of the deviation and which emission limit or operating limit from which the Permittee deviated; - Information on the number, duration, and cause of deviations (including unknown cause), as applicable, and the corrective action taken; and - If the deviation occurred during an annual performance test, provide the date the annual performance test was completed. [40 CFR 63.7550(d), Minn. R. 7011.7050]

5.5.85 Compliance Status Report Content. For each deviation from an emission limit, operating limit, and monitoring requirement in 40 CFR pt. 63, subp. DDDDD occurring at an individual boiler where the Permittee is using a CMS to comply with that emission limit or operating limit, the compliance report must additionally contain the information required in 40 CFR Section 63.7550(e)(1)-(9). This includes any deviations from the Site-Specific Monitoring Plan as required in 40 CFR Section 63.7505(d). - The date and time that each deviation started and stopped and description of the nature of the deviation; - The date and time that each CMS was inoperative, except for zero (low-level) and high-level checks; - The date, time, and duration that each CMS was out of control, including the information in 40 CFR Section 63.8(c)(8); - The date and time that each deviation started and stopped; - A summary of the total duration of the deviation during the reporting period and the total duration as a percent of the total source operating time during that reporting period; - A characterization of the total duration of the deviations during


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation the reporting period into those that are due to control equipment problems, process problems, other known causes, and other unknown causes; - A summary of the total duration of CMS's downtime during the reporting period and the total duration of CMS downtime as a percent of the total source operating time during that reporting period; - A brief description of the source for which there was a deviation; and - A description of any changes in CMSs, processes, or controls since the last reporting period for the source for which there was a deviation. [40 CFR 63.7550(e), Minn. R. 7011.7050]

5.5.86 Compliance Status Report Submittal. The Permittee must submit the Compliance Status Reports according to the procedures specified below. - Within 60 days after the date of completing each performance test as required by 40 CFR pt. 63, subp. DDDDD the Permittee must submit the results of the performance tests, including any associated fuel analyses, required by 40 CFR pt. 63, subp. DDDDD and the compliance reports required in 40 CFR Section 63.7550(b) to the EPA's WebFIRE database according to the methods in 40 CFR Section 63.7550(h)(1). - Within 60 days after the date of completing each CEMS performance evaluation test (defined in 40 CFR Section 63.2) the Permittee must submit the relative accuracy test audit (RATA) data to the EPA's Central Data Exchange according to the methods in 40 CFR Section 63.7550(h)(2). - The Permittee must submit all reports required by 40 CFR pt. 63, subp. DDDDD, Table 9 according to the methods in 40 CFR Section 63.7550(h)(3). [40 CFR 63.7550(h), Minn. R. 7011.7050]

5.5.87 Use of a COMS. - The Permittee required to use a COMS shall record the monitoring data produced during a performance test and shall furnish the Commissioner and the Administrator a written report of the monitoring results in accordance with the provisions of 40 CFR Section 63.10(e)(4). - The Permittee may submit, for compliance purposes, COMS data results produced during any performance test required under 40 CFR Section 63.7 in lieu of Method 9 data in accordance with the process specified in 40 CFR Section 63.6(h)(7). - COMS data shall be reduced to 6-minute averages over the duration of the mass emission performance test. - The Permittee is responsible for demonstrating that they have complied with the performance evaluation requirements of 40 CFR Section 63.8(e), that the COMS has been properly maintained, operated, and data quality-assured, as specified in 40 CFR Sections 63.8(c) and (d), and that the resulting data have not been altered in any way. [40 CFR 63.6(h)(7), Minn. R. 7011.7000]

5.5.88 General Reporting Requirements. The Permittee shall submit


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation reports to the Commissioner and shall send a copy of each report to the Administrator. [40 CFR 63.10(a), Minn. R. 7019.0100]

5.5.89 Progress Reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 40 CFR Section 63.6(i) shall submit such reports to the Commissioner and the Administrator by the dates specified in the written extension of compliance. [40 CFR 63.10(d)(4), Minn. R. 7019.0100]

5.5.90 Additional Reporting Requirements for Sources with Continuous Monitoring Systems. - When more than one CEMS is used to measure the emissions from one affected source, the Permittee shall report the results as required for each CEMS. - The Permittee shall furnish the Commissioner and the Administrator a copy of a written report of the results of the CMS performance evaluation simultaneously with the results of the performance test, unless otherwise specified in 40 CFR pt. 63, subp. DDDDD. The Permittee using a COMS to determine opacity compliance during any performance test shall furnish the Commissioner and the Administrator two or, upon request, three copies of a written report of the results of the COMS performance evaluation. The copies shall be furnished at least 15 calendar days before the performance test is conducted. [40 CFR 63.10(e)(1) and (2), Minn. R. 7019.0100]

5.5.91 Excess Emissions and Continuous Monitoring System Performance Report and Summary Report. Excess emissions and parameter monitoring exceedances are defined in 40 CFR pt. 63, subp. DDDDD. The Permittee shall submit an excess emissions and continuous monitoring system performance report and/or a summary report to the Commissioner and the Administrator semiannually, except when more frequent reporting is specifically required by 40 CFR pt. 63, subp. DDDDD or a reduction in frequency is approved pursuant to 40 CFR Section 63.10(e)(3). [40 CFR 63.10(e)(3)(i) - (iv), Minn. R. 7019.0100]

5.5.92 Summary Report. One summary report shall be submitted for the hazardous air pollutants monitored at each affected source (unless 40 CFR pt. 63, subp. DDDDD standard specifies that more than one summary report is required). The summary report shall be entitled "Summary Report - Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance" and shall contain the information specified in 40 CFR Section 63.10(e)(3)(vi). [40 CFR 63.10(e)(3)(vi), Minn. R. 7019.0100]

5.5.93 If the total duration of excess emissions or process or control system parameter exceedances for the reporting period is 1 percent or greater of the total operating time for the reporting period, or the total CMS downtime for the reporting period is 5 percent or greater of the total operating time for the reporting period, both the summary report and the excess emissions and continuous monitoring system performance report shall be submitted. [40 CFR 63.10(e)(3)(vii), Minn. R. 7019.0100]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.5.94 Reporting Continuous Opacity Monitoring System Data Produced

During a Performance Test. The Permittee shall record the monitoring data produced during a performance test and shall furnish the Commissioner and the Administrator a written report of the monitoring results. The report of COMS data shall be submitted simultaneously with the report of the performance test results. [40 CFR 63.10(e)(4), Minn. R. 7019.0100]

5.5.95 General Recordkeeping Requirements. Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Commissioner and the Administrator in accordance with the reporting requirements in 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.10(d)(1), Minn. R. 7019.0100]

5.5.96 Records to Keep. The Permittee must keep a copy of each notification and report submitted to comply with 40 CFR pt. 63, subp. DDDDD, including all documentation supporting any Initial Notification or Notification of Compliance Status or Compliance Status Reports submitted, according to the requirements in 40 CFR Section 63.10(b)(2)(xiv). [40 CFR 63.7555(a)(1), Minn. R. 7011.7050]

5.5.97 Records to Keep. The Permittee must keep records of performance tests, fuel analyses, or other compliance demonstrations and performance evaluations as required in 40 CFR Section 63.10(b)(2)(viii). [40 CFR 63.7555(a)(2), Minn. R. 7011.7050]

5.5.98 Records to Keep. For each CEMS, COMS, and CMS, the Permittee must keep the following records: - Records described in 40 CFR Section 63.10(b)(2)(vii)-(xi); - Monitoring data for COMS during a performance evaluation as required in 40 CFR Section 63.6(h)(7)(i) and (ii); - Previous (i.e., superseded) versions of the performance evaluation plan as required in 40 CFR Section 63.8(d)(3); - Requests for alternatives to relative accuracy test for CEMS as required in 40 CFR Section 63.8(f)(6)(i); and - Records of the date and time that each deviation started and stopped. [40 CFR 63.7555(b), Minn. R. 7011.7050]

5.5.99 Records to Keep. The Permittee must keep the records required in 40 CFR pt. 63, subp. DDDDD, Table 8 including records of all monitoring data and calculated averages for applicable operating limits, such as opacity and operating load, to show continuous compliance with each emission limit and operating limit that applies. [40 CFR 63.7555(c), Minn. R. 7011.7050]

5.5.100 Records to Keep. The Permittee must keep records of monthly fuel use including the type(s) of fuel and amount(s) used. [40 CFR 63.7555(d)(1), Minn. R. 7011.7050]

5.5.101 Records to Keep. If the Permittee combusts non-hazardous secondary materials that have been determined not to be solid waste pursuant to 40 CFR Section 241.3(b)(1) and (2), the Permittee must keep a record that documents how the secondary material meets each of the legitimacy criteria under 40 CFR Section 241.3(d)(1). If the Permittee combusts a fuel that has been


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation processed from a discarded non-hazardous secondary material pursuant to 40 CFR Section 241.3(b)(4), the Permittee must keep records as to how the operations that produced the fuel satisfy the definition of processing in 40 CFR Section 241.2. If the fuel received a non-waste determination pursuant to the petition process submitted under 40 CFR Section 241.3(c), the Permittee must keep a record that documents how the fuel satisfies the requirements of the petition process. For operating units that combust non-hazardous secondary materials as fuel per 40 CFR Section 241.4, the Permittee must keep records documenting that the material is listed as a non-waste under 40 CFR Section 241.4(a). Units exempt from the incinerator standards under Section 129(g)(1) of the Clean Air Act because they are qualifying facilities burning a homogeneous waste stream do not need to maintain the records described in 40 CFR Section 63.7555(d)(2). [40 CFR 63.7555(d)(2), Minn. R. 7011.7050]

5.5.102 Records to Keep. The Permittee must keep a copy of all calculations and supporting documentation of HCl emission rates, using Equation 16 of 40 CFR Section 63.7530, that were done to demonstrate compliance with the HCl emission limit. Supporting documentation should include results of any fuel analyses and basis for the estimates of HCl emission rates. The Permittee can use the results from one fuel analysis for multiple boilers provided they are all burning the same fuel type. However, the Permittee must calculate HCl emission rate for each boiler. [40 CFR 63.7555(d)(4), Minn. R. 7011.7050]

5.5.103 Records to Keep. The Permittee must keep a copy of all calculations and supporting documentation of mercury emission rates, using Equation 17 of 40 CFR Section 63.7530, that were done to demonstrate compliance with the mercury emission limit. Supporting documentation should include results of any fuel analyses and basis for the estimates of maximum mercury emission rates. The Permittee can use the results from one fuel analysis for multiple boilers provided they are all burning the same fuel type. However, the Permittee must calculate mercury emission rates for each boiler. [40 CFR 63.7555(d)(5), Minn. R. 7011.7050]

5.5.104 Records to Keep. If, consistent with 40 CFR Section 63.7515(b), the Permittee chooses to stack test less frequently than annually, the Permittee must keep a record that documents that the emissions in the previous stack test(s) were less than 75 percent of the applicable emission limit and document that there was no change in source operations including fuel composition and operation of air pollution control equipment that would cause emissions of the relevant pollutant to increase within the past year. [40 CFR 63.7555(d)(6), Minn. R. 7011.7050]

5.5.105 Records to Keep. The Permittee must keep records of the occurrence and duration of each malfunction of the boiler or of the associated air pollution control and monitoring equipment. [40 CFR 63.7555(d)(7), Minn. R. 7011.7050]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.5.106 Records to Keep. The Permittee must keep records of actions

taken during periods of malfunction to minimize emissions in accordance with the general duty to minimize emissions in 40 CFR Section 63.7500(a)(3), including corrective actions to restore the malfunctioning boiler, air pollution control, or monitoring equipment to its normal or usual manner of operation. [40 CFR 63.7555(d)(8), Minn. R. 7011.7050]

5.5.107 Records to Keep. The Permittee must maintain records of the calendar date, time, occurrence and duration of each startup and shutdown. [40 CFR 63.7555(d)(10), Minn. R. 7011.7050]

5.5.108 Records to Keep. The Permittee must maintain records of the type(s) and amount(s) of fuels used during each startup and shutdown. [40 CFR 63.7555(d)(11), Minn. R. 7011.7050]

5.5.109 Recordkeeping Requirements. The Permittee must keep records in accordance with 40 CFR Sections 63.7560 and 63.10(b)(1). [40 CFR 63.10(b)(1), 40 CFR 63.7560, Minn. R. 7011.7050, Minn. R. 7019.0100, subp. 2(B)]

5.5.110 Recordkeeping - Visible Emissions. The Permittee shall make available, upon request by the Commissioner or Administrator, such records to determine the conditions under which the visual observations were made and shall provide evidence indicating proof of current visible observer emission certification. [40 CFR 63.6(h)(6), Minn. R. 7011.7000]

5.5.111 Additional Recordkeeping Requirements for Sources with Continuous Monitoring Systems. The Permittee shall maintain records as specified within 40 CFR Section 63.10(c); including CMS measurements (including monitoring data recorded during breakdowns and out-of-control periods) and corrective actions. [40 CFR 63.10(c), Minn. R. 7019.0100]

EQUI 2 EU002 Power Boiler #7

(Spreader Stoker - Bark)

5.6.1 Particulate Matter <= 15.0 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.6.2 PM < 10 micron <= 21.0 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.6.3 PM < 2.5 micron <= 10.5 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.6.4 Front-half Particulate Matter <= 0.037 pounds per million Btu heat input (filterable PM). [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.6.5 Opacity <= 10 percent opacity 24-hour block average. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

5.6.6 Nitrogen Dioxide <= 90.0 pounds per hour 30-day rolling average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.6.7 Nitrogen Oxides <= 90.0 pounds per hour 1-hour average. [Title I

Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000] 5.6.8 Sulfur Dioxide <= 17.10 pounds per hour 1-hour average. This limit

does not apply when boiler is used as back-up incineration for NCG. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.6.9 Sulfur Dioxide <= 4.0 pounds per million Btu heat input 3-hour rolling average while burning solid fuels (such as coal and wood). [Minn. R. 7011.0510, subp. 1]

5.6.10 Sulfur Dioxide <= 2.0 pounds per million Btu heat input 3-hour rolling average basis when burning fuel oil. [Minn. R. 7011.0510, subp. 1]

5.6.11 Sulfur Dioxide: When fossil fuels are burned in any combination, the SO2 standard shall be determined by proration using the following formula: PS = [y(2.0)+z(4.0)] / (x+y+z) Where: x = % heat input from natural gas y = % heat input from oil z = % heat input from solid fuel. All emission limits shall be determined on a 3-hour rolling average basis. An alternative limit to this proration equation may be proposed by the Permittee. [Minn. R. 7011.0505, subp. 3(A)]

5.6.12 Carbon Monoxide <= 2200 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.6.13 Carbon Monoxide <= 720 parts per million 30-day rolling average calculated by volume on a dry basis @ 3% oxygen. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.6.14 Sulfuric Acid Mist <= 0.13 pounds per hour 3-hour average. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.6.15 Hydrochloric acid <= 0.022 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.6.16 Mercury <= 5.7E-6 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.6.17 Mercury <= 0.000924 pounds per hour 3-hour average. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. [Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a]

5.6.18 Steam Flow <= 171000 pounds per hour 8-hour block average while combusting bark, unless a new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, based on the average fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. [Minn. R. 7017.2025, subp. 3]

5.6.19 Fuel burned: limited to following fuel types: wood (including


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation railroad ties); mill waste (including knots and screen rejects, CDF as defined under COMG1, and bark, peat and/or sawdust used to clean up oil and chemical spills); fuel oil; natural gas; and wastewater treatment plant sludge. Non-condensible gas (NCG) is also burned in Power Boiler #7. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

5.6.20 Fuel Usage <= 28.5 tons per hour 8-hour block average unless a new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, based on the average fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. (WOOD/BARK USAGE). Natural gas may be used in addition to bark up to the steam-generating limit. [Minn. R. 7017.2025, subp. 3]

5.6.21 Fuel Usage <= 502 tons per day 24-hour block average unless a new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, based on the average fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. (RAILROAD TIE USAGE LIMIT). [Minn. R. 7007.3000, Minn. R. 7017.2025, subp. 3, Title I Condition: 40 CFR 52.21]

5.6.22 The Permittee shall operate and maintain the ESP (TREA15) at any time that the process equipment controlled by the ESP (EQUI2) is in operation. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.6.23 Each day, calculate and record the three (3) 8-hour block average steam flows for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the boiler. [Minn. R. 7007.0800, subp. 2]

5.6.24 Each day, calculate and record the three (3) 8-hour block averages of wood/bark usage for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the boiler. [Minn. R. 7007.0800, subp. 2]

5.6.25 Recordkeeping: After burning of RR ties has commenced, the Permittee shall record the total wood refuse usage on a daily basis for each boiler for the purpose of determining whether railroad tie usage limit is being met. If the total wood refuse/railroad tie usage is more than the railroad tie usage limit, then the Permittee shall use fuel yard inventories and operator logsheets to determine the daily railroad tie usage. The semi-annual deviations report shall include all instances where the daily wood refuse/railroad tie usage exceeded the railroad tie daily limit and shall include the determined railroad tie usage for that day. [Minn.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation R. 7007.0800, subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

5.6.26 Emissions Monitoring: The Permittee shall use a COMS to measure opacity emissions from EQUI2. [40 CFR 64.7(a), Minn. R. 7011.1006, Minn. R. 7017.0200]

5.6.27 Emissions Monitoring: The Permittee shall use a CO, O2, and SO2 CEMS to measure CO, O2, and SO2 emissions from EQUI2. [Minn. R. 7007.3000, Minn. R. 7017.1006, Title I Condition: 40 CFR 52.21]

5.6.28 Continuous Opacity Monitoring System (COMS). Install, calibrate, maintain, and operate the COMS. [40 CFR 64.7(a) - (c), Minn. R. 7017.0200, Minn. R. 7017.1006]

5.6.29 CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of SO2 and CO; and O2 percent by volume on a dry basis. [Minn. R. 7017.1040, subp. 2, Minn. R. 7017.1006]

5.6.30 Fuel Analysis. The Permittee must maintain the fuel type or fuel mixture such that the HCl and mercury emission rates calculated according to 40 CFR Section 63.7530(c) are less than the HCl and mercury emission limits. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

5.6.31 Boiler Load. The Permittee must 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. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

5.6.32 Startup. The Permittee must operate all CMS during startup. For startup of the boiler, the Permittee must use one or a combination of the following clean fuels: natural gas, synthetic natural gas, propane, distillate oil, syngas, ultra-low sulfur diesel, fuel oil-soaked rags, kerosene, hydrogen, paper, cardboard, refinery gas, and liquefied petroleum gas. If the Permittee starts firing coal/solid fossil fuel, biomass/bio-based solids, heavy liquid fuel, or gas 2 (other) gases, the Permittee must vent emissions to the main stack(s) and engage all of the applicable control devices. Startup ends when steam or heat is supplied for any purpose. The Permittee must comply with all applicable emission limits at all times except for startup or shutdown periods conforming with this work practice. The Permittee must collect monitoring data during periods of startup, as specified in 40 CFR Section 63.7535(b). The Permittee must keep records during periods of startup. The Permittee must provide reports concerning activities and periods of startup, as specified in 40 CFR Section 63.7555. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.6.33 Shutdown. The Permittee must operate all CMS during shutdown. While firing coal/solid fossil fuel, biomass/bio-based solids, heavy


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation liquid fuel, or gas 2 (other) gases during shutdown, the Permittee must vent emissions to the main stack(s) and operate all applicable control devices. The Permittee must comply with all applicable emissions limits at all times except for startup or shutdown periods conforming with this work practice. The Permittee must collect monitoring data during periods of shutdown, as specified in 40 CFR Section 63.7535(b). The Permittee must keep records during periods of shutdown. The Permittee must provide reports concerning activities and periods of shutdown, as specified in 40 CFR Section 63.7555. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.6.34 HCl & Mercury Limits. The initial compliance requirement for HCl and mercury is to conduct a fuel analysis for each type of fuel burned in the boiler according to 40 CFR Section 63.7521 and 40 CFR pt. 63, subp. DDDDD, Table 6 and establish operating limits according to 40 CFR Section 63.7530 and 40 CFR pt. 63, subp. DDDDD, Table 8. The fuels described in 40 CFR Section 63.7510(a)(2)(i) and (ii) are exempt from these fuel analysis and operating limit requirements. The fuels described in 40 CFR Section 63.7510(a)(2)(ii) are exempt from the chloride fuel analysis and operating limit requirements. The Permittee must complete the initial compliance demonstration no later than July 29, 2017 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(b) and (e), Minn. R. 7011.7050]

5.6.35 HCl & Mercury Limits. If the Permittee burns more than one fuel type, the Permittee must determine the fuel mixture the Permittee could burn in the boiler that would result in the maximum emission rates of HCl and mercury. [40 CFR 63.7530(c)(1), Minn. R. 7011.7050]

5.6.36 HCl & Mercury Limits. The Permittee must determine the 90th percentile confidence level fuel HCl and mercury concentration of the composite samples analyzed for each fuel type using the one-sided t-statistic test described in Equation 15 of 40 CFR Section 63.7510. [40 CFR 63.7530(c)(2), Minn. R. 7011.7050]

5.6.37 HCl Limit. To demonstrate compliance with the HCl emission limit, the HCl emission rate calculated for the boiler using Equation 16 of 40 CFR Section 63.7530 must not exceed the HCl emission limit. [40 CFR 63.7530(c)(3), Minn. R. 7011.7050]

5.6.38 Mercury Limit. To demonstrate compliance with the mercury emission limit, the mercury emission rate calculated for the boiler using Equation 17 of 40 CFR Section 63.7530 must not exceed the mercury emission limit. [40 CFR 63.7530(c)(4), Minn. R. 7011.7050]

5.6.39 CO Limit. The initial compliance demonstration for CO is to conduct a performance evaluation of the CO CEMS, according to


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 40 CFR Section 63.7525(a) no later than July 29, 2017 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(c) and (e), Minn. R. 7011.7050]

5.6.40 Filterable PM Limit. The initial compliance demonstration for PM is to conduct a performance test in accordance with 40 CFR Section 63.7520 and 40 CFR pt. 63, subp. DDDDD, Table 5 no later than July 29, 2017 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). (Requirements are found under PERFORMANCE TESTING REQUIREMENTS heading above.). [40 CFR 63.7510(d) and (e), Minn. R. 7011.7050]

5.6.41 Filterable PM Limit. The Permittee must establish a unit specific limit for maximum operating load according to 40 CFR Section 63.7520(c) using data from the operating load monitors or from steam generation monitors according to the following requirements: - The Permittee must collect operating load or steam generation data every 15 minutes during the entire period of the PM performance test; - Determine the average operating load by computing the hourly averages using all of the 15-minute readings taken during each PM performance test; and - Determine the average of the three test run averages during the PM performance test, and multiply this by 1.1 (110 percent) as the operating limit. [40 CFR 63.7530(a) and (b), 40 CFR pt. 63, subp. DDDDD(Table 7), Minn. R. 7011.7050]

5.6.42 Filterable PM Limit. The Permittee must install, operate, certify and maintain a COMS according to the procedures in 40 CFR Section 63.7525(c)(1)-(7) by 01/31/2017. [40 CFR 63.7525(c), Minn. R. 7011.7050]

5.6.43 HCl & Mercury Limits. The Permittee must conduct a monthly fuel analysis according to 40 CFR Section 63.7521 for each type of fuel burned that is subject to an emission limit in 40 CFR pt. 63, subp. DDDDD, Table 2. The Permittee may comply with this monthly requirement by completing the fuel analysis any time within the calendar month as long as the analysis is separated from the previous analysis by at least 14 calendar days. If the Permittee burns a new type of fuel, the Permittee must conduct a fuel analysis before burning the new type of fuel in the boiler. The Permittee must still meet all applicable continuous compliance requirements in 40 CFR Section 63.7540. If each of 12 consecutive monthly fuel analyses demonstrates 75 percent or less of the compliance level, the Permittee may decrease the fuel analysis frequency to quarterly for that fuel. If any quarterly sample exceeds 75 percent of the compliance level or the Permittee begins burning a new type of fuel, the Permittee must return to monthly monitoring for that fuel, until 12 months of fuel


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation analyses are again less than 75 percent of the compliance level. [40 CFR 63.7515(e), Minn. R. 7011.7050]

5.6.44 HCl & Mercury Limits. The Permittee must demonstrate continuous compliance with the fuel analysis requirement by: - Conducting monthly fuel analysis for HCl and mercury according to 40 CFR pt. 63, subp. DDDDD, Table 6; - Reducing the data to 12-month rolling averages; and - Maintaining the 12-month rolling average at or below the HCl and mercury emission limits. [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

5.6.45 HCl & Mercury Limits. As specified in 40 CFR Section 63.7550(c), the Permittee must keep records of the type and amount of all fuels burned in each boiler during the reporting period to demonstrate that all fuel types and mixtures of fuels burned would result in lower emissions of HCl and mercury than the applicable emission limit for each pollutant, if the Permittee demonstrates compliance through fuel analysis. [40 CFR 63.7540(a)(2)(i), Minn. R. 7011.7050]

5.6.46 HCl Limit. If the Permittee plans to burn a new type of solid or liquid fuel, the Permittee must recalculate the HCl emission rate using Equation 12 of 40 CFR Section 63.7530 according to the requirements below. The Permittee is not required to conduct fuel analyses for the fuels described in 40 CFR Section 63.7510(a)(2)(i)-(iii) and may exclude these fuels when recalculating the HCl emission rate. - The Permittee must determine the chlorine concentration for any new fuel type in units of lb/MMBtu, based on supplier data or the Permittee's own fuel analysis, according to the provisions in the Site-Specific Fuel Analysis Plan developed according to 40 CFR Section 63.7521(b). - The Permittee must determine the new mixture of fuels that will have the highest content of chlorine. - Recalculate the HCl emission rate from the boiler under these new conditions using Equation 12 of 40 CFR Section 63.7530. The recalculated HCl emission rate must be less than the HCl emission limit. [40 CFR 63.7540(a)(3), Minn. R. 7011.7050]

5.6.47 Mercury Limit. If the Permittee plans to burn a new type of fuel, the Permittee must recalculate the mercury emission rate using Equation 13 of 40 CFR Section 63.7530 according to the procedures below. The Permittee is not required to conduct fuel analyses for the fuels described in 40 CFR Section 63.7510(a)(2)(i)-(iii) and may exclude these fuels when recalculating the mercury emission rate. - The Permittee must determine the mercury concentration for any new fuel type in units of lb/MMBtu, based on supplier data or the Permittee's own fuel analysis, according to the provisions in the Site-Specific Fuel Analysis Plan developed according to 40 CFR Section 63.7521(b).


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation - The Permittee must determine the new mixture of fuels that will have the highest content of mercury. - Recalculate the mercury emission rate from the boiler under these new conditions using Equation 13 of 40 CFR Section 63.7530. The recalculated mercury emission rate must be less than the mercury emission limit. [40 CFR 63.7540(a)(5), Minn. R. 7011.7540, a(6)]

5.6.48 CO Limit. To demonstrate continuous compliance with the CO emission limit, the Permittee must meet the requirements below. - Continuously monitor CO according to 40 CFR Sections 63.7525(a) and 63.7535. - Maintain a CO emission level below or at the CO emission limit at all times the affected unit is operating. - Keep records of CO levels according to 40 CFR Section 63.7555(b). - Record and make available upon request results of CO CEMS performance audits, dates and duration of periods when the CO CEMS is out of control to completion of the corrective actions necessary to return the CO CEMS to operation consistent with the Site-Specific Monitoring Plan. [40 CFR 63.7540(a)(8), Minn. R. 7011.7050]

5.6.49 Filterable PM Limit. The Permittee must demonstrate continuous compliance with the opacity operating limit by: - Collecting the opacity monitoring system data according to 40 CFR Sections 63.7525(c) and 63.7535; - Reducing the opacity monitoring data to 6-minute averages; and - Maintaining opacity to less than or equal to 10 percent (24-hour block average). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

5.6.50 Filterable PM Limit. The Permittee must demonstrate continuous compliance with the boiler load operating limit by: - Collecting operating load data or steam generation data every 15 minutes; and - Maintaining the operating load such that it does not exceed 110 percent of the highest hourly average operating load recorded during the most recent performance test according to 40 CFR Section 63.7520(c). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

5.6.51 Tune-Ups. The Permittee must conduct a tune-up of the boiler every five years to demonstrate continuous compliance as specified in 40 CFR Section 63.7540(a)(10)(i)-(vi). Each tune-up must be no more than 61 months after the previous tune-up. The Permittee may delay the burner inspection specified in 40 CFR Section 63.7540(10)(e) until the next scheduled or unscheduled unit shutdown, but must inspect each burner at least once every 72 months. [40 CFR 63.7515(d), 40 CFR 63.7540(a)(12), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.6.52 Tune-Ups. If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation of startup. [40 CFR 63.7540(a)(13), Minn. R. 7011.7050]

5.6.53 Startup & Shutdown. For startup and shutdown, the Permittee must meet the work practice standards according to 40 CFR pt. 63, subp. DDDDD, Table 3, Items 5 and 6. [40 CFR 63.7540(d), Minn. R. 7011.7050]


(Bark)

5.7.1 Total Particulate Matter <= 21.50 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

5.7.2 Total Particulate Matter <= 0.10 pounds per million Btu heat input 3-hour average from fossil fuel or fossil fuel and wood residue. [40 CFR 60.42(a)(1), Minn. R. 7011.0555]



5.7.5 Front-half Particulate Matter <= 0.037 pounds per million Btu heat input (filterable PM). [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.7.6 Opacity <= 20 percent opacity 6-minute average except for one six-minute period per hour of not more than 27 percent opacity. [40 CFR 60.42(a)(2), Minn. R. 7011.0555]

5.7.7 Opacity <= 10 percent opacity 24-hour block average. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]


5.7.9 Nitrogen Dioxide <= 0.20 pounds per million Btu heat input 3-hour rolling average while burning natural gas only. While burning oil, oil and wood, or natural gas and wood, the limit is 0.30 lb/mmBtu. While burning coal, coal and wood, or wood, the limit is 0.70 lb/mmBtu. While burning any other mixture of fuels, the limit shall be determined by proration using the following formula: PS(NOx) = [x(0.20)+y(0.30)+z(0.70)] / (x+y+z) Where: x = % heat input from natural gas y = % heat input from oil, oil and wood, or natural gas and wood z= % input from coal, coal and wood, or wood. All emission limits shall be determined on a 3-hour rolling average basis. [40 CFR 60.44, Minn. R. 7011.0555]

5.7.10 Nitrogen Oxides <= 200.0 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.7.11 Sulfur Dioxide <= 24.60 pounds per hour. This limit does not apply

when boiler is used as back-up incineration for NCG. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.7.12 Sulfur Dioxide <= 0.8 pounds per million Btu heat input 3-hour rolling average while burning fuel oil or fuel oil and wood. While burning coal, wood, or coal and wood, SO2 must be less than or equal to 1.2 lb/mmBtu. These limits also apply if natural gas is being burned in combination with these fuels. When coal and oil are burned simultaneously, with or without natural gas and/or wood, the limit shall be determined by proration using the following formula: PS = [y(0.80)+z(1.2)] / (y+z) Where: y = % heat input from oil z = % input from coal. All emission limits shall be determined on a 3-hour rolling average basis. NCG is not considered a fuel, and the contribution from burning NCGs is to be disregarded when determining compliance with this limit. [40 CFR 60.43, Minn. R. 7011.0555]

5.7.13 Carbon Monoxide <= 3400 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.7.14 Carbon Monoxide <= 720 parts per million 30-day rolling average calculated by volume on a dry basis @ 3% oxygen. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.7.15 Sulfuric Acid Mist <= 0.19 pounds per hour 3-hour average. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.7.16 Hydrochloric acid <= 0.022 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

5.7.17 Mercury <= 5.7E-6 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]


5.7.19 Fuel burned: limited to following fuel types: wood (including railroad ties); mill waste (including knots and screen rejects, CDF as defined under COMG1, and bark, peat and/or sawdust used to clean up oil and chemical spills); fuel oil; natural gas; and wastewater treatment plant sludge. Non-condensible gas (NCG) is also burned in power boiler #9. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

5.7.20 Fuel Usage <= 45.5 tons per hour 8-hour block average unless a


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, based on the average fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. The fuel usage limit is for wood/bark usage. Natural gas may be used in addition to bark, up to the steam generating limit. Eight-hour block average is calculated by dividing total weight by total operating time in each eight-hour block. Down time of 15 min. or more is not to be included as operating time. [Minn. R. 7017.2025, subp. 3]

5.7.21 Fuel Usage <= 1030 tons per day 24-hour block average unless a new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, based on the average fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. (RAILROAD TIE USAGE LIMIT). [Minn. R. 7007.3000, Minn. R. 7017.2025, subp. 3, Title I Condition: 40 CFR 52.21]

5.7.22 The Permittee shall operate and maintain the ESP (TREA19) at any time that the process equipment controlled by the ESP (EQUI4) is in operation. The Permittee shall document periods of non-operation of the control equipment. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.7.23 Each day, calculate and record the three (3) 8-hour block averages of wood/bark usage for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the boiler. [Minn. R. 7007.0800, subp. 2]

5.7.24 Recordkeeping: After burning of RR ties has commenced, the Permittee shall record the total wood refuse usage on a daily basis for each boiler for the purpose of determining whether railroad tie usage limit is being met. If the total wood refuse/railroad tie usage is more than the railroad tie usage limit, then the Permittee shall use fuel yard inventories and operator logsheets to determine the daily railroad tie usage. The semi-annual deviations report shall include all instances where the daily wood refuse/railroad tie usage exceeded the railroad tie daily limit and shall include the determined railroad tie usage for that day. [Minn. R. 7007.0800, subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]


5.7.26 Emissions Monitoring: The Permittee shall use a CEMS to measure NOx emissions from EQUI4. [40 CFR 64.7(a), Minn. R. 7011.1006, Minn. R. 7017.0200]

5.7.27 Continuous Opacity Monitoring System (COMS). Install, calibrate, maintain, and operate the COMS according to the appropriate provisions in 40 CFR 60.13(b) & 60.45(a). [40 CFR 60.13(b), 40 CFR


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 60.45(a), 40 CFR 64.7(a)-(c), Minn. R. 7011.0555, Minn. R. 7017.0200, Minn. R. 7017.1006]

5.7.28 Emissions Monitoring: The Permittee shall use a CO, O2, NOx, and SO2 CEMS to measure CO, O2, NOx, and SO2 emissions from EQUI4. [Minn. R. 7007.3000, Minn. R. 7017.1006, Title I Condition: 40 CFR 52.21]

5.7.29 CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of NOx, SO2, CO, and O2. [40 CFR 60.45(a), Minn. R. 7011.0555, Minn. R. 7017.1006, Minn. R. 7017.1040, subp. 2]

5.7.30 Fuel Analysis. The Permittee must maintain the fuel type or fuel mixture such that the HCl and mercury emission rates calculated according to 40 CFR Section 63.7530(c) are less than the HCl and mercury emission limits. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

5.7.31 Boiler Load. The Permittee must 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. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

5.7.32 Startup. The Permittee must operate all CMS during startup. For startup of the boiler, the Permittee must use one or a combination of the following clean fuels: natural gas, synthetic natural gas, propane, distillate oil, syngas, ultra-low sulfur diesel, fuel oil-soaked rags, kerosene, hydrogen, paper, cardboard, refinery gas, and liquefied petroleum gas. If the Permittee starts firing coal/solid fossil fuel, biomass/bio-based solids, heavy liquid fuel, or gas 2 (other) gases, the Permittee must vent emissions to the main stack(s) and engage all of the applicable control devices. Startup ends when steam or heat is supplied for any purpose. The Permittee must comply with all applicable emission limits at all times except for startup or shutdown periods conforming with this work practice. The Permittee must collect monitoring data during periods of startup, as specified in 40 CFR Section 63.7535(b). The Permittee must keep records during periods of startup. The Permittee must provide reports concerning activities and periods of startup, as specified in 40 CFR Section 63.7555. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.7.33 Shutdown. The Permittee must operate all CMS during shutdown. While firing coal/solid fossil fuel, biomass/bio-based solids, heavy liquid fuel, or gas 2 (other) gases during shutdown, the Permittee must vent emissions to the main stack(s) and operate all applicable control devices. The Permittee must comply with all applicable emissions limits at all times except for startup or shutdown periods conforming with


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation this work practice. The Permittee must collect monitoring data during periods of shutdown, as specified in 40 CFR Section 63.7535(b). The Permittee must keep records during periods of shutdown. The Permittee must provide reports concerning activities and periods of shutdown, as specified in 40 CFR Section 63.7555. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.7.34 HCl & Mercury Limits. The initial compliance requirement for HCl and mercury is to conduct a fuel analysis for each type of fuel burned in the boiler according to 40 CFR Section 63.7521 and 40 CFR pt. 63, subp. DDDDD, Table 6 and establish operating limits according to 40 CFR Section 63.7530 and 40 CFR pt. 63, subp. DDDDD, Table 8. The fuels described in 40 CFR Section 63.7510(a)(2)(i) and (ii) are exempt from these fuel analysis and operating limit requirements. The fuels described in 40 CFR Section 63.7510(a)(2)(ii) are exempt from the chloride fuel analysis and operating limit requirements. The Permittee must complete the initial compliance demonstration no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(b) and (e), Minn. R. 7011.7050]

5.7.35 HCl & Mercury Limits. If the Permittee burns more than one fuel type, the Permittee must determine the fuel mixture the Permittee could burn in the boiler that would result in the maximum emission rates of HCl and mercury. [40 CFR 63.7530(c)(1), Minn. R. 7011.7050]

5.7.36 HCl & Mercury Limits. The Permittee must determine the 90th percentile confidence level fuel HCl and mercury concentration of the composite samples analyzed for each fuel type using the one-sided t-statistic test described in Equation 15 of 40 CFR Section 63.7510. [40 CFR 63.7530(c)(2), Minn. R. 7011.7050]

5.7.37 HCl Limit. To demonstrate compliance with the HCl emission limit, the HCl emission rate calculated for the boiler using Equation 16 of 40 CFR Section 63.7530 must not exceed the HCl emission limit. [40 CFR 63.7530(c)(3), Minn. R. 7011.7050]

5.7.38 Mercury Limit. To demonstrate compliance with the mercury emission limit, the mercury emission rate calculated for the boiler using Equation 17 of 40 CFR Section 63.7530 must not exceed the mercury emission limit. [40 CFR 63.7530(c)(4), Minn. R. 7011.7050]

5.7.39 CO Limit. The initial compliance demonstration for CO is to conduct a performance evaluation of the CO CEMS, according to 40 CFR Section 63.7525(a) no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(c) and (e), Minn. R. 7011.7050]

5.7.40 Filterable PM Limit. The initial compliance demonstration for PM is to conduct a performance test in accordance with 40 CFR Section


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 63.7520 and 40 CFR pt. 63, subp. DDDDD, Table 5 no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(d) and (e), Minn. R. 7011.7050]

5.7.41 Filterable PM Limit. The Permittee must establish a unit specific limit for maximum operating load according to 40 CFR Section 63.7520(c) using data from the operating load monitors or from steam generation monitors according to the following requirements: - The Permittee must collect operating load or steam generation data every 15 minutes during the entire period of the PM performance test; - Determine the average operating load by computing the hourly averages using all of the 15-minute readings taken during each PM performance test; and - Determine the average of the three test run averages during the PM performance test, and multiply this by 1.1 (110 percent) as the operating limit. [40 CFR 63.7530(a) and (b), 40 CFR pt. 63, subp. DDDDD(Table 7), Minn. R. 7011.7050]

5.7.42 Filterable PM Limit. The Permittee must install, operate, certify and maintain a COMS according to the procedures in 40 CFR Section 63.7525(c)(1)-(7) by 01/31/2017. [40 CFR 63.7525(c), Minn. R. 7011.7050]

5.7.43 HCl & Mercury Limits. The Permittee must conduct a monthly fuel analysis according to 40 CFR Section 63.7521 for each type of fuel burned that is subject to an emission limit in 40 CFR pt. 63, subp. DDDDD, Table 2. The Permittee may comply with this monthly requirement by completing the fuel analysis any time within the calendar month as long as the analysis is separated from the previous analysis by at least 14 calendar days. If the Permittee burns a new type of fuel, the Permittee must conduct a fuel analysis before burning the new type of fuel in the boiler. The Permittee must still meet all applicable continuous compliance requirements in 40 CFR Section 63.7540. If each of 12 consecutive monthly fuel analyses demonstrates 75 percent or less of the compliance level, the Permittee may decrease the fuel analysis frequency to quarterly for that fuel. If any quarterly sample exceeds 75 percent of the compliance level or the Permittee begins burning a new type of fuel, the Permittee must return to monthly monitoring for that fuel, until 12 months of fuel analyses are again less than 75 percent of the compliance level. [40 CFR 63.7515(e), Minn. R. 7011.7050]

5.7.44 HCl & Mercury Limits. The Permittee must demonstrate continuous compliance with the fuel analysis requirement by: - Conducting monthly fuel analysis for HCl and mercury according to 40 CFR pt. 63, subp. DDDDD, Table 6; - Reducing the data to 12-month rolling averages; and - Maintaining the 12-month rolling average at or below the HCl


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation and mercury emission limits. [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

5.7.45 HCl & Mercury Limits. As specified in 40 CFR Section 63.7550(c), the Permittee must keep records of the type and amount of all fuels burned in each boiler during the reporting period to demonstrate that all fuel types and mixtures of fuels burned would result in lower emissions of HCl and mercury than the applicable emission limit for each pollutant, if the Permittee demonstrates compliance through fuel analysis. [40 CFR 63.7540(a)(2)(i), Minn. R. 7011.7050]

5.7.46 HCl Limit. If the Permittee plans to burn a new type of solid or liquid fuel, the Permittee must recalculate the HCl emission rate using Equation 12 of 40 CFR Section 63.7530 according to the requirements below. The Permittee is not required to conduct fuel analyses for the fuels described in 40 CFR Section 63.7510(a)(2)(i)-(iii) and may exclude these fuels when recalculating the HCl emission rate. - The Permittee must determine the chlorine concentration for any new fuel type in units of lb/MMBtu, based on supplier data or the Permittee's own fuel analysis, according to the provisions in the Site-Specific Fuel Analysis Plan developed according to 40 CFR Section 63.7521(b). - The Permittee must determine the new mixture of fuels that will have the highest content of chlorine. - Recalculate the HCl emission rate from the boiler under these new conditions using Equation 12 of 40 CFR Section 63.7530. The recalculated HCl emission rate must be less than the HCl emission limit. [40 CFR 63.7540(a)(3), Minn. R. 7011.7050]

5.7.47 Mercury Limit. If the Permittee plans to burn a new type of fuel, the Permittee must recalculate the mercury emission rate using Equation 13 of 40 CFR Section 63.7530 according to the procedures below. The Permittee is not required to conduct fuel analyses for the fuels described in 40 CFR Section 63.7510(a)(2)(i)-(iii) and may exclude these fuels when recalculating the mercury emission rate. - The Permittee must determine the mercury concentration for any new fuel type in units of lb/MMBtu, based on supplier data or the Permittee's own fuel analysis, according to the provisions in the Site-Specific Fuel Analysis Plan developed according to 40 CFR Section 63.7521(b). - The Permittee must determine the new mixture of fuels that will have the highest content of mercury. - Recalculate the mercury emission rate from the boiler under these new conditions using Equation 13 of 40 CFR Section 63.7530. The recalculated mercury emission rate must be less than the mercury emission limit. [40 CFR 63.7540(a)(5), Minn. R. 7011.7540, a(6)]

5.7.48 CO Limit. To demonstrate continuous compliance with the CO emission limit, the Permittee must meet the requirements below.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation - Continuously monitor CO according to 40 CFR Sections 63.7525(a) and 63.7535. - Maintain a CO emission level below or at the CO emission limit at all times the affected unit is operating. - Keep records of CO levels according to 40 CFR Section 63.7555(b). - Record and make available upon request results of CO CEMS performance audits, dates and duration of periods when the CO CEMS is out of control to completion of the corrective actions necessary to return the CO CEMS to operation consistent with the Site-Specific Monitoring Plan. [40 CFR 63.7540(a)(8), Minn. R. 7011.7050]

5.7.49 Filterable PM Limit. The Permittee must demonstrate continuous compliance with the opacity operating limit by: - Collecting the opacity monitoring system data according to 40 CFR Sections 63.7525(c) and 63.7535; - Reducing the opacity monitoring data to 6-minute averages; and - Maintaining opacity to less than or equal to 10 percent (24-hour block average). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

5.7.50 Filterable PM Limit. The Permittee must demonstrate continuous compliance with the boiler load operating limit by: - Collecting operating load data or steam generation data every 15 minutes; and - Maintaining the operating load such that it does not exceed 110 percent of the highest hourly average operating load recorded during the most recent performance test according to 40 CFR Section 63.7520(c). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

5.7.51 Tune-Ups. The Permittee must conduct a tune-up of the boiler every 5 years to demonstrate continuous compliance as specified in 40 CFR Section 63.7540(a)(10)(i)-(vi). Each tune-up must be no more than 61 months after the previous tune-up. The Permittee may delay the burner inspection specified in 40 CFR Section 63.7540(10)(e) until the next scheduled or unscheduled unit shutdown, but must inspect each burner at least once every 72 months. [40 CFR 63.7515(d), 40 CFR 63.7540(a), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.7.52 Tune-Ups. If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 calendar days of startup. [40 CFR 63.7540(a)(13), Minn. R. 7011.7050]

5.7.53 Startup & Shutdown. For startup and shutdown, the Permittee must meet the work practice standards according to 40 CFR pt. 63, subp. DDDDD, Table 3, Items 5 and 6. [40 CFR 63.7540(d), Minn. R. 7011.7050]

EQUI 7 EU011 Bleach Plant 5.8.1 Chlorine Dioxide <= 1.0 pounds per hour. This is a state only


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a]

5.8.2 Carbon Monoxide <= 1.2 pounds per ton oven dried bleached pulp. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.8.3 Chloroform <= 1.10 pounds per hour. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. [Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a]

5.8.4 Chloroform Emission Control: To reduce chloroform air emissions from the bleach plant, the Permittee shall use no hypochlorite or chlorine for bleaching in the bleaching system or line. [40 CFR 63.445(d)(2), Minn. R. 7011.7700]

5.8.5 HAPs - Total <= 10 parts per million or less than or equal to 0.002 lb per ton of oven-dried pulp or reduce the Total Chlorinated HAP mass entering the control device by 99% or more by weight. In this limit, Total HAPs refers to Total Chlorinated HAPs (not including chloroform). [40 CFR 63.445(c), Minn. R. 7011.7700]

5.8.6 Volatile Organic Compounds <= 0.17 pounds per ton of air dried bleached pulp produced. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.8.7 Enclosures and Venting: All equipment at each bleaching stage where chlorinated compounds are introduced shall be enclosed and vented into a closed-vent system meeting the requirements specified in 40 CFR Section 63.450 and as described in the Total Facility subject item. [40 CFR 63.445(b), Minn. R. 7011.7700]

5.8.8 The Permittee shall vent emissions from EQUI7 to control equipment meeting the requirements of TREA17 whenever EQUI7 operates. [Minn. R. 7007.0800, subp. 14]

EQUI 18 EU037 Power Boiler #8 5.9.1 Particulate Matter <= 29.80 pounds per hour (This is based on

emissions rate of 0.08 lb/mmBtu.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.9.2 Particulate Matter <= 0.10 pounds per million Btu heat input. [Minn. R. 7011.0515, subp. 1]

5.9.3 PM < 10 micron <= 26.10 pounds per hour (This is based on emissions rate of 0.07 lb/mmBtu). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]


5.9.5 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 27 percent opacity. [Minn. R. 7011.0515, subp. 2]

5.9.6 Nitrogen Dioxide <= 0.150 pounds per million Btu heat input 30-day rolling average (This is based on emission rate of 56 lb/hr.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.9.7 Nitrogen Oxides <= 56.0 pounds per hour. [Title I Condition: 40 CFR

52.21(k)(modeling) & Minn. R. 7007.3000] 5.9.8 Nitrogen Oxides <= 0.30 pounds per million Btu heat input when

burning fuel oil. [Minn. R. 7011.0515, subp. 1] 5.9.9 Nitrogen Dioxide <= 0.20 pounds per million Btu heat input when

burning natural gas. [Minn. R. 7011.0515, subp. 1] 5.9.10 Sulfur Dioxide <= 21.30 pounds per hour. [Title I Condition: 40 CFR

52.21(k)(modeling) & Minn. R. 7007.3000] 5.9.11 Sulfur Dioxide <= 0.80 pounds per million Btu heat input when

burning fuel oil. [Minn. R. 7011.0515, subp. 1] 5.9.12 Fuel Usage: limited to natural gas and #2 fuel oil. [Title I Condition:

40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000] 5.9.13 Sulfur Content of Fuel <= 0.05 percent by weight of fuel oil. [Title I

Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000] 5.9.14 Fuel Usage <= 1.0 million gallons per year 12-month rolling sum of

fuel oil. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.9.15 Vendor Certifications: For all fuel oil burned in Power Boiler #8 (EQUI18), maintain oil vendor information on site that documents oil sulfur content in percent by weight, to verify that the fuel oil sulfur content limit of 0.05% is being met. Copies of the sulfur content certification or analysis shall be obtained from the vendor for each delivery of fuel oil and must give the sulfur content of the fuel oil. This information shall be maintained on site. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.9.16 Emissions Monitoring: The Permittee shall use a NOx and O2 CEMS to measure NOx and O2 emissions from EQUI18. [Minn. R. 7017.1006, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

5.9.17 CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of NOx and O2 percent by volume on a dry basis. [Minn. R. 7017.1006, Minn. R. 7017.1040, subp. 2]

5.9.18 Recordkeeping: By the 15th day of each month, calculate the fuel oil usage for the previous month and the previous 12 months (12-month rolling sum). For the first 12 months of operation of #8 as a power boiler, monthly determination of the 12-month rolling sum limit for fuel oil usage shall be determined based on the following: Month 1: FOU < 1,000,000; Month 2-12: FOU(month n) < 1,000,000 - sum[FOU(actual)]; Where: FOU = the fuel oil usage, in gallons/year; sum[FOU(actual)] = the sum of FOU for all months previous to month n; month n = the month for which the limit is being calculated. The limit is being met when the formula is true for month n.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation [Minn. R. 7007.0800, subp. 5]

5.9.19 Compliance Date. The Permittee must comply with 40 CFR pt. 63, subp. DDDDD no later than January 31, 2016, except as provided in 40 CFR Section 63.6(i). [40 CFR 63.7495(b), Minn. R. 7011.7050]

5.9.20 Tune-Ups. The Permittee must complete an initial tune-up by following the procedures described in 40 CFR Section 63.7540(a)(10)(i)-(vi) no later than January 31, 2016, except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(e), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.9.21 Energy Assessment. The Permittee must complete the one-time energy assessment specified in 40 CFR pt. 63, subp. DDDDD, Table 3 no later than January 31, 2016, except as specified in 40 CFR Section 63.7510(j). An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in 40 CFR pt. 63, subp. DDDDD, Table 3, satisfies the energy assessment requirement. A facility that operates under an energy management program compatible with ISO 50001 that includes the affected units also satisfies the energy assessment requirement. [40 CFR 63.7510(e), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

5.9.22 Tune-Ups. The Permittee must conduct an annual tune-up of the boiler to demonstrate continuous compliance as specified in 40 CFR Section 63.7540(a)(10)(i)-(vi). Each annual tune-up must be conducted no more than 13 months after the previous tune-up. [40 CFR 63.7515(d), 40 CFR 63.7540(a), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]


EQUI 38 EU082 I&I Emergency

Generator

5.10.1 Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R. 7011.2300, subp. 1]

5.10.2 Sulfur Dioxide <= 0.50 pounds per million Btu heat input. The potential to emit from the unit is 0.00059 lb/MMBtu due to equipment design and allowable fuel. [Minn. R. 7011.2300, subp. 2(A)]

5.10.3 Sulfur Dioxide <= 0.0015 pounds per million Btu heat input. This limit is effective on January 31, 2018. The potential to emit from the unit is 0.00059 lb/MMBtu due to equipment design and allowable fuel. [Minn. R. 7011.2300, subp. 2(B)]

5.10.4 Fuel type: Natural gas only by design. [Minn. R. 7005.0100, subp. 35a]

5.10.5 Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6, 1995, limiting operation to 500 hours per year.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation [Minn. R. 7007.0800, subps. 4-5]

5.10.6 The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R. 7007.0800, subp. 5]

EQUI 42 EU088 Ozone

bleaching system

5.11.1 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] 5.11.2 Particulate Matter <= 0.30 grains per dry standard cubic foot of

exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

EQUI 49 EU081 IQS -

Incinerator

5.12.1 Particulate Matter <= 8.80 pounds per hour 3-hour average. [Minn. R. 7007.0800, subp. 2]




5.12.5 Sulfur Dioxide <= 14.80 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.12.6 Volatile Organic Compounds <= 4.60 pounds per hour. [Minn. R. 7007.0800, subp. 2]

5.12.7 Carbon Monoxide <= 11.40 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.12.8 Sulfur - Total Reduced including H2S <= 0.50 pounds per hour. [Minn. R. 7007.0800, subp. 2]

5.12.9 Sulfuric Acid Mist <= 1.0 pounds per hour. [Minn. R. 7007.0800, subp. 2]

5.12.10 HAPs - Total <= 20 parts per million by volume, corrected to 10 percent oxygen on a dry basis. [40 CFR 63.443(d)(2), Minn. R. 7011.2450]

5.12.11 The Permittee shall vent emissions from the equipment controlled by the IQS to TREA30 whenever the equipment operates, and operate and maintain TREA30 at all times that any emissions are vented to TREA30. The Permittee shall document periods of non-operation of the control equipment TREA30 while equipment being controlled is operating. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.12.12 The Permittee shall vent emissions from EQUI49 to TREA31 (SO2 Scrubber) whenever the equipment operates, and operate and maintain TREA31 at all times that any emissions are vented to TREA31. The Permittee shall document periods of non-operation


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation of the control equipment whenever EQUI49 is operating. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.12.13 The Permittee is allowed to conduct on-line acid washes on TREA30 in accordance with the O & M Plan. The Permittee shall record the time, date, and duration of on-line acid washes. A Shutdown Breakdown Notice does not need to be submitted for the on-line acid wash. [Minn. R. 7007.0800, subp. 2]

EQUI 51 EU031 Smelt

Dissolving Tank for RB #10

5.13.1 Total Particulate Matter <= 12.5 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.13.2 Total Particulate Matter <= 0.12 pounds per ton of black liquor solids fired (dry virgin). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.13.3 Total Particulate Matter <= 0.20 pounds per ton of black liquor solids fired. [40 CFR 52.282(a)(2), 40 CFR 63.862(a)(1)(i)(B), Minn. R. 7011.2450, Minn. R. 7011.7700]


5.13.5 PM < 10 micron <= 0.12 pounds per ton of black liquor solids fired (dry weight) using 3 Hour Average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]


5.13.7 Opacity <= 20 percent opacity 6-minute average. [Minn. R. 7007.0800, subp. 2]


5.13.9 Volatile Organic Compounds <= 0.16 pounds per ton of air dried unbleached pulp. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.13.10 Sulfur - Total Reduced including H2S <= 0.0168 pounds per ton of black liquor solids (dry virgin). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.13.11 Sulfur - Total Reduced including H2S < 0.033 pounds per ton black liquor solids as H2S. [40 CFR 60.283(a)(4), Minn. R. 7011.2450]

5.13.12 The Permittee shall operate and maintain the scrubber (TREA12) at any time that EQUI51 is in operation. The Permittee shall document periods of non-operation of the control equipment. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.13.13 The Permittee shall operate and maintain the VRS (TREA6) at any time that EQUI51 is in operation. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.13.14 Continuous Parameter Monitoring System (CPMS). Install,

calibrate, maintain, and operate a CPMS that can be used to determine and record the pressure drop across the scrubber and the scrubbing liquid flow rate at least once every successive 15-minute period using the procedures in 40 CFR 63.8(c), as well as: - The monitoring device used for the continuous measurement of the pressure drop of the gas stream across the scrubber must be certified by the manufacturer to be accurate to within a gage pressure of plus or minus 500 pascals (plus or minus 2 inches of water gage pressure); and - The monitoring device used for continuous measurement of the scrubbing liquid flow rate must be certified by the manufacturer to be accurate within plus or minus 5 percent of the design scrubbing liquid flow rate. [40 CFR 63.864(e)(10), Minn. R. 7011.7700]

5.13.15 Determination of operating ranges: - Establish operating ranges for the pressure drop across the scrubber and the scrubbing liquid flow rate based on values recorded during previous performance tests. - The Permittee shall certify that all control techniques and processes have not been modified subsequent to the testing upon which the data used to establish the operating parameter ranges were obtained. - The Permittee may establish expanded or replacement operating ranges during subsequent performance tests using the test methods required in 40 CFR 63.865. - The Permittee shall continuously monitor each parameter and determine the arithmetic average value of each parameter during each performance test. Multiple performance tests may be conducted to establish a range of parameter values. [40 CFR 63.864(j), Minn. R. 7011.7700]

EQUI 52 EU033 Rotary Lime

Kiln - Kiln

5.14.1 Total Particulate Matter <= 0.035 grains per dry standard cubic foot @ 10% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.2 Total Particulate Matter <= 13.6 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.14.3 PM < 10 micron <= 0.0345 grains per dry standard cubic foot 3-hour average @ 10% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.4 PM < 10 micron <= 13.6 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling)]

5.14.5 PM < 2.5 micron <= 0.0325 grains per dry standard cubic foot 3-hour average @ 10% O2. [Title I Condition: 40 CFR 52.21(j)(BACT)


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation & Minn. R. 7007.3000]

5.14.6 PM < 2.5 micron <= 12.8 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling)]

5.14.7 Front-half Particulate Matter < 0.064 grains per dry standard cubic foot corrected to 10 percent oxygen (filterable PM). [40 CFR 60.282a(a)(5)(i), 40 CFR 60.862(a)(1)(i)(C), Minn. R. 7011.7700]

5.14.8 Opacity <= 20 percent opacity. The exemptions to opacity standards under 40 CFR Section 60.11(c) do not apply. [40 CFR 60.282a(a)(5)(ii)]

5.14.9 Nitrogen Dioxide <= 220 parts per million (calculated on a dry basis @ 10% O2.). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.10 Nitrogen Oxides <= 120 parts per million (calculated on a dry basis @ 10% O2). [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.14.11 Nitrogen Oxides <= 39.0 pounds per hour 30-day rolling average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]



5.14.14 Volatile Organic Compounds <= 1.0 pounds per ton (units are lbs/ton of calcined product). (This is based on emission rate of 20.0 lb/hr). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.15 Carbon Monoxide <= 75 parts per million (calculated on a dry basis @ 10% O2). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.16 Carbon Monoxide <= 12.9 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.14.17 Sulfur - Total Reduced including H2S <= 8 parts per million as a 12-hour average (calculated on a dry basis @ 10% O2). (This is based on emission rate of 1.7 lb/hr). [40 CFR 60.283a(a)(5), Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.18 Sulfuric Acid Mist <= 0.53 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.19 Mercury <= 0.00025 pounds per hour. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. [Minn. R. 7007.0800, subp. 2]

5.14.20 Calcium Oxide Production Process Throughput <= 175000 tons per year 12-month rolling sum. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

5.14.21 Fuel use: limited to natural gas. [Minn. R. 7007.0800, subp. 2]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.14.22 Process Throughput <= 500 tons per day 24-hour block average

(limit is for calcium oxide production). 24-hour block average is calculated by dividing total weight by total operating time in each 24-hour block. Down time of 15 minutes or more is not to be included as operating time. [Minn. R. 7017.2025, subp. 3, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.14.23 No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, Minn. R. 7011.0050]

5.14.24 The Permittee shall operate and maintain the ESP (TREA21) at any time that the process equipment controlled by the ESP (EQUI52) is in operation. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0100, subps. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1-2, Minn. R. 7009.0010-7009.0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: 40 CFR pt. 50]


5.14.26 Continuous Opacity Monitoring System (COMS): Install, calibrate, maintain, and operate a COMS to monitor and record opacity. The span of this system must be set at 70 percent opacity. The Permittee must install, certify, and operate the COMS in accordance with Performance Specification 1 in 40 CFR part 60, Appendix B and the appropriate provisions in 40 CFR Sections 63.6(h) & 63.8. [40 CFR 60.13(b), 40 CFR 60.284a(a)(1), 40 CFR 60.864(d), 40 CFR 64.7(a)-(c), Minn. R. 7011.7700, Minn. R. 7017.0200, Minn. R. 7017.1006]

5.14.27 Emissions Monitoring: The Permittee shall use an oxygen and TRS CEMS to measure oxygen and TRS emissions from EQUI52. [Minn. R. 7007.3000, Minn. R. 7017.1006, Title I Condition: 40 CFR 52.21]

5.14.28 CEMS Installation: Install, calibrate, maintain and operate a CEMS to monitor and record the concentration of TRS on a dry basis and O2 percent by volume on a dry basis. The Permittee must install, certify, and operate the continuous TRS monitoring system in accordance with Performance Specification 5 in 40 CFR part 60, Appendix B. The Permittee must install, certify, and operate the continuous oxygen monitoring system in accordance with Performance Specification 3 in 40 CFR part 60, Appendix 3. These systems must be located downstream of the control device(s). The range of the continuous monitoring system must encompass all expected concentration values, including the zero and span values used for calibration. The spans of these continuous monitoring systems must be set: - At a TRS concentration of 30 ppm for the TRS CEMS; and


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation - At 21 percent oxygen for the O2 CEMS. [40 CFR 60.284a(a)(2), Minn. R. 7017.1006, Minn. R. 7017.1040, subp. 2]

5.14.29 The Permittee must install, calibrate, maintain, and operate: - A monitoring device for the continuous measurement of the secondary voltage of each ESP collection field; and - A monitoring device for the continuous measurement of the secondary current of each ESP collection field. Total secondary power may be calculated as the product of the secondary voltage and secondary current measurements for each ESP collection field and used to demonstrate compliance as an alternative to the secondary voltage and secondary current measurements. [40 CFR 60.284a(b)(3)]

5.14.30 The Permittee must follow the procedures for collecting and reducing monitoring data and setting operating limits in 40 CFR Section 60.284a(c)(1)-(6). 40 CFR pt. 60, subp. A specifies methods for reducing continuous opacity monitoring system data. [40 CFR 60.284a(c)]

5.14.31 The Permittee must perform the following: - Calculate and record on a daily basis 12-hour average TRS concentrations for the two consecutive periods of each operating day. Each 12-hour average must be determined as the arithmetic mean of the appropriate 12 contiguous 1-hour average TRS concentrations provided by each continuous monitoring system installed under 40 CFR Section 60.284a(a)(2). - Calculate and record on a daily basis 12-hour average oxygen concentrations for the two consecutive periods of each operating day for the lime kiln. These 12- hour averages must correspond to the 12-hour average TRS concentrations under 40 CFR Section 60.284a(c)(1)(i) and must be determined as an arithmetic mean of the appropriate 12 contiguous 1-hour average oxygen concentrations provided by each continuous monitoring system installed under 40 CFR Section 60.284a(a)(2). - Using the following equation, correct all 12-hour average TRS concentrations to 10 volume percent oxygen: Ccorr = Cmeas x (21 - X) / (21 - Y) Where: Ccorr = the concentration corrected for oxygen. Cmeas = the 12-hour average of the measured concentrations uncorrected for oxygen. X = the volumetric oxygen concentration in percentage to be corrected to (10 percent for lime kilns). Y = the 12-hour average of the measured volumetric oxygen concentration. [40 CFR 60.284a(c)(1)]

5.14.32 The Permittee must record at least once each successive 15-minute period all measurements obtained from the continuous


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation monitoring devices installed under 40 CFR Section 60.284a(b)(3) and reduce the data by calculating semiannual averages from the recorded measurements of ESP parameters (secondary voltage and secondary current, or total secondary power) for ESP-controlled lime kilns that measure opacity in addition to ESP parameters. [40 CFR 60.284a(c)(3)]

5.14.33 During the initial performance test required in 40 CFR Section 60.285a, the Permittee must establish site-specific operating limits for the monitoring parameters in 40 CFR Section 60.284a(b)(3) by continuously monitoring the parameters and determining the arithmetic average value of each parameter during the performance test. The arithmetic average of the measured values for the three test runs establishes the minimum site-specific operating limit for each ESP parameter. Multiple performance tests may be conducted to establish a range of parameter values. The Permittee may establish replacement operating limits for the monitoring parameters during subsequent performance tests using the test methods in 40 CFR Section 60.285a. [40 CFR 60.284a(c)(4)]

5.14.34 The Permittee must operate the continuous monitoring systems required in 40 CFR Section 60.284a(a) and (b) to collect data at all required intervals at all times the affected facility is operating except for periods of monitoring system malfunctions or out-of-control periods, repairs associated with monitoring system malfunctions or out-of-control periods, and required monitoring system quality assurance or quality control activities including, as applicable, calibration checks and required zero and span adjustments. [40 CFR 60.284a(c)(5)]

5.14.35 The Permittee may not use data recorded during monitoring system malfunctions or out-of-control periods, repairs associated with monitoring system malfunctions or out-of-control periods, or required monitoring system quality assurance or control activities in calculations used to report emissions or operating limits. The Permittee must use all the data collected during all other periods in assessing the operation of the control device and associated control system. [40 CFR 60.284a(c)(6)]

5.14.36 For emissions from any lime kiln, periods of excess emissions are: - All 12-hour average TRS concentrations above 8 ppm by volume at 10-percent oxygen during times when lime mud is fired; and - All 6-minute average opacities that exceed 20 percent during times when lime mud is fired. [40 CFR 60.284a(d)(2)]

5.14.37 The Administrator will not consider periods of excess emissions reported under 40 CFR Section 60.288a(a) to be indicative of a violation of the standards provided that: - The percent of the total number of possible contiguous periods of excess emissions in the semiannual reporting period does not exceed: 1% for TRS emissions provided that the 12-hour average TRS concentration does not exceed 22 ppm corrected to 10-percent oxygen or 1% for average opacities provided that the ESP


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation secondary voltage and secondary current (or total secondary power) averaged over the semiannual period remained above the minimum operating limits established during the performance test; and - The Administrator determines that the affected facility, including air pollution control equipment, is maintained and operated in a manner which is consistent with good air pollution control practice for minimizing emissions during periods of excess emissions. [40 CFR 60.284a(e)]

5.14.38 The procedures under 40 CFR Section 60.13 must be followed for installation, evaluation, and operation of the continuous monitoring systems required under 40 CFR Section 60.284a. All continuous monitoring systems must be operated in accordance with the applicable procedures under Performance Specifications 1, 3, and 5 of 40 CFR pt. 60, Appendix B. [40 CFR 60.284a(f)]

5.14.39 Each day, calculate and record the 24-hour block average calcium oxide production rate for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the lime kiln. [Minn. R. 7007.0800, subp. 2]

5.14.40 Recordkeeping: By the 15th day of each month, calculate and record the calcium oxide production rate for the previous month and the previous 12 months (12-month rolling sum). [Minn. R. 7007.0800, subp. 2]

5.14.41 The Permittee must maintain records of the performance evaluations of the continuous monitoring systems. [40 CFR 60.287a(a)]

5.14.42 For each continuous monitoring system, the Permittee must maintain records of the following information: - Records of the opacity of the gases discharged into the atmosphere and records of the ESP secondary voltage and secondary current (or total secondary power) averaged over the reporting period for the opacity allowances specified in 40 CFR Section 60.284a(e)(1)(iv); - Records of the concentration of TRS emissions on a dry basis and the percent of oxygen by volume on a dry basis in the gases discharged into the atmosphere; - Records of the secondary voltage of each ESP collection field, records of the secondary current of each ESP collection field, and, if used as an alternative to secondary voltage and current, records of the total secondary power of each ESP collection field; and - Records of excess emissions as defined in 40 CFR Section 60.284a(d). [40 CFR 60.287a(b)]

5.14.43 For each malfunction, the Permittee must maintain records of the following information:


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation - Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment; and - Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR Section 60.11(d), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. [40 CFR 60.287a(c)]

5.14.44 Recordkeeping: Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), Minn. R. 7019.0100, subp. 1]

5.14.45 Recordkeeping: Maintain a file of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by 40 CFR pt. 60 recorded in a permanent form suitable for inspection for at least five years. 40 CFR Section 60.7(f) specifies two years. [40 CFR 60.7(f), Minn. R. 7007.0800, subp. 5(C), Minn. R. 7019.0100, subp. 1]

5.14.46 The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. The Permittee shall submit the notification both to the Commissioner and to the US EPA regional office in Chicago. [40 CFR 60.7(a)(4), Minn. R. 7019.0100, subp. 1]

5.14.47 The Permittee shall submit a notification of the date upon which demonstration of the continuous monitoring system performance commences in accordance with 40 CFR Section 60.13(c). Notification shall be postmarked not less than 30 days prior to such date. [40 CFR 60.7(a)(5), Minn. R. 7019.0100, subp. 1]

5.14.48 Notification of Anticipated Date for Conducting Opacity Observations: due 30 days prior to observation date. The Permittee shall submit the notification both to the Commissioner and to the US EPA regional office in Chicago. [40 CFR 60.7(a)(6), Minn. R. 7019.0100, subp. 1]

5.14.49 Within 60 days after the date of completing each performance test as required by 40 CFR pt. 60, subp. BBa, the Permittee must submit the results of the performance tests, including any associated fuel analyses, required by 40 CFR pt. 60, subp. BBa to the EPA as specified in 40 CFR Section 60.288a(b). [40 CFR 60.288a(b)]

5.14.50 Within 60 days after the date of completing each CEMS performance evaluation test as defined in 40 CFR Section 60.13, the Permittee must submit relative accuracy test audit (RATA) data to the EPA's Central Data Exchange (CDX) by using CEDRI in


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation accordance with 40 CFR Section 60.288a(b). Only RATA pollutants that can be documented with the ERT (as listed on the ERT Web site) are subject to this requirement. For any performance evaluations with no corresponding RATA pollutants listed on the ERT Web site, the Permittee must submit the results of the performance evaluation to the Administrator at the appropriate address listed in 40 CFR Section 60.4. [40 CFR 60.288a(c)]

5.14.51 If a malfunction occurred during the reporting period, the Permittee must submit a report that contains the following: - The number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded; and - A description of actions taken by the Permittee during a malfunction to minimize emissions in accordance with 40 CFR Section 60.11(d), including actions taken to correct a malfunction. [40 CFR 60.288a(d)]

EQUI 53 EU005 Recovery Boiler

#10

5.15.1 Filterable Particulate Matter <= 0.020 grains per dry standard cubic foot 3-hour average basis calculated at 8% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.15.2 Particulate Matter <= 40.0 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.15.3 Total Particulate Matter <= 0.044 grains per dry standard cubic foot (calculated at 8% O2). [40 CFR 60.282(a)(1)(i), 40 CFR 63.862(a)(1)(i)(A), Minn. R. 7011.2450, Minn. R. 7011.7700]

5.15.4 Total Particulate Matter <= 0.030 pounds per million Btu heat input. This limit applies at all times when fuel oil is being combusted, except during periods of startup, shutdown, or malfunction. [40 CFR 60.43b(h)(1), Minn. R. 7011.0565]

5.15.5 PM < 10 micron <= 0.025 grains per dry standard cubic foot 3-hour average basis calculated at 8% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.15.6 PM < 10 micron <= 40.0 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.15.7 PM < 2.5 micron <= 0.025 grains per dry standard cubic foot 3-hour average basis calculated at 8% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.15.8 PM < 2.5 micron <= 37.9 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.15.9 Opacity <= 20 percent opacity 6-minute average, except for one 6-minute period per hour of not more than 27 percent opacity. [40 CFR 60.43b(f), Minn. R. 7011.0565]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.15.10 Opacity <= 35 percent opacity. [40 CFR 60.282(a)(1)(ii), Minn. R.

7011.2450] 5.15.11 Nitrogen Dioxide <= 100 parts per million 30-day rolling average by

volume (dry) corrected to 8% oxygen. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.15.12 Nitrogen Dioxide <= 226.5 pounds per hour 30-day rolling average. [Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a]


5.15.14 Nitrogen Oxides <= 241.0 pounds per hour 1-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.15.15 Nitrogen Dioxide <= 0.20 pounds per million Btu heat input 30-day rolling average while burning natural gas only or fuel oil combined with black liquor. [40 CFR 60.44b(f)(2), Minn. R. 7011.0565]

5.15.16 Sulfur Dioxide <= 582.0 pounds per hour. (This limit is based on a concentration of 250 ppmvd @ 8% O2.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.15.17 Sulfur Dioxide <= 73.0 pounds per hour 30-day rolling average. (This limit is based on a concentration of 50 ppmvd @ 8% O2.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.15.18 Volatile Organic Compounds <= 44.0 pounds per hour 3-hour average. (This limit is based on a concentration of 60 ppmvd @ 8% O2.). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.15.19 Carbon Monoxide <= 359.1 pounds per hour 24-hour rolling average. (This limit is based on a concentration of 300 ppmvd @ 8% O2.). [Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a]

5.15.20 Carbon Monoxide <= 382.0 pounds per hour 24-hour rolling average (This limit is based on a concentration of 300 ppmvd @ 8% O2.). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.15.21 Sulfur - Total Reduced including H2S <= 5 parts per million on a dry basis, corrected to 8% oxygen, using 12-hour block average. (This limit is based on an emission rate of 4.8 lb/hr.). [40 CFR 60.283(a)(2), Minn. R. 7011.2450, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.15.22 Sulfuric Acid Mist <= 3.6 pounds per hour 3-hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]


5.15.24 Carbon Dioxide Equivalent <= 207 pounds per million Btu heat


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation input. This emission rate limit is based on emission factors and global warming potentials listed in 40 CFR Part 98 as of September, 2016. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.15.25 Fuel burned: Limited to natural gas, black liquor, and black liquor blended with distillate fuel oil (includes on-road diesel fuel oil). The combustion of fuel oil alone (i.e. not blended with black liquor) is not authorized. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.15.26 Fuel Usage <= 1.0 gallons per minute of distillate fuel oil. This is in addition to the other fuels allowed. This is a physical limitation of the design of the fuel oil feed system (pump capacity). [Minn. R. 7005.0100, subp. 35a]

5.15.27 Sulfur Content of Fuel <= 0.050 percent by weight for distillate oil. This limit also exempts the unit from the sulfur dioxide emission limits of 40 CFR Section 60.42b (40 CFR Section 60.42b(k)(2)). [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

5.15.28 Steam Flow <= 825000 pounds per hour 8-hour block average unless a new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, based on the average steam flow recorded during the most recent MPCA approved performance test where compliance was demonstrated. Limit is for Steam Production. Eight-hour block average is calculated by dividing total steam produced by total operating time in each eight-hour block. Down time of 15 min. or more is not to be included as operating time. [Minn. R. 7017.2025, subp. 3]

5.15.29 Annual capacity factor for fossil fuels: less than or equal to 10%. [40 CFR 60.44b(c), Minn. R. 7011.0565]

5.15.30 Annual Capacity Factor Daily Recordkeeping and Fuel Type Recordkeeping: On each day of operation the Permittee shall record and maintain records of the amounts of each fuel combusted in the Recovery Boiler (EQUI 53). [40 CFR 60.49b(d), Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.0565, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.15.31 Annual Capacity Factor Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following: 1) The total amount of each type of fuel combusted in the recovery boiler during the previous month. 2) The annual capacity factor of fossil fuels (natural gas and distillate oil) for the previous 12-month period. [40 CFR 60.49b(d), Minn. R. 7007.0800, subps. 4-5, Minn. R. 7011.0565]

5.15.32 The Permittee shall operate and maintain the ESP (TREA20) at any time that the process equipment controlled by the ESP (EQUI53) is in operation. The Permittee shall document periods of non-operation of the control equipment. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.15.33 Each day, calculate and record the three (3) 8-hour block average


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation steam flows for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the boiler. [Minn. R. 7007.0800, subp. 2]


5.15.35 Continuous Opacity Monitoring System (COMS). Install, calibrate, maintain, and operate the COMS according to the appropriate provisions in 40 CFR 63.6(h) & 63.8. [40 CFR 60.13(b), 40 CFR 60.284(a)(1), 40 CFR 60.48b(a), 40 CFR 63.864(d), 40 CFR 64.7(a)-(c), Minn. R. 7011.2450, Minn. R. 7011.7700, Minn. R. 7017.0200, Minn. R. 7017.1006]

5.15.36 Emissions Monitoring: The Permittee shall use an CO, NOx, SO2, and TRS CEMS to measure CO, NOx, SO2, and TRS emissions from EQUI53. [40 CFR 63.864(e), Minn. R. 7007.3000, Minn. R. 7011.7700, Minn. R. 7017.1006, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.15.37 CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of NOx, SO2, CO, CO2; and the concentration of TRS on a dry basis; and O2 percent by volume on a dry basis. [40 CFR 60.284(a)(2), Minn. R. 7011.2450, Minn. R. 7017.1006, Minn. R. 7017.1040, subp. 2]

5.15.38 Records of Startup, Shutdown, or Malfunction: Any owner or operator subject to the provisions of this part shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b)]

5.15.39 Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), 40 CFR 60.866, Minn. R. 7011.7700, Minn. R. 7017.1130]

5.15.40 Record and maintain records of the amount of fuel combusted each day. [40 CFR 60.49b(d)(1), Minn. R. 7011.0565]

5.15.41 Maintain records each operating day of the information listed under 40 CFR Section 60.49b(g). [40 CFR 60.49b(g), Minn. R. 7011.0565]

5.15.42 Obtain and maintain fuel receipts from the fuel oil supplier that certify that the oil meets the definition of distillate oil as defined in 40 CFR Section 60.41b, and the sulfur content of the fuel oil. [40 CFR 60.49b(r)(1), Minn. R. 7011.0565]

EQUI 71 MR004 Power Boiler #9


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation - SO2

5.16.1 The CEMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R. 7017.1010]

5.16.2 Sulfur Dioxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 60, subp. D, Minn. R. 7017.1010, subp 1]

5.16.3 Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R. 7017.1040, subp. 1]

5.16.4 Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R. 7017.1180, subp. 3]

5.16.5 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R. 7017.1180, subp. 1]

5.16.6 CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. [40 CFR 60.13(b), Minn. R. 7017.1050, subp. 1]

5.16.7 Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [40 CFR 60.7(a)(5), Minn. R. 7017.1060, subp. 1-3, Minn. R. 7017.1080]

5.16.8 Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]

5.16.9 Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance;


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R. 7017.1160, subps. 1-2]

5.16.10 QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR pt. 60, Appendix F, 3, Minn. R. 7017.1170, subp. 2]

5.16.11 CEMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F]

5.16.12 CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section 4.3.1 shall be used to determine out-of-control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R. 7017.1170, subp. 3]

5.16.13 Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), Minn. R. 7017.1130]

5.16.14 CEMS Monitor Design: Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15-minute period. [40 CFR 60.13(e)(2)]


- O2


5.17.2 Oxygen: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1010, subp. 1]



Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.17.4 CEMS Certification/Recertification Test: due 90 days after the first

excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. [Minn. R. 7017.1050, subp. 1]

5.17.5 Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R. 7017.1060, subp. 1-3, Minn. R. 7017.1080]

5.17.6 Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]

5.17.7 QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R. 7017.1170, subp. 2]

5.17.8 CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section 4.3.1 shall be used to determine out-of-control periods for CEMS. [Minn. R. 7017.1170, subp. 3]

5.17.9 Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R. 7017.1130]

5.17.10 The Permittee must install, certify, operate and maintain continuous emission monitoring systems for oxygen according to the procedures in 40 CFR Section 63.7525(a)(1)-(7). [40 CFR 63.7525(a), Minn. R. 7011.7050]

5.17.11 Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points:


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R. 7017.1160, subps. 1-2]

5.17.12 Install the oxygen CEMS by January 31, 2016. The CO and oxygen levels shall be monitored at the same location at the outlet of the boiler. [40 CFR 63.7525(a)(1)]

5.17.13 The Permittee must install, certify, operate, and maintain an oxygen analyzer according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the site-specific monitoring plan developed according to 40 CFR Section 63.7505(d), and the requirements in 40 CFR Sections 63.7540(a)(8) and 63.7525(a). [40 CFR 63.7525(a)(2), Minn. R. 7011.7050]

5.17.14 Complete a minimum of one cycle of CO and oxygen CEMS operation (sampling, analyzing, and data recording) for each successive 15-minute period. Collect CO and oxygen data concurrently. Collect at least four CO and oxygen CEMS data values representing the four 15-minute periods in an hour, or at least two 15-minute data values during an hour when CEMS calibration, quality assurance, or maintenance activities are being performed. [40 CFR 63.7525(a)(3), Minn. R. 7011.7050]

5.17.15 CEMS O&M. The Permittee shall maintain and operate the oxygen CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the oxygen CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]

5.17.16 CEMS Representative Location. Install CEMS such that representative measurements of emissions or process parameters from the source are obtained. In addition, the CEMS shall be located according to procedures contained in the applicable performance specifications of 40 CFR pt. 60, Appendix B. [40 CFR 63.8(c)(2)and (e), Minn. R. 7017.1010]

5.17.17 CEMS Monitor Design. Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in each 15 minute period. [40 CFR 63.8(c)(4)(ii), Minn. R. 7017.1010]




- CO

5.18.1 The CEMS requirements listed below outline the typical standards


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation of 40 CFR pt. 63 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R. 7017.1010]

5.18.2 Carbon Monoxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1010, subp 1]


5.18.4 CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. [Minn. R. 7017.1050, subp. 1]





5.18.9 Recordkeeping: The owner or operator must retain records of all


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R. 7017.1130]

5.18.10 The Permittee must install, certify, operate and maintain a continuous emission monitoring system for CO according to the procedures in 40 CFR Section 63.7525(a)(1)-(7). [40 CFR 63.7525(a), Minn. R. 7011.7050]

5.18.11 Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R. 7017.1160, subps. 1-2]

5.18.12 Install the CO CEMS by January 31, 2016. The CO and oxygen levels shall be monitored at the same location at the outlet of the boiler. [40 CFR 63.7525(a)(1)]

5.18.13 The Permittee must install, certify, operate, and maintain a CO CEMS according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the Site-Specific Monitoring Plan developed according to 40 CFR Section 63.7505(d), and the requirements in 40 CFR Sections 63.7540(a)(8) and 63.7525(a). Any boiler that has a CO CEMS that is compliant with Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, a Site-Specific Monitoring Plan developed according to 40 CFR Section 63.7505(d), and the requirements in in 40 CFR Sections 63.7540(a)(8) and 63.7525(a) must use the CO CEMS to comply with the applicable alternative CO CEMS emission standard listed in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR 63.7525(a)(2), Minn. R. 7011.7050]

5.18.14 The Permittee must install, certify, operate, and maintain the CO CEMS according to the following requirements: - The Permittee must conduct a performance evaluation of each CO CEMS according to the requirements in 40 CFR Section 63.8(e) and according to Performance Specification 4, 4A, or 4B at 40 CFR part 60, Appendix B. - During each relative accuracy test run of the CO CEMS, the Permittee must collect emission data for CO concurrently (or within a 30- to 60-minute period) by both the CO CEMS and by EPA Reference Method 10, 10A, or 10B. The relative accuracy testing must be at representative operating conditions. - The Permittee must follow the quality assurance procedures of Procedure 1 of 40 CFR pt. 60, Appendix F. The measurement span value of the CO CEMS must be two times the applicable CO emission limit, expressed as a concentration. - Any CO CEMS that does not comply with 40 CFR Section


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 63.7525(a) cannot be used to meet any requirement in 40 CFR pt. 63, subp. DDDDD to demonstrate compliance a CO emission limit listed in 40 CFR pt. 63, subp. DDDDD, Table 2. - Complete the initial performance evaluation no later than July 29, 2016. [40 CFR 63.7525(a)(2)(i)-(v), Minn. R. 7011.7050]


5.18.16 Reduce the CO CEMS data as specified in 40 CFR Section 63.8(g)(2). [40 CFR 63.7525(a)(4), Minn. R. 7011.7050]

5.18.17 Calculate one-hour arithmetic averages, corrected to 3 percent oxygen from each hour of CO CEMS data in parts per million CO concentration. The one-hour arithmetic averages required shall be used to calculate the 30-day or 10-day rolling average emissions. Use Equation 19-19 in Section 12.4.1 of Method 19 of 40 CFR pt. 60, Appendix A-7 for calculating the average CO concentration from the hourly values. [40 CFR 63.7525(a)(5), Minn. R. 7011.7050]

5.18.18 For purposes of collecting CO data, operate the CO CEMS as specified in 40 CFR Section 63.7535(b). The Permittee must use all the data collected during all periods in calculating data averages and assessing compliance, except that the Permittee must exclude certain data as specified in 40 CFR Section 63.7535(c). Periods when CO data are unavailable may constitute monitoring deviations as specified in 40 CFR Section 63.7535(d). [40 CFR 63.7525(a)(6), Minn. R. 7011.7050]

5.18.19 CEMS O&M. The Permittee shall maintain and operate the CO CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the CO CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]




5.18.23 Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 7017.1180, subp. 1]

EQUI 108 MR030 Rotary Lime

Kiln - Opacity

5.19.1 The COMS requirements listed in this permit outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R. 7017.1010]

5.19.2 Opacity: Emissions Monitoring: The Permittee shall use a COMS to measure emissions from EQUI 52 (Rotary Lime Kiln). [40 CFR pt. 60, Subp. BBa, Minn. R. 7017.1006, Minn. R. 7017.1010, subp 1]

5.19.3 NSPS COMS Performance Evaluation: Due before the performance test required under 40 CFR Section 60.8 is conducted as specified in Performance Specification 1, Appendix B of 40 CFR pt. 60. Otherwise, the Permittee shall conduct a performance evaluation of the COMS during any performance test required under Section 60.8 or within 30 days thereafter. The Permittee shall conduct COMS performance evaluations at such other times as may be required by the Administrator under Section 114 of the Clean Air Act. (Provided all applicable deadlines are met, the performance evaluation may be completed at the same time as the Minn. R. required Certification Test.) Sappi completed this requirement on October 16, 2013. [40 CFR 60.13(c), Minn. R. 7017.1010]

5.19.4 NSPS COMS Performance Evaluation Report: Due 10 days before the performance test required under 40 CFR Section 60.8 and as described in Section 60.11(e)(5) if the Permittee elects to submit COMS data In lieu of the performance test to demonstrate compliance with the opacity standard. If instead the performance evaluation is completed during the performance test or within 30 days thereafter as allowed by Section 60.13(c), the report is due within 60 days of completion. [40 CFR 60.13(c)(1) & (2), Minn. R. 7017.1010]

5.19.5 COMS QA/QC. The Permittee is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each COMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.a, 40 CFR pt. 60, Appendix F, Minn. R. 7017.1010]

5.19.6 Installation Notification: due 60 days before installing the continuous Opacity monitoring system. The notification shall include plans and drawings of the system. [Minn. R. 7017.1040, subp. 1]

5.19.7 Monitoring Data: All COMS data must be reduced to six-minute averages. A six minute average is valid only if it contains data from at least five minutes within the averaging period. COMS data shall


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation be reduced and calculated as outlined in Minn. R. 7017.1200, subp. 3. [Minn. R. 7017.1200, subp. 1-3]

5.19.8 Monitoring Data: All COMS data must be reduced to six-minute averages. Six-minute opacity averages shall be calculated from 36 or more data points equally spaced over each 6-minute period. [40 CFR 60.13(e)(1), 40 CFR 60.13(h)(2), Minn. R. 7017.1200, subp. 1-3]


5.19.10 Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]

5.19.11 QA Plan: the facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 - Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R. 7017.1215]

5.19.12 COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low-level) and upscale (high-level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for COMS. [40 CFR 60.13(d)(1), Minn. R. 7017.1210, subp. 2]

5.19.13 COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. [Minn. R. 7017.1220]

5.19.14 COMS Calibration Error Audit Notification: due 30 days before the COMS Calibration Error Audit. [Minn. R. 7017.1180, subp. 2]

5.19.15 Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R. 7017.1130]

5.19.16 Notification of Compliance Status: Due 30 days before


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation performance test required by 40 CFR Section 60.8 if COMS data results will be used in lieu of 40 CFR, Appendix A, Method 9 observation data to determine compliance with the opacity standard as allowed by 40 CFR Section 60.11(e)(5). [40 CFR 60.7(a)(7)]

5.19.17 COMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. [Minn. R. 7017.1050, subp. 1]

5.19.18 The Permittee shall perform zero alignment as described in Procedure 3, section 10.3 of 40 CFR Pt. 60, Appendix F. [40 CFR pt. 60, Appendix B(7), Minn. R. 7017.1215]

EQUI 110 MR043 RB#10 CO2 5.20.1 Carbon Dioxide: Monitoring: The Permittee shall use a CEMS to

measure CO2 diluent gas concentratoin from EQUI 53 (Recovery Boiler #10). [Minn. R. 7017.1010, subp 1]





5.20.6 Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]







- NOx

5.21.1 Nitrogen Oxides: Emissions Monitoring: The Permittee shall use a CEMS to measure NOx emissions from EQUI 18 (Power Boiler #8). [Minn. R. 7017.1010, subp 1]














Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation EQUI 113 MR014 Recovery Boiler

#10 - Opacity

5.22.1 The COMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R. 7017.1010]

5.22.2 Opacity: Emissions Monitoring: The Permittee shall use a COMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFR pt. 60, Subp. BB, Minn. R. 7017.1010, subp 1]



5.22.5 Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R. 7017.1060, subp. 1-3, Minn. R. 7017.1080, subp. 1-4]


5.22.7 QA Plan: the facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 - Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R. 7017.1215]

5.22.8 COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low-level) and upscale (high-level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60,


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation Appendix F, shall be used to determine out-of-control periods for COMS. [40 CFR 60.13(d)(1), Minn. R. 7017.1215]




5.22.12 Notification of Compliance Status: Due 30 days before performance test required by 40 CFR Section 60.8 if COMS data results will be used in lieu of 40 CFR, Appendix A, Method 9 observation data to determine compliance with the opacity standard as allowed by 40 CFR Section 60.11(e)(5). [40 CFR 60.7(a)(7)]



EQUI 114 MR015 Recovery Boiler

#10 - NOx


5.23.2 Nitrogen Oxides: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFR pt. 60, subp. D, Minn. R. 7017.1010, subp 1]











5.23.11 Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), Minn. R. 7017.1130]





#10 - SO2

5.24.1 Sulfur Dioxide: Emissions Monitoring: The Permittee shall use a CEMS to measure SO2 emissions from EQUI 53 (Recovery Boiler #10). [Minn. R. 7017.1010, subp 1]





5.24.6 Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]







#10 - TRS


5.25.2 Sulfur - Total Reduced including H2S: Emissions Monitoring: The owner or operator shall use a CEMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFR pt. 60, subp. BB, Minn. R. 7017.1010, subp 1]


5.25.4 Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R. 7017.1160, subps. 1-2]






5.25.10 CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section 4.3.1 shall be used to determine out-of-control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R. 7017.1170, subp. 3]






#10 - CO

5.26.1 Carbon Monoxide: Emissions Monitoring: The Permittee shall use a CEMS to measure CO emissions from EQUI 53 (Recovery Boiler #10). [Minn. R. 7017.1010, subp 1]




5.26.5 Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation The Test Plan and Test Report must be submitted in a format specified by the commissioner. [Minn. R. 7017.1060, subp. 1-3, Minn. R. 7017.1080]








#10 - O2


5.27.2 Oxygen: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFR pt. 60, subp. BB, Minn. R. 7017.1010, subp 1]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.27.3 Installation Notification: due 60 days before installing the

continuous emissions monitoring system. The notification shall include plans and drawings of the system. [Minn. R. 7017.1040, subp. 1]






5.27.9 CEMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F]







- SO2

5.28.1 Sulfur Dioxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 2 (Power Boiler #7). [Minn. R. 7017.1010, subp 1]



5.28.4 CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation Minn. R. 7017.1050, subp. 2. [Minn. R. 7017.1050, subp. 1]









Kiln - TRS

5.29.1 The CEMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R. 7017.1010]

5.29.2 Sulfur - Total Reduced including H2S: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 52 (Rotary Lime Kiln). [40 CFR pt. 60, subp. BBa, Minn. R. 7017.1010, subp 1]






5.29.8 QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation at the facility unless the Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR pt. 60, Appendix F, 3, Minn. R. 7017.1170, subp. 2]








Kiln - O2


5.30.2 Oxygen: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 52 (Rotary Lime Kiln). [40 CFR pt. 60, subp. BBa, Minn. R. 7017.1010, subp 1]


5.30.4 Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R. 7017.1160, subps. 1-2]






5.30.10 CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation zero and span must, at a minimum, be adjusted whenever the drift exceeds two times the limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section 4.3.1 shall be used to determine out-of-control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R. 7017.1170, subp. 3]






- O2


5.31.2 Oxygen: Monitoring: The owner or operator shall use a CEMS to measure O2 diluent gas concentration from EQUI 2 (Power Boiler #7). [40 CFR pt. 63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1006, Minn. R. 7017.1010, subp 1]




5.31.6 Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]




5.31.10 Emissions Monitoring: The Permittee shall use an oxygen CEMS to measure oxygen emissions from EQUI2. [40 CFR pt. 63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1006]

5.31.11 The Permittee must install, certify, operate and maintain continuous emission monitoring systems for oxygen according to the procedures in 40 CFR Section 63.7525(a)(1)-(7). [40 CFR 63.7525(a), Minn. R. 7011.7050]

5.31.12 The Permittee must install, certify, operate, and maintain an oxygen analyzer according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the site-specific monitoring plan developed according to 40 CFR Section 63.7505(d), and the requirements in 40 CFR Sections 63.7540(a)(8) and 63.7525(a). [40 CFR 63.7525(a)(2), Minn. R. 7011.7050]


5.31.14 CEMS O&M. The Permittee shall maintain and operate the oxygen


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the oxygen CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]






- CO


5.32.2 Carbon Monoxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 2 (Power Boiler #7). [40 CFR pt. 63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1006, Minn. R. 7017.1010, subp 1]




5.32.6 Continuous Operation: CEMS must be operated and data recorded


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]




5.32.10 The Permittee must install, certify, operate and maintain a continuous emission monitoring system for CO according to the procedures in 40 CFR Section 63.7525(a)(1)-(7). [40 CFR 63.7525(a), Minn. R. 7011.7050]


5.32.12 Install the CO CEMS by January 31, 2016. The CO and oxygen levels shall be monitored at the same location at the outlet of the boiler. [40 CFR 63.7525(a)(1)]

5.32.13 The Permittee must install, certify, operate, and maintain a CO CEMS according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the Site-Specific Monitoring Plan developed according to 40 CFR Section


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 63.7505(d), and the requirements in 40 CFR Sections 63.7540(a)(8) and 63.7525(a). Any boiler that has a CO CEMS that is compliant with Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, a Site-Specific Monitoring Plan developed according to 40 CFR Section 63.7505(d), and the requirements in in 40 CFR Sections 63.7540(a)(8) and 63.7525(a) must use the CO CEMS to comply with the applicable alternative CO CEMS emission standard listed in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR 63.7525(a)(2), Minn. R. 7011.7050]

5.32.14 The Permittee must install, certify, operate, and maintain the CO CEMS according to the following requirements: - The Permittee must conduct a performance evaluation of each CO CEMS according to the requirements in 40 CFR Section 63.8(e) and according to Performance Specification 4, 4A, or 4B at 40 CFR part 60, Appendix B. - During each relative accuracy test run of the CO CEMS, the Permittee must collect emission data for CO concurrently (or within a 30- to 60-minute period) by both the CO CEMS and by EPA Reference Method 10, 10A, or 10B. The relative accuracy testing must be at representative operating conditions. - The Permittee must follow the quality assurance procedures of Procedure 1 of 40 CFR pt. 60, Appendix F. The measurement span value of the CO CEMS must be two times the applicable CO emission limit, expressed as a concentration. - Any CO CEMS that does not comply with 40 CFR Section 63.7525(a) cannot be used to meet any requirement in 40 CFR pt. 63, subp. DDDDD to demonstrate compliance a CO emission limit listed in 40 CFR pt. 63, subp. DDDDD, Table 2. - Complete the initial performance evaluation no later than July 29, 2016. [40 CFR 63.7525(a)(2)(i)-(v), Minn. R. 7011.7050]


5.32.16 Reduce the CO CEMS data as specified in 40 CFR Section 63.8(g)(2). [40 CFR 63.7525(a)(4), Minn. R. 7011.7050]

5.32.17 Calculate one-hour arithmetic averages, corrected to 3 percent oxygen from each hour of CO CEMS data in parts per million CO concentration. The one-hour arithmetic averages required shall be used to calculate the 30-day or 10-day rolling average emissions. Use Equation 19-19 in Section 12.4.1 of Method 19 of 40 CFR pt. 60, Appendix A-7 for calculating the average CO concentration from the hourly values. [40 CFR 63.7525(a)(5), Minn. R. 7011.7050]

5.32.18 For purposes of collecting CO data, operate the CO CEMS as specified in 40 CFR Section 63.7535(b). The Permittee must use all the data collected during all periods in calculating data averages


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation and assessing compliance, except that the Permittee must exclude certain data as specified in 40 CFR Section 63.7535(c). Periods when CO data are unavailable may constitute monitoring deviations as specified in 40 CFR Section 63.7535(d). [40 CFR 63.7525(a)(6), Minn. R. 7011.7050]

5.32.19 CEMS O&M. The Permittee shall maintain and operate the CO CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the CO CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]






- Opacity

5.33.1 The COMS requirements listed below outline the typical standards of 40 CFR pt. 63 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R. 7017.1010]

5.33.2 Emissions Monitoring: The Permittee shall use a continuous opacity monitor to measure opacity emissions from EQUI2 (Power Boiler #7). [40 CFR pt. 63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1006]

5.33.3 Each COMS must be installed, operated, and maintained according to Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR 63.7525(c)(1), Minn. R. 7011.7050]

5.33.4 The Permittee must conduct a performance evaluation of each COMS according to the requirements in 40 CFR Section 63.8(e) and according to Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR 63.7525(c)(2), Minn. R. 7011.7050]

5.33.5 As specified in 40 CFR Section 63.8(c)(4)(i), each COMS must complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data recording


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation for each successive 6-minute period. [40 CFR 63.7525(c)(3), Minn. R. 7011.7050]

5.33.6 The COMS data must be reduced as specified in 40 CFR Section 63.8(g)(2). [40 CFR 63.7525(c)(5), Minn. R. 7011.7050]

5.33.7 The Permittee must include in the Site-Specific Monitoring Plan procedures and acceptance criteria for operating and maintaining each COMS according to the requirements in 40 CFR Section 63.8(d). At a minimum, the monitoring plan must include a daily calibration drift assessment, a quarterly performance audit, and an annual zero alignment audit of each COMS. [40 CFR 63.7525(c)(5), Minn. R. 7011.7050]

5.33.8 The Permittee must operate and maintain each COMS according to the requirements in the monitoring plan and the requirements of 40 CFR Section 63.8(e). The Permittee must identify periods the COMS is out of control including any periods that the COMS fails to pass a daily calibration drift assessment, a quarterly performance audit, or an annual zero alignment audit. Any 6-minute period for which the monitoring system is out of control and data are not available for a required calculation constitutes a deviation from the monitoring requirements. [40 CFR 63.7525(c)(6), Minn. R. 7011.7050]

5.33.9 The Permittee must determine and record all the 6-minute averages (and daily block averages as applicable) collected for periods during which the COMS is not out of control. [40 CFR 63.7525(c)(7), Minn. R. 7011.7050]

5.33.10 COMS O&M. The Permittee shall maintain and operate the COMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the COMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]


5.33.12 Monitoring Data: All COMS data must be reduced to six-minute averages. A six minute average is valid only if it contains data from at least five minutes within the averaging period. COMS data shall be reduced and calculated as outlined in Minn. R. 7017.1200, subp. 3. [Minn. R. 7017.1200, subp. 1-3]


5.33.14 Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]

5.33.15 QA Plan: The facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 - Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R. 7017.1215]

5.33.16 COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low-level) and upscale (high-level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for COMS. [Minn. R. 7017.1215]





5.33.21 The Permittee shall perform zero alignment as described in Procedure 3, section 10.3 of 40 CFR Pt. 60, Appendix F. [Minn. R. 7017.1215]


- Opacity

5.34.1 The COMS requirements listed below outline the typical standards of 40 CFR pt. 60 and 40 CFR pt. 63 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R. 7017.1010]

5.34.2 Opacity: Emissions Monitoring: The Permittee shall use a COMS to


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 60, Subp. D, Minn. R. 7017.1010, subp 1]

5.34.3 Emissions Monitoring: The Permittee shall use a continuous opacity monitor to measure opacity emissions from EQUI4. [40 CFR pt. 63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1006]

5.34.4 Each COMS must be installed, operated, and maintained according to Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR 63.7525(c)(1), Minn. R. 7011.7050]

5.34.5 The Permittee must conduct a performance evaluation of each COMS according to the requirements in 40 CFR Section 63.8(e) and according to Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR 63.7525(c)(2), Minn. R. 7011.7050]

5.34.6 As specified in 40 CFR Section 63.8(c)(4)(i), each COMS must complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data recording for each successive 6-minute period. [40 CFR 63.7525(c)(3), Minn. R. 7011.7050]

5.34.7 The COMS data must be reduced as specified in 40 CFR Section 63.8(g)(2). [40 CFR 63.7525(c)(5), Minn. R. 7011.7050]

5.34.8 The Permittee must include in the Site-Specific Monitoring Plan procedures and acceptance criteria for operating and maintaining each COMS according to the requirements in 40 CFR Section 63.8(d). At a minimum, the monitoring plan must include a daily calibration drift assessment, a quarterly performance audit, and an annual zero alignment audit of each COMS. [40 CFR 63.7525(c)(5), Minn. R. 7011.7050]

5.34.9 The Permittee must operate and maintain each COMS according to the requirements in the monitoring plan and the requirements of 40 CFR Section 63.8(e). The Permittee must identify periods the COMS is out of control including any periods that the COMS fails to pass a daily calibration drift assessment, a quarterly performance audit, or an annual zero alignment audit. Any 6-minute period for which the monitoring system is out of control and data are not available for a required calculation constitutes a deviation from the monitoring requirements. [40 CFR 63.7525(c)(6), Minn. R. 7011.7050]

5.34.10 The Permittee must determine and record all the 6-minute averages (and daily block averages as applicable) collected for periods during which the COMS is not out of control. [40 CFR 63.7525(c)(7), Minn. R. 7011.7050]

5.34.11 COMS O&M. The Permittee shall maintain and operate the COMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the COMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]

5.34.12 COMS QA/QC. The Permittee is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each COMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F, Minn. R. 7017.1010]


5.34.14 Monitoring Data: All COMS data must be reduced to six-minute averages. A six minute average is valid only if it contains data from at least five minutes within the averaging period. COMS data shall be reduced and calculated as outlined in Minn. R. 7017.1200, subp. 3. [Minn. R. 7017.1200, subp. 1-3]




5.34.18 QA Plan: The facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 - Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R. 7017.1215]

5.34.19 COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low-level) and upscale (high-level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out-of-control periods for COMS. [40 CFR 60.13(d)(1), Minn. R. 7017.1215]

5.34.20 COMS Calibration Error Audit Results Summary: due 30 days after


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation end of each calendar quarter in which the COMS calibration error audit was completed. [Minn. R. 7017.1220]



5.34.23 Notification of Compliance Status: Due 30 days before performance test required by 40 CFR Section 60.8 if COMS data results will be used in lieu of 40 CFR, Appendix A, Method 9 observation data to determine compliance with the opacity standard as allowed by 40 CFR Section 60.11(e)(5). [40 CFR 60.7(a)(7)]




- NOx


5.35.2 Nitrogen Oxides: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 60, subp. D, Minn. R. 7017.1010, subp 1]



5.35.5 CEMS Certification/Recertification Test: due 90 days after the first


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. [40 CFR 60.13(b), Minn. R. 7017.1050, subp. 1]








Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.35.12 CEMS Monitor Design: Each CEMS shall be designed to complete a

minimum of one cycle of sampling, analyzing, and data recording in each 15-minute period. [40 CFR 60.13(e)(2)]




- O2

5.36.1 Oxygen: Monitoring: The Permittee shall use a CEMS to measure O2 diluent gas concentration from EQUI 18 (Power Boiler #8). [Minn. R. 7017.1010, subp 1]




5.36.5 Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report - Microfiche Copy due 105 days after Certification Test. Certification Test Report due 45 days after Certification Test. The Notification, Test Plan, and Test Report may be submitted in alternate format as allowed by Minn. R. 7017.1120, subp. 2. [Minn. R. 7017.1060, subp. 1-3, Minn. R. 7017.1080, subp. 1-4]

5.36.6 Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start-up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether or not a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]






EQUI 261 927 Methanol /

14600 / EU017

5.37.1 Methanol <= 0.28 tons per year (tank is equipped with a conservation vent). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

5.37.2 Inspection: due before end of each calendar quarter starting 9/25/1998. The Permittee shall inspect the conservation vent on a quarterly basis to ensure that the vent is working properly. The results of the inspection shall be recorded and maintained on site. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI 290 EU089 R&D Boiler 5.38.1 Total Particulate Matter <= 0.4 pounds per million Btu heat input.

The potential to emit from the unit is 0.007 lb/MMBtu due to equipment design and allowable fuels. [Minn. R. 7011.0515, subp. 1]

5.38.2 Opacity <= 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0515,


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation subp. 2]

5.38.3 Allowable Fuel: Natural Gas only, by design. [Minn. R. 7005.0100, subp. 35a]


5.38.5 Tune-Ups. The Permittee must conduct a 5-year tune-up of the boiler to demonstrate continuous compliance as specified in 40 CFR Section 63.7540(a)(10)(i)-(vi). Each 5-year tune-up must be conducted no more than 61 months after the previous tune-up. The Permittee may delay the burner inspection specified in 40 CFR Section 63.7540(a)(10)(i) until the next scheduled or unscheduled unit shutdown, but the Permittee must inspect each burner at least once every 72 months. [40 CFR 63.7500(e), 40 CFR 63.7515(d), 40 CFR 63.7540(a)(12), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]


EQUI 298 EU049 #4 Paper

Machine



5.39.3 The Permittee shall perform proper maintenance of the paper machine so as to prevent excessive amounts of particulate matter from being emitted from the associated stack/vent (STRU49). [Minn. R. 7007.0800, subp. 4]

EQUI 299 EU050 #12 Paper

Machine



5.40.3 The Permittee shall perform proper maintenance of the paper machine so as to prevent excessive amounts of particulate matter from being emitted from the associated stack/vent (STRU50). [Minn. R. 7007.0800, subp. 4]

EQUI 304 EU051 #13 Coater 5.41.1 The Permittee must limit organic HAP emissions to the level

specified below:


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation - No more than 5 percent of the organic HAP applied for each month; or - No more than 4 percent of the mass of coating materials applied for each month; or - No more than 20 percent of the mass of coating solids applied for each month. These limits apply to the collection of all web coating lines (as defined in 40 CFR 63.3310). [40 CFR 63.3320(b)(1)-(3), Minn. R. 7011.7358]

5.41.2 Maintain the following records as applicable on a monthly basis as specified in 40 CFR Sect. 63.10(b)(2) of all measurements as needed to demonstrate compliance, including: 1. Continuous emission monitor data in accordance with 40 CFR Sect. 63.3350(d); 2. Control device and capture system operating parameter data in accordance with 40 CFR Sect. 63.3350(c), (e), & (f); 3. Organic HAP content data used for demonstrating compliance in accordance with 40 CFR Sect. 63.3360(c); 4. Volatile matter and coating solids content data used for demonstrating compliance with 40 CFR Sect. 63.3360(d); 5. Overall control efficiency determination using capture efficiency and control device destruction or removal efficiency test results in accordance with 40 CFR Sect. 63.3350(e) & (f); 6. Material usage, organic HAP usage, volatile matter usage, and coating solids usage and compliance demonstrations using these data in accordance with 40 CFR Sect. 63.3370(b)-(d). [40 CFR 63.10(b)(1), 40 CFR 63.3410(a), Minn. R. 7011.7385]

5.41.3 Determine the organic HAP or volatile matter and coating solids content of the coating materials according to procedures in 40 CFR Section 63.3360(c) & (d). If applicable, determine the mass of volatile matter retained in the coated web or otherwise not emitted to the atmosphere according to 40 CFR Section 63.3360(g). [40 CFR 63.3360(a), Minn. R. 7011.7385]

5.41.4 Determine the organic HAP mass fraction of each coating material "as-purchased" by following one of the procedures (Method 311, Method 24, or Formulation Data) in 40 CFR Section 63.3360(c)(1)-(3), and determine the organic HAP mass fraction of each coating material "as-applied" by following the procedures in 40 CFR Section 63.3360(c)(4). If the organic HAP content values are not determined using the procedures in 40 CFR Section 63.3360(c)(1)-(3), the Permittee must submit an alternative test method for determining the values for approval by the Administrator in accordance with 40 CFR Section 63.7(f). The recovery efficiency of the test method must be determined for all of the target organic HAP and a correction factor, if necessary, must be applied. [40 CFR 63.3360(c), Minn. R. 7011.7385]

5.41.5 If you choose to use the volatile organic content as a surrogate for the organic HAP content of coatings, you must determine the as-


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation purchased volatile organic content and coating solids content of each coating material applied by following the procedures (Method 24 or Formulation Data) in 40 CFR Section 63.3360(d)(1) or (2), and the as-applied volatile organic content and coating solids content of each coating material by following the procedures of 40 CFR Section 63.3360(d)(3). [40 CFR 63.3360(d), Minn. R. 7011.7385]

5.41.6 Volatile matter retained in the coated web or otherwise not emitted to the atmosphere - If you choose to take this into account when determining compliance with the emission standards, you must develop a testing protocol to determine the mass of volatile matter retained in the coated web or otherwise not emitted to the atmosphere and submit it to the Administrator for approval with your site-specific test plan under 40 CFR Section 63.7(f). If you intend to take into account the mass of volatile matter retained in the coated web after curing or drying or otherwise not emitted to the atmosphere and demonstrate compliance according to 40 CFR Section 63.3370(c)(3), (c)(4), or (d), then the protocol must determine the mass of organic HAP retained in the coated web or otherwise not emitted to the atmosphere. Otherwise, compliance must be shown using the volatile organic matter content as a surrogate for the HAP content of the coatings. [40 CFR 63.3360(g), Minn. R. 7011.7385]

5.41.7 Demonstrate compliance by one of the following methods: 1. Use of "as-purchased" compliant coating materials 2. Use of "as-applied" compliant coating materials 3. Tracking total monthly organic HAP applied 4. Use of a capture system and control device. [40 CFR 63.3370(a), Minn. R. 7011.7385]

5.41.8 1. Demonstrate, using the procedures in 40 CFR Section 63.3370(b), that each coating material used does not exceed: - 0.04 kg organic HAP per kg coating material as purchased; or - 0.2 kg organic HAP per kg coating solids as purchased. [40 CFR 63.3370(a)(1)&(b), Minn. R. 7011.7358]

5.41.9 2. Demonstrate that each coating material as-applied during the month does not exceed: - 0.04 kg organic HAP per kg coating material applied, as determined in accordance with 40 CFR Section 63.3370(c)(1)(i) & (ii); or - 0.20 kg organic HAP per kg coating solids applied, as determined in accordance with 40 CFR Section 63.3370(c)(2)(i) & (ii); or Demonstrate that the monthly average as-applied organic HAP content of all coating materials applied does not exceed: - 0.04 kg organic HAP per kg coating material as-applied, as determined in accordance with 40 CFR Section 63.3370(c)(3); or - 0.20 kg organic HAP per kg coating solids as-applied, as determined in accordance with 40 CFR Section 63.3370(c)(4). [40 CFR 63.3370(a)(2) & (c), Minn. R. 7011.7385]

5.41.10 3. Demonstrate that the total monthly organic HAP applied does not exceed the calculated limit as determined by 40 CFR Section


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 63.3370(l)(5), in accordance with the procedures set out in 40 CFR Section 63.3370(d). [40 CFR 63.3370(a)(3), (d) & (l), Minn. R. 7011.7358]

EQUI 315 EU085 Emergency

Diesel Fire Water Pump

5.42.1 Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R. 7011.2300, subp. 1]

5.42.2 Sulfur Dioxide <= 0.50 pounds per million Btu heat input. The potential to emit from the unit is 0.0015 lb/MMBtu due to equipment design and allowable fuel. [Minn. R. 7011.2300, subp. 2(A)]

5.42.3 Sulfur Dioxide <= 0.0015 pounds per million Btu heat input. This limit is effective on January 31, 2018. [Minn. R. 7011.2300, subp. 2(B)]

5.42.4 The Permittee shall limit Particulate Matter <= 0.60 grams per horsepower-hour. [40 CFR 60.4205(c), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

5.42.5 The Permittee shall limit NMHC+NOx <= 7.8 grams per horsepower-hour. [40 CFR 60.4205(c), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

5.42.6 The Permittee shall limit Carbon Monoxide <= 3.7 grams per horsepower-hour. [40 CFR 60.4205(c), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

5.42.7 Fuel type: Ultra-Low-Sulfur #2 Fuel Oil only. [Minn. R. 7005.0100, subp. 35a]

5.42.8 Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6, 1995, limiting operation to 500 hours per year. [Minn. R. 7007.0800, subps. 4-5]


5.42.10 The Permittee shall operate and maintain the stationary CI ICE in accordance with the emission standards as required in Sections 60.4204 and 60.4205, and according to the manufacturer's written instructions or procedures developed by the Permittee that are approved by the engine manufacturer, over the entire life of the engine. The Permittee many only change those settings that are permitted by the manufacturer. [40 CFR 60.4206, 40 CFR 60.4211(a), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

5.42.11 The Permittee shall limit Sulfur Content of Fuel <= 15.0 parts per million and either a minimum cetane index of 40 or a maximum aromatic content of 35 percent by volume, as required by 40 CFR Section 80.510(b). [40 CFR 60.4207(b), 40 CFR 63.6590(c), Minn. R.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 7011.2305, Minn. R. 7011.8150]

5.42.12 EQUI 315 is a new affected source as defined under 40 CFR pt. 63, subp. ZZZZ, the facility is a major source as defined at 40 CFR Section 63.2, and EQUI 315 is a compression ignition (CI) stationary RICE with a site rating of less than or equal to 500 brake HP. The Permittee shall meet the requirements of 40 CFR pt. 63, subp. ZZZZ by meeting the requirements of 40 CFR pt. 60, subp. IIII. No further requirements of 40 CFR pt. 63, subp. ZZZZ apply to EQUI 315. [40 CFR 63.6590(c)(7), Minn. R. 7011.8150]

5.42.13 The Permittee must install a non-resettable hour meter prior to startup of the emergency engine. [40 CFR 60.4209(a), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

5.42.14 The Permittee must demonstrate compliance with the emissions standards of 40 CFR Section 60.4205(c) according to one of the following methods: (1) Purchase an engine certified according to 40 CFR Part 89 or 94, as applicable, for the same model year and maximum engine power. The engine must be installed and configured according the manufacturer's specifications. (2) Keep record of the performance test for each pollutant for a test conducted on a similar engine. The test must have been conducted using the same methods specified in 40 CFR pt. 60, subp. IIII, and must have been followed correctly. (3) Keep records of engine manufacturer data indicating compliance with the standards. (4) Keep records of control device vendor data indicating compliance with the standards. (5) Conduct an initial performance test to demonstrate compliance with the emission standards according to the requirements specified in 40 CFR Section 60.4212. [40 CFR 60.4211(b), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

5.42.15 The Permittee may conduct maintenance checks and readiness testing provided that the tests are recommended by Federal, State, or local government; the manufacturer; the vendor; or the insurance company associated with the engine. Maintenance checks and readiness testing are limited to 100 hours/year. There is no time limit on the use of emergency stationary ICE in emergency situations unless otherwise prohibited by the permit. The Permittee may petition the Administrator for approval of additional hours. A petition is not required if the Permittee maintains records indicating that the Federal, State or local standards require maintenance and testing beyond 100 hours/year. Any other operation other than emergency operation, and maintenance and testing as permitted in this section, is prohibited. [40 CFR 60.4211(f), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

5.42.16 If the emergency engine does not meet the standards applicable to non-emergency engines in the applicable model year, the Permittee must keep records of the operation of the engine in


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation emergency and non-emergency service that are recorded through the non-resettable hour meter. The Permittee must record the time of operation of the engine and the reason the engine was in operation during that time. [40 CFR 60.4214(b), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

5.42.17 The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. [40 CFR 60.7(a)(4), 40 CFR 63.6590(c), Minn. R. 7011.8150, Minn. R. 7019.0100, subp. 1]

5.42.18 Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), 40 CFR 63.6590(c), Minn. R. 7011.8150, Minn. R. 7019.0100, subp. 1]

5.42.19 Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two years. [40 CFR 60.7(f), 40 CFR 63.6590(c), Minn. R. 7007.0800, subp. 5(C), Minn. R. 7011.8150, Minn. R. 7019.0100, subp. 1]

5.42.20 No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, 40 CFR 63.6590(c), Minn. R. 7011.0050, Minn. R. 7011.8150]

5.42.21 Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to: (1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere; or (2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. [40 CFR 63.4(b), Minn. R. 7011.7000]

5.42.22 Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. [40 CFR 63.10(b)(1), Minn. R. 7019.0100, subp. 2(B)]

5.42.23 The Permittee shall maintain, at a minimum, the following information in the files:


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 1) each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative; 2) all required measurements needed to demonstrate compliance with a relevant standard; 3) all results of performance test, CMS performance evaluations, and opacity and visible emission observations; 4) all measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 5) all CMS calibration checks; 6) all adjustments and maintenance performed on CMS; 7) any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 8) All emission levels relative to the criterion for obtaining permission to use an alternative to the relative accuracy test, if the source has been granted such permission under 40 CFR 63.8(f)(6); and 9) all documentation supporting initial notifications and notifications of compliance status. [40 CFR 63.10(b)(2), Minn. R. 7019.0100, subp. 2(B)]

5.42.24 Prior to construction or reconstruction of a major-emitting "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit. [40 CFR 63.5(b)(3)& Minn. R. 7011.7000]

5.42.25 After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, the Permittee who constructs a new affected source that is not major-emitting or reconstructs an affected source that is not major-emitting that is subject to such standard, or reconstructs a source such that the source becomes an affected source subject to the standard, must notify the Administrator of the intended construction or reconstruction. The notification must be submitted in accordance with the procedures in 40 CFR Section 63.9(b). [40 CFR 63.5(b)(4)& Minn. R. 7011.7000]

5.42.26 After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source. [40 CFR 63.5(b), Minn. R. 7011.7000]

EQUI 316 Chip

Presteaming Bin

5.43.1 The Permittee is authorized to construct EQUI316. The construction authorization expires if construction does not commence within 18 months after Issuance of Air Emissions Permit No.01700002-101, if construction is discontinued for a


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation period of 18 months or more, or if construction is not completed within a reasonable time. [40 CFR 52.21(r)(2)]



FUGI 2 EU087 Existing Cooling

Tower - zFugative

5.44.1 Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

5.44.2 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)] FUGI 6 FS008 Paved Roads 5.45.1 Fugitive Emissions: Do not cause or permit the handling, use,

transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. [Minn. R. 7011.0150]

5.45.2 Speed Limits: Not to exceed 5 miles per hour (mph) on the scale road (Segment A) or 15 mph on the paved road encompassing the roundwood storage yards (Segments F, G, H, I, J, and K). See figure in Appendix C. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

5.45.3 Modeled Silt Load Limit (grams/square meter [g/m2]): Segment A: 0.808 g/m2 The limit is the silt loading value for the listed segment from the MPCA's Standardized Air Modeling (SAM) spreadsheet, column AF. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

5.45.4 Silt Load Testing: As requested by the MPCA, the facility shall conduct separate on-site silt load testing for the paved road segment listed above (Modeled Silt Load Limit), in accordance with a performance test plan approved by the MPCA. Silt load tests shall be conducted in accordance with EPA guidance in Appendices C-1 and C-2 of AP-42. The Permittee shall keep records of all silt load testing. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation R. 7007.3000, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

5.45.5 The Permittee must conduct sweeping of FUGI6 in accordance with the approved Fugitive Dust Control Plan. [Minn. R. 7007.0800, subp. 2]

FUGI 7 FS005 Unpaved Roads 5.46.1 Chemical Dust Suppression:

At least once per month during May, June, July, August, and September of each calendar year, a chemical dust suppressant shall be applied to the travel routes at a rate of at least 0.17 gallons per square yard. Additional applications of chemical dust suppressant shall be made in other months as necessary. The travel routes must also be watered at least once between each chemical dust suppressant application, to reactivate the chemical dust suppressant. Additional waterings shall be performed as necessary. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

5.46.2 The Permittee shall regularly observe travel routes for traffic in the unpaved areas to determine if there is excessive spillage of dust that could become airborne, and if so, take steps to control fugitive emissions, including watering and/or the use of a calcium chloride solution or other chemical dust suppression, as described above. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

TREA 6 CE030 Recovery Boiler

#10 - Ventri-Rod Scrubber

5.47.1 The Permittee shall vent emissions from EQUI51 to TREA6 whenever EQUI51 operates, and operate and maintain TREA6 at all times that any emissions are vented to TREA6. The Permittee shall document periods of non-operation of the control equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.47.2 The Permittee shall operate and maintain the scrubber in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.47.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 94 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.47.4 The Permittee shall operate and maintain control equipment such


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation that it achieves a control efficiency for PM < 10 micron >= 84 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.47.5 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 84 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.47.6 Pressure Drop >= 3 and <= 9 inches of water column unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.47.7 Liquid Flow Rate >= 300 gallons per minute unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. The Liquid Flow Rate limit is the combined flow rate for TREA12 and TREA6. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.47.8 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop and liquid flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation. [Minn. R. 7007.0800, subp. 4]

5.47.9 Recordkeeping of Pressure Drop: The Permittee shall maintain a continuous hard copy readout or computer disk file of the pressure drop for TREA6. [Minn. R. 7007.0800, subps. 4-5]

5.47.10 Recordkeeping of Liquid Flow Rate. The Permittee shall maintain a continuous hard copy readout or computer disk file of the liquid flow rate for TREA6. [Minn. R. 7007.0800, subps. 4-5]

5.47.11 Daily Monitoring: The Permittee shall physically check the pressure drop and supply liquid flow rate recording devices at least once each operating day to verify that they are working and recording properly. [Minn. R. 7007.0800, subps. 4-5]

5.47.12 Control Equipment Monitoring: Once each operating day, observe and record the pressure drop across TREA6. The record shall include the time and date of the reading and whether or not it was within the range specified by this permit. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.47.13 Quarterly Inspections: At least once per calendar quarter, or more


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation frequently if required by the manufacturer, the Permittee shall inspect the control equipment components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

5.47.14 Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

5.47.15 Annual Calibration: The Permittee shall calibrate the liquid flow rate and pressure drop gauges at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7007.0800, subp. 14]

5.47.16 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the recorded pressure drop is outside the required operating range; or - the recorded liquid flow rate is outside the required operating range; or - the scrubber or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop and/or liquid flow rate to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the scrubber. The Permittee shall keep a record of the type and date of any corrective action taken for the scrubber. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4-5]

TREA 12 CE017 Smelt

Dissolving Tank - Spray Tower

5.48.1 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 95 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.48.2 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 84


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.48.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 80 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.48.4 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Sulfur - Total Reduced including H2S >= 98 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.48.5 Pressure Drop <= 0 inches of water column. A negative draft must be present for TREA12 properly operate. [40 CFR 64.3(a), Minn. R. 7007.0800, subp. 14, Minn. R. 7017.0200]

5.48.6 Water pressure >= 10 and <= 20 psi (gauge) (Liquid Supply Pressure) unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded water pressure is outside the required range, this shall be reported as a deviation. [40 CFR 64.3(a), Minn. R. 7007.0800, subp. 14, Minn. R. 7017.0200]

5.48.7 Liquid Flow Rate >= 300 gallons per minute unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded scrubber liquid flow rate is outside the required range, this shall be reported as a deviation. The Liquid Flow Rate limit is the combined flow rate for TREA12 and TREA6. [40 CFR 64.3(a), Minn. R. 7007.0800, subp. 14, Minn. R. 7017.0200]

5.48.8 Pressure Drop >= 3 and <= 9 inches of water column unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.48.9 Install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the scrubbing liquid supply pressure to the control equipment. The monitoring device is to be


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation certified by the manufacturer to be accurate within +/- 15 percent of design scrubbing liquid supply pressure. The pressure sensor or tap is to be located close to the scrubber liquid discharge point. The monitoring device shall be operational upon startup of the control equipment which is to be operational upon startup of Recovery Boiler #10. [40 CFR 60.284(b)(2)(ii), 40 CFR 64.7(a), Minn. R. 7011.2450, Minn. R. 7017.0200]

5.48.10 Liquid Flow Rate >= 300 gallons per minute unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. The Liquid Flow Rate limit is the combined flow rate for TREA12 and TREA6. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.48.11 Install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the pressure loss of the gas stream through the control equipment. The monitoring device is to be certified by the manufacturer to be accurate to within a gage pressure of +/- 2 inches water gage pressure. The monitoring device shall be operational upon startup of the control equipment which is to be operational upon startup of Recovery Boiler #10. [40 CFR 60.284(b)(2)(i), 40 CFR 64.7(a), Minn. R. 7011.2450, Minn. R. 7017.0200]

5.48.12 Record once per shift, measurements obtained from the monitoring device for the continuous measurement of the pressure loss of the gas stream through the control equipment and from the monitoring device for the continuous measurement of the scrubbing liquid supply pressure to the control equipment. This requirement is met through recordkeeping provided by continuous measurement devices for the control equipment. The Permittee shall maintain a continuous hard copy readout or computer disk file of the pressure drop of the gas stream and scrubbing liquid supply pressure and calculated eight-hour rolling average for the control equipment. [40 CFR 60.284(c)(4), Minn. R. 7011.2450]

5.48.13 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop and liquid flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation. [Minn. R. 7007.0800, subp. 4]

5.48.14 Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permittee shall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. [40 CFR 64.3, Minn. R. 7017.0200]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.48.15 Corrective Actions: The Permittee shall take corrective action as

soon as possible if any of the following occur: - the recorded liquid supply pressure is outside the required operating range; or - the recorded water flow rate is outside the required operating range; or - the recorded pressure drop is outside the required operating range; or - the spray tower or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop and/or water flow rate and/or liquid supply pressure to within the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the spray tower. The Permittee shall keep a record of the type and date of any corrective action taken for the filter. [40 CFR 64.7(d)(1), Minn. R. 7017.0200]

5.48.16 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressure drop, water flow rate, and water supply pressure as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation. [40 CFR 64.7(b), Minn. R. 7017.0200]

5.48.17 The Permittee shall calibrate the gauges at least once every 12 months and shall maintain a written record of any action resulting from the calibration. [40 CFR 64.3, Minn. R. 7017.0200]

5.48.18 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R. 7017.0200]

5.48.19 As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report listed in Section 6 of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Section 6 of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

5.48.20 The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm,


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R. 7017.0200]

TREA 15 CE003 Power Boiler #7

ESP

5.49.1 The Permittee shall vent emissions from EQUI2 (Power Boiler #7) to TREA15 whenever EQUI2 operates, and operate and maintain TREA15 at all times that any emissions are vented to TREA15. The Permittee shall document periods of non-operation of the control equipment TREA15 whenever EQUI2 is operating. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.49.2 If the Permittee replaces TREA15, the replacement control must meet or exceed the control efficiency requirements of TREA15 as well as comply with all other requirements of TREA15. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.49.3 ESP monitoring: The COMS (EQUI102) for the emission unit (EQUI2) shall be used to assess proper operation of this ESP. [40 CFR 64.7(a), Minn. R. 7007.0800, subp. 2, Minn. R. 7017.0200]

5.49.4 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing opacity limit, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R. 7017.0200]

5.49.5 As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

5.49.6 The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm,


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R. 7017.0200]

5.49.7 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.49.8 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.49.9 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.49.10 The Permittee shall operate and maintain the electrostatic precipitator (ESP) in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.49.11 Opacity <= 10.0 percent opacity 3-hour rolling average. Opacity in excess of this limit shall be considered an excursion under 40 CFR Section 64.6(c)(2). [40 CFR 64.3, Minn. R. 7017.0200]

5.49.12 Opacity: Continuous Monitoring: The Permittee shall continuously, or at a minimum once every 15 minutes, monitor the opacity of the ESP exhaust. See Subject Item EQUI102 for specific COMS operating requirements. [40 CFR 64.3(b)(4)(ii), Minn. R. 7017.0200]

5.49.13 Monitoring Equipment: The necessary monitoring equipment must be installed, in use, and properly maintained, including maintaining the necessary parts for routine repairs of the monitoring equipment, whenever operation of the monitored control equipment is required. [40 CFR 64.7(b), Minn. R. 7017.0200]

5.49.14 Periodic Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

5.49.15 Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 7017.0200]

5.49.16 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the monitored opacity, averaged over any 3-hour period, exceeds 10%; or - the ESP or any of its components are found during the inspections to need repair. Corrective actions shall return operation to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the ESP. The Permittee shall keep a record of the type and date of any corrective action taken for the ESP. [40 CFR 64.7(6), Minn. R. 7017.0200]

TREA 16 CE010 ClO2 Plant

Scrubber

5.50.1 The Permittee shall vent emissions from EQUI301 (Chlorine Dioxide Plant) to TREA16 whenever EQUI301 operates, and operate and maintain TREA16 at all times that any emissions are vented to TREA16. The Permittee shall document periods of non-operation of the control equipment TREA16 whenever EQUI301 is operating. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.50.2 The Permittee shall operate and maintain TREA16 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.50.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Chlorine Dioxide >= 82 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

5.50.4 Pressure Drop >= 0 and <= 5.0 psi (gauge) (gas pressure loss) unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, this shall be reported as a deviation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.50.5 Liquid Flow Rate >= 120 gallons per minute unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, this shall be reported as a deviation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800,


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation subp. 2]

5.50.6 Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording the liquid flow rate and pressure drop, as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when TREA16 is in operation. [Minn. R. 7007.0800, subp. 4]

5.50.7 Control Equipment Monitoring: The Permittee shall maintain a continuous hard copy readout or computer disk file of the liquid supply flow rates for TREA16. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.50.8 Daily Monitoring: The Permittee shall physically check the pressure drop and supply liquid flow rate recording devices at least once each operating day to verify that they are working and recording properly. [Minn. R. 7007.0800, subps. 4-5]

5.50.9 Control Equipment Monitoring: Once each operating day, observe and record the pressure drop across TREA16. The record shall include the time and date of the reading and whether or not it was within the range specified by this permit. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.50.10 Quarterly Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer specifications, the Permittee shall inspect the control equipment internal and external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7007.0800, subp. 14]

5.50.11 Annual Calibration: The Permittee shall calibrate the liquid flow rate and pressure drop gauges at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7007.0800, subp. 14]

5.50.12 Corrective Actions: If the liquid flow rate is below the minimum listed above, or if the pressure drop is outside the specified ranges, or if the control device or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the liquid flow rate and/or pressure drops to the specified limits/ranges and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the condenser. The Permittee shall keep a record of the type and date of any corrective action taken. [Minn. R. 7007.0800, subps. 4-5, Minn. R. 7007.0800, subp. 14]

TREA 17 CE011 Bleach Plant

Scrubber

5.51.1 The Permittee shall vent emissions from EQUI7 (Bleach Plant) to


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation TREA17 whenever EQUI7 operates, and operate and maintain TREA17 at all times that any emissions are vented to TREA17. The Permittee shall document periods of non-operation of the control equipment TREA17 whenever EQUI7 is operating. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

5.51.2 Control Equipment Operation: The Permittee shall operate the gas scrubber in a manner consistent with the minimum or maximum (as appropriate) operating parameter value or procedure required to be monitored under paragraphs (a) - (n) of 40 CFR 63.453 and as described in 40 CFR 63.453(o). Operation of the control device below minimum operating parameter values or above maximum operating parameter values established under 40 CFR pt. 63, subp. S shall constitute a violation of the applicable emission standard of 40 CFR pt. 63, subp. S and shall be reported as a period of excess emissions. [40 CFR 63.453(o), Minn. R. 7011.7700]

5.51.3 Control Equipment Monitoring: The Permittee shall maintain an electronic copy with calculated 8-hour averages for TREA17 of the: - pH or Oxidation Reduction Potential and calculated eight-hour rolling average; - Gas Scrubber Liquid Flow Rate; and - Gas Scrubber Vent Gas Inlet Fan. [40 CFR 63.453(c), Minn. R. 7007.0800, subp. 14, Minn. R. 7011.7700]

5.51.4 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Chlorine Dioxide >= 99 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

5.51.5 pH >= 10.5 (no units) or Oxidation Reduction Potential <= -400 mV; or as determined during the most recent performance test. [40 CFR 63.453(c)(1), (n), & (o), Minn. R. 7007.0800, subp. 4, Minn. R. 7011.7700]

5.51.6 Liquid Flow Rate >= 225 gallons per minute (Gas Scrubber Liquid Rate) or as determined during most recent performance test. [40 CFR 63.453(c)(3), (n), & (o), Minn. R. 7007.0800, subp. 14, Minn. R. 7011.7700]

5.51.7 Gas Scrubber Fan Amperage: >= 33%; or as determined during the most recent performance test. [40 CFR 63.453(c)(2), (n), & (o), Minn. R. 7007.0800, subp. 14, Minn. R. 7011.7700]

5.51.8 CMS for Scrubber: The Permittee shall install, calibrate, certify, operate, and maintain a CMS to measure the following parameters for the gas scrubber: 1. The pH or the oxidation/reduction potential of the gas scrubber effluent; 2. The fan amperage; and 3. The gas scrubber liquid influent flow rate. An option to the CMS requirement above, is to install, calibrate, certify, operate, and maintain a CMS to measure the chlorine outlet concentration of each gas scrubber used to comply with the bleaching system outlet concentration requirement specified in 40 CFR Section 63.445(c)(2). [40 CFR 63.453(a),(c),&(d), Minn. R. 7011.7700]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.51.9 Scrubber Parameter Values: To establish or reestablish the value

for each operating parameter required to be monitored under 40 CFR Section 63.453, the Permittee shall use the procedures described in 40 CFR Section 63.453(n). [40 CFR 63.453(n), Minn. R. 7011.7700]

5.51.10 Corrective Actions: If the monitored parameter is out of the range as described above, the Permittee shall follow the facility O&M Plan and perform the necessary corrective actions) as soon as possible to get the parameters back into the correct range. The Permittee shall keep a record of the type and date of all corrective actions taken. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 5]

TREA 19 CE006 Power Boiler #9

ESP

5.52.1 The Permittee shall vent emissions from EQUI4 (Power Boiler #9) to TREA19 whenever EQUI4 operates, and operate and maintain TREA19 at all times that any emissions are vented to TREA19. The Permittee shall document periods of non-operation of the control equipment TREA19 whenever EQUI4 is operating. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.52.2 If the Permittee replaces TREA19, the replacement control must meet or exceed the control efficiency requirements of TREA19 as well as comply with all other requirements of TREA19. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]



5.52.5 As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration,


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

5.52.6 The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and does not conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R. 7017.0200]

5.52.7 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.52.8 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.52.9 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]







Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.52.15 Annual Inspections: At least once per calendar year, or more

frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]


TREA 20 CE007 Recovery Boiler

#10 ESP

5.53.1 The Permittee shall vent emissions from EQUI53 (Recovery Boiler #10) to TREA20 whenever EQUI53 operates, and operate and maintain TREA20 at all times that any emissions are vented to TREA20. The Permittee shall document periods of non-operation of the control equipment TREA20 whenever EQUI53 is operating. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.53.2 If the Permittee replaces TREA20, the replacement control must meet or exceed the control efficiency requirements of TREA20 as well as comply with all other requirements of TREA20. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]


5.53.4 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing opacity limit, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R. 7017.0200]



5.53.7 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.53.8 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.53.9 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]



5.53.12 Opacity: Continuous Monitoring: The Permittee shall continuously, or at a minimum once every 15 minutes, monitor the opacity of the ESP exhaust. See Subject Item EQUI113 for specific COMS


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation operating requirements. [40 CFR 64.3(b)(4)(ii), Minn. R. 7017.0200]



5.53.15 Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]


TREA 21 CE019 Rotary Lime

Kiln ESP

5.54.1 The Permittee shall vent emissions from EQUI52 (Rotary Lime Kiln) to TREA21 whenever EQUI52 operates, and operate and maintain TREA21 at all times that any emissions are vented to TREA21. The Permittee shall document periods of non-operation of the control equipment TREA21 whenever EQUI52 is operating. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.54.2 If the Permittee replaces TREA21, the replacement control must meet or exceed the control efficiency requirements of TREA21 as well as comply with all other requirements of TREA21. Prior to


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.54.3 ESP monitoring: The COMS (EQUI108) for the emission unit (EQUI52) shall be used to assess proper operation of this ESP. [40 CFR 64.7(a), Minn. R. 7007.0800, subp. 2, Minn. R. 7017.0200, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]




5.54.7 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.54.8 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation 5.54.9 The Permittee shall operate and maintain control equipment such

that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]






5.54.15 Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

5.54.16 Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: - the monitored opacity, averaged over any 3-hour period, exceeds 15%; or - the ESP or any of its components are found during the inspections to need repair. Corrective actions shall return operation to within the permitted range and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the ESP.


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation The Permittee shall keep a record of the type and date of any corrective action taken for the ESP. [40 CFR 64.7(6), Minn. R. 7017.0200]

TREA 30 CE022 Incinerator for

TRS on IQS

5.55.1 The Permittee shall vent emissions from the equipment controlled by the IQS to TREA30 whenever the equipment operates, and operate and maintain TREA30 at all times that any emissions are vented to TREA30. The Permittee shall document periods of non-operation of the control equipment TREA30. If the incinerator TREA30 is not operational emissions must be vented to Power Boiler #7 or #9 as specified elsewhere in the permit. [Minn. R. 7007.0800, subp. 2]

5.55.2 If the Permittee replaces TREA30, the replacement control must meet or exceed the control efficiency requirements of TREA30 as well as comply with all other requirements of TREA30. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR-05. The notice must be received by the Agency seven working days prior to the commencement/start of replacement. [Minn. R. 7007.0800, subp. 2]

5.55.3 The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds >= 98.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

5.55.4 The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Sulfur - Total Reduced including H2S >= 98 percent destruction efficiency. [Minn. R. 7007.0800, subp. 2]

5.55.5 Temperature >= 1200 degrees Fahrenheit at the combustion chamber outlet (a minimum residence time of 0.5 seconds is also required), unless a new limit is required to be set pursuant to Minn. R. 7017.2025, subp. 3. If a new minimum is required to be set it will be based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3-hour rolling average temperature is below the minimum temperature limit, the VOC and TRS emitted during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation. [40 CFR 63.283(a)(1)(iii), 40 CFR 64.3(a), Minn. R. 7011.2450, Minn. R. 7017.0200]

5.55.6 Temperature >= 1500 degrees Fahrenheit 3-hour rolling average at the combustion chamber outlet, unless a new limit is required to


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation be set pursuant to Minn. R. 7017.2025, subp. 3. If a new minimum is required to be set it will be based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3-hour rolling average temperature is below the minimum temperature limit, the VOC emitted during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation. [40 CFR 63.443(d)(3), 40 CFR 64.3(a), Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7700, Minn. R. 7017.0200, Minn. R. 7017.2025, subp. 3]

5.55.7 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R. 7017.0200]



5.55.10 The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.55.11 CMS: A CMS shall be operated to measure the temperature in the firebox or in the ductwork immediately downstream of the firebox and before any substantial heat exchange occurs. [40 CFR 63.453(b), Minn. R. 7011.7700]

5.55.12 Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/- 0.75 percent of the temperature being measured or +/- 2.5 degrees Celsius. The recording device shall also calculate the three-hour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. [40 CFR 64.3(b)(4)(ii) and Minn. R. 7017.0200, Minn. R. 7007.0800, subp. 2]

5.55.13 Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [40 CFR 64.3(b), Minn. R. 7007.0800, subp. 2, Minn. R. 7017.0200]

5.55.14 Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring at the point of incineration of effluent gases. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [40 CFR 60.284, 40 CFR 64.7(b), Minn. R. 7011.2450, Minn. R. 7017.0200]

5.55.15 The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the combustion chamber. [Minn. R. 7007.0800, subp. 2, Minn. R. 7017.0200]

5.55.16 Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [40 CFR 64.3, Minn. R. 7017.0200]

5.55.17 Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

5.55.18 Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

5.55.19 For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: a. The overall control efficiency limit specified in this permit for this equipment (x%); or b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation the tested value in all calculations until the efficiency is demonstrated to be above the permit limit through a new test. [Minn. R. 7007.0800, subp. 2]

5.55.20 Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. [40 CFR 64.7(d), Minn. R. 7017.0200]

TREA 31 CE023 SO2 Scrubber

for IQS

5.56.1 The Permittee shall operate and maintain the scrubber in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

5.56.2 The Permittee is allowed to conduct on-line acid washes on TREA28 in accordance with the O & M Plan. The Permittee shall record the time, date, and duration of the on-line acid washes. A Shutdown Breakdown Notice does not need to be submitted for the on-line acid wash. [Minn. R. 7007.0800, subp. 2]

5.56.3 The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Sulfur Dioxide >= 99 percent destruction efficiency. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.56.4 pH >= 7.4 (no units) 3-hour block average, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. This limit does not apply during on-line acid washes as allowed in the O & M Plan. [40 CFR 64.3(a), Minn. R. 7007.3000, Minn. R. 7017.0200, Minn. R. 7017.2025, subp. 3, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.56.5 Liquid Flow Rate >= 584 gallons per minute 3-hour block average, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3, based on the values recorded during the most recent MPCA-approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. [40 CFR 64.3(a), Minn. R. 7007.3000, Minn. R. 7017.0200, Minn. R. 7017.2025, subp. 3, Title I Condition: 40 CFR 52.21(k)(modeling) &


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation Minn. R. 7007.3000]

5.56.6 Monitoring: Install, calibrate, maintain, and operate a continuous monitoring system to measure and record the pH and flow rate in the scrubber. [40 CFR 64.7(a), Minn. R. 7007.3000, Minn. R. 7017.0200, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.56.7 Daily Monitoring: The Permittee shall physically verify the operation of the pH and liquid flow rate recording devices at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [40 CFR 64.3(b), Minn. R. 7007.3000, Minn. R. 7017.0200, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.56.8 The Permittee shall maintain a continuous hard copy readout or computer disk file of the pH and liquid flow rate readings and calculated three hour rolling averages. [40 CFR 64.9(b), Minn. R. 7007.3000, Minn. R. 7017.0200, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

5.56.9 Annual Calibration: The Permittee shall calibrate the pH monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [40 CFR 64.3, Minn. R. 7017.0200]

5.56.10 Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

5.56.11 Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes all operating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

5.56.12 Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shall keep a record of the type and date of any corrective action taken. [40 CFR 64.7(d)(1), Minn. R. 7017.0200]

5.56.13 Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance or performance testing document a need to modify


Subject Item Sec. SI.Regt SI des:SI desc Requirement & Citation the existing minimum combustion chamber temperature(s), the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes. [40 CFR 64.7(e), Minn. R. 7017.0200]

5.56.14 As required by 40 CFR Section 64.9(a)(2), for the Semi-Annual Deviations Report listed in Section 6 of this permit and/or the Notification of Deviations Endangering Human Health and the Environment listed earlier in Section 5 of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]


6. Submittal/action requirements

This section lists most of the submittals required by this permit. Please note that some submittal requirements may appear in the Limits and Other Requirements section, or, if applicable, within a Compliance Schedule section.

Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation TFAC 6 01700002 Sappi Cloquet

LLC

6.1.1 The Permittee shall submit a computer dispersion modeling protocol : Due before 09/13/2025 for PM10 and PM2.5 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

6.1.2 The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July The first semiannual report submitted by the Permittee shall cover the calendar half-year in which the permit is issued. The first report of each calendar year covers January 1 - June 30. The second report of each calendar year covers July 1 - December 31. If no deviations have occurred,


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation the Permittee shall submit the report stating no deviations. [Minn. R. 7007.0800, subp. 6(A)(2)]

6.1.3 The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). The Permittee shall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. [Minn. R. 7007.0800, subp. 6(C)]

6.1.4 The Permittee shall submit excess emission/downtime report : Due by 30 days after the end of each calendar quarter following permit issuance. Submit Deviations Reporting Form DRF-1 as amended. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e. during startup, shutdown, and malfunctions. The EER must be submitted even if there were no excess emissions, downtime or bypasses during the quarter. [40 CFR 60.7(c), Minn. R. 7017.1110, subp. 1-2]


(Spreader Stoker - Bark)

6.2.1 The Permittee shall submit an initial compliance status report : Due before 07/31/2017. The Initial Compliance Status Report must cover the reporting period beginning on January 31, 2017 and ending on June 30, 2017. The Compliance Status Report must contain the information specified in 40 CFR Section 63.7550(c). [40 CFR 63.7550(b)(1)and (2), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

6.2.2 The Permittee shall submit a notification of compliance status : Due 60 calendar days after Demonstration Completion Date according to 40 CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status, including all performance test results and fuel analyses, before the close of business on the 60th day following the completion of all performance test and/or other initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2). The Notification of Compliance Status report must contain all the information specified in 40 CFR Section 63.7545(e)(1)-(8), as applicable. The Permittee must submit a signed statement in the Notification of Compliance Status report that indicates that the Permittee conducted a tune-up of the unit. [40 CFR 63.7530(d), 40 CFR 63.7545(e), Minn. R. 7011.7050]

6.2.3 The Permittee shall submit a compliance status report : Due semiannually, by the 31st of January and July according to 40 CFR Section 63.7550(h). The Compliance Status Reports must cover the applicable semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. The Compliance Status Report must be postmarked or submitted no later than July 31 or January 31, whichever date is the first date following the end of the semiannual reporting period.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation The Compliance Status Report must contain the information specified in 40 CFR Section 63.7550(c). [40 CFR 63.7550(b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

6.2.4 PM < 10 micron : The Permittee shall conduct a performance test : Due before 10/19/2019 every 36 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 36-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

6.2.5 PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 10/19/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

6.2.6 Particulate Matter : The Permittee shall conduct a performance test : Due before 10/21/2019 every 36 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 36-month period


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

6.2.7 Front-half Particulate Matter : The Permittee shall conduct a performance test : Due before 10/19/2017 every 12 months thereafter to measure emissions according to 40 CFR Section 63.7520, except as specified in 40 CFR Section 63.7515(b)-(e), (g), and (h), using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. If the performance tests for at least 2 consecutive years show that the emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the individual boiler or air pollution control equipment that could increase emissions, the Permittee may choose to conduct performance tests every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. If a performance test shows emissions exceeded 75 percent of the emission limit, the Permittee must conduct annual performance tests until all performance tests over a consecutive 2-year period are at or below 75 percent of the emission limit. [40 CFR 63.7515(a)-(c), Minn. R. 7011.7050]

6.2.8 Nitrogen Oxides : The Permittee shall conduct a performance test : Due before 08/10/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

6.2.9 Sulfuric Acid Mist : The Permittee shall conduct a performance test : Due before 11/20/2018 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using Method OTM 13A, or other method approved by MPCA in the performance test plan approval. This permit contains process throughput limits for EQUI 2. The process throughput limits will be defined by the operating rates sustained during the test, and may be reset within a Notice of Compliance letter. Target process throughput rates as of permit #01700002-101 are listed in Appendix D along with other recordkeeping items that must be included in the performance test report. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

6.2.10 Mercury : The Permittee shall conduct a performance test : Due before 05/28/2020 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 30B, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit;


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]


(Bark)

6.3.1 The Permittee shall submit a notification of compliance status : Due 60 calendar days after Demonstration Completion Date according to 40 CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status, including all performance test results and fuel analyses, before the close of business on the 60th day following the completion of all performance test and/or other initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2). The Notification of Compliance Status report must contain all the information specified in 40 CFR Section 63.7545(e)(1)-(8), as applicable. The Permittee must submit a signed statement in the Notification of Compliance Status report that indicates that the Permittee conducted a tune-up of the unit. [40 CFR 63.7530(d), 40 CFR 63.7545(e), Minn. R. 7011.7050]

6.3.2 The Permittee shall submit a compliance status report : Due by 31 days after end of each calendar half-year according to 40 CFR Section 63.7550(h). The Compliance Status Reports must cover the applicable semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. The Compliance Status Report must be postmarked or submitted no later than July 31 or January 31, whichever date is the first date following the end of the semiannual reporting period. The Compliance Status Report must contain the information specified in 40 CFR Section 63.7550(c). [40 CFR 63.7550(b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

6.3.3 PM < 10 micron : The Permittee shall conduct a performance test : Due before 01/12/2022 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

6.3.4 PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 01/12/2022 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

6.3.5 Particulate Matter : The Permittee shall conduct a performance test : Due before 01/12/2022 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 7007.3000]

6.3.6 Front-half Particulate Matter : The Permittee shall conduct a performance test : Due before 01/12/2020 every 36 months thereafter to measure emissions according to 40 CFR Section 63.7520, except as specified in 40 CFR Section 63.7515(b)-(e), (g), and (h), using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. If the performance tests for at least 2 consecutive years show that the emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation of the individual boiler or air pollution control equipment that could increase emissions, the Permittee may choose to conduct performance tests every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. If a performance test shows emissions exceeded 75 percent of the emission limit, the Permittee must conduct annual performance tests until all performance tests over a consecutive 2-year period are at or below 75 percent of the emission limit. [40 CFR 63.7515(a)-(c), Minn. R. 7011.7050]

6.3.7 Sulfuric Acid Mist : The Permittee shall conduct a performance test : Due before 12/10/2019 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method OTM 13A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

6.3.8 Mercury : The Permittee shall conduct a performance test : Due before 12/10/2019 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 30B, or other method approved by MPCA in the


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]

EQUI 7 EU011 Bleach Plant 6.4.1 Chlorine Dioxide : The Permittee shall conduct a performance test :

Due before 09/16/2019 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 20, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]

6.4.2 Carbon Monoxide : The Permittee shall conduct a performance test : Due before 09/16/2019 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 10, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required:


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

6.4.3 Volatile Organic Compounds : The Permittee shall conduct a performance test : Due before 09/16/2019 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

6.4.4 HAPs - Total (Total Chlorinated HAP) : The Permittee shall conduct a performance test : Due before 09/01/2020 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using NCASI Method 520, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation due date. [40 CFR 63.457(a)(2), Minn. R. 7011.7700]

EQUI 18 EU037 Power Boiler #8 6.5.1 Particulate Matter : The Permittee shall conduct initial

performance test : Due 180 calendar days after Initial Startup Date of combustion of fuel oil, to measure Total Particulate Matter emissions while burning fuel oil. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R. 7011.0200, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

6.5.2 PM < 10 micron : The Permittee shall conduct initial performance test : Due 150 calendar days after Initial Startup Date of combustion of fuel oil to measure emissions of Particulate Matter < 10 micron while burning fuel oil. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R. 7011.0200, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

6.5.3 The Permittee shall submit a notification of the actual date of initial startup : Due 15 calendar days after Initial Startup Date of combustion of fuel oil. [Minn. R. 7019.0100, subp. 1]

6.5.4 The Permittee shall submit a notification of compliance status : Due 60 calendar days after Demonstration Completion Date according to 40 CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status before the close of business on the 60th day following the completion of all initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2). The Notification of Compliance Status must only contain the information specified in 40 CFR Section 63.7545(e)(1) and (8). The Permittee must submit a signed statement in the Notification of Compliance Status report that indicates that the Permittee conducted a tune-up of the unit. [40 CFR 63.7530(d), 40 CFR 63.7545(e), Minn. R. 7011.7050]

6.5.5 The Permittee shall submit a compliance status report : Due by January 31 of each calendar year according to 40 CFR Section 63.7550(h). The Compliance Status Reports must cover the applicable 1-year reporting period from January 1 through December 31. The Compliance Status Report must be postmarked or submitted no later than January 31 of the year in which it is due. The Compliance Status Report must contain the information in 40 CFR Section 63.7550(c)(5)(i)-(iv) and (xiv). [40 CFR 63.7550(b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

EQUI 49 EU081 IQS - Incinerator 6.6.1 PM < 10 micron : The Permittee shall conduct a performance test :

Due before 10/23/2017 every 60 months to measure emissions.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.6.2 PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 10/23/2017 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.6.3 Particulate Matter : The Permittee shall conduct a performance test : Due before 10/23/2017 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C).. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]

6.6.4 Sulfuric Acid Mist : The Permittee shall conduct a performance test : Due before 02/19/2019 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 8, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]

6.6.5 Nitrogen Oxides : The Permittee shall conduct a performance test : Due before 09/01/2017 every 12 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 12-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.6.6 Sulfur - Total Reduced including H2S : The Permittee shall conduct a performance test : Due before 09/01/2021 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 16, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]

6.6.7 HAPs - Total : The Permittee shall conduct a performance test : Due before 09/01/2021 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using procedures in 40 CFR Section 63.457, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation due date. [40 CFR 63.457(a)(2), Minn. R. 7011.7700, Minn. R. 7017.2020, subp. 1]

EQUI 51 EU031 Smelt Dissolving

Tank for RB #10

6.7.1 Particulate Matter : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of the chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.7.2 PM < 10 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.7.3 PM < 2.5 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.7.4 Sulfur - Total Reduced including H2S : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 16C, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp.


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

6.7.5 Particulate Matter: The Permittee shall submit a test frequency plan for Particulate Matter: Due 60 calendar days after Initial Performance Test Date for Particulate Matter emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.7.6 PM < 10 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 10 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 10 microns. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.7.7 PM < 2.5 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 2.5 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 2.5 microns emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.7.8 Sulfur - Total Reduced including H2S: The Permittee shall submit a test frequency plan for Total Reduced Sulfur: Due 60 calendar days after Initial Performance Test Date for Total Reduced Sulfur emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

EQUI 52 EU033 Rotary Lime Kiln -

Kiln

6.8.1 Sulfuric Acid Mist : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using OTM 13A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

6.8.2 Carbon Monoxide : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 10, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.8.3 Sulfur Dioxide : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 6C, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.8.4 Volatile Organic Compounds : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

6.8.5 Mercury : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C).


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation The Permittee may not extend this performance test deadline. [Minn. R. 7017.2020, subp. 1]

6.8.6 Sulfuric Acid Mist: The Permittee shall submit a test frequency plan for sulfuric acid mist: Due 60 calendar days after Initial Performance Test Date for sulfuric acid mist emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

6.8.7 Carbon Monoxide: The Permittee shall submit a test frequency plan for Carbon Monoxide: Due 60 calendar days after Initial Performance Test Date for CO emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.8.8 Sulfur Dioxide: The Permittee shall submit a test frequency plan for Sulfur Dioxide: Due 60 calendar days after Initial Performance Test Date for SO2 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.8.9 Volatile Organic Compounds: The Permittee shall submit a test frequency plan for Volatile Organic Compounds: Due 60 calendar days after Initial Performance Test Date for VOC emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

6.8.10 Mercury: The Permittee shall submit a test frequency plan for Mercury: Due 60 calendar days after Initial Performance Test Date for Mercury emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1]

6.8.11 PM < 10 micron : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA in the


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.8.12 PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.8.13 Particulate Matter : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.8.14 Filterable Particulate Matter : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval and by following the provisions in 40 CFR Sections 60.8 and 63.285a(b)(1) and (2). Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [40 CFR 60.285a(b)(4)]

6.8.15 Nitrogen Oxides : The Permittee shall conduct a performance test : Due before 08/30/2017 every 12 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 12-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.8.16 Sulfur - Total Reduced including H2S : The Permittee shall conduct a performance test : Due before 10/18/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60-month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 16C, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [40 CFR 60.285a(d)(4), Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI 53 EU005 Recovery Boiler

#10

6.9.1 Particulate Matter : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of the chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

6.9.2 PM < 10 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.9.3 PM < 2.5 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.9.4 Sulfuric Acid Mist : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of the chip pre-steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 8, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

6.9.5 Particulate Matter: The Permittee shall submit a test frequency plan for Particulate Matter: Due 60 calendar days after Initial Performance Test Date for Particulate Matter emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.9.6 PM < 10 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 10 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 10 microns. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.9.7 PM < 2.5 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 2.5 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 2.5 microns emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

6.9.8 Sulfuric Acid Mist: The Permittee shall submit a test frequency plan for Total Reduced Sulfur: Due 60 calendar days after Initial Performance Test Date for Total Reduced Sulfur emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

EQUI 71 MR004 Power Boiler #9 -

SO2

6.10.1 The Permittee shall conduct a cylinder gas audit : Due semiannually (end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R. 7017.1170, subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R. 7017.1170, subp. 4a]

6.10.2 The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R. 7017.1170, subp. 5a]


O2

6.11.1 The Permittee shall conduct a cylinder gas audit : Due by the end of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2, Minn. R. 7017.1170, subp. 4a]

6.11.2 The Permittee shall conduct a relative accuracy test audit : Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1]


CO

6.12.1 The Permittee shall conduct a cylinder gas audit : Due by the end of each three of four calendar quarters but no more than three quarters in succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation F, 5.1.2, Minn. R. 7017.1170, subp. 4a]


EQUI 108 MR030 Rotary Lime Kiln -

Opacity

6.13.1 The Permittee shall conduct COMS calibration error audit : Due quarterly according to Procedure 3 of 40 CFR Pt. 60, Appendix F. Quarterly performance audits will include: optical alignment, calibration error, and zero compensation. Sources that achieve quality assured data for four consecutive quarters may reduce audit frequency to semi-annually. If an audit is failed, the source must resume quarterly audits to demonstrate performance again for four consecutive quarters. [Minn. R. 7017.1215]

EQUI 110 MR043 RB#10 CO2 6.14.1 The Permittee shall conduct a cylinder gas audit : Due semiannually

(end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in Minn. R. 7017.1170, subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace period of 168 operating hours to perform the CGA. [Minn. R. 7017.1170, subp. 4a]



NOx


6.15.2 The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R. 7017.1170, subp. 5a]


#10 - Opacity



#10 - NOx




#10 - SO2


6.18.2 The Permittee shall conduct a relative accuracy test audit : Due


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R. 7017.1170, subp. 5a]


#10 - TRS




#10 - CO




#10 - O2





Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation SO2




TRS




O2




O2




Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation EQUI 123 MR025 Power Boiler #7 -

CO




Opacity



Opacity



NOx


6.29.2 The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emission unit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [Minn. R. 7017.1170, subp. 5a]


O2



EQUI 290 EU089 R&D Boiler 6.31.1 The Permittee shall submit a notification of compliance status :

Due 60 calendar days after Demonstration Completion Date according to 40 CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status before the close of business on the 60th day following the completion of all initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2). The Notification of Compliance Status must only contain the information specified in 40 CFR Section 63.7545(e)(1) and (8). The Permittee must submit a signed statement in the Notification of Compliance Status report that indicates that the Permittee conducted a tune-up of the unit. [40 CFR 63.7530(d), 40 CFR 63.7545(e), Minn. R. 7011.7050]

6.31.2 The Permittee shall submit an initial compliance status report : Due before 01/31/2021 according to 40 CFR Section 63.7550(h). The Initial Compliance Status Report must cover the reporting period beginning on January 31, 2016 and ending on December 31, 2020. The Compliance Status Report must contain the information in 40 CFR Section 63.7550(c)(5)(i)-(iv) and (xiv). [40 CFR 63.7550(b)(1)and (2), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

6.31.3 Compliance Status Report: due 31 days after end of each calendar 60 months starting 01/01/2021, according to 40 CFR Section 63.7550(h). The Compliance Status Reports must cover the applicable 5-year reporting period from January 1 through December 31. The Compliance Status Report must be postmarked


Subject Item Sec.SI.Reqt SI des:SI desc Requirement & Citation or submitted no later than January 31 of the year in which it is due. The Compliance Status Report must contain the information in 40 CFR Section 63.7550(c)(5)(i)-(iv) and (xiv). [40 CFR 63.7550(b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

EQUI 304 EU051 #13 Coater 6.32.1 The Permittee shall submit a submit a semiannual compliance

report : Due by 30 days after end of each calendar half-year for each emission unit subject to a standard in 40 CFR pt. 63. This may be submitted with the annual Compliance Certification. The report must contain the information listed in 40 CFR Section 63.3400(c)(2). [40 CFR 63.3400(c), Minn. R. 7011.7385]

EQUI 316 Chip Presteaming

Bin

6.33.1 Volatile Organic Compounds : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date to verify the emission factor of 0.00000927 ton VOC (as mass) per ton green chips. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. [Minn. R. 7017.2020, subp. 1]

6.33.2 Volatile Organic Compounds: The Permittee shall submit a test frequency plan for Volatile Organic Compounds: Due 60 calendar days after Initial Performance Test Date for VOC emission factor. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12-month, 36-month, or 60-month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1]

6.33.3 The Permittee shall submit a notification of the date construction began: Due 30 calendar days after Date of Construction Start (or reconstruction). Submit the name and number of the Subject Item and the date construction began. [Minn. R. 7007.0800, subp. 16(L)]

6.33.4 The Permittee shall submit a notification of the actual date of initial startup: Due 15 calendar days after Initial Startup Date. Submit the name and number of the Subject Item and the date of startup. Startup is as defined in Minn. R. 7005.0100, subp. 42a. [Minn. R. 7007.0800, subp. 16(L)]


7. Appendices

Appendix A. Insignificant Activities and General Applicable Requirements The table below lists the insignificant activities that are currently at the Facility and their associated general applicable requirements.

Minn. R. Rule description of the activity General applicable requirement Minn. R. 7007.1300, subp. 3(A) Fuel Use: space heaters fueled by kerosene,

natural gas, or propane, less than 420,000 Btu/hr Sappi has fewer than 10 space heaters located throughout the facility which combust kerosene, propane, and natural gas. Combined capacity is less than 420,000 Btu/hour.

PM <= 0.6 or 0.4 lb/MMBtu, depending on year constructed Opacity <= 20% with exceptions (Minn. R. 7011.0510/0515)

Minn. R. 7007.1300, subp. 3(B)(1)

Infrared electric ovens Sappi has infrared dryers on the coater.

Opacity <= 20% (Minn. R. 7011.0105 or 7011.0110)

Minn. R. 7007.1300, subp. 3(B)(2)

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

Opacity <= 20%; SO2 <= 0.50 pounds per million Btu heat input (Minn. R. 7011.2300)

Minn. R. 7007.1300, subp. 3(E)(1)

Gasoline storage tanks with a combined total tankage capacity of not more than 10,000 gallons See Table C-3

Minn. R. 7011.0710/0715 and/or Minn. R. 7011.1505, subp. 2(B)/1505, subp. 3(B) and/or Minn. R. 7011.0105/0110

Minn. R. 7007.1300, subp. 3(E)(2)

Nonhazardous air pollutant VOC storage tanks with total capacity not more than 10,000 gallons meeting certain vapor pressure requirements See Table C-3

Minn. R. 7011.0710/0715 and/or Minn. R. 7011.1505, subp. 2(B)/1505, subp. 3 (B) and/or Minn. R. 7011.0105/0110

Minn. R. 7007.1300, subp. 3(G) Emissions from a laboratory, as defined in Minn. R. 7007.1300, subp. 3(G) Sappi has four laboratories at its facility: Pulp QC, Paper QC; Technical and Environmental Department QC and environmental analysis; and Research and Development. Materials processed in all four of these laboratories are not sold for profit. Sappi has process control labs within the mill operating departments

PM, variable depending on airflow Opacity <= 20% (Minn. R. 7011.0710/0715)

Minn. R. 7007.1300, subp. 3(H)(3)

Brazing, soldering or welding equipment Brazing, soldering and welding are performed for maintenance, repair and



Minn. R. Rule description of the activity General applicable requirement fabrication. Sappi has a maximum of 75 welding units on-site including electric welders and oxy/acetylene torches.

Minn. R. 7007.1300, subp. 3(H)(5)

Equipment used exclusively for melting or application of wax Sappi has several units on site that melt petroleum wax which is used as an adhesive in packaging activities.


Minn. R. 7007.1300, subp. 3(H)(7)

Cleaning operations: alkaline/phosphate cleaners and associated cleaners Parts cleaners


Minn. R. 7007.1300, subp. 3(I) Individual units with potential emissions less than 2000 lb/year of certain pollutants Chlorine bleach plant cooling tower, potential emissions are 0.13 tpy PM, and 0.12 tpy PM10

PM, variable depending on airflow Opacity <= 20% (Minn. R. 7011.0715)

Minn. R. 7007.1300, subp. 4 Individual units with potential or actual emissions meeting the criteria in Minn. R. 7007.1300, subp. 4(A)-(D) See Table C-3.


Table C-3. Insignificant Activities Listed under Minn. R. 7007.1300, subps. 3(E) and 4 Area Emission Source Pollutants Emitted Generally Applicable Requirement

Lime Kiln/ Recausticizing Area

Lime Mud Washer Vents TRS/VOC Minn. R. 7011.0710/0715 Lime Mud Storage Tank Vent TRS/VOC White Liquor Clarifier TRS/VOC Green Liquor Clarifier TRS/VOC Lime Mud Washer Head Tank TRS/VOC White Liquor Head Tank TRS/VOC Green Liquor Head Tank TRS/VOC Slaker Vent TRS/VOC Causticizer Tanks (4) TRS/VOC Causticizer Liquor Storage TRS/VOC NaSH Storage Tanks (2) TRS/VOC Dregs Storage Tank TRS/VOC Interceptor Sewer Vent TRS/VOC Green Liquor Stabilization Tank TRS/VOC NaOH Unloading Building Vent NaOH Sample Sink Vent Fan TRS/VOC Lime Storage Silos (2) PM Formic Acid Wash Tank Vent TRS White Liquor Oxidizer VOC

Bleach Plant Area Sulfuric Acid Storage Tank Vent H2SO4 Minn. R. 7011.0710/0715 Bleached Pulp Storage Tanks (3) ClO2/VOC EOP Tower TRS/VOC Unbleached Pulp Storage Towers (3) TRS/VOC

Power And Chemical Weak Liquor Storage Tanks (2) TRS/VOC Minn. R. 7011.0710/0715


Area Emission Source Pollutants Emitted Generally Applicable Requirement Recovery Area Boilout Tank Relief Valve TRS/VOC

Spill Tank Vents (2) TRS/VOC Soap Tank Vent TRS/VOC Soap Skimmer Tank TRS/VOC Steam Stripper Vent TRS/VOC Waste Treatment Sulfuric Acid Tank H2SO4 Sample Sink Vent Fan TRS/VOC 80’ Thickener VOC/HAP 80’ Clarifier VOC/HAP

Paper Machine/ Coating/ Finishing/ Shipping Area

Dry Bulk Storage Silos (6) PM Minn. R. 7011.0710/0715 Dry Bulk Reclaim Receivers (4) PM Color Kitchen Roof Fans (2) PM Broke Bins Criteria Pollutants Box Shop (Finishing Department) Criteria Pollutants Color Kitchen Cowles Mixers PM Leveling Towers / Stock Chest VOC

Petroleum Fuel Storage Tanks

Fuel Oil Tank Vents (2) VOC Minn. R. 7011.0710/0715 40 CFR Part 60, Subpart Kb (recordkeeping only)

Hydroelectric Plant Diesel Tank VOC Roundhouse Diesel Fuel Tank Vent VOC Roundhouse Gasoline Storage Tank VOC Wood Prep. Diesel Fuel Tank VOC Railroad Diesel Tanks (2) VOC Fuel Yard Diesel Tank VOC

R & D Building Pilot Coater Dryer Criteria Pollutants Minn. R. 7011.0610


Appendix B: Stack Parameters Relied Upon in Modeling Note: the parameters listed in this appendix reflect the worst-case operation condition for the standard listed. Table B-1: SO2, NOx, CO, and PM Modeling Parameters used in 2012 modeling

Modeling Parameter Units #7 Boiler #8 Boiler #9 Boiler #10 Recovery Boiler Lime Kiln #10 SDT IQS Stack Height ft 253 256 278 325 275 300 237

Stack Diameter ft 8 5.5 10 11 6 4.6 3.0 Exit Velocity ft/sec 43.1 78 57.7 79.0 39.8 34.1 51.9 Temperature F 375 360 413 350 554 173 160

PM lb/hr 15 29.8 21.5 40 11.8 12.5 -- tpy 65.7 130.1 94.3 175 52 49 --

SO2 lb/hr 1200* 21.3 1200* 582 8.4 6.25 -- tpy -- 58 -- 320 37 25 --

NOx (annual) lb/hr 90 56 151.1 241.1 62.2 -- -- NOx (1-hour) lb/hr 90 56 200 241.1 62.2 -- 9.1

NO2/NOx ratio** % 10 10 10 10 10 10 10 CO lb/hr 2200 29.8 3400 359.1 12.9 -- 11.4

*The combined SO2 PTE for PB7 and PB9 is 1,200 lbs per hour when burning NCGs. The PTE from permitted fuels is 17.1 lbs/hr for PB7 and 24.6 lbs/hr for PB9. **The NO2/NOx ratio was added at permit 01700002-014, to reflect assumptions made in the NO2 modeling for the Cloquet area (Sappi, USG, Jarden Home Brands, and Specialty Minerals). Table B-2: NAAQS/MAAQS Modeling Results

Pollutant Averaging Period NAAQS MAAQS Total modeled concentration (includes background and nearby sources) Percent of Standard

(ug/m3) (ug/m3) (ug/m3) NAAQS MAAQS

CO 1-hr 40,000 35,000 10,516.8 26.3% 30.1% 8-hr 10,000 10,000 3,566.1 35.7% 35.7%

NO2 1-hr 188 NA 178.8 95.1% NA

Annual 100 100 27.9 27.9% 27.9%

PM10 24-hr 150 150 96.32 64.2% 64.2%

Annual NA 50 38.34 NA 76.7%

PM2.5 24-hr 35 65 32.96 94.2% 50.7%

Annual 15 15 13.87 92.5% 92.5%


Table B-3. Point Source Parameters for PM2.5 and PM10 24-hour NAAQS Source ID EASTING NORTHING PM2.5

(lb/hr) PM2.5

(tpy) PM10

(lb/hr) PM10 (tpy)

Height (ft)

Diameter (ft)

Temp (°F)

Stack Velocity (ft/min)

Air Flow (ACFM)

SV002 543,574.18 5,174,615.00 11.10 48.62 11.800 51.684 275.0 6.0 554 2,388.54 67,500.00 SV003 543,534.74 5,174,639.10 10.50 45.99 21.000 91.980 253.0 8.0 375 2,587.58 130,000.00 SV004 543,538.76 5,174,604.50 4.13 18.09 26.100 114.318 256.0 5.5 360 4,680.00 111,000.00 SV005 543,541.18 5,174,594.90 13.50 59.13 30.100 131.838 278.0 10.0 413 3,462.00 272,000.00 SV006 543,523.14 5,174,525.85 37.90 166.01 40.000 175.200 325.0 11.0 350 4,737.59 450,000.00 SV029 543,492.18 5,174,519.47 11.46 50.18 12.500 54.750 300.0 4.6 173 2,046.89 34,000.00

IQS 543,574.98 5,174,621.40 7.50 32.85 8.800 38.544 237.0 3.0 160 3,113.94 22,000.00 12PM1 543,483.23 5,174,639.95 0.060 0.264 0.097 0.425 77.0 4.2 100 2,455.33 34,000.00 12PM2 543,448.61 5,174,648.00 0.037 0.163 0.060 0.262 77.0 3.0 100 2,972.40 21,000.00 12PM3 543,436.54 5,174,649.61 0.081 0.355 0.092 0.401 77.0 5.3 100 2,072.50 45,700.00 12PM4 543,421.25 5,174,653.63 0.081 0.355 0.092 0.401 77.0 5.3 100 2,072.50 45,700.00 12PM5 543,416.42 5,174,654.44 0.028 0.124 0.032 0.140 77.0 3.2 100 1,990.45 16,000.00 12PM6 543,410.78 5,174,656.05 0.182 0.799 0.187 0.820 77.0 3.5 100 2,204.60 21,200.00 13C1 543,462.30 5,174,610.97 0.084 0.370 0.087 0.383 71.7 2.8 100 3,005.98 18,500 13C2 543,447.00 5,174,614.19 0.084 0.370 0.087 0.383 71.7 3.0 100 2,618.54 18,500 13C3 543,443.78 5,174,615.00 0.084 0.370 0.087 0.383 71.7 3.0 100 2,618.54 18,500 13C4 543,437.35 5,174,615.80 0.093 0.408 0.097 0.423 76.0 3.0 100 3,000.71 21,200 13C5 543,431.71 5,174,618.22 0.084 0.370 0.087 0.383 71.7 2.7 100 3,232.77 18,500 13C6 543,430.10 5,174,619.02 0.093 0.408 0.097 0.423 76.0 3.0 100 3,000.71 21,200 4PM1 543,488.86 5,174,734.12 0.066 0.290 0.075 0.328 69.0 4.8 100 2,065.09 37,350 4PM2 543,480.01 5,174,734.93 0.066 0.290 0.075 0.328 69.0 4.8 100 2,065.09 37,350 4PM3 543,479.20 5,174,746.20 0.071 0.311 0.080 0.351 69.0 3.8 100 3,609.04 40,000 4PM4 543,473.57 5,174,737.34 0.066 0.290 0.075 0.328 69.0 4.8 100 2,065.09 37,350 4PM5 543,464.71 5,174,738.95 0.028 0.121 0.031 0.137 82.0 4.8 100 862.53 15,600


Table B-4. Area Source Parameters for PM2.5 and PM10 24-hour NAAQS

Source ID EASTING NORTHING PM2.5

(lb/hr) PM2.5

(tpy) PM10

(lb/hr) PM10

(tpy) Height

(ft) X-Diameter

(ft) X-Diameter

(m) Y-Diameter

(ft) Y-Diameter

(m) SPRD007 542,903.50 5,174,514.92 0.023 0.100 0.075 0.327 8.5 328.1 100.0 32.8 10.0 SPRD008 542,999.78 5,174,555.90 0.016 0.070 0.052 0.229 8.5 229.7 70.0 32.8 10.0 SPRD009 543,003.67 5,174,626.20 0.003 0.013 0.010 0.042 8.5 82 25.0 32.8 10.0 SPRD010 542,997.70 5,174,628.40 0.014 0.062 0.042 0.183 8.5 114.8 35.0 32.8 10.0 SPRD011 542,887.30 5,174,665.20 0.041 0.178 0.119 0.522 8.5 328.1 100.0 32.8 10.0 SPRD012 542,789.30 5,174,687.20 0.041 0.178 0.119 0.522 8.5 328.1 100.0 32.8 10.0 SPRD013 542,740.07 5,174,696.89 0.020 0.089 0.060 0.261 8.5 164 50.0 32.8 10.0

SPRD019a 543,106.78 5,174,673.06 0.007 0.030 0.022 0.096 8.5 131.2 40.0 32.8 10.0 SPRD019b 543,132.42 5,174,704.13 0.009 0.041 0.031 0.134 8.5 196.9 60.0 32.8 10.0 SPRD020 543,039.30 5,174,616.10 0.015 0.065 0.048 0.211 8.5 278.9 85.0 32.8 10.0 SPRD021 543,135.87 5,174,691.95 0.006 0.025 0.018 0.080 8.5 328.1 100.0 32.8 10.0 SPRD022 543,234.75 5,174,732.44 0.003 0.013 0.009 0.040 8.5 164 50.0 32.8 10.0 SPRD023 542,984.45 5,174,739.43 0.007 0.033 0.024 0.103 8.5 393.7 120.0 32.8 10.0 SPRD024 543,041.80 5,174,613.70 0.010 0.043 0.033 0.142 8.5 328.1 100.0 328.1 100.0 SPRD025 543,140.63 5,174,595.84 0.010 0.043 0.033 0.142 8.5 328.1 100.0 32.8 10.0

SPRD026a 543,216.43 5,174,527.60 0.005 0.021 0.016 0.071 8.5 164 50.0 32.8 10.0 SPRD026b 543,252.15 5,174,491.86 0.002 0.009 0.007 0.030 8.5 164 50.0 32.8 10.0 SPRD027 543,288.02 5,174,456.67 0.004 0.019 0.014 0.061 8.5 328.1 100.0 32.8 10.0 SPRD028 543,256.82 5,174,498.83 0.009 0.037 0.028 0.125 8.5 328.1 100.0 32.8 10.0 SPRD029 543,357.57 5,174,482.93 0.008 0.035 0.027 0.117 8.5 328.1 100.0 32.8 10.0 SPRD030 543,372.02 5,174,381.50 0.003 0.011 0.008 0.036 8.5 164 50.0 32.8 10.0 SPRD031 543,423.69 5,174,397.57 0.005 0.020 0.015 0.065 8.5 295.3 90.0 32.8 10.0 SPRD032 543,460.90 5,174,483.80 0.008 0.034 0.026 0.114 8.5 328.1 100.0 32.8 10.0 SPRD033 543,559.43 5,174,466.86 0.004 0.016 0.012 0.053 8.5 164 50.0 32.8 10.0 SPRD034 543,612.46 5,174,403.29 0.001 0.005 0.004 0.016 8.5 164 50.0 32.8 10.0 SPRD035 543,611.00 5,174,456.17 0.001 0.004 0.003 0.015 8.5 131.2 40.0 32.8 10.0 SPRD036 543,652.04 5,174,466.00 0.001 0.003 0.003 0.011 8.5 229.7 70.0 32.8 10.0 SPRD037 543,664.40 5,174,537.70 0.001 0.005 0.004 0.016 8.5 328.1 100.0 32.8 10.0



(lb/hr) PM2.5

(tpy) PM10

(lb/hr) PM10

(tpy) Height

(ft) X-Diameter

(ft) X-Diameter

(m) Y-Diameter

(ft) Y-Diameter

(m) SPRD038 543,688.90 5,174,638.20 0.000 0.001 0.001 0.004 8.5 82 25.0 32.8 10.0 SPRD039 543,669.30 5,174,623.50 0.000 0.001 0.001 0.003 8.5 82 25.0 32.8 10.0 SPRD040 543,588.27 5,174,562.99 0.002 0.008 0.006 0.027 8.5 229.7 70.0 32.8 10.0 SPRD041 543,519.41 5,174,577.84 0.002 0.009 0.007 0.032 8.5 229.7 70.0 32.8 10.0 SPRD042 543,523.54 5,174,587.61 0.001 0.006 0.004 0.020 8.5 164 50.0 32.8 10.0 SPRD043 543,469.34 5,174,589.32 0.002 0.007 0.005 0.023 8.5 164 50.0 32.8 10.0 SPRD044 543,453.98 5,174,550.85 0.002 0.008 0.006 0.028 8.5 164 50.0 32.8 10.0 SPRD045 543,442.60 5,174,549.15 0.002 0.009 0.007 0.031 8.5 180.4 55.0 32.8 10.0 SPRD046 543,355.41 5,174,380.78 0.001 0.006 0.004 0.019 8.5 131.2 40.0 32.8 10.0

SPRD047b 543,441.44 5,174,257.07 0.002 0.007 0.005 0.022 8.5 164 50.0 32.8 10.0 SPRD048 543,470.45 5,174,214.71 0.003 0.013 0.010 0.045 8.5 328.1 100.0 32.8 10.0 SPRD049 543,529.17 5,174,133.46 0.001 0.005 0.004 0.018 8.5 131.2 40.0 32.8 10.0 SPRD051 543,608.23 5,174,466.92 0.002 0.009 0.007 0.032 8.5 278.9 85.0 32.8 10.0 SPRD052 543,690.68 5,174,645.59 0.000 0.001 0.001 0.004 8.5 229.7 70.0 32.8 10.0 SPRD053 543,571.65 5,174,474.69 0.000 0.002 0.001 0.006 8.5 295.3 90.0 32.8 10.0 SPRD055 543,375.84 5,174,611.19 0.001 0.003 0.002 0.009 8.5 278.9 85.0 32.8 10.0 SPRD056 543,376.54 5,174,569.64 0.000 0.001 0.001 0.004 8.5 131.2 40.0 32.8 10.0 SPRD057 543,277.71 5,174,585.46 0.001 0.003 0.002 0.011 8.5 328.1 100.0 32.8 10.0 SPRD059 543,144.30 5,174,734.68 0.117 0.514 0.384 1.681 8.5 492.1 150.0 32.8 10.0 SPRD060 542,788.63 5,174,791.10 0.012 0.052 0.037 0.163 8.5 656.2 200.0 229.7 70.0 SPRD061 543,638.03 5,174,028.85 0.001 0.012 0.013 0.057 8.5 196.9 60.0 311.7 95.0 SPRD062 543,677.70 5,173,980.41 0.002 0.021 0.022 0.094 8.5 328.1 100.0 32.8 10.0 SPRD063 543,764.21 5,173,929.87 0.002 0.021 0.022 0.094 8.5 328.1 100.0 32.8 10.0 SPRD064 543,851.30 5,173,878.10 0.001 0.012 0.022 0.094 8.5 196.9 60.0 32.8 10.0 SPRD065 543,909.67 5,173,855.05 0.001 0.010 0.011 0.047 8.5 164 50.0 32.8 10.0 SPRD087 543,445.96 5,174,267.76 0.000 0.000 0.001 0.003 8.5 328.1 100.0 32.8 10.0 SPRD088 543,529.03 5,174,323.97 0.000 0.000 0.000 0.001 8.5 82 25.0 32.8 10.0 SPRD093 543,177.70 5,174,579.37 0.014 0.060 0.091 0.397 8.5 393.7 120.0 98.4 30.0



(lb/hr) PM2.5

(tpy) PM10

(lb/hr) PM10

(tpy) Height

(ft) X-Diameter

(ft) X-Diameter

(m) Y-Diameter

(ft) Y-Diameter

(m) SPRD096 542,425.10 5,175,113.90 0.086 0.378 0.768 3.365 8.5 646.7 197.1 1061.5 323.5 SPRD097 542,739.10 5,175,033.20 0.078 0.341 0.684 2.996 8.5 413.1 125.9 1219.5 371.7 SAPCT001 543,340.84 5,174,528.73 0.031 0.135 0.720 3.154 20.0 199.4 60.8 50.6 15.4

Table B-5. Volume Source Parameters for PM2.5 and PM10 24-hour NAAQS

Source ID EASTING NORTHING PM2.5 (lb/hr)

PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)

Internal Lat Dimension

(ft)


(m)


(ft)


(m) SAPMH01 543,611.90 5,174,337.95 9.47E-06 4.15E-05 6.26E-05 2.74E-04 2.0 99.2 30.2 0.5 0.1 SAPMH02 544,012.16 5,173,823.97 1.51E-04 6.60E-04 9.94E-04 4.36E-03 1.9 78.7 24.0 0.5 0.1 SAPMH03 543,659.46 5,174,630.42 2.81E-05 1.23E-04 1.86E-04 8.14E-04 10.0 4.7 1.4 2.3 0.7 SAPMH04 543,657.09 5,174,459.99 4.20E-05 1.84E-04 2.77E-04 1.21E-03 15.0 5.8 1.8 3.5 1.1 SAPMH05 542,759.44 5,174,739.10 6.89E-05 3.02E-04 4.55E-04 1.99E-03 30.0 30.5 9.3 7.0 2.1 SAPMH06 542,806.86 5,174,727.61 6.89E-05 3.02E-04 4.55E-04 1.99E-03 30.0 30.5 9.3 7.0 2.1 SAPMH07 542,856.56 5,174,712.99 6.89E-05 3.02E-04 4.55E-04 1.99E-03 30.0 30.5 9.3 7.0 2.1 SAPMH08 542,911.48 5,174,703.18 6.89E-05 3.02E-04 4.55E-04 1.99E-03 30.0 30.5 9.3 7.0 2.1 SAPMH09 543,585.05 5,174,322.12 2.76E-04 1.21E-03 1.82E-03 7.98E-03 5.0 0.8 0.2 1.2 0.4 SAPMH10 543,592.55 5,174,336.23 1.56E-04 6.83E-04 1.03E-03 4.51E-03 5.0 0.8 0.2 1.2 0.4 SAPMH11 543,578.36 5,174,344.35 3.46E-04 1.51E-03 2.28E-03 1.00E-02 0.0 0.8 0.2 0.0 0.0 SAPWE01 542,759.44 5,174,739.10 2.27E-05 9.96E-05 1.52E-04 6.64E-04 30.0 30.5 9.3 7.0 2.1 SAPWE02 542,806.86 5,174,727.61 2.27E-05 9.96E-05 1.52E-04 6.64E-04 30.0 30.5 9.3 7.0 2.1 SAPWE03 542,856.56 5,174,712.99 2.27E-05 9.96E-05 1.52E-04 6.64E-04 30.0 30.5 9.3 7.0 2.1 SAPWE04 542,911.48 5,174,703.18 2.27E-05 9.96E-05 1.52E-04 6.64E-04 30.0 30.5 9.3 7.0 2.1 SAPWE05 543,611.90 5,174,337.95 1.46E-04 6.40E-04 9.75E-04 4.27E-03 6.0 99.2 30.2 5.6 1.7 SAPWE06 544,012.16 5,173,823.97 2.05E-03 8.98E-03 1.37E-02 5.98E-02 6.0 78.7 24.0 5.6 1.7 SAPWE07 543,919.06 5,173,801.17 3.22E-03 1.41E-02 2.15E-02 9.41E-02 6.0 78.7 24.0 5.6 1.7 SAPWE08 543,805.96 5,173,778.37 3.22E-03 1.41E-02 2.15E-02 9.41E-02 6.0 78.7 24.0 5.6 1.7 SPRD094 543,611.90 5,174,337.95 1.30E-03 5.69E-03 1.14E-02 4.99E-02 8.5 99.2 30.2 7.9 2.4

SPRD095a 544,012.16 5,173,823.97 2.32E-02 1.02E-01 2.19E-01 9.58E-01 8.5 78.7 24.0 7.9 2.4



PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)


(ft)


(m)


(ft)


(m) SPRD095b 543,909.06 5,173,801.17 2.32E-02 1.02E-01 2.19E-01 9.58E-01 8.5 78.7 24.0 7.9 2.4 SPRD095c 544,044.22 5,173,709.21 2.32E-02 1.02E-01 2.19E-01 9.58E-01 8.5 78.7 24.0 7.9 2.4 SAPRA004 542,540.30 5,174,569.10 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA005 542,549.95 5,174,570.86 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA006 542,559.80 5,174,572.18 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA007 542,569.97 5,174,572.83 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA008 542,579.81 5,174,574.47 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA009 542,589.66 5,174,575.46 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA010 542,599.50 5,174,576.77 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA011 542,530.30 5,174,569.10 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA012 542,520.09 5,174,567.58 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA013 542,510.25 5,174,566.44 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA014 542,500.41 5,174,565.29 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA015 542,609.34 5,174,578.15 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA016 542,619.33 5,174,579.54 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA017 542,629.05 5,174,582.04 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA018 542,639.04 5,174,582.59 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA019 542,649.03 5,174,583.98 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA020 542,659.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA021 542,669.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA022 542,679.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA023 542,689.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA024 542,699.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA025 542,709.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA026 542,719.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA027 542,729.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA028 542,739.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA029 542,749.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5



PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)


(ft)


(m)


(ft)


(m) SAPRA030 542,759.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA031 542,769.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA032 542,779.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA033 542,789.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA034 542,799.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA035 542,809.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA036 542,819.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA037 542,829.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA038 542,839.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA039 542,849.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA040 542,859.03 5,174,584.53 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA041 542,868.96 5,174,585.75 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA042 542,878.88 5,174,586.97 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA043 542,888.81 5,174,588.19 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA044 542,898.73 5,174,589.40 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA045 542,908.66 5,174,590.62 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA046 542,918.58 5,174,591.84 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA047 542,928.51 5,174,593.06 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA048 542,938.43 5,174,594.28 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA049 542,948.36 5,174,595.50 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA050 542,958.28 5,174,596.72 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA051 542,965.83 5,174,603.28 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA052 542,973.38 5,174,609.84 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA053 542,980.93 5,174,616.40 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRA054 542,988.47 5,174,622.96 1.86E-03 8.15E-03 6.79E-03 2.97E-02 8.9 15.3 4.7 8.3 2.5 SAPRC001 542,648.01 5,174,723.30 1.75E-02 7.68E-02 7.09E-02 3.10E-01 8.5 15.3 4.7 7.9 2.4 SAPRC002 542,657.36 5,174,720.49 1.06E-02 4.63E-02 4.25E-02 1.86E-01 8.5 15.3 4.7 7.9 2.4 SAPRC003 542,667.27 5,174,718.69 1.09E-02 4.80E-02 4.40E-02 1.93E-01 8.5 15.3 4.7 7.9 2.4



PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)


(ft)


(m)


(ft)


(m) SAPRC004 542,676.95 5,174,715.98 5.93E-03 2.60E-02 2.36E-02 1.03E-01 8.5 15.3 4.7 7.9 2.4 SAPRC005 542,686.64 5,174,714.63 6.11E-03 2.67E-02 2.43E-02 1.06E-01 8.5 15.3 4.7 7.9 2.4 SAPRC006 542,696.32 5,174,712.38 6.50E-03 2.85E-02 2.58E-02 1.13E-01 8.7 15.3 4.7 8.1 2.5 SAPRC007 542,706.01 5,174,709.90 6.59E-03 2.89E-02 2.62E-02 1.15E-01 8.7 15.3 4.7 8.1 2.5 SAPRC008 542,715.92 5,174,708.55 6.59E-03 2.89E-02 2.62E-02 1.15E-01 8.7 15.3 4.7 8.1 2.5 SAPRC009 542,725.60 5,174,706.98 6.68E-03 2.93E-02 2.66E-02 1.16E-01 8.7 15.3 4.7 8.1 2.5 SAPRC010 542,735.29 5,174,704.50 6.68E-03 2.93E-02 2.66E-02 1.16E-01 8.7 15.3 4.7 8.1 2.5 SAPRD001 543,441.25 5,174,266.10 2.86E-03 1.25E-02 1.16E-02 5.08E-02 10.2 15.3 4.7 9.5 2.9 SAPRD002 543,435.28 5,174,274.55 1.53E-03 6.72E-03 6.18E-03 2.71E-02 10.2 15.3 4.7 9.5 2.9 SAPRD003 543,428.53 5,174,282.20 1.53E-03 6.72E-03 6.18E-03 2.71E-02 10.2 15.3 4.7 9.5 2.9 SAPRD004 543,417.74 5,174,298.87 8.27E-04 3.62E-03 3.30E-03 1.45E-02 10.2 15.3 4.7 9.5 2.9 SAPRD005 543,412.31 5,174,307.20 8.27E-04 3.62E-03 3.30E-03 1.45E-02 10.2 15.3 4.7 9.5 2.9 SAPRD006 543,406.68 5,174,315.54 8.27E-04 3.62E-03 3.30E-03 1.45E-02 10.2 15.3 4.7 9.5 2.9 SAPRD007 543,400.60 5,174,323.42 8.27E-04 3.62E-03 3.30E-03 1.45E-02 10.2 15.3 4.7 9.5 2.9 SAPRD008 543,396.09 5,174,332.43 8.27E-04 3.62E-03 3.30E-03 1.45E-02 10.2 15.3 4.7 9.5 2.9 SAPRD009 543,390.01 5,174,340.31 8.27E-04 3.62E-03 3.30E-03 1.45E-02 10.2 15.3 4.7 9.5 2.9 SAPRD010 543,422.44 5,174,290.09 8.27E-04 3.62E-03 3.30E-03 1.45E-02 10.2 15.3 4.7 9.5 2.9 SAPRE001 543,636.18 5,174,037.39 2.78E-03 1.22E-02 1.12E-02 4.93E-02 10.2 15.3 4.7 9.5 2.9 SAPRE002 543,629.20 5,174,044.82 1.49E-03 6.53E-03 6.01E-03 2.63E-02 10.2 15.3 4.7 9.5 2.9 SAPRE003 543,621.77 5,174,051.57 1.49E-03 6.53E-03 6.01E-03 2.63E-02 10.2 15.3 4.7 9.5 2.9 SAPRE004 543,614.11 5,174,058.11 8.04E-04 3.52E-03 3.21E-03 1.41E-02 10.2 15.3 4.7 9.5 2.9 SAPRE005 543,607.35 5,174,065.54 8.04E-04 3.52E-03 3.21E-03 1.41E-02 10.2 15.3 4.7 9.5 2.9 SAPRE006 543,600.60 5,174,072.97 8.04E-04 3.52E-03 3.21E-03 1.41E-02 10.2 15.3 4.7 9.5 2.9 SAPRE007 543,592.94 5,174,079.28 8.04E-04 3.52E-03 3.21E-03 1.41E-02 10.2 15.3 4.7 9.5 2.9 SAPRE008 543,585.28 5,174,085.58 8.04E-04 3.52E-03 3.21E-03 1.41E-02 10.2 15.3 4.7 9.5 2.9 SAPRE009 543,579.42 5,174,093.47 8.04E-04 3.52E-03 3.21E-03 1.41E-02 10.2 15.3 4.7 9.5 2.9 SAPRE010 543,572.22 5,174,099.77 8.04E-04 3.52E-03 3.21E-03 1.41E-02 10.2 15.3 4.7 9.5 2.9 SAPRF001 542,637.40 5,174,725.60 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6



PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)


(ft)


(m)


(ft)


(m) SAPRF002 542,627.50 5,174,728.00 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF003 542,617.30 5,174,730.30 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF004 542,608.00 5,174,732.60 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF005 542,598.40 5,174,735.00 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF006 542,588.50 5,174,737.30 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF007 542,578.80 5,174,739.40 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF008 542,569.20 5,174,741.70 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF009 542,559.00 5,174,744.00 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF010 542,549.40 5,174,746.60 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF011 542,539.50 5,174,749.00 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF012 542,529.30 5,174,751.60 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF013 542,518.80 5,174,753.90 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF014 542,508.90 5,174,756.60 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF015 542,499.80 5,174,758.90 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF016 542,489.90 5,174,760.90 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF017 542,480.00 5,174,763.30 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF018 542,470.70 5,174,765.60 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF019 542,461.30 5,174,767.60 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF020 542,451.40 5,174,770.30 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF021 542,441.20 5,174,772.60 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF022 542,431.00 5,174,774.90 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF023 542,421.10 5,174,777.30 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF024 542,410.90 5,174,779.60 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF025 542,401.60 5,174,781.90 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF026 542,391.70 5,174,784.30 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF027 542,382.00 5,174,786.60 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF028 542,371.80 5,174,788.60 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF029 542,362.50 5,174,791.00 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6



PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)


(ft)


(m)


(ft)


(m) SAPRF030 542,352.90 5,174,793.30 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF031 542,343.00 5,174,795.30 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF032 542,333.10 5,174,797.70 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF033 542,323.40 5,174,800.00 2.06E-03 9.02E-03 7.94E-03 3.48E-02 9.0 15.3 4.7 8.4 2.6 SAPRF034 542,313.20 5,174,802.60 1.71E-03 7.48E-03 6.51E-03 2.85E-02 9.0 15.3 4.7 8.4 2.6 SAPRF035 542,303.60 5,174,805.00 1.25E-03 5.48E-03 4.64E-03 2.03E-02 9.0 15.3 4.7 8.4 2.6 SAPRG001 542,293.00 5,174,802.30 1.07E-03 4.69E-03 4.06E-03 1.78E-02 8.5 15.3 4.7 7.9 2.4 SAPRG002 542,285.70 5,174,794.10 1.29E-03 5.65E-03 4.94E-03 2.17E-02 8.5 15.3 4.7 7.9 2.4 SAPRG003 542,275.70 5,174,789.80 1.29E-03 5.65E-03 4.94E-03 2.17E-02 8.5 15.3 4.7 7.9 2.4 SAPRG004 542,264.80 5,174,787.30 1.29E-03 5.65E-03 4.94E-03 2.17E-02 8.5 15.3 4.7 7.9 2.4 SAPRG005 542,254.80 5,174,785.00 1.07E-03 4.69E-03 4.06E-03 1.78E-02 8.5 15.3 4.7 7.9 2.4 SAPRG006 542,244.80 5,174,783.70 1.07E-03 4.69E-03 4.06E-03 1.78E-02 8.5 15.3 4.7 7.9 2.4 SAPRG007 542,234.20 5,174,785.70 7.87E-04 3.45E-03 2.90E-03 1.27E-02 8.5 15.3 4.7 7.9 2.4 SAPRG008 542,230.10 5,174,793.90 7.87E-04 3.45E-03 2.90E-03 1.27E-02 8.5 15.3 4.7 7.9 2.4 SAPRG009 542,231.20 5,174,804.80 1.07E-03 4.69E-03 4.06E-03 1.78E-02 8.5 15.3 4.7 7.9 2.4 SAPRG010 542,234.60 5,174,812.30 1.07E-03 4.69E-03 4.06E-03 1.78E-02 8.5 15.3 4.7 7.9 2.4 SAPRG011 542,241.20 5,174,820.90 1.29E-03 5.65E-03 4.94E-03 2.17E-02 8.5 15.3 4.7 7.9 2.4 SAPRG012 542,247.30 5,174,827.40 1.29E-03 5.65E-03 4.94E-03 2.17E-02 8.5 15.3 4.7 7.9 2.4 SAPRG013 542,253.50 5,174,835.30 1.29E-03 5.65E-03 4.94E-03 2.17E-02 8.5 15.3 4.7 7.9 2.4 SAPRG014 542,259.90 5,174,842.60 1.29E-03 5.65E-03 4.94E-03 2.17E-02 8.5 15.3 4.7 7.9 2.4 SAPRG015 542,266.30 5,174,850.40 2.89E-03 1.27E-02 1.15E-02 5.03E-02 8.5 15.3 4.7 7.9 2.4 SAPRG016 542,272.40 5,174,857.70 2.89E-03 1.27E-02 1.15E-02 5.03E-02 8.5 15.3 4.7 7.9 2.4 SAPRG017 542,278.50 5,174,865.30 2.89E-03 1.27E-02 1.15E-02 5.03E-02 8.5 15.3 4.7 7.9 2.4 SAPRG018 542,285.50 5,174,873.20 2.89E-03 1.27E-02 1.15E-02 5.03E-02 8.5 15.3 4.7 7.9 2.4 SAPRG019 542,291.60 5,174,880.80 5.46E-03 2.39E-02 2.19E-02 9.61E-02 8.5 15.3 4.7 7.9 2.4 SAPRG020 542,298.40 5,174,888.60 5.46E-03 2.39E-02 2.19E-02 9.61E-02 8.5 15.3 4.7 7.9 2.4 SAPRG021 542,304.80 5,174,896.80 1.04E-02 4.56E-02 4.21E-02 1.85E-01 8.5 15.3 4.7 7.9 2.4 SAPRH001 542,310.90 5,174,903.50 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9



PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)


(ft)


(m)


(ft)


(m) SAPRH002 542,318.20 5,174,911.40 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH003 542,324.60 5,174,919.00 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH004 542,331.00 5,174,926.20 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH005 542,337.40 5,174,933.80 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH006 542,343.50 5,174,941.10 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH007 542,350.30 5,174,949.00 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH008 542,356.70 5,174,956.60 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH009 542,363.40 5,174,964.40 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH010 542,370.10 5,174,972.00 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH011 542,375.90 5,174,979.30 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH012 542,381.50 5,174,988.10 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH013 542,387.30 5,174,996.50 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH014 542,393.70 5,175,004.40 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH015 542,399.20 5,175,012.30 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH016 542,405.10 5,175,019.80 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH017 542,411.20 5,175,028.00 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH018 542,417.30 5,175,036.20 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH019 542,423.40 5,175,043.70 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH020 542,429.60 5,175,051.60 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH021 542,435.40 5,175,060.10 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH022 542,441.50 5,175,067.40 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH023 542,448.80 5,175,075.20 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH024 542,456.40 5,175,080.50 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH025 542,464.80 5,175,084.90 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH026 542,474.80 5,175,088.10 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH027 542,485.20 5,175,090.70 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH028 542,494.90 5,175,091.90 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9 SAPRH029 542,504.20 5,175,093.00 1.50E-02 6.58E-02 6.09E-02 2.67E-01 10.2 15.3 4.7 9.5 2.9



PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)


(ft)


(m)


(ft)


(m) SAPRH030 542,514.40 5,175,093.60 7.86E-03 3.44E-02 3.17E-02 1.39E-01 10.2 15.3 4.7 9.5 2.9 SAPRH031 542,524.30 5,175,094.20 7.86E-03 3.44E-02 3.17E-02 1.39E-01 10.2 15.3 4.7 9.5 2.9 SAPRH032 542,533.90 5,175,094.80 4.14E-03 1.81E-02 1.66E-02 7.26E-02 10.2 15.3 4.7 9.5 2.9 SAPRH033 542,544.10 5,175,093.60 4.14E-03 1.81E-02 1.66E-02 7.26E-02 10.2 15.3 4.7 9.5 2.9 SAPRH034 542,554.30 5,175,092.40 4.14E-03 1.81E-02 1.66E-02 7.26E-02 10.2 15.3 4.7 9.5 2.9 SAPRH035 542,564.30 5,175,090.10 4.14E-03 1.81E-02 1.66E-02 7.26E-02 10.2 15.3 4.7 9.5 2.9 SAPRH036 542,574.20 5,175,088.10 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH037 542,583.50 5,175,085.40 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH038 542,593.10 5,175,083.70 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH039 542,603.00 5,175,081.40 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH040 542,612.70 5,175,079.30 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH041 542,622.30 5,175,077.00 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH042 542,632.20 5,175,075.20 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH043 542,642.10 5,175,073.20 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH044 542,651.10 5,175,070.60 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH045 542,661.10 5,175,068.50 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH046 542,670.10 5,175,065.90 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH047 542,679.70 5,175,063.30 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH048 542,689.00 5,175,060.70 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH049 542,699.00 5,175,057.70 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH050 542,708.30 5,175,055.40 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH051 542,717.90 5,175,052.50 1.82E-03 7.98E-03 7.11E-03 3.11E-02 10.2 15.3 4.7 9.5 2.9 SAPRH052 542,727.80 5,175,049.90 1.62E-03 7.09E-03 6.28E-03 2.75E-02 10.2 15.3 4.7 9.5 2.9 SAPRH053 542,736.90 5,175,046.70 1.38E-03 6.06E-03 5.33E-03 2.33E-02 10.2 15.3 4.7 9.5 2.9 SAPRH054 542,745.40 5,175,043.60 1.28E-03 5.59E-03 4.89E-03 2.14E-02 10.2 15.3 4.7 9.5 2.9 SAPRI001 542,302.70 5,174,815.20 4.18E-04 1.83E-03 1.56E-03 6.85E-03 10.2 15.3 4.7 9.5 2.9 SAPRI002 542,308.30 5,174,823.30 5.27E-04 2.31E-03 2.01E-03 8.78E-03 10.2 15.3 4.7 9.5 2.9 SAPRI003 542,314.10 5,174,831.80 7.26E-04 3.18E-03 2.82E-03 1.23E-02 10.2 15.3 4.7 9.5 2.9



PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)


(ft)


(m)


(ft)


(m) SAPRI004 542,319.60 5,174,839.60 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI005 542,325.20 5,174,848.10 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI006 542,331.30 5,174,856.30 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI007 542,336.80 5,174,864.40 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI008 542,342.70 5,174,872.00 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI009 542,352.00 5,174,876.40 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI010 542,361.60 5,174,879.00 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI011 542,371.00 5,174,879.60 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI012 542,381.20 5,174,879.30 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI013 542,391.10 5,174,877.00 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI014 542,400.70 5,174,874.60 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI015 542,410.60 5,174,872.30 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI016 542,420.20 5,174,870.30 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI017 542,429.30 5,174,868.20 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI018 542,439.20 5,174,865.90 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI019 542,448.80 5,174,863.80 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI020 542,458.70 5,174,861.20 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI021 542,468.90 5,174,859.50 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI022 542,478.50 5,174,857.10 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI023 542,487.60 5,174,855.10 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI024 542,496.60 5,174,851.90 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI025 542,506.50 5,174,849.30 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI026 542,516.20 5,174,846.90 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI027 542,525.20 5,174,844.60 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI028 542,535.10 5,174,842.30 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI029 542,545.00 5,174,839.60 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI030 542,554.60 5,174,837.30 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI031 542,564.30 5,174,834.70 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9



PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)


(ft)


(m)


(ft)


(m) SAPRI032 542,573.90 5,174,832.40 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI033 542,583.50 5,174,830.30 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI034 542,593.10 5,174,827.70 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI035 542,602.50 5,174,825.40 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI036 542,612.80 5,174,822.30 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI037 542,621.70 5,174,820.10 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI038 542,631.60 5,174,817.20 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI039 542,640.70 5,174,814.60 8.79E-04 3.85E-03 3.44E-03 1.51E-02 10.2 15.3 4.7 9.5 2.9 SAPRI040 542,650.30 5,174,812.00 7.26E-04 3.18E-03 2.82E-03 1.23E-02 10.2 15.3 4.7 9.5 2.9 SAPRI041 542,660.50 5,174,808.70 5.27E-04 2.31E-03 2.01E-03 8.78E-03 10.2 15.3 4.7 9.5 2.9 SAPRJ001 542,669.50 5,174,806.40 1.31E-04 5.76E-04 3.92E-04 1.72E-03 6.9 15.3 4.7 6.4 1.9 SAPRJ002 542,667.20 5,174,797.10 1.64E-03 7.17E-03 6.53E-03 2.86E-02 6.9 15.3 4.7 6.4 1.9 SAPRJ003 542,664.60 5,174,787.20 2.30E-03 1.01E-02 9.21E-03 4.04E-02 6.9 15.3 4.7 6.4 1.9 SAPRJ004 542,661.90 5,174,777.00 2.80E-03 1.23E-02 1.13E-02 4.94E-02 6.9 15.3 4.7 6.4 1.9 SAPRJ005 542,659.30 5,174,767.60 2.80E-03 1.23E-02 1.13E-02 4.94E-02 6.9 15.3 4.7 6.4 1.9 SAPRJ006 542,657.00 5,174,759.70 2.80E-03 1.23E-02 1.13E-02 4.94E-02 6.9 15.3 4.7 6.4 1.9 SAPRJ007 542,653.80 5,174,749.50 2.80E-03 1.23E-02 1.13E-02 4.94E-02 6.9 15.3 4.7 6.4 1.9 SAPRJ008 542,651.50 5,174,739.00 2.30E-03 1.01E-02 9.21E-03 4.04E-02 6.9 15.3 4.7 6.4 1.9 SAPRJ009 542,649.70 5,174,730.60 1.64E-03 7.17E-03 6.53E-03 2.86E-02 6.9 15.3 4.7 6.4 1.9 SAPRK001 543,078.90 5,174,823.60 7.00E-04 3.07E-03 2.77E-03 1.22E-02 6.8 15.3 4.7 6.3 1.9 SAPRK002 543,080.70 5,174,833.30 8.96E-04 3.93E-03 3.57E-03 1.57E-02 6.8 15.3 4.7 6.3 1.9 SAPRK003 543,081.80 5,174,843.10 8.96E-04 3.93E-03 3.57E-03 1.57E-02 6.8 15.3 4.7 6.3 1.9 SAPRK004 543,083.80 5,174,853.00 8.96E-04 3.93E-03 3.57E-03 1.57E-02 6.8 15.3 4.7 6.3 1.9 SAPRK005 543,085.10 5,174,862.80 8.96E-04 3.93E-03 3.57E-03 1.57E-02 6.8 15.3 4.7 6.3 1.9 SAPRK006 543,086.90 5,174,872.50 8.96E-04 3.93E-03 3.57E-03 1.57E-02 6.8 15.3 4.7 6.3 1.9 SAPRK007 543,088.50 5,174,882.20 8.96E-04 3.93E-03 3.57E-03 1.57E-02 6.8 15.3 4.7 6.3 1.9 SAPRK008 543,090.00 5,174,891.80 8.96E-04 3.93E-03 3.57E-03 1.57E-02 6.8 15.3 4.7 6.3 1.9 SAPRK009 543,091.60 5,174,901.00 8.96E-04 3.93E-03 3.57E-03 1.57E-02 6.8 15.3 4.7 6.3 1.9



PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)


(ft)


(m)


(ft)


(m) SAPRK010 543,093.10 5,174,911.00 8.96E-04 3.93E-03 3.57E-03 1.57E-02 6.8 15.3 4.7 6.3 1.9 SAPRK011 543,094.70 5,174,920.70 4.88E-04 2.14E-03 1.91E-03 8.37E-03 6.8 15.3 4.7 6.3 1.9 SAPRK012 543,094.70 5,174,930.20 4.88E-04 2.14E-03 1.91E-03 8.37E-03 6.8 15.3 4.7 6.3 1.9 SAPRK013 543,093.30 5,174,939.50 2.71E-04 1.19E-03 1.03E-03 4.50E-03 6.8 15.3 4.7 6.3 1.9 SAPRK014 543,090.30 5,174,948.10 2.71E-04 1.19E-03 1.03E-03 4.50E-03 6.8 15.3 4.7 6.3 1.9 SAPRK015 543,082.00 5,174,953.00 3.73E-04 1.63E-03 1.44E-03 6.32E-03 6.8 15.3 4.7 6.3 1.9 SAPRK016 543,071.40 5,174,956.60 4.51E-04 1.98E-03 1.76E-03 7.71E-03 6.8 15.3 4.7 6.3 1.9 SAPRK017 543,061.70 5,174,959.70 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK018 543,053.10 5,174,962.30 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK019 543,043.80 5,174,965.00 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK020 543,034.30 5,174,968.10 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK021 543,024.70 5,174,970.90 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK022 543,015.50 5,174,973.80 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK023 543,005.70 5,174,976.70 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK024 542,995.80 5,174,979.10 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK025 542,985.80 5,174,981.80 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK026 542,976.30 5,174,984.20 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK027 542,967.20 5,174,986.70 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK028 542,957.50 5,174,989.10 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK029 542,948.00 5,174,991.70 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK030 542,938.50 5,174,994.40 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK031 542,928.70 5,174,996.80 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK032 542,919.40 5,174,999.30 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK033 542,909.90 5,175,001.90 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK034 542,898.90 5,175,005.00 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK035 542,890.20 5,175,007.20 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK036 542,881.00 5,175,009.70 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK037 542,871.20 5,175,012.10 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9



PM2.5 (tpy)

PM10 (lb/hr)

PM10 (tpy)

Height (ft)


(ft)


(m)


(ft)


(m) SAPRK038 542,861.50 5,175,014.80 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK039 542,852.20 5,175,017.20 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK040 542,842.20 5,175,019.80 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK041 542,832.90 5,175,022.50 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK042 542,823.70 5,175,024.90 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK043 542,812.40 5,175,027.60 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK044 542,803.30 5,175,029.60 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK045 542,794.20 5,175,032.00 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK046 542,784.70 5,175,034.20 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK047 542,775.00 5,175,036.40 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK048 542,765.70 5,175,038.90 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9 SAPRK049 542,755.50 5,175,041.30 2.10E-04 9.20E-04 7.78E-04 3.41E-03 6.8 15.3 4.7 6.3 1.9


Table B-6. PM10 and PM2.5 Modeled Parameters for permit #01700002-015

Source Operating Scenario Easting Northing

PM10 PM2.5 Height (m)

Diameter (m)

Temperature (K)

Stack Velocity (m/s)

Air Flow (acfm) (lb/hr) (tpy) (lb/hr) (tpy)

EU 033/SV 002 Pre-Project 543,574.180 5,174,615.000 -11.8 -1.487 -11.1 -1.399 83.8 1.83 563.15 12.13 67,500 Post-Project 543,574.180 5,174,615.000 13.57 1.710 12.765 1.608 83.8 1.83 563.15 13.95 77,625

Table B-7. PM10 SIL Analysis for permit #01700002-015

Averaging Period SIL (µg/m3)

Total Modeled Concentration (µg/m3)

Percent of Standard (%)

24-hr 5 0.46 9.2 Annual 1 0.04 4.0

Table B-8. PM2.5 SIL-like Increment Screening for permit #01700002-015

Averaging Period Modeled Concentration (µg/m3)

Increment Consumption (µg/m3)

Net Concentration Change (µg/m3)

PSD Class II Increment (µg/m3)

Percent of Increment (%)

24-hr 0.38 0.00 0.38 9 4.2 Annual 0.03 0.00 0.03 4 0.75

Table B-9. PM2.5 NAAQS Screening for permit #01700002-015

Averaging Period Modeled Concentration (µg/m3)

SIL (µg/m3)


24-hr 0.38 1.2 32 Annual 0.03 0.3 10


Table B-10: Parameters used in SIL analysis for permit #01500002-101

SI ID# Description AERMOD

ID Pollutant Averaging

Time Operating Scenario

Release Type Easting (m) Northing

Base Elevation

(m)

Emission Rate

(lb/hr)

Emission Rate

(g/sec) Height

(m)

Exit Temp

(K)

Exit Velocity

(m/s) Diameter

(m)

Flow Rate

(ACFM) EQUI53 Recovery

Boiler #10

SV6PRE PM10 24-Hour 1 VERTICAL 543,523.140 5,174,525.850 354.04 -40 -5.040 99.1 449.8 24.07 3.4 463,053

EQUI53 Recovery Boiler #10

SV6POST PM10 24-Hour 2 VERTICAL 543,523.140 5,174,525.850 354.04 40 5.040 99.1 449.8 24.07 3.4 463,053


SV6PRE PM10 Annual 1 VERTICAL 543,523.140 5,174,525.850 354.04 -15.51 -1.954 99.1 449.8 24.07 3.4 463,053


SV6POST PM10 Annual 2 VERTICAL 543,523.140 5,174,525.850 354.04 40 5.040 99.1 449.8 24.07 3.4 463,053


SV6PRE PM2.5 24-Hour 1 VERTICAL 543,523.140 5,174,525.850 354.04 -37.9 -4.775 99.1 449.8 24.07 3.4 463,053


SV6POST PM2.5 24-Hour 2 VERTICAL 543,523.140 5,174,525.850 354.04 37.9 4.775 99.1 449.8 24.07 3.4 463,053


SV6PRE PM2.5 Annual 1 VERTICAL 543,523.140 5,174,525.850 354.04 -15.61 -1.967 99.1 449.8 24.07 3.4 463,053


SV6POST PM2.5 Annual 2 VERTICAL 543,523.140 5,174,525.850 354.04 37.9 4.775 99.1 449.8 24.07 3.4 463,053


SV6PRE NOx 1-hour 1 VERTICAL 543,523.140 5,174,525.850 354.04 -241 -30.365 99.1 449.8 24.07 3.4 463,053


SV6POST NOx 1-hour 2 VERTICAL 543,523.140 5,174,525.850 354.04 241 30.365 99.1 449.8 24.07 3.4 463,053


SV6PRE NOx Annual 1 VERTICAL 543,523.140 5,174,525.850 354.04 -156.9 -19.77 99.1 449.8 24.07 3.4 463,053


SV6POST NOx Annual 2 VERTICAL 543,523.140 5,174,525.850 354.04 241 30.365 99.1 449.8 24.07 3.4 463,053

EQUI51 RB #10 -

Smelt Dissolving

Tank

SV29PRE PM10 24-Hour 1 VERTICAL 543,492.180 5,174,519.470 354.09 -12.5 -1.575 91.4 351.5 10.4 1.4 34,000

EQUI51 RB #10 -

Smelt Dissolving

Tank

SV29POST PM10 24-Hour 2 VERTICAL 543,492.180 5,174,519.470 354.09 12.5 1.575 91.4 351.5 10.4 1.4 34,000

EQUI51 RB #10 -

Smelt Dissolving

Tank







Base Elevation

(m)

Emission Rate

(lb/hr)

Emission Rate

(g/sec) Height

(m)

Exit Temp

(K)

Exit Velocity

(m/s) Diameter

(m)

Flow Rate

(ACFM) EQUI51

RB #10 - Smelt

Dissolving Tank

SV29POST PM10 Annual 2 VERTICAL 543,492.180 5,174,519.470 354.09 12.5 1.575 91.4 351.5 10.4 1.4 34,000

EQUI51 RB #10 -

Smelt Dissolving

Tank


EQUI51 RB #10 -

Smelt Dissolving

Tank


EQUI51 RB #10 -

Smelt Dissolving

Tank


EQUI51 RB #10 -

Smelt Dissolving

Tank


EQUI52 Rotary Lime Kiln

















SV2PRE NOx 1-hour 3 VERTICAL 543,574.180 5,174,615.000 352.85 -39.0 -4.914 83.8 563.2 12.13 1.8 67,500






Base Elevation

(m)

Emission Rate

(lb/hr)

Emission Rate

(g/sec) Height

(m)

Exit Temp

(K)

Exit Velocity

(m/s) Diameter

(m)

Flow Rate

(ACFM) EQUI52 Rotary

Lime Kiln

SV2POST NOx 1-hour 4 VERTICAL 543,574.180 5,174,615.000 352.85 39.0 4.914 83.8 563.2 12.13 1.8 67,500




SV2POST NOx Annual 6 VERTICAL 543,574.180 5,174,615.000 352.85 39.0 4.914 83.8 563.2 12.13 1.8 67,500

EQUI49 IQS - Incinerator

















SV31PRE NOx 1-hour 1 VERTICAL 543,574.980 5,174,621.400 352.99 -9.1 -1.147 72.2 344.3 15.82 0.9 22,000


SV31POST NOx 1-hour 2 VERTICAL 543,574.980 5,174,621.400 352.99 9.1 1.147 72.2 344.3 15.82 0.9 22,000




SV31POST NOx Annual 2 VERTICAL 543,574.980 5,174,621.400 352.99 9.1 1.147 72.2 344.3 15.82 0.9 22,000


Table B-11: Point Source Parameters used in annual PM2.5 NAAQS analysis for permit #01500002-101

SI ID# AERMOD ID Pollutant Averaging

Time Release

Type Easting (m) Northing (m) Base

Elevation (m)

Emission Rate (lb/hr)

Emission Rate (g/sec)

Height (m)

Exit Temp

(K)

Exit Velocity

(m/s)

Diameter (m)

Flow Rate (ACFM)

STRU30 SAP_IQS PM2.5 Annual VERTICAL 543,574.980 5,174,621.400 352.99 7.50 0.945 72.2 344.26 15.82 0.9 21,325

STRU50 SAP12PM1 PM2.5 Annual VERTICAL 543,483.230 5,174,639.950 353.38 0.06 0.008 23.5 310.93 12.47 1.3 35,071




STRU50 SAP12PM5 PM2.5 Annual VERTICAL 543,416.420 5,174,654.440 353.81 0.03 0.004 23.5 310.93 10.11 1 16,825


STRU51 SAP13C1 PM2.5 Annual VERTICAL 543,462.300 5,174,610.970 353.59 0.08 0.011 21.9 310.93 15.27 0.9 20,584






STRU49 SAP4PM1 PM2.5 Annual VERTICAL 543,488.860 5,174,734.120 354.12 0.07 0.008 21 310.93 10.49 1.5 39,278





STRU38 SAPSV002 PM2.5 Annual VERTICAL 543,574.180 5,174,615.000 352.85 12.77 1.608 83.8 563.15 13.95 1.83 77,745


STRU28 SAPSV004 PM2.5 Annual VERTICAL 543,538.760 5,174,604.500 353.19 4.13 0.520 78 455.37 23.77 1.7 114,320

STRU41 SAPSV005 PM2.5 Annual VERTICAL 543,541.180 5,174,594.900 353.3 13.50 1.701 84.7 484.82 17.59 3 263,454



JHBSV003 PM2.5 Annual VERTICAL 542645.7 5174267.9 364.24 0.03382599 0.004262 14.224 344.26 10.922 0.559 5679.65119






JHBV2 PM2.5 Annual VERTICAL 542643.9 5174266.7 364.24 0.02739731 0.003452 11.28 293.15 0.01 0.61 6.19235074




JHBV7 PM2.5 Annual VERTICAL 542595.4 5174252 364.24 0.09412864 0.01186 15.54 293.15 9.34 0.914 12984.7964

JHBV9 PM2.5 Annual VERTICAL 542585 5174212.9 364.24 0.20270199 0.02554 17.22 293.15 5.03 1.829 28002.1432

SMI_GPIT PM2.5 Annual VERTICAL 543599.6 5174552.1 353.6 0.90001587 0.1134 13.72 319.26 21.345 0.305 3304.39316

USGH7NE PM2.5 Annual VERTICAL 540366.8 5174823.5 360.8 0.00290323 0.0003658 4.57 294.3 0.01 0.91 13.7809343

USGH7NW PM2.5 Annual VERTICAL 540248.3 5174883.9 361.3 0.00290323 0.0003658 4.57 294.3 0.01 0.91 13.7809343

USGH7SE PM2.5 Annual VERTICAL 540352.1 5174793.8 361.2 0.00290323 0.0003658 4.57 294.3 0.01 0.91 13.7809343

USGH7SW PM2.5 Annual VERTICAL 540232.6 5174854.2 361.7 0.00290323 0.0003658 4.57 294.3 0.01 0.91 13.7809343

USGSH10Z PM2.5 Annual VERTICAL 540813.7 5174703.9 360.5 0.00087621 0.0001104 4.27 410.9 0.01 0.3 1.49774675






USGSH16Z PM2.5 Annual VERTICAL 540472 5174644.2 362.1 0.00087621 0.0001104 4.27 410.9 0.01 0.3 1.49774675




USGSH1B PM2.5 Annual VERTICAL 540831.3 5174638.5 362.3 0.00748426 0.000943 6.1 410.9 0.01 0.34 1.92377249

USGSH1C PM2.5 Annual VERTICAL 540168.7 5174802.3 362.8 0.00087621 0.0001104 9.45 410.9 1.16 0.13 32.6242526

USGSH1I PM2.5 Annual VERTICAL 540667.4 5174660 361.7 0.00681441 0.0008586 4.57 410.9 0.01 0.91 13.7809343

USGSH1Q PM2.5 Annual VERTICAL 540480 5174660 361.9 0.00043818 0.00005521 3.05 410.9 0.01 0.1 0.16641631







USGSH24Z PM2.5 Annual VERTICAL 540562.2 5174702.6 361 0.00087621 0.0001104 0.61 410.9 0.01 0.3 1.49774675










USGSH32S PM2.5 Annual VERTICAL 540331.2 5174796.8 361.3 0.00350562 0.0004417 9.14 410.9 1.81 0.2 120.485405











USGSH3B PM2.5 Annual VERTICAL 540819.4 5174639.2 362.2 0.00748426 0.000943 6.1 410.9 0.01 0.34 1.92377249




USGSH5Z PM2.5 Annual VERTICAL 541006 5174699.9 361.3 0.00087621 0.0001104 4.27 410.9 0.01 0.3 1.49774675



USGSH8Z PM2.5 Annual VERTICAL 540964.3 5174700.3 361 0.00087621 0.0001104 4.27 410.9 0.01 0.3 1.49774675


USGSV005 PM2.5 Annual VERTICAL 540827.5 5174698.2 360.6 0.56381947 0.07104 41.15 463.7 14.49 0.76 13928.0862







USGSV036 PM2.5 Annual VERTICAL 540387.8 5174763 361.2 0.05142948 0.00648 16.46 294.3 2.74 0.36 590.950958




USGSV053 PM2.5 Annual VERTICAL 540838 5174698.2 360.7 0.8182684 0.1031 41.15 463.7 20.7 0.76 19897.266

USGSV057 PM2.5 Annual VERTICAL 540810 5174738.3 359.7 0.16944743 0.02135 25.91 294.3 24.38 0.31 3898.99758










USGSV108 PM2.5 Annual VERTICAL 540532 5174710 361 3.10719766 0.3915 31.39 294.3 22.36 1.37 69840.7365

USGSV114 PM2.5 Annual VERTICAL 540443.5 5174753.7 361 5.48819203 0.6915 60.66 294.3 14.99 2.03 102799.165

USGSV115 PM2.5 Annual VERTICAL 540953 5174696 361.1 1.49843913 0.1888 21.34 366.5 25.1 0.91 34590.145

USGSV116 PM2.5 Annual VERTICAL 540309 5174871 360.9 12.4803788 1.5725 42.67 310.9 15.52 2.29 135443.622


USGV1 PM2.5 Annual VERTICAL 540805.1 5174686 360.9 0.01446851 0.001823 8.23 294.3 6.06 1.22 15010.2582

USGV10 PM2.5 Annual VERTICAL 540715 5174685.2 360.9 0.01446851 0.001823 9.45 294.3 6.06 1.22 15010.2582

USGV11 PM2.5 Annual VERTICAL 540711.9 5174671.7 361.3 0.01446851 0.001823 8.23 294.3 6.06 1.22 15010.2582

USGV12 PM2.5 Annual VERTICAL 540688 5174681.4 361 0.01446851 0.001823 9.45 294.3 6.06 1.22 15010.2582


USGV14 PM2.5 Annual VERTICAL 540675.2 5174681.8 361 0.01446851 0.001823 9.45 294.3 6.06 1.22 15010.2582

















































USGV7NE PM2.5 Annual VERTICAL 540317.5 5174847.4 361 0.00290323 0.0003658 9.14 294.3 10.78 0.91 14855.8472

USGV7NW PM2.5 Annual VERTICAL 540285.3 5174862.3 361.2 0.00290323 0.0003658 9.14 294.3 10.78 0.91 14855.8472

USGV7SE PM2.5 Annual VERTICAL 540305.8 5174822.9 361.3 0.00290323 0.0003658 9.14 294.3 10.78 0.91 14855.8472

USGV7SW PM2.5 Annual VERTICAL 540273.8 5174837.2 361.4 0.00290323 0.0003658 9.14 294.3 10.78 0.91 14855.8472




Table B-12: Area Source Parameters used in annual PM2.5 NAAQS analysis for permit #01500002-101

SI ID# AERMOD ID Pollutant Averaging Time Easting (m) Northing (m) Base

Elevation (m)

Emission Rate

(g/sec/m2) Height (m) Length_X (m) Length_Y (m) Rotation

Angle (deg) Sigma z (m)

FUGI2 SAPCT001 PM2.5 Annual 543340.84 5174528.7 356.34 4.15E-06 6.1 60.77 15.41 20.32 2.84 FUGI6 SPRD007 PM2.5 Annual 542903.5 5174514.9 359.39 2.378E-06 2.59 100 10 -22.5 2.41 FUGI6 SPRD008 PM2.5 Annual 542999.78 5174555.9 358.38 2.378E-06 2.59 70 10 -52.15 2.41 FUGI6 SPRD009 PM2.5 Annual 543003.67 5174626.2 358.05 1.082E-06 2.59 25 10 9.45 2.41 FUGI6 SPRD010 PM2.5 Annual 542997.7 5174628.4 358.1 4.905E-06 2.59 35 10 -90 2.41 FUGI6 SPRD011 PM2.5 Annual 542887.3 5174665.2 359.33 4.905E-06 2.59 100 10 6.88 2.41 FUGI6 SPRD012 PM2.5 Annual 542789.3 5174687.2 359.79 4.905E-06 2.59 100 10 12.63 2.41 FUGI6 SPRD013 PM2.5 Annual 542740.07 5174696.9 359.79 4.905E-06 2.59 50 10 11.43 2.41 FUGI6 SPRD019A PM2.5 Annual 543106.78 5174673.1 356.75 2.033E-06 2.59 40 10 -50 2.41 FUGI6 SPRD019B PM2.5 Annual 543132.42 5174704.1 356.74 1.878E-06 2.59 60 10 -50 2.41 FUGI6 SPRD020 PM2.5 Annual 543039.3 5174616.1 357.51 2.108E-06 2.59 85 10 -40.95 2.41 FUGI6 SPRD021 PM2.5 Annual 543135.87 5174692 356.76 6.937E-07 2.59 100 10 -21.06 2.41 FUGI6 SPRD022 PM2.5 Annual 543234.75 5174732.4 356.68 6.937E-07 2.59 50 10 -76.22 2.41 FUGI6 SPRD023 PM2.5 Annual 542984.45 5174739.4 358.38 7.496E-08 2.59 120 100 41.56 2.41 FUGI6 SPRD024 PM2.5 Annual 543041.8 5174613.7 357.47 4.433E-07 2.59 100 10 9.7 2.41 FUGI6 SPRD025 PM2.5 Annual 543140.63 5174595.8 356.7 4.433E-07 2.59 100 10 42 2.41 FUGI6 SPRD026A PM2.5 Annual 543216.43 5174527.6 356.84 4.433E-07 2.59 50 10 45.73 2.41 FUGI6 SPRD026B PM2.5 Annual 543252.15 5174491.9 357.02 1.44E-07 2.59 50 10 45.73 2.41 FUGI6 SPRD027 PM2.5 Annual 543288.02 5174456.7 359.99 1.44E-07 2.59 100 10 48 2.41 FUGI6 SPRD028 PM2.5 Annual 543256.82 5174498.8 356.72 2.993E-07 2.59 100 10 11.36 2.41 FUGI6 SPRD029 PM2.5 Annual 543357.57 5174482.9 357.31 2.815E-07 2.59 100 10 -0.17 2.41 FUGI6 SPRD030 PM2.5 Annual 543372.02 5174381.5 358.68 3.246E-07 2.59 50 10 -15.9 2.41 FUGI6 SPRD031 PM2.5 Annual 543423.69 5174397.6 355.65 3.246E-07 2.59 90 10 -66.31 2.41 FUGI6 SPRD032 PM2.5 Annual 543460.9 5174483.8 353.7 6.952E-07 2.59 100 10 9 2.41 FUGI6 SPRD033 PM2.5 Annual 543559.43 5174466.9 353.84 6.365E-07 2.59 50 10 12 2.41 FUGI6 SPRD034 PM2.5 Annual 543612.46 5174403.3 349.69 2.534E-07 2.59 50 10 -82.01 2.41 FUGI6 SPRD035 PM2.5 Annual 543611 5174456.2 352.75 3.707E-07 2.59 40 10 1.28 2.41 FUGI6 SPRD036 PM2.5 Annual 543652.04 5174466 350.21 1.064E-07 2.59 70 10 -78.5 2.41 FUGI6 SPRD037 PM2.5 Annual 543664.4 5174537.7 349.36 1.064E-07 2.59 100 10 -60 2.41 FUGI6 SPRD038 PM2.5 Annual 543688.9 5174638.2 350.43 1.064E-07 2.59 25 10 42 2.41 FUGI6 SPRD039 PM2.5 Annual 543669.3 5174623.5 351.15 9.061E-08 2.59 25 10 -25 2.41 FUGI6 SPRD040 PM2.5 Annual 543588.27 5174563 352.52 1.244E-08 2.59 70 10 18.87 2.41 FUGI6 SPRD041 PM2.5 Annual 543519.41 5174577.8 353.78 7.11E-08 2.59 70 10 12 2.41 FUGI6 SPRD042 PM2.5 Annual 543523.54 5174587.6 353.62 5.866E-08 2.59 50 10 -80 2.41 FUGI6 SPRD043 PM2.5 Annual 543469.34 5174589.3 353.84 7.11E-08 2.59 50 10 12.85 2.41 FUGI6 SPRD044 PM2.5 Annual 543453.98 5174550.9 354.27 1.602E-07 2.59 50 10 -71.09 2.41


FUGI6 SPRD045 PM2.5 Annual 543442.6 5174549.2 354.3 1.602E-07 2.59 55 10 79.92 2.41 FUGI6 SPRD046 PM2.5 Annual 543355.41 5174380.8 357.25 4.685E-07 2.59 40 10 55 2.41 FUGI6 SPRD047B PM2.5 Annual 543441.44 5174257.1 356.89 4.52E-07 2.59 50 10 56 2.41 FUGI6 SPRD048 PM2.5 Annual 543470.45 5174214.7 356.85 4.52E-07 2.59 100 10 53.89 2.41 FUGI6 SPRD049 PM2.5 Annual 543529.17 5174133.5 356.67 4.52E-07 2.59 40 10 42.96 2.41 FUGI6 SPRD051 PM2.5 Annual 543608.23 5174466.9 353.07 1.244E-08 2.59 85 10 -74.71 2.41 FUGI6 SPRD052 PM2.5 Annual 543690.68 5174645.6 350.24 1.574E-08 2.59 70 10 -90 2.41 FUGI6 SPRD053 PM2.5 Annual 543571.65 5174474.7 353.8 5.866E-08 2.59 90 10 -78.25 2.41 FUGI6 SPRD055 PM2.5 Annual 543375.84 5174611.2 354.09 8.905E-08 2.59 85 10 12.91 2.41 FUGI6 SPRD056 PM2.5 Annual 543376.54 5174569.6 355 8.905E-08 2.59 40 10 -77.25 2.41 FUGI6 SPRD057 PM2.5 Annual 543277.71 5174585.5 356.73 8.905E-08 2.59 100 10 15.12 2.41 FUGI6 SPRD059 PM2.5 Annual 543144.3 5174734.7 356.68 1.34E-06 2.59 150 70 -50.55 2.41 FUGI6 SPRD060 PM2.5 Annual 542788.63 5174791.1 359.79 7.496E-08 2.59 200 95 13.66 2.41 FUGI7 SPRD061 PM2.5 Annual 543638.03 5174028.9 354.4 2.954E-07 2.59 60 10 51.58 2.41 FUGI7 SPRD062 PM2.5 Annual 543677.7 5173980.4 356.07 2.954E-07 2.59 100 10 30.78 2.41 FUGI7 SPRD063 PM2.5 Annual 543764.21 5173929.9 355.64 2.954E-07 2.59 100 10 30.55 2.41 FUGI7 SPRD087 PM2.5 Annual 543445.96 5174267.8 358.18 9.727E-09 2.59 100 10 -33.67 2.41 FUGI7 SPRD088 PM2.5 Annual 543529.03 5174324 356.87 9.727E-09 2.59 25 10 -33.67 2.41 FUGI7 SPRD096 PM2.5 Annual 542425.1 5175113.9 356.86 1.71E-07 2.59 197.1 323.6 104.6 2.41 FUGI7 SPRD097 PM2.5 Annual 542739.1 5175033.2 356.71 2.1E-07 2.59 125.9 371.7 104.3 2.41


Table B-13: Volume Source Parameters used in annual PM2.5 NAAQS analysis for permit #01500002-101


Time Easting (m) Northing (m)

Base Elevation

(m)

Emission Rate

(lb/hr)

Emission Rate

(g/sec) Height (m)

Lateral Dimension

(m)

Vertical Dimension

(m) Length (m)

FUGI3 SAPMH01 PM2.5 Annual 543611.9 5174338 349.58 9.475E-06 1.19E-06 0.61 30.23 0.1 129.989

FUGI8 SAPMH02 PM2.5 Annual 543982.94 5173851.8 346.77 0.0001506 0.000019 0.59 23.98 0.1 103.114

FUGI5 SAPMH03 PM2.5 Annual 543659.46 5174630.4 351.49 2.814E-05 3.55E-06 3.05 1.42 0.7 6.106








FUGI3 SAPMH11 PM2.5 Annual 543578.36 5174344.4 353.81 0.0003456 0.0000435 0 0.23 0 0.989

FUGI9 SAPWE01 PM2.5 Annual 542759.44 5174739.1 359.79 2.274E-05 2.87E-06 9.14 9.3 2.13 39.99


FUGI9 SAPWE03 PM2.5 Annual 542856.56 5174713 359.6 2.274E-05 2.87E-06 9.14 9.3 2.13 39.99


FUGI9 SAPWE05 PM2.5 Annual 543611.9 5174338 349.58 0.0001462 0.0000184 1.83 30.23 1.7 129.989

FUGI5 SAPWE06 PM2.5 Annual 543982.94 5173851.8 346.77 0.0020493 0.000258 1.83 23.98 1.7 103.114

FUGI5 SAPWE07 PM2.5 Annual 543879.84 5173829 356.67 0.0032222 0.000406 1.83 23.98 1.7 103.114

FUGI5 SAPWE08 PM2.5 Annual 543776.74 5173806.2 357.66 0.0032222 0.000406 1.83 23.98 1.7 103.114

FUGI11 SPRD094 PM2.5 Annual 543611.9 5174338 349.58 0.0013047 0.000164 2.59 30.23 2.41 129.989

FUGI5 SPRD095A PM2.5 Annual 543982.94 5173851.8 346.77 0.0249278 0.0031408 2.59 23.98 2.41 103.114

FUGI5 SPRD095B PM2.5 Annual 543879.84 5173829 356.67 0.0249278 0.0031408 2.59 23.98 2.41 103.114

FUGI5 SPRD095C PM2.5 Annual 543776.74 5173806.2 357.66 0.0249278 0.0031408 2.59 23.98 2.41 103.114

FUGI11 SAPRA004 PM2.5 Annual 542540.3 5174569.1 359.79 0.0032651 0.0004114 2.75 4.65 2.55 19.995














FUGI11 SAPRA017 PM2.5 Annual 542629.05 5174582 359.79 0.0032651 0.0004114 2.75 4.65 2.55 19.995







































FUGI11 SAPRC001 PM2.5 Annual 542648.01 5174723.3 359.79 0.017539 0.00221 2.59 4.65 2.41 19.995



FUGI11 SAPRC004 PM2.5 Annual 542676.95 5174716 359.79 0.0059278 0.000747 2.59 4.65 2.41 19.995





FUGI11 SAPRC009 PM2.5 Annual 542725.6 5174707 359.79 0.0066803 0.000842 2.65 4.65 2.46 19.995


FUGI11 SAPRD001 PM2.5 Annual 543441.25 5174266.1 357.33 0.0035594 0.0004485 3.11 4.65 2.89 19.995











FUGI11 SAPRE001 PM2.5 Annual 543636.18 5174037.4 354.2 0.0034766 0.000438 3.11 4.65 2.89 19.995





FUGI11 SAPRE006 PM2.5 Annual 543600.6 5174073 353.92 0.0009998 0.000126 3.11 4.65 2.89 19.995





FUGI11 SAPRF001 PM2.5 Annual 542637.4 5174725.6 359.79 0.0020583 0.0002593 2.75 4.65 2.56 19.995

FUGI11 SAPRF002 PM2.5 Annual 542627.5 5174728 359.79 0.0020583 0.0002593 2.75 4.65 2.56 19.995


FUGI11 SAPRF004 PM2.5 Annual 542608 5174732.6 359.79 0.0020583 0.0002593 2.75 4.65 2.56 19.995





FUGI11 SAPRF009 PM2.5 Annual 542559 5174744 359.79 0.0020583 0.0002593 2.75 4.65 2.56 19.995




























FUGI11 SAPRG001 PM2.5 Annual 542293 5174802.3 359.92 0.0010711 0.000135 2.59 4.65 2.41 19.995

FUGI11 SAPRG002 PM2.5 Annual 542285.7 5174794.1 359.96 0.0012893 0.0001624 2.59 4.65 2.41 19.995



FUGI11 SAPRG005 PM2.5 Annual 542254.8 5174785 359.95 0.0010711 0.000135 2.59 4.65 2.41 19.995


FUGI11 SAPRG007 PM2.5 Annual 542234.2 5174785.7 359.99 0.0007868 9.914E-05 2.59 4.65 2.41 19.995

FUGI11 SAPRG008 PM2.5 Annual 542230.1 5174793.9 359.97 0.0007868 9.914E-05 2.59 4.65 2.41 19.995















FUGI11 SAPRH001 PM2.5 Annual 542310.9 5174903.5 359.89 0.015032 0.001894 3.11 4.65 2.89 19.995


FUGI11 SAPRH003 PM2.5 Annual 542324.6 5174919 359.92 0.015032 0.001894 3.11 4.65 2.89 19.995

FUGI11 SAPRH004 PM2.5 Annual 542331 5174926.2 359.94 0.015032 0.001894 3.11 4.65 2.89 19.995





















































FUGI11 SAPRI001 PM2.5 Annual 542302.7 5174815.2 359.91 0.0004183 5.27E-05 3.11 4.65 2.89 19.995



FUGI11 SAPRI004 PM2.5 Annual 542319.6 5174839.6 359.79 0.0008789 0.0001107 3.11 4.65 2.89 19.995




FUGI11 SAPRI008 PM2.5 Annual 542342.7 5174872 359.79 0.0008789 0.0001107 3.11 4.65 2.89 19.995

FUGI11 SAPRI009 PM2.5 Annual 542352 5174876.4 359.79 0.0008789 0.0001107 3.11 4.65 2.89 19.995
































FUGI11 SAPRI040 PM2.5 Annual 542650.3 5174812 359.79 0.000726 9.147E-05 3.11 4.65 2.89 19.995


FUGI11 SAPRJ001 PM2.5 Annual 542669.5 5174806.4 359.75 0.0001314 1.656E-05 2.09 4.65 1.95 19.995

FUGI11 SAPRJ002 PM2.5 Annual 542667.2 5174797.1 359.77 0.0016379 0.0002064 2.09 4.65 1.95 19.995


FUGI11 SAPRJ004 PM2.5 Annual 542661.9 5174777 359.79 0.0028028 0.0003531 2.09 4.65 1.95 19.995


FUGI11 SAPRJ006 PM2.5 Annual 542657 5174759.7 359.79 0.0028028 0.0003531 2.09 4.65 1.95 19.995


FUGI11 SAPRJ008 PM2.5 Annual 542651.5 5174739 359.79 0.002297 0.0002894 2.09 4.65 1.95 19.995


FUGI11 SAPRK001 PM2.5 Annual 543078.9 5174823.6 357.23 0.0006999 8.818E-05 2.07 4.65 1.93 19.995

FUGI11 SAPRK002 PM2.5 Annual 543080.7 5174833.3 357.17 0.0008962 0.0001129 2.07 4.65 1.93 19.995



FUGI11 SAPRK004 PM2.5 Annual 543083.8 5174853 356.89 0.0008962 0.0001129 2.07 4.65 1.93 19.995




FUGI11 SAPRK008 PM2.5 Annual 543090 5174891.8 356.4 0.0008962 0.0001129 2.07 4.65 1.93 19.995







FUGI11 SAPRK015 PM2.5 Annual 543082 5174953 355.98 0.000373 4.7E-05 2.07 4.65 1.93 19.995




FUGI11 SAPRK019 PM2.5 Annual 543043.8 5174965 355.94 0.00021 2.645E-05 2.07 4.65 1.93 19.995










FUGI11 SAPRK029 PM2.5 Annual 542948 5174991.7 356.39 0.00021 2.645E-05 2.07 4.65 1.93 19.995






















USGFSA PM2.5 Annual 540714.8 5174722.3 360.1 0.1239704 0.01562 3.5 3.89 3.26 16.727

USGFSB PM2.5 Annual 540579.8 5174723 360.6 8.953E-05 1.128E-05 3.5 3.24 3.26 13.932

USGFSC PM2.5 Annual 540385 5174770 361.2 0.0042239 0.0005322 3.5 3.24 3.26 13.932

USGFSD PM2.5 Annual 540456 5174748 361 0.0001033 1.301E-05 3.5 3.24 3.26 13.932

USGUPR01 PM2.5 Annual 540241.4 5175049.1 359.9 0.0005312 6.693E-05 3 4.65 1.4 19.995









USGUPR10 PM2.5 Annual 540375.1 5174929 359.8 0.0005312 6.693E-05 3 4.65 1.4 19.995




USGUPR13 PM2.5 Annual 540421.3 5174890.7 359.8 0.0018754 0.0002363 3 4.65 1.4 19.995

USGUPR14 PM2.5 Annual 540437.6 5174879.1 359.9 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR15 PM2.5 Annual 540454 5174867.6 359.8 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR16 PM2.5 Annual 540470.9 5174856.9 359.9 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR17 PM2.5 Annual 540487.8 5174846.3 359.8 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR18 PM2.5 Annual 540504.7 5174835.7 359.9 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR19 PM2.5 Annual 540520.6 5174823.5 359.8 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR20 PM2.5 Annual 540530.9 5174807.2 359.9 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR21 PM2.5 Annual 540542.4 5174792.2 359.9 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR22 PM2.5 Annual 540559.7 5174782.1 360 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR23 PM2.5 Annual 540577 5174772.1 360 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR24 PM2.5 Annual 540594.3 5174762.1 360.1 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR25 PM2.5 Annual 540611.6 5174752.1 360 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR26 PM2.5 Annual 540629 5174742.1 360.1 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR27 PM2.5 Annual 540646.8 5174733.1 360.1 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR28 PM2.5 Annual 540665.9 5174730.9 360 0.0018746 0.0002362 3 4.65 1.4 19.995

USGUPR29 PM2.5 Annual 540685.8 5174732.5 359.9 0.0018746 0.0002362 3 4.65 1.4 19.995

USGVOLO PM2.5 Annual 540365.7 5174729 361.7 0.0473262 0.005963 8.53 30.07 3.97 129.301

JHBVS001 PM2.5 Annual 542719.2 5174340 364.24 0.0023969 0.000302 3.05 5.67 2.835 24.381

JHBVS002 PM2.5 Annual 542719.2 5174321.7 364.24 0.0023969 0.000302 3.05 5.67 2.83 24.381

JHBVS003 PM2.5 Annual 542719.2 5174303.4 364.24 0.003127 0.000394 3.05 5.67 2.83 24.381

JHBVS004 PM2.5 Annual 542719.2 5174285.1 364.24 0.003127 0.000394 3.05 5.67 2.83 24.381

JHBVS005 PM2.5 Annual 542739.16 5174273.5 364.24 0.003127 0.000394 3.05 5.67 2.83 24.381

JHBVS006 PM2.5 Annual 542759.67 5174270.1 364.24 0.003127 0.000394 3.05 5.67 2.83 24.381

JHBVS007 PM2.5 Annual 542771.86 5174253.5 364.24 0.003127 0.000394 3.05 5.67 2.83 24.381

JHBVS008 PM2.5 Annual 542771.86 5174235.2 364.24 0.0043017 0.000542 3.05 5.67 2.83 24.381

JHBVS009 PM2.5 Annual 542775.74 5174223.6 364.24 0.0043017 0.000542 3.05 5.67 2.83 24.381

JHBVS010 PM2.5 Annual 542757.45 5174217.5 364.24 0.0013254 0.000167 3.05 5.67 2.83 24.381


JHBVS011 PM2.5 Annual 542738.06 5174211.4 364.24 0.0013254 0.000167 3.05 5.67 2.83 24.381

JHBVS012 PM2.5 Annual 542718.67 5174205.3 364.24 0.0013254 0.000167 3.05 5.67 2.83 24.381

JHBVS013 PM2.5 Annual 542699.28 5174199.2 364.24 0.0013254 0.000167 3.05 5.67 2.83 24.381

JHBVS014 PM2.5 Annual 542677.65 5174195.9 364.24 0.0019524 0.000246 3.05 5.67 2.83 24.381

JHBVS015 PM2.5 Annual 542677.65 5174177.6 364.24 0.001127 0.000142 3.05 5.67 2.83 24.381

JHBVS016 PM2.5 Annual 542677.65 5174159.3 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS017 PM2.5 Annual 542696.49 5174152.7 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS018 PM2.5 Annual 542715.89 5174152.7 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS019 PM2.5 Annual 542715.89 5174132.2 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS020 PM2.5 Annual 542725.86 5174116.1 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS021 PM2.5 Annual 542745.81 5174113.3 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS022 PM2.5 Annual 542764.1 5174120.5 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS023 PM2.5 Annual 542782.39 5174127.7 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS024 PM2.5 Annual 542800.68 5174134.9 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS025 PM2.5 Annual 542817.86 5174143.2 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS026 PM2.5 Annual 542836.7 5174148.2 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS027 PM2.5 Annual 542855.54 5174153.2 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS028 PM2.5 Annual 542874.38 5174158.2 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS029 PM2.5 Annual 542893.22 5174163.2 364.24 0.0006246 0.0000787 3.05 5.67 2.83 24.381

JHBVS030 PM2.5 Annual 542765.77 5174244.7 364.24 0.0018969 0.000239 3.05 5.67 2.83 24.381

JHBVS031 PM2.5 Annual 542745.81 5174244.7 364.24 0.0018969 0.000239 3.05 5.67 2.83 24.381

JHBVS032 PM2.5 Annual 542725.85 5174244.7 364.24 0.0014048 0.000177 3.05 5.67 2.83 24.381

JHBVS033 PM2.5 Annual 542705.89 5174244.7 364.24 0.0014048 0.000177 3.05 5.67 2.83 24.381

JHBVS034 PM2.5 Annual 542783.5 5174203.6 364.24 0.0015635 0.000197 3.05 5.67 2.83 24.381

JHBVS035 PM2.5 Annual 542790.15 5174185.9 364.24 0.0015635 0.000197 3.05 5.67 2.83 24.381

JHBVS036 PM2.5 Annual 542668.23 5174213.6 364.24 0.0014524 0.000183 3.05 5.67 2.83 24.381

JHBVS037 PM2.5 Annual 542657.7 5174230.8 364.24 0.0014524 0.000183 3.05 5.67 2.83 24.381

JHBVS38A PM2.5 Annual 542717.6 5174220.4 364.24 0.0094684 0.001193 3.05 5.012 2.127 21.5516

JHBVS38B PM2.5 Annual 542630.9 5174245.1 364.24 0.0021881 0.0002757 13.7 4.652 6.38 20.0036


Table B-14: Source Parameters used in annual PM2.5 Increment analysis for permit #01500002-101



Release Type

Easting (m)

Northing (m)

Base Elevation

(m)

Emission Rate

(lb/hr)

Emission Rate

(g/sec)

Height (m)

Exit Temp (K)

Exit Velocity

(m/s)

Diameter (m)

Flow Rate (ACFM)

N/A SV6PRE PM2.5 Annual 1 VERTICAL 543523.14 5174525.9 354.04 -14.567481 -1.8354702 99.1 449.82 24.07 3.4 463053

STRU42 SV6POST PM2.5 Annual 2 VERTICAL 543523.14 5174525.9 354.04 17.476458 2.2019949 99.1 449.82 24.07 3.4 463053



N/A SV2PRE PM2.5 Annual 1 VERTICAL 543574.18 5174615 352.85 -3.5185992 -0.4433357 83.8 563.15 12.13 1.8 67500

STRU38 SV2POST PM2.5 Annual 2 VERTICAL 543574.18 5174615 352.85 4.5947489 0.5789281 83.8 563.15 12.13 1.8 67500




Appendix C: Road Segment Speed Limit and Silt Load Test Areas


Appendix D: Performance Test Recordkeeping Items and Testing Schedule

Performance Test Recordkeeping Items: Item and Description

Control Equipment Process Flow Parameters to Record and Include in Test Report

Target Process Rates for Performance Testing*

Control Equipment Parameters to Record and Include in Test Report

Control Equipment Operating Parameter Limits*

EQUI2 (EU002) Power Boiler #7

TREA11 (CE002) Multiclones; TREA15 (CE003) Electrostatic Precipitator - High Efficiency

Steam flow rate (lbs/hour); Fuel usage (tons/hour)

171,000 lbs/hour Steam Flow; 28.5 tons/hour wood/bark usage (8-hour block average); 502 tons/day railroad tie usage (24-hour block average)

Opacity (%) using COM EQUI135

Opacity <= 10% (3-hour rolling average)


TREA18 (CE005) Multiclones; TREA19 (CE006) Electrostatic Precipitator - High Efficiency

Fuel usage (tons/hour) 45.5 tons/hour wood/bark usage (8-hour block average); 1,030 tons/day railroad tie usage (24-hour block average)



EQUI53 (EU005) Recovery Boiler #10

TREA20 (CE007) Electrostatic Precipitator - High Efficiency

Black Liquor Solids (tons/hour); Steam Production (lbs/hour)

825,000 lbs/hour Steam Flow



EQUI7 (EU011) Bleach Plant

TREA17 (CE011) Bleach Plant Scrubber

Air Dried Tons Bleached Pulp (ADTBP) Production (tons/hour); Oven Dried Tons Bleached Pulp (ODTBP) Production (tons/hour)

NA pH using PEM EQUI129; Liquid Flow Rate (gpm) using PEM EQUI130; scrubber fan amperage (%) using PEM EQUI131

pH >= 10.5; Liquid Flow Rate >= 225 gpm; Fan Amperage >= 33%


Item and Description

Control Equipment Process Flow Parameters to Record and Include in Test Report

Target Process Rates for Performance Testing*

Control Equipment Parameters to Record and Include in Test Report

Control Equipment Operating Parameter Limits*

EQUI51 (EU031) Smelt Dissolving Tank

TREA6 (CE030) Ventri Rod Scrubber; TREA12 (CE017) Spray Tower

Black Liquor Solids (tons/hour); Steam Production (lbs/hour); Liquor Flow (gpm)

NA TREA12 Pressure Drop (in. w. c.) using PEM EQUI127; TREA12 Water Pressure (Liquid Supply Pressure) (psi) using PEM EQUI70; TREA6 Pressure Drop (in. w. c.) using PEM EQUI77; Both scrubbers together: total Liquid Flow Rate (gpm) using EQUI109

TREA12 Pressure Drop <= 0 in. w. c.; 20 psi >= TREA12 Water Pressure >= 10 psi; 9 in. w. c. >= TREA6 Pressure Drop >= 3 in. w. c.; Total Liquid Flow Rate >= 300 gpm

EQUI52 (EU033) Rotary Lime Kiln

TREA21 (CE019) Electrostatic Precipitator - High Efficiency

CaO production (tons/day); Natural Gas Input (kscfh); ADTBP Production (tons/hour)

500 tons/day CaO Production



EQUI49 (EU081) Incinerator Quencher Scrubber

TREA30 (CE022) Incinerator; TREA31 (CE023) Scrubber

ADTBP Production (tons/hour) NA TREA30 Combustion Chamber Outlet Temperature (Fahrenheit); TREA31 pH; TREA31 Liquid Flow Rate (gpm)

Temperature >= 1500 F; pH >= 7.4; Liquid Flow Rate >= 584 gpm

*These are the limits and required control equipment parameters in the permit as of issuance of permit #01700002-101. If these values are updated by subsequent performance testing then the most recently updated values apply.


Performance Testing Schedules and Methods: Item and Description Pollutants

tested Performance Test Method(s)

Testing frequency as of permit #01700002-101


PM PM10 PM2.5 FPM NOx Hg H2SO4

5 & 202 5 & 202 5 & 202 5 7E 30B OTM 13A

36 months 36 months 60 months 12 months 60 months 60 months 60 months


PM PM10 PM2.5 FPM Hg H2SO4

5 & 202 5 & 202 5 & 202 5 30B OTM 13A

60 months 60 months 60 months 36 months 60 months 60 months

EQUI53 (EU005) Recovery Boiler #10

PM PM10 PM2.5

5 & 202 201A & 202 201A & 202

Initial Test + Frequency Plan Initial Test + Frequency Plan Initial Test + Frequency Plan

EQUI7 (EU011) Bleach Plant

VOC CO ClO2

25A 10 320

60 months 60 months 60 months

EQUI51 (EU031) Smelt Dissolving Tank

PM PM10 PM2.5 TRS

5 & 202 5 & 202 5 & 202 16C

Initial Test + Frequency Plan Initial Test + Frequency Plan Initial Test + Frequency Plan Initial Test + Frequency Plan


Item and Description Pollutants tested

Performance Test Method(s)

Testing frequency as of permit #01700002-101

EQUI52 (EU033) Rotary Lime Kiln

PM PM10 PM2.5 FPM NOx H2SO4 TRS VOC SO2 CO Hg

5 & 202 201A & 202 201A & 202 5 7E OTM 13A8 16C 25A 6C 10 30B

60 months 60 months 60 months 60 months 12 months Initial Test + Frequency Plan 60 months Initial Test + Frequency Plan Initial Test + Frequency Plan Initial Test + Frequency Plan Initial Test + Frequency Plan

EQUI49 (EU081) Incinerator Quencher Scrubber

PM PM10 PM2.5 TRS H2SO4 NOx Total HAP

5 & 202 5 & 202 5 & 202 16C 8 7E According to 40 CFR 63.457

60 months 60 months 60 months 60 months 60 months 12 months 60 months

EQUI316 Chip Pre-Steaming Bin

VOC 25A Initial Test + Frequency Plan


Appendix E: Fugitive Emission Control Plan 1.0 PURPOSE

The Fugitive Control Plan has been developed in accordance with the requirement of the Title V Air Permit 01700002 for Sappi Cloquet, LLC.

2.0 RESPONSIBILITIES

Compliance with the Fugitive Control Plan is supervised by the Environmental Department. Major roles in plan implementation include:

§ Environmental Department o Conduct periodic visual inspections. o Implement/request dust control strategies, as needed. o Manage training requirements

§ Operating Departments o Awareness of fugitive dust sources in their area. o Complete and document required inspections. o Implement/request dust control strategies, as needed. o Complete required annual training.

§ Maintenance Department o Awareness of fugitive dust sources in their area; and o Implement/request dust control strategies, as needed.

The fugitive dust sources and the control strategies are further defined within the plan.

3.0 DEFINITIONS

3.1. Fugitive Dust means dust and/or particulate emissions from a non-point source such as roads and landfill operations.

3.2. Dry Bulk Material Handling means the three areas where dry solids are transferred, conveyed, or generated at the mill: boiler ash silos, stock prep railcar unloading, and recausticizing lime storage.

4.0 FUGITIVE CONTROL PLAN

4.1. INTRODUCTION

The permit requirement is as follows:

Fugitive Control Plan: The Permittee shall implement the Fugitive Control Plan, which is due 90 days after permit issuance. The Plan shall describe methods that the Permittee will use to control fugitive emissions from the property, including from paved and unpaved roads and from the Sappi Industrial Solid Waste Landfill. Upon approval by the MPCA, the Plan shall be an enforceable part of the permit.


4.2. FUGITIVE DUST SOURCES AND CONTROL STATEGIES

4.2.1. Paved Roadways

Most of the major roadways found at the approximately 240-acre mill site are paved. Potential major sources of deposits on the paved roadways include:

§ Soil and debris which are washed onto the roadway with stormwater; § Debris from construction and logging trucks; and § Debris from trucks hauling solid materials such as ash, lime mud, recausticizing solids, knots,

wood chips and bark.

Control Strategies § Sweep all paved roadways weekly or on an as-needed basis during non-freezing weather

conditions (generally after the snow melt in April / May through snow fall in October / November).

§ Require logging trucks to sweep down trailer beds after unloading to minimize fallout of debris on company and community roadways. This condition is part of the contract with the loggers.

§ Maintain a log of sweeping activities at the Main Gate.

4.2.2 Unpaved Roadways

The facility has very few unpaved roadways. The unpaved roadways include access pathways between

chip and log piles, which have limited traffic; roadways in the wood yard area should not be paved due to the probability of contaminating wood chips with asphalt. The perimeter roadway that surrounds the industrial solid waste landfill is also unpaved; this roadway has very limited traffic. Unpaved roadways also exist in construction areas; these roadways are temporary.

Control Strategies § Limit vehicle speed on unpaved roadways. § Apply water or chemical dust suppressant on unpaved roadways as needed to control fugitive

dust.

§ Maintain a log of water application activities in eLogger (Woodroom)


4.2.2. Industrial Solid Waste Landfill

The Cloquet mill is permitted to place boiler ash, wastewater treatment plant sludge, lime mud and recausticizing solids in the on-site industrial solid waste landfill (MPCA Permit SW-209). The Permit contains requirements intended to control fugitive dust emissions from the landfill. During the Title V permitting process for the Cloquet mill, air quality, groundwater, and solid waste staff of the MPCA agreed that all of the fugitive dust control requirements applicable to the facility would be included in the Fugitive Control Plan required by the Title V Air Permit. All fugitive dust control requirements applicable to the facility are contained in this plan and are presented below.

Control Strategies § Uncontrolled stockpiling of boiler ash, lime mud and excess re-burned lime prior to reclaim or

transport to the landfill will not be allowed for more than a 24-hour period of time with two exceptions.

(1) Material may be stockpiled in the old recausticizing process solids loading area prior

to transfer to the landfill. This loading area is shielded from the wind on three sides. If stockpiling for more than a 24-hour period at the mill-site becomes necessary, measures such as applying water, chemical dust suppressant or covering the material with a tarp may be employed to control fugitive dust.

(2) Lime mud and ash can be stockpiled at the landfill to allow for future reclaim.

Measures such as applying water, chemical dust suppressant or covering the lime mud with a tarp may be employed to control fugitive dust.

§ Apply water or chemical dust suppressant to the uncovered and inactive portion of the landfill

as needed to control fugitive dust emissions. Application of water or chemical dust suppressant is not required when the ambient air temperature is below 32 oF.

§ Intermittent cover will be freshly placed waste. Waste placed within the previous 30 days shall

meet the requirement for intermittent cover.

§ Intermediate cover (12 inches of soil or suitable cover material) will be placed in areas where no additional materials will be placed for a period of 120 days or longer, unless otherwise approved by the MPCA.


4.2.3. Dry Bulk Material Handling § Sappi has three areas where dry solids are generated, transferred, or handled in bulk. Power

boiler fly and bottom ash are generated in the ash silos and transferred to trucks for delivery to the landfill. Clays, starches, and other paper coating constituents are transferred from rail car to storage silos in the stock prep area. Finally, reburned lime is conveyed by bucket to storage silos in the recausticizing area. Purchased lime is also occasionally delivered by truck and transferred to storage silos.

§ Employees in these areas have specific inspection and recordkeeping requirements. They also receive tailored annual training to address fugitive dust concerns and review past incidents.

4.3. PERIODIC VISUAL INSPECTIONS

Visual inspections will be conducted by Environmental staff at least once every 2 weeks. The purpose of the inspections will be to verify that control strategies are being followed and to identify areas that need additional attention. The visual inspection check list is completed and filed in the environmental central files.

4.4. RECORD KEEPING

Records for dust control will be kept on file for a minimum of five (5) years for the following:

§ Paved roadway sweeping; § Landfill roadway water or chemical dust suppressant application; and § Water or chemical dust suppressant application on the active or inactive portion of the landfill. § Unpaved roadways in the wood yard including access pathways between chip and log piles.

The dust control records will contain the following information:

§ Date; § Initials of person operating equipment; and § Area swept and/or area where water or chemical dust suppressant was applied.

Records will be kept on file for a minimum of five (5) years for visual inspections. The visual inspection records will contain the following information:

§ Date; § Initials of person conducting the inspection; and § Area inspected and issues noted.

Technical Support Document, Permit Number: 01700002-101 Page 1 of 27

Technical Support Document For

Air Emission Permit No. 01700002-101 This technical support document (TSD) is intended for all parties interested in the permit and to meet the requirements that have been set forth by the federal and state regulations (40 CFR § 70.7(a)(5) and Minn. R. 7007.0850, subp. 1). The purpose of this document is to provide the legal and factual justification for each applicable requirement or policy decision considered in the determination to issue the permit. 1. General information

1.1 Applicant and stationary source location:

Table 1. Applicant and source address

Applicant/Address Stationary source/Address (SIC Code: 2611)

Sappi Fine Paper LLC 255 State St Boston, Massachusetts 02110-2617

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

Contact: Robert Schilling Phone: 218-879-2300

1.2 Facility description

Sappi Cloquet, LLC (Sappi) is an existing pulp and paper mill which manufactures kraft paper pulp, specialized cellulose pulp (SC), and fine coated paper. The pulp-making procedure starts with wood being delivered onsite, debarked, and chipped. The wood chips are then fed into ten batch digesters (EQUI 15) where they are cooked with white liquor and steam to separate the cellulose fibers (hemicellulose and cellulose) from the lignin. White liquor is a solution of sodium sulfide (Na2S) and sodium hydroxide (NaOH). When making SC pulp, an additional pre-hydrolysis step is required to remove the hemicellulose, which produces a higher purity pulp. When making kraft paper pulp the wood to pulp conversion yield is about 50% percent, and for SC pulp the yield is about 35%. Exhaust gases from the digestion process are collected by the non-condensable gas systems (NCG), which consist of VOCs and odorous total reduced sulfur compounds (TRS) including hydrogen sulfide, methyl mercaptan, dimethyl sulfide, and dimethyl disulfide. The NCGs are vented to and controlled by the Incinerator-Quencher-Scrubber (IQS) system (EQUI 49). The incinerator (TREA 30) thermally oxidizes the VOC, HAP and TRS compounds from the gas stream to produce carbon dioxide (CO2), sulfur dioxide (SO2), and water vapor. The quencher cools the gas stream from the incinerator by spraying and evaporating a circulating scrubbing solution. The scrubber portion (TREA 31) of the IQS removes SO2 by contacting the flue gas with an alkaline spraying solution. After being discharged from the digesters the spent cooking liquor and pulp must be separated. The pulp is washed, bleached, dried, sheeted and either shipped off-site or used to make paper on Sappi’s paper machines. The spent cooking liquor and pulp wash water are combined to make weak black liquor solids (BLS), which is a mixture of lignin, carbohydrates from hemicellulose, sodium carbonate, sodium sulfate, and inorganic salts. The weak BLS are concentrated in evaporators to make strong BLS, which can then be combusted in the recovery boiler (EQUI 53). NCGs from the evaporators are vented to the IQS. The primary function of the recovery boiler is to reduce the inorganic portion of BLS from sodium sulfate to sodium sulfide by chemical reduction reactions. The cooking chemicals collect as molten smelt at the bottom of the boiler. The organic portion of the BLS burns and provides steam for electricity and heat for other processes at the plant. The recovery boiler is a primary source of all criteria pollutant emissions, as well as sulfuric acid


(H2SO4) mist, TRS, and Hazardous Air Pollutants (HAPs). Particulate matter emissions from the recovery boiler are controlled by a high-efficiency electrostatic precipitator (ESP). The smelt from the recovery boiler is collected and dissolved in process water in the smelt dissolving tank (SDT, EQUI 51) to make green liquor, which is a mixture of sodium carbonate and sodium sulfide. The SDT emits particulate matter, sulfur dioxide (SO2), volatile organic compounds (VOC), TRS, and HAPs. Emissions from the SDT are controlled by a Spray Tower (TREA12) and a Ventri-Rod Scrubber (TREA 6) operated in series. The green liquor is then fed to the causticizers with slaked lime which reacts to produce white liquor. The white liquor is then returned to the fiberline to produce more pulp. Calcium carbonate (lime mud) is the byproduct of this reaction. The lime mud is sent to the Lime Kiln (EQUI 52) where it undergoes a calcination reaction to reproduce lime (CaO) and CO2. The lime kiln is a source of all criteria pollutants, in addition to H2SO4, TRS, and HAPs. Particulate matter emissions are controlled by a high-efficiency ESP (TREA 21). Other major sources of emissions are from the three power boilers #7 (EQUI 2), #8 (EQUI 18), and #9 (EQUI 4). Boilers #7 and #9 are permitted to burn distillate oil, natural gas, wood waste and sludge. The boilers are also used as backup controls for NCG combustion. Particulate matter emissions from boiler #7 and #9 are controlled by multiclones (TREA 11 and TREA 18) and high-efficiency ESPs (TREA 15 and TREA 19) at each boiler. Power boiler #8 can combust natural gas and distillate oil. All three boilers are used to produce steam for electrical generation for use on site and for process heat. Other emission sources include the bleach plant (EQUI 7), paper machines #4 and #12 (EQUI 298 and 299), a coater (EQUI 304), a market pulp machine (EQUI 50), an emergency generator (EQUI 38), a diesel engine-powered fire pump (EQUI 315), a cooling tower (FUGI 2), a building heat boiler (EQUI 290), and fugitive particulate matter sources such as dust from wood piles (FUGI 9), paved and unpaved roads (FUGI 6 and FUGI 7), track-out (FUGI 11), a fuel yard (FUGI 3), ash handling (FUGI 8), and a landfill (FUGI 5). The bleaching process consists of a chlorine dioxide plant (EQUI 301) and a bleach line. Chlorine dioxide emissions from the bleach plant and chlorine dioxide plant are controlled by a gas scrubber (TREA 17) and a packed tower scrubber (TREA 16); the bleaching system is also a source of carbon monoxide (CO) and VOC emissions.

1.3 Description of the activities allowed by this permit action This permit action is a Major Amendment. The MPCA has a combined operating and construction permitting program under Minn. R. ch. 7007, and under Minn. R. 7007.0800. Under that authority, this permit action authorizes construction. This permit action authorizes construction of a Chip Pre-Steaming Bin (EQUI 316) prior to the digesters. The chip bin will help increase annual pulp production by reducing chip fill times and improving digester cycle times by pre-steaming the chips. The addition of the Chip Bin is one of several changes Sappi will make towards the overall goal of being able to produce 100% SC pulp at the annual capacity of the plant. Currently the pulp production rate for SC pulp (which results in more BLS than kraft pulp) is limited by the BLS permit limit. A recent engineering analysis of the recovery boiler concluded that the maximum capacity of the boiler was 1,027,475 tons BLS per year (5.63 million pounds BLS per day), in contrast to the current permit-limited capacity of 904,200 ton BLS per year (4.95 million pounds BLS per day). If Sappi produces pulp up to the increased capacity of the recovery boiler (assuming a ratio of 5,000 pounds BLS per ton of pulp) they will be able to produce 410,990 tons of pulp per year, up from 361,000 tons of pulp annually.


The increase in pulp production and BLS creation will result in increased utilization of other processes at the plant. The affected units are the bleach plant, the smelt dissolving tank, the lime kiln, the market pulp machine, the IQS system, and paved roads (from additional transport of wood chips). No utilization increase will be needed from the power boilers because the additional steam from the recovery boiler will be used to steam the chips in the chip bin and for the increase in steam demand for pulp production. This permit action also rolls in an administrative amendment for a 120-day test extension for EQUI 2 (Power Boiler #7) and a reopening for a performance test conducted on EQUI 4 (Power Boiler #9).

1.4 Description of applications included in this action

Table 2. Applications included in this action

Date received Application/notification type and description NA Reopening (IND20160003)

05/06/2016 Administrative Amendment (IND20160001) 09/30/2016 Major Amendment (IND20160004)

1.5 Facility emissions:

Table 3. Title I emissions summary – actual to projected actual emissions test

Pollutant

Projected actual emissions*

(tpy)

Baseline actual emissions**

(tpy)

Projected emissions increase

(tpy) PM 182.3 149.1 33.24 PM10 155.2 126.4 28.79 PM2.5 123.2 101.2 22.03 NOx 1,028 920.7 150.9 SO2 11.91 9.479 2.429 CO 546.7 449.8 96.91 Ozone (VOC) 69.04 57.20 11.84 Lead 0.02968 0.02409 0.005586 CO2e*** 1,251,000 1,044,000 209,200 H2S 7.764 6.325 1.438 TRS 12.68 10.27 2.416 H2SO4 0.7676 0.6127 0.1545

*Projected actual emissions as defined in 40 CFR § 52.21(b)(41). **Baseline actual emissions as defined in 40 CFR § 52.21(b)(48). The baseline dates used for the analysis were from April, 2014, to March, 2016. ***Carbon dioxide equivalents as defined in Minn. R. 7007.0100. Table 4. Title I emissions summary

Pollutant


(tpy)

Emissions increase from the modification

(tpy)

NSR/112(g) Significant thresholds for major

sources (tpy)

NSR/ 112(g) review required? (yes/no)

PM 33.24 33.24 25 Yes PM10 28.79 28.79 15 Yes PM2.5 22.03 22.03 10 Yes NOx 150.9 150.9 40 Yes SO2 2.429 2.429 40 No CO 96.91 96.91 100 No Ozone (VOC) 11.84 28.78 40 No


Pollutant


(tpy)

Emissions increase from the modification

(tpy)

NSR/112(g) Significant thresholds for major

sources (tpy)

NSR/ 112(g) review required? (yes/no)

Lead 0.005586 0.005586 0.6 No CO2e* 209,200 209,200 75,000 Yes H2S 1.438 1.438 10 No TRS 2.416 2.416 10 No H2SO4 0.1545 0.1545 7 No *Carbon dioxide equivalents as defined in Minn. R. 7007.0100.

Table 5. Facility classification

Classification Major Synthetic minor/area Minor/area PSD X Part 70 Permit Program X Part 63 NESHAP X

1.6 Changes to permit

· Due to the switch to a new permitting database (Tempo) from the old database (Delta) all subject items

were assigned a new designation and number. Emission units (EUs) and monitors (MRs) are now called ‘Equipment’, designated by the abbreviation EQUI. Stack Vents (SVs) are now ‘Structures’ (STRU), control equipment (CE) are now ‘Treatment’ (TREA), and fugitive sources (FSs) are now called ‘Fugitive’ (FUGI). Per Tempo permit organization guidance, Delta groups GP009 (Paper Machines), GP011 (CEMS), and GP012 (COMS) were removed and the requirements were placed at the individual subject items previously in each group.

· Updated subject item details and PTE for the facility based on the information submitted with the reissuance application (although the reissuance is not addressed with this permit action the information had to be updated in any case because of the database switch).

· Added uncontrolled emissions to calculations that rely on control. This included EQUI 2, EQUI 4, EQUI53, EQUI 301, EQUI 7, EQUI 51, and EQUI 49.

· Updates to Aboveground Storage Tanks. With the Tempo database subject items regulated by more than one program are shared by each program, so the tanks at the facility that are also regulated by the Tank Permitting program needed to be reconciled. The SI Designation indicates the Tank ID from the tanks program, and the former air permit emission unit number is included in the name of the unit.

o Delta emission unit EU045 “Black Liquor Storage tanks” in the air permit represented six collection/storage tanks associated with the fiberline (pulp digesters). EU045 was separated out into these six emission units:

ID in Air Permit SI Designation Name in Air Permit Substance in Tanks Permit EQUI 306 597 Black Liquor / 158500 / EU045 Primary black liquor accumulator EQUI 307 598 Black Liquor / 158500 / EU045 Secondary black liquor accumulator EQUI 308 599 Black Liquor / 105700 / EU045 Neutralization liquor accumulator EQUI 309 950 Black Liquor / 530000 / EU045 Displacement liquor EQUI 310 953 Black Liquor / 28500 / EU045 Fiberline Soap EQUI 311 420 Black Liquor / 48800 / EU045 Neutralization Liquor Mixing Accumulator EQUI 317 951 Black Liquor / 315000 / EU045 Impregnation Liquor

o EU047 “Heavy Black Liquor tanks” previously represented two tanks that are regulated by both

programs. In the previous permit, the were also included in the insignificant activity list as “63% Black Liquor” and “50% Black Liquor”, so they were removed from IA table. The heavy black liquor tanks are now two separate units in the permit:


ID in Air Permit SI Designation Name in Air Permit Substance in Tanks Permit EQUI 312 285 Black Liquor / 31000 / EU047 Evap Product Liquor EQUI 204 938 Black Liquor / 155000 / EU047 Heavy Black Liquor

o EU044 represented three paper pulp holding tanks which were also included in the insignificant

activity list. Since there are little to no emissions from these tanks they were not kept in the permit as emission units but were maintained in the insignificant activity list.

o EU046 “Black Liquor Tanks (Washers)” represented five black liquor holding tanks that are now in permit as five Aboveground Storage Tank SIs:

ID in Air Permit SI Designation Name in Air Permit Substance in Tanks Permit EQUI 295 966 Black Liquor / 127000 / EU046 Second Stage Filtrate EQUI 296 967 Black Liquor / 102800 / EU046 First PO Filtrate Tank EQUI 297 968 Black Liquor / 130000 / EU046 Second PO Filtrate Tank EQUI 313 182 Black Liquor / 44648 / EU046 Spill Collection Tank EQUI 314 962 Black Liquor / 153600 / EU046 First Stage Filtrate

· Updated performance testing schedules (see more information in Section 3 of the TSD). · Added permit Appendix D for process throughput and control equipment parameters that must be

recorded during performance testing, and an appendix of performance testing schedules and methods. · Made the following changes to the requirements for the I&I Emergency Generator (EQUI 38):

o A new sulfur dioxide limit (0.0015 lbs/MMBtu) will apply to the engine starting January 1, 2018 based on changes made to the Minnesota Rules that became effective December 2016.

o A requirement to specify that the fuel type for the engine is natural gas since compliance with the SO2 limit is based on PTE calculations that rely on natural as the fuel used.

o A requirement to maintain documentation on site that the unit is an emergency generator that qualifies as such under the September 6, 1995 EPA memo entitled “Calculating Potential to Emit (PTE) for Emergency Generators” since the PTE calculations are based on 500 hours of operation per year.

· Made the following changes to the requirements for the Emergency Diesel Fire Water Pump (EQUI 315): o Added the opacity and SO2 limits from Minn. R. 7011.2300 to the Emergency Diesel Fire Water

Pump (EQUI 315) since they were not there previously and the rule applies to all stationary internal combustion engines. This includes the new sulfur dioxide limit that will apply starting January 1, 2018.

o A requirement to specify that the fuel type for the engine is ultra-low sulfur diesel since compliance with the SO2 limit is based on PTE calculations that rely on ultra-low sulfur diesel as the fuel used.

o A requirement to maintain documentation on site that the unit is an emergency generator that qualifies as such under the September 6, 1995 EPA memo entitled “Calculating Potential to Emit (PTE) for Emergency Generators” since the PTE calculations are based on 500 hours of operation per year.

· Added requirements from the standard language for control equipment to the ESPs for the Power Boilers #7 and #9, and Recovery Boiler #10 (TREA 15, TREA 19, and TREA 20):

o Requirement to vent to and operate the ESP whenever the boiler is operating, with the PSD modeling citation, since operation of the ESP is necessary to achieve the particulate matter emission rates that were assumed in modeling.

o Replacement provisions so that the same control efficiencies can be assumed for a like-kind replacement that complies with the requirements of the TREA.

o Requirements to operate and maintain the equipment so that the control efficiency assumed in the PTE calculations is achieved for PM, PM10, and PM2.5.


· Updated citations for EQUI 49 (EU081) IQS. Pound per hour limits for PM, PM10, NOx, SO2, VOC, CO, TRS, and H2SO4 were added with permit #01700002-002 (issued in 1999) when the IQS was added to the permit as part of a Pollution Control Project. Since then, the citation for all the limits has just been “Title I Condition: 40 CFR 52.21, Minn. R. 7007.3000”. Since NAAQS modeling was conducted for #01700002-002 for SO2, NOx, and PM10 using those limited emission rates and modeling conducted in 2012 that used the limited CO emission rate for the IQS, the modeling citation (52.21(k)) has been added for SO2, NOx, CO, and PM10 in place of the generic 52.21 citation. For the other pollutants (PM, VOC, TRS, and H2SO4) the citation was changed to Minn. R. 7007.0800, subp. 2 since the emissions limits were included in the permit to define the source and were not used in a BACT analysis or for PSD modeling.

· The BLS throughput limit at the recovery boiler EQUI 53 was removed since they will be allowed to operate at the BLS throughput capacity of the recovery boiler.

· In the insignificant activity Appendix A, the activity “fewer than 10 portable gasoline electrical generators” was previously listed. Since these are non-road engines that are not part of the stationary source, they were removed from the appendix.

2. Regulatory and/or statutory basis

2.1 New source review (NSR) The facility is an existing major source under New Source Review regulations. The current modification is subject to NSR for PM, PM10, PM2.5, NOx, and CO2e. Endangered Species Act (ESA) and National Historic Preservation Act (NHPA) determinations were required. A consultation correspondence was submitted to EPA Region 5 for the current project. The Permittee received the from Jennifer Darrow at EPA Region 5 on March 7, 2017. Regarding the ESA, Region 5 stated: For this permit action, a response from a threatened or endangered species to an environmental stressor is unlikely. Furthermore, [the U.S. Fish and Wildlife Service] has determined that based on the proposed actions, they do not anticipate impacts to federally listed or proposed species. Therefore, no further consultation is necessary under Section 7 of the Endangered Species Act. For the NHPA, Region 5 stated: Section 106 of the National Historic Preservation Act allows the Federal Agency initiating the action to determine if an undertaking is likely to affect historic properties. If the undertaking is not the type of activity likely to affect historic properties, then the responsible Federal agency has no further obligation under Section 106. For this permit action, US EPA has determined that the undertaking is not likely to affect historic properties and no further action is required under Section 106 of the NHPA.

2.2 Part 70 permit program

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

2.3 New source performance standards (NSPS) The Permittee has stated that New Source Performance Standards apply to the operations at this facility. The Recovery Boiler EQUI 53 is subject to 40 CFR Part 60, subpart BB Standards of Performance for Kraft Pulp Mills. There is an updated standard (40 CFR Part 60, subpart BBa) for Kraft Pulp Mill Affected Sources for Which Construction, Reconstruction, or Modification Commenced After May 23, 2013. The Recovery


Boiler was physically modified to add quaternary air injection in April, 2013 (prior to the effective date of the rule) therefore it is not subject to the updated standard. Under Subpart BBa, the new chip steamer is part of the digester system. Digester system is defined in 40 CFR § 60.281a as “…each continuous digester or each batch digester used for the cooking of wood in white liquor, and associated flash tank(s), blow tank(s), chip steamer(s) including chip bins using live steam, and condenser(s).” Sappi has stated that they will only use fresh, clean steam for chip steaming instead of “live steam” from other processes which can be contaminated with TRS, VOC, and HAPs. Although it is not obvious from the text of the rule (or from the preamble to the rule) a chip steamer using only fresh steam is not subject the NSPS. This was confirmed by Kelley Spence at EPA in an email received by the MPCA on 4/22/2017 that said “That is correct. The intent was for chip steamers only using fresh steam to be excluded, since there is no TRS in the fresh steam.” The previous permit amendment (#01700002-015) authorized modification of the Lime Kiln (EQUI 52). The Lime Kiln had been subject to 40 CFR part 60, subpart BB, but upon modification, would be subject to 40 CFR part 60, subpart BBa. Consequently, the requirements from subpart BBa were added with permit #01700002-015 but the requirements from subpart BB were maintained since the modification would not occur until after permit issuance. The modification of the Lime Kiln occurred on April 19, 2016, therefore, the requirements from 40 CFR Part 60, subpart BB have been removed with this permit action since that subpart no longer applies to the unit.

2.4 National emission standards for hazardous air pollutants (NESHAP)

The facility is an existing major source of HAPs and is subject to 40 CFR pt. 63, subparts DDDDD, S, ZZZZ, MM, and JJJJJ. This project does not affect the applicability of these NESHAPs. The new chip pre-steaming bin will not be subject to NESHAP, subpart S National Emissions Standards for Hazardous Air Pollutants from the Pulp and Paper Industry, because Sappi will only use fresh steam in the chip bin. The definition of Digester system in 40 CFR § 63.441 specifies that it includes “chip steamer(s) not using fresh steam” so a chip steam using only fresh steam is not part of the digester system under NESHAP, subpart S. The natural gas-fired emergency engine (EQUI 38) is subject to NESHAP, subpart ZZZZ for stationary reciprocating internal combustion engines. It is a new stationary RICE, as defined at 40 CFR § 63.6590(a)(2)(ii) because the engine is less than 500 brake Hp, the facility installed the stationary RICE after June 12, 2006, and Sappi is a major source of HAPs. The engine must comply with ZZZZ by meeting the requirements of NSPS, subpart JJJJ, as specified at 40 CFR § 63.6590(c)(3). However, the engine does not fit any of the applicability requirements in 40 CFR § 60.4230(a), which specifies that for purposes of determining applicability the date that construction commences is the date the engine is ordered by the owner or operator. 40 CFR § 60.4230(a)(4) applies to owners and operators of engines that commenced construction after June 12, 2006 (which does fit EQUI 38, since the engine was ordered on August 9, 2006) but none of the other criteria in 40 CFR § 60.4230(a)(4)(i)-(iv) apply, since the engine was manufactured before July 1, 2007. The only part of the applicability requirements that applies is 40 CFR § 60.4230(a)(6), which specifies that the provisions of 40 CFR § 60.4236 apply to all owners and operators of engines that commenced construction after June 12, 2006. But the requirements of 40 CFR § 60.4236 have to do with deadlines for owners or operators who import or install stationary engines produced in previous model years, so there is nothing from that section that would translate to a permit requirement for this specific engine. Therefore, no requirements from NESHAP, subp. ZZZZ or NSPS, subp. JJJJ apply.

2.5 Compliance assurance monitoring (CAM)

The table below lists the sources subject to CAM, the control for the unit, whether the source is a Large or Other pollutant specific emission unit (PSEU), and the applicable pollutants.


Table 6. CAM summary

Unit Control CAM applicability Pollutant EQUI 2 TREA 11 Multiclone and TREA 15 ESP Other PM/PM10/PM2.5 EQUI 4 TREA 18 Multiclone and TREA 19 ESP Large PM/PM10/PM2.5 EQUI 53 TREA 20 ESP Large PM/PM10/PM2.5 Numerous TREA 30 Incinerator and TREA 31 Scrubber Other TRS, VOC EQUI 52 TREA 21 ESP Other PM/PM10/PM2.5 EQUI 51 TREA 6 Venturi Scrubber and TREA 12 Spray Tower Other TRS, PM/PM10/PM2.5

For large pollutant specific emission units, records of the monitored parameter must be made at a minimum of four times per hour, or once every 15 minutes. For other PSEUs (not large), records must be made at a minimum of once per 24 hours. All CAM plans were revised by the Permittee to update the equipment numbers to their Tempo ID number. Two CAM plans, for the Recovery Boiler and the Lime Kiln were modified because they did not previously include adequate justification for the indicator ranges used. See Attachment 5 to this document for the CAM Plan submitted by the applicant.

2.8 Environmental Review & Air Emission Risk Analysis (AERA) For the project, the potentially applicable Environmental Assessment Worksheet (EAW) triggers are an increase in pulp production capacity of 50% or more (Minn. R. 4410.4300, subp. 13) or an increase in air emissions of more than 250 tons per year of any individual air pollutant except greenhouse gases, where the threshold is an increase of 100,000 tons per year (Minn. R. 4410.4300, subp. 15). This project does increase Sappi’s pulp production, but only by an estimated 16%. The calculation of the emissions increase for the modification for EAW applicability is not the same as the calculation required to determine if the modification is a Title I modification subject to PSD regulations. Since environmental review is a state (not federal) regulation, the non-Title I calculation method specified in Minn. R. 7007.1200, subp. 3 is employed to determine if an EAW is required. There will be no change in potential emissions based on this modification, so the only unit that has an increase in emissions is the new unit, the EQUI 316 Chip Pre-steaming Bin. The Chip Pre-steaming Bin is expected to emit only one pollutant: 17.25 tpy of VOC. Therefore, the modification does not require an EAW or AERA. The calculations used to determine applicability with Minn. R. 4410.4300, subp. 15 are in Attachment 1 to this TSD.

2.9 Minnesota state rules Portions of the facility are subject to the following Minnesota Standards of Performance:

· Minn. R. 7011.0515 Standards of Performance for New Indirect Heating Equipment · Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment · Minn. R. 7011.2300 Standards of Performance for Stationary Internal Combustion Engines

Table 7. Regulatory overview of units affected by the modification/permit amendment

Subject item*

Applicable regulations Rationale

EQUI 53 (Recovery Boiler #10)

40 CFR § 52.21 Prevention of Significant Deterioration. BACT limits set for PM, PM10, PM2.5, NOx, and CO2e.


Subject item*

Applicable regulations Rationale

TREA 20 (Recovery Boiler #10 ESP)

40 CFR § 52.21; 40 CFR § 64 Prevention of Significant Deterioration. Compliance Assurance Monitoring. Requirements for control of particulate matter emissions from EQUI 53 by TREA 20 ESP. The ESP is the selected BACT control for PM, PM10, and PM2.5.

EQUI 316 (Chip Presteaming Bin)

40 CFR § 52.21 Prevention of Significant Deterioration. If construction is authorized under a PSD permit the construction authorization expires if construction does not commence within 18 months after permit issuance, if construction is discontinued for a period of 18 months or more, or if construction is not completed within a reasonable time.

Minn. R. 7011.0715 Standards of Performance for Post-1969 Industrial Process Equipment. This standard applies to industrial process equipment for which a standard of performance has not been promulgated in a specific rule.

*Location of the requirement in the permit (e.g., EQUI 1, STRU 2,etc.). 3. Technical information

3.1 Emissions increase analysis Attachment 1 to this TSD includes the Title I emissions increase calculations for this modification. The

emission calculations for the proposed project were conducted according to federal Prevention of Significant Deterioration (PSD) requirements. The increase in emissions from existing units was calculated using the actual-to-projected-actual test, where projected actual emissions at the affected units are compared to actual emissions during a baseline period (40 CFR § 52.21(a)(2)(iv)(c)). The increase in emissions from the new unit (the chip pre-steaming bin) were calculated using the actual-to potential test where the potential emissions from the new unit are compared to actual emission during a baseline period (40 CFR § 52.21(a)(2)(iv)(d)). The overall emissions increase was calculated using the hybrid test, where the emissions increases from both methods are summed (40 CFR § 52.21(a)(2)(iv)(f). Netting calculations and excludable emissions were not used in the PSD analysis.

Baseline actual emissions for units (other than electric utility steam generating units) are defined at 40 CFR § 52.21(b)(48)(ii) as the average rate, in tons per year, at which the emissions unit actually emitted the pollutant during any consecutive 24-month period selected by the Permittee within the 10-year period immediately preceding either the date the Permittee begins actual construction of the project, or the date a complete PSD permit application is received by the Permitting Authority. A different 24-month period may be used for each pollutant but the same 24-month period must be used for all units for each individual pollutant. The baseline period selected for this project was April 2014 to March 2016. Process throughput and operating hours data for each unit affected by the project were taken from that time period. The existing units whose actual emissions will be affected by an increase in pulp production and BLS creation are the recovery boiler, the bleach plant, the smelt dissolving tank, the lime kiln, the market pulp machine, the IQS system, and paved roads (from additional transport of wood chips). Fugitive emissions from paved roads were included in the analysis because Kraft pulp mills are one of the categorical sources listed in 40 CFR § 52.21(b)(iii). Baseline emissions where calculated using CEMS data or stack test data wherever possible or emission factors where the former are not available.

Future projected actual emissions (FPA) are defined at 40 CFR § 52.21(b)(41)(i) as the maximum annual rate, in tons per year, at which an existing emission unit is projected to emit a regulated NSR pollutant. Similar to the baseline actual calculations, CEMS data and stack test data were used where available, and emission factors were used where necessary. The maximum process throughput rates for BLS (1,027,475 tons per year) and CaO (175,000 tons per year) were used to calculate future projected actuals where throughput-based emission factors were available. To determine the future potential actual for pollutants that had measured actual lb/hr emission rates, the lb/hr emission rate was scaled up by the ratio of the future potential throughput rate and the baseline throughput rate. The process throughput ratios were used in calculations for the recovery boiler, the lime kiln, and IQS units. The process throughput ratios used were representative of each unit’s throughput, except for the IQS system which was based on BLS production ratio. 8760 hours of operation were assumed, since Sappi is trying


to move toward shutdowns every 18 months, so the worst-case future potential emission scenario assumed 8760 operation.

To determine potential emission from the new unit, the chip pre-steaming bin (EQUI 316), Sappi conducted a bench-scale test to measure VOC and HAP emissions from chip steaming. VOC is the only NSR regulated pollutant expected to be emitted from chip steaming. The VOC emission factor derived from the testing (in ton VOC/ton green chips) was multiplied by the maximum chip throughput rate and 8760 hours of operation were assumed.

3.2 BACT Applicability

Under the Clean Air Act (CAA) and applicable regulations, a PSD permit must contain emissions limitation

based on application of Best Available Control Technology for each regulated NSR pollutant. The regulated NSR pollutants for this PSD permit are PM, PM10, PM2.5, NOx, and CO2e. As indicated in 40 CFR § 52.21(j)(3) the BACT requirement applies to each new or modified emission unit for which the modification will result in an increase of an NSR pollutant. For this permit action the only proposed unit is the chip prestreaming bin. Since the chip prestreaming bin only emits VOC (not any of the regulated pollutants for this permit) a BACT analysis is not required for the new unit. The units that are affected by the modification and will have an increase in emissions of regulated pollutants include the #10 Recovery Boiler, the Smelt Dissolving Tank, the Lime Kiln, the IQS, and paved roads. None of the units will be physically modified as part of the project, so the BACT requirement does not apply to any of the units except for the Recovery Boiler.

Physical modification is not proposed to the Recovery Boiler as part of the project either, but the ability to increase the BLS throughput rate for the Recovery Boiler was due to a physical modification that occurred as part of a previous permit action (permit #01700002-014). The purpose of amendment -014 was to modify the pulp mill to manufacture specialized cellulose pulp. The project consisted of the installation of a new ozone bleaching system, an upgrade of the wood room, the installation of two additional digesters, an increase in the utilization of the Recovery Boiler, the Smelt Dissolving Tank, the Lime Kiln, and IQS. The modification to the Recovery Boiler included the addition of a tertiary air system to help ensure efficient operation at a higher loading value. Future projected actual emissions calculations relied on the BLS limit of 904,000 tons per year for emissions from the Recovery Boiler, the Smelt Dissolving Tank, and the IQS. With that assumptions, the project was below the significance level for all NSR pollutants except for Ozone. At the time Ozone was considered a regulated NSR pollutant but did not have a Significance Level specified. As such, any increase in Ozone was considered major for PSD.

The PSD rules dictate that a subsequent relaxation of an enforceable limitation that was relied upon to avoid major source in a previous modification should result in the re-evaluation of that modification for PSD applicability. This is defined in the regulations at 40 CFR Section 52.21(r)(4), which states “At such time that a particular source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation which was established after August 7, 1980, on the capacity of the source or modification otherwise to emit a pollutant, such as a restriction on hours of operation, then the requirements or paragraphs (j) through (s) of this section shall apply to the source or modification as though construction had not yet commenced on the source or modification.” The BLS throughput limit was an enforceable limitation that was relied upon to ensure that the -014 modification was not major for most regulated pollutants (with the exception of ozone). If the current proposed BLS throughput rate is applied to the calculations used in the -014 permit application, then the modification would have been major for PM, PM10, PM2.5, NOx, and CO2e and BACT should have been applied to the new and modified units proposed at that time. 40 CFR Section 52.21(r)(4) says that PSD should be applied “as though construction had not yet commenced” for the modification. Therefore, PSD applies for PM, PM10, PM2.5, NOx, and CO2e and BACT is required for all units that were proposed to be added or physically modified in permit #0170000-014. This includes the Recovery Boiler, the Bleach Plant, the Market Pulp Machine, and the two additional Digesters.

However, since these are the same pollutants that are PSD major for the current PSD application, then no action is required except for including BACT for other units whose modification was authorized in the -014 permit. And based on the pollutants emitted by each of the units besides the Recovery Boiler, no additional BACT analyses would have been required then or are required now. The Bleach Plant emits only VOCs and CO, the


Market Pulp Machine emits only VOCs, and the Digesters emit only VOCs and TRS. Therefore, this conclusion does not affect anything except for the reasoning behind requiring a BACT analysis for the Recovery Boiler for the current permit action. Supporting documentation is attached in TSD Attachment 6 “Permit #0170000-014 Calculations” which contain the PSD calculations for permit -014 if the increased BLS throughput rate was used.

3.3 BACT Analysis for the Recovery Boiler 3.3.1 Explanation of BACT

BACT is defined in CAA § 169(3) as:

an emissions limitation (including a visible emission standard) based on the maximum degree of reduction for each pollutant subject to regulation under the Clean Air Act which would be emitted from any proposed major stationary source or major modification which the Administrator, on a case-by-case basis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such facility through application of production processes and available methods, systems, and techniques, including fuel cleaning, clean fuels, or treatment or innovative fuel combustion techniques for control of each such pollutant…

EPA recommends that permitting authorities use the five-step “top down” approach to determine BACT to ensure that the analysis complies with the relevant statutory and regulatory requirements for BACT. The top down approach requires that all available control technologies for each applicable pollutant be identified and ranked in descending order of effectiveness. The top-ranked option should be established as BACT unless the Permittee can eliminate the option by demonstrating that it is technologically infeasible, or that energy, environmental, or economic considerations render the option otherwise not achievable for the source. If the top option is determined to be infeasible or not achievable, the next option is considered. Each step is further summarized below. Step 1: Identify all available control options In this step, all air pollution control technologies or technique that have potential application to the unit and the pollutant under review should be considered. The intent is to case a wide net and contemplate technologies with the highest level of control, regardless of the source type. There are three basic categories to consider in Step 1. These are:

· inherently lower-emitting process/practices/designs (clean fuels), · add-on controls, or · combinations of the two.

Step 2: Eliminate technically infeasible options The control is technically feasible if it has been demonstrated on the same source type, or is available and applicable to the source type. If it has not been demonstrated previously, then it must be not available or not applicable in order to be ruled out. EPA considers the technology to be “available” if it is commercially available and “applicable” if it can reasonably be installed and operated at the unit. The applicant is responsible for providing evidence that an available control measure is technically infeasible, but the permitting authority is responsible for making the final decisions on technical feasibility.

Step 3: Ranking of Controls The control technologies not eliminated in the previously step are listed in order of effectiveness. Relevant data should be included with each option, such as control efficiency, expected emission rate, and expected pollutant reduction in tons per year. Step 4: Economic, Energy, and Environmental Impacts


At this point the top-ranking control should be selected as BACT unless it can be demonstrated that the option is not achievable based on economic, energy, or environmental considerations. An economic analysis generally includes a calculation of the cost of control relative to amount of pollutant removed in dollars per ton of pollutant removed. Energy impacts are direct impacts at the facility, such as fuel or electricity required to operate the control. Environmental consequences are indirect or collateral impacts from the control, such as solid or hazardous waste generation, water demand, or increased emissions of other pollutants as a result of the reduction of the regulated pollutant. Step 5: Selecting BACT The most effective control option not eliminated in Step 4 is BACT. Once BACT is selected, a BACT limit is also decided on based on the performance of the selected technology. The BACT limit does not necessarily have to reflect the highest possible control, but should allow for consistent compliance and can be tailored based on special circumstances at the source. The permitting authority is responsible for making the final decision on the form of limit (averaging time and units of measure), deciding the compliance method, and ensuring that the BACT selection is fully justified and documented. The following sections outline how the top down process was applied for each regulated pollutant. Further detail is included in the analysis submitted by the Permittee, in TSD Attachment 7. 3.3.2 BACT Analysis for PM, PM10, and PM2.5 Discussion Particulate matter emissions from the recovery boiler are from combustion of BLS and supplemental fuels (natural gas and distillate oil). The emissions consist primarily of sodium salts and are caused by the carryover of solids and the condensation of the inorganic chemicals within the flue gas. Step 1: Identify all available control options The control options considered for particulate matter control were based on a search of the RACT/BACT/LAER Clearinghouse (RBLC). The RBLC is a database for previous determinations of Reasonably Achievable Control Technology (RACT), BACT, or Lowest Achievable Emission Rate (LAER) that can be searched by source type. The control options considered were fabric filters, electrostatic precipitators, and a wet scrubbers. Step 2: Eliminate technically infeasible options The option to install a fabric filter was determined to be technically infeasible. A fabric filter is considered available technology since it is commercially available, but it is not applicable because it cannot reasonably be operated at a recovery boiler. The temperature and moisture content of the flue gas from a recovery boiler are not suitable for the application of a fabric filter for control. Furthermore, fabric filters have not been used as a control device for any other recovery boilers in the RBLC database. Step 3: Ranking of Controls The remaining control options were ranked by control efficiency: Table 8: Ranking of Particulate Matter Controls

Control Method Control Efficiency Rank

Electrostatic Precipitator PM: 99%

PM10: 99% PM2.5: 95%

1

Scrubber PM: 94%

PM10: 84% PM2.5: 84%

2

Step 4: Economic, Energy, and Environmental Impacts


The Permittee did not have any reason to eliminate the top-ranked option based on economic, energy, or environmental impacts, so the ESP was selected as BACT. Step 5: Selecting BACT In selecting the BACT emissions limit, the emission rates selected as BACT for recovery boilers recorded in the RBLC database were used as a reference. The entries for BACT determinations for recovery boilers at a pulp mill from the last ten years are summarized in Table 9. Table 9: PM BACT Limits from the RBLC

Facility Name Year Issued

RB Capacity (MMlb BLS/day)

PM BACT Limit Units Averaging

Time

Georgia Pacific LLC (Brewton) 2014 5.9 0.015 gr/dscf @8% O2 3-hr Buckeye Foley Mill 2010 2.7 0.030 gr/dscf @8% O2 1-hr Buckeye Foley Mill 2010 2.3 0.030 gr/dscf @8% O2 1-hr Alabama River Pulp 2008 7.5 0.021 gr/dscf --

Georgia Pacific LLC (Crossett) 2007 6.9 0.020 gr/dscf @8% O2 3-hr Georgia Pacific LLC (Palatka) 2007 0.21 0.030 gr/dscf @8% O2 3-hr

Performance testing for the recovery boiler that was conducted to demonstrate compliance with the previous BACT limits for PM and PM10, of 0.025 gr/dscf @8% O2 indicate that the facility would likely have trouble complying with the lowest listed emission limit from the RBLC. Additionally, the recovery boiler at the Georgia Pacific, Brewton plant was a proposed new unit, not an existing modified unit, so it should not be expected that Sappi’s existing recovery would be able to achieve a similar emission rate. Therefore, Sappi proposed a BACT limit for their Recovery Boiler of 0.020 gr/dscf @ 8% O2 for filterable PM, filterable PM10, and filterable PM2.5. The final proposed BACT limits are summarized an Table 10. The proposed limit for PM is specified as filterable and the limits for PM10, and PM2.5 are not specified as filterable. This is because of how the three indicators of particulate matter are defined in the rules and in EPA guidance. In 40 CFR § 52.21(b)(50)(i)(a) the definition of Regulated NSR Pollutant includes PM10 and PM2.5 and stipulates that “PM2.5 emissions and PM10 emissions shall include gaseous emissions from a source or activity, which condense to form particulate matter at ambient temperatures. On or after January 1, 2011, such condensable particulate matter shall be accounted for in applicability determinations and in establishing emissions limitations for PM2.5 and PM10 in PSD permits.” Therefore, the PM10 and PM2.5 BACT limits should include condensable particulate matter. Sappi was concerned about meeting the 0.020 gr/dscf emission limit if the condensable portion had to be included, because previous stack tests have demonstrated high variability in the condensable PM emissions. Therefore, the BACT limit was increased to 0.025 gr/dscf for PM10 and PM2.5. Whereas for PM, EPA revised the rules in 2012 to remove the requirement to include condensable PM within the definition of “regulated NSR Pollutant” when measuring PM for PSD or NSR regulatory purposes and stated that it had been an inadvertent error to require it previously (77 FR 65107). They explain further within the supplemental information for the rulemaking that: PM is currently being regulated under the PSD program as three separate regulated pollutants. Those include PM10 and PM2.5—both of which are indicators reflecting the way the NAAQS for PM are currently measured—and “particulate matter emissions,” which is a term used in the PSD regulations to signify the indicator of PM that is measured and regulated under various NSPS for PM (40 CFR part 60). All three of the indicators for PM are considered separately as regulated NSR pollutants subject to review under the PSD program, which means that proposed new and modified sources must treat each indicator of PM as a separate regulated pollutant for applicability determinations, and must then apply the PSD requirements, as appropriate, independently for each indicator of PM. (77 FR 65107) Therefore, the PM limit should be in the form that it is measured and regulated in under the applicable NSPS for the recovery boiler (subpart BB), which, in 40 CFR § 60.285(b) requires the use of Method 5 to demonstrate


compliance with the PM limit for recovery boilers. Method 5 measures filterable particulate matter only, so the BACT limit is set for filterable PM. Additionally, EPA has stated that “In general, it is best to express the emission limits in two different ways, with one value serving as an emissions cap (e.g., lbs/hr.) and the other ensuring continuous compliance at any operation capacity (e.g., lb/MMBtu)” (Page H.5 of the 1990 Draft NSR Workshop Manual). EPA has indicated that the purpose of the short-term limit is to ensure protection of the applicable NAAQS and PSD increments (November 24, 1986 Memorandum “Need for a Short-term Best Available Control Technology (BACT) Analysis”). Since there currently are lb/hr limits in Sappi’s permit that were set for PM, PM10 , and PM2.5 for PSD modeling, the existing lb/hr limits were utilized as the emissions cap limits for PM, PM10 and PM2.5. The performance testing record indicates that Sappi will be able to comply with these limits, but Sappi has stated that they may make upgrades to the ESP to further ensure compliance. Table 10: Proposed PM BACT Limits for PM, PM10, and PM2.5

Pollutant Limit 1 Units 1 Limit 2 Units 2 Averaging Period Filterable PM 0.020 gr/dscf @ 8% O2 40.0 lb/hr 3-hour

PM10 0.025 gr/dscf @ 8% O2 40.0 lb/hr 3-hour PM2.5 0.025 gr/dscf @ 8% O2 37.9 lb/hr 3-hour

Compliance with the limits will be demonstrated through initial (180 days after installation of the chip pre-steaming bin) performance testing at worst case conditions as defined at Minn. R. 7017.2025, subp. 2 and as identified in Appendix IV of the permit. Method 5 (or other method approved by MPCA in the performance test plan approval) will be employed for measuring filterable particulate matter, and Methods 201A and 202 (or other method approved by MPCA in the performance test plan approval) will be employed to measure PM10 and PM2.5 emissions. 3.3.3 BACT Analysis for NOx Discussion NOx emissions from combustion sources are primarily a combination of thermal NOx and fuel NOx. Thermal NOx is produced from diatomic nitrogen and oxygen in the air that dissociates in the combustion zone and recombines to form NO and NO2. Fuel NOx comes from the nitrogen bound in the fuel. The majority of NOx emissions from recovery boilers have been shown to come from fuel NOx. NOx emissions from recovery boilers are lower than other combustion sources because of the low combustion temperatures, which limits the amount of thermal NOx produced, and the relatively small amount of fuel bound nitrogen in BLS, which has a nitrogen content <0.2 % by weight. Step 1: Identify all available control options The control options considered for NOx control were informed by a search of the RBLC. The control options selected for consideration were Selective Catalytic Reduction (SCR), Selective Non-Catalytic Reduction (SNCR), Low NOx Burners (LNB), Overfire Air/Quaternary Air, and Flue Gas Recirculation. Step 2: Eliminate technically infeasible options SCR, SNCR, Low-NOx Burners, and Flue Gas Recirculation were determined to be technically infeasible control options for this source type. The controls were considered technically infeasible for the following reasons. SCR:

· SCR has not been demonstrated as a control device for a recovery boiler in the RBLC. · Optimum temperature range for an SCR catalyst is 450-800 °F, which is higher than the flue gas

temperature from the Recovery Boiler after passing through the ESP. The average temperature of the flue gas as measured in the most recent performance test was 376 °F, so it would not work ideally if installed after the particulate matter control device. If installed prior to the particulate matter control device,


catalyst fouling and plugging would be an ongoing issue due to the high particulate matter emissions from the recovery boiler.

· Additionally, according to the National Council for Air Stream Improvement, Inc. (NCASI) the catalyst is also likely to be poisoned by alkali metals present in the recovery boiler gas stream.

SNCR: · SCR has not been demonstrated as a control device for a recovery boiler in the RBLC. · The purpose of a recovery boiler is to regenerate the cooking chemicals for use in pulp digestion and

requires specific chemical conditions within the boiler in order to operate properly. SNCR requires the injection of ammonia or urea into the combustion chamber, which is likely to have a detrimental effect on the chemistry within the boiler and potentially reduce the quality of the recovered liquor.

Low NOx Burners · Low NOx Burners have not been demonstrated as a control device for a recovery boiler in the RBLC. · According to the Permittee, Low NOx Burners for a recovery boiler are not available from recovery boiler

vendors. · Low NOx Burners would not be an effective NOx control option for a recovery boiler due to the inherent

design of the recovery boiler, which already employs highly staged combustion and low reducing-zone (at the bottom of the boiler) oxygen concentrations.

Flue Gas Recirculation · Flue gas recirculation involves routing a portion of the gas stream back through the boiler. Recirculation

limits thermal NOx formation by reducing the temperature in the combustion chamber and lowering the average oxygen content of the air. Since the majority of NOx from the recovery boiler is from fuel NOx and the temperature and oxygen content are already limited because of the standard recovery boiler conditions, flue gas recirculation would not result in lower NOx emissions.

· Additionally, according to NCASI, flue gas recirculation would result in increased fouling of the recovery boiler tubes and reduce the overall efficiency of the boiler.

Step 3 and 4: Ranking of Controls and Economic, Energy, and Environmental Impacts Since the only remaining control option is Overfire Air/Quaternary Air there is no need for ranking. The control efficiency expected from the addition of quaternary air injection is summarized below. Sappi did not identify any reason to eliminate this control option based on economic, energy, or environmental factors. Table 11: Selected NOx Control

Control Method Control Efficiency Rank Quaternary Air 20-40% 1

Step 5: Selecting BACT Sappi voluntarily installed quaternary air injection in the recovery boiler in 2013, so should be able to achieve a 20-40% reduction in NOx over emissions prior to that time. The original BACT limit for the recovery boiler was 115 ppm @ 8% O2. If we assume that the low end of the control efficiency range is viable for Sappi’s recovery boiler and can be translated to a 20% reduction in the NOx limit, then the new limit would be 92 ppm. For comparison, relevant entries from the RBLC are included in Table 11. Table 12: NOx BACT Limits from the RBLC

Facility Name Year RB Capacity (MMlb BLS/day) NOx BACT Units Averaging Time

Rocktenn 2015 2.9 120 ppm @ 8% O2 30-day Georgia Pacific LLC (Brewton) 2014 5.9 90 ppm @ 8% O2 3-hr

Buckeye Foley Mill 2010 2.7 80 ppmvd @ 8% O2 30-day rolling Buckeye Foley Mill 2010 2.3 80 ppmvd @ 8% O2 30-day rolling


Alabama River Pulp 2008 7.5 75 ppm Georgia Pacific LLC (Crossett) 2007 6.9 110 ppmvd @ 8% O2 3-hr Georgia Pacific LLC (Palatka) 2007 0.21 80 ppmv @8 % O2 30-day rolling

Relative to the RBLC entries, 92 ppm would appear to be a reasonable selection. However, an examination of the NOx CEMS data for the recovery boiler indicates that even after the addition of quaternary air, Sappi would likely have trouble complying with that limit continuously. Below is a table of summary statistics for the 30-day rolling average from the 2016 NOx CEMS data and a frequency table of the same data. The frequency table shows the number of times that the 30-day rolling average was within a certain range. Table 13: 2016 NOx CEMS Data

30-day rolling average Range (ppmvd @8% O2) Frequency

NOx emissions in ppmvd @8% O2 60-65 0

Mean 80.5 65-70 43

Minimum 66.0 70-75 42

Maximum 91.5 75-80 19

Count 329 80-85 148

85-90 58

90-95 19

95-100 0 The summary statistics show that the average 30-day rolling average in 2016 was 80.5 ppm. The frequency data show that the 30-day rolling average emissions did not exceed 95 ppm and there were 19 instances where the emissions average was between 90 and 95 ppm. Sappi proposed an emission limit of 100 ppmvd @ 8% O2. Since Sappi is increasing the production rate of BLS, a limit of 100 ppmvd @ 8% O2 is reasonable and should still allow for consistent compliance at a higher emission rate. Additionally, if Sappi was required to further reduce their NOx emissions, there would be a corresponding increase in CO emissions. Therefore it is not environmentally beneficial to require an even lower emission limit for NOx. The possibility of a lower averaging time for the limit was considered, but based on the 2016 hourly NOx data reduced to 3-hour averages, Sappi would not be able to comply with a reasonable limit on a 3-hour average basis. In 2016 there were many (627) instances where the 3-hour average exceeded 100 ppm and quite a few instances (44) where the 3-hour average was over 125 ppm. The units of ppmvd @8 O2 is consistent with the current compliance method which utilizes NOx CEMS. The equivalent lb/hr emission rate is included as well. The proposed BACT limits for the #10 Recovery Boiler is summarized below. Table 14: Proposed BACT Limit for NOx

Pollutant Limit 1 Units 1 Averaging Period Limit 2 Units 2 Averaging Period NOx 100 ppmvd @ 8% O2 30 day rolling 241 lb/hr 1-hour average

3.3.4 BACT Analysis for Carbon Dioxide Equivalents (CO2e) Discussion Greenhouse gas (GHG) or CO2e emissions from the recovery boiler are generated from the combustion of BLS and the small amount of supplemental fossil fuel burned during startup and shutdown. The primary purpose of the recovery boiler is to begin the process of recovering the cooking chemicals, Na2S and NaOH from the BLS. The secondary purpose of the boiler is to produce steam for use elsewhere in the plant. Step 1: Identify all available control options


The control options for reducing GHG emissions are carbon capture and sequestration (CCS) and combustion efficiency measures. Energy efficiency options have been identified by EPA as particularly important in conducting BACT analyses for GHGs since add-on controls for CO2 are not well established (“PSD and Title V Permitting Guidance for Greenhouse Gases” 2011). EPA does consider CCS to be an available control option for facilities emitting CO2 in large quantities, so it is included in Step 1 of the analysis. The combustion efficiency options considered were informed by the EPA publication: “Available and Emerging Technologies for Reducing Greenhouse Gas Emissions from the Pulp and Paper Manufacturing Industry”. Sappi identified the following efficiency options as potentially applicable to the existing recovery boiler:

1. Burner Replacement. Replacing older burners with more efficient modern burners can reduce fuel consumption.

2. Improved Boiler Insulation. 3. Boiler Maintenance. 4. Boiler Process Control. Installation of flue gas monitors for carbon monoxide and oxygen allows the

operator to optimize the fuel/air ratio to improve efficiency. 5. Reduction of Excess Air and Flue Gas Quantity. Too much excess air or excessive flue gas as a result of

leaks in the boiler or the flue reduces efficiency because the air absorbs heat that could go to heating steam.

6. Quaternary Air Injection. Quaternary air injection reduces carry over and tube fouling resulting in fewer shutdowns for cleaning.

7. Increase of BLS Solids Content. 8. Deposition Monitoring.

Note on lower-emitting fuels: The Recovery Boiler is capable of combusting natural gas and distillate oil in addition to BLS. Natural gas and distillate oil both have lower emission rates of greenhouse gases on a heat input basis. Although in general inherently lower emitting fuels should be evaluated in a BACT analysis, using fossil fuels in place of BLS in the recovery boiler would fundamentally redefine the source, so the use of alternative fuels does not have to be considered in this case. Step 2: Eliminate technically infeasible options Several options were eliminated as technically infeasible or were eliminated because they would not improve efficiency for Sappi’s boiler. Replacing the natural gas burners was eliminated because it would have a negligible effect on efficiency because, although installed in 1998, they only operate 50-200 hours per year and are inspected and cleaned annually so are in like-new condition. Burners only apply to the natural gas injection, since the distillate oil, if used, is mixed with the BLS before it is injected into the boiler. The BLS is sprayed into the boiler using splashplate nozzles. They also stated that the boiler was already well insulated so improved boiler insulation does not apply. Increasing the BLS solids content was eliminated as an option because the solids content is maintained at the current level in order to limit the amount of steam produced from the BLS. As stated previously, the primary function of the recovery boiler is to burn BLS with steam production as a secondary function. If more steam were produced from the Recovery Boiler by increasing the solids content, then it would displace steam needed from other sources, and result in an overall reduction of GHG emissions. The solids content of BLS burned in Sappi’s Recovery Boiler is approximately 68-72%, which is already higher than typical BLS solids content of 65-68%. Sappi’s steam production rate is limited to 825,000 pounds of steam per hour and the BLS solids content is tuned so that the steam production limit is not exceeded while achieving the BLS throughput rate necessary to keep up with the desired pulp production rate. The steam limit was set through performance testing, and could be adjusted through further testing if the facility can demonstrate compliance with their emission limits at a higher steam production rate. However, the steam production rate is also limited to 853,814 lb/hr by safety valve design, which would likely be exceeded if Sappi were to further increase the BLS solids content and produce steam at a higher rate. Therefore, a further increase in the BLS solids content is technically infeasible for this source.


Sappi claimed that CCS was not technically feasible for controlling CO2 from Sappi’s recovery boiler but the MPCA does not agree. There are three main components to CCS: CO2 capture or compression, CO2 transport, and CO2 Storage. According to EPA’s 2011 guidance for GHG permitting, CCS can be considered infeasible if any of the three components are infeasible for the source. The U.S. Department of Energy website lists two main types of carbon capture systems: Post-Combustion Capture and Pre-Combustion Capture (https://energy.gov/fe/science-innovation/carbon-capture-and-storage-research/carbon-capture-rd). Pre-Combustion Capture is currently only potentially applicable to a specific type of combined cycle power plant. Post-combustion carbon capture technologies include techniques for CO2 capture by absorption, adsorption, membranes, or mineralization and bio-fixation. Due to the historical use of CO2 absorption in chemical process industries, CO2 capture via amine absorption is fairly well developed and appears to be the most viable option currently available. There are a few recent examples of the technology being employed or planned to be employed on a large scale. According to a database maintained by the Global CCS Institute (http://www.globalccsinstitute.com/projects/large-scale-ccs-projects), there are two coal-fired power plants that are currently operating post-combustion CO2 capture using an amine-based absorption chemical solvent: Boundary Dam in Canada and Petra Nova in Texas. There are four more facilities that plan to begin operation in the next few years in the Netherlands, China, and South Korea, that will also likely use amine absorption, though the facility in South Korea may use a solid sorbent instead. The technology has not been employed specifically for recovery boilers but if it can be used in gas stream from coal-fired boilers it should be translatable to the recovery boiler gas stream. Transport and storage of the CO2 would be difficult, because sequestration of the captured CO2 is not feasible within Minnesota. A 2008 Minnesota Geological Survey report, “Potential Capacity for Geologic Carbon Sequestration in the Midcontinent Rift System in Minnesota”, concluded that the geology of Minnesota was not suitable for carbon sequestration and that the most promising areas for sequestration that runs along the Midcontinent Rift sedimentary rock appears to not have the right characteristics of porosity and permeability for sequestration (http://conservancy.umn.edu/ handle/ 11299/117609). Consequently, if Sappi employed a carbon capture system, they would also have to transport the CO2 out of state to a suitable site for sequestration via truck, rail, or pipeline. Step 3: Ranking of Controls The remaining options were ranked by control efficiency. The control efficiency for CO2 capture by amine absorption has been demonstrated to be as high is 90%. A research group in Finland (VTT Technical Research Centre) recently conducted a “techno-economic assessment” on applying an amine absorption technology to a pulp and paper plant, and summarized their results in a presentation entitled “CO2 capture from integrated pulp and board mill”. The research group estimated that the CO2 removal for a recovery boiler would be about 68%, hence the range of values provided in Table 8 (http://www.ieaghg.org/docs/General_Docs/IEAGHG_ Presentations/2016_Kangas_et_al_PRESS_2016.pdf). For the energy efficiency improvements option, since energy efficiency measures are not a control technology, a control efficiency number cannot be assigned. Additionally, since the majority of the efficiency measures discussed are already employed at Sappi, the current CO2e emissions from the Recovery Boiler are listed for the energy efficiency option. Table 15: Ranking of CO2 controls

Control Method Control Efficiency CO2 Emissions (tpy) CO2e Emissions (tpy) Rank CCS 68-90% 104,000 – 334,041 112,000 - 341,000 1

Energy Efficiency Improvements -- 1,044,000 1,051,000 2

Step 4: Economic, Energy, and Environmental Impacts The economic, energy, and environmental impacts of employing carbon capture and sequestration for the recovery boiler are prohibitive. The VTT research report mentioned previously analyzed the costs required to install carbon dioxide control on an existing recovery boiler at a reference facility producing 800,000 actual tons dry pulp (actual dry tons pulp) per year. They estimated a capital expenditure of 311 million Euros in 2005 Euros, which is 415 million U.S. dollars in 2017 dollars. The capital expenditure estimate included plant modifications to incorporate the new equipment, the cost for installation of equipment for CO2 capture and compression, plus


contingencies. Additionally, the 2010 report from the Interagency Task Force on Carbon Capture and Storage, reported that the incremental cost, which is the additional cost incurred from taking a particular action, “…of new coal-fired plants with CCS relative to new conventional coal-fired plants typically range from $60 to $95 per tonne of CO2 avoided” (https://www.epa.gov/sites/production/files/ 2016-08/ documents/es-ccs-task-force-report-2010.pdf). This is very similar to the cost per ton estimate from the VTT research report, which reported estimated CO2 cost avoidance of about 60 Euros per ton (~$80 per ton in U.S. dollars in 2017 dollars) for installation of carbon capture and compression on a recovery boiler. Based on the range of potential removal efficiency and the range of cost, the total cost to remove a year’s worth of CO2 would be 43 million dollars at best and 90 million dollars at worse. As stated in the “PSD and Title V Permitting Guidance for Greenhouse Gases” in order to eliminate an option on economic grounds the Permittee has to demonstrate that that the particular option is “disproportionately high” based on comparison to previous permitting decisions. They acknowledge that this will initially be difficult for GHGs since there are not many prior permitting decision regarding GHGs to compare to. Also, the scale of CO2 emissions compared to other pollutants is problematic since the cost per ton removed appears to be much lower due to the much higher relative emissions of CO2. That said, the costs of installation and operation of a CO2 removal system appear (in the opinion of the permitting authority) disproportionately high. Even given the uncertainties of these costs as they apply to Sappi, it does not begin to incorporate the additional costs that would be involved in transporting and injecting the CO2 once removed and compressed. As a side note, the two North America sites that have employed this technology were able to make it economically viable by routing the CO2 via pipeline to nearby oil fields so it could be used for enhanced oil recovery. Besides the economic impacts, the installation of the equipment would incur energy penalties as well. The regeneration of the amine solution requires additional heat (steam) and the operation of the capture and compression equipment would require additional electricity. This would either have to come from the plant, increasing the demand on the power boilers (and increasing emissions of all pollutants from them), or from the grid, requiring more energy to be generated elsewhere. Finally, the installation of a carbon capture and compression system would require additional process water and cooling water. Additional waste water would also be created because the effectiveness of the amine solutions is degraded as it absorbs SO2, so a portion must be continuously replaced (VTT report). Therefore, CCS can be eliminated as a control option due to economic, energy, and environmental reasons. Step 5: Selecting BACT The implementation of efficiency measures is the proposed BACT control for CO2e from the recovery boiler. Sappi will employ the following energy efficiency measures as BACT: Regular boiler maintenance: Sappi will continue to employ their regular boiler maintenance schedule. The boiler maintenance program includes a planned shutdown where the boiler is inspected, repaired (as necessary), and cleaned. Testing for tube thickness is also conducted to determine of the tube need to be repaired or replaced. Boiler process control/reduction of excess air and flue gas quantity: Sappi operates an oxygen trim system for maintaining excess air at the desired level. The boiler has oxygen and carbon monoxide continuous emission monitors at the flue gas to ensure efficient combustion. The regular maintenance schedule will identify and fix leaks that lead to excess flue gas quantities. Quaternary Air Injection: Quaternary air was installed in 2013 and will continue to be implemented to improve boiler efficiency. Since BLS is a biogenic feedstock that is arguably carbon neutral, Sappi proposed the following BACT limits:

· 10% annual capacity factor for fossil fuel use at the boiler. · Limit on distillate oil use of less than 1 gallon/minute. · 74,823 tons of CO2e per year on a 12-month rolling sum basis for emissions from fossil fuel combustion.

At one point, biogenic CO2 emissions were officially exempted from PSD or Title V permitting requirements under EPA’s “Biomass Deferral Rule”. The rule was finalized on July 20, 2011 and was set to expire on July 1, 2014.


During that time, applicants were not required to include GHG emissions from biogenic sources in permit applications. This was intended to allow EPA time to develop an accounting framework for biogenic emissions in consideration of the net carbon emissions when accounting for the full carbon cycle. However, in 2013 the rule was vacated by the D.C. Circuit court due to “insufficient legal justification” for the deferral. EPA has continued to work on a framework for assessing biogenic CO2 emissions and issued a revised document Framework for Assessing Biogenic CO2 Emissions from Stationary Sources in November, 2014. The purpose of the framework is “To continue advancing the agency’s technical understanding of the role that biomass use can play in reducing overall greenhouse gas emissions” and to provide “…a methodological framework for assessing the extent to which the production, processing, and use of biogenic material at stationary sources results in a net atmospheric contribution of biogenic CO2 emissions” (Charge Questions for SAB Peer Review, February 2015). An accompanying memo from then Acting Assistant Administrator Janet McCabe stated that “the EPA plans to propose revisions to the PSD rules to include an exemption from the Best Available Control Technology (BACT) requirement for GHGs from waste-derived feedstocks and from non-waste biogenic feedstocks derived from sustainable forest or agricultural practices…” (Memorandum Addressing Biogenic Carbon Dioxide Emission from Stationary Sources, Nov 19, 2014). For non-waste feedstocks (which is the category that BLS would fall into) the exemption would require a demonstration that the feedstock comes from sustainably managed lands. Nevertheless, as of the date of this permit action the framework has not been finalized and no amendments to the PSD regulations have been proposed to address biogenic CO2 emissions. Therefore, at this point there is no justification from EPA guidance or PSD regulations that would allow the exclusion of biogenic CO2 emissions from the BACT limit. Consequently, the BACT limit for CO2e should account for al CO2 emissions, whether biogenic or from fossil fuels. The only RBLC entry for a CO2e BACT limit for a recovery boiler was a limit to 210 lb/MMBtu on a 12-month average basis. The proposed BACT limit for Sappi’s recovery boiler is summarized below and corresponds with the CO2e emission rate from combustion of BLS. The CO2e emission rate on a lb/MMBtu basis is lower for the other allowable fuels. The emission rate is based on emission factors from 40 CFR Part 98, subpart C, Table C-1 and C-2 (last updated November, 2013) and global warming potentials from 40 CFR Part 98, Subpart A, Table A-1 (last updated December, 2014). Table 16: Proposed BACT Limit for CO2e

Pollutant Limit Units CO2e 207 lb/MMBtu

The limit will be complied with by limiting fuels to BLS, natural gas, and distillate oil. 3.4 Dispersion modeling

Per 40 CFR § 52.21(k), for a PSD permit, the Permittee must demonstrate that allowable emission increases

from the proposed modification will not cause or contribute to air pollution in violation of a national ambient air quality standard (NAAQS) or any applicable maximum allowable increase over the baseline concentration for the area. Allowable emissions are defined at 40 CFR § 52.21(b)(16) as “the emissions rate of a stationary source calculated using the maximum rated capacity of the source (unless the source is subject to federally enforceable limits which restrict the operating rate, or hours of operation, or both)…”. Actual emissions are expected to increase through this permit action; however, the maximum permitted emission rates (allowable emissions) for the affected units will not increase. The PM10, PM2.5, and NOx permitted emission rates were part of a previous PSD permitting process for a nearby facility (USG Interiors) in the Cloquet area in 2012. The 2012 modeling demonstration used maximum permitted emission rates and resulted in no modeled violation of either NAAQS or increment.

At the request of EPA, Sappi submitted a Significant Impact Level (SIL) analysis for PM10, PM2.5, and NO2 that

evaluated modeled impacts of emissions before and after modification. This analysis demonstrated that there was no change in 1-hr or 24-hr ambient impacts, since the allowable short term emission rates do not change as a result of the proposed project and actual hourly emission rates from the emission units affected by the project


often emit at or near the project 1-hr and 24-hr emission rates. In the EPA’s most recent guidance on PM2.5

modeling, the approach of using SIL values was deemed unacceptable when screening out of a PM2.5 increment analysis. An alternative increment screening analysis was conducted by the Permittee according to EPA policy and is included in TSD Attachment 9. The attached document reveals that no additional increment analysis was needed for the 24-hour PM2.5 NAAQS averaging period. The annual modeled impacts were based on the current actual emissions from 2015 and 2016 emissions inventory data compared to future allowable annual emissions due to the project, and demonstrated modeled impacts less than the SILs for annual NO2. Receptors were placed along Sappi’s fence line and onsite in areas where access is not precluded by a physical barrier. Receptors falling on Sappi’s buildings or buildings of modeled nearby sources were removed per MPCA modeling practices. Annual PM10 and PM2.5 modeled impacts were greater than the SIL. The full results of the SIL analysis are below.

Table 17: Class II Significant Impact Levels Modeling Results

Pollutant Averaging

time

Modeled impacts (H1H)

(μg/m3) SILs (μg/m3)

*As of 10/26/2010 % of SIL Exceed SIL?

PM10 24-hr 0.00 5 0.00% Yes

Annual 1.84 1 184%

PM2.5 24-hr 0.00 1.2 0.00% Yes

Annual 1.55 0.3 516.7%

NO2 1-hr 0.00 7.52 0.00% No

Annual 0.55 1 55% The Company completed a modeling demonstration for the annual PM2.5 NAAQS and PSD Class II Increment

standards for the project. The modeling demonstration for this permitting action departs from the 2012 modeling demonstration in four specific ways. First, the paved road component modeled in the 2012 demonstration was removed, consistent with current MPCA modeling practice, as Sappi holds and maintains a fugitive dust management plan that is an enforceable condition of their permit (see permit Appendix E: Fugitive Dust Control Plan). Second, the modeling demonstration for this permit action included additional receptors on Sappi and Jarden Home Brands property to account for a more thorough evaluation of ambient air, consistent with state and federal modeling practices. Sections of Sappi property are fenced, thereby restricting public access, and not included in the modeling demonstration, consistent with federal modeling practices. Third, the annual PM10 Minnesota Ambient Air Quality Standard (MAAQS) was not modeled in the demonstration as the annual PM10 MAAQS has been repealed, so only the annual PM10 PSD Increment analysis was conducted for PM10. Lastly, the secondary formation of PM2.5 was evaluated outside of the modeling demonstration, consistent with MPCA practice, through a combined qualitative/quantitative analysis based on facility emissions of PM2.5, NO2, and SO2. All of Sappi’s emission units and fugitive sources were included in the NAAQS modeling analysis and the applicable increment consuming and expanding sources were included in the Class II Increment modeling analysis. In addition to Sappi’s emissions sources, nearby sources historically modeled in the Cloquet area were included in the NAAQS and Class II Increment modeling. The nearby source included in the modeling demonstration were USG Interiors LLC, Jarden Home Brands, and Specialty Minerals. An ambient air quality background concentration was included in the NAAQS modeling demonstration to account for air emission sources not explicitly modeled, such as smaller, regional sources, mobile sources, residential activities, and long-range air pollutant transport. The explanation for the selected background concentrations and nearby sources is included in TSD attachment 9, along with the final modeling report. The results of the NAAQS and Class II Increment modeling analyses are show below.

Table 18: MAAQS/NAAQS and PSD Class II Increment Modeling Results

Pollutant Modeling Analysis

Averaging Period

Modeled Concentration

(μg/m3) Standard (μg/m3) % of Standard


Pollutant Modeling Analysis

Averaging Period

Modeled Concentration

(μg/m3) Standard (μg/m3) % of Standard

PM10 PSD Increment Annual 0 30 0.00%

PM2.5 PSD Increment Annual 1.76 4 44.0%

NAAQS Annual 10.51 12 87.6%

Site-specific parameters used in the modeling demonstration are included in Appendix B to the permit. The

parameters listed in Appendix B of the permit describe the operation of the facility at maximum capacity, meaning that the flow rates and temperatures listed in Appendix B represent the minimum parameters at the maximum emission rates. The MPCA does not require any specific compliance demonstration with these parameters because they are considered worse-case permissible operating conditions. The purpose of listing the parameters in the permit appendix is to provide a benchmark for determining future additional modeling needs.

3.5 Additional Impacts Analysis

Sappi conducted an additional impacts analysis as required by 40 CFR § 52.21(o), which specifies that an additional impacts analysis includes: (1) An a analysis of the impairment to visibility, soils and vegetation that would occur as a result of the

modification and associated general commercial, residential, industrial and other growth. (2) An analysis of the air quality impacts projected for the area as a result of general commercial, residential,

industrial and other growth associated with the modification. (3) An analysis of the impacts on visibility to an Federal class I area new the stationary source. The Administrator

may require visibility monitoring. The impacts analysis concluded that there would be no negative additional impacts from this modification. The full analysis provided by the Permittee is included as TSD Attachment 9.

3.6 Performance Testing

Performance testing schedules were re-evaluated for this permit action. Table 19 contains the three most recent performance test results (as applicable), as a percent of the permit limit, for each pollutant that has a limit with testing as the compliance demonstration. For EQUI 2 and EQUI 4, only the testing results for the test frequencies that changed are shown. Other required tests for those units were not modified from the previous permit. Also shown in the table, is the test frequency in permit #01700002-015 and the proposed test frequency for permit #01700002-101. According to MPCA guidance, the rule of thumb for setting test frequencies is a performance test every 12 months if the test result is > 90% of the limit, every 36 months if the result is between 60 and 90%, and every 60 months if the result is < 60% of the limit. That criteria was not applied strictly, but was used as a guideline to select the test frequency for the current permit. In some cases testing was eliminated where the most recent two or three test results demonstrated that emissions were much lower than the limit. For the units directly affected by the BLS throughput rate increase (the recovery boiler and the smelt dissolving tank) initial testing and a new test frequency plan will be required after the chip pre-steaming bin is installed. For the lime kiln, there were several pollutants (VOC, CO, and Hg) that still needed initial performance tests from after the lime kiln was modified, so the initial testing requirement was maintained. For the other lime kiln pollutants, initial testing had been conducted and the test frequency was set based on the initial testing results (and previous results). Initial testing will also be required at the chip bin to confirm the VOC factor derived in the bench-scale test. Table 19: Performance testing summary

Test Result as percent of limit


EQUI# Pollutant Permit Limit Units Most

recent 2nd most

recent 3rd most

recent Frequency in permit

#01700002-015 Frequency in permit

#01700002-101

EQUI 2 (PB7)

PM 15 lb/hr 6.8% 39% 8.3% 24 36

PM10 21 lb/hr 12% 62% 6.9% 24 36

EQUI 4 (PB9)

FPM 0.037 lb/MMBtu 4.86% 9.5% 12 36

PM 21.5 lb/hr 5.02% 8.4% 17% 24 60

PM 0.1 lb/MMBtu 2.30% 3.8% 9.0% 24 60

PM10 30.1 lb/hr 6.48% 7.5% 12% 24 60

EQUI 53 (RB10)

H2SO4 3.6 lb/hr 1.6% 16% 55% 60 Initial test/frequency plan

Hg 0.0027 lb/hr 5.2% 11% 60 None

VOC 44 lb/hr 3.2% 2.8% 0.59% 60 None

VOC 60 ppmvd 3.6% 0.87% 60 None

PM 40 lb/hr 65% 84% 78% 24 Initial test/frequency plan

PM 0.025 gr/dscf 40% 61% 52% 24 Initial test/frequency plan

PM10 40 lb/hr 45% 78% 62% 24 Initial test/frequency plan

PM10 0.025 gr/dscf 30% 58% 38% 24 Initial test/frequency plan

PM2.5 37.9 lb/hr 45% 66% 60 Initial test/frequency plan

EQUI 51 (SDT)

TRS 0.0168 lb/ton BLS 64% 36% 167% 36 Initial test/frequency plan

SO2 6.25 lb/hr 0.2% 1.6% 8.6% 60 None

VOC 0.16 lb/ton ADUBP 11% 3.8% 2.1% 60 None

PM 12.5 lb/hr 38% 74% 60 Initial test/frequency plan

PM10 12.5 lb/hr 45% 74% 60 Initial test/frequency plan

PM2.5 12.5 lb/hr 45% 74% 60 Initial test/frequency plan

EQUI 52 (LK)

VOC 20.83 lb/hr 20% 0.37% None Initial test/frequency plan

VOC 1 lb/ton CaO 0.02% None Initial test/frequency plan

H2SO4 0.53 lb/hr 0.0% 14% None Initial test/frequency plan

CO 12.9 lb/hr 40% 6.0% None Initial test/frequency plan

CO 75 ppmvd 6.8% 6.6% None Initial test/frequency plan

Hg 0.00025 lb/hr 1.0% None Initial test/frequency plan

FPM 0.064 gr/dscf 28% 60 60

PM 13.6 lb/hr 47% 28% 89% None 60

PM10 13.6 lb/hr 50% 82% 64% None 60

PM2.5 12.8 lb/hr 20% 77% None 60

NOx 120 ppm 95% None 12

NOx 39 lb/hr 82% None 12

TRS 8 ppmvd 59% 60 60

SO2 8.4 lb/hr 9.8% 2.9% 3.3% None Initial test/frequency plan


EQUI 49 (IQS)

CO 11.4 lb/hr 4.4% 0.88% 60 None

H2SO4 1.0 lb/hr 9.0% 120% 20% 60 60

SO2 14.8 lb/hr 1.4% 11% 4.1% 60 None

VOC 4.6 lb/hr 6.3% 16% 11% 60 None

TRS 0.5 lb/hr 44% 4.4% 60 60

NOx 9.1 lb/hr 100% 66% 60 12 Total HAP 20 ppmvd 0.02% 0.050% 60 60

PM 8.8 lb/hr 19% 36% 60 60

PM10 8.8 lb/hr 21% 15% 60 60

PM2.5 7.5 lb/hr 17% 60 60

EQUI 7 (BP)

ClO2 1 lb/hr 6.0% 400% 520% 60 60

CHCl3 1.1 lb/hr 0.4% 9.6% 16% 60 None

CO 1.2 lb/ton ODBP 13% 53% 71% 60 60

VOC 0.17 lb/ton ADTBP 54% 25% 34% 60 60

3.7 Monitoring

In accordance with the Clean Air Act, it is the responsibility of the owner or operator of a facility to have sufficient knowledge of the facility to certify that the facility is in compliance with all applicable requirements. For CAM, the Permittee submitted revised CAM plans which can be found in Attachment 5 to this TSD. Further discussion of decisions about CAM can be found in Table 6. In evaluating the monitoring included in the permit, the MPCA considered the following:

· The likelihood of the facility violating the applicable requirements. · Whether add-on controls are necessary to meet the emission limits. · The variability of emissions over time. · The type of monitoring, process, maintenance, or control equipment data already available for the

emission unit. · The technical and economic feasibility of possible periodic monitoring methods. · The kind of monitoring found on similar units elsewhere.

The table below summarizes the monitoring requirements associated with this amendment.

Table 20. Monitoring

Subject item* Requirement (rule basis)

Monitoring Discussion




EQUI 53 (Recovery Boiler #10)

PM (filterable): ≤ 0.020 grains per dry standard cubic foot at 8% O2; PM10 and PM2.5: ≤ 0.025 grains per dry standard cubic foot at 8% O2; PM (filterable) and PM10 ≤ 40 lb/hr; PM2.5: ≤ 37.9 lb/hr (BACT) all limits are on a 3-hour average basis

Performance testing; COMS (for CAM)

The Permittee will demonstrate compliance with the limits by conducting an initial performance test at worst-case conditions within 180 days after the installation of the Chip Presteaming Bin (EQUI 316). To demonstrate continuous compliance, recurring tests will be performed at a frequency established after the initial test. Additionally, EQUI 53 is a large PSEU, so the particulate matter control equipment (TREA 20) is subject to monitoring 4 times per hour. This is accomplished using the COMS. See TREA 20 below for specific monitoring. These limits apply at all times including startup, shutdown, and malfunction.

NOx: ≤ 100 parts per million at 8% O2, 30-day rolling sum; ≤ 241 lb/hr on a 30-day rolling average basis (BACT)

Continuous monitoring

The Permittee will demonstrate compliance by operating and maintaining a continuous monitor (EQUI 114) for NOx emissions corrected to 8% O2. These limits apply at all times including startup, shutdown, and malfunction.

CO2e ≤ 207 pounds per million Btu heat input on a continuous basis (BACT)

None The Permittee will demonstrate compliance with this limit by limiting the fuel types combusted in the recovery boiler to BLS, distillate oil, and natural gas. This limit applies at all times including startup, shutdown, and malfunction.

Fuel Type: Limited to natural gas, black liquor solids, and distillate oil (BACT)

Daily Fuel Type Recordkeeping

On each day of operation, the Permittee will record the type and amount of each fuel combusted in the recovery boiler.

TREA 20 (Recovery Boiler #10 ESP)

PM Control Efficiency ≥ 99.0%; PM10 Control Efficiency ≥ 99.0%; PM2.5 Control Efficiency ≥ 95.0% (BACT); Opacity ≤ 15.0% on a 3-hour rolling average basis (CAM)

Continuous opacity monitoring; operation and maintenance in accordance with the O & M Plan; Quarterly inspections; Annual inspections

Monitoring according to a CAM plan that fulfills the requirements of 40 CFR § 64 are sufficient to assure compliance with the control efficiency limits (and in turn demonstrate compliance with the particulate matter limits for EQUI 53). Opacity is correlated with particulate matter emissions; the continuous opacity monitor acts as an indicator that the ESP is functioning properly. Operation according to the O & M Plan along with periodic inspections ensure that potential issues with the control are discovered and corrective actions can be taken to prevent exceedances. As with other control efficiency limits the permit does not require verification of the control efficiency limits via inlet-outlet testing. Compliance with the control efficiency is assumed as long as the equipment is operated and maintained in accordance with permit requirements and the O & M Plan.




EQUI 316 (Chip Presteaming Bin)

PM: ≤ variable with airflow; Opacity: ≤ 20 % (Minn. R. 7011.0715)

None Chip steaming is not expected to generate particulate matter emissions; therefore, the likelihood of violating either of the emission limits is very small.

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

3.8 Insignificant activities Sappi Cloquet LLC has several operations which are classified as insignificant activities under the MPCA’s permitting rules. These are listed in Appendix A to the permit. The only changes to the insignificant activity table was to remove three items (63% Black Liquor Storage Tanks, the 50% Black Liquor Storage Tank, and 10 portable electric generators), as explained in Section 1.6 above.

3.9 Permit organization

In general, the permit meets the MPCA Tempo Guidance for ordering and grouping of requirements. One area where this permit deviates slightly from Tempo guidance is in the use of appendices. While appendices are fully enforceable parts of the permit, in general, any requirement that the MPCA thinks should be electronically tracked (e.g., limits, submittals, etc.), should be in the Requirements table in Tempo. The main reason is that the appendices are word processing sections and are not part of the electronic tracking system. Violation of the appendices can be enforced, but the computer system will not automatically generate the necessary enforcement notices or documents. Staff must generate these. Another area that deviates from the guidance is in the use of groups where the requirements in the group apply to the members of the group individually. This was done in order to shorten the permit where the same requirements apply to multiple units where no testing or tracking specific to a unit is required. This is the case for COMG2 NCG System and COMG2 Process Condensates. If testing or tracking requirements are required for a specific unit in addition to the generally applicable requirement, then that requirement is at the individual unit. This is the case for requirements at COMG7 40 CFR pt. 63, subp. DDDDD Requirements where general requirements from NESHAP subp. DDDDD are housed (but specific requirements that apply to the individual unit are at the unit). In the case of COMG1 Fuel limits: #7, #8 and #9 Boilers, the group exists because there are fuel limits that apply to the boilers as a group.

3.10 Comments received The MPCA plans to issue this permit under the provisions of Minn. R. 7007.0750, subp. 7. This rule allows the MPCA to issue permits in two stages. The requirements issued in the first stage - the Stage 1 conditions - are the portions of the permit that relate to the construction activities authorized by the permit. Examples of Stage 1 conditions include emissions limits, restrictions on hours of operation and the recordkeeping associated with that restriction, and requirements to demonstrate initial compliance. In the draft/proposed permit, many Stage 1 conditions are identified as Title I Conditions for BACT and can be found at EQUI 51, EQUI 53, EQUI 316, and TREA 20. Stage 1 conditions are denoted in the permit by “[Stage 1].” Public Notice Period: 5/12/17 – 6/12/17 EPA Review Period: 6/13/17 – 6/28/17


No comments were received from the public during the review period and no changes to the permit were made. No comments were received from EPA on the Stage 1 requirements, therefore the Stage 1 requirements were issued on 6/15/17. The permit was sent to EPA for their 15-day shortened review on 6/13/17. Comments were not received from EPA during their review period.

4. Permit fee assessment Attachment 4 to this TSD contains the MPCA’s assessment of Application and Additional Points used to determine the permit application fee for this permit action as required by Minn. R. 7002.0019. The permit action includes a major amendment, an administrative amendment, and a reopening. No application or additional fees are charged for reopenings, so it does not appear on the additional point form. Additional fees were applied for the modeling review and the BACT review. The BACT review involved five pollutant (PM, PM10, PM2.5, NOx, and CO2e) and one additional point was charged for each pollutant. Only one point is charged for each modeling review.

5. Conclusion Based on the information provided by Sappi Cloquet LLC the MPCA has reasonable assurance that the proposed operation of the emission facility, as described in the Air Emission Permit No. 01700002-101 and this TSD, will not cause or contribute to a violation of applicable federal regulations and Minnesota Rules. Staff members on permit team: Rachel Yucuis (permit engineer) Jim Sullivan (air quality modeling)

Steven Palzkill (enforcement) Andrew Place (compliance) Marc Severin (compliance – stack testing) Kelsey Suddard (peer reviewer) Beckie Olson (permit writing assistant) Laurie O'Brien (administrative support)

TEMPO360 Activities: Administrative Amendment (IND20160001), Major Amendment (IND20160004), Permit Reopening (IND20160003)

Attachments: 1. Emissions increase calculation spreadsheets 2. Requirements development report 3. Subject item inventory/details 4. Points calculator 5. CAM Plans 6. Permit #01700002-014 Calculations 7. BACT Analysis Submitted by Permittee 8. Modeling documents: PM2.5 Increment Screening, Nearby Sources, Background Concentrations, and

Modeling Report 9. Additional Impacts Analysis Submitted by Permittee

TSD Attachments Attachment 1: Emissions increase calculation spreadsheets

Sappi Cloquet LLC Permit Number: 01700002-101

NSR and Netting Applicability: Future Projected Actual (FPA) to Baseline Actual (BA)Sappi Cloquet Presteaming Project Permit #01700002‐101

Summary of Project Increases and Comparison to PSD Thresholds

Pollutant PSD Threshold

Total FPA to BA Increase Summary

Debottlenecked FPA to BA

Increase Summary EU005 EU011 EU031 EU033 EU080 EU081FS 008 ‐ Chip

TrucksEU090 Potential

to EmitExceed PSD Thresold?

(tpy)Apr‐14 to Mar‐16Emissions (tpy)

Apr‐14 to Mar‐16Emissions (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy)

PM 25 33.24 33.24 18.73 ‐ 3.76 8.81 ‐ 1.78 0.15 ‐ YesPM10 15 28.79 28.79 13.60 ‐ 4.45 8.61 ‐ 2.11 0.03 ‐ YesPM2.5 10 22.03 22.03 12.74 ‐ 3.82E+00 4.71 ‐ 0.74 7.59E‐03 ‐ YesNOx 40 150.94 150.94 147.41 ‐ 0.00E+00 0.00 ‐ 3.53 ‐ ‐ YesSOx 40 2.43 2.429 0.64 ‐ 1.20E‐02 0.02 ‐ 1.76 ‐ ‐ NoCO 100 96.91 96.91 88.14 2.52 ‐ 5.74 ‐ 0.52 ‐ ‐ NoVOC 40 29.09 11.84 1.35 1.59 0.59 4.71 2.89 0.71 ‐ 17.25 NoPb 0.6 5.59E‐03 0.005586 2.65E‐03 ‐ 7.01E‐04 2.23E‐03 ‐ ‐ ‐ ‐ NoH2S 10 1.44 1.438 0.71 ‐ 0.39 0.25 ‐ 9.01E‐02 ‐ ‐ NoH2SO4 7 0.15 0.1545 0.05 ‐ ‐ ‐ ‐ 1.01E‐01 ‐ ‐ NoTRS 10 2.42 2.4159 1.15 ‐ 0.51 0.67 ‐ 9.01E‐02 ‐ ‐ NoCO2 NA 209,178 209,178 195,369 ‐ ‐ 12,279 ‐ 1,530 ‐ ‐ NoCH4 NA 4.22 4.22 3.96 ‐ ‐ 0.23 ‐ 2.89E‐02 ‐ ‐ NoN2O NA 0.90 0.90 0.88 ‐ ‐ 0.02 ‐ 2.89E‐03 ‐ ‐ NoCO2e 75,000 209,552 209,552 195,729 ‐ ‐ 12,291 ‐ 1,531 ‐ ‐ Yes

Baseline Actual Emissions Calculations Abreviation KeySappi Cloquet Presteaming Project ADTFP = Air Dried Ton Finished Product BLS = Black Liquor Solids NG HHV (MMBtu/1000cf): 1010Permit #01700002‐101 ADTUBP = Air Dried Tons Unbleached Pulp ODTBP = Oven Dried Tons Bleached Pulp BLS HHV (mmBtu/lb): 5.53E‐03

SUMMARY

Pollutant Total Baseline Actual EU005 EU011 EU031 EU033 EU080 EU081Paved Roads FS 008 ‐

Chip TrucksApr‐14 to Mar‐16Emissions (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy)

PM 149.09 93.78 ‐ 18.84 28.81 ‐ 6.52 1.13PM10 126.44 68.09 ‐ 22.27 28.14 ‐ 7.72 0.23PM2.5 101.15 63.81 ‐ 1.92E+01 15.41 ‐ 2.72 5.57E‐02NOx 920.66 669.91 ‐ 0.00E+00 214.42 ‐ 36.33 ‐SOx 9.479 2.93 ‐ 6.00E‐02 0.05 ‐ 6.44 ‐CO 449.81 400.54 28.61 ‐ 18.76 ‐ 1.90 ‐VOC 57.20 6.28 18.09 2.94 15.41 11.87 2.60 ‐Pb 0.02409 1.33E‐02 ‐ 3.51E‐03 7.30E‐03 ‐ ‐ ‐Fluorides 0.00E+00 ‐ ‐ ‐ ‐ ‐ ‐ ‐H2S 6.325 3.23 ‐ 1.96 0.80 ‐ 0.33 ‐H2SO4 0.6127 0.24 ‐ ‐ ‐ ‐ 0.37 ‐TRS 10.27 5.21 ‐ 2.57 2.16 ‐ 0.33 ‐CO2 1,042,071 981,985 ‐ ‐ 52,425 ‐ 7,660 ‐CH4 21.04 19.91 ‐ ‐ 0.99 ‐ 0.14 ‐N2O 4.506 4.39 ‐ ‐ 0.10 ‐ 1.44E‐02 ‐CO2e 1,043,939 983,792 ‐ ‐ 52,479 ‐ 7,668 ‐

#10 Recovery Boiler (EQUI 53)

Apr‐15 to Mar‐16 Apr‐14 to Mar‐15

NG Fuel Use (MMcf) 52 70

NG Fuel Use (MMBtu) 52,783 71,110

BLS (tons) 870,059 842,842

BLS (MMBtu) 9,622,850 9,321,836

Operating Hours 8,610 8,618

Pollutant Emissions Emissions NG Emission Factor NG Emission Factor NG Emission Factor BLS Emission Factor BLS Emission Factor BLS Emission Factor Apr‐15 to Mar‐16

(tons/yr)Apr‐14 to Mar‐15

(tons/yr) Units Notes Units NotesPM 95.27 92.29 0.00 lb/MMcf Stack test 0.219 lb/ton BLS 1/20/15 Stack TestPM10 69.17 67.01 0.00 lb/MMcf Stack test 0.159 lb/ton BLS 1/20/15 Stack TestPM2.5 64.82 62.79 0.00 lb/MMcf Stack test 0.149 lb/ton BLS 1/20/15 Stack TestNOx 669.59 670.23 0.00 lb/MMcf CEMS 155.543 lb/hr CEMSSOx 2.93 2.93 0.00 lb/MMcf CEMS 0.68 lb/hr CEMSCO 400.35 400.74 0.00 lb/MMcf CEMS 93.0 lb/hr CEMSVOC 6.26 6.31 5.50 lb/MMcf EPA 1.420 lb/hr 10/20/14 Stack TestPb 0.01 0.01 NA lb/MMcf NA 3.10E‐05 lb/ton BLS NCASI TB701Fluorides ‐ ‐ NA lb/MMcf NA NA NA NAH2S 3.23 3.23 NA lb/MMcf Accounted for in BLS EF 7.50E‐01 lb/hr Based on TRS and NCASI

H2SO4 0.24 0.24 NA lb/MMcf NA 0.056 lb/hr 10/21/14 Stack TestTRS 5.21 5.21 NA lb/MMcf Accounted for in BLS EF 1.21 lb/hr CEMSCO2 996,995 966,975 116.89 lb CO2/mmBtu 40 CFR Part 98 Subp C 206.57 lb CO2/mmBtu 40 CFR Part 98 Subp CCH4 20.21 19.60 2.20E‐03 lb CH4/mmBtu 40 CFR Part 98 Subp C 4.19E‐03 lb CH4/mmBtu 40 CFR Part 98 Subp CN2O 4.46 4.32 2.20E‐04 lb N2O/mmBtu 40 CFR Part 98 Subp C 9.26E‐04 lb N2O/mmBtu 40 CFR Part 98 Subp CCO2e 998,830 968,754 117.01 lb CO2e/mmBtu Calculated by GWP 206.95 lb CO2e/mmBtu Calculated by GWP Emission factors from the 2015 emissions inventory used when available and are shaded in green

Process Conversion Factors

Process Data

#10 Smelt Dissolving Tank (EU 031)

Apr‐15 to Mar‐16 Apr‐14 to Mar‐15BLS (tons) 870,059 842,842 Note: is equal to #10 RB

Pollutant Emissions Emissions Emission Factor Emission Factor Emission Factor Apr‐15 to Mar‐16


(tons/yr) Units NotesPM 19.14 18.54 0.044 lb/ton BLS 11/14/13 Stack TestPM10 22.62 21.91 0.052 lb/ton BLS 11/14/13 Stack TestPM2.5 19.45 18.85 0.86 lb/lb PM10 State Derived From Webfire

NOx 0.00 0.00 0.00 lb/ton BLS 2006 letter to MPCA

SOx 6.09E‐02 5.90E‐02 1.40E‐04 lb/ton BLS 11/14/13 Stack TestCO ‐ ‐ NA NA NAVOC 2.98 2.89 6.86E‐03 lb/ton BLS 11/14/13 Stack TestPb 3.57E‐03 3.46E‐03 8.20E‐06 lb/ton BLS Trade Group Emission Factor

Fluorides ‐ ‐ NA NA NAH2S 1.99 1.93 4.58E‐03 lbs/ton BLS Based on NCASI

H2SO4 ‐ ‐ NA NA NATRS 2.61 2.53 0.006 lbs/ton BLS 11/14/13 Stack TestCO2 ‐ ‐ NA NA NACH4 ‐ ‐ NA NA NAN2O ‐ ‐ NA NA NACO2e ‐ ‐ NA NA NAEmission factors from the 2015 emissions inventory used when available and are shaded in green

Lime Kiln (EU 033)

Apr‐15 to Mar‐16 Apr‐14 to Mar‐15CaO (tons) 142,249 125,777

NG Fuel Use (kscf) 893,800 882,450NG Fuel (MMBtu) 902,738.030 891,274.845Operating Hours 8,295 8,225



(tons/yr) Units NotesPM 30.58 27.04 0.43 lb/ton CaO 12/31/14 Stack TestPM10 29.87 26.41 0.42 lb/ton CaO 12/31/14 Stack TestPM2.5 16.36 14.46 0.23 lb/ton CaO 12/31/14 Stack TestNOx 227.60 201.24 3.20 lb/ton CaO 2/1/12 Stack TestSOx 0.05 0.05 7.49E‐04 lb/ton CaO 11/22/13 Stack TestCO 19.91 17.61 0.28 lb/ton CaO 11/18/14 Stack TestVOC 16.36 14.46 0.23 lb/ton CaO 11/18/14 Stack TestPb 0.01 0.01 1.09E‐04 lb/ton CaO EPA Fluorides ‐ ‐ NA NA NAH2S 0.85 0.75 1.20E‐02 lb/ton CaO NCASI 701 ‐ LKIF3

H2SO4 ‐ ‐ 0.00 lb/hr 11/18/14 Stack TestTRS 2.16 2.15 0.52 lb/hr CEMSCO2 52,760 52,090 116.89 lb CO2/mmBtu 40 CFR Part 98 Subp CCH4 9.95E‐01 9.82E‐01 2.20E‐03 lb CH4/mmBtu 40 CFR Part 98 Subp CN2O 9.95E‐02 9.82E‐02 2.20E‐04 lb N2O/mmBtu 40 CFR Part 98 Subp CCO2e 52,815 52,144 117.01 lb CO2e/mmBtu Calculated by GWP Emission factors from the 2015 emissions inventory used when available and are shaded in green

Process Data

Process Data

IQS (NCG) (EU 081)

Apr‐15 to Mar‐16 Apr‐14 to Mar‐15Operating hours 8,430 8,082NG Fuel Use (kscf) 153,080 106,467NG Fuel (MMBtu) 154,610.846 107,531.653



(tons/yr) Units NotesPM 6.66 6.38 1.58 lb/hr 10/23/12 Stack TestPM10 7.88 7.56 1.87 lb/hr 10/23/12 Stack TestPM2.5 2.78 2.67 0.35 lb/lb PM10 State Derived From Webfire

NOx 37.09 35.56 8.80 lb/hr 12/20/11 Stack TestSOx 6.58 6.30 1.56 lb/hr 9/8/11 Stack TestCO 1.94 1.86 0.46 lb/hr 11/20/13 Stack TestVOC 2.66 2.55 0.63 lb/hr 9/8/11 Stack TestPb ‐ ‐ NA NA NAFluorides ‐ ‐ NA NA NAH2S 0.34 0.32 0.08 lb/hr Assume equal to TRS

H2SO4 0.38 0.36 0.090 lb/hr 2/18/14 Stack TestTRS 0.34 0.32 0.08 lb/hr 9/8/11 Stack TestCO2 9,036 6,285 116.89 lb CO2/mmBtu 40 CFR Part 98 Subp CCH4 1.70E‐01 1.19E‐01 2.20E‐03 lb CH4/mmBtu 40 CFR Part 98 Subp CN2O 1.70E‐02 1.19E‐02 2.20E‐04 lb N2O/mmBtu 40 CFR Part 98 Subp CCO2e 9,045 6,291 117.01 lb CO2e/mmBtu Calculated by GWP Emission factors from the 2015 emissions inventory used when available and are shaded in green

Market Pulp Machine (EU 080)

Apr‐15 to Mar‐16 Apr‐14 to Mar‐15ADTFP 343,170 345,183



(tons/yr) Units NotesPM ‐ ‐ NA NA NAPM10 ‐ ‐ NA NA NAPM2.5 ‐ ‐ NA NA NANOx ‐ ‐ NA NA NASOx ‐ ‐ NA NA NACO ‐ ‐ NA NA NAVOC 11.84 11.91 0.069 lb/ton ADTFP Trade Group Emission Factor

Pb ‐ ‐ NA NA NAH2SO4 ‐ ‐ NA NA NATRS ‐ ‐ NA NA NACO2 ‐ ‐ NA NA NACH4 ‐ ‐ NA NA NAN2O ‐ ‐ NA NA NACO2e ‐ ‐ NA NA NAEmission factors from the 2015 emissions inventory used when available and are shaded in green

Process Data

Process Data

Bleach Plant (EU 011)


ADTBP 410,344 376,395



(tons/yr) Units NotesPM ‐ ‐ NA NA NAPM10 ‐ ‐ NA NA NAPM2.5 ‐ ‐ NA NA NANOx ‐ ‐ NA NA NASOx ‐ ‐ NA NA NACO 29.84 27.37 0.145 lb/ton ADTBP 9/16/14 Stack TestVOC 18.88 17.31 0.092 lb/ton ADTBP 9/16/14 Stack TestPb ‐ ‐ NA NA NAH2SO4 ‐ ‐ NA NA NATRS ‐ ‐ NA NA NACO2 ‐ ‐ NA NA NACH4 ‐ ‐ NA NA NAN2O ‐ ‐ NA NA NACO2e ‐ ‐ NA NA NAEmission factors from the 2015 emissions inventory used when available and are shaded in green

Paved Road FS 008 ‐ Chip Trucks


Trucks per yr 8,300 8,300

Miles per trip 1.1 1.1

Vehicle Miles Traveled (VMT) 9,130 9,130



(tons/yr) Units Notes

PM 1.13 1.13 0.248 (lb/VMT) AP‐42 13.2 derivation below

PM10 0.23 0.23 0.050 (lb/VMT) AP‐42 13.2 derivation below

PM2.5 0.06 0.06 0.012 (lb/VMT) AP‐42 13.2 derivation below

NOx ‐ ‐ NA NA NA

SOx ‐ ‐ NA NA NA

CO ‐ ‐ NA NA NA

VOC ‐ ‐ NA NA NA

Pb ‐ ‐ NA NA NA

H2SO4 ‐ ‐ NA NA NA

TRS ‐ ‐ NA NA NA

CO2 ‐ ‐ NA NA NA

CH4 ‐ ‐ NA NA NA

N2O ‐ ‐ NA NA NA

CO2e ‐ ‐ NA NA NA

Process Data

Process Data

Data for Emission Factor Derivations

H2S EF Derivation based on TRS EF and NCASI data as shown below:

EU005

TRS EF: 1.21E+00 lbs/hr Notes

NCASI Data: DMDS 0 (lbs/ton BLS) 0.00% 0.00E+00 lbs/hr 0/11 detectsDMS 2.90E‐03 (lbs/ton BLS) 11.24% 1.36E‐01 lbs/hr 1/11 detectsMM 6.90E‐03 (lbs/ton BLS) 26.74% 3.24E‐01 lbs/hr 2/11 detectsH2S 1.60E‐02 (lbs/ton BLS) 62.02% 7.50E‐01 lbs/hr

SUM 2.58E‐02 (lbs/ton BLS) 100.00% 1.21E+00 lbs/hr

EU031

TRS EF: 6.00E‐03 lbs/ton BLS Notes

NCASI Data: DMDS 1.80E‐07 (lbs/ton BLS) 0.02% 9.15E‐07 lbs/ton BLS 0/11 detectsDMS 1.40E‐07 (lbs/ton BLS) 0.01% 7.12E‐07 lbs/ton BLS 1/11 detectsMM 2.80E‐04 (lbs/ton BLS) 23.72% 1.42E‐03 lbs/ton BLS 2/11 detectsH2S 9.00E‐04 (lbs/ton BLS) 76.25% 4.58E‐03 lbs/ton BLSSUM 1.18E‐03 (lbs/ton BLS) 100.00% 6.00E‐03 lbs/ton BLS

GHG EFs derived based on 40 CFR Part 98 Global Warming Potentials (GWP) for CO2e, and Subpart C emission factors for individual GHG as follows:

GHG Pollutant GWPNG Emission Factor

(kg/mmBtu)NG Emission Factor

(lb/mmBtu)BLS Emission Factor

(kg/mmBtu)BLS Emission Factor

(lb/mmBtu)

CO2 1 53.02 116.89 93.70 206.57

CH4 25 1.00E‐03 2.20E‐03 1.90E‐03 4.19E‐03N2O 298 1.00E‐04 2.20E‐04 4.20E‐04 9.26E‐04CO2e ‐‐‐ 53.07 117.01 93.87 206.95

Conversions: 2.20462 lb/kg

Paved Road FS ‐ Chip Trucks

Particle Size Silt Loading Mean Vehicle Precipitation Uncontrolled

Pollutant Multiplier, k sL Weight, W Days, P Emission Factor, E

(lb/VMT) (g/m2) (tons) (days) (lb/VMT)

PM2.5 0.00054 0.808 28.075 130 0.012

PM10 0.0022 0.808 28.075 130 0.050

PM30 or TSP 0.011 0.808 28.075 130 0.248

E = [k * (sL)^0.91* (W)^1.02] * (1‐P/4N)where:

E = Emission factor (lb/VMT, vehicle miles traveled) from AP‐42, Section 13.2.1, Equation 2, (01/11).k = Particle size multiplier (lb/VMT) from AP‐42, Table 13.2.1‐1.sL = Road surface silt loading (g/m²) based on the site‐specific sampled value 0.808 g/m2 (August 2005) as listed in the permit.

W = Mean vehicle weight based on the "fleet" average weight of all vehicles traveling the road.P = Number of days with at least 0.01 in. of precipitation per year from AP‐42, Figure 13.2.1‐2.N = Number of days per year (365 days).

Future Projected Actual (FPA) Emissions Calculations Abreviation KeySappi Cloquet Presteaming Project ADTFP = Air Dried Ton Finished Product BLS = Black Liquor Solids NG HHV (MMBtu/1000cf): 1010Permit #01700002‐101 ADTUBP = Air Dried Tons Unbleached Pulp ODTBP = Oven Dried Tons Bleached Pulp BLS HHV (mmBtu/lb): 5.53E‐03

SC Pulp = Chemical Cellulose

SUMMARY

Kraft Pulp (tpy) 0 0 NA Rate IncreaseSC Pulp (tpy) 428,000 1,173 tons/day 13.63% Rate Increase 69.04CaO (tpy) 175,000 Maximum capacity based on a 500 ton/day BLS (tpy) 1,027,475 Updated to current boiler fuel rating : 5.63 mmlbs BLS/dayOverall Average Rate Incr 13.63%

Pollutant Total FPA Emissions EU005 EU011 EU031 EU033 EU080 EU081 EU090Paved Roads FS 008 ‐

Chip Trucks(tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy)

PM 182.33 112.51 ‐ 22.60 37.63 ‐ 8.30 ‐ 1.28PM10 155.23 81.68 ‐ 26.71 36.75 ‐ 9.83 ‐ 0.26PM2.5 123.18 76.55 ‐ 2.30E+01 20.13 ‐ 3.47 ‐ 6.33E‐02NOx 1,027.56 817.32 ‐ 0.00E+00 170.38 ‐ 39.86 ‐ ‐SOx 11.91 3.57 ‐ 7.19E‐02 0.07 ‐ 8.20 ‐ ‐CO 546.73 488.68 31.13 ‐ 24.50 ‐ 2.42 ‐ ‐VOC 86.29 7.630 19.69 3.52 20.13 14.77 3.31 17.25 ‐ 69.04Pb 0.02968 0.01593 ‐ 4.21E‐03 9.54E‐03 ‐ ‐ ‐ ‐Fluorides 0.00E+00 ‐ ‐ ‐ ‐ ‐ ‐ ‐ ‐H2S 7.764 3.943 ‐ 2.35 1.05 ‐ 0.42 ‐ ‐H2SO4 0.7672 0.2943 ‐ ‐ ‐ ‐ 0.47 ‐ ‐TRS 12.68 6.358 ‐ 3.08 2.82 ‐ 0.42 ‐ ‐CO2 1,251,248 1,177,355 ‐ ‐ 64,704 ‐ 9,190 ‐ ‐CH4 2.53E+01 23.87 ‐ ‐ 1.22 ‐ 0.17 ‐ ‐N2O 5.41E+00 5.27 ‐ ‐ 0.12 ‐ 1.73E‐02 ‐ ‐CO2e 1,253,491 1,179,521 ‐ ‐ 64,771 ‐ 9,200 ‐ ‐

Chip Pre‐steamer (EU 090) ‐ Potential Emissions for Proposed New Unit

Max Chip Throughput (tph) 213

Max Annual Operating Hours 8,760

Pollutant Potential Emissions Emission Factor Emission Factor Emission Factor (tpy) Units Notes

PM ‐ NA NA NAPM10 ‐ NA NA NAPM2.5 ‐ NA NA NANOx ‐ NA NA NASOx ‐ NA NA NACO ‐ NA NA NAVOC 17.25 9.27E‐06 ton VOC/ton green chip August 2016 site testing

Pb ‐ NA NA NAFluorides ‐ NA NA NAH2S ‐ NA NA NAH2SO4 ‐ NA NA NATRS ‐ NA NA NACO2 ‐ NA NA NACH4 ‐ NA NA NAN2O ‐ NA NA NACO2e ‐ NA NA NA

Process Conversion Factors

Future Process Data Assumptions Notes

Process Data

#10 Recovery Boiler (EU 005)

NG Fuel Use (MMcf) 61

NG Fuel Use (MMBtu) 61,947

BLS (tons) 1,027,475

BLS (MMBtu) 11,363,874

Combined Fuel Use (MMBtu) 11,425,820

Operating Hours 8,760

Pollutant FPA Emissions NG Emission Factor NG Emission Factor NG Emission Factor BLS Emission Factor BLS Emission Factor BLS Emission Factor (tpy) Units Notes Units Notes

PM 112.51 0.00 lb/MMcf Stack test 0.219 lb/ton BLS 1/20/15 Stack TestPM10 81.68 0.00 lb/MMcf Stack test 0.159 lb/ton BLS 1/20/15 Stack TestPM2.5 76.55 0.00 lb/MMcf Stack test 0.149 lb/ton BLS 1/20/15 Stack TestNOx 817.32 0.00 lb/MMcf CEMS 155.543 lb/hr CEMSSOx 3.57 0.00 lb/MMcf CEMS 0.68 lb/hr CEMSCO 488.68 0.00 lb/MMcf CEMS 93.0 lb/hr CEMSVOC 7.63 5.50 lb/MMcf EPA 1.420 lb/hr 10/20/14 Stack TestPb 0.02 NA lb/MMcf NA 3.10E‐05 lb/ton BLS NCASI TB701Fluorides ‐ NA lb/MMcf NA NA NA NAH2S 3.94 NA lb/MMcf Accounted for in BLS EF 7.50E‐01 lb/hr Based on TRS and NCASI

H2SO4 0.29 NA lb/MMcf NA 0.056 lb/hr 10/21/14 Stack TestTRS 6.36 NA lb/MMcf Accounted for in BLS EF 1.21E+00 lb/hr CEMSCO2 1,177,355 116.89 lb CO2/mmBtu 40 CFR Part 98 Subp C 206.57 lb CO2/mmBtu 40 CFR Part 98 Subp CCH4 23.87 2.20E‐03 lb CH4/mmBtu 40 CFR Part 98 Subp C 4.19E‐03 lb CH4/mmBtu 40 CFR Part 98 Subp CN2O 5.27 2.20E‐04 lb N2O/mmBtu 40 CFR Part 98 Subp C 9.26E‐04 lb N2O/mmBtu 40 CFR Part 98 Subp CCO2e 1,179,521 117.01 lb CO2e/mmBtu Calculated by GWP 206.95 lb CO2e/mmBtu Calculated by GWP

There will not be an increase in NG fuel as it is a supplementary fuel for startups and the number of startups is not expected to change as a result of this projectEmission factors from the 2015 emissions inventory used when available and are shaded in green

#10 Smelt Dissolving Tank (EU 031)

BLS (tons) 1,027,475 Note: is equal to #10 RB

Pollutant FPA Emissions Emission Factor Emission Factor Emission Factor (tpy) Units Notes

PM 22.60 0.04 lb/ton BLS 11/14/13 Stack TestPM10 26.71 0.052 lb/ton BLS 11/14/13 Stack TestPM2.5 22.97 0.86 lb/lb PM10 State Derived From Webfire

NOx 0.00 0.00 lb/ton BLS 2006 letter to MPCA

SOx 7.19E‐02 1.40E‐04 lb/ton BLS 11/14/13 Stack TestCO ‐ NA NA NAVOC 3.52 6.86E‐03 lb/ton BLS 11/14/13 Stack TestPb 4.21E‐03 8.20E‐06 lb/ton BLS Trade Group Emission Factor

Fluorides ‐ NA NA NAH2S 2.35 4.58E‐03 lbs/ton BLS Based on NCASI

H2SO4 ‐ NA NA NATRS 3.08 0.006 lbs/ton BLS 11/14/13 Stack TestCO2 ‐ NA NA NACH4 ‐ NA NA NAN2O ‐ NA NA NACO2e ‐ NA NA NAEmission factors from the 2015 emissions inventory used when available and are shaded in green

Note: scaling BA operating hours to FPA operating hours using a ratio of throughputs resulted in operation over 8,760 annual operating hours. As this is not possible, for emissions based on lb/hr factors the emissions increase is accounted for by applying the ratio to the emission calculation itself.

Annual FPA Process Data


Lime Kiln (EU 033)

CaO (tons) 175,000NG Fuel Use (kscf) 1,096,136NG Fuel (MMBtu) 1,107,097Operating Hours 8,760


PM 37.63 0.43 lb/ton CaO 12/31/14 Stack TestPM10 36.75 0.420 lb/ton CaO 12/31/14 Stack TestPM2.5 20.13 0.23 lb/ton CaO 12/31/14 Stack TestNOx 170.38 38.90 lb/hr Current Permit LimitSOx 0.07 7.49E‐04 lb/ton CaO 11/22/13 Stack TestCO 24.50 0.28 lb/ton CaO 11/18/14 Stack TestVOC 20.13 0.23 lb/ton CaO 11/18/14 Stack TestPb 9.54E‐03 1.09E‐04 lb/ton CaO EPA Fluorides ‐ NA NA NAH2S 1.05 1.20E‐02 lb/ton CaO NCASI 701 ‐ LKIF3

H2SO4 ‐ 0.00 lb/hr 11/18/14 Stack TestTRS 2.82 0.52 lb/hr CEMSCO2 64,704 116.89 lb CO2/mmBtu 40 CFR Part 98 Subp CCH4 1.22E+00 2.20E‐03 lb CH4/mmBtu 40 CFR Part 98 Subp CN2O 1.22E‐01 2.20E‐04 lb N2O/mmBtu 40 CFR Part 98 Subp CCO2e 64,771 117.01 lb CO2e/mmBtu Calculated by GWP Note: LK modified to include low NOx burners with start‐up occurring on May 13, 2016. Stack testing has not yet been performed, so FPA calcs are based on an EF derived from the current permit limit of 38.9 lb/hr, and 8,760 hr/yr of operation.

Emission factors from the 2015 emissions inventory used when available and are shaded in green

IQS (NCG) (EU 081)

Operating hours 8,760NG Fuel Use (kscf) 155,688NG Fuel (MMBtu) 157,244.842


PM 8.30 1.58 lb/hr 10/23/12 Stack TestPM10 9.83 1.870 lb/hr 10/23/12 Stack TestPM2.5 3.47 0.35 lb/lb PM10 State Derived From Webfire

NOx 39.86 9.10 lb/hr 12/20/11 Stack TestSOx 8.20 1.56 lb/hr 9/8/11 Stack TestCO 2.42 0.46 lb/hr 11/20/13 Stack TestVOC 3.31 0.63 lb/hr 9/8/11 Stack TestPb ‐ NA NA NAFluorides ‐ NA NA NAH2S 0.42 0.08 lb/hr Assume equal to TRS

H2SO4 0.47 0.090 lb/hr 2/18/14 Stack TestTRS 0.42 0.08 lb/hr 9/8/11 Stack TestCO2 9,190 116.89 lb CO2/mmBtu 40 CFR Part 98 Subp CCH4 1.73E‐01 2.20E‐03 lb CH4/mmBtu 40 CFR Part 98 Subp CN2O 1.73E‐02 2.20E‐04 lb N2O/mmBtu 40 CFR Part 98 Subp CCO2e 9,200 117.01 lb CO2e/mmBtu Calculated by GWP

Emission factors from the 2015 emissions inventory used when available and are shaded in green


Scaling BA operating hours to FPA operating hours using a ratio of throughputs resulted in operation over 8,760 annual operating hours. As this is not possible, for emissions based on lb/hr factors the emissions increase is accounted for by applying the ratio to the emission calculation itself.

Note: scaling BA operating hours and NG fuel useage to FPA values using a ratio of BLS throughputs resulted in operation over 8,760 annual operating hours. As this is not possible, for emissions based on lb/hr factors the emissions increase is accounted for by applyingthe ratio to the emission calculation itself.


The most representative way to estimate the IQS emissions increase is believed to be utilizing a ratio of BLS production increase, however there may not be a directly linear relationship between IQS operation and BLS production. Sappi believes it will be able to maintain the current NOx limit as represented in the above calculations.

Market Pulp Machine (EU 080)

ADTFP 428,000


PM ‐ NA NA NAPM10 ‐ NA NA NAPM2.5 ‐ NA NA NANOx ‐ NA NA NASOx ‐ NA NA NACO ‐ NA NA NAVOC 14.77 0.069 lb/ton ADTFP Trade Group Emission Factor

Pb ‐ NA NA NAH2SO4 ‐ NA NA NATRS ‐ NA NA NACO2 ‐ NA NA NACH4 ‐ NA NA NAN2O ‐ NA NA NACO2e ‐ NA NA NAEmission factors from the 2015 emissions inventory used when available and are shaded in green

Bleach Plant (EU 011)

ADTBP 428,000


PM ‐ NA NA NAPM10 ‐ NA NA NAPM2.5 ‐ NA NA NANOx ‐ NA NA NASOx ‐ NA NA NACO 31.13 0.145 lb/ton ADTBP 9/16/14 Stack TestVOC 19.69 0.092 lb/ton ADTBP 9/16/14 Stack TestPb ‐ NA NA NAH2SO4 ‐ NA NA NATRS ‐ NA NA NACO2 ‐ NA NA NACH4 ‐ NA NA NAN2O ‐ NA NA NACO2e ‐ NA NA NAEmission factors from the 2015 emissions inventory used when available and are shaded in green



Paved Road FS 008 ‐ Chip Trucks

Trucks per yr 9,432

Miles per trip 1.1

Vehicle Miles Traveled (VMT) 10,375


PM 1.28 0.25 (lb/VMT) AP‐42 13.2 derivation in BA

PM10 0.26 0.050 (lb/VMT) AP‐42 13.2 derivation in BA

PM2.5 0.06 0.01 (lb/VMT) AP‐42 13.2 derivation in BA

NOx ‐ NA NA NA

SOx ‐ NA NA NA

CO ‐ NA NA NA

VOC ‐ NA NA NA

Pb ‐ NA NA NA

H2SO4 ‐ NA NA NA

TRS ‐ NA NA NA

CO2 ‐ NA NA NA

CH4 ‐ NA NA NA

N2O ‐ NA NA NA

CO2e ‐ NA NA NA


VOC Emission Factor Determination for Chip Pre‐steaming UnitSappi Cloquet Presteaming and Lignoboost Project Permit #01700002‐101

Results of bench scale site testing completed in August 4, 8, and 9 of 2016 converted to total VOC Emission Factor:

Sample DescriptionVOC mg/g (bone dry) (as Carbon

basis)

VOC g/g (bone dry) (as Mass basis)

Conv. To VOC g/g (green)

(as Mass basis)

MeOH mg/g (bone dry)

(as Mass basis)

Acetaldehyde mg/g (bone dry) (as Mass

basis)

Formaldehyde mg/g (bone dry) (as Mass

basis)

Conv. To Form. g/g (green)

(as Mass basis)

Total HAP mg/g (bone dry)

(as Mass basis)

Moisture (%)

List of detected HAPs

1 Maple 08/04 0.00017 4.67E‐07 3.05E‐07 0.000132 0.000071 0.00004 2.97E‐08 0.00024 34.7 Acetaldehyde, formaldehyde, methanol

2 Maple 08/08 0.0002 5.50E‐07 3.56E‐07 0.000253 0.000097 0.00004 2.96E‐08 0.00039 35.3 Same

3 Maple 08/09 0.00124 3.41E‐06 2.19E‐06 0.000765 0.000055 0.00004 2.94E‐08 0.00086 35.9 Same

4 Aspen 08/04 0.00164 4.51E‐06 2.49E‐06 0.000296 0.000097 0.00005 3.46E‐08 0.00044 44.7 Same

5 Aspen 08/08 0.00359 9.87E‐06 5.48E‐06 0.00061 0.000064 0.00005 3.46E‐08 0.00073 44.5 Same

6 Aspen 08/09 0.00488 1.34E‐05 7.33E‐06 0.001942 0.000062 0.00006 4.13E‐08 0.00207 45.4 Same

Avg Maple 0.00054 1.48E‐06 9.60E‐07 3.83E‐04 7.50E‐05 4.00E‐05 2.96E‐08 5.00E‐04 35.3Std. Dev. 0.00061 1.68E‐06 1.07E‐06 3.36E‐04 2.12E‐05 0.00E+00 1.31E‐10 3.23E‐04 0.6090% C.I 0.00103 2.82E‐06 1.81E‐06 5.66E‐04 3.57E‐05 0.00E+00 2.21E‐10 5.45E‐04 1.01Upper 90% 0.00157 4.31E‐06 2.77E‐06 9.49E‐04 1.11E‐04 4.00E‐05 2.98E‐08 1.05E‐03 36.31Max Data 0.00124 3.41E‐06 2.19E‐06 7.65E‐04 9.70E‐05 4.00E‐05 2.97E‐08 8.60E‐04 35.9Avg Aspen 0.00337 9.26E‐06 5.11E‐06 9.49E‐04 7.40E‐05 6.00E‐05 4.14E‐08 1.08E‐03 44.9Std. Dev. 0.00163 4.48E‐06 2.44E‐06 8.74E‐04 1.97E‐05 5.77E‐06 3.86E‐09 8.70E‐04 0.4790% C.I 0.00275 7.56E‐06 4.11E‐06 1.47E‐03 3.31E‐05 9.73E‐06 6.51E‐09 1.47E‐03 0.80Upper 90% 0.00612 1.68E‐05 9.22E‐06 2.42E‐03 1.07E‐04 6.97E‐05 4.79E‐08 2.55E‐03 45.66Max Data 0.00488 1.34E‐05 7.33E‐06 1.94E‐03 9.70E‐05 6.00E‐05 4.13E‐08 2.07E‐03 45.4Worst Case Avg EF (ton VOC/ton green chips) 5.11E‐06 4.14E‐08Worst Case Upper 90% C.I. EF (ton VOC/ton green chips) 9.22E‐06 4.79E‐08Worst Case Max EF (ton VOC/ton green chips) 7.33E‐06 4.13E‐08Total VOC Emission Factor: 9.27E‐06 ton VOC/ton greenNotes: Data was collected separately from the steaming of both aspen and maple wood chips of which the facility uses a blend. Aspen chips resulted in higher emissions, and therefore were used as a conservative worst‐case estimate.

Response Factors for Analyzer (per Dan Despen of Interpoll):Carbon: 0.97MeOH: 2.75

Max. Chip Throughput Based on Max. ADTBP Throughput from Bleachplant (Physical Limitation):41.67 ADTBP/hr For SC62.50 ADTBP/hr For Kraft (Selected as conservative worst case)212.5 ton green chip/hr

Ton Green Chip/ ADTBP (Per Justin):SC pulp: 4.3Kraft pulp: 3.4

For reference ‐ Actual Green Chip Production (ton/yr):Apr‐15 to Mar‐16 Apr‐14 to Mar‐15 Avg (ton/yr) Avg (ton/hr)

1,618,175 1,556,394 1,587,284 181

Total VOC EF derivation based on MPCA guidance for wood products tested using Method 25A in 2004 memo Mass Basis of VOC Emissions for Permitting, Compliance and Emission Inventory from the VOC Workgroup. A response factor from the analyzer was used to convert VOC as carbon basis to VOC as mass basis. The VOC data includes all HAPs, except Formaldehyde as this compound does not repond on a FID as used in Method 25A. Therefore, Formaldehyde has been added into the VOC emission factor. Assumed process data and conversion factors are listed below:

EAW and AERA Applicability Emissions CalculationsSappi Cloquet Presteaming Project Permit #01700002‐101

EAW and AERA Applicability Analysis

Summary

Pollutant EAW Threshold Total PTE Increase PTE Increase from

EU090(tpy) (tpy) (tpy)

PM 250 0.00 ‐ NoPM10 250 0.00 ‐ NoPM2.5 250 0.00 ‐ NoNOx 250 0.00 ‐ NoSOx 250 0.00 ‐ NoCO 250 0.00 ‐ NoVOC 250 17.25 17.25 NoPb 250 0.00 ‐ NoFluorides 250 0.00 ‐ NoH2S 250 0.00 ‐ NoH2SO4 250 0.00 ‐ NoTRS 250 0.00 ‐ NoCO2 NA 0 ‐ NoCH4 NA 0.00 ‐ NoN2O NA 0.00 ‐ NoCO2e 100,000 0 ‐ No

PTE Increase Calculations for EU090 (Chip Pre‐Steamer)Note that the PTE Increase will be the same for all senarios, and that this is a proposed new unit

Max Chip Throughput (tph) 213Max Annual Operation (hr) 8,760

Pollutant PTE Increase PTE Increase Emission Factor Emission Factor Emission Factor (tpy) (lb/hr) Units Notes

PM ‐ ‐ NA NA NAPM10 ‐ ‐ NA NA NAPM2.5 ‐ ‐ NA NA NANOx ‐ ‐ NA NA NASOx ‐ ‐ NA NA NACO ‐ ‐ NA NA NAVOC 17.25 3.94 9.27E‐06 ton VOC/ton green chip August 2016 site testing

Pb ‐ ‐ NA NA NAFluorides ‐ ‐ NA NA NAH2S ‐ ‐ NA NA NAH2SO4 ‐ ‐ NA NA NATRS ‐ ‐ NA NA NACO2 ‐ ‐ NA NA NACH4 ‐ ‐ NA NA NAN2O ‐ ‐ NA NA NACO2e ‐ ‐ NA NA NA

Future Process Data

Exceed EAW Thresold?

Note that calculations for each scenario are performed in accordance with Minnesota Rule 7007.1200, Subpart 3. This requires determining the emissions increase based on the increase in hourly emissions from the project due to new units and existing debottlenecked emission units which exceed their maximum hourly emission rate as a result of this project. EU 090 is the only new proposed unit. EU 005 will be debottlenecked, however this project is not expected to result in an increase in hourly emissions. Any changes would be on a longer term basis.

TSD Attachments Attachment 2: Requirements development report

Sappi Cloquet LLC Permit Number: 01700002-101

Subject Item DescriptionTFAC0000000006 01700002

Permit Appendices: This permit contains appendices as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in Appendix A: Insignificant Activities Required to be Listed, Appendix C: Road Segment Speed Limit and Silt Load Test Areas, Appendix D: Performance Test Recordkeeping Items and Testing Schedule, and Appendix E: Fugitive Control Plan. Modeling parameters in Appendices B: Stack Parameters Relied Upon in Modeling are included for reference only as described elsewhere in this permit. [Minn. R. 7007.0800, subp. 2]

TFAC0000000006 01700002

Modeled Parameters for CO, NO2, PM, PM10, PM2.5, and SO2: The parameters used in PM and SO2 modeling completed in 1995, CO, NO2and PM10 modeling completed in 2012, and PM2.5 modeling completed for permit number 01700002‐015 are listed in Appendix B of this permit. The parameters describe the operation of the facility at maximum permitted capacity. The purpose of listing the parameters in theappendix is to provide a benchmark for future changes. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

Changes to Modeled Parameters for CO, NO2, PM, PM10, PM2.5, and SO2: Any permit amendment that affects any modeled parameter oremission rate for CO, NO2, PM, PM10, PM2.5, and SO2 listed in Appendix B must be a major amendment. Any addition to the information documented in Appendix B requires a major amendment. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

Equivalent or Better Dispersion (EBD) Modeling Triggers (Modeling Required) for CO, NO2, PM, PM10, PM2.5, and SO2: Changes that affecany modeled parameter or emission rate listed in Appendix B, or an addition to the information documented in Appendix B, trigger the EBDModeling Submittal requirement. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

EBD Modeling Submittal for CO, NO2, PM, PM10, PM2.5, and SO2: For changes meeting the criteria in the EBD Modeling Triggers (ModelinRequired) requirement, the Permittee shall submit an EBD modeling submittal in accordance with the current version of the MPCA Air Dispersion Modeling Guidance and shall wait for written approval (in the form of an issued permit amendment) before making such changes. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

EBD Modeling Submittal Content for CO, NO2, PM, PM10, PM2.5, and SO2: The information submitted must include, for stack and vent sources, source emission rate, location, height, diameters, exit velocity, exit temperature, discharge direction, use of rain caps or rain hats,and, if applicable, locations and dimensions of nearby buildings. For non‐stack/vent sources, this includes the source emission rate, locatiosize and shape, release height, and, if applicable, any emission rate scalars, and the initial lateral dimensions and initial vertical dimensionsand adjacent building heights. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subps. 2&4,Minn. R. 7007.3000, Minn. R. 7009.0010‐0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

Outdated EBD Baseline Modeling for CO, NO2, PM, PM10, PM2.5, and SO2: Prior to conducting the EBD analysis, the Permittee shall use thcurrent version of the MPCA Air Dispersion Modeling Guidance to determine if the Baseline Modeling (the most recent refined modeling demonstration) is outdated. If the Baseline Modeling is outdated, the Permittee shall update the Baseline Modeling to be consistent with the current version of the MPCA Air Dispersion Modeling Guidance. The updated modeling will become the new Baseline Modeling. This requirement does not require the Permittee to complete a new refined modeling demonstration using the revisions made for the EBD demonstration. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subps. 2&4, Minn. R. 7007.3000, Minn. R. 7009.0010‐0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

EBD Modeling Results for CO, NO2, PM, PM10, PM2.5, and SO2: The dispersion characteristics due to the revisions of the information in Appendix B must be equivalent to or better than the dispersion characteristics modeled September 25, 1995 (PM and SO2), March 5, 2012(CO, NO2, and PM10 and 2017 (PM2.5). The Permittee shall demonstrate this equivalency in the proposal. [Minn. R. 7007.0100, subp. 7(A)7(L), & 7(M), Minn. R. 7007.0800, subp. 1, Minn. R. 7007.0800, subp. 2&4, Minn. R. 7007.3000, Minn. R. 7009.0010‐0080, Minn. Stat. 116.0subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

Computer Dispersion Modeling Triggers for CO, NO2, PM, PM10, PM2.5, and SO2: The Permittee shall conduct a refined remodeling analysin accordance with the Computer Dispersion Modeling requirements of this permit and the current version of the MPCA Air Dispersion Modeling Guidance if: (1) the results of the EBD modeling analysis do not demonstrate equivalent or better dispersion characteristics; (2) aconclusion cannot readily be made about the dispersion, or (3) the criteria in the EBD Modeling Triggers requirement are met and the Permittee has previously conducted three successive EBD analyses using the same Baseline Modeling. [Minn. R. 7007.0100, subp. 7(A), 7(L& 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, TitI Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

Computer Dispersion Modeling Protocol: due 180 days after receipt of written MPCA request for CO, NO2, PM, PM10, PM2.5, and/or SO2 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of the MPCA Air Dispersion Modeling Guidance. The protocol must be based on projected operating conditions under the next permit term. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, MinStat. 116.07, subd. 9, Minn. Stat. 116.07, subds. 4a, Title I Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to the submitted protocol for CO,NO2, PM, PM10, PM2.5, and/or SO2 modeling. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol foCO, NO2, PM, PM10, PM2.5, and/or SO2. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. (4a), Minn. Stat. 116.07, subd. 9, Title I Condition: 4CFR 52.21(k)]

TFAC0000000006 01700002

All stacks listed in Appendix B must be vertical, with an unobstructed release point. No rain caps, rain hats, horizontal release, or tilted stacks are allowed. There are no exceptions to this. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TFAC0000000006 01700002

Inspection and Maintenance: Inspect the fencing and gates established for access control once per year. All repairs and maintenance to thefence and gates shall be completed as soon as possible but no later than 60 days after the Permittee observes the need for repair or maintenance or after the MPCA notifies the Permittee of the need for repair or maintenance. [Title I Condition: 40 CFR 52.21(k)(modeling)Minn. R. 7007.3000]

TFAC0000000006 01700002

Access Control: All gates installed at access points shall be kept closed unless: 1. A guard is present controlling access at a gate; or 2. Authorized persons are entering or leaving the property through a gate. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000

TFAC0000000006 01700002

PERMIT SHIELD: Subject to the limitations in Minn. R. 7007.1800, compliance with the conditions of this permit shall be deemed compliancwith the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations oMinn. R. 7007.1800 and 7017.0100, subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements. This permit shall not alter or affect the liability of the Permittee for any violation of applicable requirements priorto or at the time of permit issuance. [Minn. R. 7007.1800, (A)(1)‐(2), Minn. R. 7007.1800, C(2)]

TFAC0000000006 01700002

Comply with Fugitive Emission Control Plan: The Permittee shall follow the actions and recordkeeping specified in the control plan in Appendix E. The Plan shall describe methods that the Permittee will use to control fugitive emissions from the property, including from paved and unpaved roads and from the Sappi Industrial Solid Waste landfill. The plan may be amended by the Permittee as needed, and thmost recent version shall be maintained on site. If the Commissioner determines the Permittee is out of compliance with Minn. R. 7011.0150, this requirement, or the fugitive control plan, then the Permittee may be required to amend the control plan and/or to install and operate particulate matter ambient monitors as requested by the Commissioner. [Minn. R. 7007.0100, Minn. R. 7007.0800, subp. 2, Minn. R. 7009.0020, Minn. R. 7011.0150, Minn. Stat. 116.07, subd. 4a]

TFAC0000000006 01700002

Visual Inspection Training: The Permittee shall provide annual training to its employees that are directly involved in the loading operationsfor the coating department and pulp mill lime silos and ash silo. The training shall include instructions on procedures for making visual inspections of the silos, including transport lines. The person making the inspection shall be trained to look for accumulation of dust or particulate matter, as well as excess emissions or high opacity from the loading operations. The employees shall be trained on procedures be followed if there are any problems observed from such things as line ruptures or spills which may result in dust accumulations or high opacity. The Permittee shall retain records of the training given. [Minn. Stat. 116.07, subd. 4a, Minn. R. 7007.0800, subp. 2]

TFAC0000000006 01700002

These requirements apply if a reasonable possibility (RP) as defined in 40 CFR Section 52.21(r)(6)(vi) exists that a proposed project, analyzeusing the actual‐to‐projected‐actual (ATPA) test (either by itself or as part of the hybrid test at Section 52.21(a)(2)(iv)(f)) and found to not bpart of a major modification, may result in a significant emissions increase (SEI). If the ATPA test is not used for the project, or if there is noRP that the proposed project could result in a SEI, these requirements do not apply to that project. The Permittee is only subject to the Preconstruction Documentation requirement for a project where a RP occurs only within the meaning of Section 52.21(r)(6)(vi)(b). Even though a particular modification is not subject to New Source Review (NSR), or where there isn't a RP that a proposed project could result a SEI, a permit amendment, recordkeeping, or notification may still be required by Minn. R. 7007.1150 ‐ 7007.1500. [Minn. R. 7007.0800, subp. 2, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

TFAC0000000006 01700002

Preconstruction Documentation ‐‐ Before beginning actual construction on a project, the Permittee shall document the following: 1. Projecdescription 2. Identification of any emission unit whose emissions of an NSR pollutant could be affected 3. Pre‐change potential emissions any affected existing emission unit, and the projected post‐change potential emissions of any affected existing or new emission unit. 4. A description of the applicability test used to determine that the project is not a major modification for any regulated NSR pollutant, includinthe baseline actual emissions, the projected actual emissions, the amount of emissions excluded due to increases not associated with the modification and that the emission unit could have accommodated during the baseline period, an explanation of why the amounts were excluded, and any creditable contemporaneous increases and decreases that were considered in the determination. The Permittee shall maintain records of this documentation. [Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7007.1200, subp. 4, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

TFAC0000000006 01700002

The Permittee shall monitor the actual emissions of any regulated NSR pollutant that could increase as a result of the project and that weranalyzed using the ATPA test, and the potential emissions of any regulated NSR pollutant that could increase as a result of the project and that were analyzed using potential emissions in the hybrid test. The Permittee shall calculate and maintain a record of the sum of the actuaand potential (if the hybrid test was used in the analysis) emissions of the regulated pollutant, in tons per year on a calendar year basis, forperiod of 5 years following resumption of regular operations after the change, or for a period of 10 years following resumption of regular operations after the change if the project increases the design capacity of or potential to emit of any unit associated with the project. [MinR. 7007.0800, subps. 4‐5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

TFAC0000000006 01700002

The Permittee must submit a report to the Agency if the annual summed (actual, plus potential if used in hybrid test) emissions differ fromthe preconstruction projection and exceed the baseline actual emissions by a significant amount as listed at 40 CFR Section 52.21(b)(23). Such report shall be submitted to the Agency within 60 days after the end of the year in which the exceedances occur. The report shall contain : a. The name and ID number of the Facility, and the name and telephone number of the Facility contact person. b. The annual emissions (actual, plus potential if any part of the project was analyzed using the hybrid test) for each pollutant for which the preconstruction projection and significant emissions increase are exceeded c. Any other information, such as an explanation as to why the summed emissions differ from the preconstruction projection. [Minn. R. 7007.0800, subps. 4‐5, Title I Condition: 40 CFR 52.21(r)(6) and Minn. R. 7007.3000]

TFAC0000000006 01700002

The Permittee shall submit a computer dispersion modeling protocol : Due before 09/13/2025 for PM10 and PM2.5 refined modeling. The Permittee shall submit a Computer Dispersion Modeling Protocol that is complete and approvable by MPCA by the deadline in this requirement. This protocol will describe the proposed modeling methodology and input data, in accordance with the current version of theMPCA Air Dispersion Modeling Guidance. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

The Permittee shall submit a Computer Dispersion Modeling Protocol: due 60 days after receipt of written MPCA request for revisions to thprotocol for PM10 and PM2.5 modeling that is required to be submitted by 9/13/2025. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), MinnR. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

Computer Dispersion Modeling Results: due 180 days after receipt of written MPCA approval of Computer Dispersion Modeling Protocol foPM10 and PM2.5 that is required to be submitted by 9/13/2025. The Permittee shall submit a final Computer Dispersion Modeling Report that is complete and approvable by MPCA by the deadline in this requirement. The submittal shall adhere to the current version of the MPCA Air Dispersion Modeling Guidance and the approved Computer Dispersion Modeling Protocol. [Minn. R. 7007.0100, subp. 7(A), 7(L),7(M), Minn. R. 7007.0800, subp. 2, Minn. R. 7007.3000, Minn. R. 7009.0020, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, TitleCondition: 40 CFR 52.21(k)]

TFAC0000000006 01700002

The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota AmbienAir Quality Standards, Minn. R. 7009.0010 to 7009.0080. Compliance shall be demonstrated upon written request by the MPCA. [Minn. R. 7007.0100, subp. 7(A), 7(L), & 7(M), Minn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1‐2, Minn. R. 7009.0010‐7009.0080, Minn. St116.07, subd. 4a, Minn. Stat. 116.07, subd. 9]

TFAC0000000006 01700002

Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or stateair pollution control rule, without reducing the total amount of pollutant emitted. [Minn. R. 7011.0020]

TFAC0000000006 01700002

Air Pollution Control Equipment: Operate all pollution control equipment required by the permit whenever the corresponding process equipment and emission units are operated. [Minn. R. 7007.0800, subp. 16(J), Minn. R. 7007.0800, subp. 2]

TFAC0000000006 01700002

Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipmenAt a minimum, the O & M plan shall identify all air pollution control equipment and control practices and shall include a preventative maintenance program for the equipment and practices, a description of (the minimum but not necessarily the only) corrective actions to btaken to restore the equipment and practices to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment and practices, and the records kept to demonstrate planimplementation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 16(J)]

TFAC0000000006 01700002

The O&M Plan shall include information for the following control equipment: TREA 6, TREA11, TREA12, TREA15‐21, TREA30, TREA31, and the IQS (EQUI49). At a minimum, the O&M Plan shall include, for each pollution control equipment: ‐ The parameters to be monitored andthe parameter ranges to be used; ‐ Corrective action procedures to be followed to return the control equipment to within specified range(‐ Corrective action procedures to be followed in the event of a malfunction or breakdown; and ‐ A description of inspection procedures to be followed; and records kept to demonstrate plan implementation. [Minn. R. 7007.0800, subp. 2]

TFAC0000000006 01700002

Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operationto reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. [Minn. R. 7019.1000, subp. 4]

TFAC0000000006 01700002

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. [Minn. R. 7011.0150]

TFAC0000000006 01700002

Noise: The Permittee shall comply with the noise standards set forth in Minn. R. 7030.0010 to 7030.0080 at all times during the operation any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. [Minn. R. 7030.0010‐7030.0080]

TFAC0000000006 01700002

Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R. 7007.0800, subp. 9(A). [Minn. R. 7007.0800, subp. 9(A)]

TFAC0000000006 01700002

The Permittee shall comply with the General Conditions listed in Minn. R. 7007.0800, subp. 16. [Minn. R. 7007.0800, subp. 16]

TFAC0000000006 01700002

Performance Testing: Conduct all performance tests in accordance with Minn. R. ch. 7017 unless otherwise noted in this permit. [Minn. R. ch. 7017]

TFAC0000000006 01700002

Performance Test Notifications and Submittals Performance Tests are due as outlined in this permit. Performance Test Notification (written): due 30 days before each Performance Tet Performance Test Plan: due 30 days before each Performance Test Performance Test Pre‐test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report ‐ Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may besubmitted in an alternative format as allowed by Minn. R. 7017.2018. [Minn. R. 7017.2018, Minn. R. 7017.2030, subps. 1‐4, Minn. R. 7017.2035, subps. 1‐2]

TFAC0000000006 01700002

Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance teon the same unit as specified by Minn. R. 7017.2025, subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7017.2025, subp. 3]

TFAC0000000006 01700002

Monitoring Equipment Calibration ‐ The Permittee shall either: 1. Calibrate or replace required monitoring equipment every 12 months; or2. Calibrate at the frequency stated in the manufacturer's specifications. For each monitor, the Permittee shall maintain a record of all calibrations, including the date conducted, and any corrective action that resulted. The Permittee shall include the calibration frequencies,procedures, and manufacturer's specifications (if applicable) in the Operations and Maintenance Plan. Any requirements applying to continuous emission monitors are listed separately in this permit. [Minn. R. 7007.0800, subp. 4(D)]

TFAC0000000006 01700002

Operation of Monitoring Equipment: Unless noted elsewhere in this permit, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. [Minn. R. 7007.0800, subp. 4(D)]

TFAC0000000006 01700002

Recordkeeping: Retain all records at the stationary source, unless otherwise specified within this permit, for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R. 7007.0800, subp. 5(A). [Minn. R. 7007.0800, subp. 5(C)]

TFAC0000000006 01700002

Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R. 7007.1250, subp. 3) or changes contravening permit terms (as required by Minn. R. 7007.1350, subp. 2), including records of the emissions resulting from those changes. [Minn. R. 7007.0800, subp. 5(B)]

TFAC0000000006 01700002

If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R. 7007.1200. For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. [Minn. R. 7007.1200, subp. 4]

TFAC0000000006 01700002

Recordkeeping: For each storage vessel as specified in 40 CFR 60.110b(a), the Permittee shall keep readily accessible records showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel. These records will be kept for the life of the source. [40 CFR 60.116b(a) and (b)]

TFAC0000000006 01700002

Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or processequipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not havadvance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 3. At the time of notification, theowner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. [Minn. R. 7019.1000, subp. 3]

TFAC0000000006 01700002

Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24‐hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R. 7019.1000, subp. 2. At the time of notification or asoon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. [Minn. R. 7019.1000, subp. 2]

TFAC0000000006 01700002

Notification of Deviations Endangering Human Health or the Environment: As soon as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. [Minn. R. 7019.1000, subp. 1]

TFAC0000000006 01700002

Notification of Deviations Endangering Human Health or the Environment Report: Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected; 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. [Minn. R. 7019.1000, subp. 1]

TFAC0000000006 01700002

The Permittee shall submit a semiannual deviations report : Due semiannually, by the 30th of January and July The first semiannual report submitted by the Permittee shall cover the calendar half‐year in which the permit is issued. The first report of each calendar year covers January 1 ‐ June 30. The second report of each calendar year covers July 1 ‐ December 31. If no deviations have occurred, the Permittee shsubmit the report stating no deviations. [Minn. R. 7007.0800, subp. 6(A)(2)]

TFAC0000000006 01700002

Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of MinnR. 7007.1150 through Minn. R. 7007.1500. Submittal dates vary, depending on the type of amendment needed. Upon adoption of a new oamended federal applicable requirement, and if there are more than 3 years remaining in the permit term, the Permittee shall file an application for an amendment within nine months of promulgation of the applicable requirement, pursuant to Minn. R. 7007.0400, subp. 3The preceding sentence does not apply if the effective date of the requirement is later than the date on which the permit is due to expire. [Minn. R. 7007.0400, subp. 3, Minn. R. 7007.1150 ‐ 7007.1500]

TFAC0000000006 01700002

Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 dayprovided the proposed deadline extension meets the requirements of Minn. R. 7007.1400, subp. 1(H). The Permittee may apply for an administrative amendment to extend a test deadline in a permit up to 365 days if the agency finds that the extension is needed to allow thPermittee to test at worst case conditions as required by Minn. R. 7017.2025, subp. 2, provided the proposed deadline extension meets threquirements of Minn. R. 7007.1400, subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 areexamples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R. 7007.1400, subp. 1(H). [Minn. R. 7007.1400, subp. 1(H)]

TFAC0000000006 01700002

The Permittee shall submit a compliance certification : Due annually, by the 31st of January (for the previous calendar year). The Permitteeshall submit this to the Commissioner on a form approved by the Commissioner. This report covers all deviations experienced during the calendar year. [Minn. R. 7007.0800, subp. 6(C)]

TFAC0000000006 01700002

The Permittee shall submit excess emission/downtime report : Due by 30 days after the end of each calendar quarter following permit issuance. Submit Deviations Reporting Form DRF‐1 as amended. The EER shall indicate all periods of monitor bypass and all periods of exceedances of the limit including exceedances allowed by an applicable standard, i.e. during startup, shutdown, and malfunctions. The EEmust be submitted even if there were no excess emissions, downtime or bypasses during the quarter. [40 CFR 60.7(c), Minn. R. 7017.1110,subp. 1‐2]

TFAC0000000006 01700002

Emission Inventory Report: due on or before April 1 of each calendar year following permit issuance, to be submitted on a form approved bthe Commissioner. [Minn. R. 7019.3000‐7019.3100]

TFAC0000000006 01700002

Emission Fees: due 30 days after receipt of an MPCA bill. [Minn. R. 7002.0005‐7002.0095]

TFAC0000000006 01700002

The Permittee is not required to submit a Risk Management Plan (RMP) under 40 CFR pt. 68; no regulated substances are present above ththreshold quantity. Each owner or operator of a stationary source, at which a regulated substance is present above a threshold quantity inprocess, shall design and implement an accidental release prevention program. An initial RMP must be submitted no later than the latest othe following dates: 1) June 21, 1999; 2) Three years after the date on which a regulated substance is first listed under 40 CFR Section 68.130; or 3) The date on which a regulated substance is first present above a threshold quantity in a process. A full update and resubmission of the RMP is required at least once every five years. The five‐year anniversary date is reset whenever the Permittee fully updates and resubmits their RMP. If required, RMPs shall be submitted to the Risk Management Plan Reporting Center, P.O. Box 1515, Lanham‐Seabrook, Maryland 20703‐1515. RMP information may be obtained at http://www.epa.gov/swercepp or by calling 1‐800‐424‐9346. [40 CFR pt. 68]

TFAC0000000006 01700002

For changes that do not require a permit amendment: ‐ The Permittee shall submit a Part 1 MACT application within 30 days of startup of any 112(j) affected source. The application shall meet the requirements of 40 CFR Section 63.53(a). ‐ The Permittee shall submit a Part 2 MACT application within 90 days of startup of any 112(j) affected source. The application shall meet the requirements of 40 CFR Section 63.53(b). 112(j) affected source is defined in 40 CFR Section 63.51. [40 CFR 63.52(b)(1), 40 CFR 63.52(e)(1)]

TFAC0000000006 01700002

This permit contains many of the requirements from 40 CFR pt. 63, subps. A, S, MM, JJJJ, and DDDDD. Some of the requirements may be paraphrased in this permit. If there is a conflict between a permit term and the regulation, then the regulation takes precedence. [Minn. R7007.0800, subp. 2]

TFAC0000000006 01700002

At all times the Permittee shall operate and maintain the emission unit subject to the MACT standard and its associated air pollution contrequipment in a manner consistent with good air pollution control practices for minimizing emissions to at least the levels required by all relevant standards.. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(e)(1)(i), Minn. R. 7011.7000]

TFAC0000000006 01700002

Startup, Shutdown, and Malfunction (SSM) plan: Develop a written plan as described in 40 CFR 63.6(e)(3) for each of the emission units subject to MACT standards that contains specific procedures for operating and maintaining the source during periods of SSM, and a prograof corrective action for process malfunction and control systems used to comply with the standards. The SSM Plan must be located at the plant site and must be kept updated. When the SSM Plan is updated, the Permittee must keep all previous versions of the SSM Plan for a period of 5 years. The Permittee must submit the SSM Plan when required. In addition, the plan must include the following requirements: Procedures to determine and record the cause of an operating parameter exceedance and the time the exceedance began and ended; ‐ Corrective actions to be taken in the event of an operating parameter exceedance, to correct the malfunctioning process as quickly as practicable, including procedures for recording the actions taken to correct the exceedance. ‐ A maintenance schedule for each control technique that is consistent with, but not limited to, the manufacturer's instructions and recommendations for routine and long‐term maintenance; and ‐ An inspection schedule for each CMS required under 40 CFR 63.864 to ensure, at least once in each 24‐hour period, thaeach CMS is properly functioning. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(e)(340 CFR 63.866(a), Minn. R. 7011.7000, Minn. R. 7011.7700]

TFAC0000000006 01700002

Malfunctions must be corrected as soon as practicable after their occurrence. To the extent that an unexpected event arises during a startup, shutdown, or malfunction, the Permittee must comply by minimizing emissions during such a startup, shutdown, and malfunction event consistent with safety and good air pollution control practices. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(e)(1)(ii), Minn. R. 7011.7000]

TFAC0000000006 01700002

The Permittee shall maintain files of all information required by this part in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. [40 CFR 63.10(b)(1), Minn. R. 7019.0100, sub2(B)]

TFAC0000000006 01700002

The Permittee shall maintain, at a minimum, the following information in the files, as applicable to each standard: 1. The occurrence and duration of each startup, shutdown, or malfunction of operation; 2. The occurrence and duration of each malfunction of the air pollution control equipment; 3. All maintenance performed on the pollution control equipment; 4. Actions taken during periods of startup, shutdowand malfunction when such actions are different from the procedures specified in the affected source's SSM Plan. In this case, the Permitteshall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5. All information necessary to demonstrate conformance with the affected source's SSM Plan and actions taken in accordance with SSM Plan; 6. Each periodduring which a Continuous Monitoring System (CMS) is malfunctioning or inoperative; 7. All required measurements needed to demonstracompliance with a relevant standard; 8. All results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9. All measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 1All CMS calibration checks; 11. All adjustments and maintenance performed on CMS; 12. Any information demonstrating whether a sourceis meeting the requirements for a waiver of record keeping or reporting requirements under this part; 13. All documents supporting initial notifications and notifications of compliance status. [40 CFR 63.10(b)(2), Minn. R. 7019.0100, subp. 2(B)]

TFAC0000000006 01700002

Startup, shutdown, and malfunction reports shall be submitted only if there is an occurrence of startup, shutdown, or malfunction during the reporting period and shall be delivered or postmarked by the 30th day following the end of each calendar half year. This requirement does not apply to equipment subject to 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.10(d)(5)(i), Minn. R. 7019.0100, subp. 2(B)]

TFAC0000000006 01700002

If the Permittee deviates from the startup, shutdown, and malfunction plan (SSM Plan) the Permittee shall record the actions taken for thaevent and report such actions within 2 working days after commencing actions inconsistent with the plan, followed by a letter within 7 working days after the end of the event. The report must contain name, title, and signature of a responsible official who is certifying its accuracy, explaining the circumstances of the event, the reasons for not following the SSM Plan, and whether any excess emissions and/orparameter monitoring exceedances are believed to have occurred. This requirement does not apply to equipment subject to 40 CFR pt. 63subp. DDDDD. [40 CFR 63.10(d)(5)(ii), 40 CFR 63.6(e)(3)(iv), Minn. R. 7011.7000, Minn. R. 7019.0100, subp. 2(B)]

TFAC0000000006 01700002

Prior to construction or reconstruction of an "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit. [40 CFR 63.5(b)(3), Minn. R. 7011.7000]

TFAC0000000006 01700002

MACT Requirements: This facility is subject to all pertinent requirements of the MACT, 40 CFR pt. 63, subp. S (NESHAPs from the Pulp and Paper Industry). [40 CFR pt. 63, subp. S, Minn. R. 7011.7700]

TFAC0000000006 01700002

Standards for Enclosures and Closed‐vent Systems: Each enclosure shall maintain negative pressure at each enclosure or hood opening as demonstrated by procedures specified in 40 CFR 63.457(e). Each enclosure or hood opening closed during the initial performance test specified in 40 CFR 63.457(a) shall be maintained in the same closed and sealed position as during the performance test at all times exceptwhen necessary to use the opening for sampling, inspection, maintenance, or repairs. Each component of the closed‐vent system used to comply with 40 CFR Sections 63.443(c) and 63.445(b) that is operated at positive pressure and located prior to a control device shall be designed for and operated with no detectable leaks as indicated by an instrument reading of less than 500 ppm by volume above background, as measured by the procedures in 40 CFR 63.457(d). Each bypass line in the closed‐vent system that could divert vent streamscontaining HAP to the atmosphere without meeting the emission limitations in 40 CFR Section 63.443 or 63.445 shall comply with either ofthe following requirements: 1. On each bypass line, the owner or operator shall install, calibrate, maintain and operate according to manufacturer's specifications, a flow indicator that provides a record of the presence of gas stream flow in the bypass line at least once every 15 minutes. The flow indicator shall be installed in the bypass line in such a way as to indicate flow in the bypass line; or 2. For bypasline valves that are not computer controlled, the owner or operator shall maintain the bypass line valve in the closed position with a car seor a seal placed on the valve or closure mechanism in such a way that the valve or closure mechanism cannot be opened without breaking the seal. [40 CFR 63.450(b), Minn. R. 7011.7700]

TFAC0000000006 01700002

Monitoring Requirements for Enclosure and Closed‐vent Systems: 1. For each enclosure opening, a visual inspection of the closure mechanism specified in 40 CFR 63.450(b) shall be performed at least once every month to ensure the opening is maintained in the closed position and sealed. 2. Each closed‐vent system required by 40 CFR 63.450(a) shall be visually inspected at least once every month with at least 21 days between inspections, and at other times as required by the Administrator. The visual inspection shall include inspection of ductwork, piping, enclosures and connections to covers for visible evidence of defects. 3. For positive pressure closed‐vent systems or portions of closed‐vent systems, demonstrate no detectable leaks as specified in 40 CFR 63.450(c) measured initially and annually by the procedures in 40 CFR 63.457(d). 4. Demonstrate initially and annually that each enclosure opening is maintained at negative pressure as specified in 40 CFR 63.457(e). 5. The valve or closure mechanism specified in 40 CFR 63.450(d)(2) shall be inspected at least once every month with at least 21 days between inspections, to ensure that the valve is maintained in the closed position and the emission point gas stream is not diverted through the bypass line. 6. If an inspection required by paragraphs 1 through 5 of this section identified visible defecin ductwork, piping or enclosure or connections to covers required by 40 CFR 63.450, or if an instrument reading of 500 ppm by volume or greater above background is measured, or if enclosure openings are not maintained at negative pressure, then the following corrective actions shall be taken as soon as practicable: i. A first effort to repair or correct the closed‐vent system shall be made as soon as practicablbut no later than 5 calendar days after the problem is identified. ii. The repair or corrective action shall be completed no later than 15 calendar days after the problem is identified. [40 CFR 63.453(k), Minn. R. 7011.7700]

TFAC0000000006 01700002

Site‐Specific Inspection Plan: The Permittee shall prepare and maintain a site‐specific inspection plan for each applicable enclosure openingclosed‐vent system, and closed collection system. The Plan shall include a drawing or schematic of the components of applicable affected equipment. The Permittee shall record the information described in 40 CFR 63.454(b) for each inspection. [40 CFR 63.454(b), Minn. R. 7011.7700]

TFAC0000000006 01700002

The Permittee must maintain records of any occurrence when corrective action is required under 40 CFR 63.864(k)(1), and when a violatiois noted under 40 CFR 63.864(k)(2). [40 CFR 63.866(b), Minn. R. 7011.7700]

TFAC0000000006 01700002

In addition to the general records required by 40 CFR 63.10(b)(2), maintain records of the following information: ‐ Records of dry virgin blaliquor solids firing rates in units of tons/day for all recovery furnaces; ‐ Records and documentation of supporting calculations for compliance determinations made under 40 CFR 63.865(a)‐(d); ‐ Records of monitoring parameter ranges established for each process unit.[40 CFR 63.866(c), Minn. R. 7011.7700]

TFAC0000000006 01700002

The owner or operator of any affected source or process unit must submit the applicable notifications from 40 CFR pt. 63 subp. A, as specified in Table 1 of 40 CFR pt. 63 subp. MM. [40 CFR 63.867(a), Minn. R. 7011.7700]

TFAC0000000006 01700002

Excess emissions report: submit a report quarterly if measured parameters meet any of the conditions specified in 40 CFR 63.864(k)(1) or (2). The report must contain the information specified in 40 CFR 63.10(c), as well as the number and duration of occurrences when the conditions in in 40 CFR 63.864(k)(1) or (2) were met or exceeded. Reporting excess emissions below the violation thresholds of 40 CFR 63.864(k) does not constitute a violation of the applicable standard. When no exceedances of parameters have occurred, submit a semiannual report stating that no excess emissions occurred during the reporting period. Excess emissions and/or summary reports for themill for requirements of subpart MM or subpart S may be combined into one report. [40 CFR 63.867(c), Minn. R. 7011.7700]

TFAC0000000006 01700002

The Permittee shall not have engines that meet section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section 1068.30 in one location within the stationary source for more than 12 consecutive months. A location is any single site at a building, structure, facility, or installation. Any engine, or engines, that replaces an engine at a location and that is intended to perform the same or similar function as thengine it replaced will be included in calculating the consecutive time period. [40 CFR 1068.30]

TFAC0000000006 01700002

For a nonroad engine that is excluded from any requirements of 40 CFR Part 1068 because it is a stationary engine, the Permittee may not move it or install it in any mobile equipment, except as allowed by the provisions of 40 CFR Part 1068. The Permittee may not circumvent oattempt to circumvent the residence‐time requirements of Section (2)(iii) of the Nonroad Engine definition at 40 CFR Section 1068.30. [40 CFR 1068.101(b)(3)]

TFAC0000000006 01700002

The Permittee shall keep records of all engines on‐site that meet section (1)(iii) under the definition of Nonroad Engine at 40 CFR Section 1068.30. This applies to nonroad engines that are owned by the Permittee, or rented and operated by the Permittee, or brought onsite andoperated by a vendor or contractor. The records shall include the following: 1) Date that the nonroad engine is brought onsite 2) Date thatthe nonroad engine is taken offsite and/or moved to a different location. 3) Identification number. 4) Rated capacity of the nonroad engine5) The model year and date of manufacture (as defined by the applicable nonroad engine rule). 6) Which nonroad provision that the nonroad engine is certified under. 7) Rental company information. 8) Function of the nonroad engine (e.g. compressor, welder). 9) Locatioof the engine within the stationary source. 10) Statement that the nonroad engine has not been located in a single location for 12 consecutive months, and movement between locations has not been for purposes of circumvention of residence time requirements of section (2)(iii) under the definition of Nonroad Engine at 40 CFR Section 1068.30. [40 CFR 1068.30(nonrd engn)(1)(iii), Minn. R. 7007.0800, subps. 4‐5]

TFAC0000000006 01700002

A nonroad engine ceases to be a nonroad engine and becomes a new stationary engine if: 1. At any time, it meets the criteria specified in section (2)(iii) under the definition of Nonroad Engine in 40 CFR Section 1068.30. For example, a portable generator engine ceases to be a nonroad engine if it is used or will be used in a single specific location for 12 months or longer. If the Administrator or the Permitting authority determines that an engine will be or has been used in a single specific location for 12 months or longer, it ceased to be a nonroadengine when it was placed in that location. OR 2. It is otherwise regulated by a federal New Source Performance Standard promulgated under section 111 of the Clean Air Act (42 U.S.C. 7411). [40 CFR 1068.31(e)]

COMG0000000001 GP008

All requirements under this subject item apply to EQUI 2 and EQUI 4 (Power Boilers #7 and #9) only, unless otherwise noted in the requirement below. See Subject Items EQUI 2, EQUI 4, and EQUI 18 for additional requirements. [Minn. R. 7007.0800, subp. 2]

COMG0000000001 GP008

Fuel burned: limited to following fuel types: wood (including railroad ties); mill waste (including knots and screen rejects, CDF (combustiblederived fuel, which consists of office paper, cardboard, scrap pallets, scrap lumber, press trials prints, waste lap pulp or other non‐food product wood‐based wastes generated at the Cloquet mill), and bark, peat and/or sawdust used to clean up oil and chemical spills); fuel oinatural gas; and wastewater treatment plant sludge. Non‐condensible gas (NCG) is also burned in Power Boilers #7 and #9. [Title I Conditio40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

COMG0000000001 GP008

Fuel Usage <= 500000 tons per year 12‐month rolling sum, on a wet basis (WOOD AND MILL WASTE USAGE LIMIT). The wood and mill wastusage limit includes railroad ties, CDF, knots and screen rejects and bark, peat and/or sawdust used to soak up oil and chemical spills. [TitleCondition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

COMG0000000001 GP008

Fuel Usage <= 4.0 million gallons per year 12‐month rolling sum (#2 FUEL OIL USAGE LIMIT). The limit for #2 fuel oil is 4,000,000 gallons/yefor a combined basis for #7, #8, and #9 boilers (EQUI2, EQUI18, and EQUI4) on a 12‐month rolling sum basis. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

COMG0000000001 GP008

Sulfur Content of Fuel <= 0.05 percent by weight for #2 fuel oil. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

COMG0000000001 GP008

Fuel Usage <= 38220 tons per year 12‐month rolling sum on a dry basis (WASTEWATER TREATMENT PLANT SLUDGE USAGE LIMIT). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

COMG0000000001 GP008

Vendor Certifications: For all fuel oil burned in Power Boiler #7 (EQUI2) and Power Boiler #9 (EQUI4), maintain oil vendor information on sithat documents oil sulfur content in percent by weight, to verify that the fuel oil sulfur content limit of 0.05% is being met. Copies of the sulfur content certification or analysis shall be obtained from the vendor for each delivery of fuel oil and must give the sulfur content of thfuel oil. This information shall be maintained on site. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2)& Minn. R. 7007.3000]

COMG0000000001 GP008

Recordkeeping: By the 15th day of each month, record the wood and mill waste (including railroad ties, knots and screen rejects, bark, peaand/or sawdust used to soak up oil and chemical spills) usage for the previous month, and the previous 12 months (12‐month rolling sum).[Minn. R. 7007.0800, subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

COMG0000000001 GP008

Recordkeeping: By the 15th day of each month, record the fuel oil usage for the previous month and the previous 12 months (12‐month rolling sum). [Minn. R. 7007.0800, subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 4CFR 52.21(b)(2) & Minn. R. 7007.3000]

COMG0000000001 GP008

Recordkeeping: By the 15th day of each month, record the sludge usage for the previous month and the previous 12 months (12‐month rolling sum). [Minn. R. 7007.0800, subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 4CFR 52.21(b)(2) & Minn. R. 7007.3000]

COMG0000000002 GP003

HAPs ‐ Total <= 20 parts per million by volume, corrected to 10% oxygen on a dry basis. [40 CFR 63.443(a)(1)(i), 40 CFR 63.443(d)(2), Minn. 7011.7700]

COMG0000000002 GP003

HAP Control: Gases from the LVHC, HVLC, and Stripper Off Gas systems shall be combusted in the Incinerator‐Quencher‐Scrubber (IQS), or Boiler #7 or #9 as backup. When gases are burned in the IQS, the Total HAPs limit applies, and the temperature of the IQS is to be monitoreas described under TREA 30 (Incinerator for TRS on IQS). When the gases are burned in the backup (Boilers #7 or #9), the HAP emission stream shall be introduced with the primary fuel or into the flame zone. [40 CFR 63.443(a)(1)(i), 40 CFR 63.443(d)(2), Minn. R. 7011.7700]

COMG0000000002 GP003

Enclosures and Venting: All equipment listed in this group shall be enclosed and vented into a closed‐vent system meeting the requiremenspecified in 40 CFR Section 63.450 and as described in the Total Facility subject item. [40 CFR 63.443(c), 40 CFR 63.450, Minn. R. 7011.7700

COMG0000000002 GP003

TRS Control: Gases from the NCG sources shall be combusted in the IQS (EQUI49), or power boilers #7 and #9 as backup, and shall be subjected to a minimum temperature of 1200 degrees Fahrenheit for at least 0.5 second. This requirement always applies, but is generallyless stringent than the MACT requirement (40 CFR 63.443) which also applies. [40 CFR 60.283(a)(1)(iii), Minn. R. 7007.0800, subp. 2, Minn. 7011.2450]

COMG0000000002 GP003

The Permittee is not subject to 40 CFR Section 60.284(b)(1) or 40 CFR Section 60.284(d)(3)(ii) and is protected by the permit shield provisioof Minn. R. 7007.1800 from any expectation to comply with these requirements. The requirement to continuously monitor and record the combustion temperature in the power boilers does not apply since #7 and #9 power boilers (EQUI2 and EQUI4) used to combust the NCG gases are not incinerators, because according to the fourth revision to NSPS Subpart BB, EPA "...deletes the requirement to monitor the combustion (51 FR 18538) temperature in lime kilns, power boilers, or recovery furnaces." In addition, since continuous monitoring is not required, the facility is not required to submit semi‐annual excess emissions reports to EPA for periods in excess of 5 minutes and their duration which the combustion temperature at the point of incineration is less than 1200 degrees Fahrenheit. [40 CFR 60.284(b)(1), 40 CFR60.284(d)(3)(ii), Minn. R. 7007.1800(A)(2), Minn. R. 7011.2450]

COMG0000000003 GP004

Pulping Process Condensates: Pulping process condensates as listed in 40 CFR Section 63.446(b) shall be conveyed in a closed collection system that is designed and operated to meet the requirements specified in 40 CFR Section 63.446(d)(1)‐(2). [40 CFR 63.446(d), Minn. R. 7011.7700]

COMG0000000003 GP004

HAPs ‐ Total >= 11.1 pounds per ton of ODP of pulping process condensates from equipment systems listed in 40 CFR Section 63.446(b)(1)‐(b)(5) shall be collected. [40 CFR 63.446(c)(3), Minn. R. 7011.7700]

COMG0000000003 GP004

The Permittee shall reduce HAPs ‐ Total >= 92 percent by weight. The pulping process condensates shall be: ‐ Treated to reduce or destroy the total HAPs by 92% or more by weight; or ‐ Recycled to an equipment system specified in 40 CFR Section 63.442(a); or ‐ Treated by removing 10.2 lbs/ton of ODP or achieving a total HAP concentration of 330 ppm or less by weight at the outlet of the control device. [40 CFR 63.446(e), Minn. R. 7011.7700]

COMG0000000003 GP004

Monitoring: Permittee shall install, calibrate, certify, operate, and maintain continuous monitoring systems as required by 40 CFR Section 63.453. [40 CFR 63.453, Minn. R. 7011.7700]

COMG0000000007 GP015

COMG 7 contains requirements from 40 CFR pt. 63, subp. DDDDD that apply to all the emission units subject to DDDDD: EQUI 2 (Power Boiler #7), EQUI 4 (Power Boiler #9), EQUI 18 (Power Boiler #8), and EQUI 290 (R&D Boiler). Further requirements that apply specifically toeach boiler can be found at the EQUI level. [Minn. R. 7007.0800, subp. 2]

COMG0000000007 GP015

40 CFR pt. 63 General Provisions: 40 CFR pt. 63, subp. DDDDD, Table 10 shows which parts of the General Provisions in 40 CFR Sections 63.63.15 apply. [40 CFR 63.7565, Minn. R. 7011.7050]

COMG0000000007 GP015

At all times, the Permittee must operate and maintain any affected source (as defined in 40 CFR Section 63.7490), including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on informationavailable to the Administrator that may include, but is not limited to, monitoring results, review of operation and maintenance proceduresreview of operation and maintenance records, and inspection of the source. [40 CFR 63.7500(a)(3), Minn. R. 7011.7050]

COMG0000000007 GP015

General Compliance Requirements. The Permittee must be in compliance with the emission limits, work practice standards, and operating limits in 40 CFR pt. 63, subp. DDDDD. These limits apply at all times the affected unit is operating, except during periods of startup and shutdown during which time the Permittee must comply only with 40 CFR pt. 63, subp. DDDDD, Table 3. [40 CFR 63.7500(f), 40 CFR 63.7505(a), Minn. R. 7011.7050]

COMG0000000007 GP015

General Compliance Requirements. The Permittee must demonstrate compliance with all applicable emission limits using performance statesting, fuel analysis, or CMS, including a CEMS, COMS, CPMS, or PM CPMS, where applicable. The Permittee may demonstrate compliancewith the applicable emission limit for HCl, mercury, or TSM using fuel analysis if the emission rate calculated according to 40 CFR Section 63.7530(c) is less than the applicable emission limit. (For gaseous fuels, the Permittee may not use fuel analyses to comply with the TSM alternative standard or the HCl standard.) Otherwise, the Permittee must demonstrate compliance for HCl, mercury, or TSM using performance testing, if subject to an applicable emission limit listed in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR 63.7505(c), Minn. R. 7011.7050]

COMG0000000007 GP015

General Compliance Requirements ‐ Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, orprocess to conceal an emission that would otherwise constitute noncompliance with 40 CFR pt. 63, subp. DDDDD. Such concealment includes, but is not limited to: ‐ the use of diluents to achieve compliance with 40 CFR pt. 63, subp. DDDDD based on the concentration of apollutant in the effluent discharged to the atmosphere; or ‐ the use of gaseous diluents to achieve compliance with 40 CFR pt. 63, subp. DDDDD for visible emissions. [40 CFR 63.4(b), Minn. R. 7011.7000]

COMG0000000007 GP015

General Compliance Requirements. Methods for determining compliance will be, in part, based on the results of performance tests, conformance with operation and maintenance requirements, review of records, and inspection of the source as specified in 40 CFR Section63.6(f)(2). The Permittee many use the results of performance testing conducted previously if it meets the requirements of 40 CFR Section63.6(f)(2)(iii). [40 CFR 63.6(f)(2), Minn. R. 7011.7000]

COMG0000000007 GP015

Finding of Compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with a non‐opacity emission standard upon obtaining all the compliance information required by 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.6(f)(3), MinnR. 7011.7000]

COMG0000000007 GP015

Finding of Compliance. The Commissioner or the Administrator will make a finding concerning an affected source's compliance with an opacity or visible emission standard upon obtaining all the compliance information required by 40 CFR pt. 63, subp. DDDDD and any information available needed to determine whether proper operation and maintenance practices are being used. [40 CFR 63.6(h)(8), MinnR. 7011.7000]

COMG0000000007 GP015

If the Commissioner or the Administrator finds that the affected source is in compliance with all relevant standards for which initial performance tests were conducted, but during the time such performance tests were conducted fails to meet any relevant opacity emissiostandard, the Permittee may petition the Administrator to make appropriate adjustment to the opacity emission standard for the affectedsource. Until the Administrator notifies the Permittee, the relevant opacity emission standard remains applicable. [40 CFR 63.6(h)(9), MinnR. 7011.7000]

COMG0000000007 GP015

The Permittee may establish the use of an alternative non‐opacity emission standard by following the procedure specified in 40 CFR Sectio63.6(g). [40 CFR 63.6(g), Minn. R. 7011.7000]

COMG0000000007 GP015

Methods for Determining Compliance. Compliance with opacity emission standards shall be determined by using the results from the COM[40 CFR 63.6(h)(2), Minn. R. 7011.7000]

COMG0000000007 GP015

The Administrator may grant an extension of compliance with an emission standard, as specified in 40 CFR Section 63.6(i). [40 CFR 63.6(i), Minn. R. 7011.7000]

COMG0000000007 GP015

Until an extension of compliance has been granted by the Administrator, the Permittee shall comply with all applicable requirements of 40CFR pt. 63, subp. A. [40 CFR 63.6(i)(1), Minn. R. 7011.7000]

COMG0000000007 GP015

The Permittee must meet the work practice standard according to 40 CFR pt. 63, subp. DDDDD, Table 3. During startup and shutdown, the Permittee must only follow the work practice standards according to 40 CFR pt. 63, subp. DDDDD, Table 3, Items 5 and 6. [40 CFR 63.7530(h), Minn. R. 7011.7050]

COMG0000000007 GP015

For each boiler that is required or that the Permittee elects to demonstrate compliance with any of the applicable emission limits in 40 CFRpt. 63, subp. DDDDD, Table 2 through performance testing, the initial compliance requirements include all the following: ‐ Conduct performance tests according to 40 CFR Section 63.7520 and 40 CFR pt. 63, subp. DDDDD, Table 5. ‐ Conduct a fuel analysis for each type offuel burned in the boiler according to 40 CFR Section 63.7521 and 40 CFR pt. 63, subp. DDDDD, Table 6, except as specified in 40 CFR Sectio63.7510(a)(2)(i)‐(iii). ‐ Establish operating limits according to 40 CFR Section 63.7530 and 40 CFR pt. 63, subp. DDDDD, Table 7. ‐ Conduct CMS performance evaluations according to 40 CFR Section 63.7525. [40 CFR 63.7510(a), Minn. R. 7011.7050]

COMG0000000007 GP015

For existing affected sources (as defined in 40 CFR Section 63.7490) that have not operated between the effective date of 40 CFR pt. 63, subp. DDDDD and January 31, 2016, the Permittee must complete an initial tune‐up by following the procedures described in 40 CFR Sectio63.7540(a)(10)(i)‐(vi) no later than 30 days after the re‐start of the affected source and complete the one‐time energy assessment specifiedin 40 CFR pt. 63, subp. DDDDD, Table 3, no later than the compliance date specified in 40 CFR Section 63.7495. [40 CFR 63.7510(j), Minn. R7011.7050]

COMG0000000007 GP015

Following the date on which the initial compliance demonstration is completed or is required to be completed under 40 CFR Sections 63.7 and 63.7510, whichever date comes first, operation above the established maximum or below the established minimum operating limits shall constitute a deviation of established operating limits listed in 40 CFR pt. 63, subp. DDDDD, Table 4 except during performance tests conducted to determine compliance with the emission limits or to establish new operating limits. Operating limits must be confirmed or reestablished during performance tests. [40 CFR 63.7540(a)(1), Minn. R. 7011.7050]

COMG0000000007 GP015

The Permittee must report each instance in which the Permittee did not meet each emission limit and operating limit in 40 CFR pt. 63, subDDDDD, Tables 2‐4 that apply. These instances are deviations from the emission limits or operating limits, respectively, in 40 CFR pt. 63, subp. DDDDD. These deviations must be reported according to the requirements in 40 CFR Section 63.7550. [40 CFR 63.7540(b), Minn. R. 7011.7050]

COMG0000000007 GP015

The Permittee 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 Section 63.7530 and 40 CFR pt. 63, subp. DDDDD, Table 7, as applicable. The reporfor all subsequent performance tests must include all applicable information required in 40 CFR Section 63.7550. [40 CFR 63.7515(f), MinnR. 7011.7050]

COMG0000000007 GP015

For affected sources that have not operated since the previous compliance demonstration and more than one year has passed since the previous compliance demonstration, you must complete the subsequent compliance demonstration, if subject to the emission limits in 40 CFR pt. 63, subp. DDDDD, Table 2, no later than 180 days after the re‐start of the affected source and according to the applicable provisionin 40 CFR Section 63.7(a)(2) as cited in 40 CFR pt. 63, subp. DDDDD, Table 10. The Permittee must complete a subsequent tune‐up by following the procedures described in 40 CFR Section 63.7540(a)(10)(i)‐(vi) and the schedule described in 40 CFR Section 63.7540(a)(13) founits that are not operating at the time of their scheduled tune‐up. [40 CFR 63.7515(g), Minn. R. 7011.7050]

COMG0000000007 GP015

The Permittee must conduct tune‐ups of boilers demonstrate compliance as specified below: ‐ As applicable, inspect the burner, and cleanor replace any components of the burner as necessary (the Permittee may delay the burner inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months from theprevious inspection. At units where entry into a piece of process equipment or into a storage vessel is required to complete the tune‐up inspections, inspections are required only during planned entries into the storage vessel or process equipment; ‐ Inspect the flame patternas applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available; ‐ Inspect the system controlling the air‐to‐fuel ratio, as applicable, and ensure that it is correctlycalibrated and functioning properly (the Permittee may delay the inspection until the next scheduled unit shutdown). Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 36 months from the previous inspection; ‐ Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any NOx requirementto which the unit is subject; ‐ Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volumpercent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. [40 CFR 63.7540(a)(10)(i)‐(v), MinR. 7011.7050]

COMG0000000007 GP015

Maintain on‐site and submit, if requested by the Administrator, a report containing the information below: ‐ The concentrations of CO in theffluent stream in parts per million by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune‐up of the boiler; ‐ A description of any corrective actions taken as a part of the tune‐up; and ‐ The type and amount of fuel used over the 12 months prior to the tune‐up, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel used by each unit. [40 CFR 63.7540(a)(10)(vi), Minn. R. 7011.7050]

COMG0000000007 GP015

Stack Tests and Procedures. The Permittee must conduct all performance tests according to 40 CFR Section 63.7(c), (d), (f), and (h). The Permittee must also develop a Site‐Specific Test Plan according to the requirements in 40 CFR Section 63.7(c). The Permittee shall conduct all performance tests under such conditions as the Administrator specifies based on the representative performance of each boiler for the period being tested. Upon request, the Permittee shall make available to the Administrator such records as may be necessary to determinethe conditions of the performance tests. [40 CFR 63.7520(a), Minn. R. 7011.7050]

COMG0000000007 GP015

Stack Tests and Procedures. The Permittee must conduct each performance test according to the requirements in 40 CFR pt. 63, subp. DDDDD, Table 5. [40 CFR 63.7520(b), Minn. R. 7011.7050]

COMG0000000007 GP015

Stack Tests and Procedures. The Permittee must conduct each performance test under the specific conditions listed in 40 CFR pt. 63, subp.DDDDD, Tables 5 and 7. The Permittee must conduct performance tests at representative operating load conditions while burning the typeof fuel or mixture of fuels that has the highest content of chlorine and mercury and the Permittee must demonstrate initial compliance andestablish 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, the Permittee must comply with the operating limfor operating load conditions specified in 40 CFR pt. 63, subp. DDDDD, Table 4. [40 CFR 63.7520(c), Minn. R. 7011.7050]

COMG0000000007 GP015

Stack Tests and Procedures. The Permittee must conduct a minimum of three separate test runs for each performance test required in 40 CFR Section 63.7520, as specified in 40 CFR Section 63.7(e)(3). Each test run must comply with the minimum applicable sampling times or volumes specified in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR 63.7520(d), Minn. R. 7011.7050]

COMG0000000007 GP015

Stack Tests and Procedures. To determine compliance with the emission limits, the Permittee must use the F‐Factor methodology and equations in Sections 12.2 and 12.3 of EPA Reference Method 19 to convert the measured PM concentrations that result from the performance test to pounds per million Btu heat input emission rates. [40 CFR 63.7520(e), Minn. R. 7011.7050]

COMG0000000007 GP015

Stack Tests and Procedures. Except for a 30‐day rolling average based on CEMS data, if measurement results for any pollutant are reportedas below the method detection level, the Permittee must use the method detection level as the measured emissions level for that pollutanin calculating compliance. The measured result for a multiple component analysis may include a combination of method detection level daand analytical data reported above the method detection level. [40 CFR 63.7520(f), Minn. R. 7011.7050]

COMG0000000007 GP015

Stack Tests and Procedures. To conduct a performance test for filterable PM, the Permittee must collect a minimum of 2 dry standard cubimeters of sample gas per run. [40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

COMG0000000007 GP015

Stack Tests and Procedures. To conduct a performance test for filterable PM, the Permittee must: ‐ Select sampling ports location and the number of traverse points using Method 1 at 40 CFR pt. 60, Appendix A‐1; ‐ Determine velocity and volumetric flow‐rate of the stack gas using Method 2, 2F, or 2G at 40 CFR pt. 60, Appendix A‐1 or A‐2; ‐ Determine oxygen or carbon dioxide concentration of the stack gas usingMethod 3A or 3B at 40 CFR pt. 60, Appendix A‐2, or ANSI/ASME PTC 19.10‐1981; ‐ Measure the moisture content of the stack gas using Method 4 at 40 CFR pt. 60, Appendix A‐3; ‐ Measure the PM emission concentration using Method 5 or 17 at 40 CFR pt. 60, Appendix A‐3 oA‐6; and ‐ Convert emissions concentration to lb per MMBtu emission rates using Method 19 F‐factor methodology at 40 CFR pt. 60, Appendix A‐7. [40 CFR pt. 63, subp. DDDDD(Table 5), Minn. R. 7011.7050]

COMG0000000007 GP015

Site‐Specific Test Plan. Before conducting a required performance test, the Permittee shall develop and, if requested by the Commissioner or the Administrator, shall submit a Site‐Specific Test Plan for approval in accordance with the requirements of 40 CFR Section 63.7(c)(2). [4CFR 63.7(c)(2), Minn. R. 7017.2015]

COMG0000000007 GP015

Site‐Specific Test Plan. The Administrator will notify the Permittee of approval or intention to deny approval of the Site‐Specific Test Plan (ireview of the Site‐Specific Test Plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days aftereceipt of any supplementary information. [40 CFR 63.7(c)(3), Minn. R. 7017.2015]

COMG0000000007 GP015

Performance Testing Facilities. The Permittee, at the request of the Commissioner or the Administrator, shall provide performance testing facilities as specified in 40 CFR Section 63.7(d). [40 CFR 63.7(d), Minn. R. 7017.2015]

COMG0000000007 GP015

Conduct of Performance Tests. Performance tests shall be conducted and data shall be reduced in accordance with the test methods and procedures set forth in 40 CFR Section 63.7(e), in 40 CFR pt. 63, subp. DDDDD, and, if required, in applicable appendices of 40 CFR parts 5160, 61. The Commissioner has delegation to approve a minor or intermediate modification (if validated by Method 301) to a reference method or specified monitoring procedure as allowed for in 40 CFR Section 63.7(e)(2)(i) and (ii). [40 CFR 63.7(e)(2), Minn. R. 7017.2015]

COMG0000000007 GP015

Conduct of Performance Tests. Unless otherwise specified in 40 CFR pt. 63, subp. DDDDD or test method, each performance test shall consist of three separate runs using the applicable test method. Each run shall be conducted for the time and under the conditions specifiein 40 CFR pt. 63, subp. DDDDD. For the purpose of determining compliance with 40 CFR pt. 63, subp. DDDDD, the arithmetic mean of the results of the three runs shall apply, unless otherwise approved in accordance with provisions of 40 CFR Section 63.7(e)(3). [40 CFR 63.7(e)(3), Minn. R. 7017.2015]

COMG0000000007 GP015

Data Analysis, Recordkeeping, and Reporting. Unless otherwise specified in 40 CFR pt. 63, subp. DDDDD or test method, or as otherwise approved by the Commissioner or Administrator in writing, results of a performance test shall include the analysis of samples, determination of emissions, and raw data. A performance test is "completed" when field sample collection is terminated. The Permittee shall report the results of the performance test to the Commissioner or Administrator before the close of business on the 60th day followinthe completion of the performance test, unless specified otherwise in 40 CFR pt. 63, subp. DDDDD or as approved otherwise in writing. Theresults of the performance test shall be submitted as part of the notification of compliance status required under 40 CFR Section 63.9(h) tothe appropriate permitting authority. [40 CFR 63.7(g), Minn. R. 7017.2015]

COMG0000000007 GP015

Waiver of Performance Tests. Until a waiver of a performance testing requirement has been granted by the Commissioner or the Administrator under 40 CFR Section 63.7(h), the Permittee remains subject to the requirements of 40 CFR Section 63.7(h). [40 CFR 63.7(h),Minn. R. 7017.2015]

COMG0000000007 GP015

Conduct of Opacity or Visible Emission Observations. For initial compliance, opacity or visible emission observations shall be conducted concurrently with the initial performance test unless otherwise specified in 40 CFR Section 63.6(h)(5)(A) and (B). [40 CFR 63.6(h)(5), Minn. 7011.7000]

COMG0000000007 GP015

General Fuel Analysis Requirements. The Permittee must conduct fuel analyses for chloride and mercury according to the procedures in 40CFR Section 63.7521(b)‐(e) and 40 CFR pt. 63, subp. DDDDD, Table 6, as applicable. The Permittee is not required to conduct fuel analyses for fuels used for only startup, unit shutdown, and transient flame stability purposes. The Permittee is required to conduct fuel analyses onfor fuels and units that are subject to emission limits for mercury or HCl in 40 CFR pt. 63, subp. DDDDD, Table 2. Gaseous and liquid fuels aexempt from the sampling requirements in 40 CFR Section 63.7521(c) and (d) and 40 CFR pt. 63, subp. DDDDD, Table 6. [40 CFR 63.7521(a)Minn. R. 7011.7050]

COMG0000000007 GP015

Site‐Specific Fuel Monitoring Plan. The Permittee must develop a Site‐Specific Fuel Monitoring Plan according to the procedures and requirements in 40 CFR Section 63.7521(b)(1) and (2). [40 CFR 63.7521(b), Minn. R. 7011.7050]

COMG0000000007 GP015

Site‐Specific Fuel Monitoring Plan. If the Permittee intends to use an alternative analytical method other than those required by 40 CFR pt.63, subp. DDDDD, Table 6, the Permittee must submit the fuel analysis plan to the Administrator for review and approval no later than 60 days before the date that the Permittee intends to conduct the initial compliance demonstration described in 40 CFR Section 63.7510. [40 CFR 63.7521(b)(1), Minn. R. 7011.7050]

COMG0000000007 GP015

Site‐Specific Fuel Monitoring Plan. The Permittee must include the information below in the fuel analysis plan. ‐ The identification of all fuetypes anticipated to be burned in each boiler; ‐ For each anticipated fuel type, the notification of whether the Permittee or a fuel supplier will be conducting the fuel analysis; ‐ For each anticipated fuel type, a detailed description of the sample location and specific procedures tbe used for collecting and preparing the composite samples if the procedures are different from 40 CFR Section 63.7521(c) or (d). Samples should be collected at a location that most accurately represents the fuel type, where possible, at a point prior to mixing with other dissimilar fuel types; ‐ For each anticipated fuel type, the analytical methods from 40 CFR pt. 63, subp. DDDDD, Table 6, with the expected minimum detection levels, to be used for the measurement of chlorine or mercury; ‐ If the Permittee requests to use an alternative analytical method other than those required by 40 CFR pt. 63, subp. DDDDD, Table 6, the Permittee must also include a detailed descriptioof the methods and procedures that the Permittee is proposing to use. Methods in 40 CFR pt. 63, subp. DDDDD, Table 6 shall be used untilthe requested alternative is approved; and ‐ If the Permittee will be using fuel analysis from a fuel supplier in lieu of site‐specific sampling and analysis, the fuel supplier must use the analytical methods required by 40 CFR pt. 63, subp. DDDDD, Table 6. [40 CFR 63.7521(b)(2), Minn. R. 7011.7050]

COMG0000000007 GP015

Fuel Analysis Procedure. At a minimum, the Permittee must obtain three composite fuel samples for each fuel type according to the procedures in 40 CFR Section 63.7521(c)(1) or (2), or the methods listed in 40 CFR pt. 63, subp. DDDDD, Table 6, or use an automated sampling mechanism that provides representative composite fuel samples for each fuel type that includes both coarse and fine material. [4CFR 63.7521(c), Minn. R. 7011.7050]

COMG0000000007 GP015

Fuel Analysis Procedure. If sampling from a belt (or screw) feeder, the Permittee must collect fuel samples according to the requirements below. ‐ Stop the belt and withdraw a 6‐inch wide sample from the full cross‐section of the stopped belt to obtain a minimum two pounds sample. The Permittee must collect all the material (fines and coarse) in the full cross‐section. The Permittee must transfer the sample to aclean plastic bag. ‐ Each composite sample will consist of a minimum of three samples collected at approximately equal one‐hour intervals during the testing period for sampling during performance stack testing. For monthly sampling, each composite sample shall be collected aapproximately equal 10‐day intervals during the month. [40 CFR 63.7521(c)(1), Minn. R. 7011.7050]

COMG0000000007 GP015

Fuel Analysis Procedure. If sampling from a fuel pile or truck, the Permittee must collect fuel samples according to the requirements belowFor each composite sample, the Permittee must select a minimum of five sampling locations uniformly spaced over the surface of the pile.At each sampling site, the Permittee must dig into the pile to a uniform depth of approximately 18 inches. The Permittee must insert a cleashovel into the hole and withdraw a sample, making sure that large pieces do not fall off during sampling; use the same shovel to collect alsamples. ‐ The Permittee must transfer all samples to a clean plastic bag for further processing. [40 CFR 63.7521(c)(2), Minn. R. 7011.7050]

COMG0000000007 GP015

Fuel Analysis Procedure. The Permittee must prepare each composite sample according to the procedures below. ‐ The Permittee must thoroughly mix and pour the entire composite sample over a clean plastic sheet; ‐ The Permittee must break large sample pieces (e.g., largthan 3 inches) into smaller sizes; ‐ The Permittee must make a pie shape with the entire composite sample and subdivide it into four equal parts; ‐ The Permittee must separate one of the quarter samples as the first subset; ‐ If this subset is too large for grinding, the Permittee must repeat the procedure in 40 CFR Section 63.7521(d)(3) with the quarter sample and obtain a one‐quarter subset from this sample; ‐ ThPermittee must grind the sample in a mill; and ‐ The Permittee must use the procedure in 40 CFR Section 63.7521(d)(3) to obtain a one‐quarter subsample for analysis. If the quarter sample is too large, subdivide it further using the same procedure. [40 CFR 63.7521(d), MinnR. 7011.7050]

COMG0000000007 GP015

Fuel Analysis Procedure. The Permittee must determine the concentration of pollutants in the fuel (mercury and/or chlorine) in units of pounds per million Btu of each composite sample for each fuel type according to the procedures in 40 CFR pt. 63, subp. DDDDD, Table 6, fouse in Equations 7, 8, and 9 of 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.7521(e), Minn. R. 7011.7050]

COMG0000000007 GP015

Mercury Fuel Analysis. To conduct a fuel analysis for mercury, the Permittee must: ‐ Collect fuel samples using the procedure in 40 CFR Section 63.7521(c) or ASTM D5192, or ASTM D7430, or ASTM D6883, or ASTM D2234/D2234M (for coal) or EPA 1631 or EPA 1631E or ASTD6323 (for solid), or EPA 821‐R‐01‐013 (for liquid or solid), or ASTM D4177 (for liquid), or ASTM D4057 (for liquid), or equivalent; ‐ Composite fuel samples using the procedure in 40 CFR Section 63.7521(d) or equivalent; ‐ Prepare composited fuel samples using EPA SW‐846‐3050B (for solid samples), EPA SW‐846‐3020A (for liquid samples), ASTM D2013/D2013M (for coal), ASTM D5198 (for biomass), or EPA3050 (for solid fuel), or EPA 821‐R‐01‐013 (for liquid or solid), or equivalent; ‐ Determine heat content of the fuel type using ASTM D5865 (for coal) or ASTM E711 (for biomass), or ASTM D5864 (for liquids and other solids), or ASTM D240 or equivalent; ‐ Determine moisture content of the fuel type using ASTM D3173, ASTM E871, or ASTM D5864, or ASTM D240, or ASTM D95 (for liquid fuels), or ASTM D4006 (foliquid fuels), or ASTM D4177 (for liquid fuels) or ASTM D4057 (for liquid fuels), or equivalent; ‐ Measure mercury concentration in fuel sample using ASTM D6722 (for coal), EPA SW‐846‐7471B (for solid samples), or EPA SW‐846‐7470A (for liquid samples), or equivalent; ‐ Convert concentration into units of pounds of mercury per MMBtu of heat content using Equation 8 in 40 CFR Section63.7530; and ‐ Calculate the mercury emission rate from the boiler in units of pounds per million Btu using Equations 10 and 12 in 40 CFR Section 63.7530[40 CFR pt. 63, subp. DDDDD(Table 6), Minn. R. 7011.7050]

COMG0000000007 GP015

HCl Fuel Analysis. To conduct a fuel analysis for HCl, the Permittee must: ‐ Collect fuel samples using the procedure in 40 CFR Section 63.7521(c) or ASTM D5192, or ASTM D7430, or ASTM D6883, or ASTM D2234/D2234M (for coal) or ASTM D6323 (for coal or biomass), ASTD4177 (for liquid fuels) or ASTM D4057 (for liquid fuels), or equivalent; ‐ Composite fuel samples using the procedure in 40 CFR Section 63.7521(d) or equivalent; ‐ Prepare composited fuel samples using EPA SW‐846‐3050B (for solid samples), EPA SW‐846‐3020A (for liquid samples), ASTM D2013/D2013M (for coal), or ASTM D5198 (for biomass), or EPA 3050 or equivalent; ‐ Determine heat content of the fuel type using ASTM D5865 (for coal) or ASTM E711 (for biomass), ASTM D5864, ASTM D240 or equivalent; ‐ Determine moisture content of thfuel type using ASTM D3173 or ASTM E871, or D5864, or ASTM D240, or ASTM D95 (for liquid fuels), or ASTM D4006 (for liquid fuels), or ASTM D4177 (for liquid fuels) or ASTM D4057 (for liquid fuels) or equivalent; ‐ Measure chlorine concentration in fuel sample using EPA SW846‐9250, ASTM D6721, ASTM D4208 (for coal), or EPA SW‐846‐5050 or ASTM E776 (for solid fuel), or EPA SW‐846‐9056 or SW‐846‐9076 (for solids or liquids) or equivalent. ‐ Convert concentrations into units of pounds of HCl per MMBtu of heat content using Equation 7 in 40CFR Section 63.7530; and ‐ Calculate the HCl emission rate from the boiler in units of pounds per million Btu using Equations 10 and 11 in 4CFR Section 63.7530. [40 CFR pt. 63, subp. DDDDD(Table 6), Minn. R. 7011.7050]

COMG0000000007 GP015

General Compliance Requirements: If the Permittee demonstrates compliance with any applicable emission limit through performance testing and subsequent compliance with operating limits (including the use of CPMS), or with a CEMS, or COMS, the Permittee must develoa Site‐Specific Monitoring Plan according to the requirements in 40 CFR Section 63.7505(d)(1)‐(4) for the use of any CEMS, COMS, or CPMSThis requirement also applies if the Permittee petitions the EPA Administrator for alternative monitoring parameters under 40 CFR Section63.8(f). [40 CFR 63.7505(d), Minn. R. 7011.7050]

COMG0000000007 GP015

Site‐Specific Monitoring Plan. For each CMS required in 40 CFR Section 63.7505 (including CEMS, COMS, or CPMS), the Permittee must develop, and submit to the Administrator for approval upon request, a Site‐Specific Monitoring Plan that addresses design, data collection,and the quality assurance and quality control elements outlined in 40 CFR Section 63.8(d) and the elements described below: ‐ Installation of the CMS sampling probe or other interface at a measurement location relative to each affected process unit such that the measurementis representative of control of the exhaust emissions (e.g., on or downstream of the last control device); ‐ Performance and equipment specifications for the sample interface, the pollutant concentration or parametric signal analyzer, and the data collection and reduction systems; and ‐ Performance evaluation procedures and acceptance criteria (e.g., calibrations, accuracy audits, analytical drift). [40 CFR 63.7505(d)(1), Minn. R. 7011.7050]

COMG0000000007 GP015

Site‐Specific Monitoring Plan. The Permittee must submit this Site‐Specific Monitoring Plan, if requested, at least 60 days before the initial performance evaluation of the CMS. This requirement to develop and submit a Site‐Specific Monitoring Plan does not apply to affected sources with existing CEMS or COMS operated according to the performance specifications under 40 CFR pt. 60, Appendix B and that meetthe requirements of 40 CFR Section 63.7525. Using the process described in 40 CFR Section 63.8(f)(4), the Permittee may request approvalof alternative monitoring system quality assurance and quality control procedures in place of those specified in 40 CFR Section 63.7505(d)(and, if approved, include the alternatives in the Site‐Specific Monitoring Plan. [40 CFR 63.7505(d)(1), Minn. R. 7011.7050]

COMG0000000007 GP015

Site‐Specific Monitoring Plan. In the Site‐Specific Monitoring Plan, the Permittee must also address the items below: ‐ Ongoing operation and maintenance procedures in accordance with the general requirements of 40 CFR Section 63.8(c)(1)(ii), (c)(3), and (c)(4)(ii); ‐ Ongoing data quality assurance procedures in accordance with the general requirements of 40 CFR Section 63.8(d); and ‐ Ongoing recordkeeping anreporting procedures in accordance with the general requirements of 40 CFR Section 63.10(c) (as applicable in 40 CFR pt. 63, subp. DDDDDTable 10), (e)(1), and (e)(2)(i). [40 CFR 63.7505(d)(2), Minn. R. 7011.7050]

COMG0000000007 GP015

Site‐Specific Monitoring Plan. The Permittee must conduct a performance evaluation of each CMS in accordance with the Site‐Specific Monitoring Plan. [40 CFR 63.7505(d)(3), Minn. R. 7011.7050]

COMG0000000007 GP015

Site‐Specific Monitoring Plan. The Permittee must operate and maintain the CMS in continuous operation according to the Site‐Specific Monitoring Plan. [40 CFR 63.7505(d)(4), Minn. R. 7011.7050]

COMG0000000007 GP015

Monitoring Data. the Permittee must monitor and collect data according to 40 CFR Section 63.7535 and the Site‐Specific Monitoring Plan required by 40 CFR Section 63.7505(d). [40 CFR 63.7535(a), Minn. R. 7011.7050]

COMG0000000007 GP015

Monitoring Data. The Permittee must operate the monitoring system and collect data at all required intervals at all times that each boiler ioperating and compliance is required, except for periods of monitoring system malfunctions or out of control periods, and required monitoring system quality assurance or control activities, including, as applicable, calibration checks, required zero and span adjustments, and scheduled CMS maintenance as defined in the Site‐Specific Monitoring Plan. A monitoring system malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring system to provide valid data. Monitoring system failures that are caused ipart by poor maintenance or careless operation are not malfunctions. The Permittee is required to complete monitoring system repairs in response to monitoring system malfunctions or out‐of‐control periods and to return the monitoring system to operation as expeditiously apracticable. [40 CFR 63.7535(b), Minn. R. 7011.7050]

COMG0000000007 GP015

Monitoring Data. The Permittee may not use data recorded during monitoring system malfunctions or out‐of‐control periods, repairs associated with monitoring system malfunctions or out‐of‐control periods, or required monitoring system quality assurance or control activities in data averages and calculations used to report emissions or operating levels. The Permittee must record and make available uporequest results of CMS performance audits and dates and duration of periods when the CMS is out of control to completion of the correctiactions necessary to return the CMS to operation consistent with the Site‐Specific Monitoring Plan. The Permittee must use all the data collected during all other periods in assessing compliance and the operation of the control device and associated control system. [40 CFR 63.7535(c), Minn. R. 7011.7050]

COMG0000000007 GP015

Monitoring Data. Except for periods of monitoring system malfunctions, repairs associated with monitoring system malfunctions, and required monitoring system quality assurance or quality control activities (including, as applicable, system accuracy audits, calibration checks, and required zero and span adjustments), failure to collect required data is a deviation of the monitoring requirements. In calculating monitoring results, do not use any data collected during periods when the monitoring system is out of control as specified in thSite‐Specific Monitoring Plan, while conducting repairs associated with periods when the monitoring system is out of control, or while conducting required monitoring system quality assurance or quality control activities. The Permittee must calculate monitoring results usinall other monitoring data collected while the process is operating. The Permittee must report all periods when the monitoring system is ouof control in the annual report. [40 CFR 63.7535(d), Minn. R. 7011.7050]

COMG0000000007 GP015

Notification Requirements. The Permittee must meet the notification requirements in 40 CFR Section 63.7545 according to the schedule in40 CFR Section 63.7545 and in 40 CFR pt. 63, subp. A. Some of the notifications must be submitted before the Permittee is required to comply with the emission limits and work practice standards in 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.7495(d), Minn. R. 7011.7050]

COMG0000000007 GP015

General Notifications. The Permittee must submit to the Administrator all of the notifications in 40 CFR Sections 63.7(b) and (c), 63.8(e), (f)(4) and (6), and 63.9(b)‐(h) that apply by the dates specified. [40 CFR 63.7545(a), Minn. R. 7011.7050]

COMG0000000007 GP015

Notification of Intent. The Permittee must submit a Notification of Intent to conduct a performance test at least 60 days before the performance test is scheduled to begin. [40 CFR 63.7545(d), 40 CFR 63.9(e), Minn. R. 7011.7050, Minn. R. 7019.0100]

COMG0000000007 GP015

Notification of Solid Waste Combustion. If the Permittee intends to commence or recommence combustion of solid waste, the Permittee must provide 30 days prior notice of the date upon which the Permittee will commence or recommence combustion of solid waste. The notification must identify: ‐ The name of the Permittee, the location of the source, the boiler(s) that will commence burning solid waste, anthe date of the notice. ‐ The currently applicable subcategories under 40 CFR pt. 63, subp. DDDDD. ‐ The date on which the Permittee became subject to the currently applicable emission limits. ‐ The date upon which the Permittee will commence combusting solid waste. [4CFR 63.7545(g), Minn. R. 7011.7050]

COMG0000000007 GP015

Notification of Fuel Switch or Physical Change. If the Permittee has switched fuels or made a physical change to the boiler and the fuel switch or physical change resulted in the applicability of a different subcategory, the Permittee must provide notice of the date upon whichthe Permittee switched fuels or made the physical change within 30 days of the switch/change. The notification must identify: ‐ The name the Permittee, the location of the source, the boiler(s) that have switched fuels, were physically changed, and the date of the notice; ‐ The currently applicable subcategory under this subpart; and ‐ The date upon which the fuel switch or physical change occurred. [40 CFR 63.7545(h), Minn. R. 7011.7050]

COMG0000000007 GP015

Notification of Performance Test. ‐ The Permittee must notify the Commissioner and the Administrator of their intention to conduct a performance test at least 60 calendar days before the performance test is initially scheduled to begin. ‐ In the event the Permittee is unablto conduct the performance test on the date specified due to unforeseeable circumstances, the Permittee must notify the Commissioner and the Administrator as soon as practicable and without delay prior to the scheduled performance test date and specify the date when thperformance test is rescheduled. [40 CFR 63.7(b), Minn. R. 7017.2015]

COMG0000000007 GP015

Notification of Opacity or Visible Emission Observations. The Permittee shall notify the Commissioner and the Administrator in writing of thanticipated date for conducting opacity or visible emission observations in accordance with 40 CFR Section 63.9(f). [40 CFR 63.6(h)(4), MinR. 7011.7000]

COMG0000000007 GP015

Notification of Opacity or Visible Emission Observations. The Permittee shall notify the Commissioner and the Administrator in writing of thanticipated date for conducting opacity or visible emission observations. The notification shall be submitted with the notification of the performance test date, or if no performance test is required or visibility or other conditions prevent the opacity or visible emission observations from being conducted concurrently with the initial performance test. The Permittee shall deliver or postmark the notificationnot less than 30 days before the opacity or visible emission observations are scheduled to take place. [40 CFR 63.9(f), Minn. R. 7019.0100]

COMG0000000007 GP015

Change in Information Already Provided. Any change in the information already provided under 40 CFR Section 63.9 shall be provided to thCommissioner and the Administrator in writing within 15 calendar days after the change. [40 CFR 63.9(j), Minn. R. 7019.0100]

COMG0000000007 GP015

Compliance Status Report Content. A compliance report must contain: ‐ Information required in 40 CFR Section 63.7550(c)(1)‐(5); ‐ If thereare no deviations from any emission limitation (emission limit and operating limit) that applies and there are no deviations from the requirements for work practice standards in 40 CFR pt. 63, subp. DDDDD, Table 3 that apply, a statement that there were no deviations frothe emission limitations and work practice standards during the reporting period. If there were no periods during which the CMSs, includinCEMS, COMS, CPMS, were out‐of‐control as specified in 40 CFR Section 63.8(c)(7), a statement that there were no periods during which thCMSs were out‐of‐control during the reporting period; ‐ If the Permittee has a deviation from any emission limitation (emission limit and operating limit) where the Permittee is not using a CMS to comply with that emission limit or operating limit, or a deviation from a work practice standard during the reporting period, the report must contain the information in 40 CFR Section 63.7550(d); and ‐ If there were periods during which the CMSs, in including CEMS, COMS, CPMS, were out‐of‐control as specified in 40 CFR Section 63.8(c)(7), or otherwisenot operating, the report must contain the information in 40 CFR Section 63.7550(e). [40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. A compliance report must contain the following information: ‐ Company and Facility name and addressProcess unit information, emissions limitations, and operating parameter limitations; ‐ Date of report and beginning and ending dates of threporting period; and ‐ The total operating time during the reporting period. [40 CFR 63.7550(c)(5)(i)‐(iv), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. A compliance report must contain the monitoring equipment manufacturer(s) and model numbers andthe date of the last CMS certification or audit. [40 CFR 63.7550(c)(5)(v), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. A compliance report must contain the total fuel use by each individual boiler subject to an emission limwithin the reporting period, including, but not limited to, a description of the fuel, whether the fuel has received a non‐waste determinatioby the EPA or the basis for concluding that the fuel is not a waste, and the total fuel usage amount with units of measure. [40 CFR 63.7550(c)(5)(vi), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. If the Permittee is conducting performance tests once every 3 years consistent with 40 CFR Section 63.7515(b) or (c), a compliance report must contain the date of the last 2 performance tests and a statement as to whether there have beeany operational changes since the last performance test that could increase emissions. [40 CFR 63.7550(c)(5)(vii), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. A compliance report must contain a statement indicating that the Permittee burned no new types of fuin an individual boiler subject to an emission limit. Or, if the Permittee did burn a new type of fuel, the Permittee must submit the calculation of HCl emission rate using Equation 16 of 40 CFR Section 63.7530 that demonstrates that the source is still meeting the emissiolimit for HCl emissions and the calculation of mercury emission rate using Equation 17 of 40 CFR Section 63.7530 that demonstrates that thsource is still meeting the emission limit for mercury emissions. [40 CFR 63.7550(c)(5)(viii), Minn. R. 7011.7550]

COMG0000000007 GP015

Compliance Status Report Content. If the Permittee wishes to burn a new type of fuel in an individual boiler subject to an emission limit ancannot demonstrate compliance with the maximum chlorine input operating limit using Equation 7 of 40 CFR Section 63.7530 or the maximum mercury input operating limit using Equation 8 of 40 CFR Section 63.7530, the Permittee must include in the Compliance Reportstatement indicating the intent to conduct a new performance test within 60 days of starting to burn the new fuel. [40 CFR 63.7550(c)(5)(ixMinn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. A compliance report must contain a summary of any monthly fuel analyses conducted to demonstrate compliance according to 40 CFR Sections 63.7521 and 63.7530 for individual boilers subject to emission limits, and any fuel specification analyses conducted according to 40 CFR Sections 63.7521(f) and 63.7530(g). [40 CFR 63.7550(c)(5)(x), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. If there are no deviations from any emission limits or operating limits in 40 CFR pt. 63, subp. DDDDD thapply, a compliance report must contain a statement that there were no deviations from the emission limits or operating limits during the reporting period. [40 CFR 63.7550(c)(5)(xi), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. If there were no deviations from the monitoring requirements including no periods during which the CMSs, including CEMS, COMS, and CPMS, were out of control as specified in 40 CFR Section 63.8(c)(7), a compliance report must contain a statement that there were no deviations and no periods during which the CMS were out of control during the reporting period. [40 CFR 63.7550(c)(5)(xii), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. If a malfunction occurred during the reporting period, the compliance report must include the numberduration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. The report must also include a description of actions taken by the Permittee during a malfunction of a boiler or associated air pollution control device or CMS to minimize emissions in accordance with 40 CFR Section 63.7500(a)(3), including actions taken to correct the malfunction. [40 CFR 63.7550(c)(5)(xiii), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. A compliance report must contain the date of the most recent burner inspection if it was not done annually and was delayed until the next scheduled or unscheduled unit shutdown. [40 CFR 63.7550(c)(5)(xiv), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. For each reporting period, the Compliance Reports must include all of the calculated 30 day rolling average values based on the daily CEMS and CPMS data. [40 CFR 63.7550(c)(5)(xvi), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. A compliance report must contain a statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. [40 CFR 63.7550(c)(5)(xvii), Minn. R. 7011.705

COMG0000000007 GP015

Compliance Status Report Content. For each deviation from an emission limit or operating limit in 40 CFR pt. 63, subp. DDDDD that occurs an individual boiler where the Permittee is not using a CMS to comply with that emission limit or operating limit, the Compliance Report must additionally contain the information required in 40 CFR Section 63.7550(d)(1)‐(3). ‐ A description of the deviation and which emissionlimit or operating limit from which the Permittee deviated; ‐ Information on the number, duration, and cause of deviations (including unknown cause), as applicable, and the corrective action taken; and ‐ If the deviation occurred during an annual performance test, providethe date the annual performance test was completed. [40 CFR 63.7550(d), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Content. For each deviation from an emission limit, operating limit, and monitoring requirement in 40 CFR pt. 63subp. DDDDD occurring at an individual boiler where the Permittee is using a CMS to comply with that emission limit or operating limit, thecompliance report must additionally contain the information required in 40 CFR Section 63.7550(e)(1)‐(9). This includes any deviations fromthe Site‐Specific Monitoring Plan as required in 40 CFR Section 63.7505(d). ‐ The date and time that each deviation started and stopped andescription of the nature of the deviation; ‐ The date and time that each CMS was inoperative, except for zero (low‐level) and high‐level checks; ‐ The date, time, and duration that each CMS was out of control, including the information in 40 CFR Section 63.8(c)(8); ‐ The date and time that each deviation started and stopped; ‐ A summary of the total duration of the deviation during the reporting period and the total duration as a percent of the total source operating time during that reporting period; ‐ A characterization of the total duration of the deviations during the reporting period into those that are due to control equipment problems, process problems, other known causes, andother unknown causes; ‐ A summary of the total duration of CMS's downtime during the reporting period and the total duration of CMS downtime as a percent of the total source operating time during that reporting period; ‐ A brief description of the source for which there was a deviation; and ‐ A description of any changes in CMSs, processes, or controls since the last reporting period for the source for which there was a deviation. [40 CFR 63.7550(e), Minn. R. 7011.7050]

COMG0000000007 GP015

Compliance Status Report Submittal. The Permittee must submit the Compliance Status Reports according to the procedures specified below. ‐ Within 60 days after the date of completing each performance test as required by 40 CFR pt. 63, subp. DDDDD the Permittee mustsubmit the results of the performance tests, including any associated fuel analyses, required by 40 CFR pt. 63, subp. DDDDD and the compliance reports required in 40 CFR Section 63.7550(b) to the EPA's WebFIRE database according to the methods in 40 CFR Section 63.7550(h)(1). ‐ Within 60 days after the date of completing each CEMS performance evaluation test (defined in 40 CFR Section 63.2) the Permittee must submit the relative accuracy test audit (RATA) data to the EPA's Central Data Exchange according to the methods in 40 CFRSection 63.7550(h)(2). ‐ The Permittee must submit all reports required by 40 CFR pt. 63, subp. DDDDD, Table 9 according to the methods 40 CFR Section 63.7550(h)(3). [40 CFR 63.7550(h), Minn. R. 7011.7050]

COMG0000000007 GP015

Use of a COMS. ‐ The Permittee required to use a COMS shall record the monitoring data produced during a performance test and shall furnish the Commissioner and the Administrator a written report of the monitoring results in accordance with the provisions of 40 CFR Section 63.10(e)(4). ‐ The Permittee may submit, for compliance purposes, COMS data results produced during any performance test required under 40 CFR Section 63.7 in lieu of Method 9 data in accordance with the process specified in 40 CFR Section 63.6(h)(7). ‐ COMS data shall be reduced to 6‐minute averages over the duration of the mass emission performance test. ‐ The Permittee is responsible for demonstrating that they have complied with the performance evaluation requirements of 40 CFR Section 63.8(e), that the COMS has beenproperly maintained, operated, and data quality‐assured, as specified in 40 CFR Sections 63.8(c) and (d), and that the resulting data have nbeen altered in any way. [40 CFR 63.6(h)(7), Minn. R. 7011.7000]

COMG0000000007 GP015

General Reporting Requirements. The Permittee shall submit reports to the Commissioner and shall send a copy of each report to the Administrator. [40 CFR 63.10(a), Minn. R. 7019.0100]

COMG0000000007 GP015

Progress Reports. The Permittee who is required to submit progress reports as a condition of receiving an extension of compliance under 4CFR Section 63.6(i) shall submit such reports to the Commissioner and the Administrator by the dates specified in the written extension of compliance. [40 CFR 63.10(d)(4), Minn. R. 7019.0100]

COMG0000000007 GP015

Additional Reporting Requirements for Sources with Continuous Monitoring Systems. ‐ When more than one CEMS is used to measure theemissions from one affected source, the Permittee shall report the results as required for each CEMS. ‐ The Permittee shall furnish the Commissioner and the Administrator a copy of a written report of the results of the CMS performance evaluation simultaneously with the results of the performance test, unless otherwise specified in 40 CFR pt. 63, subp. DDDDD. The Permittee using a COMS to determine opacity compliance during any performance test shall furnish the Commissioner and the Administrator two or, upon request, three copies a written report of the results of the COMS performance evaluation. The copies shall be furnished at least 15 calendar days before the performance test is conducted. [40 CFR 63.10(e)(1) and (2), Minn. R. 7019.0100]

COMG0000000007 GP015

Excess Emissions and Continuous Monitoring System Performance Report and Summary Report. Excess emissions and parameter monitoriexceedances are defined in 40 CFR pt. 63, subp. DDDDD. The Permittee shall submit an excess emissions and continuous monitoring systemperformance report and/or a summary report to the Commissioner and the Administrator semiannually, except when more frequent reporting is specifically required by 40 CFR pt. 63, subp. DDDDD or a reduction in frequency is approved pursuant to 40 CFR Section 63.10(e)(3). [40 CFR 63.10(e)(3)(i) ‐ (iv), Minn. R. 7019.0100]

COMG0000000007 GP015

Summary Report. One summary report shall be submitted for the hazardous air pollutants monitored at each affected source (unless 40 CFpt. 63, subp. DDDDD standard specifies that more than one summary report is required). The summary report shall be entitled "Summary Report ‐ Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance" and shall contain the information specifiein 40 CFR Section 63.10(e)(3)(vi). [40 CFR 63.10(e)(3)(vi), Minn. R. 7019.0100]

COMG0000000007 GP015

If the total duration of excess emissions or process or control system parameter exceedances for the reporting period is 1 percent or greatof the total operating time for the reporting period, or the total CMS downtime for the reporting period is 5 percent or greater of the totaloperating time for the reporting period, both the summary report and the excess emissions and continuous monitoring system performancreport shall be submitted. [40 CFR 63.10(e)(3)(vii), Minn. R. 7019.0100]

COMG0000000007 GP015

Reporting Continuous Opacity Monitoring System Data Produced During a Performance Test. The Permittee shall record the monitoring daproduced during a performance test and shall furnish the Commissioner and the Administrator a written report of the monitoring results. The report of COMS data shall be submitted simultaneously with the report of the performance test results. [40 CFR 63.10(e)(4), Minn. R. 7019.0100]

COMG0000000007 GP015

General Recordkeeping Requirements. Notwithstanding the requirements in 40 CFR Sections 63.10(d) and 63.10(e), the Permittee shall submit reports to the Commissioner and the Administrator in accordance with the reporting requirements in 40 CFR pt. 63, subp. DDDDD. [40 CFR 63.10(d)(1), Minn. R. 7019.0100]

COMG0000000007 GP015

Records to Keep. The Permittee must keep a copy of each notification and report submitted to comply with 40 CFR pt. 63, subp. DDDDD, including all documentation supporting any Initial Notification or Notification of Compliance Status or Compliance Status Reports submitteaccording to the requirements in 40 CFR Section 63.10(b)(2)(xiv). [40 CFR 63.7555(a)(1), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. The Permittee must keep records of performance tests, fuel analyses, or other compliance demonstrations and performance evaluations as required in 40 CFR Section 63.10(b)(2)(viii). [40 CFR 63.7555(a)(2), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. For each CEMS, COMS, and CMS, the Permittee must keep the following records: ‐ Records described in 40 CFR Section 63.10(b)(2)(vii)‐(xi); ‐ Monitoring data for COMS during a performance evaluation as required in 40 CFR Section 63.6(h)(7)(i) and (ii); ‐ Previous (i.e., superseded) versions of the performance evaluation plan as required in 40 CFR Section 63.8(d)(3); ‐ Requests for alternativesto relative accuracy test for CEMS as required in 40 CFR Section 63.8(f)(6)(i); and ‐ Records of the date and time that each deviation startedand stopped. [40 CFR 63.7555(b), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. The Permittee must keep the records required in 40 CFR pt. 63, subp. DDDDD, Table 8 including records of all monitoring data and calculated averages for applicable operating limits, such as opacity and operating load, to show continuous compliance with eachemission limit and operating limit that applies. [40 CFR 63.7555(c), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. The Permittee must keep records of monthly fuel use including the type(s) of fuel and amount(s) used. [40 CFR 63.7555(d)(1), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. If the Permittee combusts non‐hazardous secondary materials that have been determined not to be solid waste pursuantto 40 CFR Section 241.3(b)(1) and (2), the Permittee must keep a record that documents how the secondary material meets each of the legitimacy criteria under 40 CFR Section 241.3(d)(1). If the Permittee combusts a fuel that has been processed from a discarded non‐hazardous secondary material pursuant to 40 CFR Section 241.3(b)(4), the Permittee must keep records as to how the operations that produced the fuel satisfy the definition of processing in 40 CFR Section 241.2. If the fuel received a non‐waste determination pursuant to tpetition process submitted under 40 CFR Section 241.3(c), the Permittee must keep a record that documents how the fuel satisfies the requirements of the petition process. For operating units that combust non‐hazardous secondary materials as fuel per 40 CFR Section 241.the Permittee must keep records documenting that the material is listed as a non‐waste under 40 CFR Section 241.4(a). Units exempt fromthe incinerator standards under Section 129(g)(1) of the Clean Air Act because they are qualifying facilities burning a homogeneous waste stream do not need to maintain the records described in 40 CFR Section 63.7555(d)(2). [40 CFR 63.7555(d)(2), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. The Permittee must keep a copy of all calculations and supporting documentation of HCl emission rates, using Equation 1of 40 CFR Section 63.7530, that were done to demonstrate compliance with the HCl emission limit. Supporting documentation should include results of any fuel analyses and basis for the estimates of HCl emission rates. The Permittee can use the results from one fuel analysis for multiple boilers provided they are all burning the same fuel type. However, the Permittee must calculate HCl emission rate for each boiler. [40 CFR 63.7555(d)(4), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. The Permittee must keep a copy of all calculations and supporting documentation of mercury emission rates, using Equation 17 of 40 CFR Section 63.7530, that were done to demonstrate compliance with the mercury emission limit. Supporting documentation should include results of any fuel analyses and basis for the estimates of maximum mercury emission rates. The Permittee can use the results from one fuel analysis for multiple boilers provided they are all burning the same fuel type. However, the Permittee mucalculate mercury emission rates for each boiler. [40 CFR 63.7555(d)(5), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. If, consistent with 40 CFR Section 63.7515(b), the Permittee chooses to stack test less frequently than annually, the Permittee must keep a record that documents that the emissions in the previous stack test(s) were less than 75 percent of the applicable emission limit and document that there was no change in source operations including fuel composition and operation of air pollution control equipment that would cause emissions of the relevant pollutant to increase within the past year. [40 CFR 63.7555(d)(6), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. The Permittee must keep records of the occurrence and duration of each malfunction of the boiler or of the associated aipollution control and monitoring equipment. [40 CFR 63.7555(d)(7), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. The Permittee must keep records of actions taken during periods of malfunction to minimize emissions in accordance witthe general duty to minimize emissions in 40 CFR Section 63.7500(a)(3), including corrective actions to restore the malfunctioning boiler, apollution control, or monitoring equipment to its normal or usual manner of operation. [40 CFR 63.7555(d)(8), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. The Permittee must maintain records of the calendar date, time, occurrence and duration of each startup and shutdown.[40 CFR 63.7555(d)(10), Minn. R. 7011.7050]

COMG0000000007 GP015

Records to Keep. The Permittee must maintain records of the type(s) and amount(s) of fuels used during each startup and shutdown. [40 CFR 63.7555(d)(11), Minn. R. 7011.7050]

COMG0000000007 GP015

Recordkeeping Requirements. The Permittee must keep records in accordance with 40 CFR Sections 63.7560 and 63.10(b)(1). [40 CFR 63.10(b)(1), 40 CFR 63.7560, Minn. R. 7011.7050, Minn. R. 7019.0100, subp. 2(B)]

COMG0000000007 GP015

Recordkeeping ‐ Visible Emissions. The Permittee shall make available, upon request by the Commissioner or Administrator, such records tdetermine the conditions under which the visual observations were made and shall provide evidence indicating proof of current visible observer emission certification. [40 CFR 63.6(h)(6), Minn. R. 7011.7000]

COMG0000000007 GP015

Additional Recordkeeping Requirements for Sources with Continuous Monitoring Systems. The Permittee shall maintain records as specifiewithin 40 CFR Section 63.10(c); including CMS measurements (including monitoring data recorded during breakdowns and out‐of‐control periods) and corrective actions. [40 CFR 63.10(c), Minn. R. 7019.0100]

EQUI0000000002 EU002

Particulate Matter <= 15.0 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

PM < 10 micron <= 21.0 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

PM < 2.5 micron <= 10.5 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Front‐half Particulate Matter <= 0.037 pounds per million Btu heat input (filterable PM). [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

EQUI0000000002 EU002

Opacity <= 10 percent opacity 24‐hour block average. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

EQUI0000000002 EU002

Nitrogen Dioxide <= 90.0 pounds per hour 30‐day rolling average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Nitrogen Oxides <= 90.0 pounds per hour 1‐hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Sulfur Dioxide <= 17.10 pounds per hour 1‐hour average. This limit does not apply when boiler is used as back‐up incineration for NCG. [TitI Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Sulfur Dioxide <= 4.0 pounds per million Btu heat input 3‐hour rolling average while burning solid fuels (such as coal and wood). [Minn. R. 7011.0510, subp. 1]

EQUI0000000002 EU002

Sulfur Dioxide <= 2.0 pounds per million Btu heat input 3‐hour rolling average basis when burning fuel oil. [Minn. R. 7011.0510, subp. 1]

EQUI0000000002 EU002

Sulfur Dioxide: When fossil fuels are burned in any combination, the SO2 standard shall be determined by proration using the following formula: PS = [y(2.0)+z(4.0)] / (x+y+z) Where: x = % heat input from natural gas y = % heat input from oil z = % heat input from solid fuel. Aemission limits shall be determined on a 3‐hour rolling average basis. An alternative limit to this proration equation may be proposed by thPermittee. [Minn. R. 7011.0505, subp. 3(A)]

EQUI0000000002 EU002

Carbon Monoxide <= 2200 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Carbon Monoxide <= 720 parts per million 30‐day rolling average calculated by volume on a dry basis @ 3% oxygen. [40 CFR 63.7500(a)(1),40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

EQUI0000000002 EU002

Sulfuric Acid Mist <= 0.13 pounds per hour 3‐hour average. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and MinnR. 7007.3000]

EQUI0000000002 EU002

Hydrochloric acid <= 0.022 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

EQUI0000000002 EU002

Mercury <= 5.7E‐6 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

EQUI0000000002 EU002

Mercury <= 0.000924 pounds per hour 3‐hour average. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. [Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a]

EQUI0000000002 EU002

Steam Flow <= 171000 pounds per hour 8‐hour block average while combusting bark, unless a new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, based on the average fuel usage recorded during the most recent MPCA approved performance test where compliancwas demonstrated. [Minn. R. 7017.2025, subp. 3]

EQUI0000000002 EU002

Fuel burned: limited to following fuel types: wood (including railroad ties); mill waste (including knots and screen rejects, CDF as defined under COMG1, and bark, peat and/or sawdust used to clean up oil and chemical spills); fuel oil; natural gas; and wastewater treatment plasludge. Non‐condensible gas (NCG) is also burned in Power Boiler #7. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Fuel Usage <= 28.5 tons per hour 8‐hour block average unless a new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, based on theaverage fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. (WOOD/BARUSAGE). Natural gas may be used in addition to bark up to the steam‐generating limit. [Minn. R. 7017.2025, subp. 3]

EQUI0000000002 EU002

Fuel Usage <= 502 tons per day 24‐hour block average unless a new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, based on theaverage fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. (RAILROAD TUSAGE LIMIT). [Minn. R. 7007.3000, Minn. R. 7017.2025, subp. 3, Title I Condition: 40 CFR 52.21]

EQUI0000000002 EU002

The Permittee shall operate and maintain the ESP (TREA15) at any time that the process equipment controlled by the ESP (EQUI2) is in operation. The Permittee shall document periods of non‐operation of the control equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Each day, calculate and record the three (3) 8‐hour block average steam flows for the previous day. A day may be defined as a calendar dayor as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the boiler. [MinnR. 7007.0800, subp. 2]

EQUI0000000002 EU002

Each day, calculate and record the three (3) 8‐hour block averages of wood/bark usage for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for theboiler. [Minn. R. 7007.0800, subp. 2]

EQUI0000000002 EU002

Recordkeeping: After burning of RR ties has commenced, the Permittee shall record the total wood refuse usage on a daily basis for each boiler for the purpose of determining whether railroad tie usage limit is being met. If the total wood refuse/railroad tie usage is more thanthe railroad tie usage limit, then the Permittee shall use fuel yard inventories and operator logsheets to determine the daily railroad tie usage. The semi‐annual deviations report shall include all instances where the daily wood refuse/railroad tie usage exceeded the railroad tdaily limit and shall include the determined railroad tie usage for that day. [Minn. R. 7007.0800, subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Emissions Monitoring: The Permittee shall use a COMS to measure opacity emissions from EQUI2. [40 CFR 64.7(a), Minn. R. 7011.1006, Minn. R. 7017.0200]

EQUI0000000002 EU002

Emissions Monitoring: The Permittee shall use a CO, O2, and SO2 CEMS to measure CO, O2, and SO2 emissions from EQUI2. [Minn. R. 7007.3000, Minn. R. 7017.1006, Title I Condition: 40 CFR 52.21]

EQUI0000000002 EU002

Continuous Opacity Monitoring System (COMS). Install, calibrate, maintain, and operate the COMS. [40 CFR 64.7(a) ‐ (c), Minn. R. 7017.020Minn. R. 7017.1006]

EQUI0000000002 EU002

CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of SO2 and COand O2 percent by volume on a dry basis. [Minn. R. 7017.1040, subp. 2, Minn. R. 7017.1006]

EQUI0000000002 EU002

Fuel Analysis. The Permittee must maintain the fuel type or fuel mixture such that the HCl and mercury emission rates calculated accordingto 40 CFR Section 63.7530(c) are less than the HCl and mercury emission limits. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4Minn. R. 7011.7050]

EQUI0000000002 EU002

Boiler Load. The Permittee must 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. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

EQUI0000000002 EU002

Startup. The Permittee must operate all CMS during startup. For startup of the boiler, the Permittee must use one or a combination of the following clean fuels: natural gas, synthetic natural gas, propane, distillate oil, syngas, ultra‐low sulfur diesel, fuel oil‐soaked rags, kerosenehydrogen, paper, cardboard, refinery gas, and liquefied petroleum gas. If the Permittee starts firing coal/solid fossil fuel, biomass/bio‐basesolids, heavy liquid fuel, or gas 2 (other) gases, the Permittee must vent emissions to the main stack(s) and engage all of the applicable control devices. Startup ends when steam or heat is supplied for any purpose. The Permittee must comply with all applicable emission limiat all times except for startup or shutdown periods conforming with this work practice. The Permittee must collect monitoring data during periods of startup, as specified in 40 CFR Section 63.7535(b). The Permittee must keep records during periods of startup. The Permittee must provide reports concerning activities and periods of startup, as specified in 40 CFR Section 63.7555. [40 CFR 63.7500(a)(1), 40 CFR pt.63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

EQUI0000000002 EU002

Shutdown. The Permittee must operate all CMS during shutdown. While firing coal/solid fossil fuel, biomass/bio‐based solids, heavy liquid fuel, or gas 2 (other) gases during shutdown, the Permittee must vent emissions to the main stack(s) and operate all applicable control devices. The Permittee must comply with all applicable emissions limits at all times except for startup or shutdown periods conforming witthis work practice. The Permittee must collect monitoring data during periods of shutdown, as specified in 40 CFR Section 63.7535(b). The Permittee must keep records during periods of shutdown. The Permittee must provide reports concerning activities and periods of shutdown, as specified in 40 CFR Section 63.7555. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

EQUI0000000002 EU002

HCl & Mercury Limits. The initial compliance requirement for HCl and mercury is to conduct a fuel analysis for each type of fuel burned in the boiler according to 40 CFR Section 63.7521 and 40 CFR pt. 63, subp. DDDDD, Table 6 and establish operating limits according to 40 CFRSection 63.7530 and 40 CFR pt. 63, subp. DDDDD, Table 8. The fuels described in 40 CFR Section 63.7510(a)(2)(i) and (ii) are exempt from these fuel analysis and operating limit requirements. The fuels described in 40 CFR Section 63.7510(a)(2)(ii) are exempt from the chloride fuel analysis and operating limit requirements. The Permittee must complete the initial compliance demonstration no later than July 29, 2017 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(b) and (e), Minn. R. 7011.7050]

EQUI0000000002 EU002

HCl & Mercury Limits. If the Permittee burns more than one fuel type, the Permittee must determine the fuel mixture the Permittee could burn in the boiler that would result in the maximum emission rates of HCl and mercury. [40 CFR 63.7530(c)(1), Minn. R. 7011.7050]

EQUI0000000002 EU002

HCl & Mercury Limits. The Permittee must determine the 90th percentile confidence level fuel HCl and mercury concentration of the composite samples analyzed for each fuel type using the one‐sided t‐statistic test described in Equation 15 of 40 CFR Section 63.7510. [40 CFR 63.7530(c)(2), Minn. R. 7011.7050]

EQUI0000000002 EU002

HCl Limit. To demonstrate compliance with the HCl emission limit, the HCl emission rate calculated for the boiler using Equation 16 of 40 CFR Section 63.7530 must not exceed the HCl emission limit. [40 CFR 63.7530(c)(3), Minn. R. 7011.7050]

EQUI0000000002 EU002

Mercury Limit. To demonstrate compliance with the mercury emission limit, the mercury emission rate calculated for the boiler using Equation 17 of 40 CFR Section 63.7530 must not exceed the mercury emission limit. [40 CFR 63.7530(c)(4), Minn. R. 7011.7050]

EQUI0000000002 EU002

CO Limit. The initial compliance demonstration for CO is to conduct a performance evaluation of the CO CEMS, according to 40 CFR Section63.7525(a) no later than July 29, 2017 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFRSection 63.7510(j). [40 CFR 63.7510(c) and (e), Minn. R. 7011.7050]

EQUI0000000002 EU002

Filterable PM Limit. The initial compliance demonstration for PM is to conduct a performance test in accordance with 40 CFR Section 63.7520 and 40 CFR pt. 63, subp. DDDDD, Table 5 no later than July 29, 2017 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). (Requirements are found under PERFORMANCE TESTING REQUIREMENTS heading above.). [40 CFR 63.7510(d) and (e), Minn. R. 7011.7050]

EQUI0000000002 EU002

Filterable PM Limit. The Permittee must establish a unit specific limit for maximum operating load according to 40 CFR Section 63.7520(c) using data from the operating load monitors or from steam generation monitors according to the following requirements: ‐ The Permittee must collect operating load or steam generation data every 15 minutes during the entire period of the PM performance test; ‐ Determine the average operating load by computing the hourly averages using all of the 15‐minute readings taken during each PM performance test; and ‐ Determine the average of the three test run averages during the PM performance test, and multiply this by 1.1 (110 percent) as the operating limit. [40 CFR 63.7530(a) and (b), 40 CFR pt. 63, subp. DDDDD(Table 7), Minn. R. 7011.7050]

EQUI0000000002 EU002

Filterable PM Limit. The Permittee must install, operate, certify and maintain a COMS according to the procedures in 40 CFR Section 63.7525(c)(1)‐(7) by 01/31/2017. [40 CFR 63.7525(c), Minn. R. 7011.7050]

EQUI0000000002 EU002

HCl & Mercury Limits. The Permittee must conduct a monthly fuel analysis according to 40 CFR Section 63.7521 for each type of fuel burnethat is subject to an emission limit in 40 CFR pt. 63, subp. DDDDD, Table 2. The Permittee may comply with this monthly requirement by completing the fuel analysis any time within the calendar month as long as the analysis is separated from the previous analysis by at least 1calendar days. If the Permittee burns a new type of fuel, the Permittee must conduct a fuel analysis before burning the new type of fuel in the boiler. The Permittee must still meet all applicable continuous compliance requirements in 40 CFR Section 63.7540. If each of 12 consecutive monthly fuel analyses demonstrates 75 percent or less of the compliance level, the Permittee may decrease the fuel analysis frequency to quarterly for that fuel. If any quarterly sample exceeds 75 percent of the compliance level or the Permittee begins burning a new type of fuel, the Permittee must return to monthly monitoring for that fuel, until 12 months of fuel analyses are again less than 75 percent of the compliance level. [40 CFR 63.7515(e), Minn. R. 7011.7050]

EQUI0000000002 EU002

HCl & Mercury Limits. The Permittee must demonstrate continuous compliance with the fuel analysis requirement by: ‐ Conducting monthfuel analysis for HCl and mercury according to 40 CFR pt. 63, subp. DDDDD, Table 6; ‐ Reducing the data to 12‐month rolling averages; and Maintaining the 12‐month rolling average at or below the HCl and mercury emission limits. [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R.7011.7050]

EQUI0000000002 EU002

HCl & Mercury Limits. As specified in 40 CFR Section 63.7550(c), the Permittee must keep records of the type and amount of all fuels burnein each boiler during the reporting period to demonstrate that all fuel types and mixtures of fuels burned would result in lower emissions oHCl and mercury than the applicable emission limit for each pollutant, if the Permittee demonstrates compliance through fuel analysis. [40CFR 63.7540(a)(2)(i), Minn. R. 7011.7050]

EQUI0000000002 EU002

HCl Limit. If the Permittee plans to burn a new type of solid or liquid fuel, the Permittee must recalculate the HCl emission rate using Equation 12 of 40 CFR Section 63.7530 according to the requirements below. The Permittee is not required to conduct fuel analyses for thefuels described in 40 CFR Section 63.7510(a)(2)(i)‐(iii) and may exclude these fuels when recalculating the HCl emission rate. ‐ The Permittemust determine the chlorine concentration for any new fuel type in units of lb/MMBtu, based on supplier data or the Permittee's own fuelanalysis, according to the provisions in the Site‐Specific Fuel Analysis Plan developed according to 40 CFR Section 63.7521(b). ‐ The Permittee must determine the new mixture of fuels that will have the highest content of chlorine. ‐ Recalculate the HCl emission rate fromthe boiler under these new conditions using Equation 12 of 40 CFR Section 63.7530. The recalculated HCl emission rate must be less than the HCl emission limit. [40 CFR 63.7540(a)(3), Minn. R. 7011.7050]

EQUI0000000002 EU002

Mercury Limit. If the Permittee plans to burn a new type of fuel, the Permittee must recalculate the mercury emission rate using Equation 13 of 40 CFR Section 63.7530 according to the procedures below. The Permittee is not required to conduct fuel analyses for the fuels described in 40 CFR Section 63.7510(a)(2)(i)‐(iii) and may exclude these fuels when recalculating the mercury emission rate. ‐ The Permittemust determine the mercury concentration for any new fuel type in units of lb/MMBtu, based on supplier data or the Permittee's own fueanalysis, according to the provisions in the Site‐Specific Fuel Analysis Plan developed according to 40 CFR Section 63.7521(b). ‐ The Permittee must determine the new mixture of fuels that will have the highest content of mercury. ‐ Recalculate the mercury emission ratefrom the boiler under these new conditions using Equation 13 of 40 CFR Section 63.7530. The recalculated mercury emission rate must be less than the mercury emission limit. [40 CFR 63.7540(a)(5), Minn. R. 7011.7540, a(6)]

EQUI0000000002 EU002

CO Limit. To demonstrate continuous compliance with the CO emission limit, the Permittee must meet the requirements below. ‐ Continuously monitor CO according to 40 CFR Sections 63.7525(a) and 63.7535. ‐ Maintain a CO emission level below or at the CO emissionlimit at all times the affected unit is operating. ‐ Keep records of CO levels according to 40 CFR Section 63.7555(b). ‐ Record and make available upon request results of CO CEMS performance audits, dates and duration of periods when the CO CEMS is out of control to completion of the corrective actions necessary to return the CO CEMS to operation consistent with the Site‐Specific Monitoring Plan. [40 CFR 63.7540(a)(8), Minn. R. 7011.7050]

EQUI0000000002 EU002

Filterable PM Limit. The Permittee must demonstrate continuous compliance with the opacity operating limit by: ‐ Collecting the opacity monitoring system data according to 40 CFR Sections 63.7525(c) and 63.7535; ‐ Reducing the opacity monitoring data to 6‐minute averageand ‐ Maintaining opacity to less than or equal to 10 percent (24‐hour block average). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

EQUI0000000002 EU002

Filterable PM Limit. The Permittee must demonstrate continuous compliance with the boiler load operating limit by: ‐ Collecting operatingload data or steam generation data every 15 minutes; and ‐ Maintaining the operating load such that it does not exceed 110 percent of thehighest hourly average operating load recorded during the most recent performance test according to 40 CFR Section 63.7520(c). [40 CFR p63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

EQUI0000000002 EU002

Tune‐Ups. The Permittee must conduct a tune‐up of the boiler every five years to demonstrate continuous compliance as specified in 40 CSection 63.7540(a)(10)(i)‐(vi). Each tune‐up must be no more than 61 months after the previous tune‐up. The Permittee may delay the burner inspection specified in 40 CFR Section 63.7540(10)(e) until the next scheduled or unscheduled unit shutdown, but must inspect eacburner at least once every 72 months. [40 CFR 63.7515(d), 40 CFR 63.7540(a)(12), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.705

EQUI0000000002 EU002

Tune‐Ups. If the unit is not operating on the required date for a tune‐up, the tune‐up must be conducted within 30 calendar days of startu[40 CFR 63.7540(a)(13), Minn. R. 7011.7050]

EQUI0000000002 EU002

Startup & Shutdown. For startup and shutdown, the Permittee must meet the work practice standards according to 40 CFR pt. 63, subp. DDDDD, Table 3, Items 5 and 6. [40 CFR 63.7540(d), Minn. R. 7011.7050]

EQUI0000000002 EU002

The Permittee shall submit an initial compliance status report : Due before 07/31/2017. The Initial Compliance Status Report must cover threporting period beginning on January 31, 2017 and ending on June 30, 2017. The Compliance Status Report must contain the information specified in 40 CFR Section 63.7550(c). [40 CFR 63.7550(b)(1)and (2), 40 CFR pt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

EQUI0000000002 EU002

The Permittee shall submit a notification of compliance status : Due 60 calendar days after Demonstration Completion Date according to 4CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status, including all performance test results and fuelanalyses, before the close of business on the 60th day following the completion of all performance test and/or other initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2). The Notification of Compliance Status report must contain all the information specified in 40 CFR Section 63.7545(e)(1)‐(8), as applicable. The Permittee must submit a signed statement in thNotification of Compliance Status report that indicates that the Permittee conducted a tune‐up of the unit. [40 CFR 63.7530(d), 40 CFR 63.7545(e), Minn. R. 7011.7050]

EQUI0000000002 EU002

The Permittee shall submit a compliance status report : Due semiannually, by the 31st of January and July according to 40 CFR Section 63.7550(h). The Compliance Status Reports must cover the applicable semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. The Compliance Status Report must be postmarked or submitted no later than July 31 or January 31, whichever date is the first date following the end of the semiannual reporting period. The Compliance Status Report must contain the information specified in 40 CFR Section 63.7550(c). [40 CFR 63.7550(b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Tab9), Minn. R. 7011.7050]

EQUI0000000002 EU002

PM < 10 micron : The Permittee shall conduct a performance test : Due before 10/19/2019 every 36 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 36‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 4CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 10/19/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 4CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Particulate Matter : The Permittee shall conduct a performance test : Due before 10/21/2019 every 36 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 36‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 4CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Front‐half Particulate Matter : The Permittee shall conduct a performance test : Due before 10/19/2017 every 12 months thereafter to measure emissions according to 40 CFR Section 63.7520, except as specified in 40 CFR Section 63.7515(b)‐(e), (g), and (h), using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. If the performance tests for at least 2 consecutive years show that the emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation ofthe individual boiler or air pollution control equipment that could increase emissions, the Permittee may choose to conduct performance tests every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. If a performance test shows emissions exceeded 75 percent of the emission limit, the Permittee must conduct annual performance tests until performance tests over a consecutive 2‐year period are at or below 75 percent of the emission limit. [40 CFR 63.7515(a)‐(c), Minn. R. 7011.7050]

EQUI0000000002 EU002

Nitrogen Oxides : The Permittee shall conduct a performance test : Due before 08/10/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due datand will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due dasatisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CF52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Sulfuric Acid Mist : The Permittee shall conduct a performance test : Due before 11/20/2018 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using Method OTM 13Aor other method approved by MPCA in the performance test plan approval. This permit contains process throughput limits for EQUI 2. Theprocess throughput limits will be defined by the operating rates sustained during the test, and may be reset within a Notice of Complianceletter. Target process throughput rates as of permit #01700002‐101 are listed in Appendix D along with other recordkeeping items that mube included in the performance test report. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

EQUI0000000002 EU002

Mercury : The Permittee shall conduct a performance test : Due before 05/28/2020 every 60 months thereafter to measure emissions. Thefirst test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D ofthis permit, using EPA Reference Method 30B, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]

EQUI0000000004 EU004

Total Particulate Matter <= 21.50 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

EQUI0000000004 EU004

Total Particulate Matter <= 0.10 pounds per million Btu heat input 3‐hour average from fossil fuel or fossil fuel and wood residue. [40 CFR 60.42(a)(1), Minn. R. 7011.0555]

EQUI0000000004 EU004


EQUI0000000004 EU004


EQUI0000000004 EU004

Front‐half Particulate Matter <= 0.037 pounds per million Btu heat input (filterable PM). [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

EQUI0000000004 EU004

Opacity <= 20 percent opacity 6‐minute average except for one six‐minute period per hour of not more than 27 percent opacity. [40 CFR 60.42(a)(2), Minn. R. 7011.0555]

EQUI0000000004 EU004

Opacity <= 10 percent opacity 24‐hour block average. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

EQUI0000000004 EU004


EQUI0000000004 EU004

Nitrogen Dioxide <= 0.20 pounds per million Btu heat input 3‐hour rolling average while burning natural gas only. While burning oil, oil andwood, or natural gas and wood, the limit is 0.30 lb/mmBtu. While burning coal, coal and wood, or wood, the limit is 0.70 lb/mmBtu. While burning any other mixture of fuels, the limit shall be determined by proration using the following formula: PS(NOx) = [x(0.20)+y(0.30)+z(0.70)] / (x+y+z) Where: x = % heat input from natural gas y = % heat input from oil, oil and wood, or natural gas and wooz= % input from coal, coal and wood, or wood. All emission limits shall be determined on a 3‐hour rolling average basis. [40 CFR 60.44, MinR. 7011.0555]

EQUI0000000004 EU004

Nitrogen Oxides <= 200.0 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000004 EU004

Sulfur Dioxide <= 24.60 pounds per hour. This limit does not apply when boiler is used as back‐up incineration for NCG. [Title I Condition: 4CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000004 EU004

Sulfur Dioxide <= 0.8 pounds per million Btu heat input 3‐hour rolling average while burning fuel oil or fuel oil and wood. While burning coawood, or coal and wood, SO2 must be less than or equal to 1.2 lb/mmBtu. These limits also apply if natural gas is being burned in combination with these fuels. When coal and oil are burned simultaneously, with or without natural gas and/or wood, the limit shall be determined by proration using the following formula: PS = [y(0.80)+z(1.2)] / (y+z) Where: y = % heat input from oil z = % input from coal. Aemission limits shall be determined on a 3‐hour rolling average basis. NCG is not considered a fuel, and the contribution from burning NCGis to be disregarded when determining compliance with this limit. [40 CFR 60.43, Minn. R. 7011.0555]

EQUI0000000004 EU004

Carbon Monoxide <= 3400 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000004 EU004

Carbon Monoxide <= 720 parts per million 30‐day rolling average calculated by volume on a dry basis @ 3% oxygen. [40 CFR 63.7500(a)(1),40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

EQUI0000000004 EU004

Sulfuric Acid Mist <= 0.19 pounds per hour 3‐hour average. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and MinnR. 7007.3000]

EQUI0000000004 EU004

Hydrochloric acid <= 0.022 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

EQUI0000000004 EU004

Mercury <= 5.7E‐6 pounds per million Btu heat input. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 2), Minn. R. 7011.7050]

EQUI0000000004 EU004


EQUI0000000004 EU004

Fuel burned: limited to following fuel types: wood (including railroad ties); mill waste (including knots and screen rejects, CDF as defined under COMG1, and bark, peat and/or sawdust used to clean up oil and chemical spills); fuel oil; natural gas; and wastewater treatment plasludge. Non‐condensible gas (NCG) is also burned in power boiler #9. [Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

EQUI0000000004 EU004

Fuel Usage <= 45.5 tons per hour 8‐hour block average unless a new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, based on theaverage fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. The fuel usaglimit is for wood/bark usage. Natural gas may be used in addition to bark, up to the steam generating limit. Eight‐hour block average is calculated by dividing total weight by total operating time in each eight‐hour block. Down time of 15 min. or more is not to be included as operating time. [Minn. R. 7017.2025, subp. 3]

EQUI0000000004 EU004

Fuel Usage <= 1030 tons per day 24‐hour block average unless a new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, based on thaverage fuel usage recorded during the most recent MPCA approved performance test where compliance was demonstrated. (RAILROAD TUSAGE LIMIT). [Minn. R. 7007.3000, Minn. R. 7017.2025, subp. 3, Title I Condition: 40 CFR 52.21]

EQUI0000000004 EU004

The Permittee shall operate and maintain the ESP (TREA19) at any time that the process equipment controlled by the ESP (EQUI4) is in operation. The Permittee shall document periods of non‐operation of the control equipment. [Title I Condition: 40 CFR 52.21(k)(modeling) Minn. R. 7007.3000]

EQUI0000000004 EU004

Each day, calculate and record the three (3) 8‐hour block averages of wood/bark usage for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for theboiler. [Minn. R. 7007.0800, subp. 2]

EQUI0000000004 EU004

Recordkeeping: After burning of RR ties has commenced, the Permittee shall record the total wood refuse usage on a daily basis for each boiler for the purpose of determining whether railroad tie usage limit is being met. If the total wood refuse/railroad tie usage is more thanthe railroad tie usage limit, then the Permittee shall use fuel yard inventories and operator logsheets to determine the daily railroad tie usage. The semi‐annual deviations report shall include all instances where the daily wood refuse/railroad tie usage exceeded the railroad tdaily limit and shall include the determined railroad tie usage for that day. [Minn. R. 7007.0800, subp. 5, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

EQUI0000000004 EU004


EQUI0000000004 EU004

Emissions Monitoring: The Permittee shall use a CEMS to measure NOx emissions from EQUI4. [40 CFR 64.7(a), Minn. R. 7011.1006, Minn. 7017.0200]

EQUI0000000004 EU004

Continuous Opacity Monitoring System (COMS). Install, calibrate, maintain, and operate the COMS according to the appropriate provisionsin 40 CFR 60.13(b) & 60.45(a). [40 CFR 60.13(b), 40 CFR 60.45(a), 40 CFR 64.7(a)‐(c), Minn. R. 7011.0555, Minn. R. 7017.0200, Minn. R. 7017.1006]

EQUI0000000004 EU004

Emissions Monitoring: The Permittee shall use a CO, O2, NOx, and SO2 CEMS to measure CO, O2, NOx, and SO2 emissions from EQUI4. [Minn. R. 7007.3000, Minn. R. 7017.1006, Title I Condition: 40 CFR 52.21]

EQUI0000000004 EU004

CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of NOx, SO2, Cand O2. [40 CFR 60.45(a), Minn. R. 7011.0555, Minn. R. 7017.1006, Minn. R. 7017.1040, subp. 2]

EQUI0000000004 EU004

Fuel Analysis. The Permittee must maintain the fuel type or fuel mixture such that the HCl and mercury emission rates calculated accordingto 40 CFR Section 63.7530(c) are less than the HCl and mercury emission limits. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4Minn. R. 7011.7050]

EQUI0000000004 EU004

Boiler Load. The Permittee must 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. [40 CFR 63.7500(a)(2), 40 CFR pt. 63, subp. DDDDD(Table 4), Minn. R. 7011.7050]

EQUI0000000004 EU004

Startup. The Permittee must operate all CMS during startup. For startup of the boiler, the Permittee must use one or a combination of the following clean fuels: natural gas, synthetic natural gas, propane, distillate oil, syngas, ultra‐low sulfur diesel, fuel oil‐soaked rags, kerosenehydrogen, paper, cardboard, refinery gas, and liquefied petroleum gas. If the Permittee starts firing coal/solid fossil fuel, biomass/bio‐basesolids, heavy liquid fuel, or gas 2 (other) gases, the Permittee must vent emissions to the main stack(s) and engage all of the applicable control devices. Startup ends when steam or heat is supplied for any purpose. The Permittee must comply with all applicable emission limiat all times except for startup or shutdown periods conforming with this work practice. The Permittee must collect monitoring data during periods of startup, as specified in 40 CFR Section 63.7535(b). The Permittee must keep records during periods of startup. The Permittee must provide reports concerning activities and periods of startup, as specified in 40 CFR Section 63.7555. [40 CFR 63.7500(a)(1), 40 CFR pt.63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

EQUI0000000004 EU004

Shutdown. The Permittee must operate all CMS during shutdown. While firing coal/solid fossil fuel, biomass/bio‐based solids, heavy liquid fuel, or gas 2 (other) gases during shutdown, the Permittee must vent emissions to the main stack(s) and operate all applicable control devices. The Permittee must comply with all applicable emissions limits at all times except for startup or shutdown periods conforming witthis work practice. The Permittee must collect monitoring data during periods of shutdown, as specified in 40 CFR Section 63.7535(b). The Permittee must keep records during periods of shutdown. The Permittee must provide reports concerning activities and periods of shutdown, as specified in 40 CFR Section 63.7555. [40 CFR 63.7500(a)(1), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

EQUI0000000004 EU004

HCl & Mercury Limits. The initial compliance requirement for HCl and mercury is to conduct a fuel analysis for each type of fuel burned in the boiler according to 40 CFR Section 63.7521 and 40 CFR pt. 63, subp. DDDDD, Table 6 and establish operating limits according to 40 CFRSection 63.7530 and 40 CFR pt. 63, subp. DDDDD, Table 8. The fuels described in 40 CFR Section 63.7510(a)(2)(i) and (ii) are exempt from these fuel analysis and operating limit requirements. The fuels described in 40 CFR Section 63.7510(a)(2)(ii) are exempt from the chloride fuel analysis and operating limit requirements. The Permittee must complete the initial compliance demonstration no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(b) and (e), Minn. R. 7011.7050]

EQUI0000000004 EU004

HCl & Mercury Limits. If the Permittee burns more than one fuel type, the Permittee must determine the fuel mixture the Permittee could burn in the boiler that would result in the maximum emission rates of HCl and mercury. [40 CFR 63.7530(c)(1), Minn. R. 7011.7050]

EQUI0000000004 EU004

HCl & Mercury Limits. The Permittee must determine the 90th percentile confidence level fuel HCl and mercury concentration of the composite samples analyzed for each fuel type using the one‐sided t‐statistic test described in Equation 15 of 40 CFR Section 63.7510. [40 CFR 63.7530(c)(2), Minn. R. 7011.7050]

EQUI0000000004 EU004

HCl Limit. To demonstrate compliance with the HCl emission limit, the HCl emission rate calculated for the boiler using Equation 16 of 40 CFR Section 63.7530 must not exceed the HCl emission limit. [40 CFR 63.7530(c)(3), Minn. R. 7011.7050]

EQUI0000000004 EU004

Mercury Limit. To demonstrate compliance with the mercury emission limit, the mercury emission rate calculated for the boiler using Equation 17 of 40 CFR Section 63.7530 must not exceed the mercury emission limit. [40 CFR 63.7530(c)(4), Minn. R. 7011.7050]

EQUI0000000004 EU004

CO Limit. The initial compliance demonstration for CO is to conduct a performance evaluation of the CO CEMS, according to 40 CFR Section63.7525(a) no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFRSection 63.7510(j). [40 CFR 63.7510(c) and (e), Minn. R. 7011.7050]

EQUI0000000004 EU004

Filterable PM Limit. The initial compliance demonstration for PM is to conduct a performance test in accordance with 40 CFR Section 63.7520 and 40 CFR pt. 63, subp. DDDDD, Table 5 no later than July 29, 2016 and according to the applicable provisions in 40 CFR Section 63.7(a)(2), except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(d) and (e), Minn. R. 7011.7050]

EQUI0000000004 EU004

Filterable PM Limit. The Permittee must establish a unit specific limit for maximum operating load according to 40 CFR Section 63.7520(c) using data from the operating load monitors or from steam generation monitors according to the following requirements: ‐ The Permittee must collect operating load or steam generation data every 15 minutes during the entire period of the PM performance test; ‐ Determine the average operating load by computing the hourly averages using all of the 15‐minute readings taken during each PM performance test; and ‐ Determine the average of the three test run averages during the PM performance test, and multiply this by 1.1 (110 percent) as the operating limit. [40 CFR 63.7530(a) and (b), 40 CFR pt. 63, subp. DDDDD(Table 7), Minn. R. 7011.7050]

EQUI0000000004 EU004

Filterable PM Limit. The Permittee must install, operate, certify and maintain a COMS according to the procedures in 40 CFR Section 63.7525(c)(1)‐(7) by 01/31/2017. [40 CFR 63.7525(c), Minn. R. 7011.7050]

EQUI0000000004 EU004

HCl & Mercury Limits. The Permittee must conduct a monthly fuel analysis according to 40 CFR Section 63.7521 for each type of fuel burnethat is subject to an emission limit in 40 CFR pt. 63, subp. DDDDD, Table 2. The Permittee may comply with this monthly requirement by completing the fuel analysis any time within the calendar month as long as the analysis is separated from the previous analysis by at least 1calendar days. If the Permittee burns a new type of fuel, the Permittee must conduct a fuel analysis before burning the new type of fuel in the boiler. The Permittee must still meet all applicable continuous compliance requirements in 40 CFR Section 63.7540. If each of 12 consecutive monthly fuel analyses demonstrates 75 percent or less of the compliance level, the Permittee may decrease the fuel analysis frequency to quarterly for that fuel. If any quarterly sample exceeds 75 percent of the compliance level or the Permittee begins burning a new type of fuel, the Permittee must return to monthly monitoring for that fuel, until 12 months of fuel analyses are again less than 75 percent of the compliance level. [40 CFR 63.7515(e), Minn. R. 7011.7050]

EQUI0000000004 EU004

HCl & Mercury Limits. The Permittee must demonstrate continuous compliance with the fuel analysis requirement by: ‐ Conducting monthfuel analysis for HCl and mercury according to 40 CFR pt. 63, subp. DDDDD, Table 6; ‐ Reducing the data to 12‐month rolling averages; and Maintaining the 12‐month rolling average at or below the HCl and mercury emission limits. [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R.7011.7050]

EQUI0000000004 EU004

HCl & Mercury Limits. As specified in 40 CFR Section 63.7550(c), the Permittee must keep records of the type and amount of all fuels burnein each boiler during the reporting period to demonstrate that all fuel types and mixtures of fuels burned would result in lower emissions oHCl and mercury than the applicable emission limit for each pollutant, if the Permittee demonstrates compliance through fuel analysis. [40CFR 63.7540(a)(2)(i), Minn. R. 7011.7050]

EQUI0000000004 EU004

HCl Limit. If the Permittee plans to burn a new type of solid or liquid fuel, the Permittee must recalculate the HCl emission rate using Equation 12 of 40 CFR Section 63.7530 according to the requirements below. The Permittee is not required to conduct fuel analyses for thefuels described in 40 CFR Section 63.7510(a)(2)(i)‐(iii) and may exclude these fuels when recalculating the HCl emission rate. ‐ The Permittemust determine the chlorine concentration for any new fuel type in units of lb/MMBtu, based on supplier data or the Permittee's own fuelanalysis, according to the provisions in the Site‐Specific Fuel Analysis Plan developed according to 40 CFR Section 63.7521(b). ‐ The Permittee must determine the new mixture of fuels that will have the highest content of chlorine. ‐ Recalculate the HCl emission rate fromthe boiler under these new conditions using Equation 12 of 40 CFR Section 63.7530. The recalculated HCl emission rate must be less than the HCl emission limit. [40 CFR 63.7540(a)(3), Minn. R. 7011.7050]

EQUI0000000004 EU004

Mercury Limit. If the Permittee plans to burn a new type of fuel, the Permittee must recalculate the mercury emission rate using Equation 13 of 40 CFR Section 63.7530 according to the procedures below. The Permittee is not required to conduct fuel analyses for the fuels described in 40 CFR Section 63.7510(a)(2)(i)‐(iii) and may exclude these fuels when recalculating the mercury emission rate. ‐ The Permittemust determine the mercury concentration for any new fuel type in units of lb/MMBtu, based on supplier data or the Permittee's own fueanalysis, according to the provisions in the Site‐Specific Fuel Analysis Plan developed according to 40 CFR Section 63.7521(b). ‐ The Permittee must determine the new mixture of fuels that will have the highest content of mercury. ‐ Recalculate the mercury emission ratefrom the boiler under these new conditions using Equation 13 of 40 CFR Section 63.7530. The recalculated mercury emission rate must be less than the mercury emission limit. [40 CFR 63.7540(a)(5), Minn. R. 7011.7540, a(6)]

EQUI0000000004 EU004

CO Limit. To demonstrate continuous compliance with the CO emission limit, the Permittee must meet the requirements below. ‐ Continuously monitor CO according to 40 CFR Sections 63.7525(a) and 63.7535. ‐ Maintain a CO emission level below or at the CO emissionlimit at all times the affected unit is operating. ‐ Keep records of CO levels according to 40 CFR Section 63.7555(b). ‐ Record and make available upon request results of CO CEMS performance audits, dates and duration of periods when the CO CEMS is out of control to completion of the corrective actions necessary to return the CO CEMS to operation consistent with the Site‐Specific Monitoring Plan. [40 CFR 63.7540(a)(8), Minn. R. 7011.7050]

EQUI0000000004 EU004

Filterable PM Limit. The Permittee must demonstrate continuous compliance with the opacity operating limit by: ‐ Collecting the opacity monitoring system data according to 40 CFR Sections 63.7525(c) and 63.7535; ‐ Reducing the opacity monitoring data to 6‐minute averageand ‐ Maintaining opacity to less than or equal to 10 percent (24‐hour block average). [40 CFR pt. 63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

EQUI0000000004 EU004

Filterable PM Limit. The Permittee must demonstrate continuous compliance with the boiler load operating limit by: ‐ Collecting operatingload data or steam generation data every 15 minutes; and ‐ Maintaining the operating load such that it does not exceed 110 percent of thehighest hourly average operating load recorded during the most recent performance test according to 40 CFR Section 63.7520(c). [40 CFR p63, subp. DDDDD(Table 8), Minn. R. 7011.7050]

EQUI0000000004 EU004

Tune‐Ups. The Permittee must conduct a tune‐up of the boiler every 5 years to demonstrate continuous compliance as specified in 40 CFR Section 63.7540(a)(10)(i)‐(vi). Each tune‐up must be no more than 61 months after the previous tune‐up. The Permittee may delay the burner inspection specified in 40 CFR Section 63.7540(10)(e) until the next scheduled or unscheduled unit shutdown, but must inspect eacburner at least once every 72 months. [40 CFR 63.7515(d), 40 CFR 63.7540(a), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

EQUI0000000004 EU004


EQUI0000000004 EU004

Startup & Shutdown. For startup and shutdown, the Permittee must meet the work practice standards according to 40 CFR pt. 63, subp. DDDDD, Table 3, Items 5 and 6. [40 CFR 63.7540(d), Minn. R. 7011.7050]

EQUI0000000004 EU004

The Permittee shall submit a notification of compliance status : Due 60 calendar days after Demonstration Completion Date according to 4CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status, including all performance test results and fuelanalyses, before the close of business on the 60th day following the completion of all performance test and/or other initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2). The Notification of Compliance Status report must contain all the information specified in 40 CFR Section 63.7545(e)(1)‐(8), as applicable. The Permittee must submit a signed statement in thNotification of Compliance Status report that indicates that the Permittee conducted a tune‐up of the unit. [40 CFR 63.7530(d), 40 CFR 63.7545(e), Minn. R. 7011.7050]

EQUI0000000004 EU004

The Permittee shall submit a compliance status report : Due by 31 days after end of each calendar half‐year according to 40 CFR Section 63.7550(h). The Compliance Status Reports must cover the applicable semiannual reporting period from January 1 through June 30 or the semiannual reporting period from July 1 through December 31. The Compliance Status Report must be postmarked or submitted no later than July 31 or January 31, whichever date is the first date following the end of the semiannual reporting period. The Compliance Status Report must contain the information specified in 40 CFR Section 63.7550(c). [40 CFR 63.7550(b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Tab9), Minn. R. 7011.7050]

EQUI0000000004 EU004

PM < 10 micron : The Permittee shall conduct a performance test : Due before 01/12/2022 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 4CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000004 EU004

PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 01/12/2022 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 4CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000004 EU004

Particulate Matter : The Permittee shall conduct a performance test : Due before 01/12/2022 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 4CFR 52.21(k)(modeling) & Minn. R. 7007.3000, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

EQUI0000000004 EU004

Front‐half Particulate Matter : The Permittee shall conduct a performance test : Due before 01/12/2020 every 36 months thereafter to measure emissions according to 40 CFR Section 63.7520, except as specified in 40 CFR Section 63.7515(b)‐(e), (g), and (h), using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. If the performance tests for at least 2 consecutive years show that the emissions are at or below 75 percent of the emission limit, and if there are no changes in the operation ofthe individual boiler or air pollution control equipment that could increase emissions, the Permittee may choose to conduct performance tests every third year. Each such performance test must be conducted no more than 37 months after the previous performance test. If a performance test shows emissions exceeded 75 percent of the emission limit, the Permittee must conduct annual performance tests until performance tests over a consecutive 2‐year period are at or below 75 percent of the emission limit. [40 CFR 63.7515(a)‐(c), Minn. R. 7011.7050]

EQUI0000000004 EU004

Sulfuric Acid Mist : The Permittee shall conduct a performance test : Due before 12/10/2019 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method OTM 13A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000]

EQUI0000000004 EU004

Mercury : The Permittee shall conduct a performance test : Due before 12/10/2019 every 60 months thereafter to measure emissions. Thefirst test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D ofthis permit, using EPA Reference Method 30B, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]

EQUI0000000007 EU011

Chlorine Dioxide <= 1.0 pounds per hour. This is a state only requirement and is not enforceable by the EPA Administrator or citizens undethe Clean Air Act. [Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a]

EQUI0000000007 EU011

Carbon Monoxide <= 1.2 pounds per ton oven dried bleached pulp. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000007 EU011

Chloroform <= 1.10 pounds per hour. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. [Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a]

EQUI0000000007 EU011

Chloroform Emission Control: To reduce chloroform air emissions from the bleach plant, the Permittee shall use no hypochlorite or chlorinfor bleaching in the bleaching system or line. [40 CFR 63.445(d)(2), Minn. R. 7011.7700]

EQUI0000000007 EU011

HAPs ‐ Total <= 10 parts per million or less than or equal to 0.002 lb per ton of oven‐dried pulp or reduce the Total Chlorinated HAP mass entering the control device by 99% or more by weight. In this limit, Total HAPs refers to Total Chlorinated HAPs (not including chloroform).[40 CFR 63.445(c), Minn. R. 7011.7700]

EQUI0000000007 EU011

Volatile Organic Compounds <= 0.17 pounds per ton of air dried bleached pulp produced. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn.R. 7007.3000]

EQUI0000000007 EU011

Enclosures and Venting: All equipment at each bleaching stage where chlorinated compounds are introduced shall be enclosed and ventedinto a closed‐vent system meeting the requirements specified in 40 CFR Section 63.450 and as described in the Total Facility subject item. [40 CFR 63.445(b), Minn. R. 7011.7700]

EQUI0000000007 EU011

The Permittee shall vent emissions from EQUI7 to control equipment meeting the requirements of TREA17 whenever EQUI7 operates. [Minn. R. 7007.0800, subp. 14]

EQUI0000000007 EU011

Chlorine Dioxide : The Permittee shall conduct a performance test : Due before 09/16/2019 every 60 months to measure emissions. The firtest is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performanctest shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 20, or other method approved by MPCA in the performance test plan approval. Process throughput limits wilbe defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test dudate for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]

EQUI0000000007 EU011

Carbon Monoxide : The Permittee shall conduct a performance test : Due before 09/16/2019 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D ofthis permit, using EPA Reference Method 10, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000007 EU011

Volatile Organic Compounds : The Permittee shall conduct a performance test : Due before 09/16/2019 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due datand will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due dasatisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CF52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000007 EU011

HAPs ‐ Total (Total Chlorinated HAP) : The Permittee shall conduct a performance test : Due before 09/01/2020 every 60 months thereafteto measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using NCASI Method 520, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [40 CFR 63.457(a)(2), Minn. R. 7011.7700]

EQUI0000000018 EU037

Particulate Matter <= 29.80 pounds per hour (This is based on emissions rate of 0.08 lb/mmBtu.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000018 EU037

Particulate Matter <= 0.10 pounds per million Btu heat input. [Minn. R. 7011.0515, subp. 1]

EQUI0000000018 EU037

PM < 10 micron <= 26.10 pounds per hour (This is based on emissions rate of 0.07 lb/mmBtu). [Title I Condition: 40 CFR 52.21(k)(modeling)& Minn. R. 7007.3000]

EQUI0000000018 EU037


EQUI0000000018 EU037

Opacity <= 20 percent opacity except for one six‐minute period per hour of not more than 27 percent opacity. [Minn. R. 7011.0515, subp. 2

EQUI0000000018 EU037

Nitrogen Dioxide <= 0.150 pounds per million Btu heat input 30‐day rolling average (This is based on emission rate of 56 lb/hr.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000018 EU037


EQUI0000000018 EU037

Nitrogen Oxides <= 0.30 pounds per million Btu heat input when burning fuel oil. [Minn. R. 7011.0515, subp. 1]

EQUI0000000018 EU037

Nitrogen Dioxide <= 0.20 pounds per million Btu heat input when burning natural gas. [Minn. R. 7011.0515, subp. 1]

EQUI0000000018 EU037

Sulfur Dioxide <= 21.30 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000018 EU037

Sulfur Dioxide <= 0.80 pounds per million Btu heat input when burning fuel oil. [Minn. R. 7011.0515, subp. 1]

EQUI0000000018 EU037

Fuel Usage: limited to natural gas and #2 fuel oil. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000018 EU037

Sulfur Content of Fuel <= 0.05 percent by weight of fuel oil. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000018 EU037

Fuel Usage <= 1.0 million gallons per year 12‐month rolling sum of fuel oil. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000018 EU037

Vendor Certifications: For all fuel oil burned in Power Boiler #8 (EQUI18), maintain oil vendor information on site that documents oil sulfurcontent in percent by weight, to verify that the fuel oil sulfur content limit of 0.05% is being met. Copies of the sulfur content certification analysis shall be obtained from the vendor for each delivery of fuel oil and must give the sulfur content of the fuel oil. This information shabe maintained on site. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000018 EU037

Emissions Monitoring: The Permittee shall use a NOx and O2 CEMS to measure NOx and O2 emissions from EQUI18. [Minn. R. 7017.1006, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000018 EU037

CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of NOx and O2percent by volume on a dry basis. [Minn. R. 7017.1006, Minn. R. 7017.1040, subp. 2]

EQUI0000000018 EU037

Recordkeeping: By the 15th day of each month, calculate the fuel oil usage for the previous month and the previous 12 months (12‐monthrolling sum). For the first 12 months of operation of #8 as a power boiler, monthly determination of the 12‐month rolling sum limit for fueloil usage shall be determined based on the following: Month 1: FOU < 1,000,000; Month 2‐12: FOU(month n) < 1,000,000 ‐ sum[FOU(actual)]; Where: FOU = the fuel oil usage, in gallons/year; sum[FOU(actual)] = the sum of FOU for all months previous to month nmonth n = the month for which the limit is being calculated. The limit is being met when the formula is true for month n. [Minn. R. 7007.0800, subp. 5]

EQUI0000000018 EU037

Particulate Matter : The Permittee shall conduct initial performance test : Due 180 calendar days after Initial Startup Date of combustion ofuel oil, to measure Total Particulate Matter emissions while burning fuel oil. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. [Minn. R. 7011.0200, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000018 EU037

PM < 10 micron : The Permittee shall conduct initial performance test : Due 150 calendar days after Initial Startup Date of combustion of fuel oil to measure emissions of Particulate Matter < 10 micron while burning fuel oil. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 201A and 202, or other method approved by MPCin the performance test plan approval. [Minn. R. 7011.0200, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000018 EU037

The Permittee shall submit a notification of the actual date of initial startup : Due 15 calendar days after Initial Startup Date of combustionof fuel oil. [Minn. R. 7019.0100, subp. 1]

EQUI0000000018 EU037

Compliance Date. The Permittee must comply with 40 CFR pt. 63, subp. DDDDD no later than January 31, 2016, except as provided in 40 CFSection 63.6(i). [40 CFR 63.7495(b), Minn. R. 7011.7050]

EQUI0000000018 EU037

Tune‐Ups. The Permittee must complete an initial tune‐up by following the procedures described in 40 CFR Section 63.7540(a)(10)(i)‐(vi) nlater than January 31, 2016, except as specified in 40 CFR Section 63.7510(j). [40 CFR 63.7510(e), 40 CFR pt. 63, subp. DDDDD(Table 3), MinR. 7011.7050]

EQUI0000000018 EU037

Energy Assessment. The Permittee must complete the one‐time energy assessment specified in 40 CFR pt. 63, subp. DDDDD, Table 3 no latthan January 31, 2016, except as specified in 40 CFR Section 63.7510(j). An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in 40 CFR pt. 63, subp. DDDDD, Table 3, satisfies the energy assessmenrequirement. A facility that operates under an energy management program compatible with ISO 50001 that includes the affected units alssatisfies the energy assessment requirement. [40 CFR 63.7510(e), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

EQUI0000000018 EU037

Tune‐Ups. The Permittee must conduct an annual tune‐up of the boiler to demonstrate continuous compliance as specified in 40 CFR Section 63.7540(a)(10)(i)‐(vi). Each annual tune‐up must be conducted no more than 13 months after the previous tune‐up. [40 CFR 63.7515(d), 40 CFR 63.7540(a), 40 CFR pt. 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

EQUI0000000018 EU037


EQUI0000000018 EU037

The Permittee shall submit a notification of compliance status : Due 60 calendar days after Demonstration Completion Date according to 4CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status before the close of business on the 60th day following the completion of all initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2). The Notification of Compliance Status must only contain the information specified in 40 CFR Section 63.7545(e)(1) and (8). The Permittee mustsubmit a signed statement in the Notification of Compliance Status report that indicates that the Permittee conducted a tune‐up of the un[40 CFR 63.7530(d), 40 CFR 63.7545(e), Minn. R. 7011.7050]

EQUI0000000018 EU037

The Permittee shall submit a compliance status report : Due by January 31 of each calendar year according to 40 CFR Section 63.7550(h). The Compliance Status Reports must cover the applicable 1‐year reporting period from January 1 through December 31. The Compliance Status Report must be postmarked or submitted no later than January 31 of the year in which it is due. The Compliance Status Report mustcontain the information in 40 CFR Section 63.7550(c)(5)(i)‐(iv) and (xiv). [40 CFR 63.7550(b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Table 9)Minn. R. 7011.7050]

EQUI0000000038 EU082

Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R. 7011.2300, subp. 1]

EQUI0000000038 EU082

Sulfur Dioxide <= 0.50 pounds per million Btu heat input. The potential to emit from the unit is 0.00059 lb/MMBtu due to equipment desigand allowable fuel. [Minn. R. 7011.2300, subp. 2(A)]

EQUI0000000038 EU082

Sulfur Dioxide <= 0.0015 pounds per million Btu heat input. This limit is effective on January 31, 2018. The potential to emit from the unit i0.00059 lb/MMBtu due to equipment design and allowable fuel. [Minn. R. 7011.2300, subp. 2(B)]

EQUI0000000038 EU082

Fuel type: Natural gas only by design. [Minn. R. 7005.0100, subp. 35a]

EQUI0000000038 EU082

Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6, 1995, limitinoperation to 500 hours per year. [Minn. R. 7007.0800, subps. 4‐5]

EQUI0000000038 EU082

The Permittee shall keep records of fuel type and usage on a monthly basis. [Minn. R. 7007.0800, subp. 5]

EQUI0000000042 EU088

Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)]

EQUI0000000042 EU088

Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with theless stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

EQUI0000000049 EU081

Particulate Matter <= 8.80 pounds per hour 3‐hour average. [Minn. R. 7007.0800, subp. 2]

EQUI0000000049 EU081


EQUI0000000049 EU081


EQUI0000000049 EU081


EQUI0000000049 EU081


EQUI0000000049 EU081

Volatile Organic Compounds <= 4.60 pounds per hour. [Minn. R. 7007.0800, subp. 2]

EQUI0000000049 EU081

Carbon Monoxide <= 11.40 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000049 EU081

Sulfur ‐ Total Reduced including H2S <= 0.50 pounds per hour. [Minn. R. 7007.0800, subp. 2]

EQUI0000000049 EU081

Sulfuric Acid Mist <= 1.0 pounds per hour. [Minn. R. 7007.0800, subp. 2]

EQUI0000000049 EU081

HAPs ‐ Total <= 20 parts per million by volume, corrected to 10 percent oxygen on a dry basis. [40 CFR 63.443(d)(2), Minn. R. 7011.2450]

EQUI0000000049 EU081

The Permittee shall vent emissions from the equipment controlled by the IQS to TREA30 whenever the equipment operates, and operate and maintain TREA30 at all times that any emissions are vented to TREA30. The Permittee shall document periods of non‐operation of the control equipment TREA30 while equipment being controlled is operating. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000049 EU081

The Permittee shall vent emissions from EQUI49 to TREA31 (SO2 Scrubber) whenever the equipment operates, and operate and maintain TREA31 at all times that any emissions are vented to TREA31. The Permittee shall document periods of non‐operation of the control equipment whenever EQUI49 is operating. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000049 EU081

The Permittee is allowed to conduct on‐line acid washes on TREA30 in accordance with the O & M Plan. The Permittee shall record the timdate, and duration of on‐line acid washes. A Shutdown Breakdown Notice does not need to be submitted for the on‐line acid wash. [Minn.R. 7007.0800, subp. 2]

EQUI0000000049 EU081

PM < 10 micron : The Permittee shall conduct a performance test : Due before 10/23/2017 every 60 months to measure emissions. The firstest is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performanctest shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset thetest due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test dudate requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000049 EU081

PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 10/23/2017 every 60 months to measure emissions. The firtest is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performanctest shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset thetest due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test dudate requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000049 EU081

Particulate Matter : The Permittee shall conduct a performance test : Due before 10/23/2017 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D ofthis permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C).. Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]

EQUI0000000049 EU081

Sulfuric Acid Mist : The Permittee shall conduct a performance test : Due before 02/19/2019 every 60 months to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D ofthis permit, using EPA Reference Method 8, or other method approved by MPCA in the performance test plan approval. Process throughpulimits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset thetest due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test dudate requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]

EQUI0000000049 EU081

Nitrogen Oxides : The Permittee shall conduct a performance test : Due before 09/01/2017 every 12 months to measure emissions. The firtest is due by the date specified and all subsequent tests are due by the end of each 12‐month period following that date. The performanctest shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. Process throughput limits wilbe defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test dudate for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000049 EU081

Sulfur ‐ Total Reduced including H2S : The Permittee shall conduct a performance test : Due before 09/01/2021 every 60 months to measuemissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 16, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due datand will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due dasatisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1]

EQUI0000000049 EU081

HAPs ‐ Total : The Permittee shall conduct a performance test : Due before 09/01/2021 every 60 months to measure emissions. The first teis due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance tesshall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, usingprocedures in 40 CFR Section 63.457, or other method approved by MPCA in the performance test plan approval. Process throughput limitwill be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test dudate for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [40 CFR 63.457(a)(2), Minn. R. 7011.7700, Minn. R. 7017.2020, subp. 1]

EQUI0000000051 EU031

Total Particulate Matter <= 12.5 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000051 EU031

Total Particulate Matter <= 0.12 pounds per ton of black liquor solids fired (dry virgin). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000051 EU031

Total Particulate Matter <= 0.20 pounds per ton of black liquor solids fired. [40 CFR 52.282(a)(2), 40 CFR 63.862(a)(1)(i)(B), Minn. R. 7011.2450, Minn. R. 7011.7700]

EQUI0000000051 EU031


EQUI0000000051 EU031

PM < 10 micron <= 0.12 pounds per ton of black liquor solids fired (dry weight) using 3 Hour Average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000051 EU031


EQUI0000000051 EU031

Opacity <= 20 percent opacity 6‐minute average. [Minn. R. 7007.0800, subp. 2]

EQUI0000000051 EU031


EQUI0000000051 EU031

Volatile Organic Compounds <= 0.16 pounds per ton of air dried unbleached pulp. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000051 EU031

Sulfur ‐ Total Reduced including H2S <= 0.0168 pounds per ton of black liquor solids (dry virgin). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000051 EU031

Sulfur ‐ Total Reduced including H2S < 0.033 pounds per ton black liquor solids as H2S. [40 CFR 60.283(a)(4), Minn. R. 7011.2450]

EQUI0000000051 EU031

The Permittee shall operate and maintain the scrubber (TREA12) at any time that EQUI51 is in operation. The Permittee shall document periods of non‐operation of the control equipment. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000051 EU031

The Permittee shall operate and maintain the VRS (TREA6) at any time that EQUI51 is in operation. The Permittee shall document periods onon‐operation of the control equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

EQUI0000000051 EU031

Continuous Parameter Monitoring System (CPMS). Install, calibrate, maintain, and operate a CPMS that can be used to determine and record the pressure drop across the scrubber and the scrubbing liquid flow rate at least once every successive 15‐minute period using the procedures in 40 CFR 63.8(c), as well as: ‐ The monitoring device used for the continuous measurement of the pressure drop of the gas stream across the scrubber must be certified by the manufacturer to be accurate to within a gage pressure of plus or minus 500 pascals (plus or minus 2 inches of water gage pressure); and ‐ The monitoring device used for continuous measurement of the scrubbing liquid flowrate must be certified by the manufacturer to be accurate within plus or minus 5 percent of the design scrubbing liquid flow rate. [40 CFR 63.864(e)(10), Minn. R. 7011.7700]

EQUI0000000051 EU031

Determination of operating ranges: ‐ Establish operating ranges for the pressure drop across the scrubber and the scrubbing liquid flow ratbased on values recorded during previous performance tests. ‐ The Permittee shall certify that all control techniques and processes have nbeen modified subsequent to the testing upon which the data used to establish the operating parameter ranges were obtained. ‐ The Permittee may establish expanded or replacement operating ranges during subsequent performance tests using the test methods requiredin 40 CFR 63.865. ‐ The Permittee shall continuously monitor each parameter and determine the arithmetic average value of each parameter during each performance test. Multiple performance tests may be conducted to establish a range of parameter values. [40 CFR 63.864(j), Minn. R. 7011.7700]

EQUI0000000051 EU031

Particulate Matter : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of the chip prsteaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in theperformance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during thetest pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000051 EU031

PM < 10 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre‐steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in theperformance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during thetest pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000051 EU031

PM < 2.5 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre‐steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in theperformance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during thetest pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000051 EU031

Sulfur ‐ Total Reduced including H2S : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 16C, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuantto Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

EQUI0000000051 EU031

Particulate Matter: The Permittee shall submit a test frequency plan for Particulate Matter: Due 60 calendar days after Initial PerformanceTest Date for Particulate Matter emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000051 EU031

PM < 10 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 10 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 10 microns. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon writtenapproval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000051 EU031

PM < 2.5 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 2.5 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 2.5 microns emissions. The plan shall specify a testing frequency based on the test data andMPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000051 EU031

Sulfur ‐ Total Reduced including H2S: The Permittee shall submit a test frequency plan for Total Reduced Sulfur: Due 60 calendar days afterInitial Performance Test Date for Total Reduced Sulfur emissions. The plan shall specify a testing frequency based on the test data and MPCguidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon writtenapproval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Total Particulate Matter <= 0.035 grains per dry standard cubic foot @ 10% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000052 EU033

Total Particulate Matter <= 13.6 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000052 EU033

PM < 10 micron <= 0.0345 grains per dry standard cubic foot 3‐hour average @ 10% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R7007.3000]

EQUI0000000052 EU033

PM < 10 micron <= 13.6 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: CFR 52.21(k)(modeling)]

EQUI0000000052 EU033

PM < 2.5 micron <= 0.0325 grains per dry standard cubic foot 3‐hour average @ 10% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. 7007.3000]

EQUI0000000052 EU033

PM < 2.5 micron <= 12.8 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition:40 CFR 52.21(k)(modeling)]

EQUI0000000052 EU033

Front‐half Particulate Matter < 0.064 grains per dry standard cubic foot corrected to 10 percent oxygen (filterable PM). [40 CFR 60.282a(a)(5)(i), 40 CFR 60.862(a)(1)(i)(C), Minn. R. 7011.7700]

EQUI0000000052 EU033

Opacity <= 20 percent opacity. The exemptions to opacity standards under 40 CFR Section 60.11(c) do not apply. [40 CFR 60.282a(a)(5)(ii)]

EQUI0000000052 EU033

Nitrogen Dioxide <= 220 parts per million (calculated on a dry basis @ 10% O2.). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000052 EU033

Nitrogen Oxides <= 120 parts per million (calculated on a dry basis @ 10% O2). [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Nitrogen Oxides <= 39.0 pounds per hour 30‐day rolling average. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000052 EU033


EQUI0000000052 EU033


EQUI0000000052 EU033

Volatile Organic Compounds <= 1.0 pounds per ton (units are lbs/ton of calcined product). (This is based on emission rate of 20.0 lb/hr). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000052 EU033

Carbon Monoxide <= 75 parts per million (calculated on a dry basis @ 10% O2). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000052 EU033

Carbon Monoxide <= 12.9 pounds per hour. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000052 EU033

Sulfur ‐ Total Reduced including H2S <= 8 parts per million as a 12‐hour average (calculated on a dry basis @ 10% O2). (This is based on emission rate of 1.7 lb/hr). [40 CFR 60.283a(a)(5), Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000052 EU033

Sulfuric Acid Mist <= 0.53 pounds per hour. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000052 EU033

Mercury <= 0.00025 pounds per hour. This is a state only requirement and is not federally enforceable or enforceable by citizens under theAct. [Minn. R. 7007.0800, subp. 2]

EQUI0000000052 EU033

Calcium Oxide Production Process Throughput <= 175000 tons per year 12‐month rolling sum. [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2), Title I Condition: Avoid major modification under 40 CFR 52.21(b)(3)(netting) & Minn. R. 7007.3000, Title I Condition: Avoid major source under 40 CFR 52.21(b)(1)(i) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Fuel use: limited to natural gas. [Minn. R. 7007.0800, subp. 2]

EQUI0000000052 EU033

Process Throughput <= 500 tons per day 24‐hour block average (limit is for calcium oxide production). 24‐hour block average is calculated dividing total weight by total operating time in each 24‐hour block. Down time of 15 minutes or more is not to be included as operating time. [Minn. R. 7017.2025, subp. 3, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000052 EU033

No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, Minn. R. 7011.0050]

EQUI0000000052 EU033

The Permittee shall operate and maintain the ESP (TREA21) at any time that the process equipment controlled by the ESP (EQUI52) is in operation. The Permittee shall document periods of non‐operation of the control equipment. [Minn. R. 7007.0100, subps. 7(A), 7(L), & 7(MMinn. R. 7007.0800, subp. 4, Minn. R. 7007.0800, subps. 1‐2, Minn. R. 7009.0010‐7009.0080, Minn. Stat. 116.07, subd. 4a, Minn. Stat. 116.07, subd. 9, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling), Title I Conditio40 CFR pt. 50]

EQUI0000000052 EU033


EQUI0000000052 EU033

Continuous Opacity Monitoring System (COMS): Install, calibrate, maintain, and operate a COMS to monitor and record opacity. The span othis system must be set at 70 percent opacity. The Permittee must install, certify, and operate the COMS in accordance with Performance Specification 1 in 40 CFR part 60, Appendix B and the appropriate provisions in 40 CFR Sections 63.6(h) & 63.8. [40 CFR 60.13(b), 40 CFR 60.284a(a)(1), 40 CFR 60.864(d), 40 CFR 64.7(a)‐(c), Minn. R. 7011.7700, Minn. R. 7017.0200, Minn. R. 7017.1006]

EQUI0000000052 EU033

Emissions Monitoring: The Permittee shall use an oxygen and TRS CEMS to measure oxygen and TRS emissions from EQUI52. [Minn. R. 7007.3000, Minn. R. 7017.1006, Title I Condition: 40 CFR 52.21]

EQUI0000000052 EU033

CEMS Installation: Install, calibrate, maintain and operate a CEMS to monitor and record the concentration of TRS on a dry basis and O2 percent by volume on a dry basis. The Permittee must install, certify, and operate the continuous TRS monitoring system in accordance witPerformance Specification 5 in 40 CFR part 60, Appendix B. The Permittee must install, certify, and operate the continuous oxygen monitoring system in accordance with Performance Specification 3 in 40 CFR part 60, Appendix 3. These systems must be located downstream of the control device(s). The range of the continuous monitoring system must encompass all expected concentration values, including the zero and span values used for calibration. The spans of these continuous monitoring systems must be set: ‐ At a TRS concentration of 30 ppm for the TRS CEMS; and ‐ At 21 percent oxygen for the O2 CEMS. [40 CFR 60.284a(a)(2), Minn. R. 7017.1006, Minn.R. 7017.1040, subp. 2]

EQUI0000000052 EU033

The Permittee must install, calibrate, maintain, and operate: ‐ A monitoring device for the continuous measurement of the secondary voltage of each ESP collection field; and ‐ A monitoring device for the continuous measurement of the secondary current of each ESP collection field. Total secondary power may be calculated as the product of the secondary voltage and secondary current measurements foeach ESP collection field and used to demonstrate compliance as an alternative to the secondary voltage and secondary current measurements. [40 CFR 60.284a(b)(3)]

EQUI0000000052 EU033

The Permittee must follow the procedures for collecting and reducing monitoring data and setting operating limits in 40 CFR Section 60.284a(c)(1)‐(6). 40 CFR pt. 60, subp. A specifies methods for reducing continuous opacity monitoring system data. [40 CFR 60.284a(c)]

EQUI0000000052 EU033

The Permittee must perform the following: ‐ Calculate and record on a daily basis 12‐hour average TRS concentrations for the two consecutive periods of each operating day. Each 12‐hour average must be determined as the arithmetic mean of the appropriate 12 contiguous 1‐hour average TRS concentrations provided by each continuous monitoring system installed under 40 CFR Section 60.284a(a)(2). ‐ Calculate and record on a daily basis 12‐hour average oxygen concentrations for the two consecutive periods of each operating day for the lime kiln. These 12‐ hour averages must correspond to the 12‐hour average TRS concentrations under 40 CFR Section60.284a(c)(1)(i) and must be determined as an arithmetic mean of the appropriate 12 contiguous 1‐hour average oxygen concentrations provided by each continuous monitoring system installed under 40 CFR Section 60.284a(a)(2). ‐ Using the following equation, correct all 12hour average TRS concentrations to 10 volume percent oxygen: Ccorr = Cmeas x (21 ‐ X) / (21 ‐ Y) Where: Ccorr = the concentration corrected for oxygen. Cmeas = the 12‐hour average of the measured concentrations uncorrected for oxygen. X = the volumetric oxygen concentration in percentage to be corrected to (10 percent for lime kilns). Y = the 12‐hour average of the measured volumetric oxygen concentration. [40 CFR 60.284a(c)(1)]

EQUI0000000052 EU033

The Permittee must record at least once each successive 15‐minute period all measurements obtained from the continuous monitoring devices installed under 40 CFR Section 60.284a(b)(3) and reduce the data by calculating semiannual averages from the recorded measurements of ESP parameters (secondary voltage and secondary current, or total secondary power) for ESP‐controlled lime kilns that measure opacity in addition to ESP parameters. [40 CFR 60.284a(c)(3)]

EQUI0000000052 EU033

During the initial performance test required in 40 CFR Section 60.285a, the Permittee must establish site‐specific operating limits for the monitoring parameters in 40 CFR Section 60.284a(b)(3) by continuously monitoring the parameters and determining the arithmetic averagvalue of each parameter during the performance test. The arithmetic average of the measured values for the three test runs establishes thminimum site‐specific operating limit for each ESP parameter. Multiple performance tests may be conducted to establish a range of parameter values. The Permittee may establish replacement operating limits for the monitoring parameters during subsequent performantests using the test methods in 40 CFR Section 60.285a. [40 CFR 60.284a(c)(4)]

EQUI0000000052 EU033

The Permittee must operate the continuous monitoring systems required in 40 CFR Section 60.284a(a) and (b) to collect data at all requireintervals at all times the affected facility is operating except for periods of monitoring system malfunctions or out‐of‐control periods, repaiassociated with monitoring system malfunctions or out‐of‐control periods, and required monitoring system quality assurance or quality control activities including, as applicable, calibration checks and required zero and span adjustments. [40 CFR 60.284a(c)(5)]

EQUI0000000052 EU033

The Permittee may not use data recorded during monitoring system malfunctions or out‐of‐control periods, repairs associated with monitoring system malfunctions or out‐of‐control periods, or required monitoring system quality assurance or control activities in calculations used to report emissions or operating limits. The Permittee must use all the data collected during all other periods in assessingthe operation of the control device and associated control system. [40 CFR 60.284a(c)(6)]

EQUI0000000052 EU033

For emissions from any lime kiln, periods of excess emissions are: ‐ All 12‐hour average TRS concentrations above 8 ppm by volume at 10‐percent oxygen during times when lime mud is fired; and ‐ All 6‐minute average opacities that exceed 20 percent during times when lime mud is fired. [40 CFR 60.284a(d)(2)]

EQUI0000000052 EU033

The Administrator will not consider periods of excess emissions reported under 40 CFR Section 60.288a(a) to be indicative of a violation of the standards provided that: ‐ The percent of the total number of possible contiguous periods of excess emissions in the semiannual reporting period does not exceed: 1% for TRS emissions provided that the 12‐hour average TRS concentration does not exceed 22 ppm corrected to 10‐percent oxygen or 1% for average opacities provided that the ESP secondary voltage and secondary current (or total secondary power) averaged over the semiannual period remained above the minimum operating limits established during the performanctest; and ‐ The Administrator determines that the affected facility, including air pollution control equipment, is maintained and operated inmanner which is consistent with good air pollution control practice for minimizing emissions during periods of excess emissions. [40 CFR 60.284a(e)]

EQUI0000000052 EU033

The procedures under 40 CFR Section 60.13 must be followed for installation, evaluation, and operation of the continuous monitoring systems required under 40 CFR Section 60.284a. All continuous monitoring systems must be operated in accordance with the applicable procedures under Performance Specifications 1, 3, and 5 of 40 CFR pt. 60, Appendix B. [40 CFR 60.284a(f)]

EQUI0000000052 EU033

Each day, calculate and record the 24‐hour block average calcium oxide production rate for the previous day. A day may be defined as a calendar day, or as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for thelime kiln. [Minn. R. 7007.0800, subp. 2]

EQUI0000000052 EU033

Recordkeeping: By the 15th day of each month, calculate and record the calcium oxide production rate for the previous month and the previous 12 months (12‐month rolling sum). [Minn. R. 7007.0800, subp. 2]

EQUI0000000052 EU033

The Permittee must maintain records of the performance evaluations of the continuous monitoring systems. [40 CFR 60.287a(a)]

EQUI0000000052 EU033

For each continuous monitoring system, the Permittee must maintain records of the following information: ‐ Records of the opacity of the gases discharged into the atmosphere and records of the ESP secondary voltage and secondary current (or total secondary power) averageover the reporting period for the opacity allowances specified in 40 CFR Section 60.284a(e)(1)(iv); ‐ Records of the concentration of TRS emissions on a dry basis and the percent of oxygen by volume on a dry basis in the gases discharged into the atmosphere; ‐ Records of the secondary voltage of each ESP collection field, records of the secondary current of each ESP collection field, and, if used as an alternative tosecondary voltage and current, records of the total secondary power of each ESP collection field; and ‐ Records of excess emissions as defined in 40 CFR Section 60.284a(d). [40 CFR 60.287a(b)]

EQUI0000000052 EU033

For each malfunction, the Permittee must maintain records of the following information: ‐ Records of the occurrence and duration of eachmalfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment; and ‐ Records of actions taken during periods of malfunction to minimize emissions in accordance with 40 CFR Section 60.11(d), including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation. [40 CFR 60.287a(c)

EQUI0000000052 EU033

Recordkeeping: Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), Minn. R. 7019.0100, subp. 1]

EQUI0000000052 EU033

Recordkeeping: Maintain a file of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by 40 CFR pt.60 recorded in a permanent form suitable for inspection for at least five years. 40 CFR Section 60.7(f) specifies two years. [40 CFR 60.7(f), Minn. R. 7007.0800, subp. 5(C), Minn. R. 7019.0100, subp. 1]

EQUI0000000052 EU033

The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. The Permittee shall submit the notification both to the Commissioner and to the US EPA regional office in Chicago. [40 CFR 60.7(a)(4), Minn. R. 7019.0100, subp. 1]

EQUI0000000052 EU033

The Permittee shall submit a notification of the date upon which demonstration of the continuous monitoring system performance commences in accordance with 40 CFR Section 60.13(c). Notification shall be postmarked not less than 30 days prior to such date. [40 CFR 60.7(a)(5), Minn. R. 7019.0100, subp. 1]

EQUI0000000052 EU033

Notification of Anticipated Date for Conducting Opacity Observations: due 30 days prior to observation date. The Permittee shall submit thnotification both to the Commissioner and to the US EPA regional office in Chicago. [40 CFR 60.7(a)(6), Minn. R. 7019.0100, subp. 1]

EQUI0000000052 EU033

Within 60 days after the date of completing each performance test as required by 40 CFR pt. 60, subp. BBa, the Permittee must submit theresults of the performance tests, including any associated fuel analyses, required by 40 CFR pt. 60, subp. BBa to the EPA as specified in 40 CFR Section 60.288a(b). [40 CFR 60.288a(b)]

EQUI0000000052 EU033

Within 60 days after the date of completing each CEMS performance evaluation test as defined in 40 CFR Section 60.13, the Permittee mussubmit relative accuracy test audit (RATA) data to the EPA's Central Data Exchange (CDX) by using CEDRI in accordance with 40 CFR Section60.288a(b). Only RATA pollutants that can be documented with the ERT (as listed on the ERT Web site) are subject to this requirement. Forany performance evaluations with no corresponding RATA pollutants listed on the ERT Web site, the Permittee must submit the results of the performance evaluation to the Administrator at the appropriate address listed in 40 CFR Section 60.4. [40 CFR 60.288a(c)]

EQUI0000000052 EU033

If a malfunction occurred during the reporting period, the Permittee must submit a report that contains the following: ‐ The number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded; and ‐ A description of actions taken by the Permittee during a malfunction to minimize emissions in accordance with 40 CFR Section 60.11(d), including actions taken to correct a malfunction. [40 CFR 60.288a(d)]

EQUI0000000052 EU033

Sulfuric Acid Mist : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performantest shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using OTM 13A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by thmaximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Carbon Monoxide : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D ofthis permit, using EPA Reference Method 10, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Sulfur Dioxide : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 6C, or other method approved by MPCA in the performance test plan approval. Process throughput limits wilbe defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). The Permitteemay not extend this performance test deadline. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Volatile Organic Compounds : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D ofthis permit, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). The Permittee may not extend this performance test deadline. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Mercury : The Permittee shall conduct an initial performance test : Due before 05/13/2017 to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, usingEPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). The Permittee mnot extend this performance test deadline. [Minn. R. 7017.2020, subp. 1]

EQUI0000000052 EU033

Sulfuric Acid Mist: The Permittee shall submit a test frequency plan for sulfuric acid mist: Due 60 calendar days after Initial Performance TeDate for sulfuric acid mist emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Carbon Monoxide: The Permittee shall submit a test frequency plan for Carbon Monoxide: Due 60 calendar days after Initial Performance Test Date for CO emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance testbased on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and MinnR. 7007.3000]

EQUI0000000052 EU033

Sulfur Dioxide: The Permittee shall submit a test frequency plan for Sulfur Dioxide: Due 60 calendar days after Initial Performance Test Datfor SO2 emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based o12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Volatile Organic Compounds: The Permittee shall submit a test frequency plan for Volatile Organic Compounds: Due 60 calendar days afterInitial Performance Test Date for VOC emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval othe MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Mercury: The Permittee shall submit a test frequency plan for Mercury: Due 60 calendar days after Initial Performance Test Date for Mercury emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.202subp. 1]

EQUI0000000052 EU033

PM < 10 micron : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 4CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000052 EU033

PM < 2.5 micron : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 4CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Particulate Matter : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5 and 202, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 4CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Filterable Particulate Matter : The Permittee shall conduct a performance test : Due before 08/30/2021 every 60 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period followinthat date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified inAppendix D of this permit, using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval and by following the provisions in 40 CFR Sections 60.8 and 63.285a(b)(1) and (2). Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days priorto the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due date satisfies this test due date requirement and will reset the performance test due date. [40 CFR 60.285a(b)(4)]

EQUI0000000052 EU033

Nitrogen Oxides : The Permittee shall conduct a performance test : Due before 08/30/2017 every 12 months thereafter to measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 12‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 7E, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn. R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due datand will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test due dasatisfies this test due date requirement and will reset the performance test due date. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CF52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000052 EU033

Sulfur ‐ Total Reduced including H2S : The Permittee shall conduct a performance test : Due before 10/18/2021 every 60 months thereafteto measure emissions. The first test is due by the date specified and all subsequent tests are due by the end of each 60‐month period following that date. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 16C, or other method approved by MPCA in the performance test plaapproval. Process throughput limits will be defined by the maximum achievable operating rate sustained during the test pursuant to Minn.R. 7017.2025, subp. 3(C). Testing conducted during the 60 days prior to the performance test due date satisfies the performance test due date, and will not reset the test due date for future testing as required: 1) by this permit; 2) by the most recently approved Performance Test Frequency Plan; or 3) within a Notice of Compliance letter. Testing conducted more than two months prior to the performance test dudate satisfies this test due date requirement and will reset the performance test due date. [40 CFR 60.285a(d)(4), Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Filterable Particulate Matter <= 0.020 grains per dry standard cubic foot 3‐hour average basis calculated at 8% O2. [Title I Condition: 40 CF52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Particulate Matter <= 40.0 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Conditio40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Total Particulate Matter <= 0.044 grains per dry standard cubic foot (calculated at 8% O2). [40 CFR 60.282(a)(1)(i), 40 CFR 63.862(a)(1)(i)(A)Minn. R. 7011.2450, Minn. R. 7011.7700]

EQUI0000000053 EU005

Total Particulate Matter <= 0.030 pounds per million Btu heat input. This limit applies at all times when fuel oil is being combusted, except during periods of startup, shutdown, or malfunction. [40 CFR 60.43b(h)(1), Minn. R. 7011.0565]

EQUI0000000053 EU005

PM < 10 micron <= 0.025 grains per dry standard cubic foot 3‐hour average basis calculated at 8% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

PM < 10 micron <= 40.0 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000053 EU005

PM < 2.5 micron <= 0.025 grains per dry standard cubic foot 3‐hour average basis calculated at 8% O2. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

PM < 2.5 micron <= 37.9 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition:40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Opacity <= 20 percent opacity 6‐minute average, except for one 6‐minute period per hour of not more than 27 percent opacity. [40 CFR 60.43b(f), Minn. R. 7011.0565]

EQUI0000000053 EU005

Opacity <= 35 percent opacity. [40 CFR 60.282(a)(1)(ii), Minn. R. 7011.2450]

EQUI0000000053 EU005

Nitrogen Dioxide <= 100 parts per million 30‐day rolling average by volume (dry) corrected to 8% oxygen. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Nitrogen Dioxide <= 226.5 pounds per hour 30‐day rolling average. [Minn. R. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a]

EQUI0000000053 EU005


EQUI0000000053 EU005

Nitrogen Oxides <= 241.0 pounds per hour 1‐hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Nitrogen Dioxide <= 0.20 pounds per million Btu heat input 30‐day rolling average while burning natural gas only or fuel oil combined with black liquor. [40 CFR 60.44b(f)(2), Minn. R. 7011.0565]

EQUI0000000053 EU005

Sulfur Dioxide <= 582.0 pounds per hour. (This limit is based on a concentration of 250 ppmvd @ 8% O2.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Sulfur Dioxide <= 73.0 pounds per hour 30‐day rolling average. (This limit is based on a concentration of 50 ppmvd @ 8% O2.). [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Volatile Organic Compounds <= 44.0 pounds per hour 3‐hour average. (This limit is based on a concentration of 60 ppmvd @ 8% O2.). [TitleCondition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Carbon Monoxide <= 359.1 pounds per hour 24‐hour rolling average. (This limit is based on a concentration of 300 ppmvd @ 8% O2.). [MinR. 7007.0800, subp. 2, Minn. Stat. 116.07, subd. 4a]

EQUI0000000053 EU005

Carbon Monoxide <= 382.0 pounds per hour 24‐hour rolling average (This limit is based on a concentration of 300 ppmvd @ 8% O2.). [TitleCondition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Sulfur ‐ Total Reduced including H2S <= 5 parts per million on a dry basis, corrected to 8% oxygen, using 12‐hour block average. (This limit ibased on an emission rate of 4.8 lb/hr.). [40 CFR 60.283(a)(2), Minn. R. 7011.2450, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Sulfuric Acid Mist <= 3.6 pounds per hour 3‐hour average. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005


EQUI0000000053 EU005

Carbon Dioxide Equivalent <= 207 pounds per million Btu heat input. This emission rate limit is based on emission factors and global warming potentials listed in 40 CFR Part 98 as of September, 2016. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Fuel burned: Limited to natural gas, black liquor, and black liquor blended with distillate fuel oil (includes on‐road diesel fuel oil). The combustion of fuel oil alone (i.e. not blended with black liquor) is not authorized. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Fuel Usage <= 1.0 gallons per minute of distillate fuel oil. This is in addition to the other fuels allowed. This is a physical limitation of the design of the fuel oil feed system (pump capacity). [Minn. R. 7005.0100, subp. 35a]

EQUI0000000053 EU005

Sulfur Content of Fuel <= 0.050 percent by weight for distillate oil. This limit also exempts the unit from the sulfur dioxide emission limits o40 CFR Section 60.42b (40 CFR Section 60.42b(k)(2)). [Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) and Minn. R. 7007.3000]

EQUI0000000053 EU005

Steam Flow <= 825000 pounds per hour 8‐hour block average unless a new maximum is set pursuant to Minn. R. 7017.2025, subp. 3, basedon the average steam flow recorded during the most recent MPCA approved performance test where compliance was demonstrated. Limitis for Steam Production. Eight‐hour block average is calculated by dividing total steam produced by total operating time in each eight‐hourblock. Down time of 15 min. or more is not to be included as operating time. [Minn. R. 7017.2025, subp. 3]

EQUI0000000053 EU005

Annual capacity factor for fossil fuels: less than or equal to 10%. [40 CFR 60.44b(c), Minn. R. 7011.0565]

EQUI0000000053 EU005

Annual Capacity Factor Daily Recordkeeping and Fuel Type Recordkeeping: On each day of operation the Permittee shall record and maintain records of the amounts of each fuel combusted in the Recovery Boiler (EQUI 53). [40 CFR 60.49b(d), Minn. R. 7007.0800, subps. 45, Minn. R. 7011.0565, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Annual Capacity Factor Monthly Recordkeeping: By the 15th day of each month, the Permittee shall calculate and record the following: 1) The total amount of each type of fuel combusted in the recovery boiler during the previous month. 2) The annual capacity factor of fossil fuels (natural gas and distillate oil) for the previous 12‐month period. [40 CFR 60.49b(d), Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7011.0565]

EQUI0000000053 EU005

The Permittee shall operate and maintain the ESP (TREA20) at any time that the process equipment controlled by the ESP (EQUI53) is in operation. The Permittee shall document periods of non‐operation of the control equipment. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000053 EU005

Each day, calculate and record the three (3) 8‐hour block average steam flows for the previous day. A day may be defined as a calendar dayor as another 24 hour period of the Permittee's choice. However it is defined, it must be consistently used in that way for the boiler. [MinnR. 7007.0800, subp. 2]

EQUI0000000053 EU005


EQUI0000000053 EU005

Continuous Opacity Monitoring System (COMS). Install, calibrate, maintain, and operate the COMS according to the appropriate provisionsin 40 CFR 63.6(h) & 63.8. [40 CFR 60.13(b), 40 CFR 60.284(a)(1), 40 CFR 60.48b(a), 40 CFR 63.864(d), 40 CFR 64.7(a)‐(c), Minn. R. 7011.2450Minn. R. 7011.7700, Minn. R. 7017.0200, Minn. R. 7017.1006]

EQUI0000000053 EU005

Emissions Monitoring: The Permittee shall use an CO, NOx, SO2, and TRS CEMS to measure CO, NOx, SO2, and TRS emissions from EQUI53[40 CFR 63.864(e), Minn. R. 7007.3000, Minn. R. 7011.7700, Minn. R. 7017.1006, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000053 EU005

CEMS Installation: Install, calibrate, maintain and operate a continuous monitoring system for measuring the concentration of NOx, SO2, CCO2; and the concentration of TRS on a dry basis; and O2 percent by volume on a dry basis. [40 CFR 60.284(a)(2), Minn. R. 7011.2450, MinR. 7017.1006, Minn. R. 7017.1040, subp. 2]

EQUI0000000053 EU005

Records of Startup, Shutdown, or Malfunction: Any owner or operator subject to the provisions of this part shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b)]

EQUI0000000053 EU005

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), 40 CFR 60.866, MinnR. 7011.7700, Minn. R. 7017.1130]

EQUI0000000053 EU005

Record and maintain records of the amount of fuel combusted each day. [40 CFR 60.49b(d)(1), Minn. R. 7011.0565]

EQUI0000000053 EU005

Maintain records each operating day of the information listed under 40 CFR Section 60.49b(g). [40 CFR 60.49b(g), Minn. R. 7011.0565]

EQUI0000000053 EU005

Obtain and maintain fuel receipts from the fuel oil supplier that certify that the oil meets the definition of distillate oil as defined in 40 CFRSection 60.41b, and the sulfur content of the fuel oil. [40 CFR 60.49b(r)(1), Minn. R. 7011.0565]

EQUI0000000053 EU005

Particulate Matter : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of the chip prsteaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 5, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during thetest pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.300Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

EQUI0000000053 EU005

PM < 10 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre‐steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA inthe performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained duringthe test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000053 EU005

PM < 2.5 micron : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of chip pre‐steaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 201A and 202, or other method approved by MPCA inthe performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained duringthe test pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R7007.3000]

EQUI0000000053 EU005

Sulfuric Acid Mist : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date of the chip presteaming bin, to measure emissions. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, and as identified in Appendix D of this permit, using EPA Reference Method 8, or other method approved by MPCA in the performance test plan approval. Process throughput limits will be defined by the maximum achievable operating rate sustained during thetest pursuant to Minn. R. 7017.2025, subp. 3(C). [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

EQUI0000000053 EU005

Particulate Matter: The Permittee shall submit a test frequency plan for Particulate Matter: Due 60 calendar days after Initial PerformanceTest Date for Particulate Matter emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000053 EU005

PM < 10 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 10 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 10 microns. The plan shall specify a testing frequency based on the test data and MPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon writtenapproval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000053 EU005

PM < 2.5 micron: The Permittee shall submit a test frequency plan for Particulate Matter < 2.5 microns: Due 60 calendar days after Initial Performance Test Date for Particulate Matter < 2.5 microns emissions. The plan shall specify a testing frequency based on the test data andMPCA guidance. Future performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(k)(modeling) and Minn. R. 7007.3000]

EQUI0000000053 EU005

Sulfuric Acid Mist: The Permittee shall submit a test frequency plan for Total Reduced Sulfur: Due 60 calendar days after Initial PerformancTest Date for Total Reduced Sulfur emissions. The plan shall specify a testing frequency based on the test data and MPCA guidance. Futureperformance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval of the MPCA. [Minn. R. 7017.2020, subp. 1, Title I Condition: 40 CFR 52.21(j)(BACT) and Minn. R. 7007.3000]

EQUI0000000071 MR004

The CEMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Facility to meet all applicable requirements. [Minn. R. 7017.1010]

EQUI0000000071 MR004

Sulfur Dioxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 60,subp. D, Minn. R. 7017.1010, subp 1]

EQUI0000000071 MR004

Installation Notification: due 60 days before installing the continuous emissions monitoring system. The notification shall include plans anddrawings of the system. [Minn. R. 7017.1040, subp. 1]

EQUI0000000071 MR004

Relative Accuracy Test Audit (RATA) Results Summary: due 30 days after end of each calendar quarter in which a RATA was conducted. [Minn. R. 7017.1180, subp. 3]

EQUI0000000071 MR004

Cylinder Gas Audit (CGA) Results Summary: due 30 days after end of each calendar quarter in which a CGA was conducted. [Minn. R. 7017.1180, subp. 1]

EQUI0000000071 MR004

CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. [40 CFR 60.13(b), Minn. R. 7017.1050, subp. 1]

EQUI0000000071 MR004

Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by thecommissioner. [40 CFR 60.7(a)(5), Minn. R. 7017.1060, subp. 1‐3, Minn. R. 7017.1080]

EQUI0000000071 MR004

Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start‐up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether onot a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]

EQUI0000000071 MR004

Monitoring Data: All data points collected by a CEMS shall be used to calculate individual hourly emission averages unless another applicable requirement requires more frequent averaging. In order for an hour of data to be considered, it must contain the following minimum number of data points: A. four data points, equally spaced, if the emission unit operated during the entire hour; B. two data points, at least 15 minutes apart, during periods of monitor calibration or routine maintenance; C. one data point if the emission unit operated for 15 minutes or less during the hour. [Minn. R. 7017.1160, subps. 1‐2]

EQUI0000000071 MR004

QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unlesthe Commissioner gives written approval to exclude specific spare parts from the list. [40 CFR pt. 60, Appendix F, 3, Minn. R. 7017.1170, subp. 2]

EQUI0000000071 MR004

CEMS QA/QC: The owner or operator of an affected facility is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each CEMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F]

EQUI0000000071 MR004

CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two timesthe limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section 4.3.1 shall be used to determine out‐of‐control periods for CEMS. [40 CFR 60.13(d)(1), 40 CFR pt. 60, Appendix F, 4.1, Minn. R. 7017.1170, subp. 3]

EQUI0000000071 MR004

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [40 CFR 60.7(f), Minn. R. 7017.1130]

EQUI0000000071 MR004

CEMS Monitor Design: Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in eac15‐minute period. [40 CFR 60.13(e)(2)]

EQUI0000000071 MR004

The Permittee shall conduct a cylinder gas audit : Due semiannually (end of every second QA operating quarter in which there are at least 168 unit operating hours) except that a CGA is not required during any quarter in which a RATA was performed. The initial CGA must be performed within 180 days following certification of the CEMS. The CGAs shall be conducted according to the procedures outlined in MinnR. 7017.1170, subp 4a(A). If the monitored emission unit is not in operation on the CGA due date, the owner or operator has a grace periodof 168 operating hours to perform the CGA. [Minn. R. 7017.1170, subp. 4a]

EQUI0000000071 MR004

The Permittee shall conduct a relative accuracy test audit : Due annually (end of every fourth QA operating quarter). RATAs shall be conducted and frequency may be reduced according to the procedures outlined in Minn. R. 7017.1170, subp. 5a. If the monitored emissionunit is not in operation on the RATA due date, the owner or operator has a grace period of 720 operating hours to perform the RATA. [MinR. 7017.1170, subp. 5a]

EQUI0000000076 MR044


EQUI0000000076 MR044

Oxygen: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1010, subp. 1]

EQUI0000000076 MR044


EQUI0000000076 MR044

CEMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. [Minn. R. 7017.1050, subp. 1]

EQUI0000000076 MR044

Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by thecommissioner. [Minn. R. 7017.1060, subp. 1‐3, Minn. R. 7017.1080]

EQUI0000000076 MR044

Continuous Operation: CEMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start‐up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether onot a numerical emission limit applies during these periods. A CEMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]

EQUI0000000076 MR044

QA Plan: Develop and implement a written quality assurance plan that covers each CEMS. The plan shall be on site and available for inspection within 30 days after monitor certification. The plan shall contain all of the information required by 40 CFR Part 60, Appendix F, Section 3. The plan shall include the manufacturer's spare parts list for each CEMS and require that those parts be kept at the facility unlesthe Commissioner gives written approval to exclude specific spare parts from the list. [Minn. R. 7017.1170, subp. 2]

EQUI0000000076 MR044

CEMS Daily Calibration Drift Test: Check the zero (low level value between 0 and 20 percent of span value) and span (50 to 100 percent of span value) calibration drifts at least once daily. The zero and span must, at a minimum, be adjusted whenever the drift exceeds two timesthe limit specified in 40 CFR pt. 60, Appendix B. 40 CFR pt. 60, Appendix F, Section 4.3.1 shall be used to determine out‐of‐control periods for CEMS. [Minn. R. 7017.1170, subp. 3]

EQUI0000000076 MR044

Recordkeeping: The owner or operator must retain records of all CEMS monitoring data and support information for a period of five years from the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R. 7017.1130]

EQUI0000000076 MR044

The Permittee must install, certify, operate and maintain continuous emission monitoring systems for oxygen according to the procedures 40 CFR Section 63.7525(a)(1)‐(7). [40 CFR 63.7525(a), Minn. R. 7011.7050]

EQUI0000000076 MR044


EQUI0000000076 MR044

Install the oxygen CEMS by January 31, 2016. The CO and oxygen levels shall be monitored at the same location at the outlet of the boiler. [40 CFR 63.7525(a)(1)]

EQUI0000000076 MR044

The Permittee must install, certify, operate, and maintain an oxygen analyzer according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the site‐specific monitoring plan developed according to 40 CFR Section 63.7505(d),and the requirements in 40 CFR Sections 63.7540(a)(8) and 63.7525(a). [40 CFR 63.7525(a)(2), Minn. R. 7011.7050]

EQUI0000000076 MR044

Complete a minimum of one cycle of CO and oxygen CEMS operation (sampling, analyzing, and data recording) for each successive 15‐minute period. Collect CO and oxygen data concurrently. Collect at least four CO and oxygen CEMS data values representing the four 15‐minute periods in an hour, or at least two 15‐minute data values during an hour when CEMS calibration, quality assurance, or maintenanceactivities are being performed. [40 CFR 63.7525(a)(3), Minn. R. 7011.7050]

EQUI0000000076 MR044

CEMS O&M. The Permittee shall maintain and operate the oxygen CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the oxygen CEMS equipment readily available. [40 CFR 63.8(c)(1), MinnR. 7017.1010]

EQUI0000000076 MR044

CEMS Representative Location. Install CEMS such that representative measurements of emissions or process parameters from the source are obtained. In addition, the CEMS shall be located according to procedures contained in the applicable performance specifications of 40 CFR pt. 60, Appendix B. [40 CFR 63.8(c)(2)and (e), Minn. R. 7017.1010]

EQUI0000000076 MR044

CEMS Monitor Design. Each CEMS shall be designed to complete a minimum of one cycle of sampling, analyzing, and data recording in eac15 minute period. [40 CFR 63.8(c)(4)(ii), Minn. R. 7017.1010]

EQUI0000000076 MR044

The Permittee shall conduct a cylinder gas audit : Due by the end of each three of four calendar quarters but no more than three quarters succession. A CGA is not required during any calendar quarter in which a RATA was performed. [40 CFR pt. 60, Appendix F, 5.1.2, Minn. R. 7017.1170, subp. 4a]

EQUI0000000076 MR044

The Permittee shall conduct a relative accuracy test audit : Due one of each four calendar quarters. [40 CFR pt. 60, Appendix F, 5.1.1]

EQUI0000000076 MR044


EQUI0000000076 MR044


EQUI0000000107 MR027


EQUI0000000107 MR027

Carbon Monoxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt.63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1010, subp 1]

EQUI0000000107 MR027


EQUI0000000107 MR027


EQUI0000000107 MR027


EQUI0000000107 MR027


EQUI0000000107 MR027


EQUI0000000107 MR027


EQUI0000000107 MR027


EQUI0000000107 MR027

The Permittee must install, certify, operate and maintain a continuous emission monitoring system for CO according to the procedures in 4CFR Section 63.7525(a)(1)‐(7). [40 CFR 63.7525(a), Minn. R. 7011.7050]

EQUI0000000107 MR027


EQUI0000000107 MR027

Install the CO CEMS by January 31, 2016. The CO and oxygen levels shall be monitored at the same location at the outlet of the boiler. [40 CFR 63.7525(a)(1)]

EQUI0000000107 MR027

The Permittee must install, certify, operate, and maintain a CO CEMS according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the Site‐Specific Monitoring Plan developed according to 40 CFR Section 63.7505(d)and the requirements in 40 CFR Sections 63.7540(a)(8) and 63.7525(a). Any boiler that has a CO CEMS that is compliant with Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, a Site‐Specific Monitoring Plan developed according to 40 CFR Section 63.7505(d), and the requirements in in 40 CFR Sections 63.7540(a)(8) and 63.7525(a) must use the CO CEMS to comply with the applicable alternative CO CEMS emission standard listed in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR 63.7525(a)(2), Minn. R. 7011.7050]

EQUI0000000107 MR027

The Permittee must install, certify, operate, and maintain the CO CEMS according to the following requirements: ‐ The Permittee must conduct a performance evaluation of each CO CEMS according to the requirements in 40 CFR Section 63.8(e) and according to PerformancSpecification 4, 4A, or 4B at 40 CFR part 60, Appendix B. ‐ During each relative accuracy test run of the CO CEMS, the Permittee must collecemission data for CO concurrently (or within a 30‐ to 60‐minute period) by both the CO CEMS and by EPA Reference Method 10, 10A, or 10B. The relative accuracy testing must be at representative operating conditions. ‐ The Permittee must follow the quality assurance procedures of Procedure 1 of 40 CFR pt. 60, Appendix F. The measurement span value of the CO CEMS must be two times the applicable Cemission limit, expressed as a concentration. ‐ Any CO CEMS that does not comply with 40 CFR Section 63.7525(a) cannot be used to meetany requirement in 40 CFR pt. 63, subp. DDDDD to demonstrate compliance a CO emission limit listed in 40 CFR pt. 63, subp. DDDDD, Table2. ‐ Complete the initial performance evaluation no later than July 29, 2016. [40 CFR 63.7525(a)(2)(i)‐(v), Minn. R. 7011.7050]

EQUI0000000107 MR027


EQUI0000000107 MR027

Reduce the CO CEMS data as specified in 40 CFR Section 63.8(g)(2). [40 CFR 63.7525(a)(4), Minn. R. 7011.7050]

EQUI0000000107 MR027

Calculate one‐hour arithmetic averages, corrected to 3 percent oxygen from each hour of CO CEMS data in parts per million CO concentration. The one‐hour arithmetic averages required shall be used to calculate the 30‐day or 10‐day rolling average emissions. Use Equation 19‐19 in Section 12.4.1 of Method 19 of 40 CFR pt. 60, Appendix A‐7 for calculating the average CO concentration from the hourlyvalues. [40 CFR 63.7525(a)(5), Minn. R. 7011.7050]

EQUI0000000107 MR027


EQUI0000000107 MR027

For purposes of collecting CO data, operate the CO CEMS as specified in 40 CFR Section 63.7535(b). The Permittee must use all the data collected during all periods in calculating data averages and assessing compliance, except that the Permittee must exclude certain data as specified in 40 CFR Section 63.7535(c). Periods when CO data are unavailable may constitute monitoring deviations as specified in 40 CFR Section 63.7535(d). [40 CFR 63.7525(a)(6), Minn. R. 7011.7050]

EQUI0000000107 MR027


EQUI0000000107 MR027

CEMS O&M. The Permittee shall maintain and operate the CO CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the CO CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]

EQUI0000000107 MR027


EQUI0000000107 MR027


EQUI0000000107 MR027


EQUI0000000107 MR027


EQUI0000000108 MR030

The COMS requirements listed in this permit outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R. 7017.1010]

EQUI0000000108 MR030

Opacity: Emissions Monitoring: The Permittee shall use a COMS to measure emissions from EQUI 52 (Rotary Lime Kiln). [40 CFR pt. 60, SubBBa, Minn. R. 7017.1006, Minn. R. 7017.1010, subp 1]

EQUI0000000108 MR030

NSPS COMS Performance Evaluation: Due before the performance test required under 40 CFR Section 60.8 is conducted as specified in Performance Specification 1, Appendix B of 40 CFR pt. 60. Otherwise, the Permittee shall conduct a performance evaluation of the COMS during any performance test required under Section 60.8 or within 30 days thereafter. The Permittee shall conduct COMS performance evaluations at such other times as may be required by the Administrator under Section 114 of the Clean Air Act. (Provided all applicable deadlines are met, the performance evaluation may be completed at the same time as the Minn. R. required Certification Test.) Sappi completed this requirement on October 16, 2013. [40 CFR 60.13(c), Minn. R. 7017.1010]

EQUI0000000108 MR030

NSPS COMS Performance Evaluation Report: Due 10 days before the performance test required under 40 CFR Section 60.8 and as describein Section 60.11(e)(5) if the Permittee elects to submit COMS data In lieu of the performance test to demonstrate compliance with the opacity standard. If instead the performance evaluation is completed during the performance test or within 30 days thereafter as allowed Section 60.13(c), the report is due within 60 days of completion. [40 CFR 60.13(c)(1) & (2), Minn. R. 7017.1010]

EQUI0000000108 MR030

COMS QA/QC. The Permittee is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each COMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.a, 40 CFR pt. 60, Appendix F, Minn. R. 7017.1010]

EQUI0000000108 MR030

Installation Notification: due 60 days before installing the continuous Opacity monitoring system. The notification shall include plans and drawings of the system. [Minn. R. 7017.1040, subp. 1]

EQUI0000000108 MR030

Monitoring Data: All COMS data must be reduced to six‐minute averages. A six minute average is valid only if it contains data from at least five minutes within the averaging period. COMS data shall be reduced and calculated as outlined in Minn. R. 7017.1200, subp. 3. [Minn. R. 7017.1200, subp. 1‐3]

EQUI0000000108 MR030

Monitoring Data: All COMS data must be reduced to six‐minute averages. Six‐minute opacity averages shall be calculated from 36 or more data points equally spaced over each 6‐minute period. [40 CFR 60.13(e)(1), 40 CFR 60.13(h)(2), Minn. R. 7017.1200, subp. 1‐3]

EQUI0000000108 MR030


EQUI0000000108 MR030

Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start‐up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether onot a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 60.13(e), 40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]

EQUI0000000108 MR030

QA Plan: the facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 ‐ Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R. 7017.1215]

EQUI0000000108 MR030

COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low‐level) and upscale (high‐level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out‐of‐control periods for COMS. [40 CFR 60.13(d)(1Minn. R. 7017.1210, subp. 2]

EQUI0000000108 MR030

COMS Calibration Error Audit Results Summary: due 30 days after end of each calendar quarter in which the COMS calibration error audit was completed. [Minn. R. 7017.1220]

EQUI0000000108 MR030

COMS Calibration Error Audit Notification: due 30 days before the COMS Calibration Error Audit. [Minn. R. 7017.1180, subp. 2]

EQUI0000000108 MR030

Recordkeeping: The owner or operator must retain records of all COMS monitoring data and support information for a period of five yearsfrom the date of the monitoring sample, measurement or report. Records shall be kept at the source. [Minn. R. 7017.1130]

EQUI0000000108 MR030

Notification of Compliance Status: Due 30 days before performance test required by 40 CFR Section 60.8 if COMS data results will be used lieu of 40 CFR, Appendix A, Method 9 observation data to determine compliance with the opacity standard as allowed by 40 CFR Section 60.11(e)(5). [40 CFR 60.7(a)(7)]

EQUI0000000108 MR030

COMS Certification/Recertification Test: due 90 days after the first excess emissions report required for the CEMS or any change which invalidates the monitor's certification status as outlined in Minn. R. 7017.1050, subp. 2. [Minn. R. 7017.1050, subp. 1]

EQUI0000000108 MR030

The Permittee shall conduct COMS calibration error audit : Due quarterly according to Procedure 3 of 40 CFR Pt. 60, Appendix F. Quarterly performance audits will include: optical alignment, calibration error, and zero compensation. Sources that achieve quality assured data forfour consecutive quarters may reduce audit frequency to semi‐annually. If an audit is failed, the source must resume quarterly audits to demonstrate performance again for four consecutive quarters. [Minn. R. 7017.1215]

EQUI0000000108 MR030

The Permittee shall perform zero alignment as described in Procedure 3, section 10.3 of 40 CFR Pt. 60, Appendix F. [40 CFR pt. 60, AppendiB(7), Minn. R. 7017.1215]

EQUI0000000110 MR043

Carbon Dioxide: Monitoring: The Permittee shall use a CEMS to measure CO2 diluent gas concentratoin from EQUI 53 (Recovery Boiler #10[Minn. R. 7017.1010, subp 1]

EQUI0000000110 MR043


EQUI0000000110 MR043


EQUI0000000110 MR043


EQUI0000000110 MR043


EQUI0000000110 MR043


EQUI0000000110 MR043


EQUI0000000110 MR043


EQUI0000000110 MR043


EQUI0000000110 MR043


EQUI0000000110 MR043


EQUI0000000110 MR043


EQUI0000000110 MR043


EQUI0000000112 MR013

Nitrogen Oxides: Emissions Monitoring: The Permittee shall use a CEMS to measure NOx emissions from EQUI 18 (Power Boiler #8). [Minn.R. 7017.1010, subp 1]

EQUI0000000112 MR013


EQUI0000000112 MR013


EQUI0000000112 MR013


EQUI0000000112 MR013


EQUI0000000112 MR013


EQUI0000000112 MR013


EQUI0000000112 MR013


EQUI0000000112 MR013


EQUI0000000112 MR013


EQUI0000000112 MR013


EQUI0000000112 MR013


EQUI0000000112 MR013


EQUI0000000113 MR014

The COMS requirements listed below outline the typical standards of 40 CFR pt. 60 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R. 7017.1010]

EQUI0000000113 MR014

Opacity: Emissions Monitoring: The Permittee shall use a COMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFR pt. 60, Subp. BB, Minn. R. 7017.1010, subp 1]

EQUI0000000113 MR014


EQUI0000000113 MR014


EQUI0000000113 MR014

Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report due 45 days after Certification Test. The Test Plan and Test Report must be submitted in a format specified by thecommissioner. [Minn. R. 7017.1060, subp. 1‐3, Minn. R. 7017.1080, subp. 1‐4]

EQUI0000000113 MR014


EQUI0000000113 MR014

QA Plan: the facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 ‐ Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R. 7017.1215]

EQUI0000000113 MR014

COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low‐level) and upscale (high‐level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out‐of‐control periods for COMS. [40 CFR 60.13(d)(1Minn. R. 7017.1215]

EQUI0000000113 MR014


EQUI0000000113 MR014


EQUI0000000113 MR014


EQUI0000000113 MR014


EQUI0000000113 MR014


EQUI0000000113 MR014


EQUI0000000113 MR014


EQUI0000000114 MR015


EQUI0000000114 MR015

Nitrogen Oxides: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFRpt. 60, subp. D, Minn. R. 7017.1010, subp 1]

EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000114 MR015


EQUI0000000115 MR016

Sulfur Dioxide: Emissions Monitoring: The Permittee shall use a CEMS to measure SO2 emissions from EQUI 53 (Recovery Boiler #10). [MinR. 7017.1010, subp 1]

EQUI0000000115 MR016


EQUI0000000115 MR016


EQUI0000000115 MR016


EQUI0000000115 MR016


EQUI0000000115 MR016


EQUI0000000115 MR016


EQUI0000000115 MR016


EQUI0000000115 MR016


EQUI0000000115 MR016


EQUI0000000115 MR016


EQUI0000000115 MR016


EQUI0000000115 MR016


EQUI0000000116 MR017


EQUI0000000116 MR017

Sulfur ‐ Total Reduced including H2S: Emissions Monitoring: The owner or operator shall use a CEMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFR pt. 60, subp. BB, Minn. R. 7017.1010, subp 1]

EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000116 MR017


EQUI0000000117 MR018

Carbon Monoxide: Emissions Monitoring: The Permittee shall use a CEMS to measure CO emissions from EQUI 53 (Recovery Boiler #10). [Minn. R. 7017.1010, subp 1]

EQUI0000000117 MR018


EQUI0000000117 MR018


EQUI0000000117 MR018


EQUI0000000117 MR018


EQUI0000000117 MR018


EQUI0000000117 MR018


EQUI0000000117 MR018


EQUI0000000117 MR018


EQUI0000000117 MR018


EQUI0000000117 MR018


EQUI0000000117 MR018


EQUI0000000117 MR018


EQUI0000000118 MR019


EQUI0000000118 MR019

Oxygen: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 53 (Recovery Boiler #10). [40 CFR pt. 60, subp. BB, Minn. R. 7017.1010, subp 1]

EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000118 MR019


EQUI0000000119 MR020

Sulfur Dioxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 2 (Power Boiler #7). [Minn. R. 7017.1010, subp 1]

EQUI0000000119 MR020


EQUI0000000119 MR020


EQUI0000000119 MR020


EQUI0000000119 MR020


EQUI0000000119 MR020


EQUI0000000119 MR020


EQUI0000000119 MR020


EQUI0000000119 MR020


EQUI0000000119 MR020


EQUI0000000119 MR020


EQUI0000000119 MR020


EQUI0000000119 MR020


EQUI0000000120 MR021


EQUI0000000120 MR021

Sulfur ‐ Total Reduced including H2S: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 52 (Rotary Lime Kiln). [40 CFR pt. 60, subp. BBa, Minn. R. 7017.1010, subp 1]

EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000120 MR021


EQUI0000000121 MR022


EQUI0000000121 MR022

Oxygen: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 52 (Rotary Lime Kiln). [40 CFR pt. 60, subpBBa, Minn. R. 7017.1010, subp 1]

EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000121 MR022


EQUI0000000122 MR023


EQUI0000000122 MR023

Oxygen: Monitoring: The owner or operator shall use a CEMS to measure O2 diluent gas concentration from EQUI 2 (Power Boiler #7). [40 CFR pt. 63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1006, Minn. R. 7017.1010, subp 1]

EQUI0000000122 MR023


EQUI0000000122 MR023


EQUI0000000122 MR023


EQUI0000000122 MR023


EQUI0000000122 MR023


EQUI0000000122 MR023


EQUI0000000122 MR023


EQUI0000000122 MR023

Emissions Monitoring: The Permittee shall use an oxygen CEMS to measure oxygen emissions from EQUI2. [40 CFR pt. 63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1006]

EQUI0000000122 MR023

The Permittee must install, certify, operate and maintain continuous emission monitoring systems for oxygen according to the procedures 40 CFR Section 63.7525(a)(1)‐(7). [40 CFR 63.7525(a), Minn. R. 7011.7050]

EQUI0000000122 MR023

The Permittee must install, certify, operate, and maintain an oxygen analyzer according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the site‐specific monitoring plan developed according to 40 CFR Section 63.7505(d),and the requirements in 40 CFR Sections 63.7540(a)(8) and 63.7525(a). [40 CFR 63.7525(a)(2), Minn. R. 7011.7050]

EQUI0000000122 MR023


EQUI0000000122 MR023

CEMS O&M. The Permittee shall maintain and operate the oxygen CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the oxygen CEMS equipment readily available. [40 CFR 63.8(c)(1), MinnR. 7017.1010]

EQUI0000000122 MR023


EQUI0000000122 MR023


EQUI0000000122 MR023


EQUI0000000122 MR023


EQUI0000000122 MR023


EQUI0000000122 MR023


EQUI0000000123 MR025


EQUI0000000123 MR025

Carbon Monoxide: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 2 (Power Boiler #7). [40 CFR pt.63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1006, Minn. R. 7017.1010, subp 1]

EQUI0000000123 MR025


EQUI0000000123 MR025


EQUI0000000123 MR025


EQUI0000000123 MR025


EQUI0000000123 MR025


EQUI0000000123 MR025


EQUI0000000123 MR025


EQUI0000000123 MR025

The Permittee must install, certify, operate and maintain a continuous emission monitoring system for CO according to the procedures in 4CFR Section 63.7525(a)(1)‐(7). [40 CFR 63.7525(a), Minn. R. 7011.7050]

EQUI0000000123 MR025


EQUI0000000123 MR025

Install the CO CEMS by January 31, 2016. The CO and oxygen levels shall be monitored at the same location at the outlet of the boiler. [40 CFR 63.7525(a)(1)]

EQUI0000000123 MR025

The Permittee must install, certify, operate, and maintain a CO CEMS according to the applicable procedures under Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, the Site‐Specific Monitoring Plan developed according to 40 CFR Section 63.7505(d)and the requirements in 40 CFR Sections 63.7540(a)(8) and 63.7525(a). Any boiler that has a CO CEMS that is compliant with Performance Specification 4, 4A, or 4B at 40 CFR pt. 60, Appendix B, a Site‐Specific Monitoring Plan developed according to 40 CFR Section 63.7505(d), and the requirements in in 40 CFR Sections 63.7540(a)(8) and 63.7525(a) must use the CO CEMS to comply with the applicable alternative CO CEMS emission standard listed in 40 CFR pt. 63, subp. DDDDD, Table 2. [40 CFR 63.7525(a)(2), Minn. R. 7011.7050]

EQUI0000000123 MR025

The Permittee must install, certify, operate, and maintain the CO CEMS according to the following requirements: ‐ The Permittee must conduct a performance evaluation of each CO CEMS according to the requirements in 40 CFR Section 63.8(e) and according to PerformancSpecification 4, 4A, or 4B at 40 CFR part 60, Appendix B. ‐ During each relative accuracy test run of the CO CEMS, the Permittee must collecemission data for CO concurrently (or within a 30‐ to 60‐minute period) by both the CO CEMS and by EPA Reference Method 10, 10A, or 10B. The relative accuracy testing must be at representative operating conditions. ‐ The Permittee must follow the quality assurance procedures of Procedure 1 of 40 CFR pt. 60, Appendix F. The measurement span value of the CO CEMS must be two times the applicable Cemission limit, expressed as a concentration. ‐ Any CO CEMS that does not comply with 40 CFR Section 63.7525(a) cannot be used to meetany requirement in 40 CFR pt. 63, subp. DDDDD to demonstrate compliance a CO emission limit listed in 40 CFR pt. 63, subp. DDDDD, Table2. ‐ Complete the initial performance evaluation no later than July 29, 2016. [40 CFR 63.7525(a)(2)(i)‐(v), Minn. R. 7011.7050]

EQUI0000000123 MR025


EQUI0000000123 MR025

Reduce the CO CEMS data as specified in 40 CFR Section 63.8(g)(2). [40 CFR 63.7525(a)(4), Minn. R. 7011.7050]

EQUI0000000123 MR025

Calculate one‐hour arithmetic averages, corrected to 3 percent oxygen from each hour of CO CEMS data in parts per million CO concentration. The one‐hour arithmetic averages required shall be used to calculate the 30‐day or 10‐day rolling average emissions. Use Equation 19‐19 in Section 12.4.1 of Method 19 of 40 CFR pt. 60, Appendix A‐7 for calculating the average CO concentration from the hourlyvalues. [40 CFR 63.7525(a)(5), Minn. R. 7011.7050]

EQUI0000000123 MR025


EQUI0000000123 MR025

For purposes of collecting CO data, operate the CO CEMS as specified in 40 CFR Section 63.7535(b). The Permittee must use all the data collected during all periods in calculating data averages and assessing compliance, except that the Permittee must exclude certain data as specified in 40 CFR Section 63.7535(c). Periods when CO data are unavailable may constitute monitoring deviations as specified in 40 CFR Section 63.7535(d). [40 CFR 63.7525(a)(6), Minn. R. 7011.7050]

EQUI0000000123 MR025


EQUI0000000123 MR025

CEMS O&M. The Permittee shall maintain and operate the CO CEMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the CO CEMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]

EQUI0000000123 MR025


EQUI0000000123 MR025


EQUI0000000123 MR025


EQUI0000000123 MR025


EQUI0000000135 MR001

The COMS requirements listed below outline the typical standards of 40 CFR pt. 63 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of the Permittee to meet all applicable requirements. [Minn. R. 7017.1010]

EQUI0000000135 MR001

Emissions Monitoring: The Permittee shall use a continuous opacity monitor to measure opacity emissions from EQUI2 (Power Boiler #7). [40 CFR pt. 63, subp. DDDDD, Minn. R. 7011.7050, Minn. R. 7017.1006]

EQUI0000000135 MR001

Each COMS must be installed, operated, and maintained according to Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR 63.7525(c)(1), Minn. R. 7011.7050]

EQUI0000000135 MR001

The Permittee must conduct a performance evaluation of each COMS according to the requirements in 40 CFR Section 63.8(e) and accordito Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR 63.7525(c)(2), Minn. R. 7011.7050]

EQUI0000000135 MR001

As specified in 40 CFR Section 63.8(c)(4)(i), each COMS must complete a minimum of one cycle of sampling and analyzing for each successi10‐second period and one cycle of data recording for each successive 6‐minute period. [40 CFR 63.7525(c)(3), Minn. R. 7011.7050]

EQUI0000000135 MR001

The COMS data must be reduced as specified in 40 CFR Section 63.8(g)(2). [40 CFR 63.7525(c)(5), Minn. R. 7011.7050]

EQUI0000000135 MR001

The Permittee must include in the Site‐Specific Monitoring Plan procedures and acceptance criteria for operating and maintaining each COMS according to the requirements in 40 CFR Section 63.8(d). At a minimum, the monitoring plan must include a daily calibration drift assessment, a quarterly performance audit, and an annual zero alignment audit of each COMS. [40 CFR 63.7525(c)(5), Minn. R. 7011.7050]

EQUI0000000135 MR001

The Permittee must operate and maintain each COMS according to the requirements in the monitoring plan and the requirements of 40 CFSection 63.8(e). The Permittee must identify periods the COMS is out of control including any periods that the COMS fails to pass a daily calibration drift assessment, a quarterly performance audit, or an annual zero alignment audit. Any 6‐minute period for which the monitoring system is out of control and data are not available for a required calculation constitutes a deviation from the monitoring requirements. [40 CFR 63.7525(c)(6), Minn. R. 7011.7050]

EQUI0000000135 MR001

The Permittee must determine and record all the 6‐minute averages (and daily block averages as applicable) collected for periods during which the COMS is not out of control. [40 CFR 63.7525(c)(7), Minn. R. 7011.7050]

EQUI0000000135 MR001

COMS O&M. The Permittee shall maintain and operate the COMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the COMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]

EQUI0000000135 MR001


EQUI0000000135 MR001


EQUI0000000135 MR001


EQUI0000000135 MR001

Continuous Operation: COMS must be operated and data recorded during all periods of emission unit operation including periods of emission unit start‐up, shutdown, or malfunction except for periods of acceptable monitor downtime. This requirement applies whether onot a numerical emission limit applies during these periods. A COMS must not be bypassed except in emergencies where failure to bypass would endanger human health, safety, or plant equipment. [40 CFR 64.7(c), Minn. R. 7017.0200, Minn. R. 7017.1090]

EQUI0000000135 MR001

QA Plan: The facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 ‐ Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R. 7017.1215]

EQUI0000000135 MR001

COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low‐level) and upscale (high‐level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out‐of‐control periods for COMS. [Minn. R. 7017.121

EQUI0000000135 MR001


EQUI0000000135 MR001


EQUI0000000135 MR001


EQUI0000000135 MR001


EQUI0000000135 MR001


EQUI0000000135 MR001

The Permittee shall perform zero alignment as described in Procedure 3, section 10.3 of 40 CFR Pt. 60, Appendix F. [Minn. R. 7017.1215]

EQUI0000000136 MR002

The COMS requirements listed below outline the typical standards of 40 CFR pt. 60 and 40 CFR pt. 63 when combined with Minn. R. Additional monitoring requirements may also apply to the Facility based on this combination of standards and it is the responsibility of thePermittee to meet all applicable requirements. [Minn. R. 7017.1010]

EQUI0000000136 MR002

Opacity: Emissions Monitoring: The Permittee shall use a COMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 60, Subp.D, Minn. R. 7017.1010, subp 1]

EQUI0000000136 MR002

Emissions Monitoring: The Permittee shall use a continuous opacity monitor to measure opacity emissions from EQUI4. [40 CFR pt. 63, subDDDDD, Minn. R. 7011.7050, Minn. R. 7017.1006]

EQUI0000000136 MR002

Each COMS must be installed, operated, and maintained according to Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR 63.7525(c)(1), Minn. R. 7011.7050]

EQUI0000000136 MR002

The Permittee must conduct a performance evaluation of each COMS according to the requirements in 40 CFR Section 63.8(e) and accordito Performance Specification 1 at 40 CFR pt. 60, Appendix B. [40 CFR 63.7525(c)(2), Minn. R. 7011.7050]

EQUI0000000136 MR002

As specified in 40 CFR Section 63.8(c)(4)(i), each COMS must complete a minimum of one cycle of sampling and analyzing for each successi10‐second period and one cycle of data recording for each successive 6‐minute period. [40 CFR 63.7525(c)(3), Minn. R. 7011.7050]

EQUI0000000136 MR002

The COMS data must be reduced as specified in 40 CFR Section 63.8(g)(2). [40 CFR 63.7525(c)(5), Minn. R. 7011.7050]

EQUI0000000136 MR002

The Permittee must include in the Site‐Specific Monitoring Plan procedures and acceptance criteria for operating and maintaining each COMS according to the requirements in 40 CFR Section 63.8(d). At a minimum, the monitoring plan must include a daily calibration drift assessment, a quarterly performance audit, and an annual zero alignment audit of each COMS. [40 CFR 63.7525(c)(5), Minn. R. 7011.7050]

EQUI0000000136 MR002

The Permittee must operate and maintain each COMS according to the requirements in the monitoring plan and the requirements of 40 CFSection 63.8(e). The Permittee must identify periods the COMS is out of control including any periods that the COMS fails to pass a daily calibration drift assessment, a quarterly performance audit, or an annual zero alignment audit. Any 6‐minute period for which the monitoring system is out of control and data are not available for a required calculation constitutes a deviation from the monitoring requirements. [40 CFR 63.7525(c)(6), Minn. R. 7011.7050]

EQUI0000000136 MR002

The Permittee must determine and record all the 6‐minute averages (and daily block averages as applicable) collected for periods during which the COMS is not out of control. [40 CFR 63.7525(c)(7), Minn. R. 7011.7050]

EQUI0000000136 MR002

COMS O&M. The Permittee shall maintain and operate the COMS in a manner consistent with good air pollution control practices. The Permittee must keep the necessary parts for routine repairs of the COMS equipment readily available. [40 CFR 63.8(c)(1), Minn. R. 7017.1010]

EQUI0000000136 MR002

COMS QA/QC. The Permittee is subject to the performance specifications listed in 40 CFR pt. 60, Appendix B and shall operate, calibrate, and maintain each COMS according to the QA/QC procedures in 40 CFR pt. 60, Appendix F as amended and maintain a written QA/QC program available in a form suitable for inspection. [40 CFR 60.13(a), 40 CFR pt. 60, Appendix F, Minn. R. 7017.1010]

EQUI0000000136 MR002


EQUI0000000136 MR002


EQUI0000000136 MR002


EQUI0000000136 MR002


EQUI0000000136 MR002


EQUI0000000136 MR002

QA Plan: The facility owner or operator must conduct quality assurance and quality control as specified in Procedure 3 ‐ Quality Assurance Requirements for Continuous Opacity Monitoring Systems at Stationary Sources, 40 CFR Pt. 60, Appendix F. [40 CFR 64.3(b)(3), Minn. R. 7017.1215]

EQUI0000000136 MR002

COMS Daily Calibration Drift Test: The Calibration Drift shall be quantified and recorded at zero (low‐level) and upscale (high‐level) calibration drift at least once daily according to the procedures listed in 40 CFR Section 60.13(d)(2) and pt. 60, Appendix B, PS 1. The zero and upscale calibration levels must be determined using the span value specified in the applicable requirement. If the applicable requirement does not specify a span value, a span value of 60, 70, or 80 percent opacity must be used unless an alternative span value is approved by the commissioner. 40 CFR pt. 60, Appendix F, shall be used to determine out‐of‐control periods for COMS. [40 CFR 60.13(d)(1Minn. R. 7017.1215]

EQUI0000000136 MR002


EQUI0000000136 MR002


EQUI0000000136 MR002


EQUI0000000136 MR002


EQUI0000000136 MR002


EQUI0000000136 MR002


EQUI0000000136 MR002


EQUI0000000137 MR003


EQUI0000000137 MR003

Nitrogen Oxides: Emissions Monitoring: The Permittee shall use a CEMS to measure emissions from EQUI 4 (Power Boiler #9). [40 CFR pt. 6subp. D, Minn. R. 7017.1010, subp 1]

EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000137 MR003


EQUI0000000138 MR012

Oxygen: Monitoring: The Permittee shall use a CEMS to measure O2 diluent gas concentration from EQUI 18 (Power Boiler #8). [Minn. R. 7017.1010, subp 1]

EQUI0000000138 MR012


EQUI0000000138 MR012


EQUI0000000138 MR012


EQUI0000000138 MR012

Certification Test Plan due 30 days before Certification Test. Certification Test Pretest Meeting due 7 days before Certification Test. Certification Test Report ‐ Microfiche Copy due 105 days after Certification Test. Certification Test Report due 45 days after Certification Test. The Notification, Test Plan, and Test Report may be submitted in alternate format as allowed by Minn. R. 7017.1120, subp. 2. [Minn. 7017.1060, subp. 1‐3, Minn. R. 7017.1080, subp. 1‐4]

EQUI0000000138 MR012


EQUI0000000138 MR012


EQUI0000000138 MR012


EQUI0000000138 MR012


EQUI0000000138 MR012


EQUI0000000138 MR012


EQUI0000000138 MR012


EQUI0000000138 MR012


EQUI0000000261 927

Methanol <= 0.28 tons per year (tank is equipped with a conservation vent). [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000

EQUI0000000261 927

Inspection: due before end of each calendar quarter starting 9/25/1998. The Permittee shall inspect the conservation vent on a quarterly basis to ensure that the vent is working properly. The results of the inspection shall be recorded and maintained on site. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

EQUI0000000290 EU089

Total Particulate Matter <= 0.4 pounds per million Btu heat input. The potential to emit from the unit is 0.007 lb/MMBtu due to equipmendesign and allowable fuels. [Minn. R. 7011.0515, subp. 1]

EQUI0000000290 EU089

Opacity <= 20 percent opacity except for one six‐minute period per hour of not more than 60 percent opacity. [Minn. R. 7011.0515, subp. 2

EQUI0000000290 EU089

Allowable Fuel: Natural Gas only, by design. [Minn. R. 7005.0100, subp. 35a]

EQUI0000000290 EU089


EQUI0000000290 EU089

Tune‐Ups. The Permittee must conduct a 5‐year tune‐up of the boiler to demonstrate continuous compliance as specified in 40 CFR Section63.7540(a)(10)(i)‐(vi). Each 5‐year tune‐up must be conducted no more than 61 months after the previous tune‐up. The Permittee may delthe burner inspection specified in 40 CFR Section 63.7540(a)(10)(i) until the next scheduled or unscheduled unit shutdown, but the Permittee must inspect each burner at least once every 72 months. [40 CFR 63.7500(e), 40 CFR 63.7515(d), 40 CFR 63.7540(a)(12), 40 CFR 63, subp. DDDDD(Table 3), Minn. R. 7011.7050]

EQUI0000000290 EU089


EQUI0000000290 EU089

The Permittee shall submit a notification of compliance status : Due 60 calendar days after Demonstration Completion Date according to 4CFR Section 63.9(h)(2)(ii). The Permittee must submit the Notification of Compliance Status before the close of business on the 60th day following the completion of all initial compliance demonstrations for all boilers at the facility according to 40 CFR Section 63.10(d)(2). The Notification of Compliance Status must only contain the information specified in 40 CFR Section 63.7545(e)(1) and (8). The Permittee mustsubmit a signed statement in the Notification of Compliance Status report that indicates that the Permittee conducted a tune‐up of the un[40 CFR 63.7530(d), 40 CFR 63.7545(e), Minn. R. 7011.7050]

EQUI0000000290 EU089

The Permittee shall submit an initial compliance status report : Due before 01/31/2021 according to 40 CFR Section 63.7550(h). The Initial Compliance Status Report must cover the reporting period beginning on January 31, 2016 and ending on December 31, 2020. The Compliance Status Report must contain the information in 40 CFR Section 63.7550(c)(5)(i)‐(iv) and (xiv). [40 CFR 63.7550(b)(1)and (2), 40 Cpt. 63, subp. DDDDD(Table 9), Minn. R. 7011.7050]

EQUI0000000290 EU089

Compliance Status Report: due 31 days after end of each calendar 60 months starting 01/01/2021, according to 40 CFR Section 63.7550(h)The Compliance Status Reports must cover the applicable 5‐year reporting period from January 1 through December 31. The Compliance Status Report must be postmarked or submitted no later than January 31 of the year in which it is due. The Compliance Status Report mustcontain the information in 40 CFR Section 63.7550(c)(5)(i)‐(iv) and (xiv). [40 CFR 63.7550(b)(3)and (4), 40 CFR pt. 63, subp. DDDDD(Table 9)Minn. R. 7011.7050]

EQUI0000000298 EU049


EQUI0000000298 EU049


EQUI0000000298 EU049

The Permittee shall perform proper maintenance of the paper machine so as to prevent excessive amounts of particulate matter from beinemitted from the associated stack/vent (STRU49). [Minn. R. 7007.0800, subp. 4]

EQUI0000000299 EU050


EQUI0000000299 EU050


EQUI0000000299 EU050

The Permittee shall perform proper maintenance of the paper machine so as to prevent excessive amounts of particulate matter from beinemitted from the associated stack/vent (STRU50). [Minn. R. 7007.0800, subp. 4]

EQUI0000000304 EU051

The Permittee must limit organic HAP emissions to the level specified below: ‐ No more than 5 percent of the organic HAP applied for eachmonth; or ‐ No more than 4 percent of the mass of coating materials applied for each month; or ‐ No more than 20 percent of the mass of coating solids applied for each month. These limits apply to the collection of all web coating lines (as defined in 40 CFR 63.3310). [40 CFR 63.3320(b)(1)‐(3), Minn. R. 7011.7358]

EQUI0000000304 EU051

Maintain the following records as applicable on a monthly basis as specified in 40 CFR Sect. 63.10(b)(2) of all measurements as needed to demonstrate compliance, including: 1. Continuous emission monitor data in accordance with 40 CFR Sect. 63.3350(d); 2. Control device ancapture system operating parameter data in accordance with 40 CFR Sect. 63.3350(c), (e), & (f); 3. Organic HAP content data used for demonstrating compliance in accordance with 40 CFR Sect. 63.3360(c); 4. Volatile matter and coating solids content data used for demonstrating compliance with 40 CFR Sect. 63.3360(d); 5. Overall control efficiency determination using capture efficiency and control device destruction or removal efficiency test results in accordance with 40 CFR Sect. 63.3350(e) & (f); 6. Material usage, organic HAP usagevolatile matter usage, and coating solids usage and compliance demonstrations using these data in accordance with 40 CFR Sect. 63.3370(b(d). [40 CFR 63.10(b)(1), 40 CFR 63.3410(a), Minn. R. 7011.7385]

EQUI0000000304 EU051

Determine the organic HAP or volatile matter and coating solids content of the coating materials according to procedures in 40 CFR Section63.3360(c) & (d). If applicable, determine the mass of volatile matter retained in the coated web or otherwise not emitted to the atmosphere according to 40 CFR Section 63.3360(g). [40 CFR 63.3360(a), Minn. R. 7011.7385]

EQUI0000000304 EU051

Determine the organic HAP mass fraction of each coating material "as‐purchased" by following one of the procedures (Method 311, Metho24, or Formulation Data) in 40 CFR Section 63.3360(c)(1)‐(3), and determine the organic HAP mass fraction of each coating material "as‐applied" by following the procedures in 40 CFR Section 63.3360(c)(4). If the organic HAP content values are not determined using the procedures in 40 CFR Section 63.3360(c)(1)‐(3), the Permittee must submit an alternative test method for determining the values for approval by the Administrator in accordance with 40 CFR Section 63.7(f). The recovery efficiency of the test method must be determined foall of the target organic HAP and a correction factor, if necessary, must be applied. [40 CFR 63.3360(c), Minn. R. 7011.7385]

EQUI0000000304 EU051

If you choose to use the volatile organic content as a surrogate for the organic HAP content of coatings, you must determine the as‐purchased volatile organic content and coating solids content of each coating material applied by following the procedures (Method 24 or Formulation Data) in 40 CFR Section 63.3360(d)(1) or (2), and the as‐applied volatile organic content and coating solids content of each coating material by following the procedures of 40 CFR Section 63.3360(d)(3). [40 CFR 63.3360(d), Minn. R. 7011.7385]

EQUI0000000304 EU051

Volatile matter retained in the coated web or otherwise not emitted to the atmosphere ‐ If you choose to take this into account when determining compliance with the emission standards, you must develop a testing protocol to determine the mass of volatile matter retainein the coated web or otherwise not emitted to the atmosphere and submit it to the Administrator for approval with your site‐specific test plan under 40 CFR Section 63.7(f). If you intend to take into account the mass of volatile matter retained in the coated web after curing or drying or otherwise not emitted to the atmosphere and demonstrate compliance according to 40 CFR Section 63.3370(c)(3), (c)(4), or (d), then the protocol must determine the mass of organic HAP retained in the coated web or otherwise not emitted to the atmosphere. Otherwise, compliance must be shown using the volatile organic matter content as a surrogate for the HAP content of the coatings. [40 CF63.3360(g), Minn. R. 7011.7385]

EQUI0000000304 EU051

Demonstrate compliance by one of the following methods: 1. Use of "as‐purchased" compliant coating materials 2. Use of "as‐applied" compliant coating materials 3. Tracking total monthly organic HAP applied 4. Use of a capture system and control device. [40 CFR 63.3370(a), Minn. R. 7011.7385]

EQUI0000000304 EU051

1. Demonstrate, using the procedures in 40 CFR Section 63.3370(b), that each coating material used does not exceed: ‐ 0.04 kg organic HAPper kg coating material as purchased; or ‐ 0.2 kg organic HAP per kg coating solids as purchased. [40 CFR 63.3370(a)(1)&(b), Minn. R. 7011.7358]

EQUI0000000304 EU051

2. Demonstrate that each coating material as‐applied during the month does not exceed: ‐ 0.04 kg organic HAP per kg coating material applied, as determined in accordance with 40 CFR Section 63.3370(c)(1)(i) & (ii); or ‐ 0.20 kg organic HAP per kg coating solids applied, as determined in accordance with 40 CFR Section 63.3370(c)(2)(i) & (ii); or Demonstrate that the monthly average as‐applied organic HAP content of all coating materials applied does not exceed: ‐ 0.04 kg organic HAP per kg coating material as‐applied, as determined in accordance with 40 CFR Section 63.3370(c)(3); or ‐ 0.20 kg organic HAP per kg coating solids as‐applied, as determined in accordance with 40 CFR Section 63.3370(c)(4). [40 CFR 63.3370(a)(2) & (c), Minn. R. 7011.7385]

EQUI0000000304 EU051

3. Demonstrate that the total monthly organic HAP applied does not exceed the calculated limit as determined by 40 CFR Section 63.3370(l)(5), in accordance with the procedures set out in 40 CFR Section 63.3370(d). [40 CFR 63.3370(a)(3), (d) & (l), Minn. R. 7011.7358]

EQUI0000000304 EU051

The Permittee shall submit a submit a semiannual compliance report : Due by 30 days after end of each calendar half‐year for each emissiounit subject to a standard in 40 CFR pt. 63. This may be submitted with the annual Compliance Certification. The report must contain the information listed in 40 CFR Section 63.3400(c)(2). [40 CFR 63.3400(c), Minn. R. 7011.7385]

EQUI0000000315 EU085

Opacity <= 20 percent opacity once operating temperatures have been attained. [Minn. R. 7011.2300, subp. 1]

EQUI0000000315 EU085

Sulfur Dioxide <= 0.50 pounds per million Btu heat input. The potential to emit from the unit is 0.0015 lb/MMBtu due to equipment designand allowable fuel. [Minn. R. 7011.2300, subp. 2(A)]

EQUI0000000315 EU085

Sulfur Dioxide <= 0.0015 pounds per million Btu heat input. This limit is effective on January 31, 2018. [Minn. R. 7011.2300, subp. 2(B)]

EQUI0000000315 EU085

The Permittee shall limit Particulate Matter <= 0.60 grams per horsepower‐hour. [40 CFR 60.4205(c), 40 CFR 63.6590(c), Minn. R. 7011.230Minn. R. 7011.8150]

EQUI0000000315 EU085

The Permittee shall limit NMHC+NOx <= 7.8 grams per horsepower‐hour. [40 CFR 60.4205(c), 40 CFR 63.6590(c), Minn. R. 7011.2305, MinnR. 7011.8150]

EQUI0000000315 EU085

The Permittee shall limit Carbon Monoxide <= 3.7 grams per horsepower‐hour. [40 CFR 60.4205(c), 40 CFR 63.6590(c), Minn. R. 7011.2305Minn. R. 7011.8150]

EQUI0000000315 EU085

Fuel type: Ultra‐Low‐Sulfur #2 Fuel Oil only. [Minn. R. 7005.0100, subp. 35a]

EQUI0000000315 EU085

Hours of Operation: The Permittee shall maintain documentation on site that the unit is an emergency generator by design that qualifies under the U.S. EPA memorandum entitled "Calculating Potential to Emit (PTE) for Emergency Generators" dated September 6, 1995, limitinoperation to 500 hours per year. [Minn. R. 7007.0800, subps. 4‐5]

EQUI0000000315 EU085


EQUI0000000315 EU085

The Permittee shall operate and maintain the stationary CI ICE in accordance with the emission standards as required in Sections 60.4204 and 60.4205, and according to the manufacturer's written instructions or procedures developed by the Permittee that are approved by theengine manufacturer, over the entire life of the engine. The Permittee many only change those settings that are permitted by the manufacturer. [40 CFR 60.4206, 40 CFR 60.4211(a), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

EQUI0000000315 EU085

The Permittee shall limit Sulfur Content of Fuel <= 15.0 parts per million and either a minimum cetane index of 40 or a maximum aromatic content of 35 percent by volume, as required by 40 CFR Section 80.510(b). [40 CFR 60.4207(b), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

EQUI0000000315 EU085

EQUI 315 is a new affected source as defined under 40 CFR pt. 63, subp. ZZZZ, the facility is a major source as defined at 40 CFR Section 63and EQUI 315 is a compression ignition (CI) stationary RICE with a site rating of less than or equal to 500 brake HP. The Permittee shall meethe requirements of 40 CFR pt. 63, subp. ZZZZ by meeting the requirements of 40 CFR pt. 60, subp. IIII. No further requirements of 40 CFR p63, subp. ZZZZ apply to EQUI 315. [40 CFR 63.6590(c)(7), Minn. R. 7011.8150]

EQUI0000000315 EU085

The Permittee must install a non‐resettable hour meter prior to startup of the emergency engine. [40 CFR 60.4209(a), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

EQUI0000000315 EU085

The Permittee must demonstrate compliance with the emissions standards of 40 CFR Section 60.4205(c) according to one of the following methods: (1) Purchase an engine certified according to 40 CFR Part 89 or 94, as applicable, for the same model year and maximum engine power. The engine must be installed and configured according the manufacturer's specifications. (2) Keep record of the performance test for each pollutant for a test conducted on a similar engine. The test must have been conducted using the same methods specified in 40 CFpt. 60, subp. IIII, and must have been followed correctly. (3) Keep records of engine manufacturer data indicating compliance with the standards. (4) Keep records of control device vendor data indicating compliance with the standards. (5) Conduct an initial performance testo demonstrate compliance with the emission standards according to the requirements specified in 40 CFR Section 60.4212. [40 CFR 60.4211(b), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

EQUI0000000315 EU085

The Permittee may conduct maintenance checks and readiness testing provided that the tests are recommended by Federal, State, or locagovernment; the manufacturer; the vendor; or the insurance company associated with the engine. Maintenance checks and readiness testing are limited to 100 hours/year. There is no time limit on the use of emergency stationary ICE in emergency situations unless otherwiprohibited by the permit. The Permittee may petition the Administrator for approval of additional hours. A petition is not required if the Permittee maintains records indicating that the Federal, State or local standards require maintenance and testing beyond 100 hours/year. Any other operation other than emergency operation, and maintenance and testing as permitted in this section, is prohibited. [40 CFR 60.4211(f), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

EQUI0000000315 EU085

If the emergency engine does not meet the standards applicable to non‐emergency engines in the applicable model year, the Permittee must keep records of the operation of the engine in emergency and non‐emergency service that are recorded through the non‐resettable hour meter. The Permittee must record the time of operation of the engine and the reason the engine was in operation during that time. [40 CFR 60.4214(b), 40 CFR 63.6590(c), Minn. R. 7011.2305, Minn. R. 7011.8150]

EQUI0000000315 EU085

The Permittee shall submit a notification of any physical or operational change which increases emission rate: due 60 days (or as soon as practical) before the change is commenced. [40 CFR 60.7(a)(4), 40 CFR 63.6590(c), Minn. R. 7011.8150, Minn. R. 7019.0100, subp. 1]

EQUI0000000315 EU085

Recordkeeping: The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of the facility including; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. [40 CFR 60.7(b), 40 CFR 63.6590(c), Minn. R. 7011.8150, Minn. R. 7019.0100, subp.

EQUI0000000315 EU085

Recordkeeping: The Permittee shall maintain a file of all measurements, maintenance, reports and records for at least five years. This requirement is more stringent than 40 CFR Section 60.7(f), which specifies two years. [40 CFR 60.7(f), 40 CFR 63.6590(c), Minn. R. 7007.080subp. 5(C), Minn. R. 7011.8150, Minn. R. 7019.0100, subp. 1]

EQUI0000000315 EU085

No owner or operator shall build, erect, install, or use any article, machine, equipment or process, the use of which conceals an emission which would otherwise constitute a violation of an applicable standard. [40 CFR 60.12, 40 CFR 63.6590(c), Minn. R. 7011.0050, Minn. R. 7011.8150]

EQUI0000000315 EU085

Circumvention. The Permittee shall not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such concealment includes, but is not limited to: (1) The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere; or (2) The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions. [40 CFR 63.4(b), MinnR. 7011.7000]

EQUI0000000315 EU085

Recordkeeping: The Permittee shall maintain files of all information required by 40 CFR pt. 63 in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. [40 CFR 63.10(b)(1)Minn. R. 7019.0100, subp. 2(B)]

EQUI0000000315 EU085

The Permittee shall maintain, at a minimum, the following information in the files: 1) each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative; 2) all required measurements needed to demonstrate compliance with a relevant standard3) all results of performance test, CMS performance evaluations, and opacity and visible emission observations; 4) all measurements as mabe necessary to determine the conditions of performance tests and performance evaluations; 5) all CMS calibration checks; 6) all adjustments and maintenance performed on CMS; 7) any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 8) All emission levels relative to the criterion for obtaining permission use an alternative to the relative accuracy test, if the source has been granted such permission under 40 CFR 63.8(f)(6); and 9) all documentation supporting initial notifications and notifications of compliance status. [40 CFR 63.10(b)(2), Minn. R. 7019.0100, subp. 2(B)]

EQUI0000000315 EU085

Prior to construction or reconstruction of a major‐emitting "affected source" under the promulgated MACT standards, the Permittee mustapply for and obtain an air emission permit. [40 CFR 63.5(b)(3)& Minn. R. 7011.7000]

EQUI0000000315 EU085

After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, the Permittee who constructs a new affected source that is not major‐emitting or reconstructs an affected source that is not major‐emitting that is subject to such standaror reconstructs a source such that the source becomes an affected source subject to the standard, must notify the Administrator of the intended construction or reconstruction. The notification must be submitted in accordance with the procedures in 40 CFR Section 63.9(b). [40 CFR 63.5(b)(4)& Minn. R. 7011.7000]

EQUI0000000315 EU085

After the effective date of any relevant standard promulgated by the Administrator under 40 CFR pt. 63, equipment added (or a process change) to an affected source that is within the scope of the definition of affected source under the relevant standard must be considered part of the affected source and subject to all provisions of the relevant standard established for that affected source. [40 CFR 63.5(b), MinnR. 7011.7000]

EQUI0000000316 The Permittee is authorized to construct EQUI316. The construction authorization expires if construction does not commence within 18 months after Issuance of Air Emissions Permit No.01700002‐101, if construction is discontinued for a period of 18 months or more, or if construction is not completed within a reasonable time. [40 CFR 52.21(r)(2)]

EQUI0000000316 Opacity <= 20 percent opacity. [Minn. R. 7011.0715, subp. 1(B)]EQUI0000000316 Particulate Matter <= 0.30 grains per dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the

less stringent limit of either Minn. R. 7011.0730 or Minn. R. 7011.0735. [Minn. R. 7011.0715, subp. 1(A)]

EQUI0000000316 Volatile Organic Compounds : The Permittee shall conduct an initial performance test : Due 180 calendar days after Initial Startup Date to verify the emission factor of 0.00000927 ton VOC (as mass) per ton green chips. The performance test shall be conducted at worst case conditions as defined at Minn. R. 7017.2025, subp. 2, using EPA Reference Method 25A, or other method approved by MPCA in the performance test plan approval. [Minn. R. 7017.2020, subp. 1]

EQUI0000000316 Volatile Organic Compounds: The Permittee shall submit a test frequency plan for Volatile Organic Compounds: Due 60 calendar days afterInitial Performance Test Date for VOC emission factor. The plan shall specify a testing frequency based on the test data and MPCA guidanceFuture performance tests based on 12‐month, 36‐month, or 60‐month intervals, or as applicable, shall be required upon written approval othe MPCA. [Minn. R. 7017.2020, subp. 1]

EQUI0000000316 The Permittee shall submit a notification of the date construction began: Due 30 calendar days after Date of Construction Start (or reconstruction). Submit the name and number of the Subject Item and the date construction began. [Minn. R. 7007.0800, subp. 16(L)]

EQUI0000000316 The Permittee shall submit a notification of the actual date of initial startup: Due 15 calendar days after Initial Startup Date. Submit the name and number of the Subject Item and the date of startup. Startup is as defined in Minn. R. 7005.0100, subp. 42a. [Minn. R. 7007.0800subp. 16(L)]

FUGI0000000002 EU087


FUGI0000000002 EU087


FUGI0000000006 FS008

Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R. 7011.0150. [Minn. R. 7011.0150]

FUGI0000000006 FS008

Speed Limits: Not to exceed 5 miles per hour (mph) on the scale road (Segment A) or 15 mph on the paved road encompassing the roundwood storage yards (Segments F, G, H, I, J, and K). See figure in Appendix C. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

FUGI0000000006 FS008

Modeled Silt Load Limit (grams/square meter [g/m2]): Segment A: 0.808 g/m2 The limit is the silt loading value for the listed segment fromthe MPCA's Standardized Air Modeling (SAM) spreadsheet, column AF. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000,Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

FUGI0000000006 FS008

Silt Load Testing: As requested by the MPCA, the facility shall conduct separate on‐site silt load testing for the paved road segment listed above (Modeled Silt Load Limit), in accordance with a performance test plan approved by the MPCA. Silt load tests shall be conducted in accordance with EPA guidance in Appendices C‐1 and C‐2 of AP‐42. The Permittee shall keep records of all silt load testing. [Title I Conditio40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

FUGI0000000006 FS008

The Permittee must conduct sweeping of FUGI6 in accordance with the approved Fugitive Dust Control Plan. [Minn. R. 7007.0800, subp. 2]

FUGI0000000007 FS005

Chemical Dust Suppression: At least once per month during May, June, July, August, and September of each calendar year, a chemical dustsuppressant shall be applied to the travel routes at a rate of at least 0.17 gallons per square yard. Additional applications of chemical dust suppressant shall be made in other months as necessary. The travel routes must also be watered at least once between each chemical dussuppressant application, to reactivate the chemical dust suppressant. Additional waterings shall be performed as necessary. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. 7007.3000]

FUGI0000000007 FS005

The Permittee shall regularly observe travel routes for traffic in the unpaved areas to determine if there is excessive spillage of dust that could become airborne, and if so, take steps to control fugitive emissions, including watering and/or the use of a calcium chloride solution or other chemical dust suppression, as described above. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000, Title I Condition: Avoid major modification under 40 CFR 52.21(b)(2) & Minn. R. 7007.3000]

TREA0000000006 CE030

The Permittee shall vent emissions from EQUI51 to TREA6 whenever EQUI51 operates, and operate and maintain TREA6 at all times that aemissions are vented to TREA6. The Permittee shall document periods of non‐operation of the control equipment. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA0000000006 CE030

The Permittee shall operate and maintain the scrubber in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

TREA0000000006 CE030

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 94 percentcontrol efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000006 CE030

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 84 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000006 CE030

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 84 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000006 CE030

Pressure Drop >= 3 and <= 9 inches of water column unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3, based on the valuerecorded during the most recent MPCA‐approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA0000000006 CE030

Liquid Flow Rate >= 300 gallons per minute unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3, based on the values recordedduring the most recent MPCA‐approved performance test where compliance was demonstrated. The new limit shall be implemented uponreceipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. The Liquid Flow Rate limit is the combined flow rate for TREA12 and TREA6. [Minn. R. 7007.0800, subp. 14, MinnR. 7007.0800, subp. 2]

TREA0000000006 CE030

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressurdrop and liquid flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when thmonitored scrubber is in operation. [Minn. R. 7007.0800, subp. 4]

TREA0000000006 CE030

Recordkeeping of Pressure Drop: The Permittee shall maintain a continuous hard copy readout or computer disk file of the pressure drop fTREA6. [Minn. R. 7007.0800, subps. 4‐5]

TREA0000000006 CE030

Recordkeeping of Liquid Flow Rate. The Permittee shall maintain a continuous hard copy readout or computer disk file of the liquid flow rafor TREA6. [Minn. R. 7007.0800, subps. 4‐5]

TREA0000000006 CE030

Daily Monitoring: The Permittee shall physically check the pressure drop and supply liquid flow rate recording devices at least once each operating day to verify that they are working and recording properly. [Minn. R. 7007.0800, subps. 4‐5]

TREA0000000006 CE030

Control Equipment Monitoring: Once each operating day, observe and record the pressure drop across TREA6. The record shall include thetime and date of the reading and whether or not it was within the range specified by this permit. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA0000000006 CE030

Quarterly Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [MinR. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5]

TREA0000000006 CE030

Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5]

TREA0000000006 CE030

Annual Calibration: The Permittee shall calibrate the liquid flow rate and pressure drop gauges at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7007.0800, subp. 14]

TREA0000000006 CE030

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: ‐ the recorded pressure dropis outside the required operating range; or ‐ the recorded liquid flow rate is outside the required operating range; or ‐ the scrubber or any its components are found during the inspections to need repair. Corrective actions shall return the pressure drop and/or liquid flow rate towithin the permitted range, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the scrubber. The Permittee shall keep a record of the type anddate of any corrective action taken for the scrubber. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subps. 4‐5]

TREA0000000012 CE017

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 95 percentcontrol efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000012 CE017

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 84 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000012 CE017

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 80 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000012 CE017

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Sulfur ‐ Total Reduced including H2S >= 98 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000012 CE017

Pressure Drop <= 0 inches of water column. A negative draft must be present for TREA12 properly operate. [40 CFR 64.3(a), Minn. R. 7007.0800, subp. 14, Minn. R. 7017.0200]

TREA0000000012 CE017

Water pressure >= 10 and <= 20 psi (gauge) (Liquid Supply Pressure) unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 bason the values recorded during the most recent MPCA‐approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded water pressure is outside the required range, this shall be reported as a deviation. [40 CFR 64.3(a), Minn. R. 7007.0800, subp. 14, Minn. R. 7017.0200]

TREA0000000012 CE017

Liquid Flow Rate >= 300 gallons per minute unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recordedduring the most recent MPCA‐approved performance test where compliance was demonstrated. The new range shall be implemented uporeceipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded scrubber liquid flow rate is outside the required range, this shall be reported as a deviation. The Liquid Flow Rate limit is the combined flow rate for TREA12 and TREA6. [40 CFR 64.3(a), Minn. R. 7007.0800, subp. 14, Minn. R. 7017.0200

TREA0000000012 CE017

Pressure Drop >= 3 and <= 9 inches of water column unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3, based on the valuerecorded during the most recent MPCA‐approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA0000000012 CE017

Install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the scrubbing liquid supply pressure to thcontrol equipment. The monitoring device is to be certified by the manufacturer to be accurate within +/‐ 15 percent of design scrubbing liquid supply pressure. The pressure sensor or tap is to be located close to the scrubber liquid discharge point. The monitoring device shall be operational upon startup of the control equipment which is to be operational upon startup of Recovery Boiler #10. [40 CFR 60.284(b)(2)(ii), 40 CFR 64.7(a), Minn. R. 7011.2450, Minn. R. 7017.0200]

TREA0000000012 CE017

Liquid Flow Rate >= 300 gallons per minute unless a new limit is set pursuant to Minn. R. 7017.2025, subp. 3, based on the values recordedduring the most recent MPCA‐approved performance test where compliance was demonstrated. The new limit shall be implemented uponreceipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. The Liquid Flow Rate limit is the combined flow rate for TREA12 and TREA6. [Minn. R. 7007.0800, subp. 14, MinnR. 7007.0800, subp. 2]

TREA0000000012 CE017

Install, calibrate, maintain, and operate a monitoring device for the continuous measurement of the pressure loss of the gas stream througthe control equipment. The monitoring device is to be certified by the manufacturer to be accurate to within a gage pressure of +/‐ 2 inchewater gage pressure. The monitoring device shall be operational upon startup of the control equipment which is to be operational upon startup of Recovery Boiler #10. [40 CFR 60.284(b)(2)(i), 40 CFR 64.7(a), Minn. R. 7011.2450, Minn. R. 7017.0200]

TREA0000000012 CE017

Record once per shift, measurements obtained from the monitoring device for the continuous measurement of the pressure loss of the gastream through the control equipment and from the monitoring device for the continuous measurement of the scrubbing liquid supply pressure to the control equipment. This requirement is met through recordkeeping provided by continuous measurement devices for the control equipment. The Permittee shall maintain a continuous hard copy readout or computer disk file of the pressure drop of the gas stream and scrubbing liquid supply pressure and calculated eight‐hour rolling average for the control equipment. [40 CFR 60.284(c)(4), Minn. R. 7011.2450]

TREA0000000012 CE017

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressurdrop and liquid flow rate as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when thmonitored scrubber is in operation. [Minn. R. 7007.0800, subp. 4]

TREA0000000012 CE017

Periodic Inspections: At least once per calendar quarter, or more frequently as required by the manufacturing specifications, the Permitteeshall inspect the control equipment components. The Permittee shall maintain a written record of these inspections. [40 CFR 64.3, Minn. R7017.0200]

TREA0000000012 CE017

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: ‐ the recorded liquid supply pressure is outside the required operating range; or ‐ the recorded water flow rate is outside the required operating range; or ‐ the recordepressure drop is outside the required operating range; or ‐ the spray tower or any of its components are found during the inspections to need repair. Corrective actions shall return the pressure drop and/or water flow rate and/or liquid supply pressure to within the permittedrange, and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are nolimited to, those outlined in the O & M Plan for the spray tower. The Permittee shall keep a record of the type and date of any corrective action taken for the filter. [40 CFR 64.7(d)(1), Minn. R. 7017.0200]

TREA0000000012 CE017

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording pressurdrop, water flow rate, and water supply pressure as required by this permit. The monitoring equipment must be installed, in use, and properly maintained when the monitored scrubber is in operation. [40 CFR 64.7(b), Minn. R. 7017.0200]

TREA0000000012 CE017

The Permittee shall calibrate the gauges at least once every 12 months and shall maintain a written record of any action resulting from thecalibration. [40 CFR 64.3, Minn. R. 7017.0200]

TREA0000000012 CE017

Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance operformance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R. 7017.0200]

TREA0000000012 CE017

As required by 40 CFR Section 64.9(a)(2), for the Semi‐Annual Deviations Report listed in Section 6 of this permit and/or the Notification ofDeviations Endangering Human Health and the Environment listed earlier in Section 6 of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

TREA0000000012 CE017

The Permittee shall maintain records of monitoring data, monitor performance data, corrective actions taken, and other supporting information required to be maintained. The Permittee may maintain records on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of such alternative media allows for expeditious inspection and review, and doesnot conflict with other applicable recordkeeping requirements. [40 CFR 64.9(b), Minn. R. 7017.0200]

TREA0000000015 CE003

The Permittee shall vent emissions from EQUI2 (Power Boiler #7) to TREA15 whenever EQUI2 operates, and operate and maintain TREA15 all times that any emissions are vented to TREA15. The Permittee shall document periods of non‐operation of the control equipment TREA15 whenever EQUI2 is operating. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000015 CE003

If the Permittee replaces TREA15, the replacement control must meet or exceed the control efficiency requirements of TREA15 as well as comply with all other requirements of TREA15. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR‐05. The notice must be received by the Agency seven working days prior to the commencement/start of replacemen[Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000015 CE003

ESP monitoring: The COMS (EQUI102) for the emission unit (EQUI2) shall be used to assess proper operation of this ESP. [40 CFR 64.7(a), Minn. R. 7007.0800, subp. 2, Minn. R. 7017.0200]

TREA0000000015 CE003

Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance operformance testing document a need to modify the existing opacity limit, the Permittee shall promptly notify the MPCA and, if necessary,submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R. 7017.0200]

TREA0000000015 CE003

As required by 40 CFR Section 64.9(a)(2), for the Semi‐Annual Deviations Report required by this permit and/or the Notification of Deviations Endangering Human Health and the Environment required by this permit, as applicable, the Permittee shall include the followinrelated to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursionor exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

TREA0000000015 CE003


TREA0000000015 CE003

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percencontrol efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000015 CE003

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000015 CE003

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000015 CE003

The Permittee shall operate and maintain the electrostatic precipitator (ESP) in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

TREA0000000015 CE003

Opacity <= 10.0 percent opacity 3‐hour rolling average. Opacity in excess of this limit shall be considered an excursion under 40 CFR Sectio64.6(c)(2). [40 CFR 64.3, Minn. R. 7017.0200]

TREA0000000015 CE003

Opacity: Continuous Monitoring: The Permittee shall continuously, or at a minimum once every 15 minutes, monitor the opacity of the ESPexhaust. See Subject Item EQUI102 for specific COMS operating requirements. [40 CFR 64.3(b)(4)(ii), Minn. R. 7017.0200]

TREA0000000015 CE003

Monitoring Equipment: The necessary monitoring equipment must be installed, in use, and properly maintained, including maintaining thenecessary parts for routine repairs of the monitoring equipment, whenever operation of the monitored control equipment is required. [40CFR 64.7(b), Minn. R. 7017.0200]

TREA0000000015 CE003

Periodic Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer, the Permittee shall inspect thcontrol equipment components that are subject to wear or plugging, for example: bearings, belts, hoses, fans, nozzles, orifices, and ducts. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3Minn. R. 7017.0200]

TREA0000000015 CE003

Annual Inspections: At least once per calendar year, or more frequently if required by the manufacturer, the Permittee shall inspect the control equipment components not covered by the quarterly inspections. This includes, but is not limited to, components that are not subject to wear or plugging including structural components, housings, and hoods. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

TREA0000000015 CE003

Corrective Actions: The Permittee shall take corrective action as soon as possible if any of the following occur: ‐ the monitored opacity, averaged over any 3‐hour period, exceeds 10%; or ‐ the ESP or any of its components are found during the inspections to need repair. Corrective actions shall return operation to within the permitted range and/or include completion of necessary repairs identified during thinspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the ESP. The Permittee shakeep a record of the type and date of any corrective action taken for the ESP. [40 CFR 64.7(6), Minn. R. 7017.0200]

TREA0000000016 CE010

The Permittee shall vent emissions from EQUI301 (Chlorine Dioxide Plant) to TREA16 whenever EQUI301 operates, and operate and maintain TREA16 at all times that any emissions are vented to TREA16. The Permittee shall document periods of non‐operation of the control equipment TREA16 whenever EQUI301 is operating. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA0000000016 CE010

The Permittee shall operate and maintain TREA16 in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

TREA0000000016 CE010

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Chlorine Dioxide >= 82 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

TREA0000000016 CE010

Pressure Drop >= 0 and <= 5.0 psi (gauge) (gas pressure loss) unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on thvalues recorded during the most recent MPCA‐approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, this shall be reported as a deviation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA0000000016 CE010

Liquid Flow Rate >= 120 gallons per minute unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3 based on the values recordedduring the most recent MPCA‐approved performance test where compliance was demonstrated. The new range shall be implemented uporeceipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. If the recorded pressure drop is outside the required range, this shall be reported as a deviation. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA0000000016 CE010

Monitoring Equipment: The Permittee shall install and maintain the necessary monitoring equipment for measuring and recording the liquflow rate and pressure drop, as required by this permit. The monitoring equipment must be installed, in use, and properly maintained wheTREA16 is in operation. [Minn. R. 7007.0800, subp. 4]

TREA0000000016 CE010

Control Equipment Monitoring: The Permittee shall maintain a continuous hard copy readout or computer disk file of the liquid supply flowrates for TREA16. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA0000000016 CE010

Daily Monitoring: The Permittee shall physically check the pressure drop and supply liquid flow rate recording devices at least once each operating day to verify that they are working and recording properly. [Minn. R. 7007.0800, subps. 4‐5]

TREA0000000016 CE010

Control Equipment Monitoring: Once each operating day, observe and record the pressure drop across TREA16. The record shall include thtime and date of the reading and whether or not it was within the range specified by this permit. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA0000000016 CE010

Quarterly Inspections: At least once per calendar quarter, or more frequently if required by the manufacturer specifications, the Permitteeshall inspect the control equipment internal and external system components. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7007.0800, subp. 14]

TREA0000000016 CE010

Annual Calibration: The Permittee shall calibrate the liquid flow rate and pressure drop gauges at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [Minn. R. 7007.0800, subps. 4‐5, Minn. R. 7007.0800, subp. 14]

TREA0000000016 CE010

Corrective Actions: If the liquid flow rate is below the minimum listed above, or if the pressure drop is outside the specified ranges, or if thcontrol device or any of its components are found during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the liquid flow rate and/or pressure drops to the specified limits/ranges and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the condenser. The Permittee shall keep a record of the type and date of any corrective action taken. [MinnR. 7007.0800, subps. 4‐5, Minn. R. 7007.0800, subp. 14]

TREA0000000017 CE011

The Permittee shall vent emissions from EQUI7 (Bleach Plant) to TREA17 whenever EQUI7 operates, and operate and maintain TREA17 at atimes that any emissions are vented to TREA17. The Permittee shall document periods of non‐operation of the control equipment TREA17 whenever EQUI7 is operating. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 2]

TREA0000000017 CE011

Control Equipment Operation: The Permittee shall operate the gas scrubber in a manner consistent with the minimum or maximum (as appropriate) operating parameter value or procedure required to be monitored under paragraphs (a) ‐ (n) of 40 CFR 63.453 and as described in 40 CFR 63.453(o). Operation of the control device below minimum operating parameter values or above maximum operating parameter values established under 40 CFR pt. 63, subp. S shall constitute a violation of the applicable emission standard of 40 CFR pt. 63, subp. S and shall be reported as a period of excess emissions. [40 CFR 63.453(o), Minn. R. 7011.7700]

TREA0000000017 CE011

Control Equipment Monitoring: The Permittee shall maintain an electronic copy with calculated 8‐hour averages for TREA17 of the: ‐ pH orOxidation Reduction Potential and calculated eight‐hour rolling average; ‐ Gas Scrubber Liquid Flow Rate; and ‐ Gas Scrubber Vent Gas InleFan. [40 CFR 63.453(c), Minn. R. 7007.0800, subp. 14, Minn. R. 7011.7700]

TREA0000000017 CE011

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Chlorine Dioxide >= 99 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

TREA0000000017 CE011

pH >= 10.5 (no units) or Oxidation Reduction Potential <= ‐400 mV; or as determined during the most recent performance test. [40 CFR 63.453(c)(1), (n), & (o), Minn. R. 7007.0800, subp. 4, Minn. R. 7011.7700]

TREA0000000017 CE011

Liquid Flow Rate >= 225 gallons per minute (Gas Scrubber Liquid Rate) or as determined during most recent performance test. [40 CFR 63.453(c)(3), (n), & (o), Minn. R. 7007.0800, subp. 14, Minn. R. 7011.7700]

TREA0000000017 CE011

Gas Scrubber Fan Amperage: >= 33%; or as determined during the most recent performance test. [40 CFR 63.453(c)(2), (n), & (o), Minn. R. 7007.0800, subp. 14, Minn. R. 7011.7700]

TREA0000000017 CE011

CMS for Scrubber: The Permittee shall install, calibrate, certify, operate, and maintain a CMS to measure the following parameters for the gas scrubber: 1. The pH or the oxidation/reduction potential of the gas scrubber effluent; 2. The fan amperage; and 3. The gas scrubber liquid influent flow rate. An option to the CMS requirement above, is to install, calibrate, certify, operate, and maintain a CMS to measure the chlorine outlet concentration of each gas scrubber used to comply with the bleaching system outlet concentration requirement specified in 40 CFR Section 63.445(c)(2). [40 CFR 63.453(a),(c),&(d), Minn. R. 7011.7700]

TREA0000000017 CE011

Scrubber Parameter Values: To establish or reestablish the value for each operating parameter required to be monitored under 40 CFR Section 63.453, the Permittee shall use the procedures described in 40 CFR Section 63.453(n). [40 CFR 63.453(n), Minn. R. 7011.7700]

TREA0000000017 CE011

Corrective Actions: If the monitored parameter is out of the range as described above, the Permittee shall follow the facility O&M Plan andperform the necessary corrective actions) as soon as possible to get the parameters back into the correct range. The Permittee shall keep arecord of the type and date of all corrective actions taken. [Minn. R. 7007.0800, subp. 14, Minn. R. 7007.0800, subp. 5]

TREA0000000019 CE006

The Permittee shall vent emissions from EQUI4 (Power Boiler #9) to TREA19 whenever EQUI4 operates, and operate and maintain TREA19 all times that any emissions are vented to TREA19. The Permittee shall document periods of non‐operation of the control equipment TREA19 whenever EQUI4 is operating. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000019 CE006

If the Permittee replaces TREA19, the replacement control must meet or exceed the control efficiency requirements of TREA19 as well as comply with all other requirements of TREA19. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR‐05. The notice must be received by the Agency seven working days prior to the commencement/start of replacemen[Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000019 CE006


TREA0000000019 CE006


TREA0000000019 CE006


TREA0000000019 CE006


TREA0000000019 CE006

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percencontrol efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000019 CE006

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000019 CE006

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000019 CE006


TREA0000000019 CE006


TREA0000000019 CE006


TREA0000000019 CE006


TREA0000000019 CE006


TREA0000000019 CE006


TREA0000000019 CE006


TREA0000000020 CE007

The Permittee shall vent emissions from EQUI53 (Recovery Boiler #10) to TREA20 whenever EQUI53 operates, and operate and maintain TREA20 at all times that any emissions are vented to TREA20. The Permittee shall document periods of non‐operation of the control equipment TREA20 whenever EQUI53 is operating. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000020 CE007

If the Permittee replaces TREA20, the replacement control must meet or exceed the control efficiency requirements of TREA20 as well as comply with all other requirements of TREA20. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR‐05. The notice must be received by the Agency seven working days prior to the commencement/start of replacemen[Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000020 CE007


TREA0000000020 CE007


TREA0000000020 CE007


TREA0000000020 CE007


TREA0000000020 CE007

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percencontrol efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000020 CE007

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000020 CE007

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000020 CE007


TREA0000000020 CE007


TREA0000000020 CE007


TREA0000000020 CE007


TREA0000000020 CE007


TREA0000000020 CE007


TREA0000000020 CE007


TREA0000000021 CE019

The Permittee shall vent emissions from EQUI52 (Rotary Lime Kiln) to TREA21 whenever EQUI52 operates, and operate and maintain TREA21 at all times that any emissions are vented to TREA21. The Permittee shall document periods of non‐operation of the control equipment TREA21 whenever EQUI52 is operating. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000021 CE019

If the Permittee replaces TREA21, the replacement control must meet or exceed the control efficiency requirements of TREA21 as well as comply with all other requirements of TREA21. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR‐05. The notice must be received by the Agency seven working days prior to the commencement/start of replacemen[Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000021 CE019

ESP monitoring: The COMS (EQUI108) for the emission unit (EQUI52) shall be used to assess proper operation of this ESP. [40 CFR 64.7(a), Minn. R. 7007.0800, subp. 2, Minn. R. 7017.0200, Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000]

TREA0000000021 CE019


TREA0000000021 CE019


TREA0000000021 CE019


TREA0000000021 CE019

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Particulate Matter >= 99.0 percencontrol efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000021 CE019

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 10 micron >= 99.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000021 CE019

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for PM < 2.5 micron >= 95.0 percent control efficiency. [Title I Condition: 40 CFR 52.21(j)(BACT) & Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000021 CE019


TREA0000000021 CE019


TREA0000000021 CE019


TREA0000000021 CE019


TREA0000000021 CE019


TREA0000000021 CE019


TREA0000000021 CE019


TREA0000000030 CE022

The Permittee shall vent emissions from the equipment controlled by the IQS to TREA30 whenever the equipment operates, and operate and maintain TREA30 at all times that any emissions are vented to TREA30. The Permittee shall document periods of non‐operation of the control equipment TREA30. If the incinerator TREA30 is not operational emissions must be vented to Power Boiler #7 or #9 as specified elsewhere in the permit. [Minn. R. 7007.0800, subp. 2]

TREA0000000030 CE022

If the Permittee replaces TREA30, the replacement control must meet or exceed the control efficiency requirements of TREA30 as well as comply with all other requirements of TREA30. Prior to making such a change, the Permittee shall apply for and obtain the appropriate permit amendment, as applicable. If no amendment is needed for the replacement, the Permittee shall submit an electronic notice to the Agency using Form CR‐05. The notice must be received by the Agency seven working days prior to the commencement/start of replacemen[Minn. R. 7007.0800, subp. 2]

TREA0000000030 CE022

The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Volatile Organic Compounds >= 98.0 percent control efficiency. [Minn. R. 7007.0800, subp. 2]

TREA0000000030 CE022

The Permittee shall operate and maintain control equipment such that it achieves an overall control efficiency for Sulfur ‐ Total Reduced including H2S >= 98 percent destruction efficiency. [Minn. R. 7007.0800, subp. 2]

TREA0000000030 CE022

Temperature >= 1200 degrees Fahrenheit at the combustion chamber outlet (a minimum residence time of 0.5 seconds is also required), unless a new limit is required to be set pursuant to Minn. R. 7017.2025, subp. 3. If a new minimum is required to be set it will be based on the values recorded during the most recent MPCA‐approved performance test where compliance was demonstrated. The new limit shall bimplemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the change. If the 3‐hour rolling average temperature is below the minimum temperature limit, the VOC and TRemitted during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shabe reported as a deviation. [40 CFR 63.283(a)(1)(iii), 40 CFR 64.3(a), Minn. R. 7011.2450, Minn. R. 7017.0200]

TREA0000000030 CE022

Temperature >= 1500 degrees Fahrenheit 3‐hour rolling average at the combustion chamber outlet, unless a new limit is required to be setpursuant to Minn. R. 7017.2025, subp. 3. If a new minimum is required to be set it will be based on the values recorded during the most recent MPCA‐approved performance test where compliance was demonstrated. The new limit shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The limit is final upon issuance of a permit amendment incorporating the changIf the 3‐hour rolling average temperature is below the minimum temperature limit, the VOC emitted during that time shall be considered uncontrolled until the average temperature is above the minimum temperature limit. This shall be reported as a deviation. [40 CFR 63.443(d)(3), 40 CFR 64.3(a), Minn. R. 7007.0800, subp. 2, Minn. R. 7011.7700, Minn. R. 7017.0200, Minn. R. 7017.2025, subp. 3]

TREA0000000030 CE022

Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance operformance testing document a need to modify the existing pressure drop range, the Permittee shall promptly notify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring change. [40 CFR 64.7(e), Minn. R. 7017.0200]

TREA0000000030 CE022


TREA0000000030 CE022


TREA0000000030 CE022

The Permittee shall operate and maintain the thermal oxidizer in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available onsite for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

TREA0000000030 CE022

CMS: A CMS shall be operated to measure the temperature in the firebox or in the ductwork immediately downstream of the firebox and before any substantial heat exchange occurs. [40 CFR 63.453(b), Minn. R. 7011.7700]

TREA0000000030 CE022

Temperature Monitoring: The Permittee shall maintain and operate a thermocouple monitoring device that continuously indicates and records the combustion chamber temperature of the thermal oxidizer. The monitoring device shall have a margin of error less than the greater of +/‐ 0.75 percent of the temperature being measured or +/‐ 2.5 degrees Celsius. The recording device shall also calculate the threhour rolling average combustion chamber temperature. Recorded values outside the range specified in this permit are considered Deviations as defined by Minn. R. 7007.0100, subp. 8a. [40 CFR 64.3(b)(4)(ii) and Minn. R. 7017.0200, Minn. R. 7007.0800, subp. 2]

TREA0000000030 CE022

Daily Monitoring: The Permittee shall physically verify the operation of the temperature recording device at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [40 CFR 64.3(b), Minn. R. 7007.0800, subp. 2, Minn. R. 7017.0200]

TREA0000000030 CE022

Monitoring Equipment: The Permittee shall install and maintain thermocouples to conduct temperature monitoring at the point of incineration of effluent gases. The monitoring equipment must be installed, in use, and properly maintained whenever operation of the monitored control equipment is required. [40 CFR 60.284, 40 CFR 64.7(b), Minn. R. 7011.2450, Minn. R. 7017.0200]

TREA0000000030 CE022

The Permittee shall maintain a continuous hard copy readout or computer disk file of the temperature readings and calculated three hour rolling average temperatures for the combustion chamber. [Minn. R. 7007.0800, subp. 2, Minn. R. 7017.0200]

TREA0000000030 CE022

Annual Calibration: The Permittee shall calibrate the temperature monitor at least once every 12 months and shall maintain a written recoof the calibration and any action resulting from the calibration. [40 CFR 64.3, Minn. R. 7017.0200]

TREA0000000030 CE022

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

TREA0000000030 CE022

Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes aloperating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

TREA0000000030 CE022

For periods when the thermal oxidizer is operated above the minimum combustion chamber temperature, the Permittee shall use either one of the following when completing calculations as required elsewhere in this permit: a. The overall control efficiency limit specified in this permit for this equipment (x%); or b. The overall control efficiency determined during the most recent MPCA approved performance test. If the tested efficiency is less than the efficiency limit in this permit, the Permittee must use the tested value in all calculations until thefficiency is demonstrated to be above the permit limit through a new test. [Minn. R. 7007.0800, subp. 2]

TREA0000000030 CE022

Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components arfound during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shalkeep a record of the type and date of any corrective action taken. [40 CFR 64.7(d), Minn. R. 7017.0200]

TREA0000000031 CE023

The Permittee shall operate and maintain the scrubber in accordance with the Operation and Maintenance (O & M) Plan. The Permittee shall keep copies of the O & M Plan available for use by staff and MPCA staff. [Minn. R. 7007.0800, subp. 14]

TREA0000000031 CE023

The Permittee is allowed to conduct on‐line acid washes on TREA28 in accordance with the O & M Plan. The Permittee shall record the timdate, and duration of the on‐line acid washes. A Shutdown Breakdown Notice does not need to be submitted for the on‐line acid wash. [Minn. R. 7007.0800, subp. 2]

TREA0000000031 CE023

The Permittee shall operate and maintain control equipment such that it achieves a control efficiency for Sulfur Dioxide >= 99 percent destruction efficiency. [Minn. R. 7007.3000, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000031 CE023

pH >= 7.4 (no units) 3‐hour block average, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3, based on the values recordedduring the most recent MPCA‐approved performance test where compliance was demonstrated. The new range shall be implemented uporeceipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. This limit does not apply during on‐line acid washes as allowed in the O & M Plan. [40 CFR 64.3(a), Minn. R. 7007.3000, Minn. R. 7017.0200, Minn. R. 7017.2025, subp. 3, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000031 CE023

Liquid Flow Rate >= 584 gallons per minute 3‐hour block average, unless a new range is set pursuant to Minn. R. 7017.2025, subp. 3, basedon the values recorded during the most recent MPCA‐approved performance test where compliance was demonstrated. The new range shall be implemented upon receipt of the Notice of Compliance letter granting preliminary approval. The range is final upon issuance of a permit amendment incorporating the change. [40 CFR 64.3(a), Minn. R. 7007.3000, Minn. R. 7017.0200, Minn. R. 7017.2025, subp. 3, Title Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000031 CE023

Monitoring: Install, calibrate, maintain, and operate a continuous monitoring system to measure and record the pH and flow rate in the scrubber. [40 CFR 64.7(a), Minn. R. 7007.3000, Minn. R. 7017.0200, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000031 CE023

Daily Monitoring: The Permittee shall physically verify the operation of the pH and liquid flow rate recording devices at least once each operating day to verify that it is working and recording properly. The Permittee shall maintain a written record of the daily verifications. [40CFR 64.3(b), Minn. R. 7007.3000, Minn. R. 7017.0200, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn. R. 7007.3000]

TREA0000000031 CE023

The Permittee shall maintain a continuous hard copy readout or computer disk file of the pH and liquid flow rate readings and calculated three hour rolling averages. [40 CFR 64.9(b), Minn. R. 7007.3000, Minn. R. 7017.0200, Title I Condition: 40 CFR 52.21(k)(modeling) & Minn.R. 7007.3000]

TREA0000000031 CE023

Annual Calibration: The Permittee shall calibrate the pH monitor at least once every 12 months and shall maintain a written record of the calibration and any action resulting from the calibration. [40 CFR 64.3, Minn. R. 7017.0200]

TREA0000000031 CE023

Quarterly Inspections: At least once per calendar quarter, the Permittee shall inspect the control equipment internal and external system components, including but not limited to the refractory, heat exchanger, and electrical systems. The Permittee shall maintain a written record of the inspection and any corrective actions taken resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

TREA0000000031 CE023

Annual Inspection: At least once per calendar year, the Permittee shall conduct an internal inspection of the control device that includes aloperating systems of the control device. The Permittee shall maintain a written record of the inspection and any action resulting from the inspection. [40 CFR 64.3, Minn. R. 7017.0200]

TREA0000000031 CE023

Corrective Actions: If the temperature is below the minimum specified by this permit or if the thermal oxidizer or any of its components arfound during the inspections to need repair, the Permittee shall take corrective action as soon as possible. Corrective actions shall return the temperature to at least the permitted minimum and/or include completion of necessary repairs identified during the inspection, as applicable. Corrective actions include, but are not limited to, those outlined in the O & M Plan for the thermal oxidizer. The Permittee shalkeep a record of the type and date of any corrective action taken. [40 CFR 64.7(d)(1), Minn. R. 7017.0200]

TREA0000000031 CE023

Documentation of Need for Improved Monitoring: If the Permittee fails to achieve compliance with an emission limitation or standard for which the monitoring did not provide an indication of an excursion or exceedance while providing valid data, or the results of compliance operformance testing document a need to modify the existing minimum combustion chamber temperature(s), the Permittee shall promptlynotify the MPCA and, if necessary, submit a permit amendment application to address the necessary monitoring changes. [40 CFR 64.7(e), Minn. R. 7017.0200]

TREA0000000031 CE023

As required by 40 CFR Section 64.9(a)(2), for the Semi‐Annual Deviations Report listed in Section 6 of this permit and/or the Notification ofDeviations Endangering Human Health and the Environment listed earlier in Section 5 of this permit, as applicable, the Permittee shall include the following related to the monitoring identified as required by 40 CFR pt. 64: 1) Summary information on the number, duration, and cause of excursions or exceedances, as applicable, and the corrective action taken; and 2) Summary information on the number, duration, and cause for monitor downtime incidents. [40 CFR 64.9(a)(2), Minn. R. 7017.0200]

TREA0000000031 CE023


TSD Attachments Attachment 3: Subject item inventory/details

Sappi Cloquet LLC Permit Number: 01700002‐101

Subject Item ListTEMPO SI Category TEMPO SI ID Delta ID TEMPO SI Type Description TEMPO Status TEMPO Status Date NameEquipment EQUI 313 182 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 44648 / EU046Equipment EQUI 312 285 Aboveground Storage Tank Active / Existing 1/1/1993 Black Liquor / 31000 / EU047Equipment EQUI 311 420 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 48800 / EU045Equipment EQUI 306 597 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 158500 / EU045Equipment EQUI 307 598 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 158500 / EU045Equipment EQUI 308 599 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 105700 / EU045Equipment EQUI 261 927 Aboveground Storage Tank Active / Existing 10/10/1999 Methanol / 14600 / EU017Equipment EQUI 204 938 Aboveground Storage Tank Active / Existing 1/1/1993 Black Liquor / 155000 / EU047Equipment EQUI 309 950 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 530000 / EU045Equipment EQUI 310 953 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 28500 / EU045Equipment EQUI 314 962 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 153600 / EU046Equipment EQUI 295 966 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 127000 / EU046Equipment EQUI 296 967 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 102800 / EU046Equipment EQUI 297 968 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 130000 / EU046Equipment EQUI 317 951 Aboveground Storage Tank Active / Existing 1/1/1996 Black Liquor / 315000 / EU045Total Facility TFAC 6 1700002 Air Quality Total Facility Active / Existing 6/12/1996 Sappi Cloquet LLCStructure STRU 1 BG001 Building Active / Existing 11/17/2016 Causticizing BuildingStructure STRU 2 BG002 Building Active / Existing 11/17/2016 Building 62 ‐ Old Chlorine Evap BuildingStructure STRU 4 BG004 Building Active / Existing 11/17/2016 Lime Kiln North BuildingStructure STRU 5 BG005 Building Active / Existing 11/17/2016 Building 162 ‐ No. 4 Turbine GeneratorStructure STRU 6 BG006 Building Active / Existing 11/17/2016 Building 169 ‐ Soap SkimmerStructure STRU 7 BG007 Building Active / Existing 11/17/2016 PURR OfficesStructure STRU 8 BG008 Building Active / Existing 11/17/2016 Heavy Liquor PumphouseStructure STRU 9 BG009 Building Active / Existing 11/17/2016 Lime Kiln South BuildingStructure STRU 10 BG010 Building Active / Existing 11/17/2016 Waste Treatment OfficeStructure STRU 11 BG011 Building Active / Existing 11/17/2016 Building 10 ‐ Clarifier Lift StationStructure STRU 12 BG012 Building Active / Existing 11/17/2016 Building 159 ‐ HD Storage and PumphouseStructure STRU 13 BG013 Building Active / Existing 11/17/2016 Building 156 ‐ Turpentine StorageStructure STRU 14 BG014 Building Active / Existing 11/17/2016 Building 129 ‐ Construction Warehouse No. 3Structure STRU 15 BG015 Building Active / Existing 11/17/2016 Building 153 ‐ Evaporator Cooling TowerStructure STRU 16 BG016 Building Active / Existing 11/17/2016 Building 168 ‐ Peroxide Unloading BuildingStructure STRU 17 BG017 Building Active / Existing 11/17/2016 Building 166 ‐ New Bleach PlantStructure STRU 18 BG018 Building Active / Existing 11/17/2016 Building 142 ‐ Warehouse #3Structure STRU 20 BG020 Building Active / Existing 11/17/2016 Building 78 ‐ Bleached Hardwood MD TowerStructure STRU 21 BG021 Building Active / Existing 11/17/2016 OOS #10 Digester Blow Steam Acumulator TkStructure STRU 24 BG024 Building Active / Existing 11/17/2016 Building 30 ‐ ClO2 StorageStructure STRU 25 BG025 Building Active / Existing 11/17/2016 Building 31 ‐ ClO2 GeneratorTreatment TREA 11 CE002 076‐Multiclone wo Fly Ash Reinj (Most Multiclone) Active / Existing 11/17/2016 Power Boiler #7 ‐ MulticlonesTreatment TREA 12 CE017 052‐Spray Tower Active / Existing 11/17/2016 Smelt Dissolving Tank ‐ Spray TowerTreatment TREA 15 CE003 010‐Electrostatic Precipitator ‐ High Efficiency Active / Existing 11/17/2016 Power Boiler #7 ESPTreatment TREA 16 CE010 050‐Packed‐Gas Adsorption Column Active / Existing 11/17/2015 ClO2 Plant ScrubberTreatment TREA 17 CE011 013‐Gas Scrubber (General, Not Classified) Active / Existing 11/17/2016 Bleach Plant ScrubberTreatment TREA 18 CE005 076‐Multiclone wo Fly Ash Reinj (Most Multiclone) Active / Existing 11/17/2016 Power Boiler #9 ‐ MulticlonesTreatment TREA 19 CE006 010‐Electrostatic Precipitator ‐ High Efficiency Active / Existing 11/17/2016 Power Boiler #9 ESPTreatment TREA 20 CE007 010‐Electrostatic Precipitator ‐ High Efficiency Active / Existing 11/17/2016 Recovery Boiler #10 ESP

Treatment TREA 21 CE019 010‐Electrostatic Precipitator ‐ High Efficiency Active / Existing 11/17/2016 Rotary Lime Kiln ESPTreatment TREA 30 CE022 021‐Direct Flame Afterburner Active / Existing 1/10/2017 Incinerator for TRS on IQSTreatment TREA 31 CE023 052‐Spray Tower Active / Existing 1/10/2017 SO2 Scrubber for IQSTreatment TREA 6 CE030 053‐Venturi Scrubber Active / Existing 11/17/2016 Smelt Dissolving Tank ‐ Venturi ScrubberEquipment EQUI 65 DA002 Data Acquisition System Active / Existing 11/1/2008 Process Information SystemEquipment EQUI 63 DA003 Data Acquisition System Active / Existing 11/1/2008 RegPerfectEquipment EQUI 2 EU002 Boiler Active / Existing 12/31/1965 Power Boiler #7 (Spreader Stoker ‐ Bark)Equipment EQUI 4 EU004 Boiler Active / Existing 1/1/1981 Power Boiler #9 (Bark)Equipment EQUI 53 EU005 Boiler Active / Existing 5/20/1998 Recovery Boiler #10Equipment EQUI 301 EU009 Other Emission Unit Active / Existing 1/10/2017 Chlorine Dioxide PlantEquipment EQUI 7 EU011 Bleaching Equipment Active / Existing 11/15/1999 Bleach PlantEquipment EQUI 302 EU013 Other Emission Unit Active / Existing 1/10/2017 140' Clarifier (covered)Equipment EQUI 294 EU016 Digestor Active / Existing 12/20/2016 Digesters (10)Equipment EQUI 303 EU018 Other Emission Unit Active / Existing 1/10/2017 Oxygen Delignification SystemEquipment EQUI 51 EU031 Dissolver Active / Existing 5/21/1998 Smelt Dissolving Tank for RB#10Equipment EQUI 52 EU033 Kiln Active / Existing 11/21/1999 Rotary Lime Kiln ‐ KilnEquipment EQUI 15 EU034 Digestor Active / Existing 1/1/1996 Digester ReliefEquipment EQUI 305 EU035 Other Emission Unit Active / Existing 1/10/2017 Turpentine SystemEquipment EQUI 17 EU036 Stripping Equipment Active / Existing 1/1/1993 Condensate Stripper Equipment EQUI 18 EU037 Boiler Active / Existing 6/22/1998 Power Boiler #8Equipment EQUI 300 EU041 Concentrators Active / Existing 1/10/2017 Evaporator Vacuum Equipment EQUI 20 EU043 Washer Active / Existing 1/1/1996 Brownstock WashersEquipment EQUI 23 EU046 Washer Active / Existing 1/1/1996 Black Liquor Tanks (Washers)Equipment EQUI 24 EU048 Digestor Active / Existing 1/1/1996 Digester Air EvacuationEquipment EQUI 298 EU049 Other Emission Unit Active / Existing 1/10/2017 #4 Paper MachineEquipment EQUI 299 EU050 Other Emission Unit Active / Existing 1/10/2017 #12 Paper MachineEquipment EQUI 304 EU051 Other Emission Unit Active / Existing 1/10/2017 #13 Coater Equipment EQUI 28 EU052 Mixing Equipment Active / Existing 5/20/1998 Recovery Boiler #10 ‐ Salt‐Cake Mix TankEquipment EQUI 50 EU080 Other Emission Unit Active / Existing 12/6/1999 Market Pulp Machine ‐ Pressing EquipmentEquipment EQUI 49 EU081 Other Emission Unit Active / Existing 10/1/2000 IQS ‐ IncineratorEquipment EQUI 38 EU082 Reciprocating IC Engine Active / Existing 4/6/2007 I&I Emergency GeneratorEquipment EQUI 315 EU085 Reciprocating IC Engine Active / Existing 1/13/2017 Emergency Diesel Fire Water PumpFugitive FUGI 2 EU087 Cooling Tower Active / Existing 11/16/2016 Existing Cooling Tower ‐ zFugativeEquipment EQUI 42 EU088 Bleaching Equipment Active / Existing 11/16/2016 Ozone bleaching systemEquipment EQUI 290 EU089 Boiler Active / Existing 1/1/1986 R&D BoilerFugitive FUGI 8 FS001 Material Handling/Transfer/Storage Active / Existing 11/16/2016 Fly Ash HandlingFugitive FUGI 3 FS002 Open Air Source Active / Existing 11/16/2016 Fuel YardFugitive FUGI 9 FS004 Piles Active / Existing 11/16/2016 Wood Chip PileFugitive FUGI 7 FS005 Unpaved Roads Active / Existing 11/16/2016 Unpaved RoadsFugitive FUGI 5 FS006 Air Landfill Active / Existing 11/16/2016 LandfillFugitive FUGI 6 FS008 Paved Road Active / Existing 11/16/2016 Paved RoadsFugitive FUGI 11 FS009 Material Handling/Transfer/Storage Active / Existing 11/16/2016 Track‐outComponent Group COMG 2 GP003 Air Component Group Active / Existing 4/5/2007 NCG SystemComponent Group COMG 3 GP004 Air Component Group Active / Existing 4/5/2007 Process CondensatesComponent Group COMG 1 GP008 Air Component Group Active / Existing 5/1/2007 Fuel limits: #7, #8 and #9 BoilersComponent Group COMG 7 GP015 Air Component Group Active / Existing 1/16/2015 40 CFR pt. 63, subp. DDDDD RequirementsEquipment EQUI 135 MR001 Continuous Opacity Monitor Active / Existing 11/17/2016 Power Boiler #7 ‐ Opacity

Equipment EQUI 136 MR002 Continuous Opacity Monitor Active / Existing 11/17/2016 Power Boiler #9 ‐ OpacityEquipment EQUI 137 MR003 Continuous Emission Monitor Active / Existing 11/17/2016 Power Boiler #9 ‐ NOxEquipment EQUI 71 MR004 Continuous Emission Monitor Active / Existing 11/16/2016 Power Boiler #9 ‐ SO2Equipment EQUI 138 MR012 Continuous Emission Monitor Active / Existing 11/17/2016 Power Boiler #8 ‐ O2Equipment EQUI 112 MR013 Continuous Emission Monitor Active / Existing 11/16/2016 Power Boiler #8 ‐ NOxEquipment EQUI 113 MR014 Continuous Opacity Monitor Active / Existing 11/17/2016 Recovery Boiler #10 ‐ OpacityEquipment EQUI 114 MR015 Continuous Emission Monitor Active / Existing 11/16/2016 Recovery Boiler #10 ‐ NOxEquipment EQUI 115 MR016 Continuous Emission Monitor Active / Existing 11/17/2016 Recovery Boiler #10 ‐ SO2Equipment EQUI 116 MR017 Continuous Emission Monitor Active / Existing 11/17/2016 Recovery Boiler #10 ‐ TRSEquipment EQUI 117 MR018 Continuous Emission Monitor Active / Existing 11/17/2016 Recovery Boiler #10 ‐ COEquipment EQUI 118 MR019 Continuous Emission Monitor Active / Existing 11/17/2016 Recovery Boiler #10 ‐ O2Equipment EQUI 119 MR020 Continuous Emission Monitor Active / Existing 11/17/2016 Power Boiler #7 ‐ SO2Equipment EQUI 120 MR021 Continuous Emission Monitor Active / Existing 11/17/2016 Rotary Lime Kiln ‐ TRSEquipment EQUI 121 MR022 Continuous Emission Monitor Active / Existing 11/17/2016 Rotary Lime Kiln ‐ O2Equipment EQUI 122 MR023 Continuous Emission Monitor Active / Existing 1/1/1900 Power Boiler #7 ‐ O2Equipment EQUI 123 MR025 Continuous Emission Monitor Active / Existing 10/1/2001 Power Boiler #7 ‐ COEquipment EQUI 291 MR026 Parametric Monitor Active / Existing 12/14/2016 Power Boiler #7 ‐ Stack FlowEquipment EQUI 107 MR027 Continuous Emission Monitor Active / Existing 10/1/2001 Power Boiler #9 ‐ COEquipment EQUI 292 MR028 Parametric Monitor Active / Existing 12/14/2016 Power Boiler #9 ‐ Stack FlowEquipment EQUI 293 MR029 Parametric Monitor Active / Existing 12/14/2016 Recovery Boiler #10 ‐ Stack FlowEquipment EQUI 108 MR030 Continuous Opacity Monitor Active / Existing 11/17/2016 Rotary Lime Kiln ‐ OpacityEquipment EQUI 127 MR031 Parametric Monitor Active / Existing 11/17/2016 RB #10 ‐ SDT ‐ Pressure DropEquipment EQUI 70 MR032 Parametric Monitor Active / Existing 11/17/2016 RB #10 ‐ SDT ‐ Supply PressureEquipment EQUI 109 MR033 Parametric Monitor Active / Existing 1/1/1900 RB #10 ‐ SDT ‐ Scrubber FlowEquipment EQUI 129 MR034 Parametric Monitor Active / Existing 11/17/2016 Bleach Plant ‐ pHEquipment EQUI 130 MR035 Parametric Monitor Active / Existing 11/17/2016 Bleach Plant ‐ FlowEquipment EQUI 131 MR036 Parametric Monitor Active / Existing 11/17/2016 Bleach Plant ‐ FanEquipment EQUI 132 MR037 Parametric Monitor Active / Existing 11/17/2016 ClO2 Plant ‐ FlowEquipment EQUI 133 MR038 Parametric Monitor Active / Existing 11/17/2016 IQS ‐ TempEquipment EQUI 134 MR039 Parametric Monitor Active / Existing 11/17/2016 IQS ‐ FlowEquipment EQUI 72 MR040 Parametric Monitor Active / Existing 11/17/2016 IQS ‐ pHEquipment EQUI 110 MR043 Continuous Emission Monitor Active / Existing 5/20/1998 RB#10 CO2Equipment EQUI 76 MR044 Continuous Emission Monitor Active / Existing 12/3/2013 Power Boiler #9 ‐ O2Equipment EQUI 77 MR045 Parametric Monitor Active / Existing 5/31/2013 RB #10 ‐ SDT ‐ VRS Pressure DropStructure STRU 38 SV002 Stack/Vent Active / Existing 11/17/2016 Lime KilnStructure STRU 40 SV003 Stack/Vent Active / Existing 11/17/2016 Power Boiler #7Structure STRU 28 SV004 Stack/Vent Active / Existing 11/17/2016 Power Boiler #8Structure STRU 41 SV005 Stack/Vent Active / Existing 11/17/2016 Power Boiler #9Structure STRU 42 SV006 Stack/Vent Active / Existing 11/17/2016 Recovery Boiler #10Structure STRU 43 SV009 Stack/Vent Active / Existing 11/17/2016 Chlorine Dioxide PlantStructure STRU 44 SV010 Stack/Vent Active / Existing 11/17/2016 Bleach PlantStructure STRU 29 SV011 Stack/Vent Active / Existing 11/17/2016 IA stack (140' Clarifier)Structure STRU 27 SV012 Stack/Vent Active / Existing 11/17/2016 Power Boiler #7 BypassStructure STRU 47 SV029 Stack/Vent Active / Existing 11/17/2016 Smelt Dissolving Tank for RB#10Structure STRU 30 SV031 Stack/Vent Active / Existing 11/17/2016 Incinerator Quencher ScrubberStructure STRU 49 SV036 Stack/Vent Active / Existing 11/17/2016 #4 Paper MachineStructure STRU 50 SV037 Stack/Vent Active / Existing 11/17/2016 #12 Paper Machine

Structure STRU 51 SV038 Stack/Vent Active / Existing 11/17/2016 #13 Off‐Machine CoaterStructure STRU 31 SV039 Stack/Vent Active / Existing 11/17/2016 I&I Emergency GeneratorStructure STRU 37 SV043 Stack/Vent Active / Existing 11/17/2016 R&D BoilerStructure STRU 60 SV085 Stack/Vent Active / Existing 3/1/2008 Emergency Fire Pump StackEquipment EQUI 316 Other Emission Unit Active / Existing 2/7/2017 Chip Presteaming BinStructure STRU 59 Stack/Vent Active / Existing 2/7/2017 Chip Presteaming Bin StackActivity ACTV 19 Insignificant Air Emissions Activity Active / Existing 11/29/2016 All IAs

Subject Item Relationships Subject Item Relationships

Subject Item Category Description Subject Item Type DescriptionSubject Item ID

Subject Item Designation Subject Item Description Relationship (F/R)

Related Subject Item ID Related Subject Item Type Description

Start Date (Subject Item Related)

Treatment 021‐Direct Flame Afterburner TREA30 CE022 Incinerator for TRS on IQS is controlled in series by TREA31 052‐Spray Tower 10/1/2000Treatment 053‐Venturi Scrubber TREA6 CE030 Recovery Boiler #10 ‐ Venturi Scrubber is controlled in series by TREA12 052‐Spray Tower 5/7/2013Treatment 076‐Multiclone wo Fly Ash Reinj (Most Multiclone) TREA11 CE002 Power Boiler #7 ‐ Multiclones is controlled in series by TREA15 010‐Electrostatic Precipitator ‐ High Efficiency 12/31/1965Treatment 076‐Multiclone wo Fly Ash Reinj (Most Multiclone) TREA18 CE005 Power Boiler #9 ‐ Multiclones is controlled in series by TREA19 010‐Electrostatic Precipitator ‐ High Efficiency 1/1/1981Equipment Aboveground Storage Tank EQUI204 938 Black Liquor / 155000 / EU047 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1992Equipment Aboveground Storage Tank EQUI204 938 Black Liquor / 155000 / EU047 is controlled by TREA31 052‐Spray Tower 1/1/1992Equipment Aboveground Storage Tank EQUI295 966 Black Liquor / 127000 / EU046 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI295 966 Black Liquor / 127000 / EU046 is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Aboveground Storage Tank EQUI296 967 Black Liquor / 102800 / EU046 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI296 967 Black Liquor / 102800 / EU046 is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Aboveground Storage Tank EQUI297 968 Black Liquor / 130000 / EU046 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI297 968 Black Liquor / 130000 / EU046 is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Aboveground Storage Tank EQUI306 597 Black Liquor / 158500 / EU045 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI306 597 Black Liquor / 158500 / EU045 is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Aboveground Storage Tank EQUI307 598 Black Liquor / 158500 / EU045 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI307 598 Black Liquor / 158500 / EU045 is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Aboveground Storage Tank EQUI308 599 Black Liquor / 105700 / EU045 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI308 599 Black Liquor / 105700 / EU045 is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Aboveground Storage Tank EQUI309 950 Black Liquor / 530000 / EU045 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI309 950 Black Liquor / 530000 / EU045 is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Aboveground Storage Tank EQUI310 953 Black Liquor / 28500 / EU045 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI310 953 Black Liquor / 28500 / EU045 is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Aboveground Storage Tank EQUI311 420 Black Liquor / 48800 / EU045 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI311 420 Black Liquor / 48800 / EU045 is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Aboveground Storage Tank EQUI312 285 Black Liquor / 31000 / EU047 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI312 285 Black Liquor / 31000 / EU047 is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Aboveground Storage Tank EQUI313 182 Black Liquor / 44648 / EU046 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI313 182 Black Liquor / 44648 / EU046 is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Aboveground Storage Tank EQUI314 962 Black Liquor / 153600 / EU046 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Aboveground Storage Tank EQUI314 962 Black Liquor / 153600 / EU046 is controlled by TREA31 052‐Spray Tower 1/1/1996

Aboveground Storage Tank EQUI317 951 Black Liquor / 315000 / EU045 is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Aboveground Storage Tank EQUI317 951 Black Liquor / 315000 / EU045 is controlled by TREA31 052‐Spray Tower 1/1/1996

Equipment Bleaching Equipment EQUI7 EU011 Bleach Plant is monitored by EQUI129 Parametric Monitor 6/27/2007Equipment Bleaching Equipment EQUI7 EU011 Bleach Plant is monitored by EQUI130 Parametric Monitor 6/27/2007Equipment Bleaching Equipment EQUI7 EU011 Bleach Plant is monitored by EQUI131 Parametric Monitor 6/27/2007Equipment Bleaching Equipment EQUI7 EU011 Bleach Plant sends to STRU44 Stack/Vent 11/15/1999Equipment Bleaching Equipment EQUI42 EU088 Ozone bleaching system is controlled by TREA8 203‐Catalytic Converter 3/13/2012Equipment Bleaching Equipment EQUI42 EU088 Ozone bleaching system sends to STRU44 Stack/Vent 3/13/2012Equipment Boiler EQUI2 EU002 Power Boiler #7 (Spreader Stoker ‐ Bark) is controlled by TREA11 076‐Multiclone wo Fly Ash Reinj (Most Multiclone) 12/31/1965Equipment Boiler EQUI2 EU002 Power Boiler #7 (Spreader Stoker ‐ Bark) is controlled by TREA15 010‐Electrostatic Precipitator ‐ High Efficiency 12/31/1965Equipment Boiler EQUI2 EU002 Power Boiler #7 (Spreader Stoker ‐ Bark) is monitored by EQUI119 Continuous Emission Monitor 9/25/1998Equipment Boiler EQUI2 EU002 Power Boiler #7 (Spreader Stoker ‐ Bark) is monitored by EQUI122 Continuous Emission Monitor 9/25/1998Equipment Boiler EQUI2 EU002 Power Boiler #7 (Spreader Stoker ‐ Bark) is monitored by EQUI123 Continuous Emission Monitor 6/27/2007Equipment Boiler EQUI2 EU002 Power Boiler #7 (Spreader Stoker ‐ Bark) is monitored by EQUI135 Continuous Opacity Monitor 9/25/1998Equipment Boiler EQUI2 EU002 Power Boiler #7 (Spreader Stoker ‐ Bark) is monitored by EQUI291 Parametric Monitor 1/1/1900Equipment Boiler EQUI2 EU002 Power Boiler #7 (Spreader Stoker ‐ Bark) sends to STRU27 Stack/Vent 1/1/1981Equipment Boiler EQUI2 EU002 Power Boiler #7 (Spreader Stoker ‐ Bark) sends to STRU40 Stack/Vent 12/31/1965Equipment Boiler EQUI4 EU004 Power Boiler #9 (Bark) is controlled by TREA18 076‐Multiclone wo Fly Ash Reinj (Most Multiclone) 1/1/1981Equipment Boiler EQUI4 EU004 Power Boiler #9 (Bark) is controlled by TREA19 010‐Electrostatic Precipitator ‐ High Efficiency 1/1/1981Equipment Boiler EQUI4 EU004 Power Boiler #9 (Bark) is monitored by EQUI71 Continuous Emission Monitor 9/25/1998Equipment Boiler EQUI4 EU004 Power Boiler #9 (Bark) is monitored by EQUI76 Continuous Emission Monitor 4/23/2015Equipment Boiler EQUI4 EU004 Power Boiler #9 (Bark) is monitored by EQUI107 Continuous Emission Monitor 6/27/2007Equipment Boiler EQUI4 EU004 Power Boiler #9 (Bark) is monitored by EQUI136 Continuous Opacity Monitor 9/25/1998Equipment Boiler EQUI4 EU004 Power Boiler #9 (Bark) is monitored by EQUI137 Continuous Emission Monitor 9/25/1998Equipment Boiler EQUI4 EU004 Power Boiler #9 (Bark) is monitored by EQUI292 Parametric Monitor 1/1/1900Equipment Boiler EQUI4 EU004 Power Boiler #9 (Bark) sends to STRU41 Stack/Vent 1/1/1981Equipment Boiler EQUI18 EU037 Power Boiler #8 is monitored by EQUI112 Continuous Emission Monitor 9/25/1998Equipment Boiler EQUI18 EU037 Power Boiler #8 is monitored by EQUI138 Continuous Emission Monitor 9/25/1998Equipment Boiler EQUI18 EU037 Power Boiler #8 sends to STRU28 Stack/Vent 9/25/1998Equipment Boiler EQUI53 EU005 Recovery Boiler #10 is controlled by TREA20 010‐Electrostatic Precipitator ‐ High Efficiency 5/20/1998Equipment Boiler EQUI53 EU005 Recovery Boiler #10 is monitored by EQUI110 Continuous Emission Monitor 3/13/2012Equipment Boiler EQUI53 EU005 Recovery Boiler #10 is monitored by EQUI113 Continuous Opacity Monitor 9/25/1998Equipment Boiler EQUI53 EU005 Recovery Boiler #10 is monitored by EQUI114 Continuous Emission Monitor 9/25/1998Equipment Boiler EQUI53 EU005 Recovery Boiler #10 is monitored by EQUI115 Continuous Emission Monitor 9/25/1998Equipment Boiler EQUI53 EU005 Recovery Boiler #10 is monitored by EQUI116 Continuous Emission Monitor 9/25/1998Equipment Boiler EQUI53 EU005 Recovery Boiler #10 is monitored by EQUI117 Continuous Emission Monitor 9/25/1998Equipment Boiler EQUI53 EU005 Recovery Boiler #10 is monitored by EQUI118 Continuous Emission Monitor 9/25/1998Equipment Boiler EQUI53 EU005 Recovery Boiler #10 is monitored by EQUI293 Parametric Monitor 1/1/1900Equipment Boiler EQUI53 EU005 Recovery Boiler #10 sends to STRU42 Stack/Vent 5/20/1998

Equipment Boiler EQUI290 EU089 R&D Boiler sends to STRU37 Stack/Vent 1/1/1986Equipment Concentrators EQUI300 EU041 Evaporator Vacuum is controlled by TREA30 021‐Direct Flame Afterburner 10/18/1993Equipment Concentrators EQUI300 EU041 Evaporator Vacuum is controlled by TREA31 052‐Spray Tower 10/18/1993Equipment Concentrators EQUI300 EU041 Evaporator Vacuum sends to STRU30 Stack/Vent 10/18/1993Equipment Concentrators EQUI300 EU041 Evaporator Vacuum sends to STRU40 Stack/Vent 10/18/1993Equipment Concentrators EQUI300 EU041 Evaporator Vacuum sends to STRU41 Stack/Vent 10/18/1993Equipment Digestor EQUI15 EU034 Digester Relief is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Digestor EQUI15 EU034 Digester Relief is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Digestor EQUI15 EU034 Digester Relief sends to STRU30 Stack/Vent 1/1/1996Equipment Digestor EQUI15 EU034 Digester Relief sends to STRU40 Stack/Vent 1/1/1996Equipment Digestor EQUI15 EU034 Digester Relief sends to STRU41 Stack/Vent 1/1/1996Equipment Digestor EQUI24 EU048 Digester Air Evacuation is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Digestor EQUI24 EU048 Digester Air Evacuation is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Digestor EQUI24 EU048 Digester Air Evacuation sends to STRU30 Stack/Vent 1/1/1996Equipment Digestor EQUI24 EU048 Digester Air Evacuation sends to STRU40 Stack/Vent 1/1/1996Equipment Digestor EQUI24 EU048 Digester Air Evacuation sends to STRU41 Stack/Vent 1/1/1996Equipment Digestor EQUI294 EU016 Digesters (10) is controlled by TREA30 021‐Direct Flame Afterburner 11/1/1999Equipment Digestor EQUI294 EU016 Digesters (10) is controlled by TREA31 052‐Spray Tower 11/1/1999Equipment Dissolver EQUI51 EU031 Recovery Boiler #10 ‐ Smelt Dissolving Tank is controlled by TREA6 053‐Venturi Scrubber 5/21/1998Equipment Dissolver EQUI51 EU031 Recovery Boiler #10 ‐ Smelt Dissolving Tank is controlled by TREA12 052‐Spray Tower 5/21/1998Equipment Dissolver EQUI51 EU031 Recovery Boiler #10 ‐ Smelt Dissolving Tank is monitored by EQUI70 Parametric Monitor 6/27/2007Equipment Dissolver EQUI51 EU031 Recovery Boiler #10 ‐ Smelt Dissolving Tank is monitored by EQUI77 Parametric Monitor 4/23/2015Equipment Dissolver EQUI51 EU031 Recovery Boiler #10 ‐ Smelt Dissolving Tank is monitored by EQUI109 Parametric Monitor 6/27/2007Equipment Dissolver EQUI51 EU031 Recovery Boiler #10 ‐ Smelt Dissolving Tank is monitored by EQUI127 Parametric Monitor 6/27/2007Equipment Dissolver EQUI51 EU031 Recovery Boiler #10 ‐ Smelt Dissolving Tank sends to STRU47 Stack/Vent 5/21/1998Equipment Kiln EQUI52 EU033 Rotary Lime Kiln ‐ Kiln is controlled by TREA21 010‐Electrostatic Precipitator ‐ High Efficiency 1/21/1999Equipment Kiln EQUI52 EU033 Rotary Lime Kiln ‐ Kiln is monitored by EQUI108 Continuous Opacity Monitor 6/27/2007Equipment Kiln EQUI52 EU033 Rotary Lime Kiln ‐ Kiln is monitored by EQUI120 Continuous Emission Monitor 9/25/1998Equipment Kiln EQUI52 EU033 Rotary Lime Kiln ‐ Kiln is monitored by EQUI121 Continuous Emission Monitor 9/25/1998Equipment Kiln EQUI52 EU033 Rotary Lime Kiln ‐ Kiln sends to STRU38 Stack/Vent 11/21/1999Equipment Mixing Equipment EQUI28 EU052 Recovery Boiler #10 ‐ Salt‐Cake Mix Tank is controlled by TREA30 021‐Direct Flame Afterburner 5/20/1998Equipment Mixing Equipment EQUI28 EU052 Recovery Boiler #10 ‐ Salt‐Cake Mix Tank is controlled by TREA31 052‐Spray Tower 5/20/1998Equipment Mixing Equipment EQUI28 EU052 Recovery Boiler #10 ‐ Salt‐Cake Mix Tank sends to STRU30 Stack/Vent 5/20/1998Equipment Mixing Equipment EQUI28 EU052 Recovery Boiler #10 ‐ Salt‐Cake Mix Tank sends to STRU40 Stack/Vent 5/20/1998Equipment Mixing Equipment EQUI28 EU052 Recovery Boiler #10 ‐ Salt‐Cake Mix Tank sends to STRU41 Stack/Vent 5/20/1998Equipment Other Emission Unit EQUI49 EU081 IQS ‐ Incinerator is controlled by TREA30 021‐Direct Flame Afterburner 10/1/2000Equipment Other Emission Unit EQUI49 EU081 IQS ‐ Incinerator is controlled by TREA31 052‐Spray Tower 10/1/2000Equipment Other Emission Unit EQUI49 EU081 IQS ‐ Incinerator is monitored by EQUI72 Parametric Monitor 6/27/2007Equipment Other Emission Unit EQUI49 EU081 IQS ‐ Incinerator is monitored by EQUI133 Parametric Monitor 6/27/2007Equipment Other Emission Unit EQUI49 EU081 IQS ‐ Incinerator is monitored by EQUI134 Parametric Monitor 6/27/2007Equipment Other Emission Unit EQUI49 EU081 IQS ‐ Incinerator sends to STRU30 Stack/Vent 10/1/2000Equipment Other Emission Unit EQUI49 EU081 IQS ‐ Incinerator sends to STRU40 Stack/Vent 10/1/2000Equipment Other Emission Unit EQUI49 EU081 IQS ‐ Incinerator sends to STRU41 Stack/Vent 10/1/2000Equipment Other Emission Unit EQUI298 EU049 #4 Paper Machine sends to STRU49 Stack/Vent 12/31/1998Equipment Other Emission Unit EQUI299 EU050 #12 Paper Machine sends to STRU50 Stack/Vent 1/1/1998Equipment Other Emission Unit EQUI301 EU009 Chlorine Dioxide Plant is controlled by TREA16 050‐Packed‐Gas Adsorption Column 1/1/1993Equipment Other Emission Unit EQUI301 EU009 Chlorine Dioxide Plant is monitored by EQUI132 Parametric Monitor 6/27/2007Equipment Other Emission Unit EQUI301 EU009 Chlorine Dioxide Plant sends to STRU43 Stack/Vent 1/1/1993Equipment Other Emission Unit EQUI302 EU013 140' Clarifier (covered) sends to STRU29 Stack/Vent 1/1/1978Equipment Other Emission Unit EQUI303 EU018 Oxygen Delignification System is controlled by TREA30 021‐Direct Flame Afterburner 11/1/1999Equipment Other Emission Unit EQUI303 EU018 Oxygen Delignification System is controlled by TREA31 052‐Spray Tower 11/1/1999Equipment Other Emission Unit EQUI303 EU018 Oxygen Delignification System sends to STRU30 Stack/Vent 11/1/1999Equipment Other Emission Unit EQUI303 EU018 Oxygen Delignification System sends to STRU40 Stack/Vent 11/1/1999Equipment Other Emission Unit EQUI303 EU018 Oxygen Delignification System sends to STRU41 Stack/Vent 11/1/1999Equipment Other Emission Unit EQUI304 EU051 #13 Coater sends to STRU51 Stack/Vent 1/1/1989Equipment Other Emission Unit EQUI305 EU035 Turpentine System is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Other Emission Unit EQUI305 EU035 Turpentine System is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Other Emission Unit EQUI305 EU035 Turpentine System sends to STRU30 Stack/Vent 1/1/1996Equipment Other Emission Unit EQUI305 EU035 Turpentine System sends to STRU40 Stack/Vent 1/1/1996Equipment Other Emission Unit EQUI305 EU035 Turpentine System sends to STRU41 Stack/Vent 1/1/1996Equipment Other Emission Unit EQUI316 Chip Presteaming Bin sends to STRU59 Stack/Vent 2/7/2017Equipment Reciprocating IC Engine EQUI38 EU082 I&I Emergency Generator sends to STRU31 Stack/Vent 6/27/2007Equipment Reciprocating IC Engine EQUI315 EU085 Emergency Diesel Fire Water Pump sends to STRU60 Stack/Vent 3/1/2008Equipment Stripping Equipment EQUI17 EU036 Condensate Stripper is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1993Equipment Stripping Equipment EQUI17 EU036 Condensate Stripper is controlled by TREA31 052‐Spray Tower 1/1/1993Equipment Stripping Equipment EQUI17 EU036 Condensate Stripper sends to STRU30 Stack/Vent 1/1/1993Equipment Stripping Equipment EQUI17 EU036 Condensate Stripper sends to STRU40 Stack/Vent 1/1/1993Equipment Stripping Equipment EQUI17 EU036 Condensate Stripper sends to STRU41 Stack/Vent 1/1/1993Equipment Washer EQUI20 EU043 Brownstock Washers is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Washer EQUI20 EU043 Brownstock Washers is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Washer EQUI20 EU043 Brownstock Washers sends to STRU30 Stack/Vent 1/1/1996Equipment Washer EQUI20 EU043 Brownstock Washers sends to STRU40 Stack/Vent 1/1/1996

Equipment Washer EQUI20 EU043 Brownstock Washers sends to STRU41 Stack/Vent 1/1/1996Equipment Washer EQUI23 EU046 Black Liquor Tanks (Washers) is controlled by TREA30 021‐Direct Flame Afterburner 1/1/1996Equipment Washer EQUI23 EU046 Black Liquor Tanks (Washers) is controlled by TREA31 052‐Spray Tower 1/1/1996Equipment Washer EQUI23 EU046 Black Liquor Tanks (Washers) sends to STRU30 Stack/Vent 1/1/1996Equipment Washer EQUI23 EU046 Black Liquor Tanks (Washers) sends to STRU40 Stack/Vent 1/1/1996Equipment Washer EQUI23 EU046 Black Liquor Tanks (Washers) sends to STRU41 Stack/Vent 1/1/1996

CEMS and COMS

Subject Item Type DescriptionSubject Item ID

Subject Item Designation Manufacturer Model

Serial Number

Parameter Monitored (continuous monitors)

Primary or backup monitor?

Em Bypass Capability?

Monitor Install Date

Certification Date

Certification Basis

Em Span

System Full Scale Value

Optical Path Length

Continuous Emission Monitor EQUI71 MR004 Monitor Labs T100 1598 Sulfur Dioxide P N 5/1/2015 5/28/2015 40 CFR Pt 60 750 586Continuous Emission Monitor EQUI76 MR044 Monitor Labs SM425 U1N303592 Oxygen P N 12/3/2013 12/4/2013 40 CFR Pt 60 25 21Continuous Emission Monitor EQUI107 MR027 Monitor Labs T300U 237 Carbon Monoxide P N 2/1/2015 12/29/2015 40 CFR Pt 60 1000 9999Continuous Emission Monitor EQUI110 MR043 Teledyne Monitor Labs TM360 79 Carbon Dioxide P N 12/3/2015 12/5/2013 40 CFR Pt 60 20 18Continuous Emission Monitor EQUI112 MR013 Monitor Labs SM8160 0482549R Nitrogen Oxides P N 10/1/1998 10/1/1998 40 CFR Pt 60 208 109Continuous Emission Monitor EQUI114 MR015 Monitor Labs ML9841AS 2853‐108 Nitrogen Oxides P N 7/1/1998 7/30/1998 40 CFR Pt 60 450 350Continuous Emission Monitor EQUI115 MR016 Monitor Labs ML9850M 2858‐904 Sulfur Dioxide P N 7/1/1998 7/30/1998 40 CFR Pt 60 450 350Continuous Emission Monitor EQUI116 MR017 Monitor Labs ML9850B 213B‐102 Sulfur ‐ Total Reduced including H2S P N 10/1/1998 10/1/1998 40 CFR Pt 60 30 25Continuous Emission Monitor EQUI117 MR018 Monitor Labs ML9830B 198B‐123 Carbon Monoxide P N 7/1/1998 7/30/1998 40 CFR Pt 60 1000 450Continuous Emission Monitor EQUI118 MR019 Monitor Labs Citi Cell 1800‐OC Oxygen P N 10/1/1998 10/1/1998 40 CFR Pt 60 25 21Continuous Emission Monitor EQUI119 MR020 Monitor Labs SM8160 0892563R Sulfur Dioxide P N 1/1/2001 1/1/2001 40 CFR Pt 60 1500 1100Continuous Emission Monitor EQUI120 MR021 Teledyne Monitor Labs T100 1387 Sulfur ‐ Total Reduced including H2S P N 12/1/2014 12/9/2014 40 CFR Pt 60 30 25Continuous Emission Monitor EQUI121 MR022 Monitor Labs Citi Cell 1852‐OC Oxygen P N 2/1/2001 10/1/2001 40 CFR Pt 60 25 21Continuous Emission Monitor EQUI122 MR023 Monitor Labs LS420 JJ113TA339 Oxygen P N 1/1/2001 1/1/2001 40 CFR Pt 60 25 21Continuous Emission Monitor EQUI123 MR025 Monitor Labs ML9830 00‐0255 Carbon Monoxide P N 9/1/2001 10/1/2001 40 CFR Pt 60 9999 1000Continuous Emission Monitor EQUI137 MR003 Teledyne Monitor Labs T200 1245 Nitrogen Oxides P N 5/1/2014 5/1/2014 40 CFR Pt 60 750 612Continuous Emission Monitor EQUI138 MR012 Monitor Labs LS‐420 J80715A335 Oxygen P N 10/1/1998 10/1/1998 40 CFR Pt 60 25 21Continuous Opacity Monitor EQUI108 MR030 Teledyne Monitor Labs Lighthawk 560 5602541 Opacity P N 10/1/2013 10/16/2013 40 CFR Pt 60 33 100 0.5Continuous Opacity Monitor EQUI113 MR014 Teledyne Monitor Labs ML560 5602419 Opacity P N 10/1/2012 10/3/2012 40 CFR Pt 60 100 33 0.5Continuous Opacity Monitor EQUI135 MR001 Monitor Labs Lighthawk 5600145 Opacity P Y 9/1/2007 9/1/2007 40 CFR Pt 60 100 33 0.5Continuous Opacity Monitor EQUI136 MR002 Monitor Labs Lighthawk 5600541 Opacity P N 1/1/2004 1/1/2004 40 CFR Pt 60 100 33 0.5

COMG MembersAgency Interest Name Subject Item ID Subject Item Designation Subject Item Description Group Member ID (padded)Sappi Cloquet LLC COMG1 GP008 Fuel limits: #7, #8 and #9 Boilers EQUI2Sappi Cloquet LLC COMG1 GP008 Fuel limits: #7, #8 and #9 Boilers EQUI4Sappi Cloquet LLC COMG1 GP008 Fuel limits: #7, #8 and #9 Boilers EQUI18Sappi Cloquet LLC COMG2 GP003 NCG System EQUI15Sappi Cloquet LLC COMG2 GP003 NCG System EQUI17Sappi Cloquet LLC COMG2 GP003 NCG System EQUI20Sappi Cloquet LLC COMG2 GP003 NCG System EQUI24Sappi Cloquet LLC COMG2 GP003 NCG System EQUI28Sappi Cloquet LLC COMG2 GP003 NCG System EQUI49Sappi Cloquet LLC COMG2 GP003 NCG System EQUI204Sappi Cloquet LLC COMG2 GP003 NCG System EQUI295Sappi Cloquet LLC COMG2 GP003 NCG System EQUI296Sappi Cloquet LLC COMG2 GP003 NCG System EQUI297Sappi Cloquet LLC COMG2 GP003 NCG System EQUI300Sappi Cloquet LLC COMG2 GP003 NCG System EQUI303Sappi Cloquet LLC COMG2 GP003 NCG System EQUI305Sappi Cloquet LLC COMG2 GP003 NCG System EQUI306Sappi Cloquet LLC COMG2 GP003 NCG System EQUI307Sappi Cloquet LLC COMG2 GP003 NCG System EQUI308Sappi Cloquet LLC COMG2 GP003 NCG System EQUI309Sappi Cloquet LLC COMG2 GP003 NCG System EQUI310Sappi Cloquet LLC COMG2 GP003 NCG System EQUI312Sappi Cloquet LLC COMG2 GP003 NCG System EQUI313Sappi Cloquet LLC COMG2 GP003 NCG System EQUI314Sappi Cloquet LLC COMG2 GP003 NCG System STRU30Sappi Cloquet LLC COMG2 GP003 NCG System STRU40Sappi Cloquet LLC COMG2 GP003 NCG System STRU41Sappi Cloquet LLC COMG2 GP003 NCG System TREA30Sappi Cloquet LLC COMG2 GP003 NCG System TREA31Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI15Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI17Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI20Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI24

Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI28Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI204Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI295Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI296Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI297Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI300Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI303Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI305Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI306Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI307Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI308Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI309Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI310Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI312Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI313Sappi Cloquet LLC COMG3 GP004 Process Condensates EQUI314Sappi Cloquet LLC COMG7 GP015 40 CFR pt. 63, subp. DDDDD Requirements EQUI2Sappi Cloquet LLC COMG7 GP015 40 CFR pt. 63, subp. DDDDD Requirements EQUI4Sappi Cloquet LLC COMG7 GP015 40 CFR pt. 63, subp. DDDDD Requirements EQUI18Sappi Cloquet LLC COMG7 GP015 40 CFR pt. 63, subp. DDDDD Requirements EQUI290

Aboveground Storage Tanks


Subject Item Designation

Capacity (gal)

AST Substance Stored

Interior Diameter (ft)

Interior Height (ft)

Maximum True Vapor Pressure (psia)

Construction Type Name in Air Permit Substance in Tanks Permit

Aboveground Storage Tank EQUI204 938 155000 Other 30 30 5 Fixed Roof Black Liquor / 155000 / EU047 South Heavy Black LiquorAboveground Storage Tank EQUI261 927 14600 Methanol 12 19 14.7 Fixed Roof Methanol / 14600 / EU017 MethanolAboveground Storage Tank EQUI295 966 127000 Other 24 24 5 Fixed Roof Black Liquor / 127000 / EU046 Second Stage FiltrateAboveground Storage Tank EQUI296 967 102800 Other 27 24 5 Fixed Roof Black Liquor / 102800 / EU046 First PO Filtrate TankAboveground Storage Tank EQUI297 968 130000 Other 27 24 5 Fixed Roof Black Liquor / 130000 / EU046 Second PO Filtrate TankAboveground Storage Tank EQUI306 597 158500 Other 20 57 190 Pressure Tank Black Liquor / 158500 / EU045 Primary black liquor accumulatorAboveground Storage Tank EQUI307 598 158500 Other 20 57 190 Pressure Tank Black Liquor / 158500 / EU045 Secondary black liquor accumulatorAboveground Storage Tank EQUI308 599 105700 Other 16 60 190 Pressure Tank Black Liquor / 105700 / EU045 Neutralization liquor accumulatorAboveground Storage Tank EQUI309 950 530000 Other 34 66 190 Pressure Tank Black Liquor / 530000 / EU045 Displacement liquorAboveground Storage Tank EQUI310 953 28500 Other 8 63 5 Fixed Roof Black Liquor / 28500 / EU045 Fiberline SoapAboveground Storage Tank EQUI311 420 48800 Other 12 78 190 Pressure Tank Black Liquor / 48800 / EU045 Neutralization Liquor Mixing AccumulatorAboveground Storage Tank EQUI312 285 31000 Other 14 24 5 Fixed Roof Black Liquor / 31000 / EU047 Evaporation Product LiquorAboveground Storage Tank EQUI313 182 44648 Other 20 20 5 Fixed Roof Black Liquor / 44648 / EU046 Spill Collection TankAboveground Storage Tank EQUI314 962 153600 Other 27 24 5 Fixed Roof Black Liquor / 153600 / EU046 First Stage FiltrateAboveground Storage Tank EQUI317 951 315000 Other 26.3 66.1 190 Fixed Roof Black Liquor / 315000 / EU045 Impregnation Liquor

Thermal Oxidizer



Install Start Date Pollutant Controlled (treatment)

Capture Efficiency (%)

Destruction/Collection Efficiency (%)

Subject to CAM?

Large PSEU?

Efficiency Basis

Thermal Oxidation Minimum Combustion Temperature (°F)

Thermal Oxidation Residence Time (seconds)

021‐Direct Flame Afterburner TREA30 CE022 Kvaerner Chemetics 223239 1/1/2000 Sulfur ‐ Total Reduced including H2S 100 98 Y N Other 1500 0.8021‐Direct Flame Afterburner TREA30 CE022 Kvaerner Chemetics 223239 1/1/2000 Volatile Organic Compounds 100 98 Y N Other 1500 0.8

010‐Electrostatic Precipitators ‐ High EfficiencySubject Item ID


Install Start Date

Pollutant Controlled (treatment)



Subject to CAM?

Large PSEU?

Efficiency Basis

TREA15 CE003 Envirotech/Buell BA1.1X421333‐2.3P 1/24/1978 Particulate Matter 100 99 Y N OtherTREA15 CE003 Envirotech/Buell BA1.1X421333‐2.3P 1/24/1978 PM < 2.5 micron 100 95 Y N OtherTREA15 CE003 Envirotech/Buell BA1.1X421333‐2.3P 1/24/1978 PM < 10 micron 100 99 Y N OtherTREA19 CE006 Envirotech/Buell BA1.1X5OJ343‐2.3P 7/25/1978 Particulate Matter 100 99 Y N OtherTREA19 CE006 Envirotech/Buell BA1.1X5OJ343‐2.3P 7/25/1978 PM < 2.5 micron 100 95 Y N OtherTREA19 CE006 Envirotech/Buell BA1.1X5OJ343‐2.3P 7/25/1978 PM < 10 micron 100 99 Y Y OtherTREA20 CE007 Environmental Elements Corp 420598 1/1/1997 Particulate Matter 100 99 Y Y OtherTREA20 CE007 Environmental Elements Corp 420598 1/1/1997 PM < 2.5 micron 100 95 Y Y OtherTREA20 CE007 Environmental Elements Corp 420598 1/1/1997 PM < 10 micron 100 99 Y Y OtherTREA21 CE019 Environmental Elements NA 1/1/1999 Particulate Matter 100 99 Y N OtherTREA21 CE019 Environmental Elements NA 1/1/1999 PM < 2.5 micron 100 95 Y N OtherTREA21 CE019 Environmental Elements NA 1/1/1999 PM < 10 micron 100 99 Y N Other

076‐Multiclones wo Fly Ash Reinj (Most Multiclone)Subject Item ID


Install Start Date




Subject to CAM?

Large PSEU?

Efficiency Basis

Minimum Pressure Drop (in. of water column)

Maximum Pressure Drop (in. of water column)

TREA11 CE002 Western Precipitation VGRAE 12/31/1965 Particulate Matter 100 92 Y N Other NA NATREA11 CE002 Western Precipitation VGRAE 12/31/1965 PM < 2.5 micron 100 72 Y N Other NA NATREA11 CE002 Western Precipitation VGRAE 12/31/1965 PM < 10 micron 100 72 Y N Other NA NATREA18 CE005 Barron 14K35‐1010AV 1/1/1997 Particulate Matter 100 66 Y N Other NA NATREA18 CE005 Barron 14K35‐1010AV 1/1/1997 PM < 2.5 micron 100 66 Y N Other NA NATREA18 CE005 Barron 14K35‐1010AV 1/1/1997 PM < 10 micron 100 66 Y Y Other NA NA

Scrubber



Install Start Date




Subject to CAM?

Large PSEU?

Efficiency Basis

Scrubber Minimum Pressure Drop (in. of water column)

Scrubber Maximum Pressure Drop (in. of water column)

Scrubber Minimum Liquid Flow Rate (gal./min)

013‐Gas Scrubber (General, Not Classified) TREA17 CE011 Bionomic Ind Rotabed 530‐XM‐0340 1/1/1999 Chlorine Dioxide 100 99 N Other NA NA 225050‐Packed‐Gas Adsorption Column TREA16 CE010 Sterling Pulp Chemicals 31‐399 1/1/1993 Chlorine Dioxide 100 82 N Other 0.1 99* 120052‐Spray Tower TREA12 CE017 Ducon Environmental Systems 420639 1/1/1997 Particulate Matter 100 95 Y N Other NA** 0.1 300052‐Spray Tower TREA12 CE017 Ducon Environmental Systems 420639 1/1/1997 PM < 2.5 micron 100 80 Y N Other NA** 0.1 300052‐Spray Tower TREA12 CE017 Ducon Environmental Systems 420639 1/1/1997 PM < 10 micron 100 84 Y N Other NA** 0.1 300052‐Spray Tower TREA12 CE017 Ducon Environmental Systems 420639 1/1/1997 TRS 100 98 Y N Other NA** 0.1 300052‐Spray Tower TREA31 CE023 Kvaerner Chemetics 223239 1/1/2000 Sulfur Dioxide 100 99 Y N Other NA NA 584053‐Venturi Scrubber TREA6 CE030 Ducon A33M 4/1/2013 Particulate Matter 100 94 Y N Other 3 9 300053‐Venturi Scrubber TREA6 CE030 Ducon A33M 4/1/2013 PM < 10 micron 100 84 Y N Other 3 9 300053‐Venturi Scrubber TREA6 CE030 Ducon A33M 4/1/2013 PM < 2.5 micron 100 84 Y N Other 3 9 300*Current permitted max pressure drop for TREA16 (CE010) is 5 psi (138.5 in. of water column), which is out of range of the database field for max pressure drop**Pressure drop is required to be less than or equal to 0 inches of water column for TREA12 (CE017).

Stack/VentsSubject Item Type Description

Subject Item ID

Subject Item Designation

Stack Height (feet)

Stack Diameter (feet)

Stack Flow Rate (cubic ft/min)

Discharge Temp (°F)

Info Source Desc Discharge Direction

Stack/Vent STRU27 SV012 127 7.5 144760 375 Test data Upwards with no cap on stack/ventStack/Vent STRU28 SV004 256 5.5 111190 360 Test data Upwards with no cap on stack/ventStack/Vent STRU29 SV011 50 3 43000 80 Manufacturer Upwards with no cap on stack/ventStack/Vent STRU30 SV031 237 3 27600 180 Manufacturer Upwards with no cap on stack/ventStack/Vent STRU31 SV039 12 0.25 687 1184 Manufacturer HorizontallyStack/Vent STRU37 SV043 45 3 458 100 Estimate Upwards with no cap on stack/ventStack/Vent STRU38 SV002 275 6 77625 554 Estimate Upwards with no cap on stack/ventStack/Vent STRU40 SV003 253 8 144760 375 Test data Upwards with no cap on stack/ventStack/Vent STRU41 SV005 278 10 272000 413 Test data Upwards with no cap on stack/ventStack/Vent STRU42 SV006 325 11 406161 350 Estimate Upwards with no cap on stack/ventStack/Vent STRU43 SV009 70 1.5 1000 50 Manufacturer Upwards with no cap on stack/ventStack/Vent STRU44 SV010 77 2.2 11000 145 Manufacturer Upwards with no cap on stack/ventStack/Vent STRU47 SV029 300 4.6 37000 173 Manufacturer Upwards with no cap on stack/ventStack/Vent STRU49 SV036 53 9.9 167750 165 Manufacturer Upwards with no cap on stack/ventStack/Vent STRU50 SV037 70 9.2 118414 130 Manufacturer Upwards with no cap on stack/ventStack/Vent STRU51 SV038 68 6.7 62406 160 Manufacturer Upwards with no cap on stack/ventStack/Vent STRU59 192 2 13.5 42 Estimate Upwards with no cap on stack/ventStack/Vent STRU60 SV085 7 0.5 800 1000 Manufacturer Horizontally

BuildingsSubject Item Type Description Subject Item ID Subject Item Designation Height Units (height) Length Units (length) Width Units (width)Building STRU1 BG001 66 feet 110 feet 40 feetBuilding STRU2 BG002 16.1 feet 23 feet 21 feetBuilding STRU4 BG004 407 feet 108 feet 60 feetBuilding STRU5 BG005 49.9 feet 98 feet 76 feetBuilding STRU6 BG006 12.1 feet 18 feet 14 feetBuilding STRU7 BG007 89.9 feet 70 feet 47 feetBuilding STRU8 BG008 103 feet 64 feet 33 feetBuilding STRU9 BG009 70.9 feet 66 feet 60 feetBuilding STRU10 BG010 42 feet 54 feet 36 feetBuilding STRU11 BG011 9.9 feet 44 feet 24 feetBuilding STRU12 BG012 40 feet 170 feet 128 feetBuilding STRU13 BG013 22 feet 40 feet 28 feetBuilding STRU14 BG014 16.1 feet 135 feet 55 feetBuilding STRU15 BG015 20 feet 40 feet 50 feetBuilding STRU16 BG016 12.1 feet 44 feet 23 feetBuilding STRU17 BG017 70.9 feet 160 feet 158 feetBuilding STRU18 BG018 16.1 feet 44 feet 41 feetBuilding STRU20 BG020 21 feet 75 feet 32.5 feetBuilding STRU21 BG021 40 feet 20 feet 20 feetBuilding STRU24 BG024 72.2 feet 92 feet 62 feetBuilding STRU25 BG025 75.1 feet 49 feet 25 feet

Fugitive SourcesSubject Item Type Description Subject Item ID Subject Item Designation Install Year Pollutants Emitted SI NameAir Landfill FUGI5 FS006 1999 Particulate Matter LandfillAir Landfill FUGI5 FS006 1999 PM < 2.5 micron LandfillAir Landfill FUGI5 FS006 1999 PM < 10 micron LandfillCooling Tower FUGI2 EU087 1986 Particulate Matter Existing Cooling Tower ‐ zFugativeCooling Tower FUGI2 EU087 1986 PM < 2.5 micron Existing Cooling Tower ‐ zFugativeCooling Tower FUGI2 EU087 1986 PM < 10 micron Existing Cooling Tower ‐ zFugativeMaterial Handling/Transfer/Storage FUGI8 FS001 1965 Particulate Matter Fly Ash HandlingMaterial Handling/Transfer/Storage FUGI8 FS001 1965 PM < 2.5 micron Fly Ash HandlingMaterial Handling/Transfer/Storage FUGI8 FS001 1965 PM < 10 micron Fly Ash HandlingMaterial Handling/Transfer/Storage FUGI11 FS009 1965 Particulate Matter Material Handling/Transfer/StorageMaterial Handling/Transfer/Storage FUGI11 FS009 1965 PM < 2.5 micron Material Handling/Transfer/StorageMaterial Handling/Transfer/Storage FUGI11 FS009 1965 PM < 10 micron Material Handling/Transfer/StorageOpen Air Source FUGI3 FS002 1965 Particulate Matter Fuel YardOpen Air Source FUGI3 FS002 1965 PM < 2.5 micron Fuel YardOpen Air Source FUGI3 FS002 1965 PM < 10 micron Fuel YardPaved Road FUGI6 FS008 1965 Particulate Matter Paved RoadsPaved Road FUGI6 FS008 1965 PM < 2.5 micron Paved RoadsPaved Road FUGI6 FS008 1965 PM < 10 micron Paved RoadsPiles FUGI9 FS004 1971 Particulate Matter Wood Chip PilePiles FUGI9 FS004 1971 PM < 2.5 micron Wood Chip PilePiles FUGI9 FS004 1971 PM < 10 micron Wood Chip PileUnpaved Roads FUGI7 FS005 1965 Particulate Matter Unpaved RoadsUnpaved Roads FUGI7 FS005 1965 PM < 2.5 micron Unpaved RoadsUnpaved Roads FUGI7 FS005 1965 PM < 10 micron Unpaved Roads

Data Acquisition SystemsSubject Item ID Subject Item Designation Manufacturer Model Serial Number Primary or backup DAS? Das Install DateEQUI63 DA003 Teledyne Monitor Labs Version 5.1.0 NA P 11/1/2008EQUI65 DA002 OSI Software Inc 2012Sp2 3.3.2.2076 P 11/1/2008

Parametric MonitorsSubject Item ID

Subject Item Designation Manufacturer Model Serial Number

Parameter Monitored (parametric monitors)

Pm Bypass Flag

Pm Install Date

EQUI70 MR032 Rosemount 8140 SDT091 Liquid Flow Rate N 7/1/1998EQUI72 MR040 Foxboro 871A‐3F‐13 562AIC785 pH N 1/1/2001EQUI77 MR045 Rosemount 3051G1 SDT‐093 Pressure Drop N 5/31/2013EQUI109 MR033 Rosemount V‐150 SDT092 Liquid Flow Rate N 7/1/1998EQUI127 MR031 Rosemount 8140 SDT090 Pressure Drop N 7/1/1998EQUI129 MR034 TBI TB82PH000101 BP090 pH N 12/1/1999EQUI130 MR035 Fischer & Porter 505M13A1CXD1DACEC2101 BP091 Liquid Flow Rate N 12/1/1999EQUI131 MR036 KEILSEN‐KULIAN A200‐1 BP093 Secondary Current N 12/1/1999EQUI132 MR037 Rosemount 1151DP5E23B3 R8090 Liquid Flow Rate N 12/1/1999EQUI133 MR038 Pyromation 111023 8092754 Temperature N 10/1/2000EQUI134 MR039 Rosemount V‐150 562F1789 Liquid Flow Rate N 1/1/2001EQUI291 MR026 EMRC Pitot Tube 743 Air N 10/1/2001EQUI292 MR028 EMRC Pitot Tube 742 Air N 10/1/2001EQUI293 MR029 EMRC Pitot Tube 8478049 Air N 7/1/1998

Emissions Units 1Subject Item Type Description

Subject Item ID


Max Design Capacity

Max Design Capacity Units (numerator)

Max Design Capacity Units (denominator) Material

Construction Start Date

Operation Start Date

Bleaching Equipment EQUI7 EU011 Metso CL‐PU‐020 62.5 tons hours Pulp 1/1/1999 11/15/1999Bleaching Equipment EQUI42 EU088 Wedeco Z‐Compact 8233 pounds days Pulp 4/1/2013 5/30/2013Concentrators EQUI300 EU041 HPD, Inc. 99‐38026‐04 62.5 tons hours Pulp 4/1/1993 10/18/1993Digestor EQUI15 EU034 Consolidated 1906‐GC‐XDL 62.5 tons hours Pulp 1/1/1995 1/1/1996Digestor EQUI24 EU048 Sunds Defribrator 1583 62.5 tons hours Pulp 1/1/1995 1/1/1996Digestor EQUI294 EU016 Metso CL‐PU‐010‐030 62.5 tons hours Pulp 1/1/1997 11/1/1999Dissolver EQUI51 EU031 Tampella 164225 234583 pounds hours Black Liquor Solids (Kraft Pulp Mill) 1/1/1997 5/21/1998Mixing Equipment EQUI28 EU052 Apache 164224 2100 gallons batch Material 1/1/1997 5/20/1998Other Emission Unit EQUI49 EU081 Kvaerner Chemetics NA 35 million British thermal units hours Energy 1/1/2000 10/1/2000Other Emission Unit EQUI50 EU080 Andritz TWP515D 53 tons hours Pulp 1/1/1999 12/6/1999Other Emission Unit EQUI298 EU049 Voith/Beloit NA 482 tons days Paper 12/31/1928 12/31/1928Other Emission Unit EQUI299 EU050 Voith NA 500 tons hours Paper 1/1/1988 1/1/1988Other Emission Unit EQUI301 EU009 Sterling Chemical 31‐399 1.25 tons hours Chlorine Dioxide 1/1/1993 1/1/1993Other Emission Unit EQUI302 EU013 Eimco HRCNO.17‐XH 1080000 gallons hours Waste Water 1/1/1978 1/1/1978Other Emission Unit EQUI303 EU018 Metso 172760 625 tons hours Pulp 1/1/1997 11/1/1999Other Emission Unit EQUI304 EU051 Voith/Beloit NA 1185 tons days Paper 1/1/1989 1/1/1989Other Emission Unit EQUI305 EU035 Sunds 164201 62.5 tons hours Pulp 1/1/1995 1/1/1996Other Emission Unit EQUI316 Andritz Help‐200 5 tons minutes Wafer/ChipStripping Equipment EQUI17 EU036 HPD 20‐445 62.5 tons hours Pulp 1/1/1993 1/1/1993Washer EQUI20 EU043 Sunds Defribrator 1555, 1255 62.5 tons hours Pulp 1/1/1995 1/1/1996Washer EQUI23 EU046 Moorehead Mach & Felker 7860 62.5 tons hours Pulp 1/1/1995 1/1/1996

Emission Units 2Subject Item Type Description

Subject Item ID


Max Design Capacity


Max Design Capacity Units (denominator) Material Firing Method

Subject to CSAPR?



Boiler EQUI2 EU002 Babcock & Wilcox B&W C‐10177 220000 pounds hours Steam Spreader stoker N 12/31/1965 12/31/1965Boiler EQUI4 EU004 Combustion Engineering CEVU ‐ 40 300000 pounds hours Steam Spreader stoker N 1/1/1979 1/1/1981Boiler EQUI18 EU037 Babcock & Wilcox B&W C‐00813 250000 pounds hours Steam Not coal burning N 1/1/1971 6/22/1998Boiler EQUI53 EU005 Tampella CL‐RE‐030 5.63 million pounds days Black Liquor Solids (Kraft Pulp Mill) Not coal burning N 1/1/1997 5/20/1998Boiler EQUI290 EU089 America Standard Kewanee 3.86 million British thermal units hours Steam Not coal burning N 1/1/1986 1/1/1986Kiln EQUI52 EU033 FFE Minerals CLRE040 500 tons days Lime Not coal burning 1/1/1999 11/21/1999Reciprocating IC Engine EQUI38 EU082 Cummins GGHH 60 Hz 100 kilowatts each Energy 3/28/2007 4/6/2007Reciprocating IC Engine EQUI315 EU085 Cummins CFP59‐F40 1760 revolutions per minute each Energy 3/1/2008 3/1/2008

Emission Units (Engines)

Subject Item Type Description

Subject Item ID


Max Design Capacity


Max Design Capacity Units (denominator) Material

Firing Method Engine Use

Engine Displacement

Engine Displacement Units



Reciprocating IC Engine EQUI38 EU082 Cummins GGHH 60 Hz 100 kilowatts each Energy SI

Emergency/ blackstart 6751 total cubic centimeters 3/28/2007 4/6/2007

Reciprocating IC Engine EQUI315 EU085 Cummins CFP59‐F40 1760 revolutions per minute each Energy CI Firepump 1 liters per cylinder 3/1/2008 3/1/2008

TSD Attachments Attachment 4: Points calculator


Points Calculator

1) AI ID No.: 2309 Total Points 1162) Facility Name: Sappi Cloquet LLC3) Small business? y/n? n 4) Air Project Tracking Numbers (including all rolled) : 5563, 5672 5) Date of each Application Received: 5/6/2016, 9/30/166) Final Permit No. 01700002‐1017) Permit Staff Rachel Yucuis

Total TotalApplication Type Air Project Tracking No. Tempo Activity ID Qty. Points Points Additionl Cost DetailsAdministrative Amendment 5563 IND20160001 1 1 1 285.00$ Already paidMinor Amendment 4 0 ‐$ Applicability Request 10 0 ‐$ Moderate Amendment 15 0 ‐$ Major Amendment 5672 IND20160004 1 25 25 7,125.00$ Already paidIndividual State Permit (not reissuance) 50 0 ‐$ Individual Part 70 Permit (not reissuance) 75 0 ‐$

Additional PointsModeling Review 5672 IND20160004 1 15 15 4,275.00$ NSR: PM10, PM2.5, NOx

BACT Review 5672 IND20160004 5 15 75 21,375.00$ PM, PM10, PM2.5, NOx, CO2eLAER Review 15 0 ‐$ CAA section 110(a)(2)(D)(i)(I) Review (i.e., Transport Rule/CAIR/CSAPR)

10 0 ‐$

Part 75 CEM analysis 10 0 ‐$ NSPS Review 10 0 ‐$ NESHAP Review 10 0 ‐$ Case‐by‐case MACT Review 20 0 ‐$ Netting 10 0 ‐$ Limits to remain below threshold 10 0 ‐$ Plantwide Applicability Limit (PAL) 20 0 ‐$ AERA review 15 0 ‐$ Variance request under 7000.7000 35 0 ‐$ Confidentiality request under 7000.1300 2 0 ‐$ EAW review 0Part 4410.4300, subparts 18, item A; and 29 15 0 ‐$ Part 4410.4300, subparts 8, items A & B; 10, items A to C; 16, items A & D; 17, items A to C & E to G; and 18, items B & C

35 0 ‐$

Part 4410.4300, subparts 4; 5 items A & B; 13; 15; 16, items B & C; and 17 item D

70 0 ‐$

Add'l Points 90

NOTES:

(DQ Points)

TSD Attachments Attachment 5: CAM Plans


AQ ID 01700002 Sappi Cloquet LLC Unit/Pollutant for CAM Plan: Power Boiler 7/PM, PM10 and PM2.5 I. BACKGROUND A. Emission Unit: Power Boiler 7 – EQUI 2, STRU 40 B. Applicable Regulation, Emission Limit and Monitoring Requirements: Applicable Regulations/Emission Limits:

Title I limits from modeling – 15 lbs PM/hr 21 lbs PM10/hr 10.5 lbs PM2.5/hr

Monitoring Requirements:

Opacity – EQUI 135 The existing Title V permit has opacity monitoring requirements. C. Control Technology (pollutant controlled) TREA 11 – Multiple Cyclone (PM/PM10/PM2.5) TREA 15 – High Efficiency Electrostatic Precipitator (PM/PM10/PM2.5) II. MONITORING APPROACH

Sappi proposes to use opacity as an indicator that will act as a trigger to take action at the cyclone/ESP. Power boiler 7 is subject to an opacity limit under Minn. R. 7011.0510, subp. 2. An opacity COMs has been used in the past and will continue to be used to show compliance with that limit. Unexpected or sudden increases in opacity that persist for more than very short periods of time are indications that there may be a cyclone or ESP malfunction. Such unexpected or sudden increases will be used to trigger actions to investigate the functioning of the cyclone/ESP and to take any necessary corrective actions. During an ESP malfunction, smaller particulates are likely to be emitted at higher rates. This is because ESP’s generally have lower control efficiencies for small particles than for larger particles. Smaller particles have a higher impact on opacity. Therefore, use of opacity as a monitoring parameter for an ESP is reasonable. Sappi does not propose to establish a detailed correlation between PM, PM10 or PM2.5 emissions and opacity – i.e. relationships such as X% opacity = Y lbs PM/MMBtu will not be established. Rather, changes in opacity will be used to trigger action by plant personnel to inspect and correct as necessary cyclone/ESP functionality.

CAM Plan – Sappi – Power Boiler 7 Page 2 of 2

1. Indicator: Changes in Opacity - magnitude and duration

2. Indicator Range: 10% opacity (3-hr rolling average) 20% opacity (instantaneous) These triggers are included in the operation and maintenance plan for the

cyclone/ESP on Boiler #7 3. Performance Criteria:

o Data Representativeness – Opacity is caused by interaction of particles with light (transmissivity). Therefore, changes in opacity are an indicator of potential changes in particulate emissions. The COMs is located to be representative of opacity from the unit to meet opacity monitoring requirements.

o Verification of Operational Status – COMs requirements included elsewhere in the permit for opacity compliance will address operational status (Total Facility Requirements)

o QA/QC – COMs requirements included elsewhere in the permit for opacity compliance will address QA/QC (Total Facility Requirements)

o Monitoring Frequency - Continuous

AQ ID 01700002 Sappi Cloquet LLC Unit/Pollutant for CAM Plan: Power Boiler 9/PM, PM10 and PM2.5 I. BACKGROUND A. Emission Unit: Power Boiler 9 – EQUI 4, STRU 41 B. Applicable Regulation, Emission Limit and Monitoring Requirements: Applicable Regulations/Emission Limits:

Title I limits from modeling 21.5 lbs PM/hr 30.1 lbs PM10/hr 13.5 lbs PM2.5/hr


Opacity – EQUI 136

The existing Title V permit has opacity monitoring requirements. C. Control Technology (pollutant controlled) TREA 18 – Multiple Cyclone (PM/PM10/PM2.5) TREA 19 – High Efficiency Electrostatic Precipitator (PM/PM10/PM2.5) II. MONITORING APPROACH

Sappi proposes to use opacity as an indicator that will act as a trigger to take action at the cyclone/ESP. Power boiler 9 is subject to an opacity limit under NSPS subpart D (60.42 (a) (2)). An opacity COMs has been used in the past and will continue to be used to show compliance with that limit. Unexpected or sudden increases in opacity that persist for more than very short periods of time are indications that there may be a cyclone or ESP malfunction. Such unexpected or sudden increases will be used to trigger actions to investigate the functioning of the cyclone/ESP and to take any necessary corrective actions. During an ESP malfunction, smaller particulates are likely to be emitted at higher rates. This is because ESP’s generally have lower control efficiencies for small particles than for larger particles. Smaller particles have a higher impact on opacity. Therefore, use of opacity as a monitoring parameter for an ESP is reasonable.

Sappi does not propose to establish a detailed correlation between PM, PM10 or PM2.5 emissions and opacity – i.e. relationships such as X% opacity = Y lbs PM/MMBtu will not be established. Rather, changes in opacity will be used to trigger action by plant personnel to inspect and correct as necessary cyclone/ESP functionality.

1. Indicator: Changes in Opacity - magnitude and duration 2. Indicator Range:

10% opacity (3-hr rolling average) 20% opacity (instantaneous) These triggers are included in the operation and maintenance plan for the

cyclone/ESP on Boiler #9 3. Performance Criteria:





AQ ID 01700002 Sappi Cloquet LLC Unit/Pollutant for CAM Plan: Smelt Dissolving Tank/ PM, PM10 and PM2.5 I. BACKGROUND A. Emission Unit: Recovery Boiler No. 10 - Smelt Dissolving Tank – EQUI 51, STRU 47 B. Applicable Regulation, Emission Limit and Monitoring Requirements: Applicable Regulations/Emission Limits:

Title I Limits – BACT PM – 0.12 lbs/ton Black liquor solids fired (dry virgin).

(More stringent than NSPS Subpart BB and NESHAPs Subpart MM) PM10 – 0.12 lbs/ton Black liquor solids fired (dry virgin).

Title I Limits - Modeling PM – 12.5 lbs/hr PM10 – 12.5 lbs/hr PM2.5 – 11.45 lbs/hr


Pressure Drop – EQUI 127 Scrubber Supply Pressure – EQUI 70 Scrubber Flow Rate – EQUI 109

The existing Title V permit has requirements for monitoring pressure drop, supply pressure and flow rate in accordance with NSPS Subpart BB and NESHAPs Subpart MM.

C. Control Technology (pollutant controlled) TREA 12 – Spray Tower (PM/PM10/PM2.5) TREA 6 – Ventri Rod Scrubber (PM/PM10/PM2.5) II. MONITORING APPROACH

Sappi proposes to use monitoring systems for pressure drop, scrubber supply pressure and scrubber flow rate for purposes of ensuring that the spray tower is operating as required. These are key operating parameters for a spray tower. There are NESHAPs limits from Subpart MM and related monitoring in the permit – pressure drop, scrubber liquid supply pressure and scrubber liquid flow rate. The NESHAPs monitoring meets current CAM requirements as that standard was issued after Nov. 15, 1990. However, the BACT and modeling based limits are less than the NESHAPs limits and therefore CAM must be satisfied for them. The NESHAPs requirements address the critical operating parameters for PM and PM10 for a scrubber. The indicator ranges are set based on testing and therefore will address the lower emission limits.

CAM Plan – Sappi – Recovery Boiler No. 10 - Smelt Dissolving Tank Page 2 of 2

1. Indicators:

Pressure Drop Supply Pressure Scrubber Flow

2. Indicator Range: Set based on most recent performance test. Current rates:

Pressure Drop: < 0 inches water column for TREA 12 Pressure Drop: 3 – 9 inches water column for TREA 6 Supply Pressure: 10 – 20 psi Flow Rate: ≥ 300 gallons/minute (combined TREA 12 and TREA 6)

3. Performance Criteria:

o Data Representativeness – See QA/QC below. The three types of data address all portions of the scrubbing system.

o Verification of Operational Status – records required 1/shift which can be met by continuous measurement devices. A hard copy readout or computer disk file and calculated 8-hr rolling averages are required.

o QA/QC – Calibration (or similar preventive maintenance) required annually. Also:

Supply Pressure – Accuracy required to be +/- 15% of the design scrubbing liquid supply pressure.

Pressure Drop – Accuracy required to be +/- 2 inches water gage.

o Monitoring Frequency – Once every successive 15-minute period Note that QA/QC criteria for the parameter monitoring systems are set by NESHAPs subpart MM.

AQ ID 01700002 Sappi Cloquet LLC Unit/Pollutant for CAM Plan: IQS/SO2 I. BACKGROUND A. Emission Unit: IQS – EQUI 49, STRU 30 B. Applicable Regulation, Emission Limit and Monitoring Requirements: Applicable Regulations/Emission Limits: Title I Limits

14.8 lbs SO2/hr Monitoring Requirements:

Scrubber Liquid Flow Rate – EQUI 134 Scrubber pH – EQUI 72 The existing permit has requirements to monitor both scrubber liquid flow and pH.

C. Control Technology TREA 31 – Scrubber (SO2) II. MONITORING APPROACH

Sappi proposes to use monitoring systems for pH and scrubber liquid flow rate for purposes of ensuring that the SO2 scrubber is operating as required. These are key operating parameters for a SO2 scrubber. For the scrubber to work efficiently, sufficient scrubbing fluid above a minimum pH must be supplied. Flow and pH are key parameters to ensuring removal of SO2. 1. Indicators:

Scrubber Liquid Flow Rate Scrubber Liquid pH

2. Indicator Range: Set based on most recent performance test. Current rates:

Scrubber Liquid Flow Rate: ≥ 584 gallons/minute Scrubber Liquid pH: ≥ 7.4

3. Performance Criteria:

o Data Representativeness –The two data types address the key portions of the scrubbing system.

o Verification of Operational Status – Continuous compliance required. QA/QC – Calibration (or similar preventive maintenance)

required annually. o Monitoring Frequency – Continuous

AQ ID 01700002 Sappi Cloquet LLC Unit/Pollutant for CAM Plan: IQS/VOC AND IQS/TRS I. BACKGROUND A. Emission Unit: IQS – EQUI 49, STRU 30 B. Applicable Regulation, Emission Limit and Monitoring Requirements: Applicable Regulations/Emission Limits:

Title I Limits – VOC – 4.6 lbs/hr TRS – 0.5 lbs/hr


Incinerator Temperature Monitoring – EQUI 133 The existing Title V permit has requirements for temperature in accordance with NSPS Subpart BB and NESHAPs Subpart S.

C. Control Technology TREA 30 – Incinerator (VOC and TRS) II. MONITORING APPROACH

Sappi proposes to use monitoring systems for temperature for purposes of ensuring that the incinerator is functioning properly. There are NESHAPs (Subpart S) and NSPS (Subpart BB) limits and related monitoring in the permit - temperature. The NESHAPs monitoring meets current CAM requirements because the standard was issued after Nov. 15, 1990. However, that limit is for control of HAPs rather than VOC and TRS. VOCs controlled by incinerators are typically monitored in numerous NSPS and NESHAPs requirements by monitoring temperature. NSPS Subpart BB sets monitoring for TRS and NESHAPs Subpart S sets monitoring for HAPs for an incinerator each as using temperature monitoring. Therefore, temperature monitoring is the common approach in all cases, with the required temperature set based on the most stringent needed for the pollutants addressed (HAPs, TRS, VOC).

CAM Plan – Sappi – IQS – VOC, TRS Page 2 of 2

1. Indicators:

Temperature 2. Indicator Range: Set based on most recent performance test. Current rate (most restrictive):

Temperature: ≥ 1500 degrees F and a residence time of 0.75 seconds 3. Performance Criteria:

o Data Representativeness – NESHAPs Subpart S requirements for the CMS specify location of the temperature monitor.

o Verification of Operational Status – Continuous monitoring required. Annual calibration or equivalent required.

o Monitoring Frequency – Continuous

AQ ID 01700002 Sappi Cloquet LLC Unit/Pollutant for CAM Plan: Lime Kiln/ PM, PM10 and PM2.5 I. BACKGROUND A. Emission Unit: Lime Kiln – EQUI 57,STRU 38 B. Applicable Regulation, Emission Limit and Monitoring Requirements: Applicable Regulations/Emission Limits:

Title I Limits – BACT PM – 0.035 grains/dry standard cubic foot (gr/dscf)

(More stringent than NSPS Subpart BB and NESHAPs Subpart MM) PM10 – 0.035 gr/dscf

Title I Limits - Modeling PM – 13.6 lbs/hr PM10 – 13.6 lbs/hr PM2.5 – 12.8 lbs/hr


Opacity – EQUI 108 The existing Title V permit has opacity monitoring requirements. C. Control Technology (pollutant controlled) TREA 21 – High Efficiency Electrostatic Precipitator (PM/PM10/PM2.5) II. MONITORING APPROACH

Sappi proposes to use opacity as an indicator that will act as a trigger to take action at the ESP. The Lime Kiln is subject to an opacity limit under NSPS Subpart BBa. A continuous opacity monitor (COMs) has been used in the past and will continue to be used to show compliance with that limit. Unexpected or sudden increases in opacity that persist for more than very short periods of time are indications that there may be an ESP malfunction. Such unexpected or sudden increases will be used to trigger actions to investigate the functioning of the ESP and to take any necessary corrective actions. During an ESP malfunction, smaller particulates are likely to be emitted at higher rates. This is because ESP’s generally have lower control efficiencies for small particles than for larger particles. Smaller particles have a higher impact on opacity. Therefore, use of opacity as a monitoring parameter for an ESP is reasonable. Sappi created a correlation of total PM10 emissions (gr/dscf @10% O2 and lb/hr) and opacity using measured opacity and compliance stack test data (10 tests dating from 2004 to 2016). There is a good correlation between the two parameters. The correlation is shown below and suggests that 15% opacity is a good predictor of compliance with the particulate limits.

1. Indicator: Changes in Opacity - magnitude and duration 2. Indicator Range:

15% opacity (3-hr rolling average) Those triggers are included in the operation and maintenance plan for the

ESP on the Lime Kiln. 3. Performance Criteria:

Data Representativeness – Opacity is caused by interaction of particles with light (transmissivity). Therefore, changes in opacity are an indicator of potential changes in particulate emissions. The COMs is located to be representative of opacity from the unit to meet opacity monitoring requirements.

Verification of Operational Status – COMs requirements included elsewhere in the permit for opacity compliance will address operational status (Total Facility Requirements)

QA/QC – COMs requirements included elsewhere in the permit for opacity compliance will address QA/QC (Total Facility Requirements)

Monitoring Frequency – Continuous

CAM Plan – Sappi – IQS – VOC, TRS Page 2 of 2 AQ ID 01700002 Sappi Cloquet LLC Unit/Pollutant for CAM Plan: Recovery Boiler 10/ PM, PM10 and PM2.5 I. BACKGROUND A. Emission Unit: Recovery Boiler 10 – EQUI 53, STRU 42 B. Applicable Regulation, Emission Limit and Monitoring Requirements: Applicable Regulations/Emission Limits:

Title I Limits – BACT PM – 0.025 grains/dry standard cubic foot (gr/dscf)

(More stringent than NSPS Subpart BB and NESHAPs Subpart MM) PM10 – 0.025 gr/dscf

Title I Limits - Modeling PM – 40 lbs/hr PM10 – 40 lbs/hr PM2.5 – 37.9 lbs/hr


Opacity – EQUI 113 The existing Title V permit has opacity monitoring requirements. C. Control Technology (pollutant controlled) TREA 20 – High Efficiency Electrostatic Precipitator (PM/PM10/PM2.5) II. MONITORING APPROACH

Sappi proposes to use opacity as an indicator that will act as a trigger to take action at the ESP. Recovery Boiler 10 is subject to an opacity limit under NSPS subpart’s D and BB. An opacity COMs has been used in the past and will continue to be used to show compliance with that limit. Unexpected or sudden increases in opacity that persist for more than very short periods of time are indications that there may be an ESP malfunction. Such unexpected or sudden increases will be used to trigger actions to investigate the functioning of the ESP and to take any necessary corrective actions. During an ESP malfunction, smaller particulates are likely to be emitted at higher rates. This is because ESP’s generally have lower control efficiencies for small particles than for larger particles. Smaller particles have a higher impact on opacity. Therefore, use of opacity as a monitoring parameter for an ESP is reasonable.

Sappi created a correlation of total PM10 emissions (gr/dscf @8% O2 and lb/hr) and opacity using measured opacity and compliance stack test data (9 tests dating from 2006 to 2017). There is a strong correlation between the two parameters. The correlation is shown below and suggests that 15% opacity is a good predictor of compliance with the particulate limits.


Based on this analysis it is appropriate to use opacity to trigger action by plant personnel to inspect and correct as necessary ESP functionality. 1. Indicator: Changes in Opacity - magnitude and duration


2. Indicator Range:

15% opacity (3-hr rolling average) These triggers are included in the operation and maintenance plan for the

ESP on Recovery Boiler #10 3. Performance Criteria:





TSD Attachments Attachment 6: Permit #01700002‐014 Calculations


Operational DataSappi Cloquet Project AthenaPermit #01700002-014

Year BLS (tons)#10 Hours of

Operation BLS(tons)/hr CaO (tons)Lime Kiln

(hrs) Lime/BLSMarket Pulp

(tons)ADTUBP

(tons)BLS ton/ ADTUBP Hrs (IQS) ODTBP BLS ton/ODTBP

Bleach Plant Hrs of Operation

#4 Paper Machine (tons of

product/yr)

#12 Paper Machine (tons of product/yr)

#12 Paper Machine (mmcf)

Coater (tons of product/yr) Coater (mmcf)

Boiler 9 (Hrs)

2010 795943 8597 92.58 121547 8196 0.15 330043 532339 1.495 7892 451986 1.76 8612 170,006.0 177,399.0 61.3 377,154.8 49.0 8,502.002009 746047 8474 88.04 108788 8257 0.15 301594 481111 1.551 7611 408490 1.83 8561 144,109.0 162,571.0 39.4 333,685.0 31.5 8,588.002008 775554 8534 90.88 104067 7933 0.13 319325 508937 1.524 8034 432116 1.79 8630 149,296.0 170,034.0 44.2 327,526.3 35.4 8,625.002007 823487 8461 97.33 124010 8137 0.15 335910 508103 1.621 7539 431408 1.91 8599 143,020.4 164,982.3 50.0 318,379.1 40.0 8,532.002006 782521 8327 93.97 117493 7871 0.15 308237 489877 1.597 7470 415933 1.88 8575 145,933.0 177,265.9 50.0 315,667.3 40.0 8,599.002005 782617 8304 94.25 116856 7533 0.15 307437 462379 1.693 6963 392586 1.99 8550 160,120.0 176,855.0 0.0 291,771.2 0.0 8,624.002004 774784 8525 90.88 114458 8053 0.15 307352 489756 1.582 6750 415830 1.86 8545 141,701.0 138,975.0 304,009.0 8,561.002003 733518 8428 87.03 98735 7537 0.13 318266 467796 1.568 7341 397185 1.85 8606 124,495.0 129,017.0 253,858.0 8,557.002002 690056 8437 81.79 89808 7784 0.13 301475 446107 1.547 7227 378770 1.82 8489 123,873.0 126,405.0 253,108.0 8,587.00

Average 767170 8454 91 110640 7922 0.14 1.58 7425 8574 8575

803004 120752 144477 171124 317023

TRS Emissions Proj. Actual: 904200 Key:2010 2009 2008 2007 2006 2005 2004 2003 2002 BLS = Black Liquor Solids

#10 Recovery Boiler (EU 005) ADTUBP = Air Dried Tons Unbleached Pulpppm 0.87 0.77 0.98 1.08 0.92 0.62 0.84 0.71 0.7 ODTBP = Oven Dried Tons Bleached Pulp Recovery Boiler 821939 tons BLSlb/hr 0.835 0.739 0.941 1.037 0.883 0.595 0.806 0.682 0.672 CaO = Calcium Oxide Lime Kiln 123284 tons CAOtons per year 3.59 3.13 4.01 4.39 3.68 2.47 3.44 2.87 2.83

#10 Smelt Dissolving Tank (EU 031)lb/ton BLS (2004 test) 0.011 0.011 0.011 0.011 0.011 0.011 0.011 0.011 0.011tons per year 4.38 4.10 4.27 4.53 4.30 4.30 4.26 4.03 3.80

Lime Kiln (EU 033)lb/ton CaO (2001 test) 0.020 0.020 0.020 0.020 0.020 0.020 0.020 0.020 0.020tons per year 1.22 1.09 1.04 1.24 1.17 1.17 1.14 0.99 0.90

IQS (EU 081)lb/hr (permit limit) 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5tons per year 1.97 1.90 2.01 1.88 1.87 1.74 1.69 1.84 1.81

TOTAL 11.2 10.2 11.3 12.0 11.0 9.7 10.5 9.7 9.3

H2SO4 Emissions2010 2009 2008 2007 2006 2005 2004 2003 2002

#10 Recovery Boiler (EU 005)lb/hr (2001 test) 0.58 0.58 0.58 0.58 0.58 0.58 0.58 0.58 0.58tons per year 2.49 2.46 2.47 2.45 2.41 2.41 2.47 2.44 2.45

#10 Smelt Dissolving Tank (EU 031) Not Available (NA)

Lime Kiln (EU 033)lb/ton CaO (2001 test) 0.005 0.005 0.005 0.005 0.005 0.005 0.005 0.005 0.005tons per year 0.30 0.27 0.26 0.31 0.29 0.29 0.29 0.25 0.22

IQS (EU 081)lb/hr (permit limit) 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0tons per year 3.95 3.81 4.02 3.77 3.74 3.48 3.38 3.67 3.61

TOTAL 6.7 6.5 6.8 6.5 6.4 6.2 6.1 6.4 6.3

PM, PM10, PM2.5Revised Baseline

07/06-06/08

H:\Sappi Cloquet\TSD Attachments\Att 6 ‐ Permit 014 Calcs.xlsxOperating Data&RS Calc

Future Projected Actual (FPA) Emissions CalculationsSappi Cloquet Project Athena

Production IncreaseFuture Projected (FPA) Actual BLS

CaO at Future Projected Actual

BLStons BLS/yr tons CaO/year1,027,475 134,397

Required Relationshipstons BLS/ ADTUBP

tons CaO/ ton BLS tons BLS/ODTBP

1.50 0.153 1.76

EMISSION CALCULATIONS Derivation of Emission Factors:

#10 Recovery Boiler (EU 005) Factor and Process Data823,487 Tons BLS 8,597 Hours

Emissions Emission Factor Emission Factor Production Emission Converted Emission(tons/yr) value units in units of factor Data Units Data Units Notes

CO 231.18 0.45 lbs/ton BLS 1,027,475.00 0.45 lbs/ton CEMs 0.45 lbs/ton BLS CEM lbs/hr * hrs/yr / tons BLS Most Recent Months Data Pb NA NA NA no permit limit, no data in inventoryNOx 658.87 1.28 lbs/ton BLS 1,027,475.00 1.28 lbs/ton CEMs 1.28 lbs/ton BLS CEM lbs/hr * hrs/yr / tons BLSPM 88.36 1.72E-01 lbs/ton BLS 1,027,475.00 lbs/hr, tests 1.72E-01 lbs/ton BLSPM10 87.85 1.71E-01 lbs/ton BLS 1,027,475.00 lbs/hr, tests 1.71E-01 lbs/ton BLSPM2.5 47.26 9.20E-02 lbs/ton BLS 1,027,475.00 lbs/hr, tests 9.20E-02 lbs/ton BLS Calc based on PM10 & AP42 Table 10.2-2 (9/90) (controlled)SOx 22.09 4.30E-02 lbs/ton BLS 1,027,475.00 4.30E-02 lbs/ton CEMs 4.30E-02 lbs/ton BLS CEM lbs/hr * hrs/yr / tons BLSVOC 6.70 1.30E-02 lbs/ton BLS 1,027,475.00 1.25 lbs/hr, tests 1.30E-02 lbs/ton BLSTRS 4.67 9.08E-03 lbs/ton BLS 1,027,475.00 8.70E-01 lbs/hr, CEM 3 9.08E-03 lbs/ton BLS CEM lbs/hr * hrs/yr / tons BLS, and note 3H2SO4 2.82 5.50E-03 lbs/ton BLS 1,027,475.00 5.80E-01 < lbs/hr, test 7/2001 5.50E-03 lbs/ton BLSCO2e 1,210,964.23 2,357.2 lb/ton BLS 1,027,475.00 946,406.60 tpy 2,357.2 lbs/ton BLS See Baseline CO2e CalculationsCO2e (no bio) 4,180.8 8.14 lb/ton BLS 1,027,475.00 3,267.40 tpy 8.14 lbs/ton BLS See Baseline CO2e Calculations

#10 Smelt Dissolving Tank (EU 031) Factor and Process DataEmissions Emission Factor Emission Factor Production Emission Converted Emission(tons/yr) value units units of factor Data Units Data Units Notes

CO NA NA NAPb NA NA NANOx NA NA NAPM 29.14 5.67E-02 lbs/ton BLS 1,027,475.00 5.67E-02 lbs/ton BLS 5.67E-02 lbs/ton BLS Stack Test PM10 42.03 8.18E-02 lbs/ton BLS 1,027,475.00 8.18E-02 lbs/ton BLS 8.18E-02 lbs/ton BLS Stack Test PM2.5 24.83 4.83E-02 lbs/ton BLS 1,027,475.00 4.83E-02 lbs/ton BLS 4.83E-02 lbs/ton BLS Calc based on PM10 and AP42 Table 10.2-6 (9/90) (controlledSOx 0.487 9.48E-04 lbs/ton BLS 1,027,475.00 0.10 lbs/hr, test 7/2001 9.48E-04 lbs/ton BLS Stack Test VOC 3.08 6.00E-03 lbs/ton BLS 1,027,475.00 6.00E-03 lbs/ton BLS 6.00E-03 lbs/ton BLS Stack Test TRS 5.65 1.10E-02 lbs/ton BLS 1,027,475.00 1.10E-02 lbs/ton BLS 1.10E-02 lbs/ton BLS Stack Test H2SO4 NA NA NACO2e NA NA NA

Lime Kiln (EU 033) Factor and Process Data124,010 tons CaO 8257 Hours

Emissions Emission Factor Emission Factor Production Emissions Data Converted Emission(tons/yr) value units units of factor Rate Units Rate Units Notes

CO 3.45 5.13E-02 lbs/ton CaO 134,397.12 0.77 lb/hr 5.13E-02 lbs/ton CaO Stack TestsPb 3.21E-02 4.77E-04 lbs/ton CaO 134,397.12 1.09E-04 lb/ADTUBP 4.77E-04 lbs/ton CaO from EB inventory, converted using 1.74 ADTUBP/ton BLS, NOx 124.93 1.86 lbs/ton CaO 134,397.12 1.86 lbs/ton CaO 1.86 lbs/ton CaO Stack TestsPM 35.61 0.530 lbs/ton CaO 134,397.12 0.53 lbs/ton CaO 0.53 lbs/ton CaO Stack TestsPM10 37.63 0.560 lbs/ton CaO 134,397.12 0.56 lbs/ton CaO 0.56 lbs/ton CaO Stack TestsPM2.5 29.74 0.443 lbs/ton CaO 134,397.12 0.44 lbs/ton CaO 0.44 lbs/ton CaO Calc based on PM10 and AP42 Table 10.2-5 (9/90) (controlledSOx 2.61 3.88E-02 lbs/ton CaO 134,397.12 0.58 lb/hr 3.88E-02 lbs/ton CaO Stack TestsVOC 0.345 5.13E-03 lbs/ton CaO 134,397.12 7.70E-02 lb/hr 5.13E-03 lbs/ton CaO Stack TestsTRS 1.33 1.97E-02 lbs/ton CaO 134,397.12 0.30 < lbs/hr, tst 1/25/2001 1.97E-02 lbs/ton CaO 364.9 tons CaO/day during test, assumed 24 hrs/dy 1

H2SO4 0.337 0.00502 lbs/ton CaO 134,397.12 5.02E-03 lbs/ton CaO 5.02E-03 lbs/ton Ca\O Test 1/25/2001 1

CO2e 49,625.03 738.48 lbs/ton CaO 134,397.12 44,586.50 tpy 738.48 lbs/ton CaO See Baseline CO2e Calculations

H:\Sappi Cloquet\TSD Attachments\Att 6 ‐ Permit 014 Calcs.xlsxFPA

Future Projected Actual (FPA) Emissions CalculationsSappi Cloquet Project AthenaIQS (NCG) (EU 081) Factor and Process Data

823,487 Tons BLS 8034.00 IQS HrsEmissions Emission Factor Emission Factor Production Emission Data Converted Emission(tons/yr) value units units of factor Rate Units Rate Units Notes

CO 25.81 5.02E-02 lbs/ton BLS 1,027,475.00 5.15 lbs/hr 5.02E-02 lbs/ton BLS Stack TestsPb NA NA NA NANOx 34.08 6.63E-02 lbs/ton BLS 1,027,475.00 6.80 lbs/hr 6.63E-02 lbs/ton BLS Stack TestsPM 10.13 2.70E+00 lb/hr 8,034.00 2.70 lbs/hr 2.70E+00 lb/hr Stack Tests, No change in PM emissions as a result of projectPM10 15.27 4.07E+00 lb/hr 8,034.00 4.07 lbs/hr 4.07E+00 lb/hr Stack Tests, No change in PM emissions as a result of projectPM2.5 10.13 2.70E+00 lb/hr 8,034.00 2.70 lbs/hr 2.70E+00 lb/hr Assume PM2.5 equals total particulatesSOx 7.42 1.44E-02 lbs/ton BLS 1,027,475.00 1.48 lbs/hr 1.44E-02 lbs/ton BLS Stack TestsVOC 1.06 2.06E-03 lbs/ton BLS 1,027,475.00 0.21 lbs/hr 2.06E-03 lbs/ton BLS Stack TestsTRS 2.73 5.32E-03 lbs/ton BLS 1,027,475.00 0.50 lbs/hr 5.32E-03 lbs/ton BLS Used permitted emission rate - 8760 hours at 0.5 lbs/hrH2SO4 5.46 1.06E-02 lbs/ton BLS 1,027,475.00 1.00 lbs/hr 1.06E-02 lbs/ton BLS Used permitted emission rate - 8760 hours at 1 lbs/hrCO2e 17,050.37 33.19 lbs/ton BLS 1,027,475.00 13,325.40 tpy 33.19 lb/ton BLS See Baseline CO2e Calculations

Market Pulp Machine (EU 080) Factor and Process DataProduction:Based on 1200 tpd for Kraft Pulp Assumption: Pulp is fairly wet - no PM emissions 8379 2010 hours of operation

Emissions Emission Factor Emission Factor Production Emission Data Converted Emission(tons/yr) value units units of factor Rate Units Rate Units Notes

CO NA NA NA NAPb NA NA NA NANOx NA NA NA NAPM NA NA NA NAPM10 NA NA NA NAPM2.5 NA NA NA NASOx NA NA NA NAVOC 18.83 8.60E-02 NA 438,000 8.60E-02 lb/ADTFP 8.60E-02 lb/ADTFP Emission factors derived from NCASI TB 681TRS NA NA NA NAH2SO4 NA NA NA NA

Bleach Plant (EU 011) Include Emissions from Ozone System Factor and Process Data(See Worksheet Tab Titled Ozone) 823,487 BLS 8630 hours


CO 159.43 36.40 lb/hr 8,760 36.40 lbs/hr 36.40 lb/hr Stack TestPb NA NA NA NANOx NA NA NA NAPM NA NA NA NAPM10 NA NA NA NAPM2.5 NA NA NA NASOx NA NA NA NAVOC 12.26 2.80 lb/hr 8,760 2.80 lbs/hr 2.80 lb/hr Stack TestTRS NA NA NA NAH2SO4 NA NA NA NAOzone 0.1249 2.40188 lb/hr 104.0 2.402 lbs/hr 2.4019 Vendor Data


Future Projected Actual (FPA) Emissions CalculationsSappi Cloquet Project Athena#4 Paper Machine (EU 049) Factor and Process Data

170,006 tons paper 2009 173,406 tons paper with 2% increaseEmissions Emission Factor Emission Factor Production Emission Data Converted Emission(tons/yr) value units units of factor Rate Units Rate Units Notes

CO NA NA NA NAPb NA NA NA NANOx NA NA NA NAPM 3.77 0.861 NA 8,760 0.0435 lb/ADTFP 0.86 lb/hr Emission factors derived from NCASIPM10 2.90 0.663 NA 8,760 0.0335 lb/ADTFP 0.66 lb/hr Emission factors derived from NCASIPM2.5 2.90 0.663 NA 8,760 0.0335 lb/ADTFP 0.66 lb/hr Assumed equal to PM10SOx NA NA NA NAVOC 8.15 1.86 lb/hr 8,760 0.094 lbs/ton (as C3H8) 1.86 lb/hr Emission factors derived from NCASI TB 681TRS NA NA NA NAH2SO4 NA NA NA NA

#12 Paper Machine (EU 050) Factor and Process Data180,947 tons paper with 2% increase 62.485098 mmcf with 2% increase 177,399 tons paper 2008 61.3 mmcf


CO 2.62 0.60 lb/hr 8,760 84.00 lb/MMCF 0.59 lb/hr AP-42 / FIREPb 0.00 0.00 lb/hr 8,760 0.005 lb/MMCF 0.0000 lb/hr AP-42 / FIRENOx 3.12 0.71 lb/hr 8,760 100 lb/MMCF 0.6993 lb/hr AP-42 / FIRE

4.17 0.95 lb/hr 8,760 7.6 lb/MMCF 0.0531 lb/hr AP-42 / FIRE0.0435 lb/ADTFP 0.90 lb/hr Emission factors derived from NCASI

3.26 0.75 lb/hr 8,760 7.6 lb/MMCF 0.0531 lb/hr AP-42 / FIRE0.0335 lb/ADTFP 0.69 lb/hr Emission factors derived from NCASI

3.26 0.75 lb/hr 8,760 7.6 lb/MMCF 0.0531 lb/hr AP-42 / FIRE0.0335 lb/ADTFP 0.69 lb/hr Assumed equal to PM10

SOx 0.0187 0.004 lb/hr 8,760 0.6 lb/MMCF 0.0042 lb/hr AP-42 / FIRE0.094 lbs/ton (as C3H8) 1.94 lb/hr Emission factors derived from NCASI TB 681

5.5 lb/MMCF 0.0385 lb/hr AP-42 / FIRETRS NA NA NA NAH2SO4 NA NA NA NACO2e 3,772.4 120,744.11 lb/MMcf 62.5 3,020.4 tpy 120,744.11 lb/MMcf See Baseline CO2e Calculations

Coater (EU 051) Factor and Process Data 49.99 mmcf with 2% increase377,155 tons paper 2010 49.0 384,698 tons paper with 2% increase


CO 2.10 84.00 lb/MMCF 50.0 84.00 lb/MMCF 84.00 lb/MMCF AP-42 / FIREPb 0.00 0.01 lb/MMCF 50.0 0.005 lb/MMCF 0.005 lb/MMCF AP-42 / FIRENOx 2.50 100.00 lb/MMCF 50.0 100 lb/MMCF 100.00 lb/MMCF AP-42 / FIREPM 0.04 lb/hr 50.0 7.6 lb/MMCF 7.60 lb/MMCF AP-42 / FIRE

0.40 lb/hr 0.0092 lb/ton 0.40 lb/hrPM10 0.04 lb/hr 50.0 7.6 lb/MMCF 7.60 lb/MMCF AP-42 / FIRE

0.36 lb/hr 0.0081 lb/ton 0.36 lb/hrPM2.5 0.04 lb/hr 50.0 7.6 lb/MMCF 7.60 lb/MMCF AP-42 / FIRE

0.34 lb/hr 0.0077 lb/ton 0.34 lb/hrSOx 0.0150 0.60 lb/MMCF 50.0 0.6 lb/MMCF 0.60 lb/MMCF AP-42 / FIRE

0.032 lbs/ton (as C3H8) 1.41 lb/hr Emission factors derived from NCASI TB 6815.5 lb/MMCF 0.03 lb/hr AP-42 / FIRE

TRS NA NA NA NAH2SO4 NA NA NA NACO2e 3,018.0 120,744 lb/MMcf 50.0 2,416 tpy 120,744.12 lb/MMcf See Baseline CO2e Calculations

1. Process data for conversion from Sappi Emissions Inventory2. Recovery Boiler TRSEB 20009 inventory states 0.77 ppm TRS 0.7392 lbs/hr (Proportioned)Permit limit 5 ppm TRS equivalent to 4.8 lbs/hr3. Recovery Boiler CEM data includes hours on gas. Adjusting for this might reduce emissions slightly.ADTFP = Air Dried Ton Finished Product BLS = Black Liquor SolidsADTUBP = Air Dried Tons Unbleached Pulp ODTBP = Oven Dried Tons Bleached Pulp

PM

PM10

PM2.5

VOC 8.67

VOC 6.29 1.44 lb/hr 8,760

lb/hr 8,760

1.96

1.75

1.67

1.98


Baseline Actual Emission CalculationsSappi Cloquet Project Athena

Baseline Year#10 Recovery Boiler (EU 005) 2002 2003 2004 2005 2006 2007 2008 2009 2010 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/2010

CO 150.09 213.15 305.23 154.00 266.00 249.00 162.00 150.00 156.00 181.62 259.19 229.62 210.00 257.50 205.50 156.00 153.00Lead 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00NOx 398.88 291.85 453.01 379.00 552.00 574.50 538.00 540.00 614.00 345.37 372.43 416.01 465.50 563.25 556.25 539.00 577.00PM 67.31 67.31 70.83 66.71 64.17 68.46 0.00 0.00 33.65 67.31 70.70 68.77 65.44 66.32

PM10 67.70 67.70 71.24 67.10 64.55 68.86 0.00 0.00 33.85 67.70 71.11 69.17 65.82 66.70PM2.5 0.00 0.00 0.00 36.42 36.42 38.33 36.10 34.73 37.05 0.00 0.00 18.21 36.42 38.26 37.21 35.41 35.89

SO2 6.03 4.12 1.23 11.70 22.80 73.40 63.50 16.30 14.80 5.08 2.68 6.47 17.25 48.10 68.45 39.90 15.55VOC 5.55 5.38 5.43 5.25 5.23 5.32 5.40 5.48 5.51 5.46 5.40 5.34 5.24 5.28 5.36 5.44 5.50TRS 2.83 2.87 3.44 2.47 3.68 4.39 4.01 3.13 3.59 2.85 3.15 2.95 3.07 4.03 4.20 3.57 3.36

H2SO4 0.58 2.44 2.47 2.41 2.41 2.45 2.47 2.46 2.49 1.51 2.46 2.44 2.41 2.43 2.46 2.47 2.48CO2e 946,407 942,242

CO2e (no bio) 3,267.4 2,494.46

Smelt Dissolving Tank (EU 031) 2002 2003 2004 2005 2006 2007 2008 2009 2010 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/2010

CO 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Lead 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00PM 19.56 20.80 21.97 22.19 22.18 23.35 21.99 21.15 22.56 20.18 21.38 22.08 22.19 23.31 22.67 21.57 21.86

PM10 28.22 30.00 31.69 32.01 32.08 33.68 31.72 30.52 32.55 29.11 30.84 31.85 32.05 33.66 32.70 31.12 31.54PM2.5 16.67 17.72 18.71 18.90 18.90 19.89 18.73 18.02 19.23 17.19 18.22 18.81 18.90 19.86 19.31 18.38 18.62

SO2 0.42 0.42 0.43 0.42 0.42 0.42 0.43 0.42 0.42 0.42 0.42 0.42 0.42 0.42 0.42 0.43 0.42VOC 1.34 1.40 1.47 1.39 1.47 1.52 1.53 0.94 1.60 1.37 1.44 1.43 1.43 1.50 1.53 1.24 1.27TRS 3.80 4.03 4.26 4.30 4.30 4.53 4.27 4.10 4.38 3.91 4.15 4.28 4.30 4.42 4.40 4.18 4.24

H2SO4 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00CO2e 0 0.00

Lime Kiln (EU 033) 2002 2003 2004 2005 2006 2007 2008 2009 2010 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/2010CO 3.00 2.90 3.10 2.90 3.03 3.13 3.05 3.18 3.16 2.95 3.00 3.00 2.97 3.08 3.09 3.12 3.17

Lead 0.02 0.02 0.02 0.02 0.02 0.03 0.03 0.00 0.00 0.02 0.02 0.02 0.02 0.02 0.03 0.01 0.00NOx 83.52 91.82 106.45 108.68 109.27 115.33 96.78 101.17 113.04 87.67 99.14 107.56 108.97 112.30 106.06 98.98 107.11PM 23.80 26.16 30.33 30.97 31.14 32.86 27.58 28.83 32.21 24.98 28.25 30.65 31.05 32.67 30.22 28.20 30.52

PM10 25.15 27.65 32.05 32.72 32.90 34.72 29.14 30.46 34.03 26.40 29.85 32.38 32.81 34.52 31.93 29.80 32.25PM2.5 19.87 21.85 25.33 25.86 26.00 27.44 23.03 24.07 26.90 20.86 23.59 25.59 25.93 27.28 25.23 23.55 25.48

SO2 2.26 2.19 2.34 2.18 2.28 2.36 2.30 2.39 2.38 2.22 2.26 2.26 2.23 2.32 2.33 2.35 2.39VOC 0.30 0.29 0.31 0.29 0.30 0.31 0.31 0.32 0.32 0.29 0.30 0.30 0.30 0.31 0.31 0.31 0.32TRS 0.90 0.99 1.14 1.17 1.17 1.24 1.04 1.09 1.22 0.94 1.07 1.16 1.17 1.21 1.14 1.06 1.15

H2SO4 0.22 0.25 0.29 0.29 0.29 0.31 0.26 0.27 0.30 0.24 0.27 0.29 0.29 0.30 0.29 0.27 0.29CO2e 44586.5 43,377.21

PM, PM10, PM2.5 Revised based on baseline years.

H:\Sappi Cloquet\TSD Attachments\Att 6 ‐ Permit 014 Calcs.xlsxBaseline Actual


Baseline Year


IQS (EU 081) 2002 2003 2004 2005 2006 2007 2008 2009 2010 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/2010CO 18.61 18.90 17.38 17.93 19.24 19.41 20.69 19.60 20.32 18.76 18.14 17.66 18.58 19.32 20.05 20.14 19.96

Lead 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00NOx 24.57 24.96 22.95 23.67 25.40 25.63 27.32 25.88 26.83 24.77 23.95 23.31 24.54 25.52 26.47 26.60 26.35PM 9.76 9.91 9.11 9.40 10.08 10.18 10.85 10.27 10.65 9.83 9.51 9.26 9.74 10.13 10.51 10.56 10.46

PM10 14.71 14.94 13.74 14.17 15.20 15.34 16.35 15.49 16.06 14.82 14.34 13.95 14.69 15.27 15.85 15.92 15.77PM2.5 9.76 9.91 9.11 9.40 10.08 10.18 10.85 10.27 10.65 9.83 9.51 9.26 9.74 10.13 10.51 10.56 10.46

SO2 5.35 5.43 5.00 5.15 5.53 5.58 5.95 5.63 5.84 5.39 5.21 5.07 5.34 5.55 5.76 5.79 5.74VOC 0.76 0.77 0.71 0.73 1.28 0.79 0.84 0.80 0.83 0.76 0.74 0.72 1.00 1.03 0.82 0.82 0.81TRS 1.81 1.84 1.69 1.74 1.87 1.88 2.01 1.90 1.97 1.82 1.76 1.71 1.80 1.88 1.95 1.96 1.94

H2SO4 3.61 3.67 3.38 3.48 3.74 3.77 4.02 3.81 3.95 3.64 3.52 3.43 3.61 3.75 3.89 3.91 3.88CO2e 13325.4 13826.09

Market Pulp (EU 080) 2002 2003 2004 2005 2006 2007 2008 2009 2010 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/2010CO 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Lead 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00PM 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

PM10 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00PM2.5 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

SO2 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00VOC 10.55 11.14 10.76 10.76 10.79 11.76 13.73 12.97 14.19 10.85 10.95 10.76 10.77 11.27 12.74 13.35 13.58TRS 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

H2SO4 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00CO2e 0 0.00

Bleach Plant (EU 011) 2002 2003 2004 2005 2006 2007 2008 2009 2010 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/2010CO 154.50 156.63 155.52 155.61 156.07 156.50 157.07 155.81 156.74 155.56 156.07 155.56 155.84 156.28 156.78 156.44 156.27

Lead 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00PM 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

PM10 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00PM2.5 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

SO2 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00VOC 11.88 12.05 11.96 11.97 12.01 12.04 12.08 11.99 12.06 11.97 12.01 11.97 11.99 12.02 12.06 12.03 12.02TRS 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

H2SO4 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00CO2e 0 0.00



Baseline Year


#4 Paper Machine (EU 049) 2002 2003 2004 2005 2006 2007 2008 2009 2010 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/2010

CO 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Lead 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00NOx 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00PM 3.17 3.11 3.25 3.13 3.70 0.00 0.00 0.00 1.59 3.14 3.18 3.19 3.42

PM10 2.44 2.40 2.50 2.41 2.85 0.00 0.00 0.00 1.22 2.42 2.45 2.46 2.63PM2.5 2.44 2.40 2.50 2.41 2.85 0.00 0.00 0.00 1.22 2.42 2.45 2.46 2.63

SO2 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00VOC 2.35 2.37 2.82 3.14 3.22 2.58 9.51 9.76 8.67 2.36 2.59 2.98 3.18 2.90 6.04 9.63 9.21TRS 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

H2SO4 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00CO2e 0 0.00

#12 Paper Machine (EU 050) 2002 2003 2004 2005 2006 2007 2008 2009 2010 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/2010

CO 2.10 2.10 1.86 1.65 2.57 0.00 0.00 0.00 1.05 2.10 1.98 1.76 2.11Lead 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00NOx 2.50 2.50 2.50 2.21 1.97 3.06 0.00 0.00 1.25 2.50 2.50 2.36 2.09 2.52

Combustion PM 0.17 0.15 0.17 0.15 0.23 0.00 0.00 0.00 2.01 3.88 3.80 3.78 3.89Process PM 3.86 3.59 3.70 3.54 3.86

Combustion PM10 0.19 0.19 0.17 0.15 0.23 0.00 0.00 0.00 1.58 3.05 2.99 2.95 3.04Process PM10 2.97 2.76 2.85 2.72 2.97

Combustion PM2.5 0.19 0.19 0.17 0.15 0.23 0.00 0.00 0.00 1.58 3.05 2.99 2.95 3.04Process PM2.5 2.97 2.76 2.85 2.72 2.97

SO2 0.02 0.02 0.01 0.01 0.02 0.00 0.00 0.00 0.01 0.02 0.02 0.01 0.02VOC 2.40 2.45 2.63 3.70 3.67 3.16 10.77 10.43 9.55 2.43 2.54 3.17 3.68 3.41 6.97 10.60 9.99TRS 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

H2SO4 0.00 0.00 0.00 0.00 0.00 0.0000 0.0000 0.000CO2e 3020.4 2,844.4

Coater (EU 051) 2002 2003 2004 2005 2006 2007 2008 2009 2010 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/2010CO 1.68 1.68 1.49 1.32 2.06 0.00 0.00 0.00 0.84 1.68 1.59 1.41 1.69

Lead 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00NOx 2.50 2.00 2.00 1.77 1.57 2.45 0.00 0.00 1.25 2.25 2.00 1.89 1.67 2.01PM 0.19 1.60 1.63 0.13 0.12 0.19 0.00 0.00 0.10 0.90 1.61 0.88 0.13 0.16

PM10 0.19 1.43 1.45 0.13 0.12 0.19 0.00 0.00 0.10 0.81 1.44 0.79 0.13 0.16PM2.5 0.19 1.36 1.38 0.13 0.12 0.19 0.00 0.00 0.10 0.78 1.37 0.76 0.13 0.16

SO2 0.02 0.01 0.01 0.01 0.01 0.01 0.00 0.00 0.01 0.01 0.01 0.01 0.01 0.01VOC 2.15 2.16 2.58 2.48 2.68 2.73 5.38 5.48 6.53 2.15 2.37 2.53 2.58 2.70 4.05 5.43 6.00TRS 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

H2SO4 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00CO2e 2416.3

Total 2002 2003 2004 2005 2006 2007 2008 2009 2010 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09 2009/2010CO 326.20 391.58 481.23 330.44 448.11 431.83 346.16 331.56 340.84 358.89 436.41 405.84 389.28 439.97 388.99 338.86 336.20

Lead 0.02 0.02 0.02 0.02 0.02 0.03 0.03 0.00 0.00 0.02 0.02 0.02 0.02 0.02 0.03 0.01 0.00NOx 506.97 408.63 582.41 516.35 691.17 719.96 666.08 670.59 759.38 457.80 495.52 549.38 603.76 705.56 693.02 668.33 714.98PM 53.12 56.87 61.41 130.05 139.51 145.69 134.37 131.37 141.87 54.99 59.14 95.73 134.78 145.44 140.03 132.87 136.62

PM10 68.08 72.59 77.47 146.78 154.92 161.78 149.95 146.42 157.74 70.33 75.03 112.13 150.85 161.46 155.87 148.19 152.08PM2.5 46.30 49.48 53.15 90.77 98.37 102.56 94.35 92.50 100.06 47.89 51.31 71.96 94.57 102.36 98.46 93.43 96.28

SO2 14.06 12.16 8.99 19.47 31.06 81.79 72.19 24.77 23.47 13.11 10.57 14.23 25.26 56.42 76.99 48.48 24.12VOC 37.29 38.01 38.68 39.71 40.64 40.22 59.55 58.15 59.25 37.65 38.34 39.19 40.17 40.43 49.89 58.85 58.70TRS 9.33 9.73 10.53 9.68 11.02 12.04 11.33 10.23 11.16 9.53 10.13 10.11 10.35 11.53 11.68 10.78 10.69

H2SO4 4.42 6.36 6.13 6.18 6.44 6.53 6.75 6.53 6.74 5.39 6.25 6.16 6.31 6.49 6.64 6.64 6.64CO2e 1,009,755 1,002,289

CO2e (no bio) 66,616 62,542


STEP 1: NSR and NETTING APPLICABILITYFPA-Baseline Actual Emission CalculationsSappi Cloquet Project Athena

FPA* PA FPA-PA** FPA* PA FPA-PA** FPA* PA FPA-PA**Pollutant (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy)PM 88.36 70.70 17.66 29.14 23.31 5.84 35.61 32.67 2.94PM10 87.85 71.11 16.74 42.03 33.66 8.38 37.63 34.52 3.11PM2.5 47.26 38.26 9.01 24.83 19.86 4.97 29.74 27.28 2.46Pb 0.00 0.00 0.00 0.00 0.00 0.00 0.03 0.02 0.01NOx 658.87 563.25 95.62 0.00 0.00 0.00 124.93 112.30 12.63CO 231.18 257.50 0.00 0.00 0.00 0.00 3.45 3.08 0.36SOx 22.09 48.10 0.00 0.49 0.42 0.07 2.61 2.32 0.29VOC 6.70 5.28 1.43 3.08 1.50 1.59 0.34 0.31 0.04TRS 4.67 4.03 0.63 5.65 4.42 1.23 1.33 1.21 0.12H2SO4 2.82 2.43 0.39 0.00 0.00 0.00 0.34 0.30 0.04CO2e (No Biogenics) 4,181 3,267 913 0.00 0.00 0.00 49,625 44,587 5,039Ozone 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

* FPA = Future projected actuals** Negatives Set at Zero*** Burns NG and Diesel; Pulping Liquors not included

Recovery Boiler (EU 005) *** Smelt Dissolving Tank (EU 031) Lime Kiln (EU 033)

H:\Sappi Cloquet\TSD Attachments\Att 6 ‐ Permit 014 Calcs.xlsxFPA‐Baseline Actual

PollutantPMPM10PM2.5PbNOxCOSOxVOCTRSH2SO4CO2e (No Biogenics)Ozone


FPA* PA FPA-PA** FPA* PA FPA-PA** FPA* PA FPA-PA** FPA* PA FPA-PA**(tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy)10.13 10.13 0.00 0.00 0.00 0.00 0.00 0.00 0.00 3.77 3.14 0.6315.27 15.27 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2.90 2.42 0.4810.13 10.13 0.00 0.00 0.00 0.00 0.00 0.00 0.00 2.90 2.42 0.480.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0034.08 25.52 8.57 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.0025.81 19.32 6.49 0.00 0.00 0.00 159.43 156.28 3.15 0.00 0.00 0.007.42 5.55 1.86 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.001.06 1.03 0.02 18.83 11.27 7.56 12.26 12.02 0.24 8.15 2.90 5.252.73 1.88 0.86 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.005.46 3.75 1.71 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

17,050 13,325 3,725 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.1249 0.00 0.1249 0.00 0.00 0.00

IQS (EU 081) Market Pulp Machine (EU 080) Bleach Plant (EU 011) #4 Paper Machine (EU 049)




FPA* PA FPA-PA** FPA* PA FPA-PA** FPA* PA FPA-PA** FPA* PA FPA-PA**(tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy) (tpy)4.17 3.88 0.29 1.96 1.61 0.35 10.80 10.69 0.12 13.66 15.09 0.003.26 3.05 0.22 1.75 1.44 0.31 2.16 2.14 0.02 2.73 3.02 0.003.26 3.05 0.22 1.67 1.37 0.31 0.53 0.53 0.00 0.67 0.74 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.003.12 2.50 0.62 2.50 2.00 0.50 0.00 0.00 0.00 0.00 0.00 0.002.62 2.10 0.52 2.10 1.68 0.42 0.00 0.00 0.00 0.00 0.00 0.000.02 0.02 0.00 0.01 0.01 0.00 0.00 0.00 0.00 0.00 0.00 0.008.67 3.41 5.26 6.29 2.70 3.59 0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

3,772 3,020 751.93 3,018 2,416 601.68 0.00 0.00 0.00 0.00 0.00 0.000.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Track Out#12 Paper Machine (EU 050) Coater (EU 051) Paved Roads




FPA* PA FPA-PA**(tpy) (tpy) (tpy) (tpy) (tpy)18.17 77.33 0.00 27.8 25 Yes4.63 19.72 0.00 29.3 15 Yes0.46 1.97 0.00 17.4 10 Yes0.00 0.00 0.00 0.01 0.6 No0.00 0.00 0.00 117.9 40 Yes0.00 0.00 0.00 10.9 100 No0.00 0.00 0.00 2.2 40 No0.00 0.00 0.00 25.0 40 No0.00 0.00 0.00 2.8 10 No0.00 0.00 0.00 2.1 7 No

0.00 0.00 0.00 11,030 75,000 No0.00 0.00 0.00 0.1249 >0 Yes

Unpaved Roads Totals FPA-PA

PSD Threshold Exceed PSD

Thresold?


INCREASE BLS PERMIT LIMIT - PSD Calculations Using Test DataSappi Cloquet Project Athena

Production IncreaseFuture Projected (FPA) Actual BLS

CaO at Future Projected Actual

BLS(tons BLS/yr) (tons CaO/year)

904,200 138,079

Required Relationshipstons BLS/ ADTUBP

tons CaO/ ton BLS

tons BLS/ ODTBP

1.50 0.153 1.76

Summary of Emission Change - Based on Test DataFuture

EmissionsExisting

EmissionsDifference Emissions Difference

lb/hr lb/hr lb/hr tons/yearCO 174.5 174.5 0.00 0.00 250 No No 5.70 NoPb 0.014 0.014 0.00 0.00 250 No No 0.03 NoNOx 274.8 282.0 -7.22 -31.62 250 No No 2.28 NoPM 39.0 39.0 0.00 0.00 250 No No NAPM10 42.8 42.8 0.00 0.00 250 No No 0.86 NoPM2.5 27.6 27.6 0.00 0.00 250 No No NASOx 7.3 7.3 0.00 0.00 250 No No 2.28 NoVOC 16.2 16.2 0.00 0.00 250 No No 2.28 NoTRS 2.9 2.9 0.00 0.00 250 No No NAH2SO4 4.1 1.7 2.40 10.52 250 No No NACO2e 262,486 262,486 0 0 100,000 No No NACO2e (no bio 20,243 20,243 0 0 100,000 No No NAOzone 2.40 0 2 11 250 No No NA

EMISSION CALCULATIONS

#10 Recovery Boiler (EU 005) No increase in hourly emissions from what can already be lbBLS/Dayachieved. Although Sappi is adding digesters the efficiency 4950000 8,597 Hrs of Operation 2010will be lower. Even during Kraft Pulp production the RB10 will be bottleneck 2475 823,487 tons BLS 2010

CO 46.41 0.45 lbs/ton BLS 2475.00 2475 46.41 0.45 lbs/ton BLS CEM lbs/hr * hrs/yr / tons BLSPb NA NANOx 132.00 1.28 lbs/ton BLS 2475.00 2475 139.22 1.35 lbs/ton BLS CEM lbs/hr * hrs/yr / tons BLSPM 17.74 0.17 lbs/ton BLS 2475.00 2475 17.74 0.17 lbs/ton BLSPM10 17.63 0.17 lbs/ton BLS 2475.00 2475 17.63 0.17 lbs/ton BLSPM2.5 9.49 0.09 lbs/ton BLS 2475.00 2475 9.49 0.09 lbs/ton BLS Calc based on PM10 & AP42 Table 10.2-2 (9/90) (controlled)SOx 4.43 4.30E-02 lbs/ton BLS 2475.00 2475 4.43 0.04 lbs/ton BLS CEM lbs/hr * hrs/yr / tons BLSVOC 1.35 1.30E-02 lbs/ton BLS 2475.00 2475 1.35 0.01 lbs/ton BLSTRS 0.94 9.08E-03 lbs/ton BLS 2475.00 2475 0.94 0.01 lbs/ton BLS CEM lbs/hr * hrs/yr / tons BLS, and note 3H2SO4 0.57 5.50E-03 lbs/ton BLS 2475.00 2475 0.57 0.01 lbs/ton BLSCO2e 243,083 2,357 lbs/ton BLS 2475.00 2475 243,083 2,357 lbs/ton BLS See Baseline CO2e CalculationsCO2e (no bi 839 8 lbs/ton BLS 2475.00 2475 839 8 lbs/ton BLS See Baseline CO2e Calculations

#10 Smelt Dissolving Tank (EU 031)Recovery boiler No. 10 will continue to be bottleneck. There will be no increase in hourly emissions. 4950000 lbs BLS/dayFuture Emissions emissions Existing Emissions 2475 tons BLS/day

CO NA NA NA no permit limit, no data in inventoryPb NA NA NA no permit limit, no data in inventoryNOx NA NA NAPM 5.85 5.67E-02 lbs/ton BLS 2475.00 2475 5.85 0.06 lbs/ton BLS Stack TestsPM10 8.44 8.18E-02 lbs/ton BLS 2475.00 2475 8.44 0.08 lbs/ton BLS Stack TestsPM2.5 4.98 4.83E-02 lbs/ton BLS 2475.00 2475 4.98 0.05 lbs/ton BLS Calc based on PM10 and AP42 Table 10.2-6 (9/90) (controlled)SOx 0.10 9.48E-04 lbs/ton BLS 2475.00 2475 0.10 0.00 lbs/ton BLS Stack TestsVOC 0.62 6.00E-03 lbs/ton BLS 2475.00 2475 0.62 0.01 lbs/ton BLS Stack TestsTRS 1.13 1.10E-02 lbs/ton BLS 2475.00 2475 1.13 0.01 lbs/ton BLS Stack TestsH2SO4 NA NA NA

EAW Level (tpy) EAW - YES/NO Go Through EAW

Insignificant Modification

Threshold (lb/hr) Exceeds Insignificant Modification Threshold - YES/NO

Emissions(lb/hr)

Emission Factor Value

Emission Factor Units

Production Units of Factor

Emission Data Rate (tpd)

Existing Max. Hourly Emissions

Converted Emission Rate Units Notes

NotesEmissions

(lb/hr)Emission Factor

ValueEmission Factor

UnitsProduction Units

of Factor Emission Data RateExisting Max. Hourly

EmissionsConverted

Emission Rate Units

H:\Sappi Cloquet\TSD Attachments\Att 6 ‐ Permit 014 Calcs.xlsxEAW‐State Analysi


Lime Kiln (EU 033) Existing EmissionsFuture Emissions 440 ton CaO/day 8,196 hr

CO 0.94 5.13E-02 lbs/ton CaO 440.00 440 0.94 0.05 lb/ton CaO Test 1/25/2001 and 2002 data 1

Pb 0.01 4.77E-04 lbs/ton CaO 440.00 440 0.01 0.00 lb/ton CaOfrom EB inventory, converted using 1.74 ADTUBP/ton BLS, and 6.8 tons BLS/ton CaO

NOx 34.08 1.86 lbs/ton CaO 440.00 440 34.08 1.86 lb/ton CaO Stack TestsPM 9.72 0.53 lbs/ton CaO 440.00 440 9.72 0.53 lb/ton CaO Stack TestsPM10 10.27 0.56 lbs/ton CaO 440.00 440 10.27 0.56 lb/ton CaO Stack TestsPM2.5 8.11 0.44 lbs/ton CaO 440.00 440 8.11 0.44 lb/ton CaO Calc based on PM10 and AP42 Table 10.2-5 (9/90) (controlled)SOx 0.71 3.88E-02 lbs/ton CaO 440.00 440 0.71 0.04 lb/ton CaO Test07/2009 converted using 431.6 tpd CaOVOC 0.09 5.13E-03 lbs/ton CaO 440.00 440 0.09 0.01 lb/ton CaO Test 1/25/2001 and 2002 data 1

TRS 0.36 1.97E-02 lbs/ton CaO 440.00 440 0.36 0.02 lb/ton CaO 364.9 tons CaO/day during test, assumed 24 hrs/dy 1

H2SO4 0.09 5.02E-03 lbs/ton CaO 440.00 440 0.09 0.01 lb/ton CaO Test 1/25/2001 1

CO2e 13,539 738.48 lbs/ton CaO 440.00 440 13,539 738.48 lb/ton CaO See Baseline CO2e Calculations

IQS (NCG) (EU 081)All though there will be an increase in # of digesters the chemical cellulose process is less efficient. There will be less emission generatedon a unit basis that are exhausted to the IQS. The exhaust fan system will not be changing. There will be an increase in ozone emissions.Future Emissions Existing Emissions 823,487 tons BLS 2010 7892 hrs IQS 2010

CO 5.15 5.02E-02 lbs/ton BLS 904200.00 5.15 5.15 0.05 lbs/ton BLS Stack TestsPb NA NA NA 0.00 tons BLS/ton CaONOx 6.80 6.63E-02 lbs/ton BLS 904200.00 6.80 6.80 0.07 lbs/ton BLS Stack TestsPM 2.70 2.70E+00 lbs/ton BLS 904200.00 2.70 2.70 2.70 lbs/ton BLS Stack TestsPM10 4.07 4.07E+00 lbs/ton BLS 904200.00 4.07 4.07 4.07 lbs/ton BLS Stack TestsPM2.5 2.70 2.70E+00 lbs/ton BLS 904200.00 2.70 2.70 2.70 lbs/ton BLS Calc based on PM10 and AP42 Table 10.2-5 (9/90) (controlled)SOx 1.48 1.44E-02 lbs/ton BLS 904200.00 1.48 1.48 0.01 lbs/ton BLS Stack TestsVOC 0.21 2.06E-03 lbs/ton BLS 904200.00 0.21 0.21 0.00 lbs/ton BLS Stack TestsTRS 0.50 5.32E-03 lbs/ton BLS 904200.00 0.50 0.50 0.01 lbs/ton BLS 364.9 tons CaO/day during test, assumed 24 hrs/dy 1

H2SO4 1.00 1.06E-02 lbs/ton BLS 904200.00 1.00 1.00 0.01 lbs/ton BLS Test 1/25/2001 1

CO2e 3,377 33.19 lbs/ton BLS 904200.00 13,325 3,377 33.19 lb/ton BLS See Baseline CO2e Calculations

Market Pulp Machine (EU 080)Production:Based on an increase to 1200 tpd for Kraft Pulp Assumption: Pulp is fairly wet - no PM emissionsFuture Emissions Existing Emissions Existing Maximum Capacity: 1200 ADTFP/day

CO NA NA NA NAPb NA NA NA NANOx NA NA NA NAPM NA NA NA NAPM10 NA NA NA NAPM2.5 NA NA NA NASOx NA NA NA NAVOC 4.300 0.0860 NA 1200.00 1200.00 4.30 8.60E-02 lb/ADTFP Emission factors derived from NCASI TB 681TRS NA NA NA NAH2SO4 NA NA NA NA

Converted Emission Rate Units

Emissions(lb/hr)



Production Units of Factor Emission Data Rate



Notes

Emissions(lb/hr)






Emissions(lb/hr)







Bleach Plant (EU 011)Will be adding ozone stage. Emission will result in peroxide stage and ozone stage.

Future Emissions Existing Emissions 823,487 tons BLS 2010 8612 hr

CO 36.40 36.40 lb/hr 0.00 36.40 36.40 36.40 lb/hr Derived from 06/2001 stack testPb NA NA NA NANOx NA NA NA NAPM NA NA NA NAPM10 NA NA NA NAPM2.5 NA NA NA NASOx NA NA NA NAVOC 2.80 2.80 lb/hr 0.00 2.80 2.80 2.80 lb/hr Derived from 06/2001 stack testTRS NA NA NA NAH2SO4 NA NA NAOzone 2.40 NA NA NA 0

Paper Machine 4 (EU 049)2% increase in capacity 665 ADTFP/day Previous MaxFuture Emissions Existing Emissions 665 ADTFP/Day

CO NA NAPb NA NANOx NA NAPM 1.21 1.21 lb/hr 8760.00 0.0435 1.21 0.86 lb/hr NCASIPM10 0.93 0.93 lb/hr 8760.00 0.0335 0.93 0.66 lb/hr NCASIPM2.5 0.93 0.93 lb/hr 8760.00 0.0335 0.93 0.66 lb/hr NCASISOx NA NAVOC 2.60 2.60 lb/hr 8760.00 0.094 2.60 1.86 lb/hr Emission factors derived from NCASI TB 681TRS NA NAH2SO4 NA NACO2e NA NA

Paper Machine 12 (EU 050) 627 ADTFP/day Previous Max20.0 mmcf with 2% increase 627 ADTFP/Day

Future Emissions Existing Emissions 20.0 mmcf

CO 84.00 84.00 lb/hr 8,760 84.00 84.00 84.00 lb/hr AP-42 / FIREPb 5.00E-03 5.00E-03 lb/hr 8,760 0.01 5.00E-03 5.00E-03 lb/hr AP-42 / FIRENOx 100.00 100.00 lb/hr 8,760 100.00 100.00 100.00 lb/hr AP-42 / FIRE

1.14 lb/hr 8,760 lb/hrlb/hr 4.35E-02 4.04E-01 lb/hr Emission factors derived from NCASI

0.87 lb/hr 8,760lb/hr 3.35E-02 3.56E-01 lb/hr Emission factors derived from NCASI

0.87 lb/hr 8,760lb/hr 3.35E-02 3.38E-01 lb/hr Assumed equal to PM10

SOx 6.00E-01 6.00E-01 lb/hr 8,760 6.00E-01 6.00E-01 lb/hr AP-42 / FIRE2.45E+00 lb/hr 1.41 lb/hr Emission factors derived from NCASI TB 681

lb/hr 9.40E-02 3.14E-02 lb/hr AP-42 / FIRETRS NA 0.00 NAH2SO4 NA 0.00 NACO2e 276 120,744 lb/MMcf 20.00 276 276 120,744 lb/MMcf See Baseline CO2e Calculations





Emissions(lb/hr)




Units Notes

PM 1.14 1.14

Emission Data RateExisting Max. Hourly

EmissionsConverted

Emission Rate Units Notes

Emissions(lb/hr)




Emissions(lb/hr)


PM10 0.87 0.87

PM2.5 0.87 0.87

Emission Data RateExisting Max. Hourly

EmissionsConverted

Emission Rate

VOC 2.45 8,760 2.45



Coater (EU 051) 1,292 tons/day 20 MMBtu/hr180.5 mmcf with 2% increase 1,292 tons/day 0.0190 MMcf/hr

Future Emissions Existing Emissions 180.5 mmcf NG

CO 1.60 84.00 lb/MMCF 180.50 1.60 1.60 84.00 lb/MMCF AP-42 / FIREPb 1.03E-04 5.00E-03 lb/MMCF 180.50 1.03E-04 1.03E-04 5.00E-03 lb/MMCF AP-42 / FIRENOx 1.90 100.00 lb/MMCF 180.50 1.90 1.90 100.00 lb/MMCF AP-42 / FIREPM 0.145 lb/hr 180.50 0.14 7.60 lb/MMCF AP-42 / FIRE

0.50 lb/hr 1291.60 0.50 9.20E-03 lb/tonPM10 0.145 lb/hr 180.50 0.14 7.60 lb/MMCF AP-42 / FIRE

0.44 lb/hr 1291.60 0.44 8.10E-03 lb/tonPM2.5 0.145 lb/hr 180.50 0.14 7.60 lb/MMCF AP-42 / FIRE

0.41 lb/hr 1291.60 0.41 7.70E-03 lb/tonSOx 1.24E-02 0.60 lb/MMCF 180.50 1.24E-02 0.011 6.00E-01 lb/MMCF AP-42 / FIRE

1.72 lb/hr 1292 1.72 0.032 lb/hr Emission factors derived from NCASI TB 6810.001 lb/hr 8760 0.001 3.14E-02 lb/hr AP-42 / FIRE

TRS NAH2SO4 NACO2e 2,488 120,744 lb/MMcf 180.50 2,488 2,488 120,744 lb/MMcf See Baseline CO2e Calculations

1. Process data for conversion from Sappi Emissions Inventory2. Recovery Boiler TRSEB 2009 inventory states 0.77 ppm TRS 0.7392 lbs/hrPermit limit 5 ppm TRS equivalent to 4.8 lbs/hr3. Recovery Boiler CEM data includes hours on gas. Adjusting for this might reduce emissions slightly.ADTFP = Air Dried Ton Finished Product BLS = Black Liquor SolidsADTUBP = Air Dried Tons Unbleached Pulp ODTBP = Oven Dried Tons Bleached Pulp

Units Notes

0.640.64

Emissions(lb/hr)




0.580.58

0.560.56

VOC 1.721.72


Converted Emission Rate


Ozone Bleaching System (EU 088)Ozone destructor system only used when fiber line is down.Fiber line is down for maintenance 9 periods per year , 12 hours per period.Assume ozone equals VOC.Per revised application: No limitations taken on annual emissions - assumed 8760 hours per year

Oxygen lb/day

Ozone Fraction

lbs emitted per day

lbs emitted/hr

No. Maintenance Periods per

Year

Hours Per Maintenance

Period

Tons Emitted per Year

Control Efficiency

1

Controlled Emissions

(lb/hr)Control

(tpy)68,625 0.014 960.75 40.0 9 12 2.1 94.00% 2.4019 0.1249

1 Based on Wedeco Guarantee Data for Ozone Destructor

H:\Sappi Cloquet\TSD Attachments\Att 6 - Permit 014 Calcs.xlsxOzone Bleaching System

TSD Attachments Attachment 7: BACT Analysis Submitted by Permittee


September 2016, Revised March

2017 4-1

H:\Sappi Cloquet\TSD Attachments\Att 7 - BACT Analysis by Permittee.docx

4.0 Best Available Control Technology

Sappi Cloquet is submitting this Best Available Control Technology (BACT) Analysis for its pulp and paper mill located in Cloquet, MN. Sappi is seeking to increase pulp production to match the capacity of the recovery boiler. Due to the relaxation of the current BLS throughput limit, the previous changes to the recovery boiler (quaternary air injection) made during the switch to SC pulp, and potential changes to the ESP associated with this project, a BACT review is included for the recovery boiler #10 (EU 005). None of the other emission units impacted by this project require BACT review. The recovery boiler is the only emission unit for which a BACT analysis is required. The proposed project will increase emissions of particulate matter (PM), particulate matter less than ten microns in diameter (PM10) and particulate matter less than 2.5 microns in diameter (PM2.5), nitrogen oxides (NOx) and greenhouse gas (CO2e) above the Prevention of Significant Deterioration (PSD) significance levels for each pollutant. The PSD rules (40 CFR Part 52.21 (j)) require the completion of a control technology review for those pollutants exceeding a significant amount. Table 2 is a summary of the net emissions increase for pollutants which triggered PSD from the project compared to the PSD Significance Levels. Table 1: Summary of Proposed Project Emissions Increase Compared to PSD Thresholds

Pollutant Difference FPA-BA (tpy)

PSD Significance Level (tpy)

PM 32.76 25 PM10 28.22 15 PM2.5 21.83 10 NOx 137.31 40 CO2e 209,552 75,000

4.1 BACT DEFINITION BACT is defined in 40 CFR 52.21(j) as follows:

“an emission limitation (including a visible emission standard) based on the maximum degree of reduction of each air pollutant subject to regulation under the Clean Air Act which would be emitted from any proposed major stationary source or major modification which the Administrator, on a case-by-case basis, taking into account energy, environmental and economic impacts, and other costs, determines is achievable for such source or modification through application of production processes or available methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control of such pollutant…”

BACT is determined using EPA’s top-down approach. Following the top-down approach, progressively less stringent control technologies are analyzed until a level of control considered BACT is reached based on environmental, energy, and economic impacts. The steps involved include:

Identify all control technologies; Eliminate technically infeasible options;


2017 4-2


Rank remaining alternatives by control effectiveness; Evaluate most effective controls; and Select BACT.

The recovery boiler #10 (EU 005) is the only source affected by the modification that emits PM, PM10, PM2.5, NOx and CO2e. In determining BACT for the recovery boiler #10 (EU 005), information from the following sources was evaluated:

On-line EPA Reasonably Available Control Technology (RACT)/BACT/Lowest Achievable Emission Rate (LAER) Clearinghouse (RBLC) System and other state BACT control technology databases (see Appendix B);

EPA/State/Local air quality permits and applications; Drawing from similar experience; Control technology vendors; and Researching available literature.

The following sections outline the results of the evaluations to determine PM, PM10, PM2.5, NOx and CO2e BACT for the recovery boiler #10. 4.2 PM, PM10 AND PM2.5 EMISSIONS FROM THE RECOVERY BOILER #10 To accommodate the pulp production increase, Sappi is proposing to increase the recovery boiler BLS firing limit from 904,200 tons/yr to 1,027,475 tons per year. This increase matches the recovery boiler capacity of 5.63 MMlbs BLS/day. Currently, particulate emissions from the recovery boiler are controlled by an electrostatic precipitator (CE 007) and vented externally through a stack (SV 006). Particulate matter emissions from recovery boilers are a combination of filterable (front-half) and condensable (back-half) particulate. A small amount of supplemental natural gas and diesel fuel is combusted in the recovery boiler for specific operational situations such as start up or for supplemental steam; these fuels are already authorized in the current permit and will not change as a result of this project. 4.3 APPLICABLE CONTROL TECHNOLOGIES FOR PM, PM10 AND PM2.5 EMISSIONS FROM RECOVERY BOILER #10 A search of the RBLC for similar sized recovery boilers was conducted. A list of the results is located in Appendix B. Based on this search, technologies available to potentially control PM, PM10 and PM2.5 emissions from the recovery boilers include the following:

1. Fabric Filter; 2. Electrostatic Precipitator (ESP); and 3. Wet Scrubber.

Please note that there were no entries in the RBLC for PM2.5. Therefore, entries for PM10 and PM were used for the analysis. 4.3.1 Fabric Filter Fabric filters, or baghouses, consist of a structure containing tubular bags made of a woven or felted fabric in which particulate matter is removed by drawing the particulate laden gas through the bags with the bags capturing the particulate matter. The collected particulate is


2017 4-3


periodically removed by shaking the bag, sending a pulse of high velocity air in the opposite direction, or by other means. Most of the particulate matter is collected by a cake of solid material that forms on the bags by the already collected particulate matter. The technical feasibility of using fabric filters depends on exhaust gas temperatures and moisture content. Exhaust gas temperatures must be less than 500°F to avoid damaging the bag material. Additionally, moisture must be minimized to avoid condensation and possible blinding of the bags. Since wet particles in the exhaust stream can clog the bag pores and block gas movement, the high level of moisture and the temperature in the exhaust streams of Sappi’s recovery boiler #10 makes this alternative unsuitable. Fabric filters are not identified in the RBLC as an acceptable control technology for PM/PM10/PM2.5 emissions from recovery boilers. Therefore, fabric filters are not considered to be technically feasible for control of PM/PM10/PM2.5 from the recovery boiler #10. 4.3.2 Electrostatic Precipitator (ESP) ESPs clean particulate matter from exhaust streams in three steps:

1. Passing the suspended particles through a direct current corona to electrically charge them;

2. Collecting the charged particles on a grounded plate; and 3. Removing the particles from the plates by mechanical means or water flushing.

ESPs can be further classified as dry ESPs and wet ESPs. Dry ESPs are typically used for applications where the exhaust stream has very little moisture content. Wet ESPs are typically used to collect particulate matter from streams that have relatively high moisture contents. While dry ESPs are primarily effective at collecting filterable PM, wet ESPs have shown effectiveness at collecting condensable PM via the mechanism of condensation on to liquid covered plates. Sappi currently utilizes an electrostatic precipitator (CE 007) to control emissions from the recovery boiler and is considering potential changes to the ESP as discussed earlier in order to assist in meeting emission limits. ESPs are considered the base case, so it is not evaluated further in this analysis. 4.3.3 Wet Scrubber Wet scrubbers remove particulate matter from exhaust gases by capturing the particles in liquid droplets and subsequently separating the droplets from the exhaust gas stream. Wet scrubbers are effective at removing both condensable and filterable particulates. Condensable PM is removed due to the reduction in the temperature of the exhaust stream thereby condensing the condensable PM. Wet scrubbers can be grouped into the following major categories:

1. Venturi scrubbers; 2. Mechanically aided scrubbers; 3. Pump aided scrubbers; 4. Wetted filter-type scrubbers; and 5. Tray or sieve-type scrubbers.


2017 4-4


The difference between these scrubber types is the manner in which the liquid is introduced into the gas stream, the methods by which the particles are captured by the liquid droplets, and the fashion in which the liquid droplets are removed. The main advantages of a wet scrubber include its ease of maintenance and its ability to remove both filterable and condensable PM. The main drawbacks of a wet scrubbing system include the operational and maintenance expenses resulting from the water supply requirements and liquid effluent disposal requirements. However, in pulp mill operations the spent scrubbing solution can be returned to the causticizing process. Wet scrubbing is considered to be technically feasible for application to recovery boilers for the control of PM/PM10/PM2.5 emissions. 4.4 TECHNICAL FEASIBILITY AND RANKING OF PARTICULATE CONTROL TECHNOLOGIES As discussed previously, a fabric filter is not a technically feasible control type for the recovery boiler. Sappi ranked the technically feasible options for particulate control in the table below: Table 2: Summary of Effectiveness of PM, PM10 and PM2.5 Control Technologies

Control Method

Control Efficiency

(%)

Rank

Electrostatic Precipitator PM 99% PM10 99% PM2.5 95%

1

Scrubber PM 94% PM10 84% PM2.5 84%

2

Note: ESP Control efficiency is based on the applicable EPA Air Pollution Control Technology Fact Sheet. Scrubber control efficiency is based on Minn. R. 7011.0070 listed control efficiency. Additionally, discussion in the preamble to 40 CFR 60, subp. BBa indicates that EPA reviewed stack test data and found that sources controlled by a scrubber had higher particulate emissions than sources controlled by an ESP.1 4.5 PROPOSED PARTICULATE BACT SELECTION AND EMISSION LIMITS The base case of using the existing electrostatic precipitator to control emissions from the recovery boiler (EU 005) is the highest-ranking control type; therefore, no further justification is required. There are sixteen entries in the RBLC for recovery boilers, fourteen of which are BACT determinations. All entries with a listed control equipment type are controlled by ESPs. All entries in the past ten years were between 2006 and 2008 except for a single entry in 2014. The 2014 entry was from a Georgia Pacific Recovery Furnace to be located in Brewton, AL. The proposed unit was a new emission unit, not a modified unit. The particulate limit proposed for that unit (0.015 gr/dscf PM @ 8% O2) applies to filterable particulate only and was driven by the filterable particulate limit for new recovery furnaces in NSPS Subpart BBa and MACT Subpart MM.

1 Federal Register, Vol. 78, No. 100, Thursday, May 23, 2013/Proposed Rules p. 31323


2017 4-5


Sappi evaluated upgrades to the existing ESP. The black liquor combusted in Sappi Cloquet’s recovery boiler from specialized cellulose (SC) pulping (also known as pre-hydrolysis Kraft pulp) is not directly comparable to black liquor combusted at other traditional Kraft pulp mills. The cooking liquor used in the SC pulping process has a lower sulfidity than the liquor used in the traditional paper Kraft pulping processes. This results in a notable difference in electrostatic precipitator performance. It is Sappi’s experience that this low sulfidity results in high carbonate-to-sulfate ratios in the combusting liquor and resulting ash (known as saltcake) in the flue. This ratio increases fume (fine particles) generated in the lower furnace and increases overall particulate load to control equipment. Furthermore, the fume and saltcake have low resistivity and higher pH due to their elevated carbon content. This makes it more difficult to remove this saltcake from the flue gas with an electrostatic precipitator. Therefore, the performance achieved by a typical paper kraft recovery boiler precipitator may not be achievable for SC pulping. Most if not all the entries in the RBLC are for Kraft mills and therefore, are not directly comparable to the Sappi recovery boiler. Sappi’s recovery boiler #10 is regulated as an existing source under the standards and therefore is not subject to the same emission limitation. Sappi proposes to reduce the existing BACT limitation for RB10 of 0.025 gr/dscf PM @ 8% O2, to 0.020 gr/dscf PM @ 8% O2., filterable only. The limits for PM10 and PM2.5 will be equal to the PM limit. This is based on a review of existing test results, projecting future rates/loading and assuming a margin for compliance. In the preamble to 40 CFR 60, subpart BBa, EPA evaluated lowering the filterable particulate limit for existing recovery boilers down to the 0.015 gr/dscf level and found that some existing modified sources would have difficulty meeting that emission level if they attempt to use existing control equipment to meet the limit. EPA further estimated that the cost effectiveness of incremental improvements in ESP performance needed for modified recovery boilers to meet the 0.015 gr/dscf limit would be $27,500/ton in 2012 dollars. EPA also evaluated other emission limits between 0.015 gr/dscf and 0.044 gr/dscf, but because the costs associated with the ESP upgrades remained the same with smaller emission reductions, the options were less cost effective. Due to the low resistivity of the flue gas, ESP upgrades are not anticipated to result in significant decreases in outlet particulate concentrations, and therefore an emission limit of 0.015 gr/dscf is not feasible for Sappi’s recovery boiler. The emission limitations that are proposed to represent BACT recovery boiler #10 are summarized in Table 3.


2017 4-6


Table 3: Particulate BACT Summary

Equipment Description Proposed PM, PM10 and PM2.5 BACT Limitation

EU 005 Recovery Boiler #10

0.020 gr filterable PM /dscf @ 8% O2

0.020 gr filterable PM10/dscf @ 8% O2

0.020 gr filterable PM2.5/dscf @ 8% O2

4.6 NOX EMISSIONS FROM THE RECOVERY BOILER #10 NOx emissions will also trigger BACT review for this project. In general, NOx emissions from recovery boilers are a combination of thermal NOx and fuel NOx. Thermal NOx is produced by a series of chemical reactions in which diatonic nitrogen and oxygen in the combustion air react to form NOx in a high temperature combustion zone. Fuel NOx is generated when nitrogen available in the fuel (BLS) is oxidized to NOx. Black liquor solids are generally low in NOx (<0.10% by weight), compared to residual fuel oil which ranges from 0.2-0.5% NOx. Additionally, moderate combustion zone temperatures (<1500 °F) are typically maintained by staged combustion techniques, limiting the formation of thermal NOx. 4.7 APPLICABLE CONTROL TECHNOLOGIES FOR NOX EMISSIONS FROM RECOVERY BOILER #10 A search of the RBLC for similar sized recovery boilers was conducted. A list of the results is located in Appendix B. Technologies available to potentially control NOx emissions from the recovery boilers include the following:

1. Selective Catalytic Reduction (SCR); 2. Selective Noncatalytic Reduction (SNCR); 3. Low NOx Burners (LNB); 4. Overfire Air/Quaternary Air; and 5. Flue Gas Recirculation.

These control types as well as additional available NOx controls are discussed below. 4.7.1 Selective Catalytic Reduction (SCR) SCR systems control NOx emissions by injecting ammonia into the exhaust stream and passing the exhaust across a catalyst bed to further the chemical reaction reducing NOx emissions. The system converts NOx to elemental nitrogen and water vapor. Optimum temperature range for a SCR catalyst is 450° up to 800 °F (EPA Air Pollution Control Fact Sheet for SCR, 7-15-03). There is a concern that the injection of ammonia will have a detrimental effect on the chemistry occurring within the boiler. Additionally, combustion of BLS results in high particulate matter loading of boiler exhaust which could plug the catalyst and cause operational issues. None of the sources in the RBLC use SCR as a control type as this is not considered a technically feasible control type.


2017 4-7


4.7.2 Selective Non-Catalytic Reduction (SNCR) SNCR systems control NOx emissions by injecting ammonia or urea in to a high temperature portion of the furnace to convert NOx into elemental nitrogen and water vapor. The temperature range for this reaction in an ammonia-based system is 1600° to 2000° F. For a urea based system, the temperature range for the reaction is 1600° to 2100° F (EPA Air Pollution Control Fact Sheet for SNCR, 7-15-03). Additionally, SNCR is not considered a technically feasible control option because the recovery boiler is a complete, chemical reaction system and any disruption of the chemistry could potentially damage the boiler or impact the quality of the product. There is also a concern that the injection of ammonia or urea could negatively impact the chemistry within the recovery boiler, and could potentially lead to an explosion if any of the water from a urea solution condensed and mixed with the BLS. Additionally, it is not a commercially available control technology for recovery boilers. 4.7.3 Low-NOx Burners (LNB) LNBs provide a stable flame that has several different zones. Typically, the first zone is primary combustion, the second zone is re-burn with fuel added to chemically reduce NOx, and the third zone is a final combustion in low excess air to prevent high temperatures. Recovery furnace vendors do not offer true low NOx burners for fossil fuel due to the unique design of the combustion chamber within a recovery boiler. Therefore, this is not considered a commercially available control technology for recovery boilers and its installation is considered technically infeasible.

4.7.4 Staged Combustion/Quaternary Air Recovery boilers are typically designed with multiple stages of combustion airs with an overfire air system to reduce NOx emissions. Initial combustion air is provided with the fuel to produce a reducing flame. Subsequent combustion air is added in two more zones to complete combustion of the fuel while maintaining the low temperatures that prevent thermal NOx formation. Typical staged combustion includes 2-3 stages of air combustion. Quaternary air injection involves a fourth stage of combustion where injection ports are located between the secondary and tertiary air injection ports. This design promotes for more efficient mixing and combustion without solid particle carryover. This is the only type of combustion modification control that is currently offered for recovery boilers and is the only technically feasible control option. 4.8 TECHNICAL FEASIBILITY AND RANKING OF NITROGEN OXIDES CONTROL TECHNOLOGIES As discussed previously, both SNCR and SCR are not feasible control types for the recovery boiler. Additionally, low-NOx burners are not commercially available for recovery boilers. Staged air combustion is the only combustion modification technique currently used for control of recovery boilers. Quaternary air represents the highest level of staged combustion control. Sappi listed technically feasible option for particulate control in the table below:


2017 4-8


Table 4: Summary of Effectiveness of NOx Control Technologies

Control Method

Control Efficiency

(%)

Rank

Quaternary Air 20-50% 1

4.9 PROPOSED NOX BACT SELECTION AND EMISSION LIMITS Sappi’s recovery boiler is equipped with quaternary air injection. This is a top-ranked control technology, so no economic justification is required. Quaternary air injection ports are located above the tertiary air injection ports. Air introduced at this level provides more efficient mixing and combustion. There are fifteen entries in the RBLC for recovery boilers. BACT entries for recovery boilers range between 75 ppm and 120 ppm. Note that selecting BACT for NOx requires a balance between NOx and CO emissions – optimizing NOx combustion emissions can result in an increase in CO emissions. A recent BACT for Georgia Pacific Crossett facility was reviewed. It has a NOx BACT limit of 110 ppmvd and has stack tested as low as 68 ppm. It however, has a CO limit of 930 ppmvd. This is compared to the existing Sappi CO limit of 300 ppmvd at 8% O2. Sappi is proposing an emission limit of 100 ppm @ 8% O2 as a 30-day rolling average for the recovery boiler #10 based on facility Continuous Emissions Monitoring (CEM) data as well as the projected annual increase in actual BLS throughput. This proposed limit should allow Sappi to retain its current existing recovery boiler CO limit. The emission limitation proposed to represent BACT for the recovery boiler #10 is summarized in Table 5. Table 5: NOx BACT Summary

Equipment Description Proposed NOx BACT Limitation

EU 005 Recovery Boiler #10 100 ppmvd NOx @ 8% O2, 30-d rolling average

4.10 GREENHOUSE GAS (CO2E) EMISSIONS FROM THE RECOVERY BOILER #10 Greenhouse gas (CO2e) emissions will also trigger BACT review for this project. Greenhouse gas is primarily formed from the combustion of black liquor solids. Only a small amount of supplemental fossil fuel is combusted in the unit to assist with startups. Weak black liquor is generated as a byproduct of the Kraft (traditional or pre-hydrolysis) wood pulping process and is concentrated and fired in the mills recovery furnaces to generate steam and to recover cooking chemicals in the form of molten smelt. The smelt is further processed to become white liquor which is reused in the digesters as cooking chemicals to make pulp. Greenhouse gas emissions associated with the combustion of black liquor are biogenic in nature since the carbon originates from wood. As Sappi sources its wood from sustainably managed forests the wood used to generate BLS should be considered a carbon neutral fuel.


2017 4-9


It should be noted that the primary purpose of the recovery boiler is for chemical recovery. The fact that it generates steam is secondary to the process. Therefore, it should not directly be evaluated in the same manner as other combustion sources where their primary purpose is to generate energy. (Reference: Guidance for Determining Best Available Control Technology for Reducing Carbon Dioxide Emissions from Bioenergy Production.) 4.11 APPLICABLE CONTROL TECHNOLOGIES FOR GREEHOUSE GAS EMISSIONS FROM RECOVERY BOILER #10 A search of the RBLC for recovery boilers was conducted. A list of the results is located in Appendix B. Based on this search, there is only one entry. This entry proposed an efficiency limitation with no additional add-on control equipment. The following control types were evaluated:

1. Combustion Efficiencies; 2. CO2 capture and compression; 3. CO2 Transport; and 4. CO2 Storage.

These control types are discussed below. 4.11.1 Combustion Efficiencies There are two modes of operation in the recovery boiler. Black liquor solids combustion provides the majority of the fuel input for the boiler and a small amount of fossil fuel is used during startup and shutdown. Sappi can currently combust natural gas and distillate oil. The recovery boiler is limited to an annual capacity factor of 10% on these fuels. In reviewing EPA’s Available and Emerging Technologies for Reducing Greenhouse Gas Emissions from the Pulp and Paper Manufacturing Industry (10/2010), there are several combustion efficiency improvements that are potentially applicable to boilers and could apply to the fossil fuel combustion portion of recovery boiler #10. These are:

1. Burner Replacement- The natural gas boilers were installed in 1998 (the #2 fuel oil is blended with the BLS and does not have an independent burner). It would not make sense to replace them considering the limited fossil fuel combusted and based on their age.

2. Improved boiler insulation – The recovery boiler is currently well insulated and is monitored frequently for leaks.

3. Boiler Maintenance- The recovery boiler is on a regular maintenance schedule. This includes the fossil fuel burners.

4. Boiler Process Control/Reduction of Excess Air – Sappi currently operates an O2 trim system inside the boiler, and operates a carbon monoxide CEMS and O2 CEMS. These monitors ensure efficient combustion as well as prevents the use of too much excess air.

5. Reduction of Flue Gas Quantity – As noted above the recovery boiler is on a regular maintenance schedule as well as is well insulated. This will minimize leaking air infiltration and minimize the flue gas quantity.


2017 4-10


The distillate oil for recovery boiler #10 is blended with the Black Liquor Solids and is limited to 1 gallon/minute. Additionally, distillate fuel has not been combusted in recovery boiler #10 in the past 5 years. Therefore, Sappi is minimizing the use of fossil fuels in the recovery boiler. In regard to the combustion black liquor solids, as discussed previously, Sappi’s recovery boiler #10 is equipped with quaternary air injection. Quaternary air injection reduces plugging of boiler tubes by reducing carryover. This results in improved boiler efficiency and reduces the number of times the boiler would need to be shut down for maintenance and cleaning. Additionally, chemical conversion efficiency is improved chemical conversion efficiency and improved thermal efficiency, more stable combustion, lower auxiliary energy requirements, and increased runtime between shutdowns have also been observed. More efficient combustion results in less fuel consumption to produce the same quantity of heat, therefore reducing greenhouse gas emissions produced. In addition to quaternary air, recovery boiler #10 is equipped with composite tubes in the lower furnace, which improve energy efficiency. The evaporator system also includes a super concentrator for the BLS, which acts to increase the solids content. The recovery boiler No. 10 current solids content is approximately 68-72%. This level is maintained to meet the current permit steam limit which was established based on steaming levels achieved during various stack tests. Regardless of the stack testing limit the recovery boiler steam production is also limited based upon safety valve designs. Increasing the solids content would increase the steaming rate and could result in Sappi exceeding its permit limit or safety limit. As discussed previously, the primary purpose of the recovery boiler is to recover cooking chemicals – steam production is a secondary benefit. It is critical to match necessary BLS throughput to steaming rate. Sappi currently inspects the recovery boiler annually. During this inspection, it has not found that deposits on heat transfer surfaces is an issue. Additionally, Sappi periodically completes superheater steam enthalpy calculation in order to monitor the deposition rate. Therefore, deposition monitoring will not result in an increase in an increase in recovery boiler efficiency. 4.11.2 CO2 Capture and Compression The amine absorption technology for CO2 capture has been applied to processes in the petroleum refining and natural gas processing industries and to exhausts from gas-fired industrial boilers. However, it has not been identified in the RBLC as applicable to recovery boilers similar to Sappi’s recovery boiler #10, therefore it is not evaluated as a technically feasible control type. 4.11.3 CO2 Transport Even if it is assumed that CO2 capture and compression could feasibly be achieved for the proposed project, the high-volume CO2 stream generated would need to be transported to a facility capable of storing it. There are no potential geologic storage sites in Minnesota suitable for sequestration. A 2008 report by the Minnesota Geological Survey concluded that the Midcontinent Rift, which extends from the Lake Superior Basin to Kansas, has attributes that makes it far less suitable for sequestration than sites being considered elsewhere.2 2 Minnesota Geological Survey: Potential for Geologic Carbon Sequestration in Minnesota. (2009, Jan. 9). Retrieved from: http://www.mngs.umn.edu/newCO2seq.html


2017 4-11


Therefore, to access any potentially large-scale storage capacity site, assuming that it is eventually demonstrated to indefinitely store a substantial portion of the large volume of CO2 generated by the proposed project, a very long and sizable pipeline would need to be constructed to transport the large volume of high-pressure CO2 from the plant to the storage facility, thereby rendering implementation of a CO2 transport system infeasible. 4.11.4 CO2 Storage Even if it is assumed that CO2 capture and compression could feasibly be achieved for the proposed project and that the CO2 could be transported economically, the feasibility of CCS technology would still depend on the availability of a suitable sequestration site. The suitability of potential storage sites is a function of volumetric capacity of their geologic formations, CO2 trapping mechanisms within formations (including dissolution in brine, reactions with minerals to form solid carbonates, and/or adsorption in porous rock), and potential environmental impacts resulting from injection of CO2 into the formations. Potential environmental impacts resulting from CO2 injection that still require assessment before CCS technology can be considered feasible include:

Uncertainty concerning the significance of dissolution of CO2 into brine, Risks of brine displacement resulting from large-scale CO2 injection, including a

pressure leakage risk for brine into underground drinking water sources and/or surface water,

Risks to fresh water as a result of leakage of CO2, including the possibility for damage to the biosphere, underground drinking water sources, and/or surface water,3 and

Potential effects on wildlife. Potentially suitable storage sites, exist in Eastern Montana and Northwestern North Dakota However, there are no pipelines that connect to these formations. Based on the reasons provided above, Sappi believes that CCS technology should be eliminated from further consideration as a potential feasible control technology for purposes of this BACT analysis. For the CO2e emissions, this leaves the inherently lower-emitting processes/practices/designs as the only feasible control technology. Effectiveness of these lower-emitting process/practices/designs can be measured in terms of thermal efficiency. Because fuel use is directly related to CO2 emissions for the recovery boiler and the impact of control measures, combustion efficiency is a useful indicator of CO2 control efficiency. 4.12 TECHNICAL FEASIBILITY AND RANKING OF GREEHOUSE GAS CONTROL TECHNOLOGIES

3 DOE-NETL, Carbon Sequestration: FAQ Information Portal, http://extsearch1.netl.doe.gov/search?q=cache:e0yvzjAh22cJ:www.netl.doe.gov/technologies/carbon_seq/FAQs/te ch-status.html+emerging+R%26D&access=p&output=xml_no_dtd&ie=UTF-8&client=default_frontend&site=default_collection&proxystylesheet=default_frontend&oe=ISO-8859-1 (last visited Aug. 8, 2011).


2017 4-12


As discussed previously, CO2 capture, CO2 transport and CO2 storage are not feasible control types for the recovery boiler. The only technically feasible control option is efficient combustion practices met by using quaternary air injection in the recovery boiler in addition to the other energy efficiency measures mentioned previously and are currently in place. These include:

Use of composite boiler tubes in the lower furnace Use of the super concentrator to improve the solids content of the black liquors solids Regular maintenance for on the recovery boiler and fossil fuel combustion burners. Regular inspection and maintenance of the boiler insulations.

4.13 PROPOSED CO2E BACT SELECTION AND EMISSION LIMITS As noted earlier, Sappi’s recovery boiler is equipped with quaternary air injection. It is equipped with many other measures as noted above that improve the combustion and recovery efficiency of the unit. There is only one entry in the RBLC for greenhouse gas emissions for recovery boilers. This entry is from 2014 and proposes a limit of 210.1 lb. CO2e/MMBtu. As this value can vary due to many process variables Sappi does not wish to limit CO2e in this manner. As BLS is a biogenic fuel, sustainably sourced, its contribution to CO2 plant emissions is minimal or neutral.44 For this reason, Sappi does not believe it should be necessary to limit the combustion of BLS. Instead Sappi wishes to propose a limit on the fossil fuel use as identified below limiting the amount of fossil fuel combusted, which is a fossil fuel. The emission limitation proposed to represent BACT for the recovery boiler #10 is summarized in Table 6. Table 6: CO2e BACT Summary

Equipment Description Proposed CO2e BACT Limitation

EU 005 Recovery Boiler #10

Fuel Use - BLS is a biogenic feedstock and is carbon neutral. Fossil fuel combustion will be limited to an annual capacity factor of less than 10%. Distillate oil (a fossil fuel) is limited to less than 1 gallon/minute. 74,823 tons of CO2e emissions from the combustion of fossil fuels as a 12-month rolling sum. Compliance with this limit is to be calculated based on emission factors and global warming potentials identified in 40 CFR Part 98.

4 EPA Memorandum; Addressing Biogenic Carbon Dioxide Emissions from Stationary Sources dated November 19, 2014 from Janet G. McCabe, Acting Assistant Administrator, Office of Air and Radiation.

TSD Attachments Attachment 8: Modeling documents: PM2.5 Increment Screening, Nearby Sources, Background Concentrations,

and Modeling Report Sappi Cloquet LLC

Permit Number: 01700002‐101

www.pca.state.mn.us • 651-296-6300 • 800-657-3864 • Use your preferred relay service • Available in alternative formats aq2-48 • 8/26/16 Page 1 of 8

AQDM-06 Air Quality Dispersion Modeling (AQDM) Results Form

(Previously AQDMR-01)

Doc Type: Air Dispersion Modeling

Acronym information on page 7 Instructions: Permit applicants required to conduct air dispersion modeling should submit two paper copies of the completed Air Quality Dispersion Modeling Report Form (AQDM-06) and all accompanying files to:

Air Quality Permit Document Coordinator Minnesota Pollution Control Agency 520 Lafayette Road North St. Paul, MN 55155-4194

Applicants may also submit an electronic version via email, in addition to the two paper copies. This is highly recommended. Please note that all assumptions made in the air dispersion modeling analysis could result in air permit requirements.

Electronic copies of the forms and accompanying files should be emailed to: [email protected]. Note: The air modeling e-Service may not be used to submit air modeling results.

Facility information

AQ tracking no.: AQ facility/permit ID no.: 01700002 Today’s date (mm/dd/yyyy): 05/11/2017

Three-letter modeling facility ID (ex., XEK = Xcel Energy Allen S. King, MEC = Mankato Energy Center, etc.): SAP

Facility name: Sappi Cloquet LLC

Facility street address: 2201 Avenue B

City: Cloquet County: Carlton Zip code: 55720 State: MN

Facility contact: Rob Schilling Protocol prepared by: Jared Anderson

Facility contact phone: (218) 879-0638 Preparer phone: (651) 294-4592

Facility contact email address: [email protected] Preparer e-mail address: [email protected]

*UTM coordinates of facility (NAD83, zone 15 extended ONLY): x = 434,356.00 m East, y = 5,174,623.00 m North

*This should be the central location of the facility/source.

These results are associated with (check all that apply): AERA or Dispersion/Deposition modeling for air toxics Environmental assessment worksheet Environmental impact statement Modeling information request Modeling Impacts from animal feedlots Siting an air monitoring station Siting a meteorological station Permit condition Permit modification Prevention of significant deterioration Screening modeling Special project State implementation plan

Project description (50 words or less)

This project increases pulp production by increasing digester availability by reducing chip fill times. The pre-steaming will improve digester cycle times. Additional project details are included in the attched memo.

http://www.pca.state.mn.us/



Files to accompany modeling results

Include the following files with the completed modeling report form. Use checkbox to indicate that all applicable files are included.

1. AERMOD input files (*.inp, *.adi, *.ami) AERMOD output files (*.out, *.ado, *.amo) AERMOD plot files (*.plt) AERMOD post files (*.pst) (If applicable) AERMOD event files (*.evi, *.evo) (If applicable) AERMOD miscellaneous/other files (MAXDCONT, .DAT, .emi, etc.) (If applicable)

2. AERMET files: *.sfc *.pfl

3. BPIP-PRIME files: Input (*.bpi) Output (*.bpo, *.sum) (If applicable)

4. AERMAP files: Terrain (*.dem(s), *.tif [NED files]), Input (*.ami), Output (*.rou, *.sou, etc.) (If applicable)

5. Background data files: Background concentrations for applicable pollutants (seasonal, monthly, daily, hourly, etc.) (If applicable)

6. Modeling results: Figures (*.jpeg, *.pdf), GIS Maps (*.shp)

7. AQDM-02 spreadsheet: (Provide the final spreadsheet [i.e., AQDM-02] and indicate/highlight changes.)

8. Paved roads results: (If applicable)

9. SIL analysis and results: (If applicable)

10. Hourly O3 file: (If applicable)

11. AERA forms: (If applicable)

12. Other files and supporting documents (paved roads fugitive dust modeling output files, etc.):

Section 1. Modeling protocol

1. The Air Dispersion Modeling presented in this report is based on a protocol that has been: Approved Conditionally approved *MPCA approval date (mm/dd/yyyy): 05/10/2017

*This is the date given on AQDM-04 form 2. Does this modeling submittal completely follow the approved protocol? Yes No

If yes, proceed to Section 3. If no, proceed to Section 2.

Section 2. Changes to approved/conditionally approved modeling protocol

Table 1: Protocol changes (Please indicate which sections in the approved/conditionally approved protocol have been changed.) Modeling protocol by sections Section name Change/No change Modeling purpose No Change Processors No Change Model selection and options No Change Point sources No Change Volume sources No Change Area sources No Change Area source coordinates No Change Paved roads fugitive dust Change Receptors Change Meteorological data No Change Area of impact analysis Change Background values No Change Nearby sources No Change Pollutant based considerations No Change Attachments No Change



Section 2.1: Detailed changes to modeling protocol

Please provide specific information corresponding to those sections in Table 1 where changes are indicated.

Modeling purpose

MPCA approved change: Yes No Date (mm/dd/yyyy):

Describe changes:

Processors


Describe changes:

Model selection and options


Describe changes:

Point sources


Describe changes:

Volume sources


Describe changes:

Area sources


Describe changes:

Area source coordinates


Describe changes:

Paved roads fugitive dust

MPCA approved change: Yes No Date (mm/dd/yyyy): 5/10/2017

Describe changes:

Per Mr. Jim Sullivan's comments in the conditional modeling approval, paved roads were removed from the NAAQS modeling analysis, because the facility actively maintains a fugitive dust emission plan as a legally enforceable condition of their air quality permit.

Receptors

MPCA approved change: Yes No Date (mm/dd/yyyy): 5/10/2017

Describe changes:



Receptors were placed along Sappi's fence line at 10 m spacing and between the fence line and the property boundary at 50 m spacing including on the river and uncontrolled railroads. Additionally, receptors were placed on Jarden Home Brands property at 50 m spacing. Receptors falling on Sappi or Jarden Home Brands buildings were removed.

Meteorological data MPCA approved change: Yes No Date (mm/dd/yyyy):

Describe changes:

Area of impact analysis MPCA approved change: Yes No Date (mm/dd/yyyy):

Describe changes:

Receptors were placed along Sappi's fence line at 10 m spacing and between the fence line and the property boundary at 50 m spacing including on the river and uncontrolled railroads. Additionally, receptors were placed on Jarden Home Brands property at 50 m spacing. Receptors falling on Sappi or Jarden Home Brands buildings were removed.

The area of impact analysis was completed using two separate SIL runs: onsite and offsite. The onsite run was completed using the receptor placement noted above. Offsite recptors were consistent with those from the submitted protocol. Onsite and offsite receptors above the SIL for the project emissions were then combined into a single receptor grid for NAAQS and increment modeling for PM10 and PM2.5.

SIL results from the two SIL runs are shown in Table 1 attached.

Background values MPCA approved change: Yes No Date (mm/dd/yyyy):

Describe changes:

Nearby sources MPCA approved change: Yes No Date (mm/dd/yyyy):

Describe changes:

Pollutant based considerations MPCA approved change: Yes No Date (mm/dd/yyyy):

Describe changes:

Attachments MPCA approved change: Yes No Date (mm/dd/yyyy):

Describe changes:

Section 3. Paved roads fugitive dust (Optional)

Facilities that have indicated in their e-Services submittal the exclusion of paved roads in the air dispersion modeling should provide the results of that modeling in Table 1. Results should not include fugitive dust from paved roads.

Table 1: Model results for paved roads fugitive dust exemption policy. (See tables 2 and 3 for categories and requirements)

Averaging period

NAAQS (μg/m3)

Total Modeled NAAQS concentration (includes Background and Nearby Sources) (ug/m3) % of NAAQS

PSD Class II increments (μg/m3)

Modeled Class II increment impact concentrations (μg/m3)

% of Class II increments

PM10 24-hour 150 0.00% 30 0.00%



Annual 50 31.46 63.00% 17 0.00 0.00%

PM2.5 24-hour 35 0.00% 9 0.00% Annual 12 10.51 88.00% 4 1.76 44.00%

Table 2: NAAQS PSD Class II Increments

NAAQS/MAAQS result(s) w/ background and nearby sources (%) Cat. 1 Cat. 2 Cat. 3

PSD Class II result(s) (%) Cat. 1 Cat. 2 Cat. 3

PM10 63.00% # < 60% 60% < # < 95% 95% < # 0.00% # < 35% 35% < # < 75% 75% < # PM2.5 88.00% # < 80% 80% < # < 95% 95% < # 44.00% # < 40% 40% < # < 80% 80% < #

Table 3: Cat 1: Paved road fugitive emissions not required to be modeled, and no paved road fugitive dust permit conditions.

Requirements in Minn. R. 7011.150 apply.

Cat 2: Paved road fugitive emissions not required to be modeled, with paved road fugitive dust permit conditions determined by levels of traffic at the facility.

Cat 3: Paved road fugitive emissions are required to be modeled, with site-specific paved road fugitive dust permit conditions. Re-modeling and/or addition of paved road fugitive emissions source group required.

Section 4. Modeling results

Table 2: Pollutants and averaging periods (Check all the boxes for each pollutant and averaging period(s) modeled.)

Pollutant Averaging Period Standard

Increment SIL-only NAAQS MAAQS

CO 1-hr 8-hr

Lead Rolling 3 mo. Avg Quarterly Avg

NO2 1-hr Annual

SO2

1-hr 3-hr 24-hr Annual

PM10 24-hr Annual

PM2.5 24-hr Annual

Table 3: NAAQS/MAAQS modeling results (Enter modeling results along with the percent of standard.)

Pollutant Averaging period

NAAQS standard (ug/m3)

MAAQS standard (ug/m3)

Total modeled concentration (includes background and nearby sources) (ug/m3)

Percent of standard (%)

NAAQS MAAQS

CO 1-hr 40,000 35,000 8-hr 10,000 10,000

Lead Rolling 3 mo. Avg 0.15 *** Quarterly Avg 1.5 1.5

NO2 1-hr 188 *** Annual 100 100

SO2 1-hr 196 1300



3-hr *** 1300/*915 24-hr 365 365 Annual 80 60

PM10 24-hr 150 150 Annual *** 50 31.46 --- 62.9%

PM2.5 24-hr 35 65 Annual 12 15 10.51 87.6% 70.1%

*SO2 3-hr for Northern Minnesota is 915 ug/m3.

Table 4: Increment modeling results (Provide the increment modeling results along with the percent of standard.)

Pollutant Averaging Period

Class II Increment (ug/m3)

Total Modeled Concentration (includes other increment sources) (ug/m3)


NO2 1-hr *** Annual 25

SO2

1-hr *** 3-hr 512 24-hr 91 Annual 20

PM10 24-hr 30 Annual 17 0 0%

PM2.5 24-hr 9 Annual 4 1.76 44%

Table 5: SIL-only modeling results (Provide the SIL modeling results along with the percent of standard.)

Pollutant Averaging Period SIL (ug/m3)

Total Modeled Concentration (ug/m3)


NO2 1-hr 7.52 0 0% Annual 1 0.57 57%

SO2

1-hr 7.83 3-hr 25 24-hr 5 Annual 1

PM10 24-hr 5 0 0% Annual 1

PM2.5 24-hr 1.2 0 0% Annual 0.3

CO 1-hr 2000 8-hr 500

Section 5. Discussion Enter any discussion or comments on the information provided in this form (this can be used as a substitute for a written report): This modeling report is being submitted in response to a request from MPCA. A brief timeline has been included for clarification.

The modeling protocol was approved by Jim Sullivan and Rachel Yucuis on January 30, 2017.

In a conference call with Ms. Yucuis on April 7, 2017, Ms. Yucuis provided a TSD for the project describing the future allowable to past allowable emissions test that was described in the January 30 protocol approval. Based on discussions with MPCA and EPA, it was determined to model the significant net emissions increase.

Ms. Yucuis requested an updated modeling demonstration on April 19, 2017 based on the future allowable emissions to current actual emissions (2015-2016) as the basis for a SIL demonstration. In an email sent from Ms. Yucuis on April 19, 2017, it was noted



that the current actual to future allowable demonstration should be conducted for annual averaging periods only and that no change in short term emission rates is acceptable based on her review of rule FR 31390 published June 6, 2007, because Sappi has been operating near maximum capacity on a short-term basis within the last two years.

In a conference call with Mr. Sullivan and Mr. Jared LaFave on April 26, 2017 and confirmed by email on April 27, 2017 from Mr. LaFave, it was determined that a modeling protocol resubmittal and modeling report is the appropriate documentation needed to facilitate the change in modeling of the project from what was approved on January 30, 2017.

Although not typical, the April 27, 2017 email allowed Sappi to submit the modeling protocol resubmittal and the modeling report simultaneously to the MPCA. The protocol resubmittal and the modeling report were submitted on May 1, 2017.

On May 8, 2017 Sappi participated in a conference call with Mr. Sullivan, Ms. Yucuis, and Mr. LaFave where MPCA clarified the EPA definition of ambient air. Mr. Sullivan commented that receptors should be placed along Sappi's fence line at 10 m spacing, between the fence line and property line at 50 m spacing, and on Jarden Home Brand property.

On May 10, 2017 Sappi participated in a conference call with Mr. Sullivan, Ms. Yucuis, and Mr. LaFave where Mr. Sullivan explained MPCA policy to remove receptors on structures within the model and exclude paved roads in modeling demonstrations where fugitive dust control plans are enforceable permit conditions.

Additionally, It was noted in the conditional modeling approval on May 10, 2017 that the PM10 annual NAAQS standard no longer applies. Sappi recognizes this change, but to remain consistent with modeling files submitted in regards to this project a PM10 annual NAAQS demonstration was included in the modeing report.

Section 6. Modeling results figures/maps Insert a figure or map showing the facility emission sources, receptors, and the location of the modeled maximum concentration(s) for each applicable pollutant, corresponding averaging periods, and operating scenarios. See attached figures. Please note that there is no figure for PM10 increment contours, because the PM10 increment results were zero or less.



Acronyms AERMAP AERMOD Terrain Preprocessor AERMET AERMOD Meteorological Preprocessor AERMOD AMS/EPA Regulatory Model AQ AQDMR-01

Air Quality Previous Modeling Results Form

BPIP-PRIME Building Profile Input Program for PRIME CO Carbon Monoxide EPA U.S. Environmental Protection Agency FAC 3-letter facility ID MAAQS Minnesota State Ambient Air Quality Standard MPCA Minnesota Pollution Control Agency NAAQS National Ambient Air Quality Standard NO2 Nitrogen Dioxide OU Operable Unit Pb Lead PM10 Particulate Matter less than 10 um in size PM2.5 Particulate Matter less than 2.5 um in size PRIME Plume Rise Model Enhancements

PSD Prevention of Significant Deterioration Program SIL Significant Impact Level SO2 Sulfur Dioxide SIP State Implementation Plan SMS Standardized Mobile Source μg/m3 Micrograms per cubic meter (μg/m3) UTM Universal Transverse Mercator


Table 1: SIL Results

Pollutant Averaging

Period Offsite

Receptors Onsite

Receptors SIL NO2 Annual 0.55 0.57 1 PM10 Annual 1.84 1.89 1 PM2.5 Annual 1.55 1.58 0.3

Supplemental Figure 1: Sappi Source Configuration

Supplemental Figure 2: Sappi and Nearby Source Configuration

Supplemental Figure 3: Sappi PM10 NAAQS and Increment Receptor Grid

Supplemental Figure 4: PM10 NAAQS Impacts

Supplemental Figure 5: Sappi PM2.5 NAAQS and Increment Receptor Grid

Supplemental Figure 6: PM2.5 Increment Impacts

Supplemental Figure 7: PM2.5 NAAQS Impacts

TechnicalMemo

Wenck Associates, Inc. | 1800 Pioneer Creek Center | P.O. Box 249 | Maple Plain, MN 55359-0249

Toll Free 800-472-2232 Main 763-479-4200 Email [email protected] Web wenck.com-

To: Rob Schilling, Sappi

From: Charlene Becka, Wenck Associates, Inc. Jared Anderson, Wenck Associates, Inc.

Date: April 25, 2017

Subject: Sappi Proposed Background Concentrations

Introduction

The objective of this memo is to propose background concentrations for 24-hour and annual PM10 and PM2.5. The background concentrations will be used in a dispersion modeling analysis for the Sappi facility located in Cloquet, MN, Carlton County, Minnesota.

Monitor Site Selection Procedure

The process to develop background concentration for the site was based on current air dispersion modeling guidance from the Minnesota Pollution Control Agency (MPCA) as well as a presentation given by Mr. Jim Sullivan of the MPCA at the Air Modeling Guidance Seminar on July 16, 2013. The approach was discussed on pages 8 through 10 of the presentation entitled “Ambient Air Pollutant Background Concentrations: Development and Use”. This procedure will be used for this analysis as well. The procedure is discussed in greater detail below.

Sappi is proposing to use an average between two monitored background concentrations for particulate matter less than 10 microns in diameter (PM10) and particulate matter less than 2.5 microns in diameter (PM2.5). The site selection methodology will include the following:

1. Description of the monitoring dataa. basic descriptive statistics of the data such as

i. density and diversity of the emission sources;ii. determination of how well the monitor captures the influence of nearby

sources that are not affected by the project;iii. differences in land use and terrain between the monitor and project

site;b. purpose of the monitor activity and geographic scale of representation

2. Quality Control/Assurance Measures – Not applicable as the data was provided by the MPCA.

Monitor Site Selection

Sappi is proposing to use monitor concentrations from Virginia, Duluth at Oneota Street, and WDSE Duluth.

Sappi is located on the north side of Cloquet, Minnesota in Carlton County. Carlton County is a rural area with land primarily being undeveloped/forested or used for agriculture. While there are some areas of development, such as the city of Cloquet, Sappi is located on the

Rob SchillingSappiApril 25, 2017

2N:\Technical\1251\0044\Air Dispersion Modeling\Background\Background Concentrations Technical Memo 4-25-17.docx

north edge of town adjacent to undeveloped areas. Therefore, overall this location can be considered rural.

According to the MPCA’s 2017 “Annual Air Monitoring Network Plan for Minnesota,” there are 28 ambient air monitor locations across Minnesota that monitor PM10 and/or PM2.5.

Monitors located in the Minneapolis/St. Paul metropolitan area were excluded as their concentrations would likely be influenced by urban activity which would not be present at Sappi. Additionally, monitors at a distance greater than 150 km were excluded as they would not be representative of local ambient air concentrations.

Table 1 shows the remaining monitors for PM10 and PM2.5 within 150 km of Sappi.

Table 1. Ambient Monitor Location Summary

Site MPCA Site ID

Pollutant Distance (km) Distance (miles)

Cloquet 7417 PM2.5 6.21 3.86Duluth Laura MacArthur School 7554 PM2.5 20.34 12.64

Duluth Oneota Street 7545 PM10 22.32 13.87Duluth WDSE 7550 PM2.5 24.30 15.10Virginia 1300 PM10, PM2.5 88.97 55.28Brainerd 3201 PM2.5 135.97 84.49

The Cloquet monitor was removed from consideration as it does not have a complete dataset for a three-year average.

Next, the surface roughness at all the monitor sites was compared to that at Sappi. EPA’s AERSURFACE utility was used to calculate the characteristics at the project site and each of the monitor sites. The surface roughness values within one kilometer of each location were identified using USEPA’s AERSURFACE program as this is recommended by the AERMET user’s guide. The land use and land cover data were obtained from the United States Geological Survey (USGS) National Land Cover Data 1992 (NLCD92) archives. The values were calculated using twelve sectors and a 1-km radius circle.

A simple statistical analysis was performed on the surface roughness values. The statistical analysis consisted of calculating the maximum, minimum, and average surface roughness values across all sectors and all months for each data set. The results of the statistical analysis are shown in Table 2.

The average surface roughness of Sappi is moderate compared to some of the other sites. The ideal monitor site(s) would also have moderate surface roughness, so sites with an average surface roughness greater than 0.5 and less than 0.15 were excluded. This removes the Brainerd and Duluth Laura MacArthur monitors from consideration.



Table 2. Surface Roughness Statistics

Site MPCA Site ID

Maximum Roughness

Minimum Roughness

AverageRoughness

MedianRoughness

Sappi X 0.69 0.05 0.28 0.21Duluth Laura MacArthur School

7554 0.86 0.44 0.64 0.64

Duluth Oneota Street 7545 0.71 0.01 0.36 0.35

Duluth WDSE 7550 0.72 0.09 0.41 0.41Virginia 1300 0.91 0.03 0.37 0.24Brainerd 3201 0.35 0.02 0.10 0.06

The remaining monitors for consideration include Virginia, Duluth Oneota Street, and Duluth WDSE. The decision to use one of these monitors as the basis for the background concentrations in the project cannot be made on the basis of descriptive statistics alone.

The appropriateness of the background sites was next examined by graphing the surface roughness values for each sector. Figure 1 highlights the differences in surface roughness for each month and sector. The figure shows a graph of surface roughness height as a function of the combination of the twelve sectors and the twelve months for each sector. Each sector corresponds to one of the two 30-degree wind sectors set up to determine the land use out to one kilometer from each respective site. The first twelve data points shown in the figure represent the monthly surface roughness values that were calculated for Sector 1.

Figure 1 generally shows that while some sectors of surface roughness at each ambient air monitor follows the surface roughness at Sappi, other sectors can vary widely from the surface roughness surrounding Sappi. Each monitor shows large discrepancies in nearly all sectors with no single monitor performing significantly better than another. Therefore; the decision to use one of these monitors as the basis for the background concentrations in the project cannot be made using this method.

The locational aspects of each monitor were next examined. As noted previously, Sappi is considered a rural site, lying on the edge of Cloquet as shown in Figure 2. There is moderate development to the south of the facility, but considerable undeveloped areas to the north and east as the Saint Louis River borders the north end of the facility. The Virginia monitor (Figure 3) is located in the middle of the city near busy streets and large areas of development. The monitor in Duluth at Oneota Street (Figure 4) is located near Saint Louis Bay which is a transition point between Lake Superior and the Saint Louis River. It is adjacent to undeveloped park areas as well as I-35 which could be a large source of particulate matter due to heavy traffic. Overall, the influence of the relatively large body of water in close proximity to the monitor is likely to keep concentrations lower than those farther inland. The WDSE monitor in Duluth (Figure 5) is located at the University of Minnesota Duluth campus (UMD). It is surrounded by campus development as well as several undeveloped park areas. Additionally, a considerable amount of the potential traffic at UMD is pedestrian, which would cut down on potential vehicle emissions and thus lead to lower particulate emissions.



The urban nature of the Virginia monitor is inadequate to represent Sappi concentrations as are the less developed or low activity areas where the Duluth monitors are located. While no single monitor is adequate in representing the project site, averaging two monitors for each pollutant will better represent the ambient air concentrations around Sappi. Therefore; an average of the Virginia monitor and the Duluth monitor at Oneota street will be used to represent PM10 ambient air concentrations and an average of the Virginia monitor and the WDSE monitor in Duluth will be used to represent PM2.5 concentrations at Sappi.

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1

1 13 25 37 49 61 73 85 97 109 121 133

Zo (M

)

12 Sectors * 12 Months

Figure 1. Sappi 1 km Surface Roughness Comparison

SappiVirginiaOneotaWDSE



Figure 2 Sappi Facility Location

Figure 3 Virginia Monitor Location

Sappi



Figure 4 Duluth Monitor Location at Oneota Street

Figure 5 Duluth WDSE Monitor Location



Background Concentration Summary

The representative PM2.5 background concentrations and the PM10 24-hour background concentration were obtained from the 2017 MPCA Air Monitoring Network Plan for Minnesota. The annual background concentration for PM10 was obtained from MPCA’s Minnesota 2013 Design Values for All Pollutants downloaded from the MPCA website and attached to this memo. This is the most recent annual average for Virginia and the Duluth monitor at Oneota Street processed by the MPCA. Table 3 summarizes the proposedbackground concentrations that will be used for air dispersion modeling at Sappi.

Table 3. Proposed Background Concentrations

Pollutant Averaging Period

Monitor Location

Background Concentration

(ppb)

Background Concentration

(μg/m3)

Modeled Background

Concentration (μg/m3)

PM10 24-hrVirginia - 40

65Duluth (Oneota Street) - 90

PM10 AnnualVirginia - 13

18Duluth (Oneota Street) - 23

PM2.5 24-hr Virginia - 18 17Duluth (WDSE) - 16

PM2.5 AnnualVirginia - 7.5

6.5Duluth (WDSE) - 5.5FHR 423 5 9.4

Min

neso

ta 2

013

Desi

gn V

alue

s for

All

Crite

ria A

ir Po

lluta

nts

aq2-

68M

inne

sota

Pol

lutio

n Co

ntro

l Age

ncy

• 5

20 L

afay

ette

Rd.

N.,

St. P

aul,

MN

551

55-4

194

• w

ww

.pca

.sta

te.m

n.us

651-

296-

6300

• 8

00-6

57-3

864

• T

TY 6

51-2

82-5

332

or 8

00-6

57-3

864

• A

vaila

ble

in a

ltern

ativ

e fo

rmat

sSe

ptem

ber 2

014

Leve

lCo

mpl

ianc

e Te

st

53 p

pb

100

ppb

30 p

pb

140

ppb

75 p

pb

9 pp

m

35 p

pm

75 p

pb

12 u

g/m

3

35 u

g/m

3

0.15

ug/

m3

150

ug/m

3

Min

neso

ta A

mbi

ent A

ir Q

ualit

y St

anda

rds -

Prim

ary

Leve

l

50 u

g/m

3

75 u

g/m

3

260

ug/m

3

Upd

ated

Sep

tem

ber 1

9, 2

014

byCa

ssie

McM

ahon

218-

302-

6600

A sit

e m

eets

the

8-Hr

O3

stan

dard

if th

e 3-

year

ave

rage

of t

he 4

th-d

aily

max

imum

8-

hr O

3 co

ncen

trat

ion

is le

ss th

an o

r eq

ual t

o 75

ppb

.A

site

mee

ts th

e an

nual

PM

2.5

stan

dard

if th

e 3-

year

ave

rage

of t

he q

uart

erly

wei

ghte

d an

nual

ave

rage

PM

2.5

conc

entr

atio

n is

less

than

or e

qual

to 1

2 ug

/m3.

A sit

e m

eets

the

24-H

r PM

2.5

stan

dard

if th

e 3-

year

ave

rage

of t

he a

nnua

l 98t

h pe

rcen

tile

daily

PM

2.5

conc

entr

atio

n is

less

th

an o

r equ

al to

35

ug/m

3.A

site

mee

ts th

e le

ad st

anda

rd if

the

max

imum

rolli

ng q

uart

er a

vera

ge le

ad c

once

ntra

tion

does

not

exc

eed

0.15

ug/

m3

over

a

3-ye

ar p

erio

d.

Nat

iona

l Am

bien

t Air

Qua

lity

Stan

dard

s - P

rimar

y

A sit

e m

eets

the

annu

al N

O2

stan

dard

if th

e an

nual

ave

rage

NO

2 co

ncen

trat

ion

is le

ss th

an o

r equ

al to

53

ppb.

A sit

e m

eets

the

1-Hr

NO

2 st

anda

rd if

the

3-ye

ar a

vera

ge o

f the

ann

ual 9

8th

perc

entil

e 1-

Hr N

O2

conc

entr

atio

n is

less

than

or

equ

al to

100

ppb

.A

site

mee

ts th

e an

nual

SO

2 st

anda

rd if

the

annu

al a

vera

ge S

O2

conc

entr

atio

n is

less

than

or e

qual

to 3

0 pp

b. T

his s

tand

ard

was

resc

inde

d by

EPA

in 2

010.

A sit

e m

eets

the

24-H

r SO

2 st

anda

rd if

the

2nd

high

est 2

4-ho

ur S

O2

conc

entr

atio

n at

a si

te is

less

than

or e

qual

to 1

40 p

pb.

EPA

resc

inde

d th

e 24

-Hr S

O2

stan

dard

in 2

010.

A sit

e m

eets

the

1-Hr

SO

2 st

anda

rd if

thre

e-ye

ar a

vera

ge o

f the

ann

ual 9

9th

perc

entil

e 1-

HR S

O2

conc

entr

atio

n is

less

than

or

equ

al to

75

ppb.

Pollu

tant

Aver

agin

g Ti

me

Year

Est

ablis

hed

or

Revi

sed

Nitr

ogen

Dio

xide

(NO

2)An

nual

1971

1-Hr

2010

Sulfu

r Dio

xide

(SO

2)

Annu

al19

71

24-H

r19

71

1-Hr

2010

Carb

on M

onox

ide

(CO

)8-

Hr19

71

1-Hr

1971

A sit

e m

eets

the

8-Hr

CO

stan

dard

if th

e 2n

d hi

gest

dai

ly m

axim

um n

on-o

verla

ppin

g 8-

Hr C

O c

once

ntra

tion

is le

ss th

an o

r eq

ual t

o 9

ppm

.

A sit

e m

eets

the

1-Hr

CO

stan

dard

if th

e 2n

d hi

ghes

t 1-h

r CO

con

cent

ratio

n is

less

than

or e

qual

to 3

5 pp

m.

Ozo

ne (O

3)8-

Hr20

08

Fine

Par

ticul

ate

(PM

2.5)

Annu

al

2012

24-H

r20

06

Lead

(Pb)

Rolli

ng Q

uart

er20

08

PM10

24

-Hr

1987

A sit

e m

eets

the

annu

al T

SP st

anda

rd if

the

annu

al a

vera

ge T

SP c

once

ntra

tion

is le

ss th

an o

r equ

al to

75

ug/m

3. S

econ

dary

st

anda

rd is

60

ug/m

3.A

site

mee

ts th

e 24

-hou

r TSP

stan

dard

if th

e 2n

d m

axim

um c

once

ntra

tion

is le

ss th

an o

r equ

al to

260

ug/

m3.

Sec

onda

ry

stan

dard

is 1

50 u

g/m

3.

Annu

al

24-H

our

TSP

1971

Pollu

tant

Aver

agin

g Ti

me

Year

Est

ablis

hed

or

Revi

sed

A sit

e m

eets

the

24-H

r PM

10 st

anda

rd if

the

3-ye

ar a

vear

ge o

f the

est

imat

ed n

umbe

r of d

aily

con

cent

ratio

ns g

reat

er th

an

the

leve

l of t

he st

anda

rd is

less

than

1.

Com

plia

nce

Test

PM10

An

nual

1987

A sit

e m

eets

the

annu

al P

M10

stan

dard

if th

e an

nual

ave

rage

PM

10 c

once

ntra

tion

is le

ss th

an o

r equ

al to

50

ug/m

3.

Min

neso

ta 2

013

Desig

n Va

lues

for A

ll Po

lluta

nts •

aq2

-68

• Se

ptem

ber 2

014

2 of

24

1-Hr

CO

AQSI

DSi

te N

ame

2012

2013

Stan

dard

2713

7001

8Du

luth

(752

6)1.

64.

635

2703

7002

0FH

R 42

00.

30.

735

2703

7042

3FH

R 42

31.

23.

335

2705

3095

4M

inne

apol

is (9

54)

2.3

1.4

3527

0530

962

Min

neap

olis

(962

)1.

635

2712

3005

0St

. Pau

l (86

1)3.

42.

435

8-hr

CO

Site

Nam

e20

1220

13St

anda

rd27

1370

018

Dulu

th (7

526)

0.6

1.5

927

0370

020

FHR

420

0.3

0.5

927

0370

423

FHR

423

1.0

2.5

927

0530

954

Min

neap

olis

(954

)1.

10.

79

2705

3096

2M

inne

apol

is (9

62)

0.8

927

1230

050

St. P

aul (

861)

1.5

1.1

9

A sit

e m

eets

the

1-Hr

CO

stan

dard

if th

e 2n

d hi

ghes

t

1-hr

CO

con

cent

ratio

n is

less

than

or e

qual

to 3

5 pp

m.

A sit

e m

eets

the

8-Hr

CO

stan

dard

if th

e 2n

d hi

ghes

t no

n-ov

erla

ppin

g 8-

Hr C

O c

once

ntra

tion

is le

ss th

an o

r eq

ual t

o 9

ppm

.

Min

neso

ta 2

013

Desig

n Va

lues

for A

ll Po

lluta

nts •

aq2

-68

• Se

ptem

ber 2

014

3 of

24

Lead

(Rol

ling

Qua

rter

)AQ

SID

Site

Nam

e20

10-2

012

2011

-201

3St

anda

rdN

otes

2700

3602

0An

oka

(602

0)*

0.03

80.

040

0.15

Clos

ed Ju

ne 2

013

2703

7047

0Ap

ple

Valle

y (4

70)

0.00

20.

004

0.15

2716

3044

6Ba

ypor

t (44

6)0.

001

0.00

30.

1527

0031

002

Blai

ne (6

010)

*0.

012

0.02

10.

152

Yrs

2713

7755

5Du

luth

(755

5)0.

005

0.00

50.

1527

0370

465

Eaga

n (4

65)

0.25

90.

111

0.15

2703

7002

0FH

R 42

00.

013

0.01

20.

15

2705

3100

7M

inne

apol

is (9

07)*

0.00

50.

152

yrs

3705

3096

3M

inne

apol

is (9

63)

0.00

40.

005

0.15

2705

3096

6M

inne

apol

is (9

66)

0.01

60.

006

0.15

2716

3043

8N

orth

ern

Tier

En

ergy

(438

)0.

005

0.00

60.

15

2714

5305

3St

. Clo

ud

(305

3)*

0.00

80.

009

0.15

Clos

ed Ju

ne 2

013

2712

3087

1St

. Pau

l (87

1)0.

007

0.00

70.

1527

1377

001

Virg

inia

(130

0)0.

008

0.00

80.

15

* De

sign

valu

e is

base

d on

less

than

3-y

ears

of c

ompl

ete

mon

itorin

g da

ta

A sit

e m

eets

the

lead

stan

dard

if th

e m

axim

um ro

lling

3-m

onth

ave

rage

le

ad c

once

ntra

tion

does

not

exc

eed

0.15

ug/

m3

over

a 3

-yea

r per

iod.

Min

neso

ta 2

013

Desig

n Va

lues

for A

ll Po

lluta

nts •

aq2

-68

• Se

ptem

ber 2

014

Page

4 o

f 24

NO

2 1-

Hr (p

pb)

AQSI

DSi

te N

ame

2010

-201

220

11-2

013

Stan

dard

2700

3100

2Bl

aine

(601

0)46

4310

027

0370

020

FHR

420

4644

100

2703

7042

3FH

R 42

333

2910

0

NO

2 An

nual

(ppb

)AQ

SID

Site

Nam

e20

1220

13St

anda

rd27

0031

002

Blai

ne (6

010)

87

5327

0370

020

FHR

420

119

5327

0370

423

FHR

423

55

53

A sit

e m

eets

the

1-Hr

NO

2 st

anda

rd if

the

3-ye

ar a

vera

ge

of th

e an

nual

98t

h pe

rcen

tile

1-Hr

NO

2 co

ncen

trat

ion

is le

ss th

an o

r equ

al to

100

ppb

.

A sit

e m

eets

the

annu

al N

O2

stan

dard

if th

e an

nual

av

erag

e N

O2

conc

entr

atio

n is

less

than

or e

qual

to 5

3

Min

neso

ta 2

013

Desig

n Va

lues

for A

ll Po

lluta

nts •

aq2

-68

• Se

ptem

ber 2

014

Page

5 o

f 24

8-Hr

Ozo

ne

(ppb

)AQ

S ID

Site

Nam

e20

08-2

010

2009

-201

120

10-2

012

2011

-201

3N

otes

Stan

dard

2700

3100

2Bl

aine

(60

10)

6265

6767

7527

0353

204

Brai

nerd

(320

4)60

6162

6275

2701

7741

6Cl

oque

t (74

16)

5654

5556

7527

0052

013

Detr

oit L

akes

(201

3)59

5961

6175

2713

7755

0Du

luth

(755

0)52

4950

5075

2700

3100

1Ea

st B

ethe

l (60

12)

6163

6767

7527

0750

005

Ely

(700

1)59

5859

5875

27-1

63-6

016

Mar

ine

on S

t. Cr

oix

(601

6)*

63O

nly

2 ye

ars o

f Dat

a in

201

3. In

com

plet

e fo

r NAA

QS

Dete

rmin

atio

n75

2708

3421

0M

arsh

all (

4210

)62

6364

6575

2709

5305

1M

ille

Lacs

(305

1)57

5960

6075

2710

9500

8Ro

ches

ter (

5008

)60

6063

6475

2713

9050

5Sh

akop

ee (5

05)

6060

6265

7527

1453

052

St. C

loud

(305

2)56

5861

6275

2717

1320

1St

. Mic

hael

(320

1)60

6264

6375

2704

9530

2St

anto

n (5

302)

6060

6263

7527

1370

034

Voya

geur

s62

6263

5975

A sit

e m

eets

the

8-Hr

O3

stan

dard

if th

e 3-

year

ave

rage

of t

he 4

th-d

aily

max

imum

8-h

r O3

conc

entr

atio

n is

less

than

or e

qual

to 7

5 pp

b.

Min

neso

ta 2

013

Desig

n Va

lues

for A

ll Po

lluta

nts •

aq2

-68

• Se

ptem

ber 2

014

Page

6 o

f 24

PM10

24-

HR

AQSI

DSi

te N

ame

2012

2013

Stan

dard

Estim

ated

Ex

ceed

ance

s 20

1327

0031

002

Blai

ne (6

010)

6049

150

027

1370

032

Dulu

th (7

545)

5057

150

027

0530

966

Min

neap

olis

(966

)37

3615

00

2712

3086

6St

. Pau

l (86

6)55

5715

00

2712

3086

8St

. Pau

l (86

8)67

5815

00

2713

7700

1Vi

rgin

ia (1

300)

2435

150

0

PM10

Ann

ual

NO

FED

ERAL

STA

NDA

RD -

MAA

QS

= 50

ug/

m3

AQSI

DSi

te N

ame

2012

2013

Stan

dard

2700

3100

2Bl

aine

(601

0)19

1750

2713

7003

2Du

luth

(754

5)21

2350

2705

3096

6M

inne

apol

is (9

66)

2019

5027

1230

866

St. P

aul (

866)

2627

5027

1230

868

St. P

aul (

868)

2522

5027

1377

001

Virg

inia

(130

0)12

1350

2nd

max

imum

PM

10 c

once

ntra

tion

mus

t not

ex

ceed

150

ug/

m3.

A si

te m

eets

the

stan

dard

if

the

estim

ated

num

ber o

f exc

eeda

nces

ave

rage

d ov

er 3

-yea

rs is

less

than

1.

Min

neso

ta 2

013

Desig

n Va

lues

for A

ll Po

lluta

nts •

aq2

-68

• Se

ptem

ber 2

014

Page

7 o

f 24

PM2.

5 Da

ilyAQ

SID

Site

Nam

e20

08-2

010

2009

-201

120

10-2

012

2011

-201

3St

anda

rd27

0370

470

Appl

e Va

lley

(470

)31

3125

2235

2700

3100

2Bl

aine

(601

0)23

2235

2713

7755

0Du

luth

(755

0)21

1917

1835

2708

3421

0M

arsh

all (

4210

)20

3527

0530

963

Min

neap

olis

(963

)31

3025

2335

2710

9500

8Ro

ches

ter (

5008

)31

3025

2235

2713

9050

5Sh

akop

ee (5

05)

2928

2522

3527

1453

052

St. C

loud

(305

2)26

2724

2235

2705

3200

6St

. Lou

is Pa

rk (2

50)

2928

2523

3527

1230

868

St. P

aul (

868)

3634

2824

3527

1230

871

St. P

aul (

871)

3733

2722

3527

1377

001

Virg

inia

(130

0)17

1715

1635

PM2.

5 An

nual

AQSI

DSi

te N

ame

2008

-201

020

09-2

011

2010

-201

2 20

11-2

013

Stan

dard

2703

7047

0Ap

ple

Valle

y (4

70)

9.6

9.2

98.

412

2700

3100

2Bl

aine

(601

0)8.

58.

212

2713

7755

0Du

luth

(755

0)6.

15.

85.

55.

712

2708

3421

0M

arsh

all (

4210

)7.

112

2705

3096

3M

inne

apol

is (9

63)

9.7

9.5

98.

412

2710

9500

8Ro

ches

ter (

5008

)9.

79.

69

8.5

1227

1390

505

Shak

opee

(505

)9.

38.

88.

68.

512

2714

5305

2St

. Clo

ud (3

052)

8.6

8.6

8.5

7.9

1227

0532

006

St. L

ouis

Park

(250

)9.

59

8.8

8.8

1227

1230

868

St. P

aul (

868)

10.6

109.

79.

812

2712

3087

1St

. Pau

l (87

1)10

.19.

69.

18.

712

2713

7700

1Vi

rgin

ia (1

300)

5.6

5.4

5.3

6.1

12

A sit

e m

eets

the

24-H

r PM

2.5

stan

dard

if th

e 3-

year

av

erag

e of

the

annu

al 9

8th

perc

entil

e da

ily P

M2.

5 co

ncen

trat

ion

is le

ss th

an o

r equ

al to

35

ug/m

3.

A sit

e m

eets

the

annu

al P

M2.

5 st

anda

rd if

the

3-ye

ar

aver

age

of th

e qu

arte

rly w

eigh

ted

annu

al a

vera

ge P

M2.

5 co

ncen

trat

ion

is le

ss th

an o

r equ

al to

12

ug/m

3.

Min

neso

ta 2

013

Desig

n Va

lues

for A

ll Po

lluta

nts •

aq2

-68

• Se

ptem

ber 2

014

Page

8 o

f 24

SO2

1-HR

ppb

2010

-201

220

11-2

013

Stan

dard

FHR

420

1714

75FH

R 42

310

875

FHR

442

33

75FH

R 44

33.

32

75M

inne

apol

is (9

54)

149

75Sa

int P

aul P

ark

(436

)11

1075

SO2

24-H

Rpp

b20

1220

13St

anda

rdFH

R 42

04.

24

140

FHR

423

2.5

314

0FH

R 44

21.

51

140

FHR

443

1.3

114

0M

inne

apol

is (9

54)

2.4

1514

0Sa

int P

aul P

ark

(436

)2.

33

140

SO2-

Annu

alpp

b

2012

2013

Stan

dard

FHR

420

0.65

0.7

30FH

R 42

30.

750.

630

FHR

442

0.26

0.6

30FH

R 44

30.

180.

430

Min

neap

olis

(954

)0.

210.

930

Sain

t Pau

l Par

k (4

36)

0.49

0.6

30

A sit

e m

eets

the

1-Hr

SO

2 st

anda

rd if

thre

e-ye

ar a

vera

ge o

f the

ann

ual 9

9th

perc

entil

e 1-

HR S

O2

conc

entr

atio

n is

less

than

or e

qual

to 7

5 pp

b.

A sit

e m

eets

the

annu

al S

O2

stan

dard

if th

e an

nual

ave

rage

SO

2 co

ncen

trat

ion

is le

ss th

an o

r equ

al to

30

ppb.

Thi

s sta

ndar

d w

as re

scin

ded

by E

PA in

201

0.

A sit

e m

eets

the

24-H

r SO

2 st

anda

rd if

the

2nd

high

est 2

4-ho

ur S

O2

conc

entr

atio

n at

a si

te is

less

than

or e

qual

to 1

40 p

pb. E

PA re

scin

ded

the

24-H

r SO

2 st

anda

rd in

201

0.

Min

neso

ta 2

013

Desig

n Va

lues

for A

ll Po

lluta

nts •

aq2

-68

• Se

ptem

ber 2

014

Page

9 o

f 24

SO2

- 3HR

pp

b20

1220

13St

anda

rdSe

cond

ary

FHR

420

10.0

10.0

500

350

FHR

423

6.0

5.6

500

350

FHR

442

3.0

21.3

500

350

FHR

443

1.6

2.0

500

350

Min

neap

olis

(954

)6.

317

.350

035

0Sa

int P

aul P

ark

(436

)6.

69.

650

035

0

A sit

e m

eets

the

3-Ho

ur S

O2

stan

dard

if th

e 2n

d hi

ghes

t no

n-ov

erla

ppin

g 3-

hour

con

cent

ratio

n is

less

than

500

ppb

.

Minnesota 2013 Design Values for All Pollutants • aq2-68 • September 2014 Page 10 of 24

Primary MAAQS = 260 ug/m3 Secondary MAAQS = 150 ug/m3

TSP 24-HR 2nd High 24-hour TSP ConcentrationAQSID Site Name 2012 2013 Secondary Standard270370470 Apple Valley (470) 68 76 150271630446 Bayport (446) 54 53 150270031002 Blaine (6010) 63 64 150271377555 Duluth (7555) 130 75 150270370465 Eagan (465) 104 78 150270370020 FHR 420 105 98 150270530963 Minneapolis (907) 81 68 150270530966 Minneapolis (963) 72 65 150270531007 Minneapolis (966) 77 69 150271630438 Newport (438) 107 102 150271230871 St. Paul (871) 66 69 150271377001 Virginia (1300) 79 99 150

Primary MAAQS = 75 ug/m3 Secondary MAAQS = 60 ug/m3

TSP Annual Annual Geometric Mean (ug/m3)AQSID Site Name 2012 2013 Secondary Standard270370470 Apple Valley (470) 31 21 60271630446 Bayport (446) 26 19 60270031002 Blaine (6010) 27 20 60271377555 Duluth (7555) 50 32 60270370465 Eagan (465) 44 29 60270370020 FHR 420 48 40 60270530963 Minneapolis (907) 39 31 60270530966 Minneapolis (963) 33 24 60270531007 Minneapolis (966) 37 30 60271630438 Newport (438) 38 28 60271230871 St. Paul (871) 31 23 60271377001 Virginia (1300) 31 28 60

2013

CO

1-H

R

4.6

0.7

3.3

1.4

1.6

2.4

0510152025303540

Dul

uth

(752

6)FH

R 4

20FH

R 4

23M

inne

apol

is (9

54)

Min

neap

olis

(962

)St

. Pau

l (86

1)

Carbon Monoxide Concentration (parts per million)

2013

Stan

dard

2013

CO

8-H

R

1.5

0.5

2.5

0.7

0.8

1.1

0246810

Dul

uth

(752

6)FH

R 4

20FH

R 4

23M

inne

apol

is (9

54)

Min

neap

olis

(962

)St

. Pau

l (86

1)

Carbon Monoxide Concentration (parts per million)20

13St

anda

rd

2011

-201

3 Le

ad

0.04

0

0.00

40.

003

0.02

1

0.00

5

0.11

1

0.01

20.

005

0.00

50.

006

0.00

60.

009

0.00

70.

008

0.00

0.02

0.04

0.06

0.08

0.10

0.12

0.14

0.16

Anoka (6020)*

Apple Valley (470)

Bayport (446)

Blaine (6010)*

Duluth (7555)

Eagan (465)

FHR 420

Minneapolis (907)*

Minneapolis (963)

Minneapolis (966)

Northern Tier Energy (438)

St. Cloud (3053)*

St. Paul (871)

Virginia (1300)

Lead Concentration (micrograms per cubic meter)20

11-2

013

Stan

dard

* le

ss th

an 3

-yea

rs o

f com

plet

e da

ta

2011

-201

3 N

O2

1-HR

4344

29

020406080100

120

Blai

ne (6

010)

FHR

420

FHR

423

Nitrogen Dioxide Concentration (parts per billion)

2011

-201

3St

anda

rd

2013

NO

2 An

nual

79

5

0102030405060

Blai

ne (6

010)

FHR

420

FHR

423

Nitrogen Dioxide Concentration (parts per billion)

2013

Stan

dard

2011

-201

3 O

zone

8-H

R

67

62

56

61

50

67

58

6365

6064

6562

6363

59

01020304050607080

Ozone Concentration (parts per billion)20

11-2

013

Sta

ndar

d

* le

ss th

an 3

-yea

rs o

f com

plet

e da

ta

2013

PM

10 D

aily

49

57

36

5758

35

020406080100

120

140

160

Blai

ne (6

010)

Dul

uth

(754

5)M

inne

apol

is (9

66)

St. P

aul (

866)

St. P

aul (

868)

Virg

inia

(130

0)

PM10(micrograms per cubic meter)20

13St

anda

rd

2011

-201

3 PM

2.5

Daily

2222

18

20

2322

2222

2324

22

16

0510152025303540Fine Particle Concentration (micrograms per cubic meter)

2011

-201

3St

anda

rd

2011

-201

3 PM

2.5

Annu

al

8.4

8.2

5.7

7.1

8.4

8.5

8.5

7.9

8.8

9.8

8.7

6.1

02468101214Fine Particle Concentration (micrograms per cubic meter)

2011

-201

3St

anda

rd

2011

-201

3 SO

2 1-

HR

14

8

32

910

01020304050607080

FHR

420

FHR

423

FHR

442

FHR

443

Min

neap

olis

(954

)Sa

int P

aul P

ark

(436

)

Sulfur Dioxide Concentration (parts per billion)20

11-2

013

Stan

dard

2011

-201

3 SO

2 24

-HR

43

11

15

3

020406080100

120

140

160

FHR

420

FHR

423

FHR

442

FHR

443

Min

neap

olis

(954

)Sa

int P

aul P

ark

(436

)

Sulfur Dioxide Concentration (parts per billion)

2013

Stan

dard

2011

-201

3 SO

2 An

nual

0.7

0.6

0.6

0.4

0.9

0.6

0.0

5.0

10.0

15.0

20.0

25.0

30.0

35.0

FHR

420

FHR

423

FHR

442

FHR

443

Min

neap

olis

(954

)Sa

int P

aul P

ark

(436

)

Sulfur Dioxide Concentration (parts per billion)

2013

Stan

dard

2013

TSP

Dai

ly

76

53

64

7578

98

6865

69

102

69

99

020406080100

120

140

160

Total Suspended Particulate Concentration (micrograms per cubic meter)20

13Se

cond

ary

Stan

dard

2013

TSP

Ann

ual

2119

20

3229

40

31

24

3028

23

28

010203040506070Total Suspended Particulate Concentration (micrograms per cubic meter)

2013

Seco

ndar

y St

anda

rd

TechnicalMemo

Wenck Associates, Inc. | 1800 Pioneer Creek Center | P.O. Box 249 | Maple Plain, MN 55359-0249

Toll Free 800-472-2232 Main 763-479-4200 Email [email protected] Web wenck.com-

To: Rob Schilling, Sappi

From: Charlene Becka, Wenck Associates, Inc. Jared Anderson, Wenck Associates, Inc.

Date: April 25, 2017

Subject: Sappi Proposed Nearby Sources

Introduction

The objective of this memo is to propose nearby sources to include for the annual PM10 and PM2.5 NAAQS and increment air dispersion modeling demonstrations. The sources will be used in a Prevention of Significant Deterioration (PSD) modeling analysis for the Sappi facility located in Cloquet, MN, Carlton County, Minnesota.

Nearby Source Identification

MPCA provides a GIS-based tool for use in dispersion modeling analyses that allow users to look up relevant nearby sources (based on 2011-2013 emissions inventories) within a 50-kilometer radius of the facility. The tool was used for Sappi, and the sources identified are shown in Table 1.

Table 1 Nearby Source Identification Summary

Facility Distance (km)PM10

Jarden Home Brands 0.42Ulland Brothers Inc North - Nonmetallic 8.12USG Interiors LLC 2.01Wisconsin Central LTD – Duluth Ore Dock 23.02ME Global Inc/Electrical Duluth 17.83Calumet Superior LLC 28.25

PM2.5

Jarden Home Brands 0.42USG Interiors LLC 2.01

Additionally, Specialty Minerals Inc (Specialty Minerals) was identified as a relevant source as it is located on Sappi property, emits particulates, and has traditionally been included in previous modeling analyses of the Cloquet area.

Source Selection

Of the sources noted in Table 1, Ulland Brothers Inc North – Nonmetallic (Ulland) is a portable aggregate crushing operation that operates under Air Emissions Permit No. 1700043-002. The distance provided by the MPCA’s nearby source tool does not reflect the


2N:\Technical\1251\0044\Air Dispersion Modeling\Nearby Sources\Nearby Sources Technical Memo 4-25-17.docx

actual location of the source relative to Sappi due to the source’s portable nature. Therefore; Ulland will not be modeled as a nearby source. This source is best representedby ambient monitoring data.

Figure 1 and Figure 2 show the locations of the nearby sources relative to Sappi. Jarden Home Brands (Jarden), USG Interiors LLC (USG), and Specialty Minerals are within a short distance from the facility, and emissions from these sources will be modeled explicitly. ME Global Inc/Electrical Duluth (ME Global), Wisconsin Central LTD – Duluth Ore Dock (Wisconsin Central), and Calumet Superior LLC (Calumet) are all between 15 and 30 km from Sappi, and it is likely impacts from these sources will rarely overlap with the plumes from Sappi to any significant degree.

Figure 1 Cloquet Area Sources Relative to Sappi

Figure 2 Distant Sources Relative to Sappi



For this modeling analysis, the Duluth International Airport (DLH) will be used to represent meteorological conditions at Sappi. Figure 3 shows the wind rose for DLH. The predominant wind direction is generally from the northwest. Winds from the west are also typical, which means contributions from Sappi can flow into the general areas of ME Global, Wisconsin Central, and Calumet. However, based on a SIL analysis, impacts from the proposed project are below the Significant Impact Level (SIL) beyond approximately 0.7 km from the facility. Therefore; emissions from the project will not significantly impact areas close to these sources.

The second most dominant wind direction is from the east. ME Global, Wisconsin Central, and Calumet are all generally east of the facility, therefore; emissions from these sources would travel in the general direction of Sappi.

Figure 3 Duluth International Airport Wind Rose

Figure 4 shows the topography of the area around Sappi and the distant nearby sources. ME Global, Wisconsin Central, and Calumet are all at elevations between approximately 185 m and 200 m above sea level. Sappi is at a higher elevation at approximately 354 m above sea level. It is unlikely that emissions from these sources will be able to overcome the approximately 160 m change in topography. It is more likely that the emissions will settle on the upslope side of the quickly changing terrain. As shown in Figure 4, the most rapidchange in terrain is more than 10 km from Sappi. As previously mentioned, impacts from the proposed Sappi project are below the SIL beyond 0.7 km from the facility. Therefore;



plumes of emissions from ME Global, Wisconsin Central, and Calumet are unlikely to overlap with plumes from Sappi around the Cloquet area.

Figure 4 Topography Summary

Summary

Due to the portable nature of the source, Ulland will not be modeled as a nearby source in this modeling demonstration. Based on the distance from Sappi, surface wind characteristics, and topography, plumes of emissions from ME Global, Wisconsin Central, and Calumet will not overlap with plumes from Sappi in areas where emissions from the proposed project exceed the SIL. These sources will not be included in the modeling analysis. Jarden, USG, and Specialty Minerals are close to Sappi and will likely influenceambient air concentrations near the facility. Therefore; these sources will be modeled explicitly as nearby sources in the analysis.

Technical Memo

Wenck Associates, Inc. | 1802 Wooddale Drive | Woodbury, MN 55125-2937

Toll Free 800-472-2232 Main 651-294-4580 Email [email protected] Web wenck.com -

To: Mr. Rob Schilling, Sappi Cloquet, LLC From: Jared Anderson, Wenck Associates, Inc. Charlene Becka, Wenck Associates, Inc. Date: December 20, 2016 Subject: Sappi North America Pulp and Paper Mill PM2.5 Increment Screening Analysis Sappi Cloquet, LLC (Sappi) has proposed to install a chip pre-steaming bin (EU 090) which would increase digester availability by reducing chip fill and cycle times resulting in an increased production rate of pulp, and therefore increase production of black liquor solids (BLS). The proposed project is described in more detail in the Major Air Permit Amendment Application submitted to the Minnesota Pollution Control Agency (MPCA) on October 5, 2016. Sappi was required to complete an air dispersion modeling analysis for NOx, PM10, and PM2.5 since the project is subject to Prevention of Significant Deterioration (PSD) permitting. The PSD permitting determinations must address air quality modeling and monitoring provisions in areas protected by the PSD program. Air dispersion modeling demonstrating compliance with increments or significant impact levels (SILs) can be used to determine that a source does not significantly deteriorate air quality. The air dispersion modeling analysis demonstrated that NOx and PM10 impacts were less than the SIL, and a more comprehensive, cumulative modeling analysis for PM10 or NOx was not required. The DC Circuit Court vacated and remanded the PM2.5 SIL in February 2013; however, a PM2.5 Increment Screening approach was completed in lieu of a SIL analysis as directed by MPCA via conference call between Sappi, MPCA, and Wenck Associates, Inc. (Wenck) on November 28, 2016. Details for the PM2.5 Increment Screening approach as directed by the MPCA are provided below. PM2.5 Increment Screening Approach

For the purpose of screening out of a cumulative air dispersion modeling analysis to demonstrate compliance with the National Ambient Air Quality Standards (NAAQS) and the PSD increment standards, in the past it has been acceptable to demonstrate that project impacts are below the SIL and background concentration was at least one SIL below the NAAQS. However, in the Environmental Protection Agency’s (EPA’s) most recent guidance on PM2.5 modeling, that approach was deemed unacceptable when screening out of a PM2.5 increment analysis. Figure 1 below shows the new guidance policy for screening out of PM2.5 increment modeling.

Mr. Rob Schilling PM2.5 Increment Screening Analysis Sappi Cloquet, LLC December, 2016

2

N:\Technical\1251\0044\Air Dispersion Modeling\Increment Screening\Increment Screening Memo 12 07 2016.docx

Figure 1: PM2.5 Increment Screening Approach

The minor source baseline date (MiSBD) for Carlton County (the baseline area) was set in October 2014 by the proposed increase in capacity for Sappi’s Lime Kiln. Following the flow of Figure 1, the current proposed Sappi project will proceed down the right side of the figure. Step 1 – Compare Project Impacts Directly to Increment Value

Sappi completed a project SIL analysis for 24-hour PM2.5, the project displayed modeled impacts of 0 μg/m3 or 0% of the 24-hour PM2.5 Class II increment of 9 μg/m3. The Annual SIL analysis showed modeled impacts of 0 μg/m3 or 0% of the annual PM2.5 Class II increment of 4 μg/m3. Modeled impacts from this project are well below the increment values. Step 2 – Analyze How Much Increment Has Been Consumed

Part A: Analyze How Much Increment Has Been Consumed by Major “Nearby” Source Construction Between the Major and Minor Source Baseline Dates. The first step in this process was to analyze the construction projects for Major nearby sources since the major source baseline date (MaSBD, i.e. October 21, 2010). In order to obtain an inventory of nearby sources, MPCA’s nearby source tool was used with 2011-2013 emissions inventory information to find which PSD major sources are located within a 50 kilometer (km) radius of Sappi that could produce a significant concentration gradient of PM2.5 in the vicinity of Sappi. The list of Major nearby sources that produces a significant concentration gradient of PM2.5 in the vicinity of Sappi as calculated using the MPCA Nearby Source Tool is shown in Table 1.


3


Table 1: List of All Major Nearby Sources that Produces a Significant Concentration Gradient at Sappi

Nearby Source USG Interiors, LLC Sappi Cloquet, LLC

Besides Sappi, the only major nearby source that produced a significant concentration gradient of PM2.5 in the vicinity of Sappi is USG Interiors, LLC (USG). Both USG and Sappi were issued renewed or amended permits after the MaSBD, and, therefore, both are major sources that potentially consumed PM2.5 increment since the MaSBD. While MPCA would prefer to address increment consumption and expansion through modeling changes in actual emissions, the changes in calculation methods and emission factors for PM2.5 make it very difficult to compare emissions from year to year. The only way to directly compare emissions from year to year would be to go back and apply consistent emission factors on a process by process basis. The time and resources required to complete that level of data analysis would be inconsistent with a screening approach. Therefore, while MPCA hopes to refine this screening method to use actual emissions in the future, current PM2.5 data confines this particular analysis to an analysis of potential emissions. The Sappi pulp mill modifications permitted in 2012 were subject to PSD Review. As part of this analysis, Sappi calculated the potential change in emissions on a pound per hour basis pre/post construction to determine if an Environmental Assessment Worksheet (EAW) was triggered according to Minn. R. 4410.4300 due to an increase in air emissions. The mill modification project did not involve an increase in design capacity or potential PM2.5 emissions. A summary of potential emissions of PM2.5 pre/post construction is included in Table 2. A summary of USG’s potential emissions before the MaSBD and at the time of the MiSBD are also included in Table 2. USG’s permit no. 01700006-001 issued in 2003 did not include PM2.5, so PM10 emissions were conservatively assumed to be representative of PM2.5 emissions. Permit no 01700006-002 issued on September 24, 2004, permitted a stack test extension, and did not affect potential emissions. USG’s permit was not modified again until 2012. Thus, the emissions from the 2003 permit represents potential emissions at the time of the MaSBD. Permit no. 01700006-003, issued in 2012, updated facility emissions which resulted in a decrease of PM10 emissions. The USG permit has not been modified since 2012. Therefore, USG has expanded PM2.5 increment between the MaSBD and the MiSBD.


4


Table 2: Total Facility PM2.5 Emissions Increase Since MaSBD

Source Name Pollutant

MaSBD Potential Emissions (tons/yr)

Post-MaSBD, Pre-MiSBD Potential Emissions (tons/yr)

Emissions Increase

(tons/yr)a

USG Interiors, LLC

PM10 787 329 -458

Sappi Cloquet, LLC

PM2.5 121.09 121.09 0.00

The change in potential emissions at Sappi and USG has not increased since the MaSBD. However, the amount of increment consumed cannot be determined solely on the quantity of emissions change. Increment consumption is based on concentration change which is estimated through air dispersion modeling. For this screening analysis, the concentration change would also be zero because the facility’s increase in emissions (tpy) was zero. While USG saw a decrease in emissions after the MaSBD, no credit will be taken for the decrease in emissions for this analysis and will be represented by an emission increase of zero. Therefore, based on MPCA guidance for PM2.5 Increment Screening, the increment consumption from Major “nearby” source construction between the major and minor source baseline dates is zero. Part B: Analyze How Much Increment Has Been Consumed by Any Permitted “Nearby” Source Since the Minor Source Baseline Date. The second portion of the increment consumption/expansion analysis, Part B, addresses changes since the MiSBD. As shown in Table 3, the listed nearby sources based on the MPCA’s nearby source tool for PM2.5 in the vicinity of Sappi are limited to Jarden Home Brands (Jarden) and USG.

Table 3: List of All Nearby Sources that Produces a Significant Concentration Gradient at Sappi

Nearby Source Jarden Home Brands USG Interiors, LLC Sappi Cloquet, LLC

No construction at USG has occurred since the MiSBD (October 2014). Jarden’s potential emissions at the time of the MiSBD as detailed in permit no. 01700003-004, issued August 28, 2012, are shown in Table 4. Permit no. 1700003-005 was issued on December 31, 2014 to incorporate operating limits, additional recordkeeping, revised permit language, removed outdated notifications, and updated a carbon monoxide emission factor but did not increase emissions at the facility. Therefore; neither USG nor Jarden consumed increment since the MiSBD.


5


Table 4: Total Facility PM2.5 Emissions Increase Since MiSBD

Source Name Pollutant MiSBD Potential

Emissions (tons/yr)

Current Potential Emissions (tons/yr)

Emissions Increase

(tons/yr)a

Jarden Home Brands

PM2.5 50.6 50.6 0

USG Interiors, LLC

PM10 329 329 0

The Sappi Lime Kiln project, which set the MiSBD, was permitted on April 23, 2015. The project was subject to PSD review and included an increment screening analysis. As part of the analysis, the consumption of increment by the project was evaluated. It was determined that the lime kiln expansion at Sappi consumed 0.38 µg/m3 of increment for the 24-hour averaging period and 0.03 µg/m3 of increment for the annual averaging period. This concentration increase represents Sappi’s consumption of increment since the MiSBD. Step 3 – Consider Increment Consumption/Expansion by More Distant Sources

In addition to the analysis completed in Step 2 of Major “nearby” sources outside the baseline area, Appendix W section 8.2.3 states that distant major sources are captured in monitored background. In addition, Section V.4.2.3 of EPA’s Guidance for PM2.5 Permit Modeling notes that ambient monitoring data can be used on a case by case basis as “the primary means of assessing increment consumption or expansion for PM2.5 by measuring ambient air quality on the minor source baseline date and thereafter to determine changes in air quality resulting from direct PM2.5 emissions and PM2.5 precursors.” Therefore, Step 3 of this analysis is to determine the increment consumption or expansion through an inspection of monitored background data. For this assessment, the average of the Virginia 1300, Duluth 7554, and Duluth 7550 monitors were used as they are the closest active PM2.5 monitors to the baseline area (Carlton County). The monitors for Duluth are within 14 miles of Sappi and the Virginia monitor is within 55 miles of Sappi. 24-hour and annual concentrations from MPCA’s annual air monitoring network plans for 2016 and 2017 for these monitors are included in Tables 5 and 6.

Table 5: PM2.5 24-hour (μg/m3) Monitored Concentrations Site Name

2012-2014

2013-2015

Change

Virginia (1300)

17 18 1

Duluth (7554)

17 17 0

Duluth (7550)

18 16 -2

Average 17 17 0


6


Table 6: PM2.5 Annual (μg/m3) Monitored Concentrations Site

Name 2012-2014

2013-2015

Change

Virginia (1300)

7.2 7.5 0.3

Duluth (7554)

5.9 5.9 0

Duluth (7550)

5.7 5.5 -0.2

Average 6.3 6.3 0 Monitored values in the Virginia (1300) and the Duluth (7550 and 7554) monitors show that despite some increases in emissions as a result of Sappi’s modifications, there has been no change in background concentrations over the 24-hour and annual averaging periods since the MiSBD. Conclusion

As stated in EPA’s Guidance for PM2.5 Permit Modeling, steps 1-3 as described above are being recommended by the MPCA in order to demonstrate that sufficient “headroom” exists for the new source contribution within the allowable increment. An accounting of the increment consumption based on Steps 1 and 2 is summarized in Table 7. The analysis shows that the impact from the Sappi Pulp Production Project (Step 1) does not consume any increment, and the Sappi Lime Kiln Project (Step 2) consumes a small amount of increment. Therefore, the net concentration changes of PM2.5 since the MiSBD is still well under the PSD Class II 24-hour and annual increment standards.

Table 7: Accounting of Steps 1 and 2

Contributions

24-Hour Concentration

Change (μg/m3)

Annual Concentration

Change (μg/m3)

Sappi Pulp Production Project – Step 1 0.00 0.00 Increment Consumption between MaSBD and MiSBD – Step 2a

0.00 0.00

Increment Consumption since MiSBD – Step 2b

+0.38 +0.03

Net Concentration Change +0.38 +0.03 PSD Class II Increment 9 4

In addition to accounting for increment consumers, monitored background concentrations in the project areas continue to stay the same. Therefore, the “headroom” between the net project impacts and the PSD Class II increment standards remains large. This shows that no further increment modeling should be required for the pulp production project.

Technical Memo

Wenck Associates, Inc. | 1802 Wooddale Drive | Woodbury, MN 55125-2937

Toll Free 800-472-2232 Main 651-294-4580 Email [email protected] Web wenck.com -

To: Mr. Rob Schilling, Sappi Cloquet, LLC From: Jared Anderson, Wenck Associates, Inc. Charlene Becka, Wenck Associates, Inc. Date: December 20, 2016 Subject: Hybrid Qualitative/Quantitative Assessment of the Potential for Secondary PM2.5

Formation Introduction

Particulate Matter Less than 2.5 Micrometers (PM2.5) can be emitted directly from an emission source such as a stack. However, the interaction of gaseous emissions in the atmosphere can also produce secondary formation of fine particles. These particles pose a challenge in permitting evaluations that use AERMOD (EPA’s preferred regulatory dispersion model) because the complex reactions that form these particles cannot be properly characterized with a Gaussian dispersion model that does not have a chemical module. In previous EPA guidance1 it was noted that the use of AERMOD for new source analyses was limited to modeling only the primary or direct PM2.5 emissions. Thus, secondary formation of PM2.5 was not considered in dispersion modeling evaluations. However, on January 4, 2012, the EPA committed to, as appropriate, incorporate new analytical techniques or models for secondary PM2.52. As a result, EPA released Draft Guidance for PM2.5 Permit Modeling on March 4, 2013. This draft guidance was finalized on May 20, 2014 by EPA. Section III.2.2 from this document states the following:

“To inform a hybrid/qualitative/quantitative assessment, the existing air quality model-based information would need to be appropriate in terms of representing the type of source, its precursor emissions, and its geographic location, in addition to those elements of the conceptual description discussed above for the qualitative assessment. The quantitative modeling information may be available from past or current SIP attainment demonstration modeling, published modeling studies, or peer-reviewed literature with estimates of model responsiveness to precursor emissions I context that are relevant to the new or modifying source. The estimates of model responsiveness, such as impact on PM2.5 concentrations per ton of SO2 emissions, could then be used in conjunction with the precursor emissions estimates for the proposed new or modifying source to provide a quantitative estimate of the impacts of such precursor emissions on the formation of secondary PM2.5 concentrations. The estimates should be technically credible in representing such impacts and it may be advisable for the estimate to reflect an upper bound of potential impacts. The NACAA Workgroup final report (NACAA, 2011) provides details on potential approaches to quantify the secondary PM2.5 impacts from a proposed new or

1 EPA, Modeling Procedures for Demonstrating Compliance with PM2.5 NAAQS”, March 23, 2010 2 Gina McCarthy, January 4, 2012, administrative grant of the July 28, 2012, Sierra Club petition.

Mr. Rob Schilling Qualitative Assessment of the Potential for Secondary PM2.5 Formation Sappi Cloquet, LLC December 20, 2016

2

N:\Technical\1251\0044\Air Dispersion Modeling\Protocol\Technical Memo PM25 Qualitative Assessment 12-20-16.docx

modifying source that may be appropriate to inform a hybrid qualitative/quantitative assessments of PM2.5 impacts (See Appendix C and D of NACAA, 2011).”

The evaluation described in this memorandum follows this guidance in providing a hybrid qualitative/quantitative evaluation of secondary PM2.5 emissions for the proposed project at Sappi Cloquet, LLC (Sappi) pulp and paper mill in Cloquet, Minnesota. This evaluation is based on the results presented in Appendix C of the NACAA Workgroup final report. 3

PM2.5 Monitoring Data

There are no active PM2.5 monitors in the city of Cloquet or the immediate surrounding area to use for background concentrations in an air dispersion modeling analysis. Therefore, the average from the Virginia (MPCA Site ID 1300), Duluth (MPCA Site ID 7554), and Duluth (MPCA Site ID 7550) ambient monitors was proposed as background. These data have been quality assured and quality controlled by the MPCA. The 98th percentile of the daily PM2.5 averages from these ambient monitors are 18 (1300), 17 (7554), and 16 µg/m3 (7550) for the 2013-2015 period.4 Therefore, an average value of 17 µg/m3 can be assumed to represent the background PM2.5 concentration of the Sappi facility. Since these three monitors are in the general vicinity of Cloquet, they are deemed representative for the area around Sappi. The readings from these monitors include both: primary and secondary concentrations in ambient air. Therefore, secondary PM2.5 is being included in the background concentration used for the dispersion modeling analysis. Because Sappi’s modeled impacts from the proposed project were less than the significant impact level (SIL), explicit modeling using background concentrations were not necessary. PM2.5 Modeling

The National Association of Clean Air Agencies (NACAA) presented a case study3 specific to Minnesota related to secondary PM2.5 formations. This case study used the Comprehensive Air Quality Model with Extensions (CAMx) version 5.20.1 to determine secondary formation of PM2.5. This included particulate sulfate and particulate nitrate. CAMx simulates atmospheric and surface reactions that affect the transport, chemical transformation and deposition of air pollutants and their precursors. The Minnesota case study is the only one of its kind and included emissions of SO2, NOx, ammonia, primary PM2.5 and VOC from point, mobile on road, non-road, area and biogenic sources. The scope of the case study was limited to the 24-hour averaging period since this tends to be the controlling averaging time for PM2.5 modeling evaluations. Emissions and meteorology were obtained from the Lake Michigan Air Directors Consortium (LADCO) for the year 2005, version BaseM. The evaluation included 4 cases including 3 power plants and 1 taconite mine aimed at representing different geographic locations and source dispersion parameters. Whereas

3 National Association of Clean Air Agencies. 2011. PM2.5 Modeling Implementation for Projects Subject to National Ambient Air Quality Demonstration Requirements Pursuant to New Source Review—Report from NACAA PM2.5 Modeling Implementation Workgroup, January 7, 2011, Washington, D.C. 4 Gavin, K., C. McMahon, R. Strassman. 2014. Annual Air Monitoring Network Plan for Minnesota 2015. Saint Paul, MN: Minnesota Pollution Control Agency.


3


there is not specifically a pulp and paper mill case (Table 1), these cases were chosen to reflect varying conditions across Minnesota for significant emitters of secondary PM2.5 precursors (i.e., NOx and SO2). Therefore, the range of values obtained from this case study is believed to be a conservative estimate for other industry in the state. Table 1. Potential-to-emit for four cases evaluated in the NACAA case study.

Case Case Description Emissions (tons/year)

NOx SO2 NH3 Primary

PM2.5

1

Significant emitter of NOX and SO2. Tallest stack height and good dispersion

parameters. Metropolitan location

13,273 14,954 1.8 28

2

Significantly less NOX and SO2 than Case 1. Located in the southern part of the state where there is a significant amount of

available ammonia to form ammonium sulfate and ammonium nitrate.

401 532 -- 17

3

Significant emitter of NOX and SO2. Lower stack height and potentially less

dispersion. Metropolitan location.

4,475 2,257 0.3 8

4

More equitable emissions of NOX, SO2 and primary PM2.5 emissions.

Located in the Northeastern part of the state, where there is the least amount of available

ammonia from agricultural contributions.

11,488 472 -- 356

The results from the CAMx case study are segregated by ammonium sulfate ((NH4)2SO4) and ammonium nitrate (NH4NO3), primary PM2.5 and total PM2.5 (Table 2). In all cases, the maximum 98th percentile contribution from secondary PM2.5 was between 0.057 to 1.023 µg/m3 for the 24-hour averaging period. The results also indicate that, in general, the maximum primary PM2.5 concentrations occur near the stack and the maximum secondary PM2.5 concentrations occur between 5,000 to 9,000 meters from the stack. Table 2. Primary and Secondary PM2.5 concentrations from CAMx results in µg/m3.

Case NH4NO3 (NH4)2SO4 Total

Secondary PM2.5

Primary PM2.5

Total PM2.5

1 0.002 0.207 0.209 0.006 0.216 2 0.002 0.055 0.057 0.325 0.383 3 0.000 0.248 0.248 0.028 0.276 4 0.393 0.630 1.023 6.518 7.541

In this hybrid qualitative/quantitative evaluation, the CAMx impacts were scaled linearly to provide an estimate of secondary PM2.5 formations in the form of ammonium sulfate and ammonium nitrate. This linear assumption is a worst-case scenario since reactions are limited by other compounds. Thus, a ratio was calculated to estimate the increase in ambient ammonium sulfate concentrations (µg/m3) from SO2 emissions (tpy). The same


4


calculation was performed to estimate the increase in ambient ammonium nitrate concentrations (µg/m3) from NOx emissions (tpy). For example, based on the CAMx model results, for Case 1, an increase of 0.207 µg/m3 in (NH4)2SO4 resulted from 14,954 tpy of SO2 emitted. Therefore, it is estimated that ambient (NH4)2SO4 concentrations would increase 1.384 E-05 µg/m3 for each tpy of SO2 (or 0.207 µg/m3 divided by 14,954 tpy). Table 3 depicts these ratios for each of the four cases presented. For NOx it is estimated that, for the 24-hour averaging period, an increase in ambient concentrations between 1.507 E-07 µg/m3 to 3.421 E-05 µg/m3 would result from each tpy of NOx. For SO2 it is estimated that, for the 24-hour averaging period, an increase in ambient concentrations between 1.335 E-03 µg/m3 to 1.384 E-05 µg/m3 would result from each tpy of SO2. For Case 3 the model did not show any formation of secondary PM2.5 as ammonium nitrate in spite of the 4,475 tpy of NOx emissions. However, this case was ignored since only the most conservative ratios were used in estimating the possible increase in PM2.5 from secondary formation. Table 3. Concentrations of ammonium nitrate and ammonium sulfate per tons per year of NOx and SO2.

Case NH4NO3 / NOx (µg/m3)/(tpy)

(NH4NO3)2SO4 / SO2 (µg/m3)/(tpy)

1 1.507 E-07 1.384 E-05 2 4.988 E-06 1.034 E-04 3 N/A 1.099 E-04 4 3.421 E-05 1.335 E-03

The comparison presented is conservative because secondary PM2.5 impacts associated with Sappi’s precursor emissions are expected to be low near the emission release points where modeled concentrations associated with primary PM2.5 emissions are highest. That is the case because there is not enough time in a short distance for much of the secondary chemical reactions to occur. On the other hand, secondary PM2.5 impacts are more likely to be higher farther from Sappi where impacts from primary PM2.5 emissions from the facility are expected to be lower. This makes it highly unlikely that maximum primary PM2.5 impacts and maximum secondary PM2.5 impacts from Sappi’s proposed project will occur at the same time (paired in time) and location (paired in space)5. Additionally, other than Sappi and the neighboring nearby sources that are evaluated in a PM2.5 increment screening analysis, there are no major sources of PM2.5 or PM2.5 precursors (i.e., NOx and SO2) in the vicinity. Impacts from Sappi’s Project

Sappi expects no increases in allowable SO2 or NOx emissions from the proposed pulp production project. As neither precursor is increased by the proposed project, there will not be any increase in secondary PM2.5 formations as a result regardless of the ratio used from Table 3.

5 Page 9 from EPA’s March 23, 2010 PM2.5 Guidance Memo.

Documents

Air Individual Permit Major Amendment 01700002-101 for