Hood Container Corporation has applied to the …...Hood Container Corporation has applied to the Tennessee Air Pollution Control Division (TAPCD) for an existing major source operating

PUBLIC NOTICE

Hood Container Corporation has applied to the Tennessee Air Pollution Control Division (TAPCD) for an existing major source

operating permit subject to the provisions of paragraph 1200-03-09-.02(11) of the Tennessee Air Pollution Control Regulations (also

frequently referred to as Title V regulations). A major source (Title V) operating permit is required by both the Federal Clean Air Act and

the Tennessee Air Pollution Control Regulations.

The applicant is Hood Container Corporation. with a site address of 2877 Scepter Road New Johnsonville, TN 37185. They seek to

renew their major source operating permit for their Papermill facility that produces corrigated paper

EPA has agreed to treat this draft Part 70 permit as a proposed Part 70 permit and to perform its 45-day review provided by the law

concurrently with the public notice period. If any substantive comments are received, EPA’s 45-day review period will cease to be

performed concurrently with the public notice period. EPA’s 45-day review period will start once the public notice period has

been completed and EPA receives notification from the Tennessee Air Pollution Control Division that comments have been received and

resolved. Whether EPA’s 45-day review period is performed concurrently with the public comment period or after the public comment

period has ended, the deadline for citizen’s petitions to the EPA Administrator will be determined as if EPA’s 45-day review period is

performed after the public comment period has ended (i.e., sequentially).

The status regarding EPA’s 45-day review of this project and the deadline for submitting a citizen’s petition can be found at the following

website address:

http://www2.epa.gov/caa-permitting/caa-permitting-epas-southeastern-region

A copy of the application materials used by the TAPCD and a copy of the draft permit are available for public inspection during normal

business hours at the following locations:

Humphreys County Public Library

201 Pavo Avenue

Waverly, TN 37185

931-296-2143

Ethel M. Carmical, Library Director

and

Tennessee Department of Environment and Conservation

Division of Air Pollution Control

William R. Snodgrass Tennessee Tower

312 Rosa L. Parks Avenue, 15th Floor

Nashville, TN 37243

Also, if you require a copy of the draft/proposed permit it is available electronically by accessing the Air Pollution Control Public

Participation Opportunity (APC PPO) page:

https://www.tn.gov/environment/ppo-public-participation/ppo-public-participation/ppo-air.html

Interested parties are invited to review these materials and comment. In addition, a public hearing may be requested at which written or oral

presentations may be made. To be considered, written comments or requests for a public hearing must be made within thirty (30) days of

the date of this notice and should be addressed to Michelle Walker Owenby, Director, Division of Air Pollution Control, William R.

Snodgrass Tennessee Tower, 312 Rosa L. Parks Avenue, 15th Floor, Nashville, Tennessee 37243. Questions concerning the source(s)

may be addressed to Mr. Jerry Swinea at the same address or by calling (615)-532-0639 or by emailing [email protected]. A final

determination will be made after weighing all relevant comments.

Individuals with disabilities who wish to review information maintained at the above-mentioned depositories should contact the Tennessee

Department of Environment and Conservation to discuss any auxiliary aids or services needed to facilitate such review. Such contact may

be in person, by writing, telephone, or other means, and should be made no less than ten days prior to the end of the public comment period

to allow time to provide such aid or services. Contact the Tennessee Department of Environment and Conservation ADA Coordinator,

William R. Snodgrass Tennessee Tower, 312 Rosa L. Parks Avenue 2nd Floor, Nashville, TN 37243, 1-(866)-253-5827. Hearing impaired

callers may use the Tennessee Relay Service, 1-(800)-848-0298.

-------------------------------------------------------------------------------------------------------------------------------------------------------------------------

(Do Not Publish Text Below The Dotted Line.)

http://www2.epa.gov/caa-permitting/caa-permitting-epas-southeastern-region

https://www.tn.gov/environment/ppo-public-participation/ppo-public-participation/ppo-air.html

mailto:[email protected]

For Humphreys County “News Democrat”-- publish once during the time period of March 26, 2020 through April 9, 2020

Air Pollution Control DATE: MARCH 26, 2020

Assigned to – Shawn Auth

No alterations to the above are allowed:

Hood Container Corporation. must pay to place this advertisement in the newspaper.

Air Pollution Control must be furnished with an affidavit from the newspaper stating that the ad was run and the date of the ad or one

complete sheet from the newspaper showing this advertisement, the name of the newspaper and the date of publication. Mail to Jerry

Swinea, Division of Air Pollution Control, William R. Snodgrass Tennessee Tower, 15th Floor, 312 Rosa L. Parks Avenue, Nashville,

Tennessee 37243 or send a pdf copy of this information electronically to [email protected].

T5 Permit Number 575065 DRAFT Expiration Date: XXXXX XX, 2025

ii

TITLE V PERMIT STATEMENT

Facility Name: Hood Container Corporation

City: New Johnsonville

County: Humphreys

Date Application Received: September 24, 2018

Date Application Deemed Complete: September 24, 2108

Emission Source Reference No.: 43-0010

Permit No.: 575065

INTRODUCTION

This narrative is being provided to assist the reader in understanding the content of the

attached Title V operating permit. This Title V Permit Statement is written pursuant to

Tennessee Air Pollution Control Rule 1200-03-09-.02(11)(f)1.(v). The primary purpose of

the Title V operating permit is to consolidate and identify existing state and federal

air requirements applicable to Hood Container Corporation and to provide practical

methods for determining compliance with these requirements. The following narrative is

designed to accompany the Title V Operating Permit. It initially describes the facility

receiving the permit, then the applicable requirements and their significance, and

finally the compliance status with those applicable requirements. This narrative is

intended only as an adjunct for the reviewer and has no legal standing. Any revisions

made to the permit in response to comments received during the public participation

process will be described in an addendum to this narrative.

Acronyms

PSD - Prevention of Significant Deterioration

NESHAP - National Emission Standards for Hazardous Air Pollutants

NSPS - New Source Performance Standards

MACT - Maximum Achievable Control Technology

NSR - New Source Review

GHG - Green House Gases

I. Identification Information

A. Source Description


iii

List and describe emission source(s): Processes/fuel burning operations at Hood

Container Corporation for manufacturing of corrugated paper media include:

43-0010-02: Package/backup boilers #2 & #3-Natural gas/No. 2 fuel oil, 192 MM BTU/hr

each, backup for wood refuse boiler and combustion of LVHC gases

43-0010-07: 527 MM BTU/hr boiler burning wood refuse, ammonium sulfite spent liquor,

sludge, OCC rejects, facility waste oil, natural gas/No. 2 fuel oil and

combusting LVHC gases with venturi scrubber and tray absorption scrubber

control

43-0010-08: Cooking liquor preparation with wet scrubber

43-0010-10: Paper machine and associated operations

43-0010-11: Pulp mill operations including blow tank and associated equipment:

43-0010-12: Wastewater treatment plant

43-0010-13: Secondary Fiber Recycle Pulp Mill

B. Facility Classification

1. Attainment or Non-Attainment Area Location

Area is designated as an attainment area for all criteria pollutants.

2. Company is located in a Class II area.

C. Regulatory Status

1. PSD/NSR

This facility is major source under PSD for particulate matter (PM).

2. Title V Major Source Status by Pollutant

If emitted, what is the

facility’s status?

Pollutant

Is the

pollutant

emitted?

Major Source

Status

Non-Major

Source Status

PM YES YES

PM10

SO2 YES YES

VOC YES YES

NOX YES YES

CO YES YES

Individual HAP YES YES

Total HAPs YES YES

GHG YES YES

3. MACT Standards

This facility is a major source for HAPs. This facility is subject to two final

MACT Standards.

List MACT Rule(s) if applicable:

a. Subpart S for pulp and paper industry for semi-chemical pulping processes.

b. Subpart DDDDD for industrial, commercial and institutional boilers and

process heaters


iv

c. Subpart ZZZZ for Reciprocating Internal Combustion Engine

(RICE)(insignificant sources.

4. Program Applicability

Are the following programs applicable to the facility?

PSD yes

NESHAP (yes, see above MACT standard Subpart S, Subpart DDDDD, and Subpart ZZZZ)

NSPS (yes) 40 CFR 60 Subpart D for fossil fuel-fired units when burning fossil

fuel or wood-fossil fuel mixture for wood refuse boiler (Source 07)

II. Compliance Information

A. Compliance Status

Is the facility currently in compliance with all applicable requirements?(yes)

If no, explain.

Are there any applicable requirements that will become effective during the

permit term? (no)..

III. Other Requirements

A. Emissions Trading

The facility is not involved in an emission trading program.

B. Acid Rain Requirements

This facility is not subject to any requirements in Title IV of the Clean Air

Act.

C. Prevention of Accidental Releases

This facility will report accidental releases to EPA Region IV and to the

Tennessee Division of Air Pollution Control and annually certify compliance with

their accidental release plan.

D. Greenhouse Gases (GHG)Emissions

This facility is a major source of GHG emissions

IV. Public Participation Procedures

Notification of this draft permit was mailed to the following environmental

agencies:

A. Environmental Protection Agency Region IV

B. Kentucky Department for Environmental Protection, Air Pollution Control

V. Project Description


v

Title V Operating Permit No. 560438 represents the first renewal of the initial Title

V Operating Permit No. 548424 issued May 9, 2002. The following changes

(modifications) have occurred since the initial Title V operating permit was issued.

A. Minor Modification 1 on July 18, 2011. This modification involves the repair of the

wood refuse boiler economizer and superheater sections and the installation of a

replacement attemperator with associated condensed water tank and the modification

of the paper machine by the addition of thermo-compressor heat recovery loops for

energy conservation, improvements to the threading operation for reduction of

start-up time, and adding cleaning showers to the 2nd dryer section along with

table modifications to reduce the amount of downtime in the machine

B. Administrative Amendment 2 on December 18, 2008. This Administrative Amendment

incorporates the requirements from PSD Construction Permit Number 961563P into the

Title V operating permit.

C. Significant Modification 1 on May 9, 2006. This modification involves upgrades to

the paper machine and new secondary fiber recycle pulp mill equipment. This

reflects the final PSD construction permit #958331P that was issued on April 21,

2006.

D. Administrative Amendment 1 on January 28, 2004. This administrative amendment

specifies the minimum limits for acceptable control equipment operation, which are

to recorded during daily operation of the wood refuse boiler and the cooking liquor

preparation. This is considered an administrative amendment pursuant to 1200-03-

09-.02(11)(f)4(i)(II) of Tennessee Air Pollution Control Regulations because more

frequent monitoring and reporting is required and specified. Permit conditions E5-

1 and E6-1 are the affected permit conditions. This involves the scrubbers serving

both operations.

VI. Title V Permit 560438 Addendums

A. Title V 560438 issued April 1, 2014.

B. Operational Flexibility #1 was issued April 10, 2014 to add a 600 tons per day Center Disc Thickener and accompanying equipment as part of the Secondary fiber

Recycle Pulp Mill

C. This is a minor permit modification to the Title V Permit 560438, as stated under 1200-03-09-.02(11) (f) 5 (ii) of the Tennessee Air Pollution Control Regulations.

This is not a modification under Title I of the Federal Act. The following brief

description outlines the changes/modification to the conditions are modified for

this modification. On July 16, 2015 Hood Container Corporation applied for minor

modification #1 to their Title V air Emissions Permit consisting of the following

changes to the permit. Clarify that the facility does not have to comply with the

wet electrostatic precipitator permit requirements until January 31, 2017 and shall

follow the requirements for the existing equipment until the WESP is installed.

Permit condition E5-1(MM1). Additionally the reporting of Sulfur Dioxide

Monitoring emissions data in condition E5-8(MM1)was changed from a separate

quarterly report to a part the semi annual report.


vi

Minor Modification #1 was issued on November 16, 2015.

D. Operational Flexibility #2 issued December 21, 2016 to upgrade the 160 pound steam supply line to the Paper Machine (Source ID: 43-0010-10; Facility ID: 4000P). The

scope of this project includes the addition of a larger diameter supply line, as

well as upgrading the sectional steam pressure control instrumentation.

E. Significant permit modification #1 application to the Title V Permit 560438

received February 2, 2016. This modification is to restrict the use of fuel oil

for the package boilers #2 and #3 at source 02 to periods of natural gas

curtailment.

Significant Modification #1 was issued on January 30, 2017.

F. Operational Flexibility #3 issued June 4, 2018 to allow changes proposed to the

paper machine dryer from the current maximum allowable working pressure (MAWP) of

150 psi to approximately 158 psi MAWP.

G. Operational Flexibility #4 issued August 22, 2018 to replace fuel oil burner #3 in the Refuse Boiler. The proposed changes will not affect the capacity of Refuse

Boiler or increase the Mill’s production.

H. This is a minor permit modification to the Title V Permit 560438, as stated under

1200-03-09-.02(11) (f) 5 (ii) of the Tennessee Air Pollution Control Regulations.

This is not a modification under Title I of the Federal Act. The following brief

description outlines the changes/modification to the conditions that are modified

for this modification. On September 12, 2018, Hood Container Corporation applied

for minor modification #2 to their Title V air Emissions Permit. This modification

is to add an emergency generator for a 413 horsepower (hp) River water fire pump

and a 113 hp emergency fire water pump. Condition D14 was added to the permit to

address the emergency engines. Conditions D11-D14 were added to update the permit

shell. Conditions A8, A16, B5. B6, and B10,

Title V 575065 issued XXXXX XX, 2020. No Changes.

STATE OF TENNESSEE

AIR POLLUTION CONTROL BOARD

DEPARTMENT OF ENVIRONMENT AND CONSERVATION

NASHVILLE, TENNESSEE 37243

OPERATING PERMIT (TITLE V) Issued Pursuant to Tennessee Air Quality Act This permit fulfills the requirements of Title V of the Federal Clean Air Act (42 U.S.C. 7661a-7661e) and the federal regulations

promulgated thereunder at 40 CFR Part 70. (FR Vol. 57, No. 140, Tuesday, July 21, 1992 p.32295-32312). This permit is issued in

accordance with the provisions of paragraph 1200-03-09-.02(11) of the Tennessee Air Pollution Control Regulations. The permittee has

been granted permission to operate an air contaminant source in accordance with emissions limitations and monitoring requirements set

forth herein.

Date Issued: XXXXXX XX, 2020 Permit Number: 575065

Date Expires: Issue Date +5 years – 1 day

Issued To: Installation Address: 2877 Scepter Road

Hood Container Corporation New Johnsonville


vii

Installation Description: Pulp and paper mill producing corrugated paper 43-0010-02: Package boilers #2 & #3 192 MM BTU/hr each, backup for wood refuse boiler & LVHC

43-0010-07: 527 MM BTU/hr boiler

43-0010-08: Cooking liquor preparation with wet scrubber

43-0010-10: Paper machine and associated operations

43-0010-11: Pulp mill operations and associated equipment

43-0010-12: Wastewater treatment plant

43-0010-13: Secondary Fiber Recycle Pulp Mill

Emission Source Reference No.: 43-0010

Renewal Application Due Date: Between XXXXX, 2025 and XXXX, 2025 Primary SIC: 26

Information Relied Upon:

Title V Application dated September 24, 2018.

Construction permit 961563P issued November 20, 2008

Construction permit 958331P issued April 21, 2006

_________________DRAFT_________________________

TECHNICAL SECRETARY

No Authority is Granted by this Permit to Operate, Construct, or Maintain any Installation in Violation of any Law,

Statute, Code, Ordinance, Rule, or Regulation of the State of Tennessee or any of its Political Subdivisions.

POST AT INSTALLATION ADDRESS Rev.2-13 RDA-1298

CONTENTS

SECTION A

GENERAL PERMIT CONDITIONS

A1. Definitions 1

A2. Compliance requirement 1

A3. Need to halt or reduce activity 1

A4. The permit 1

A5. Property rights 1

A6. Submittal of requested information 1 A7. Severability clause 2 A8. Fee payment 2 A9. Permit revision not required 2 A10. Inspection and entry 2

A11. Permit shield 3

A12. Permit renewal and expiration 3

A13. Reopening for cause 3


viii

A14. Permit transference 4 A15. Air pollution alert 4 A16. Construction permit required 4 A17. Notification of changes 4 A18. Schedule of compliance 5 A19. Title VI 6 A20. 112 (r) 6

SECTION B GENERAL CONDITIONS for MONITORING,

REPORTING, and ENFORCEMENT

B1. Recordkeeping 7 B2. Retention of monitoring data 7 B3. Reporting 7 B4. Certification 7

B5. Annual compliance certification 7 B6. Submission of compliance certification 8 B7. Emergency provisions 8

B8. Excess emissions reporting 8

B9. Malfunctions, startups and shutdowns - reasonable measures required 9 B10. Reserved 8 B11. Report required upon the issuance of a notice of violation for excess emissions 9

CONTENTS

SECTION C

PERMIT CHANGES

C1. Operational flexibility changes 10 C2. Section 502(b)(10) changes 10

C3. Administrative amendment 10

C4. Minor permit modifications 10

C5. Significant permit modifications 11

C6. New construction or modifications 11


ix

SECTION D

GENERAL APPLICABLE REQUIREMENTS

D1. Visible emissions 12

D2. General provisions and applicability for non-process gaseous emissions 12

D3. Non-process emission standards 12

D4. General provisions and applicability for process gaseous emissions 12

D5. Particulate emissions from process emission sources 12

D6. Sulfur dioxide emission standards 12

D7. Fugitive dust 12

D8. Open burning 13

D9. Asbestos 13

D10. Annual certification of compliance 13

D11. Emission Standards for Hazardous Air Pollutants 13

D12. Standards of Performance for New Stationary Sources 13

D13. Gasoline Dispensing Facilities 13

D14. Internal Combustion Engines 13


x

CONTENTS

SECTION E

SOURCE SPECIFIC EMISSION STANDARDS, OPERATING LIMITATIONS, and

MONITORING, RECORDKEEPING and REPORTING REQUIREMENTS

E1. Fee payment: allowable emissions basis 14

E2. Reporting requirements 16

(a) Semiannual reports

(b) Annual compliance certification

E3. General Permit Requirements 18

E4. 43-0010-02: Package/backup boilers #2 & #3 firing natural gas/No. 2 fuel oil,

192 MM BTU/hr each, backup to wood refuse boiler for producing

steam and combusting LVHC gases 25

E5. 43-0010-07: 527 MM BTU/hr boiler firing wood refuse, ammonium sulfite spent

liquor, sludge, OCC rejects, facility waste oil, natural gas/No. 2 fuel oil for

producing plant steam and combusting LVHC gases with venturi

scrubber and tray absorption scrubber control 29

E6. 43-0010-08: Cooking liquor preparation with wet scrubber 34

E7. 43-0010-10: Paper machine and associated operations 35

E8. 43-0010-11: Pulp mill including blow tank operations and associated equipment 36

E9. 43-0010-12: Wastewater treatment plant 38

E10. 43-0010-13: Secondary Fiber Recycle Pulp Mill 38

END OF PERMIT NUMBER 575065 39

ATTACHMENT 1 Opacity Matrix Decision Tree for Visible Emission Evaluation for

TVEE Method 2 and EPA Method 9, dated June 18, 1996 and

Amended September 11, 2013 4 pages

ATTACHMENT 2 The Beaufort Scale Of Wind Speed Equivalents 1 Page


1

SECTION A

GENERAL PERMIT CONDITIONS

A permit issued under the provisions of paragraph 1200-03-09-.02(11) is a permit issued pursuant to the requirements of Title V

of the Federal Act and its implementing Federal regulations promulgated at 40 CFR, Part 70.

A1. Definitions. Terms not otherwise defined in the permit shall have the meaning assigned to such terms in the referenced

regulation.

TAPCR 1200-03

A2. Compliance requirement. All terms and conditions in a permit issued pursuant to paragraph 1200-03-09-.02(11) including any

provisions designed to limit a source's potential to emit, are enforceable by the Administrator and citizens under the Federal Act.

The permittee shall comply with all conditions of its permit. Except for requirements specifically designated herein as

not being federally enforceable (State Only), non-compliance with the permit requirements is a violation of the Federal Act and

the Tennessee Air Quality Act and is grounds for enforcement action; for a permit termination, revocation and reissuance, or

modification; or for denial of a permit renewal application. Non-compliance with permit conditions specifically designated

herein as not being federally enforceable (State Only) is a violation of the Tennessee Air Quality Act and may be grounds for

these actions.

TAPCR 1200-03-09-.02(11)(e)2(i) and 1200-03-09-.02(11)(e)1(vi)(I)

A3. Need to halt or reduce activity. The need to halt or reduce activity is not a defense for noncompliance. It shall not be a

defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in

order to maintain compliance with the conditions of the permit. However, nothing in this item shall be construed as precluding

consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for noncompliance if the health,

safety or environmental impacts of halting or reducing operations would be more serious than the impacts of continuing

operations.

TAPCR 1200-03-09-.02(11)(e)1(vi)(II)

A4. The permit. The permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request

by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or

anticipated noncompliance does not stay any permit condition.

TAPCR 1200-03-09-.02(11)(e)1(vi)(III)

A5. Property rights. The permit does not convey any property rights of any sort, or any exclusive privilege.

TAPCR 1200-03-09-.02(11)(e)1(vi)(IV)

A6. Submittal of requested information. The permittee shall furnish to the Technical Secretary, within a reasonable time,

any information that the Technical Secretary may request in writing to determine whether cause exists for modifying, revoking

and reissuing, or termination of the permit or to determine compliance with the permit. Upon request, the permittee shall also

furnish to the Technical Secretary copies of records required to be kept by the permit. If the permittee claims that such

information is confidential, the Technical Secretary may review that claim and hold the information in protected status until such

time that the Board can hear any contested proceedings regarding confidentiality disputes. If the information is desired by EPA,

the permittee may mail the information directly to EPA. Any claims of confidentiality for federal purposes will be determined

by EPA.

TAPCR 1200-03-09-.02(11)(e)1(vi)(V)


2

A7. Severability clause. The requirements of this permit are severable. A dispute regarding one or more requirements of this

permit does not invalidate or otherwise excuse the permittee from their duty to comply with the remaining portion of the permit.

TAPCR 1200-03-09.02(11)(e)1(v)

A8. Fee payment. (a) The permittee shall pay an annual Title V emission fee based upon the responsible official's choice of actual emissions,

allowable emissions, or a combination of actual and allowable emissions; and on the responsible official’s choice of annual

accounting period. An emission cap of 4,000 tons per year per regulated pollutant per major source SIC Code shall apply to

actual or allowable based emission fees. A Title V annual emission fee will not be charged for emissions in excess of the cap.

Title V annual emission fees will not be charged for carbon monoxide or for greenhouse gas pollutants solely because they are

greenhouse gases.

(b) Title V sources shall pay allowable based emission fees until the beginning of the next annual accounting period

following receipt of their initial Title V operating permit. At that time, the permittee shall begin paying their Title V fee based

upon their choice of actual or allowable based fees, or mixed actual and allowable based fees. Once permitted, the Responsible

Official may revise their existing fee choice by submitting a written request to the Division no later than December 31 of the

annual accounting period for which the fee is due.

(c) When paying annual Title V emission fees, the permittee shall comply with all provisions of 1200-03-26-.02 and 1200-

03-09-.02(11) applicable to such fees.

(d) Where more than one (1) allowable emission limit is applicable to a regulated pollutant, the allowable emissions for

the regulated pollutants shall not be double counted. Major sources subject to the provisions of paragraph 1200-03-26-.02(9)

shall apportion their emissions as follows to ensure that their fees are not double counted.

1. Sources that are subject to federally promulgated hazardous air pollutant under 40 CFR 60, 61, or 63 will

place such regulated emissions in the regulated hazardous air pollutant (HAP) category.

2. A category of miscellaneous HAPs shall be used for hazardous air pollutants listed at part 1200-03-26-

.02(2)(i)12 that are not subject to federally promulgated hazardous air pollutant standards under 40 CFR 60, 61, or

63.

3. HAPs that are also in the family of volatile organic compounds, particulate matter, or PM10 shall not be

placed in either the regulated HAP category or miscellaneous HAP category.

4. Sources that are subject to a provision of chapter 1200-03-16 New Source Performance Standards (NSPS) or

chapter 0400-30-39 Standards of Performance for New Stationary Sources for pollutants that are neither particulate

matter, PM10, sulfur dioxide (SO2), volatile organic compounds (VOC), nitrogen oxides (NOx), or hazardous air

pollutants (HAPs) will place such regulated emissions in an NSPS pollutant category.

5. The regulated HAP category, the miscellaneous HAP category, and the NSPS pollutant category are each

subject to the 4,000 ton cap provisions of subparagraph 1200-03-26-.02(2)(i).

6. Major sources that wish to pay annual emission fees for PM10 on an allowable emission basis may do so if

they have a specific PM10 allowable emission standard. If a major source has a total particulate emission standard,

but wishes to pay annual emission fees on an actual PM10 emission basis, it may do so if the PM10 actual emission

levels are proven to the satisfaction of the Technical Secretary. The method to demonstrate the actual PM10 emission

levels must be made as part of the source’s major source operating permit in advance in order to exercise this option.

The PM10 emissions reported under these options shall not be subject to fees under the family of particulate

emissions. The 4,000 ton cap provisions of subparagraph 1200-03-26-.02(2)(i) shall also apply to PM10 emissions.

.

TAPCR 1200-03-26-.02 and 1200-03-09-.02(11)(e)1(vii)

A9. Permit revision not required. A permit revision will not be required under any approved economic incentives, marketable

permits, emissions trading and other similar programs or process for changes that are provided for in the permit.

TAPCR 1200-03-09-.02(11)(e)1(viii)

A10. Inspection and entry. Upon presentation of credentials and other documents as may be required by law, the permittee shall

allow the Technical Secretary or an authorized representative to perform the following for the purposes of determining

compliance with the permit applicable requirements:

(a) Enter upon, at reasonable times, the permittee's premises where a source is located or emissions-related activity is

conducted, or where records must be kept under the conditions of the permit;

(b) Have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit;


3

(c) Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment),

practices, or operations regulated or required under the permit; and

(d) As authorized by the Clean Air Act and Chapter 1200-03-10 of TAPCR, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit or applicable requirements.

(e) "Reasonable times" shall be considered to be customary business hours unless reasonable cause exists to suspect

noncompliance with the Act, Division 1200-03 or any permit issued pursuant thereto and the Technical Secretary specifically

authorizes an inspector to inspect a facility at any other time.

TAPCR 1200-03-09-.02(11)(e)3.(ii)

A11. Permit shield. (a) Compliance with the conditions of this permit shall be deemed compliance with all applicable requirements as of the

date of permit issuance, provided that:

1. Such applicable requirements are included and are specifically identified in the permit; or

2. The Technical Secretary, in acting on the permit application or revision, determines in writing that other

requirements specifically identified are not applicable to the source, and the permit includes the determination or a

concise summary thereof.

(b) Nothing in this permit shall alter or affect the following:

1. The provisions of section 303 of the Federal Act (emergency orders), including the authority of the

Administrator under that section. Similarly, the provisions of T.C.A. §68-201-109 (emergency orders) including the

authority of the Governor under the section;

2. The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the

time of permit issuance;

3. The applicable requirements of the acid rain program, consistent with section 408(a) of the Federal Act; or

4. The ability of EPA to obtain information from a source pursuant to section 114 of the Federal Act.

(c) Permit shield is granted to the permittee.

TAPCR 1200-03-09-.02(11)(e)6

A12. Permit renewal and expiration. (a) An application for permit renewal must be submitted at least 180 days, but no more than 270 days prior to the

expiration of this permit. Permit expiration terminates the source's right to operate unless a timely and complete renewal

application has been submitted.

(b) If the permittee submits a timely and complete application for permit renewal the source will not be considered to be

operating without a permit until the Technical Secretary takes final action on the permit application, except as otherwise

noted in paragraph 1200-03-09-.02(11).

(c) This permit, its shield provided in Condition A11, and its conditions will be extended and effective after its

expiration date provided that the source has submitted a timely, complete renewal application to the Technical Secretary.

TAPCR 1200-03-09-.02(11)(f)2 and 3, 1200-03-09-.02(11)(d)1(i)(III), and 1200-03-09-.02(11)(a)2

A13. Reopening for cause. (a) A permit shall be reopened and revised prior to the expiration of the permit under any of the circumstances listed

below:

1. Additional applicable requirements under the Federal Act become applicable to the sources contained in this

permit provided the permit has a remaining term of 3 or more years. Such a reopening shall be completed not later than

18 months after promulgation of the applicable requirement. No such reopening is required if the effective date of the

requirement is later than the permit expiration date of this permit, unless the original has been extended pursuant to

1200-03-09-.02(11)(a)2.

2. Additional requirements become applicable to an affected source under the acid rain program.

3. The Technical Secretary or EPA determines that the permit contains a material mistake or that inaccurate

statements were made in establishing the emissions standards or other terms or conditions of the permit.

4. The Technical Secretary or EPA determines that the permit must be revised or revoked to assure compliance

with the applicable requirements.

(b) Proceedings to reopen and issue a permit shall follow the same proceedings as apply to initial permit issuance and shall

affect only those parts of the permit for which cause to reopen exists, and not the entire permit. Such reopening shall be made as

expeditiously as practicable.


4

(c) Reopenings for cause shall not be initiated before a notice of such intent is provided to the permittee by the Technical

Secretary at least 30 days in advance of the date that the permit is to be reopened except that the Technical Secretary may

provide a shorter time period in the case of an emergency. An emergency shall be established by the criteria of T.C.A.

68-201-109 or other compelling reasons that public welfare is being adversely affected by the operation of a source that is in

compliance with its permit requirements.

(d) If the Administrator finds that cause exists to terminate, modify, or revoke and reissue a permit as identified in A13, he

is required under federal rules to notify the Technical Secretary and the permittee of such findings in writing. Upon receipt of

such notification, the Technical Secretary shall investigate the matter in order to determine if he agrees or disagrees with the

Administrator's findings. If he agrees with the Administrator's findings, the Technical Secretary shall conduct the reopening in

the following manner:


5

1. The Technical Secretary shall, within 90 days after receipt of such notification, forward to EPA a proposed

determination of termination, modification, or revocation and reissuance, as appropriate. If the Administrator grants

additional time to secure permit applications or additional information from the permittee, the Technical Secretary shall

have the additional time period added to the standard 90 day time period.

2. EPA will evaluate the Technical Secretary's proposed revisions and respond as to their evaluation.

3. If EPA agrees with the proposed revisions, the Technical Secretary shall proceed with the reopening in the

same manner prescribed under Condition A13 (b) and Condition A13 (c).

4. If the Technical Secretary disagrees with either the findings or the Administrator that a permit should be

reopened or an objection of the Administrator to a proposed revision to a permit submitted pursuant to Condition

A13(d), he shall bring the matter to the Board at its next regularly scheduled meeting for instructions as to how he

should proceed. The permittee shall be required to file a written brief expressing their position relative to the

Administrator's objection and have a responsible official present at the meeting to answer questions for the Board. If

the Board agrees that EPA is wrong in their demand for a permit revision, they shall instruct the Technical Secretary to

conform to EPA's demand, but to issue the permit under protest preserving all rights available for litigation against

EPA.

TAPCR. 1200-03-09-.02(11)(f)6 and 7.

A14. Permit transference. An administrative permit amendment allows for a change of ownership or operational control of a

source where the Technical Secretary determines that no other change in the permit is necessary, provided that the following

requirements are met:

(a) Transfer of ownership permit application is filed consistent with the provisions of 1200-03-09-.03(6), and

(b) written agreement containing a specific date for transfer of permit responsibility, coverage, and liability between the

current and new permittee has been submitted to the Technical Secretary.

TAPCR 1200-03-09-.02(11)(f)4(i)(IV) and 1200-03-09-.03(6)

A15. Air pollution alert. When the Technical Secretary has declared that an air pollution alert, an air pollution warning, or an

air pollution emergency exists, the permittee must follow the requirements for that episode level as outlined in TAPCR 1200-03-

09-.03(1) and TAPCR 1200-03-15-.03.

A16. Construction permit required. Except as exempted in TAPCR 1200-03-09-.04, or excluded in subparagraph TAPCR

1200-03-02-.01(1)(aa) or subparagraph TAPCR 1200-03-02-.01(1)(cc), this facility shall not begin the construction of a new air

contaminant source or the modification of an air contaminant source which may result in the discharge of air contaminants

without first having applied for and received from the Technical Secretary a construction permit for the construction or

modification of such air contaminant source.

TAPCR 1200-03-09-.01(1)(a)

A17. Notification of changes. The permittee shall notify the Technical Secretary 30 days prior to commencement of any of the

following changes to an air contaminant source which would not be a modification requiring a construction permit.

(a) change in air pollution control equipment

(b) change in stack height or diameter

(c) change in exit velocity of more than 25 percent or exit temperature of more than 15 percent based on absolute

temperature.

TAPCR 1200-03-09-.02(7)

A18. Schedule of compliance. The permittee will comply with any applicable requirement that becomes effective during the permit

term on a timely basis. If the permittee is not in compliance the permittee must submit a schedule for coming into compliance

which must include a schedule of remedial measure(s), including an enforceable set of deadlines for specific actions.

TAPCR 1200-03-09-.02(11)(d)3 and 40 CFR Part 70.5(c)


6

A19. Title VI. (a) The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR, Part 82,

Subpart F, except as provided for motor vehicle air conditioners (MVACs) in Subpart B:

1. Persons opening appliances for maintenance, service, repair, or disposal must comply with the required

practices pursuant to Section 82.156.

2. Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the

standards for recycling and recovery equipment pursuant to Section 82.158.

3. Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved

technician certification program pursuant to Section 82.161.

(b) If the permittee performs a service on motor (fleet) vehicles when this service involves ozone depleting substance

refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to all the applicable requirements as specified

in 40 CFR, Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners.

(c) The permittee shall be allowed to switch from any ozone-depleting substance to any alternative that is listed in the

Significant New Alternatives Program(SNAP) promulgated pursuant to 40 CFR, Part 82, Subpart G, Significant New

Alternatives Policy Program.

A20. 112 (r). Sources which are subject to the provisions of Section 112(r) of the federal Clean Air Act or any federal

regulations promulgated thereunder, shall annually certify in writing to the Technical Secretary that they are properly

following their accidental release plan. The annual certification is due in the office of the Technical Secretary no later than

January 31 of each year. Said certification will be for the preceding calendar year.

TAPCR 1200-03-32-.03(3)


7

SECTION B

GENERAL CONDITIONS for MONITORING,

REPORTING, and ENFORCEMENT

B1. Recordkeeping. Monitoring and related record keeping shall be performed in accordance with the requirements specified in

the permit conditions for each individual permit unit. In no case shall reports of any required monitoring and record keeping

be submitted less frequently than every six months.

(a) Where applicable, records of required monitoring information include the following:

1. The date, place as defined in the permit, and time of sampling or measurements;

2. The date(s) analyses were performed;

3. The company or entity that performed the analysis;

4. The analytical techniques or methods used;

5. The results of such analyses; and

6. The operating conditions as existing at the time of sampling or measurement.

(b) Digital data accumulation which utilizes valid data compression techniques shall be acceptable for compliance

determination as long as such compression does not violate an applicable requirement and its use has been approved in

advance by the Technical Secretary.

TAPCR 1200-03-09-.02(11)(e)1(iii)

B2. Retention of monitoring data. The permittee shall retain records of all required monitoring data and support information

for a period of at least 5 years from the date of the monitoring sample, measurement, report, or application. Support

information includes all calibration and maintenance records and all original strip chart recordings for continuous monitoring

instrumentation, and copies of all reports required by the permit.

TAPCR 1200-03-09-.02(11)(e)1(iii)(II)II

B3. Reporting. Reports of any required monitoring and record keeping shall be submitted to the Technical Secretary in

accordance with the frequencies specified in the permit conditions for each individual permit unit. Reports shall be submitted

within 60 days of the close of the reporting period unless otherwise noted. All instances of deviations from permit

requirements must be clearly identified in such reports. All required reports must be certified by a responsible official.

Reports required under "State only requirements" are not required to be certified by a responsible official.

TAPCR 1200-03-09-.02(11)(e)1(iii)

B4. Certification. Except for reports required under “State Only” requirements, any application form, report or compliance

certification submitted pursuant to the requirements of this permit shall contain certification by a responsible official of truth,

accuracy and completeness. This certification shall state that, based on information and belief formed after reasonable

inquiry, the statements and information in the document are true, accurate and complete.

TAPCR 1200-03-09-.02(11)(d)4

B5. Annual compliance certification. The permittee shall submit annually compliance certifications with terms and conditions

contained in Sections A, B, D and E of this permit, including emission limitations, standards, or work practices. This

compliance certification shall include all of the following (provided that the identification of applicable information may

cross-reference the permit or previous reports, as applicable):

(a) The identification of each term or condition of the permit that is the basis of the certification;

(b) The identification of the method(s) or other means used by the owner or operator for determining the compliance

status with each term and condition during the certification period; such methods and other means shall include, at a

minimum, the methods and means required by this permit. If necessary, the owner or operator also shall identify any other

material information that must be included in the certification to comply with section 113(c)(2) of the Federal Act, which

prohibits knowingly making a false certification or omitting material information;

(c) The status of compliance with the terms and conditions of the permit for the period covered by the certification,

including whether compliance during the period was continuous or intermittent. The certification shall be based on the

method or means designated in B5(b) above. The certification shall identify each deviation and take it into account in the

compliance certification. The certification shall also identify as possible exceptions to compliance any periods during which

compliance is required and in which an excursion* or exceedance** as defined below occurred; and

(d) Such other facts as the Technical Secretary may require to determine the compliance status of the source.

* “Excursion” shall mean a departure from an indicator range established for monitoring under this paragraph, consistent

with any averaging period specified for averaging the results of the monitoring.


8

** “Exceedance” shall mean a condition that is detected by monitoring that provides data in terms of an emission limitation

or standard and that indicates that emissions (or opacity) are greater than the applicable emission limitation or standard (or

less than the applicable standard in the case of a percent reduction requirement) consistent with any averaging period

specified for averaging the results of the monitoring.

40 CFR Part 70.6(c)(5)(iii) as amended in the Federal Register Vol. 79, No.144, July 28, 2014, pages 43661 through 43667

B6. Submission of compliance certification. The compliance certification shall be submitted to:

The Tennessee Department of

Environment and Conservation

Environmental Field Office specified in

Section E of this permit

and Air Enforcement Branch

US EPA Region IV

61 Forsyth Street, SW

Atlanta, Georgia 30303

TAPCR 1200-03-09-.02(11)(e)3(v)(IV)

B7. Emergency provisions. An emergency constitutes an affirmative defense to an enforcement action brought against this

source for noncompliance with a technology based emission limitation due to unavoidable increases in emissions attributable

to the emergency. An emergency shall not include noncompliance to the extent caused by improperly designed equipment,

lack of preventative maintenance, careless or improper operation, or operator error.

(a) The affirmative defense of the emergency shall be demonstrated through properly signed, contemporaneous

operating logs, or other relevant evidence that:

1. An emergency occurred and that the permittee can identify the probable cause(s) of the emergency.

"Probable" must be supported by a credible investigation into the incident that seeks to identify the causes and

results in an explanation supported by generally accepted engineering or scientific principles.

2. The permitted source was at the time being properly operated. In determining whether or not a source was

being properly operated, the Technical Secretary shall examine the source's written standard operating procedures

which were in effect at the time of the noncompliance and any other code as detailed below that would be relevant to

preventing the noncompliance. Adherence to the source's standard operating procedures will be the test of adequate

preventative maintenance, careless operation, improper operation or operator error to the extent that such adherence

would prevent noncompliance. The source's failure to follow recognized standards of practice to the extent that

adherence to such a standard would have prevented noncompliance will disqualify the source from any claim of an

emergency and an affirmative defense.

3. During the period of the emergency, the permittee took all reasonable steps to minimize levels of emissions

that exceeded the emission standards, or other requirements in the permit.

4. The permittee submitted notice of the emergency to the Technical Secretary according to the notification

criteria for malfunctions in rule 1200-03-20-.03. For the purposes of this condition, "emergency" shall be substituted

for "malfunction(s)" in rule 1200-03-20-.03 to determine the relevant notification threshold. The notice shall include

a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken.

(b) In any enforcement proceeding the permittee seeking to establish the occurrence of an emergency has the burden of

proof.

(c) The provisions of this condition are in addition to any emergency, malfunction or upset requirement

contained in Division 1200-03 or other applicable requirement.

TAPCR 1200-03-09-.02(11)(e)7

B8. Excess emissions reporting. (a) The permittee shall promptly notify the Technical Secretary when any emission source, air pollution control

equipment, or related facility breaks down in such a manner to cause the emission of air contaminants in excess of the

applicable emission standards contained in Division 1200-03 or any permit issued thereto, or of sufficient duration to cause

damage to property or public health. The permittee must provide the Technical Secretary with a statement giving all

pertinent facts, including the estimated duration of the breakdown. Violations of the visible emission standard which occur

for less than 20 minutes in one day (midnight to midnight) need not be reported. Prompt notification will be within 24 hours

of the malfunction and shall be provided by telephone to the Division's Nashville office. The Technical Secretary shall be

notified when the condition causing the failure or breakdown has been corrected. In attainment and unclassified areas if

emissions other than from sources designated as significantly impacting on a nonattainment area in excess of the standards

will not and do not occur over more than a 24-hour period (or will not recur over more than a 24-hour period) and no damage

to property and or public health is anticipated, notification is not required.

(b) Any malfunction that creates an imminent hazard to health must be reported by telephone immediately to the

Division's Nashville office at (615) 532-0554 and to the State Civil Defense.


9

(c) A log of all malfunctions, startups, and shutdowns resulting in emissions in excess of the standards in Division

1200-03 or any permit issued thereto must be kept at the plant. All information shall be entered in the log no later than

twenty-four (24) hours after the startup or shutdown is complete, or the malfunction has ceased or has been corrected. Any later

discovered corrections can be added in the log as footnotes with the reason given for the change. This log must record at least

the following:

1. Stack or emission point involved

2. Time malfunction, startup, or shutdown began and/or when first noticed

3. Type of malfunction and/or reason for shutdown

4. Time startup or shutdown was complete or time the air contaminant source returned to normal operation

5. The company employee making entry on the log must sign, date, and indicate the time of each log entry

The information under items 1. and 2. must be entered into the log by the end of the shift during which the malfunction

or startup began. For any source utilizing continuous emission(s) monitoring, continuous emission(s) monitoring collection

satisfies the above log keeping requirement.

TAPCR 1200-03-20-.03 and .04

B9. Malfunctions, startups and shutdowns - reasonable measures required. The permittee must take all reasonable

measures to keep emissions to a minimum during startups, shutdowns, and malfunctions. These measures may include

installation and use of alternate control systems, changes in operating methods or procedures, cessation of operation until the

process equipment and/or air pollution control equipment is repaired, maintaining sufficient spare parts, use of overtime labor,

use of outside consultants and contractors, and other appropriate means. Failures that are caused by poor maintenance, careless

operation or any other preventable upset condition or preventable equipment breakdown shall not be considered malfunctions.

This provision does not apply to standards found in 40 CFR, Parts 60(Standards of performance for new stationary sources),

61(National emission standards for hazardous air pollutants) and 63(National emission standards for hazardous air pollutants for

source categories).

TAPCR 1200-03-20-.02

B10. Reserved.

B11. Report required upon the issuance of a notice of violation for excess emissions. The permittee must submit within

twenty (20) days after receipt of the notice of violation, the data required below. If this data has previously been available to the

Technical Secretary prior to the issuance of the notice of violation no further action is required of the violating source.

However, if the source desires to submit additional information, then this must be submitted within the same twenty (20) day

time period. The minimum data requirements are:

(a) The identity of the stack and/or other emission point where the excess emission(s) occurred;

(b) The magnitude of the excess emissions expressed in pounds per hour and the units of the applicable emission limitation

and the operating data and calculations used in determining the magnitude of the excess emissions;

(c) The time and duration of the emissions;

(d) The nature and cause of such emissions;

(e) For malfunctions, the steps taken to correct the situation and the action taken or planned to prevent the recurrence of

such malfunctions;

(f) The steps taken to limit the excess emissions during the occurrence reported, and

(g) If applicable, documentation that the air pollution control equipment, process equipment, or processes were at all times

maintained and operated in a manner consistent with good operating practices for minimizing emissions.

Failure to submit the required report within the twenty (20) day period specified shall preclude the admissibility of the

data for determination of potential enforcement action.

TAPCR 1200-03-20-.06(2), (3) and (4)


10

SECTION C

PERMIT CHANGES

C1. Operational flexibility changes. The source may make operational flexibility changes that are not addressed or prohibited by

the permit without a permit revision subject to the following requirements:

(a) The change cannot be subject to a requirement of Title IV of the Federal Act or Chapter 1200-03-30.

(b) The change cannot be a modification under any provision of Title I of the federal Act or Division 1200-03.

(c) Each change shall meet all applicable requirements and shall not violate any existing permit term or condition.

(d) The source must provide contemporaneous written notice to the Technical Secretary and EPA of each such change,

except for changes that are below the threshold of levels that are specified in Rule 1200-03-09-.04.

(e) Each change shall be described in the notice including the date, any change in emissions, pollutants emitted, and any

applicable requirements that would apply as a result of the change.

(f) The change shall not qualify for a permit shield under the provisions of part 1200-03-09-.02(11)(e)6.

(g) The permittee shall keep a record describing the changes made at the source that result in emissions of a regulated air

pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from

those changes. The records shall be retained until the changes are incorporated into subsequently issued permits.

TAPCR 1200-03-09-.02(11)(a)4 (ii)

C2. Section 502(b)(10) changes. (a) The permittee can make certain changes without requiring a permit revision, if the changes are not modifications under

Title I of the Federal Act or Division 1200-03 and the changes do not exceed the emissions allowable under the permit. The

permittee must, however, provide the Administrator and Technical Secretary with written notification within a minimum of 7

days in advance of the proposed changes. The Technical Secretary may waive the 7 day advance notice in instances where the

source demonstrates in writing that an emergency necessitates the change. Emergency shall be demonstrated by the criteria of

TAPCR 1200-03-09-.02(11)(e)7 and in no way shall it include changes solely to take advantages of an unforeseen business

opportunity. The Technical Secretary and EPA shall attach each such notice to their copy of the relevant permit.

(b) The written notification must be signed by a facility Title V responsible official and include the following:

1. a brief description of the change within the permitted facility;

2. the date on which the change will occur;

3. a declaration and quantification of any change in emissions;

4. a declaration of any permit term or condition that is no longer applicable as a result of the change; and

5. a declaration that the requested change is not a Title I modification and will not exceed allowable emissions

under the permit.

(c) The permit shield provisions of TAPCR 1200-03-09-.02(11)(e)6 shall not apply to Section 502(b)(10) changes.

TAPCR 1200-03-09-.02(11)(a)4 (i)

C3. Administrative amendment. (a) Administrative permit amendments to this permit shall be in accordance with 1200-03-09-.02(11)(f)4. The source may

implement the changes addressed in the request for an administrative amendment immediately upon submittal of the request.

(b) The permit shield shall be extended as part of an administrative permit amendment revision consistent with the

provisions of TAPCR 1200-03-09-.02(11)(e)6 for such revisions made pursuant to item (c) of this condition which meet the

relevant requirements of TAPCR 1200-03-09-.02(11)(e), TAPCR 1200-03-09-.02(11)(f) and TAPCR 1200-03-09-.02(11)(g) for

significant permit modifications.

(c) Proceedings to review and grant administrative permit amendments shall be limited to only those parts of the permit for

which cause to amend exists, and not the entire permit.

TAPCR 1200-03-09-.02(11)(f)4

C4. Minor permit modifications. (a) The permittee may submit an application for a minor permit modification in accordance with TAPCR 1200-03-09-

.02(11)(f)5(ii).

(b) The permittee may make the change proposed in its minor permit modification immediately after an application is filed

with the Technical Secretary.

(c) Proceedings to review and modify permits shall be limited to only those parts of the permit for which cause to modify

exists, and not the entire permit.


11

(d) Minor permit modifications do not qualify for a permit shield.

TAPCR 1200-03-09-.02(11)(f)5(ii)

C5. Significant permit modifications. (a) The permittee may submit an application for a significant modification in accordance with TAPCR 1200-03-09-

.02(11)(f)5(iv).

(b) Proceedings to review and modify permits shall be limited to only those parts of the permit for which cause to modify

exists, and not the entire permit.

TAPCR 1200-03-09-.02(11)(f)5(iv)

C6. New construction or modifications. Future construction at this facility that is subject to the provisions of TAPCR 1200-03-09-.01 shall be governed by the

following:

(a) The permittee shall designate in their construction permit application the route that they desire to follow for the

purposes of incorporating the newly constructed or modified sources into their existing operating permit. The Technical

Secretary shall use that information to prepare the operating permit application submittal deadlines in their construction permit.

(b) Sources desiring the permit shield shall choose the administrative amendment route of TAPCR 1200-03-09-.02(11)(f)4

or the significant modification route of TAPCR 1200-03-09-.02(11)(f)5(iv).

(c) Sources desiring expediency instead of the permit shield shall choose the minor permit modification procedure route of

TAPCR 1200-03-09-.02(11)(f)5(ii) or group processing of minor modifications under the provisions of TAPCR 1200-03-09-

.02(11)(f)5(iii) as applicable to the magnitude of their construction.

TAPCR 1200-03-09-.02(11)(d) 1(i)(V)


12

SECTION D

GENERAL APPLICABLE REQUIREMENTS

D1. Visible emissions. With the exception of air emission sources exempt from the requirements of TAPCR

Chapter 1200-03-05 and air emission sources for which a different opacity standard is specifically provided elsewhere in this

permit, the permittee shall not cause, suffer, allow or permit discharge of a visible emission from any air contaminant source

with an opacity in excess of twenty (20) percent for an aggregate of more than five (5) minutes in any one (1)hour or more than

twenty (20) minutes in any twenty-four (24) hour period; provided, however, that for fuel burning installations with fuel burning

equipment of input capacity greater than 600 million btu per hour, the permittee shall not cause, suffer, allow, or permit

discharge of a visible emission from any fuel burning installation with an opacity in excess of twenty (20) percent (6-minute

average) except for one six minute period per one (1) hour of not more than forty (40) percent opacity. Sources constructed or

modified after July 7, 1992 shall utilize 6-minute averaging.

Consistent with the requirements of TAPCR Chapter 1200-03-20, due allowance may be made for visible emissions in

excess of that permitted under TAPCR 1200-03-05 which are necessary or unavoidable due to routine startup and shutdown

conditions. The facility shall maintain a continuous, current log of all excess visible emissions showing the time at which such

conditions began and ended and that such record shall be available to the Technical Secretary or an authorized representative

upon request.

TAPCR 1200-03-05-.01(1), TAPCR 1200-03-05-.03(6) and TAPCR 1200-03-05-.02(1)

D2. General provisions and applicability for non-process gaseous emissions. Any person constructing or otherwise

establishing a non-portable air contaminant source emitting gaseous air contaminants after April 3, 1972, or relocating an air

contaminant source more than 1.0 km from the previous position after November 6, 1988, shall install and utilize the best

equipment and technology currently available for controlling such gaseous emissions.

TAPCR 1200-03-06-.03(2)

D3. Non-process emission standards. The permittee shall not cause, suffer, allow, or permit particulate emissions from non-

process sources in excess of the standards in TAPCR 1200-03-06.

D4. General provisions and applicability for process gaseous emissions. Any person constructing or otherwise establishing an

air contaminant source emitting gaseous air contaminants after April 3, 1972, or relocating an air contaminant source more than

1.0 km from the previous position after November 6, 1988, shall install and utilize equipment and technology which is deemed

reasonable and proper by the Technical Secretary.

TAPCR 1200-03-07-.07(2)

D5. Particulate emissions from process emission sources. The permittee shall not cause, suffer, allow, or permit

particulate emissions from process sources in excess of the standards in TAPCR 1200-03-07.

D6. Sulfur dioxide emission standards. The permittee shall not cause, suffer, allow, or permit Sulfur dioxide emissions from

process and non-process sources in excess of the standards in TAPCR 1200-03-14. Regardless of the specific emission standard,

new process sources shall utilize the best available control technology as deemed appropriate by the Technical Secretary of the

Tennessee Air Pollution Control Board.

D7. Fugitive Dust. (a) The permittee shall not cause, suffer, allow, or permit any materials to be handled, transported, or stored; or a building,

its appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking reasonable precautions to

prevent particulate matter from becoming airborne. Such reasonable precautions shall include, but not be limited to, the

following:

1. Use, where possible, of water or chemicals for control of dust in demolition of existing buildings or

structures, construction operations, grading of roads, or the clearing of land;

2. Application of asphalt, water, or suitable chemicals on dirt roads, material stock piles, and other surfaces

which can create airborne dusts;


13

3. Installation and use of hoods, fans, and fabric filters to enclose and vent the handling of dusty materials.

Adequate containment methods shall be employed during sandblasting or other similar operations.

(b) The permittee shall not cause, suffer, allow, or permit fugitive dust to be emitted in such manner to exceed five (5)

minutes per hour or twenty (20) minutes per day as to produce a visible emission beyond the property line of the property on

which the emission originates, excluding malfunction of equipment as provided in Chapter 1200-03-20.

TAPCR 1200-03-08

D8. Open burning. The permittee shall comply with the TAPCR 1200-03-04 for all open burning activities at the facility.

TAPCR 1200-03-04

D9. Asbestos. Where applicable, the permittee shall comply with the requirements of TAPCR 1200-03-11-.02(2)(d) when

conducting any renovation or demolition activities at the facility.

TAPCR 1200-03-11-.02(2)(d) and 40 CFR, Part 61

D10. Annual certification of compliance. The generally applicable requirements set forth in Section D of this permit are

intended to apply to activities and sources that are not subject to source-specific applicable requirements contained in State of

Tennessee and U.S. EPA regulations. By annual certification of compliance, the permittee shall be considered to meet the

monitoring and related record keeping and reporting requirements of TAPCR 1200-03-09-.02(11)(e)1.(iii) and 1200-03-10-

.04(2)(b)1 and compliance requirements of TAPCR 1200-03-09-.02(11)(e)3.(i). The permittee shall submit compliance

certification for these conditions annually.

D11. Emission Standards for Hazardous Air Pollutants. When applicable, the permittee shall comply with the TAPCR 0400-30-

38 for all emission sources subject to a requirement contained therein.

TAPCR 0400-30-38

D12. Standards of Performance for New Stationary Sources. When applicable, the permittee shall comply with the TAPCR

0400-30-39 for all emission sources subject to a requirement contained therein.

TAPCR 0400-30-39

D13. Gasoline Dispensing Facilities. When applicable, the permittee shall comply with the TAPCR 1200-03-18-.24 for all

emission sources subject to a requirement contained therein.

D14. Internal Combustion Engines.

(a) All stationary reciprocating internal combustion engines, including engines deemed insignificant activities and insignificant

emission units, shall comply with the applicable provisions of TAPCR 0400-30-38-.01.

(b) All stationary compression ignition internal combustion engines, including engines deemed insignificant activities and

insignificant emission units, shall comply with the applicable provisions of TAPCR 0400-30-39-.01.

(c) All stationary spark ignition internal combustion engines, including engines deemed insignificant activities and insignificant

emission units, shall comply with the applicable provisions of TAPCR 0400-30-39-.02.

TAPCR 0400-30-38 and 39


14

SECTION E

SOURCE SPECIFIC EMISSION STANDARDS, OPERATING LIMITATIONS, and

MONITORING, RECORDKEEPING and REPORTING REQUIREMENTS

43-0010

Facility Description:

Neutral sulfite semi-chemical (NSSC) pulp and paper mill producing corrugated paper

medium

Conditions E1 through E3-21 apply to all sources in Section E of this permit unless otherwise noted.

E1. Fee payment

FEE EMISSIONS SUMMARY TABLE FOR MAJOR SOURCE 43-0010

REGULATED POLLUTANTS

ALLOWABLE

EMISSIONS

(tons per AAP)

ACTUAL

EMISSIONS

(tons per AAP)

COMMENTS

PARTICULATE MATTER (PM) 379.7 AEAR Includes all fee emissions.

PM10 N/A N/A Includes all fee emissions.

SO2 576.4 AEAR Includes all fee emissions.

VOC 453.5 AEAR Includes all fee emissions.

NOX 863.9 AEAR Includes all fee emissions.

CATEGORY OF MISCELLANEOUS HAZARDOUS AIR POLLUTANTS (HAPs WITHOUT A STANDARD)*

VOC FAMILY GROUP N/A AEAR Fee emissions are included in VOC above.

NON-VOC GASEOUS GROUP 1.0 AEAR List the appropriate TAPCD rule or other Standard. Fee

emissions are not included above

PM FAMILY GROUP 5.5 AEAR Fee emissions are included in PM above.

CATEGORY OF SPECIFIC HAZARDOUS AIR POLLUTANTS (HAPs WITH A STANDARD)**

VOC FAMILY GROUP N/A AEAR Fee emissions are included in VOC above.

NON-VOC GASEOUS GROUP

(HCL)

` AEAR Fee emissions are not included above.

PM FAMILY GROUP(Mercury) 0.01 AEAR Fee emissions are included in PM above.

CATEGORY OF NSPS POLLUTANTS NOT LISTED ABOVE***

EACH NSPS POLLUTANT

NOT LISTED ABOVE 12.7

3.5

AEAR Max. H2S emissions from Source 11

Max. Sulfuric Acid Mist Emissions from

Sources 02 & 07 Fee emissions are not included above.

(1) Maximum HAP emissions utilized in lieu of obtaining AEAR (actual emission analysis required)

(2) No specific allowable values for HAP emissions subject to Subpart S, designated NCG gases (LVHC) are combusted in

wood refuse boiler or package boilers.

NOTES

AAP The Annual Accounting Period (AAP) is a 12 consecutive month period that either (a) begins each July 1st and

ends June 30th

of the following year when fees are paid on a fiscal year basis, or (b) begins January 1st and ends

December 31st of the same year when paying on a calendar year basis. The Annual Accounting Period at the time

of permit renewal issuance began July 1, 2019 and ends June 30, 2020. The next Annual Accounting Period begins

July 1, 2020 and ends June 30, 2021 unless a request to change the annual accounting period is submitted by the

responsible official as required by subparagraph 1200-03-26-.02(9)(b) of the TAPCR and approved by the Technical

Secretary. If the permittee wishes to revise their annual accounting period or their annual emission fee basis as allowed

by subparagraph 1200-03-26-.02(9)(b) of the TAPCR, the responsible official must submit the request to the Division


15

in writing on or before December 31 of the annual accounting period for which the fee is due. If a change in fee basis

from allowable emissions to actual emissions for any pollutant is requested, the request from the responsible official

must include the methods that will be used to determine actual emissions. Changes in fee bases must be made using the

Title V Fee Selection form, form number APC 36 (CN-1583), included as an attachment to this permit and available on

the Division of Air Pollution Control’s website.

N/A N/A indicates that no emissions are specified for fee computation.

AEAR If the permittee is paying annual emission fees on an actual emissions basis, AEAR indicates that an Actual Emissions

Analysis is Required to determine the actual emissions of:

(1) each regulated pollutant (Particulate matter, SO2, VOC, NOX and so forth. See TAPCR 1200-03-

26-.02(2)(i) for the definition of a regulated pollutant.),

(2) each pollutant group (VOC Family, Non-VOC Gaseous, and Particulate Family),

(3) the Miscellaneous HAP Category,

(4) the Specific HAP Category, and

(5) the NSPS Category

under consideration during the Annual Accounting Period.

* Category Of Miscellaneous HAP (HAP Without A Standard): This category is made-up of hazardous air

pollutants that do not have a federal or state standard. Each HAP is classified into one of three groups, the VOC

Family group, the Non-VOC Gaseous group, or the Particulate (PM) Family group. For fee computation, the

Miscellaneous HAP Category is subject to the 4,000 ton cap provisions of subparagraph 1200-03-26-.02(2)(i) of the

TAPCR.

** Category Of Specific HAP (HAP With A Standard): This category is made-up of hazardous air pollutants

(HAP) that are subject to Federally promulgated Hazardous Air Pollutant Standards that can be imposed under Chapter

1200-03-11 or Chapter 1200-03-31. Each individual hazardous air pollutant is classified into one of three groups, the

VOC Family group, the Non-VOC Gaseous group, or the Particulate (PM) Family group. For fee computation,

each individual hazardous air pollutant of the Specific HAP Category is subject to the 4,000 ton cap provisions of

subparagraph 1200-03-26-.02(2)(i) of the TAPCR.

*** Category Of NSPS Pollutants Not Listed Above: This category is made-up of each New Source Performance

Standard (NSPS) pollutant whose emissions are not included in the PM, SO2, VOC or NOX emissions from each

source in this permit. For fee computation, each NSPS pollutant not listed above is subject to the 4,000 ton cap

provisions of subparagraph 1200-03-26-.02(2)(i) of the TAPCR.

END NOTES

The permittee shall: (1) Pay Title V annual emission fees, on the emissions and year bases requested by the

responsible official and approved by the Technical Secretary, for each annual accounting

period (AAP) by the payment deadline(s) established in TAPCR 1200-03-26-.02(9)(g).

Fees may be paid on an actual, allowable, or mixed emissions basis; and on either a

state fiscal year or a calendar year, provided the requirements of TAPCR 1200-03-26-

.02(9)(b) are met. If any part of any fee imposed under TAPCR 1200-03-26-.02 is not

paid within 15 days of the due date, penalties shall at once accrue as specified in TAPCR

1200-03-26-.02(8).

(2) Sources paying annual emissions fees on an allowable emissions basis: pay annual

allowable based emission fees for each annual accounting period no later than April 1 of

each year pursuant to TAPCR 1200-03-26-.02(9)(d).

(3) Sources paying annual emissions fees on an actual emissions basis: prepare an actual

emissions analysis for each AAP and pay actual based emission fees pursuant to

TAPCR 1200-03-26-.02(9)(d). The actual emissions analysis shall include:

(a) the completed Fee Emissions Summary Table,

(b) each actual emissions analysis required, and

(c) the actual emission records for each pollutant and each source as required for actual

emission fee determination, or a summary of the actual emission records required for

fee determination, as specified by the Technical Secretary or the Technical


16

Secretary’s representative. The summary must include sufficient information for the

Technical Secretary to determine the accuracy of the calculations. These calculations

must be based on the annual fee basis approved by the Technical Secretary (a state

fiscal year [July 1 through June 30] or a calendar year [January 1 through December

31]). These records shall be used to complete the actual emissions analyses required

by the above Fee Emissions Summary Table.

(4) Sources paying annual emissions fees on a mixed emissions basis: for all pollutants and

all sources for which the permittee has chosen an actual emissions basis, prepare an

actual emissions analysis for each AAP and pay actual based emission fees pursuant to

TAPCR 1200-03-26-.02(9)(d). The actual emissions analysis shall include:

(a) the completed Fee Emissions Summary Table,

(b) each actual emissions analysis required, and

(c) the actual emission records for each pollutant and each source as required for actual

emission fee determination, or a summary of the actual emission records required for

fee determination, as specified by the Technical Secretary or the Technical

Secretary’s representative. The summary must include sufficient information for the

Technical Secretary to determine the accuracy of the calculations. These calculations

must be based on the fee bases approved by the Technical Secretary (payment on an

actual or mixed emissions basis) and payment on a state fiscal year (July 1 through

June 30) or a calendar year (January 1 through December 31). These records shall be

used to complete the actual emissions analysis.

For all pollutants and all sources for which the permittee has chosen an allowable

emissions basis, pay allowable based emission fees pursuant to TAPCR 1200-03-26-

.02(9)(d).

(5) When paying on an actual or mixed emissions basis, submit the actual emissions

analyses at the time the fees are paid in full.

The annual emission fee due dates are specified in TAPCR 1200-03-26-.02(9)(g) and are dependent on the Responsible Official’s

choice of fee bases as described above. If any part of any fee imposed under TAPCR 1200-03-26-.02 is not paid within 15 days of the

due date, penalties shall at once accrue as specified in TAPCR 1200-03-26-.02(8). Emissions for regulated pollutants shall not be

double counted as specified in Condition A8(d) of this permit.

Payment of the fee due and the actual emissions analysis (if required) shall be submitted to The Technical Secretary at the

following address: Payment of Fee to: Actual Emissions Analyses to:

The Tennessee Department of Environment and

Conservation

Division of Fiscal Services

Consolidated Fee Section – APC 43-0010



Nashville, Tennessee 37243

and The Tennessee Department of

Environment and Conservation


Emission Inventory Program



Nashville, Tennessee 37243

or

An electronic copy (PDF) of actual emissions analysis can also

be submitted to: [email protected]

E2. Reporting requirements.

(a) Semiannual reports. Semiannual reports shall cover the six-month periods from October 1st to March 31st

and April 1st to September 30th and shall be submitted within 60 days after the end of each six-month period. Subsequent reports shall be submitted within 60 days after the end of each 6-month period following the first report. The first semiannual report following issuance of this permit shall cover the following permits and reporting periods:

Permit Number Reporting Period Begins Reporting Period Ends

560438 October 1, 2019 day before new permit issuance 575065

575065 Issuance Date of new permit (with year) end of SAR period (with year)



17

These semiannual reports shall include:

(1) Any monitoring and recordkeeping required by Conditions and associated Logs as follows: Log 2 of E3-5,

E3-11, E3-12, Log 3 of E4-4, Log 4 of E5-1, Log 5 of E5-2, Log 6 of E5-12, Log 7 of E6-1, E7-3, E8-4,

E10-1 and the report required by Condition E5-8 of this permit. However, a summary report of this

data is acceptable provided there is sufficient information to enable the Technical Secretary to evaluate

compliance.

(2) The visible emission evaluation readings from condition E4-3, E5-4, E6-2, E7-2, E8-2, and E10-3 of this

permit if required. However, a summary report of this data is acceptable provided there is sufficient

information to enable the Technical Secretary to evaluate compliance.

(3) Identification of all instances of deviations from ALL PERMIT REQUIREMENTS.

These reports must be certified by a responsible official consistent with condition B4 of this permit and shall be

submitted to The Technical Secretary at the address in Condition E2(b) of this permit.

TAPCR 1200-03-09-.02(11)(e)1.(iii)

(b) Annual compliance certification. The permittee shall submit annually compliance certifications with each term or

condition contained in Sections A, B, D and E of this permit, including emission limitations, standards, or work

practices. This compliance certification shall include all of the following (provided that the identification of

applicable information may cross-reference the permit or previous reports, as applicable):

(1) The identification of each term or condition of the permit that is the basis of the certification;

(2) The identification of the method(s) or other means used by the owner or operator for determining the

compliance status with each term and condition during the certification period; Such methods and other

means shall include, at a minimum, the methods and means required by this permit. If necessary, the owner

or operator also shall identify any other material information that must be included in the certification to

comply with section 113(c)(2) of the Federal Act, which prohibits knowingly making a false certification or

omitting material information;

(3) The status of compliance with each term or condition of the permit for the period covered by the certification,

including whether compliance during the period was continuous or intermittent. The certification shall be

based on the method or means designated in E2(b)2 above. The certification shall identify each deviation and

take it into account in the compliance certification. The certification shall also identify as possible exceptions

to compliance any periods during which compliance is required and in which an excursion* or exceedance**

as defined below occurred; and (4) Such other facts as the Technical Secretary may require to determine the compliance status of the source.

* “Excursion” shall mean a departure from an indicator range established for monitoring under this paragraph, consistent

with any averaging period specified for averaging the results of the monitoring.

** “Exceedance” shall mean a condition that is detected by monitoring that provides data in terms of an emission limitation

or standard and that indicates that emissions (or opacity) are greater than the applicable emission limitation or standard (or

less than the applicable standard in the case of a percent reduction requirement) consistent with any averaging period

specified for averaging the results of the monitoring.

Annual compliance certifications shall cover the 12-month period from October 1st to September 30th and shall be submitted within 60 days after the end of each 12-month period. The first annual compliance certification following issuance of this permit shall cover the following permits and reporting periods:

Permit Number Reporting Period Begins Reporting Period Ends

560438 October 1, 2019 day before new permit issuance 575065

575065 Issuance Date of new permit 575065 end of ACC period (2020)

These certifications shall be submitted to: TN APCD and EPA


18


Nashville Environmental Field Office

711 R.S. Gass Blvd

Nashville, TN 37216

or

[email protected]

and Air Enforcement Branch

US EPA Region IV


Atlanta, Georgia 30303

40 CFR Part 70.6(c)(5)(iii) as amended in the Federal Register Vol. 79, No.144, July 28, 2014, pages 43661 through 43667

TAPCR 1200-03-09-.02(11)(e)3.(v)

(c) Retention of Records All records required by any condition in Section E of this permit must be retained for a

period of not less than five years. Additionally, these records shall be kept available for inspection by the Technical

Secretary or a Division representative.

TAPCR 1200-03-09-.02(11)(e)1.(iii)(II)II

Note:

Public Notices, Draft or Proposed Title V Permits

When you are sending Public Notices, or Draft or Proposed Title V permits to EPA, the notification letter shall be addressed as

follows:

Heather Ceron, Chief

Air Permitting Section

ATTN: Operating Permit Program

US EPA Region IV


Atlanta, GA 30303

However, the e-mail notifications to EPA which actually contain the letter and draft permit shall be sent to [email protected].

E3. General Permit Requirements.

E3-1. Monthly logs of maintenance and/or repair for each designated air pollution control device shall be kept. This includes the

venturi scrubber and tray absorption scrubber which both serve the wood refuse boiler, the cooking liquor scrubber, and the

LVHC system. The logs shall denote what maintenance and what repair was done, when it was done, by whom, and when

problems were rectified denoting date accomplished. Each log must be made available upon request by the Technical

Secretary or his representative. Such logs must be maintained during term of the Title V permit except for the LVHC system

which must be maintained for 5 years. Records from these logs are not required to be submitted semiannually except for the

LVHC system.

TAPCR 1200-03-09-.02(11)(e)1.(iii)

Compliance Method: Included with the requirement.

E3-2. This facility is subject to 40 CFR 63 Subpart S, a NESHAP (MACT) requirement affecting the pulp and paper industry. The

facility is considered a semi-chemical pulp and paper plant which processes wood and old corrugated containers (OCC)/recycled

corrugated paper resulting in a corrugating paper medium as a final product. The applicable rule affects certain Kraft, soda,

sulfite, or semi-chemical pulping processes using wood as stipulated in 63.440(a)(1). The facility has chosen to comply with the

applicable (EPA Cluster Rule) standards contained in the rule by venting HAP emissions to a low volume high concentration

(LVHC) gas system into the wood refuse boiler or into one of two package boilers for combustion. The LVHC system collects

and routes gases from various operations/equipment including a blow tank and digester relief from the NSSC pulp mill and boil-

out tank, evaporator hot well, and water reclaim tank from the black liquor tank. The gases are routed through a closed-vent

system consisting of hard-case piping to either the wood refuse boiler or to one of the package boilers.



19

The thermal oxidation of the non-condensable gases (NCG) in the wood refuse boiler or in one of two package/backup

boilers (secondary backup system) constitutes a Pollution Prevention Project in the context of the EPA memorandum from

Mr. John S. Seitz dated July 1, 1994.

The applicable rules that pertain to this facility under Subpart S with which the facility must comply, include, but are not limited

to, the following:

Rule/federal citation Requirement/explanation

1. 63.440(a)(1) Applicability to semi-chemical pulping processes using wood

2. 63.443(b)(1) Total HAP emissions from existing affected equipment/sources to be controlled for LVHC

system

3. 63.443(c) Equipment to be enclosed and routed through a closed-vent system

4. 63.443(d)(4) Control device to reduce total HAP emissions using a boiler by introducing HAP emission

stream with the primary fuel or into flame zone of the boiler

5. 63.443(e)(1) Excess emissions for LVHC systems do not result if excess emission time divided by the total

process operating time during a semi-annual period is less than or equal to 1%.

6 63.450(a) Standards for enclosures and closed-vent systems

7. 63.450(b) Negative pressure to be maintained on enclosures and hoods at all times except for sampling,

inspection, maintenance, and repairs

8. 63.450(d) Bypass venting for closed-vent systems

9. 63.450(d)(1) Installation of a flow indicator to show the presence of a gas stream flow in the bypass line

every 15 minutes

10. 63.453(k)(2) Visible inspections of possible defects in closed-vent systems every 30 days

11. 63.453(k)(3) Positive pressure closed-vent systems to be visibly checked initially and annually

12. 63.453(k)(6) If defects are found or leaks noted per (k)(2) or (k)(3) or instrument readings indicate 500 PPM

above background, then corrective action to be taken.

13. 63.453(k)(6)(i) Closed-vent repairs/corrections to be attempted within 5 calendar days after problem is noted

14. 63.453(k)(6)(ii) Repairs/corrective action to be completed within 15 days after problem is noted. Delay is

allowed if technically not feasible without a process shutdown or other specified reasons.

15. 63.454(a) General recordkeeping under 63.10 of Subpart A and records under 63.453

16. 63.454(b) Site specific inspection plan with schematics of affected equipment and inspection records

17. 63.1 Reporting pursuant to Subpart A General Provisions; 63.6 - O & M related to startup, shutdown,

and malfunction; 63.7 - performance testing requirements; 63.9 - notification of testing and

source compliance; 63.10 - recordkeeping and reporting and associated reports

Construction permit 961563P issued November 20, 2008

Compliance Method: The permittee shall comply with applicable sections and requirements listed above for Subpart S

as stipulated for each rule or section. The method of compliance utilized by the permittee is capturing and routing LVHC

gases from designated equipment/operations per 63.443(c) into a control device (boiler) for thermal oxidation per

63.443(d)(4). The closed-vent system using sealed tank venting meet the applicable requirements of 63.450. A report of the

compliance status and findings shall be submitted semiannually. Logs and records pertaining to Subpart S shall be kept on

site and shall be made available upon request by the Technical Secretary or his representative and shall be retained for a

period of not less than five years unless otherwise noted. This pertains to the wood refuse boiler (Source 07) and package

boilers (Source 02) when routing and combusting NCG gases from the LVHC system.

The following log (Log 1) shall be kept to denote the times when the LVHC system is vented directly to the atmosphere

uncontrolled due to malfunction and what boiler unit(s) shall be used to combust the NCG gas stream along with the reason

for the malfunction. It shall also be used to calculate the total amount of time vented in the semi-annual period for

comparison to the 1% of operational time allowed. Records of Log 1 shall be kept and shall be submitted semiannually in

accordance with Condition E2(a)(4).

LOG 1

LOG OF LVHC SYSTEM MALFUNCTION PERIODS & SUBPART S ACTIONS

Month ________ Year _________


20

Date Boiler

being Utilized

to Combust

NCG Gases

Time Period

Non-

Operational

Reason for

Malfunction

Steps Taken to

Minimize Emissions

During Malfunction

Steps Taken to Prevent

Recurrence of This

Malfunction

E3-3. Logs and records specified in this permit shall be made available upon request by the Technical Secretary or his

representative and shall be retained for a period of not less than five years unless otherwise noted. Maintenance logs other

than Subpart S must be kept during the term of the Title V permit. These logs or records may or may not be required to be

submitted semiannually. Each respective permit condition requiring logs or records will specify whether semiannual

reporting is required.

E3-4. Reasonable precautions must be taken to prevent the generation of fugitive dust.

TAPCR 1200-03-08-.01

Compliance Method: Compliance shall be assured by measures already in place. If valid complaints result, fugitive dust

from this site shall not produce visible emissions beyond the property line for more than five (5) minutes per hour or twenty

(20) minutes per day as determined by Tennessee Visible Emissions Evaluation Method 4.

E3-5. Open burning, as listed below, may be conducted subject to specified limitations. This grant of exception shall in no way

relieve the person responsible for such burning from the consequences, damages, injuries, or claims resulting from such

burning.

TAPCR 1200-03-04

(a) Material for open burning includes vegetation grown on the property of the burn site; manufactured lumber products not

chemically treated to prevent insect or rot damage, such as plywood, fiberboard, and paneling, uncoated paper and uncoated

cardboard; and paper items including roll cores and non-plastic packing material.

Compliance Method: A log (Log 2) listing the specific materials that are open burned and time periods of burning shall

be kept during each day of open burning. Only those materials listed above may be burned at this location. Records of Log

2 shall be kept in accordance with Condition E3-3 and shall be submitted semiannually in accordance Condition E2(a)(1).

LOG 2

MONTHLY OPEN BURNING LOG

Month ________ Year ________

Date

Time at Beginning

of Open Burn(s)

(x:xx AM/PM)

Time at Ending of

Open Burn(s)

(x:xx AM/PM)

Specific Material Combusted Person making log

entry


21

(b) The open burning of materials, handling and disposal of ash and other waste generated from this burning process must be

conducted in accordance with all applicable Tennessee Division of Solid Waste Management regulations.

(c) Open burning may be conducted five (5) days per week and may commence no earlier than 9:00 AM and no later than

2:00 PM. If, in an emergency situation, open burning must be conducted outside these hours, verbal notification must be

made to Air Pollution Control staff in the Nashville Environmental Assistance Center on the next work day.

(d) The open burning site must be located at least one-half mile from any airport, hospital, nursing home, school, Interstate,

US or State highway(s), national reservation, national or state park, wildlife area, national or state forest, and/or residence not

on the same property as the open burning site, and shall be operated in such fashion as to assure no impairment of highway

visibility. In addition, the site must be at least five hundred feet from any registered sanitary landfill or other land disposal

sites for combustible solid waste or other similar facility. The person responsible for such burning must certify compliance

with the distance requirements by written statement. The certification must include the types and amounts of materials

projected to be burned, and must be delivered to the Division of Air Pollution Control at the appropriate regional

Environmental Field Office at least ten working days prior to commencing the burn.

(e) No burning shall be conducted on days when the wind velocity is above twenty miles per hour, described as “Fresh” on

the Beaufort Wind Scale. Refer to Attachment 2.

(f) All materials to be burned must be in a state to sustain good combustion. Burning must be conducted when ambient

conditions are such that good dispersion of combustion products will result. No open burning will be conducted on a day

when the Tennessee Division of Air Pollution Control has declared an Air Pollution Emergency Episode.

(g) Fugitive dust from the open burning site shall not produce visible emissions beyond the property line for more than five

minutes per hour or twenty minutes per day as determined by Tennessee Visible Emissions Evaluation Method 4.

(h) If valid complaints are received by Division staff because of dust generated from roadways and parking areas, visible

emissions from roads and parking lots associated with operation of this open burning site shall meet ten percent (10%)

opacity as determined by Tennessee Visible Emissions Evaluation Method 1.

(i) Any exception to the open burning prohibition granted by this Rule Chapter does not relieve any person of the responsibility

to obtain a permit required by any other agency, or of complying with other applicable requirements, ordinances, or

restrictions.

(j) Materials strictly prohibited from being burned at this site shall include, but are not limited to:

1. Municipal waste and the waste resulting from the processing, storage, serving or consumption of food,

2. Tires,

3. Automobile batteries,

4. Asphalt shingles and roll roofing material,

5. Household furniture, appliances and store fixtures,

6. Wood that has been treated with or is contaminated with pentachlorophenol (PCP),

7. Waste paint and solvents,

8. Rubber, polystyrene, urea formaldehyde, styrofoam, electrical wire coatings and polyvinyl chloride,

9. Asbestos-containing materials, and

10. Other materials identified by the Technical Secretary because they generate noxious or toxic fumes or because

the products of combustion adversely affect public health and welfare

E3-6. For the purposes of calculating sulfur dioxide emissions based on PPM measured, the following formula based on the 40 CFR

(Code of Federal Regulations) Part 60.45 shall be used. This is based on pollutant concentration calculations where the one-hour

concentration is multiplied by 2.59 x 10-9

M lbs/dscf per PPM, where M is the molecular weight, (64.07 for SO2) at 680 F.

SO2 in lbs/hr = 0.165315 x 10-6

/PPM x DSCF/min x 60 min/hr x Actual PPM SO2 where DSCF is at 700 F

E3-7. This facility is subject to 40 CFR 63 Subpart DDDDD, a NESHAP (MACT) requirement affecting Industrial, Commercial, and

Institutional Boilers and Process Heaters because the permittee is a major source of HAP emissions and has three boilers on

site that produce steam for the mill operation. 40 CFR 63 Subpart DDDDD Industrial Boiler MACT applies to the operational

boiler (43-0010-07) and the two package boilers (43-0010-02).


22

E3-8. Pursuant to 40 CFR §63.7550, the permittee must submit semiannual, annual, biennial, or 5-year, 40 CFR 63, Subpart DDDDD

compliance reports, whichever is applicable. The compliance reports must contain the information required in (a) through (e)

below:

(a) Company and Facility name and address.

(b) Process unit information, emissions limitations, and operating parameter limitations.

(c) Date of report and beginning and ending dates of the reporting period.

(d) The total operating time during the reporting period.

(e) Information as specified in section 40 CFR 63.7550 (c) for the reporting period

Compliance Method: Upon review and approval of the Notification of Compliance Status for 40 CFR 63 Subpart DDDDD,

NESHAP for Major Source Industrial, Commercial, and Institutional Boilers and Process Heaters, the semiannual reporting

requirements will be incorporated using the applicable procedures in Condition C4 (Minor Permit Modifications) of this permit.

E3-9. Pursuant to 40 CFR §63.7555 and §63.7560, the permittee must keep the following records pertaining to 40 CFR 63, Subpart

DDDDD in a form suitable and readily available for expeditious review, according to §63.10(b)(1). The permittee must keep

each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record.

Each record must be kept on site, or they must be accessible from on site (for example, through a computer network), for at least

2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record, according to §

63.10(b)(1). Records may be kept off site for the remaining 3 years.

(a) A copy of each notification and report submitted to comply with subpart DDDDD, including all

documentation supporting any Initial Notification or Notification of Compliance Status or compliance report submitted,

according to the requirements in § 63.10(b)(2)(xiv). (b) Records of performance tests, fuel analyses, or other

compliance demonstrations and performance evaluations as required in § 63.10(b)(2)(viii).

(c) If the permittee operates a unit in the unit designed to burn gas 1 subcategory, and an alternative fuel other

than natural gas, refinery gas, gaseous fuel subject to another subpart under part 63, other gas 1 fuel, or gaseous fuel

subject to another subpart of part 63 or part 60, 61, or 65, is used, the permittee must keep records of the total hours per

calendar year that alternative fuel is burned and the total hours per calendar year that the unit operated during periods of

gas curtailment or gas supply emergencies.

(d) Records of the calendar date, time, occurrence and duration of each startup and shutdown.

(e) Records of the type(s) and amount(s) of fuels used during each startup and shutdown.


E3-10. The Notice of Compliance Status must address any applicable rules that pertain to this facility under Subpart DDDDD with

which the permittee must comply, which may include, but are not limited to, the following:


63.7500 Work practice standards

63.7505 General requirements including

63.7510 Fuel analysis for each type of fuel burned

63.7515 Annual performance tests

63.7520 Stack tests and procedures

63.7525(h) Operation of ESP

63.7530 Demonstration of initial compliance with emissions limits, fuel specifications, and work

practice standards as appropriate

63.7535 Data will be collected and monitored as required

63.7540 Compliance demonstrations

63.7541 Emissions Averaging

63.7545

63.7550 Submit annual, or 5-year, 40 CFR 63, Subpart DDDDD compliance reports. Tracking of

amount and types of fuel burned in boilers as appropriate

63.7555 and 63.7560 Record keeping

Table 2 Items 1, 7, 14, and 15

Table 3 Items 3, 4, 5, and 6

Table 4 Item 4 for electrostatic precipitator beginning no later than January 31, 216, and Items 7-10 if


23


these methods are used to prove compliance with emissions limits by fuel analysis or

performance testing.

Table 5 Items 3 and 4 if using performance test to demonstrate compliance with HCl and Mercury

limits

Table 6 Items 1 and 2 if using fuel analysis to demonstrate compliance with Mercury and HCl limits

Table 9 Reporting requirements

Table 10 Applicability of General Provisions to Subpart DDDDD


E3-11. Fuel oil combusted shall not exceed 8.23 million gallons during any 12 consecutive months. This limitation was set as part of a

PSD review. This is a facility-wide limitation.

TAPCR 1200-03-09-.01(4) and construction permit number 961563P issued November 20, 2008

Compliance Method: A log of onsite fuel oil usage, in gallons per month (backup boilers), gallons per month (wood refuse

boiler), and gallons per 12 consecutive months (all boilers), must be maintained at the source location and kept available for

inspection by the Technical Secretary or his representative. The logs required by this condition shall be used to certify

compliance with this condition and in the requirements of Condition E2. This log must be retained for a period of not less than

five years. Reports and certifications shall be submitted semiannually in accordance with Condition E2(a)(1) of this permit.

E3-12. Fuel oil combusted onsite for purposes of generating process steam shall not have a sulfur content in excess of 0.05%. This

limitation was set as part of a PSD review.

TAPCR 1200-03-09-.01(4) and construction permit number 961563P issued November 20, 2008

Compliance Method: Compliance with this limitation shall be assured through vendor’s certification of sulfur content.

The logs required by this condition shall be used to certify compliance with this condition and in the requirements of

Condition E2. The permittee shall use vendor’s certification for the sulfur content for each shipment of fuel oil or

alternatively, the vendor may supply a statement effectively that all No. 2 fuel oil will contain no more than 0.05% sulfur by

weight. The logs must be maintained on site and made readily available for a period of not less than five years. Reports and

certifications shall be submitted semiannually in accordance with Condition E2(a)(1) of this permit.

E3-13. Regarding recordkeeping of logs, the following is applicable:

a. For sources required to maintain monthly logs:

All data, including all required calculations, must be entered in the log no later than 30 days from the end of the month for

which the data is required.

b. For sources required to maintain weekly logs:

All data, including all required calculations, must be entered in the log no later than 7 days from the end of the week for

which the data is required.

c. For sources required to maintain daily logs:

All data, including all required calculations, must be entered in the log no later than 7 days from the end of the day for which

the data is required.

TAPCR 1200-03-09

Compliance Method: Maintain record keeping schedule as required.

E3-14. This facility is not subject to 40 CFR 60 Subpart DDDD, a NSPS requirement affecting Commercial, Industrial, Solid Waste

incineration because the permittee’s mill does not conduct solid waste incineration. The Refuse Boiler (43-0010-07) burns

wood, fuel oil, gas, black liquor, and pulping residuals including OCC. Black liquor is a by-product of the mill and is either

sold as ligno-sulfate or burned in the Refuse Boiler for its heating value. The black liquor is never discarded and therefore

never meets the definition of a solid waste. Pulping residuals falls under the exclusion found in 40 CFR 241.4(a)4 for pulp

and paper sludges that are not discarded and are burned on-site for their heating value. Records will be kept to document that

the material is listed as a non-waste under 40 CFR 241.4.

40 CFR 60.2500


24

E3-15. In accordance with Section 112(r) of the Clean Air Act and 1200-03-32-.03(1) of Tennessee Air Pollution Control

Regulations, this facility is required to file a copy of its accidental release plan with both EPA Region IV and the Tennessee

Division of Air Pollution Control. The permittee shall annually certify in writing to the Technical Secretary that they are

properly following their accidental release plan. Such certification is due no later than January 31 for the preceding calendar

year in accordance with 1200-03-32-.03(3) of TAPCR.

E3-16. All air pollution control devices shall be operating when the equipment served by the devices are in operation. Upon the

malfunction/failure of any emission control device(s) serving a particular source, the operation of the process(es) served by

the device(s) shall be regulated by Chapter 1200-03-20 of the Tennessee Air Pollution Control Regulations. This also applies

to any excess emissions due to start-up and shutdowns.

TAPCR 1200-03-20

Compliance Method: Following the requirements as identified in TAPCR 1200-03-20.

E3-17. Unless otherwise specified, visible emissions from any stack at this facility shall not exhibit greater than twenty percent (20%)

opacity, except for one six-minute period in any one hour period, and for no more than four six-minute periods in any twenty-

four hour period. Visible emissions from this source shall be determined by EPA Method 9, as published in the current 40

CFR 60, Appendix A (six-minute average).

TAPCR 1200-03-05-.03(6) and TAPCR 1200-03-05-.01(1)

Compliance Method: The permittee shall assure compliance with the opacity standard by utilizing the opacity matrix dated

June 18, 1996, and amended September 11, 2013, using EPA Method 9 that is enclosed as Attachment 1.

If the magnitude and frequency of excursions reported by the permittee in the periodic monitoring for emissions is

unsatisfactory to the Technical Secretary, this permit may be reopened to impose additional opacity monitoring requirements.

E3-18. CAM Plan. This facility is not currently subject to regulations under 40 CFR Part 64 (Compliance Assurance Monitoring).

E3-19. This Title V Operating Permit No. 575065 represents the second renewal of the initial Title V Permit No. 548424 issued May

9, 2002, and all subsequent revisions since the initial Title V permit was issued.

Compliance Method: None.

E3-20 Identification of Responsible Official (RO), Technical Contact, and Billing Contact.

(a) The application that was utilized in the preparation of this permit is dated September 24, 2018, and was signed by

Jimmy Gibson, Mill Manager indicates he would serve as the RO. If this person terminates his/her employment or is

assigned different duties such that he/she is no longer a Responsible Official for this facility as defined in part 1200-03-

09-.02(11)(b)21 of the Tennessee Air Pollution Control Regulations, the owner or operator of this air contaminant

source shall notify the Technical Secretary of the change. Said notification must be in writing and must be submitted

within thirty days of the change. The notification shall include the name and title of the new Responsible Official and

certification of truth and accuracy. All representations, agreement to terms and conditions, and covenants made by the

former Responsible Official that were used in the establishment of the permit terms and conditions will continue to be

binding on the facility until such time that a revision to this permit is obtained that would change said representations,

agreements, and/or covenants.

(b) The application that was utilized in the preparation of this permit is dated September 24, 2018, and was signed by

Jimmy Gibson, Mill Manager indicates that Mike Goodman, Environmental Manager would serve as the Principal

Technical Contact for the permitted facility. If this person terminates his/her employment or is assigned different duties

such that he/she is no longer the Principal Technical Contact for this facility, the owner or operator of this air

contaminant source shall notify the Technical Secretary of the change. Said notification must be in writing and must be

submitted within thirty days of the change. The notification shall include the name and title of the new Principal

Technical Contact and certification of truth and accuracy.

(c) The application that was utilized in the preparation of this permit is dated September 24, 2018, and was signed by

Jimmy Gibson, Mill Manager identifies Mike Goodman, Environmental Manager as the Billing Contact for the

permitted facility. If this person terminates his/her employment or is assigned different duties such that he/she is no

longer the Billing Contact for this facility, the owner or operator of this air contaminant source shall notify the


25

Technical Secretary of the change. Said notification must be in writing and must be submitted within thirty days of the

change. The notification shall include the name and title of the new Billing Contact and certification of truth and

accuracy.

E3-21.(SM1) MACT and NSPS semiannual and annual reporting periods shall be synchronized with the semiannual and annual

reporting periods for this Title V permit. The semiannual reporting periods of April-September and October-March and the

annual reporting period of October-September have been established and are stipulated in Conditions E2(a) and E2(b). The

MACT and NSPS reports shall be submitted within 60 days after each 6-month period ends. Unless otherwise noted, the

MACT and NSPS reports shall be submitted within 60 days after each 6-month period ends.

All MACT and NSPS reports must be certified by a responsible official consistent with condition B4 of this permit

and shall be submitted to: The Technical Secretary, Tennessee Division of Air Pollution Control, 312 Rosa L. Parks

Avenue, 15TH

Floor, Nashville, TN 37243 or electronic copy via email: [email protected]

43-0010-02 Two backup boilers to the wood

refuse boiler for producing steam

and secondary backup for

combusting the NCG stream

from a LVHC system, fired with

natural gas/no. 2 fuel oil

Package boilers #2 and #3 serve as backup boilers to the wood refuse boiler.

They produce plant steam and also serve as secondary backup boilers for

combusting NCG gases and are rated at 192 MM BTU/hr each. The NCG gas

stream from various operations/emission points are routed in the LVHC system

via hard case piping for incineration in the boiler unit used. This source is

subject to MACT 40 CFR 63 Subpart S and Subpart DDDDD and is non-NSPS.

Conditions E4-1 through E4-12 apply to source 43-0010-02

E4-1. Sulfur dioxide emitted from Source 02 shall not exceed 0.51 pounds per million BTU heat input to the fuel burning installation

(195.84 lb/hr, totaled from both boilers) and shall not exceed 29.21 tons totaled from both boilers during all intervals of twelve

consecutive months. The 29.21 tons during all intervals of twelve consecutive months limitation was set as part of a PSD

review. This total includes emissions from the combined combustion of primary fuel(s) and the NCG fuel.

TAPCR 1200-03-19-.14(1)(b)(5), 1200-03-09-.01(4), and construction permit 958331P issued April 21, 2006.

Compliance Method: Compliance shall be assured by compliance with Conditions E4-4 and E4-10. At 0.05%

maximum sulfur content in fuel oil as required by Condition E3-12, representative of worst-case SO2 emissions, the 0.51

lbs/MMBtu emission limit is not exceeded, the actual maximum emissions being 0.0507 lbs/MMBtu and 19.47 lb/hr, based

on an AP-42 factor of 142S lb SO2/1,000 gal, a fuel oil heating value of 140,000 Btu/gal and a maximum sulfur content in

fuel oil of 0.05% (i.e., S =0.05). At this rate, the annual tonnage limit will not be exceeded provided the fuel oil combusted

does not exceed 8.23 million gallons during all intervals of twelve consecutive months as stipulated in Condition E4-10.

If natural gas is used as fuel, the actual maximum emissions are 0.0006 lbs/MMBtu and 0.23 lb/hr, based on an AP-42 factor

of 0.6 lb SO2/MMSCF and a natural gas heating value of 1,020 MMBtu/MMSCF. At this rate, the annual tonnage limit

cannot be exceeded.

E4-2. Particulate matter emitted from this fuel-burning installation shall not exceed 0.2329 pounds per million Btu heat input and

89.43 lb/hr, and shall not exceed 8.23 tons during all intervals of twelve consecutive months. The 8.23 tons during all intervals

of twelve consecutive months limitation was set as part of a PSD review. This total includes emissions from the combined

combustion of primary fuel(s) and the NCG fuel.



26

TAPCR 1200-03-06-.02(1), 1200-03-09-.01(4), and construction permit 958331F issued April 21, 2006.

Compliance Method: Compliance shall be assured by the use of No. 2 fuel oil or natural gas which meets the particulate

emission limit per MMBtu of heat input. Using maximum emissions from fuel oil, the 0.2329 lbs/MMBtu and 89.43 lb/hr

emission limitations are not exceeded, the actual maximum emissions being 0.0143 lbs/MMBtu and 5.49 lb/hr, based on an

AP-42 factor of 2 lb PM/1,000 gal and a fuel oil heating value of 140,000 Btu/gal. Using the worst case fuel and maximum

emissions from No. 2 fuel oil, the annual tonnage limit will not be exceeded provided the fuel oil combusted does not exceed

8.23 million gallons during all intervals of twelve consecutive months as stipulated in Condition E4-10.

If natural gas is used as fuel, the actual maximum emissions are 0.0075 lbs/MMBtu and 2.86 lb/hr, based on an AP-42 factor

of 7.6 lb PM/MMSCF and a natural gas heating value of 1,020 MMBtu/MMSCF. At this rate, the annual tonnage limit will

not be exceeded provided the operating hours from Boiler #2 plus the operating hours from Boiler #3 do not exceed 6000 hours

during all intervals of twelve consecutive months as stipulated in Condition E4-4.

E4-3. Visible emissions from the boilers shall not exhibit greater than twenty percent opacity, except for one six-minute period in

any one hour period and for no more than four six-minute periods in any twenty-four hour period. Visible emissions from

this source shall be determined by EPA Method 9, as published in the current 40 CFR 60, Appendix A (six-minute average).

TAPCR 1200-03-05-.03(6) and 1200-03-05-.01(1)

Compliance Method: The permittee shall assure compliance with the opacity standard by utilizing the opacity matrix

dated June 18, 1996, and amended September 11, 2013, using EPA Method 9 that is enclosed as Attachment 1.


unsatisfactory to the Technical Secretary, this permit may be reopened to impose additional opacity monitoring

requirements.

E4-4. Operating hours from Boiler #2 plus operating hours from Boiler #3 shall not exceed 6000 hours during all intervals of twelve

consecutive months. This operational limitation was set as part of a PSD review.

TAPCR 1200-03-09-.01(4) and construction permit number 958331P issued April 21, 2006.

Compliance Method: Compliance shall be assured by recording the monthly operating hours for each of the boilers.

The following log (Log 3) shall be kept in accordance in Condition E3-3 and shall be submitted semiannually in accordance

Condition E2(a)(1).

LOG 3

LOG OF OPERATING HOURS FOR PACKAGE BOILERS

(SOURCE 02)

Month _____ Year ______

Date

Month/year

Boiler

#2

(hours)

Boiler

#3

(hours)

Monthly operating

hours totaled from both

boilers (hours)

Total cumulative boiler

operating hours for previous 12

months (hours)

E4-5. For fee purposes, the following values shall be utilized for allowable emissions based on maximum emissions for each billable

gaseous pollutant not previously specified. This total includes emissions from the combined combustion of primary fuel(s) and

the NCG fuel. The maximum VOC emissions are based on VOC emissions from natural gas as worst case with an emission

factor of 5.5 lbs VOC/million scf of natural gas. The maximum NOX emissions are based on NOX emissions from natural gas as

worst case and the results of a 7/13/2001 source test.


27

VOC 3.1 tons for 12 consecutive months

NOX 171.4 tons for 12 consecutive months

Sulfuric Acid Mist 1.5 tons for 12 consecutive months

TAPCR 1200-03-26-.02(2)(d)3

E4-6. This facility shall comply with the applicable standards of 40 CFR 63 Subpart S.

NESHAPS MACT standard 40 CFR 63 Subpart S and construction permit 953392F issued January 12, 2001

Compliance Method: Compliance is assured by meeting the conditions and requirements of Condition E3-2.

Emission limits when combusting NCG gases in a package boiler

E4-7. Sulfur dioxide emitted from the incineration of the NCG gas stream in two back-up boilers shall not exceed 8.27 pounds per

hour and shall not exceed 6.0 tons during all intervals of twelve consecutive months.

TAPCR 1200-03-14-.01(3); agreement letter dated December 20, 2000; PSD avoidance; and construction permit 953392F

issued January 12, 2001

Compliance Method: Source tests conducted during July and August of 2001 and observed by the Division were done in

accordance with construction permit 953392F, within 120 days of the startup of the non-condensable gas (NCG) incineration

system. Test results indicated no appreciable NCG emissions and complied with the above limit. Subsequent tests of the

NCG scrubber alone conducted in October of 2001 indicated compliance with NCG emission limits with or without the NCG

scrubber in place. Combustion of NCG gases in the boiler will comply with the emission limits without the need of the NCG

scrubber prior to combustion.

E4-8. Nitrogen oxides emitted from the incineration of the NCG gas stream in two back-up boilers shall not exceed 7.43 pounds per



issued January 12, 2001


accordance with construction permit 953392F, within 120 days of the startup of the non-condensable gas (NCG) incineration





E4-9. Carbon monoxide emitted from the incineration of the NCG gas stream in two back-up boilers shall not exceed 2.33 pounds per




accordance with construction permit 953392F, within 120 days of the startup of the non-condensable gas incineration (NCG)





E4-10. Fuel oil combusted by this boiler is subject to the facility-wide limitation set forth in Condition E3-11.

Compliance Method: As specified in Condition E3-11.

E4-11. These boilers shall comply with the applicable standards of 40 CFR 63 Subpart DDDDD.


28

Compliance Method: The permittee must meet the applicable work practice standards in Table 3 to subpart DDDDD for

each affected unit designed to burn gas 1 type fuel in accordance with 40 CFR §63.7500:

If the unit is . . . The permittee must. . .

A boiler or process heater with a continuous oxygen trim system that

maintains an optimum air to fuel ratio.

Conduct a tune-up of the boiler or process heater

every 5 years in accordance with § 63.7540

A boiler or process heater with heat input capacity of less than 10

million Btu per hour, but greater than 5 million Btu per hour.


biennially in accordance with § 63.7540

A boiler or process heater without a continuous oxygen trim system

and with heat input capacity of 10 million Btu per hour or greater.


annually in accordance with § 63.7540

An existing boiler or process heater located at a major source

facility, not including limited use units.

Have a one-time energy assessment performed by a

qualified energy assessor according to § 63.7530(e).

The energy assessment must include the items a.

through h. in Table 3 as appropriate for the on-site

technical hours listed in § 63.7575

(a) Pursuant to 40 CFR §63.7530(f) and 63.7545(a), the permittee must submit all of the notifications in §63.7(b) and (c),

§63.8(e), (f)(4) and (6), and §63.9(b) through (h), including the Notification of Compliance Status containing the

results of the initial compliance demonstration.

(b) Pursuant to 40 CFR §63.7550, the permittee must submit annual, biennial, and/or 5-year, 40 CFR 63, Subpart DDDDD

compliance reports, whichever are applicable. In order to synchronize the reporting period with the Title V reporting

period, the initial 40 CFR 63, Subpart DDDDD compliance report must cover the period beginning January 31, 2017

and ending on either December 31, 2017 if reporting annually, December 31, 2018 if reporting biennially, or

December 31, 2022 if reporting every 5-years, whichever are applicable. Reports must be postmarked or delivered

with the next required Semi Annual Report (SAR) in accordance with the reporting schedule established in condition

E(2)(a). Subsequent compliance reports after the initial report will cover shall be submitted with the next required

Semi Annual Report (SAR) in accordance with the reporting schedule established in condition E(2)(a) after the end of

each annual, biennial, or 5-year period following the first report.

(c) Pursuant to 40 CFR §63.7555 and §63.7560, the permittee must keep records pertaining to 40 CFR 63, Subpart

DDDDD in a form suitable and readily available for expeditious review, according to §63.10(b)(1). The permittee

must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action,

report, or record. Each record must be kept on site, or they must be accessible from on site (for example, through a

computer network), for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action,

report, or record, according to § 63.10(b)(1). Records may be kept off site for the remaining 3 years.

E4-12. Fuel oil is to be combusted in Package Boiler #2 and/or Boiler #3 only during periods of natural gas curtailment. During

Curtailment, these boilers are also subject to the conditions set forth in Conditions E4-1-E4-4, E4-6, E4-10 and E4-11.

Compliance Method: As specified in Conditions E4-1 throughE4-4, E4-6, E4-10 and E4-11

43-0010-07 527 MMBtu/hr boiler

burning wood refuse,

ammonium sulfite spent

liquor, sludge, OCC rejects,

facility waste oil, natural

gas, and No. 2 fuel oil

serving as primary boiler

fuel for producing plant

steam and combusting

NCG gases from the LVHC

system

This spreader stoker boiler is used to burn several fuels primarily wood and spent

liquor. Facility waste oil and other material as described herein may be burned. This

operation uses two primary air pollution control devices consisting of a venturi

scrubber and tray type absorption scrubber. This boiler unit serves as the primary

combustor device for generating plant steam and thermally oxidizing the NCG gas

stream to comply with Subpart S. These gases are routed through the LVHC system

via hard case piping into the boiler for thermal oxidation. This source is subject to

MACT 40 CFR 63 Subpart S, MACT 40 CFR 63 Subpart DDDDD, and to NSPS 40

CFR 60.40, and NSPS 40 CFR 60 Subpart D for Fossil-fuel-fired steam generating

units when solely burning fossil fuel or a fossil fuel-wood mixture.



29

E5-1. Filterable particulate matter emitted from this source shall comply with the limits specified in Table 2 of 40 CFR 63 Subpart

DDDDD.

Compliance Method: Prior to the installation of the Wet Electrostatic Precipitator (WESP):

The primary particulate control equipment at this source consists of a high efficiency venturi scrubber and a tray type absorption

scrubber. Previous source sampling observed by the Division has verified particulate compliance using various fuels and

combinations. On-going compliance with the above particulate limits shall be assured by maintaining a daily log of venturi

scrubber parameters during days of boiler operation along with boiler fuel constituents and feed rates. For the venturi scrubber

this pertains to the scrubber liquid flow rate (gallons per minute) and pressure drop (inches of water) across the venturi throat.

For boiler operation this means type of fuel being burned (wood waste, fossil fuels, spent liquor or other permitted fuels)

including any fuel additives and their quantities. One daily reading of each parameter is required for each day that the boiler

operates and such readings shall be taken during actual boiler operation.

Based on Division review and discussions with the facility, a value of 1000 gallons per minute represents the acceptable

minimum value of the venturi scrubber liquor flow rate and 10 inches of water represents the minimum acceptable pressure

differential across the venturi scrubber.

Accordingly, official recording of such values shall commence no later than February 2, 2004. Readings shall only be taken on

days when the wood refuse boiler is operational. Daily readings shall be reported semiannually in accordance with Condition

E2(a)(1) and the following log (Log 4) shall be kept. Based on the established minimum acceptable values for the venturi

scrubber liquid flow rate and the pressure differential across the venturi scrubber, if readings fall below these levels, relevant

comments and any action taken shall be noted by the recorder on the daily log. Such values shall be reported as deviations in the

semiannual report and reported in accordance with Condition E2(a)(1).

Compliance assurance of emission limits for the Refuse Boiler has been verified by source testing conducted on April 29, April

30, May 1, May 4, and July 9, 2009, with results submitted to the Division in a report dated July 24, 2009, and accepted by the

Division in a letter dated February 11, 2010. The flow rate shall be no less than 1,328 gpm (gallons per minute) and the scrubber

differential shall measure no less than 13.1 inches of water when the Refuse Boiler is burning bark only. The venture scrubber

flow rate shall be no less than 1,595 gpm and the scrubber differential shall be no less than 12.2 inches of water when the Refuse

Boiler is burning 25 gpm or less of liquor only; the flowrate shall be no less than 2,297 gpm and the scrubber differential shall be

no less than 12.8 inches of water when the Refuse Boiler is burning between 25.1 and 30 gpm of liquor only; and the water

flowrate shall be no less than 2,574 gpm and the scrubber differential shall be no less than 13.2 inches of water when the Refuse

boiler is burning between 30.1 and 32 gpm liquor. Any values outside these ranges over a 3-hour rolling average shall be

recorded as deviations.

LOG 4

PARAMETERS FOR WOOD REFUSE BOILER VENTURI SCRUBBER FOR SOURCE 07

All Values Represent a 3 hour rolling average

Month ________ Year ________

Date Hour Venturi

scrubber

flow rate

(gal/min)

Venturi scrubber

differential

pressure

(inches of water)

Liquor being fed to

the Boiler

(gpm)

Compliant with

Control

Conditions

(Y or N)

Comments

Compliance Method: After January 31, 2017, the compliance method will be specified in the Notification of Compliance

Status. Upon review and approval of the Notification of Compliance Status, the provisions of Subpart DDDDD will be

incorporated into this permit using the applicable procedures in Condition C4 (Minor Permit Modifications) of this permit.


30

E5-2. The burning of wood must supply at least thirty percent of the heat input to this boiler when ammonium sulfite spent liquor is

burned for the boiler unit to qualify as a wood-fired boiler and the applicable standards.

TAPCR 1200-03-16-.02(3)(a)1 and construction permit 961563P issued November 20, 2008

Compliance Method: Compliance shall be assured by maintaining the following log (Log 5) for days when ammonium sulfite

is burned. Semiannual reporting for this log is not necessary.

LOG 5

LOG OF DATES WHEN AMMONIUM SULFITE SPENT LIQUOR IS FIRED WITH WOOD

Month ________ Year ________

Date when

ammonium sulfite

spent liquor is burned

Wood refuse heat input to boiler

greater than 30% of total heat input

Yes/No

Person making log entry

E5-3. Nitrogen oxides emitted from this boiler shall not exceed 0.3 pounds per million BTU of heat input to this source and shall not

exceed 692.5 tons during all intervals of twelve consecutive months. This total includes emissions from the combined

combustion of primary fuel(s) and the NCG fuel.

TAPCR 1200-03-16-.02(5)(a), 40 CFR 60.44(a)(2), and construction permit 961563P issued November 20, 2008

Compliance Method: Compliance shall be assured by determining the worst case emissions from various fuels. Using the

worst case fuel and maximum NOx emissions from ammonium sulfite spent liquor, the annual tonnage limit will not be

exceeded.

E5-4. Visible emissions from the wood refuse boiler shall not exceed twenty percent (20%) opacity except for one six minute

period per hour of not more than 27 percent opacity as determined by EPA Method 9 published in 40 CFR 60, Appendix A

(6-minute average).

TAPCR 1200-03-16-.02(6)(g)1, 40 CFR 60.45(g)(1), and construction permit 961563P issued November 20, 2008


dated June 18, 1996, and amended September 11, 2013, using EPA Method 9 that is enclosed as Attachment 1.



requirements.

E5-5. The sulfur dioxide emissions from this source shall not exceed 0.20 pounds of SO2 per million Btu of heat input and 105.4

pounds per hour. This total includes emissions from the combined combustion of primary fuel(s) and the NCG fuel. This

emission limitation shall apply at all times when wood refuse, fossil fuels, ammonium sulfite spent liquor, primary sludge,

corrugated container rejects, and waste oil are burned. This standard supersedes and is more restrictive than the previous sulfur

dioxide emission standards of ninety percent controlled when burning ammonium sulfite spent liquor and less than 0.80 pounds

of SO2 per million Btu of heat input when operating pursuant to 40 CFR Subpart D.

This emission limitation was set as part of a previous PSD review (for permit 958331P), in order to limit allowable sulfur

dioxide emissions from increased utilization of this boiler.

TAPCR 1200-03-09-.01(4) and Construction permit 961563P issued November 20, 2008

Compliance Method: Compliance with these emission standards shall be determined through the use of continuous in-

stack monitoring for sulfur dioxide. NSPS applicability and the requirement for continuous monitoring for the wood refuse


31

boiler at Inland was established based on the November 1, 1977 EPA memo from Edward Reich to Tommie Gibbs.

Compliance shall be determined utilizing a three-hour averaging basis (block average).

TAPCR 1200-03-09-.02(11)(e)1.(iii) and construction permit 961563P issued November 20, 2008

E5-6. Operational Availability Condition for the Sulfur Dioxide Monitoring System

The use of continuous in-stack monitoring for sulfur dioxide is the method by which this fuel burning installation proves

continual compliance with the applicable sulfur dioxide emission limitation. Therefore, for this fuel burning installation to

demonstrate continual compliance with the applicable sulfur dioxide emission limitation, the sulfur dioxide monitoring system

shall be fully operational for at least ninety five percent of the operational time of the monitored unit during each month of the

calendar quarter. An operational availability level of less than this amount may be considered the basis for declaring the fuel

burning installation in noncompliance with the applicable monitoring requirements, unless the reasons for the failure to maintain

these levels of operational availability are accepted by the Division as being legitimate malfunctions of the instruments or due to

limited operation of the monitored units.

TAPCR 1200-03-10-.02(1)(a) and construction permit 961563P issued November 20, 2008

E5-7. Quality Assurance Condition for the Sulfur Dioxide Monitoring System

Quality assurance checks shall be performed on the sulfur dioxide monitoring system on an annual basis. The quality assurance

checks shall consist of a repetition of the relative accuracy portion of the Performance Specification Test. Written reports of the

quality assurance checks shall be submitted to the Technical Secretary.

Within ninety days of each major modification or major repair of any sulfur dioxide emissions monitor, diluent monitor, or

electronic signal combining system, a repeat of the performance specification test shall be conducted. A written report of the

performance specification test shall be submitted to the Technical Secretary as proof of the continuous operation of the sulfur

dioxide emissions monitoring system within acceptable limits.

TAPCR 1200-03-10-.02(1)(a) and construction permit 961563P issued November 20, 2008

E5-8. From the emissions data generated by the continuous sulfur dioxide monitoring systems, reports of excess sulfur

dioxide emissions shall be generated. The format of these reports shall meet the requirements of Paragraph 1200-03-

10-.02(2) of the Tennessee Air Pollution Control Regulations. These reports shall be submitted as part of the

semiannual reports required by Condition E2(a).

TAPCR 1200-03-10-.02(2), 1200-03-09-.02(11)(e)1(iii) and construction permit 961563P issued November 20, 2008

E5-9. For sulfur dioxide monitoring, the reports referenced in Condition E5-8 shall consist of:

(a) Emission averages, in the units of the applicable standard, for each averaging period during operation of the source.

(b) Identification of each averaging period in which the applicable standard was exceeded and the nature and cause of

excess emissions, if known;

(c) The date and time identifying each period during which the system was inoperative, except for zero and span checks,

and the nature of system repairs or adjustments shall be reported. The Technical Secretary may require proof of system

performance whenever system repairs or adjustments have been made; and

(d) When no excess emissions have occurred and the system has not been inoperative, repaired, or adjusted, such

information shall be included in the report.

TAPCR 1200-03-10-.02(2), 1200-03-09-.02(11)(e)1(iii) and construction permit 961563P issued November 20, 2008

E5-10. This boiler shall comply with the applicable standards of 40 CFR 63 Subpart S.

NESHAPS MACT standard Subpart S and construction permit 953393F issued January 12, 2001

Compliance Method: Compliance is assured by meeting the conditions and requirements of Condition E3-2.

E5-11. For fee purposes the following is pertinent for emission source 07:


32

HAP and VOC emissions are billable pollutants pursuant to 1200-03-26-.02(2)(i)(12) of TAPCR. In accordance with 1200-

03-26-.02(2)(d)3, for pollutants with no specific allowable emission rate, the allowable emissions are based on maximum

actual emissions expected at full design capacity operating at 24 hours per day, every day, or expected at the operating time

specified in a legally enforceable permit. Pollutants are not to be double-counted for fees so that HAP-VOC emissions are not to

be counted twice as VOC emissions but are a subset of the VOC emissions previously listed. The remaining HAP emissions are

to be categorized as non-VOC gaseous HAPs and particulate matter HAPs. For emission source 07, the following values shall

be used utilized for billing purposes based on maximum actual emissions as described above:

VOC emissions: 30.8 tons per year based on AP-42 emission factor of 0.12 lbs VOC per ton of wood, VOC HAPs of 20.3 tons

per year (included in the VOC emissions) based on the revised VOC and HAP emission submittal of September 4, 2001, 0.8

tons per year of non-VOC gaseous HAPs (same submittal), and 5.5 tons per year of particulate matter HAPs (same submittal).

Particulate emissions of 369.3 tons per year based on 0.16 lbs/MM BTU

Sulfur dioxide emissions of 461.7 tons per year based on 0.20 lbs/MM BTU

TAPCR 1200-03-26-.02(2)(d)3., 1200-03-26-.02(2)(i)(12) and construction permit 961563P issued November 20, 2008

E5-12. The amount of on and off spec oil, as defined at 40 CFR 279, and nonhazardous solvents that can be burned in this fuel burning

installation shall not exceed 1000 gallons per month. In addition, oil contaminated media, and oil-contaminated soil and

absorbent material used to clean up oil spills may be burned.

TAPCR 1200-03-09-.02(11)(e)1.(iii) and construction permit 961563P issued November 20, 2008

Compliance Method: Compliance for this condition is assured by the utilizing the following log (Log 6) to record the type and

amount of material burned listed above. The data from this log shall be kept as stipulated in Condition E3-3 and shall be

submitted semiannually in accordance with Condition E2(a)(1).

LOG 6

MONTHLY WASTE OIL BURNED AND NON-CONVENTIONAL

MATERIAL BURNED IN WOOD REFUSE BOILER

Month ________ Year ________

Date

Specific

Material

Combusted

Amount of waste oil and

solvents burned

(gallons)

Amount of

material other than

waste oil and

solvents

combusted

(pounds/gallons)

Person making log

entry

Emission limits when combusting NCG gases in the wood refuse boiler

E5-13. Sulfur dioxide emitted from the thermal oxidation of the NCG gas stream in the wood refuse boiler shall not exceed 0.83 pounds

per hour.

TAPCR 1200-03-14-.01(3); agreement letter dated December 20, 2000; PSD avoidance; and construction permit 961563P

issued November 20, 2008


accordance with construction permit 953393F, within 120 days of the startup of the non-condensable gas thermal oxidation

system. Test results indicated no appreciable sulfur dioxide emissions from NCG combustion.


33

E5-14. Nitrogen oxides emitted from the thermal oxidation of the NCG gas stream in the wood refuse boiler shall not exceed 7.3 pounds

per hour.





system. Test results indicated no appreciable NOX emissions from NCG combustion.

E5-15. Carbon monoxide emitted from the thermal oxidation of the NCG gas stream in the wood refuse boiler shall not exceed 2.33

pounds per hour.





system. Test results indicated no appreciable CO emissions from NCG combustion.

E5-16. After January 31, 2016, Hydrogen Chloride emitted from this source shall comply with the limits stated in

40 CFR 63.7500 Table 2, 63.7505(c ), 63.7545, and 63.7525(l).




E5-17. After January 31, 2016, Mercury emitted from this source shall comply with the limits stated in

40 CFR 63.7500 table 2, 63.7505(c ), 63.7545, and 63.7525(l).




E5-18. Fuel oil combusted by this boiler is subject to the facility-wide limitation set forth in Condition E3-11.

Compliance Method: As specified in Condition E3-11.

E5-19. This boiler shall comply with the applicable standards of 40 CFR 63 Subpart DDDDD.

43-0010-08 Cooking liquor

preparation system

with wet scrubber

The cooking liquor preparation system processes sulfur, which is burned and then, is

combined with water and ammonia in an absorption system to produce cooking liquor.

The absorption system serves primarily as a process device as well as a sulfur dioxide

scrubber.

Conditions E6-1 and E6-2 apply to source 43-0010-08

E6-1. Sulfur Dioxide emissions shall not exceed 100 ppm (dry basis). An allowable of 1.48 pounds per hour based on the

application of record results from a maximum flow tare of 1,480 dscf/min. This corresponds to 6.48 tons of sulfur dioxide

during all intervals of twelve consecutive months. This value shall be assigned as the allowable sulfur dioxide tonnage for

fee purposes.

TAPCR 1200-03-19-.14(1)(c)(7)(i) for cooking liquor systems and 1200-03-26-.02(2)(d)(3)


34

Compliance Method: Compliance shall be assured by Lundberg data and in-house test values of sulfur dioxide from the

scrubber outlet. A source test conducted on July 12, 2001 that was observed by the Division indicated an average outlet stack

concentration of 19 PPM for sulfur dioxide. Daily readings during cooking liquor operation shall be taken of the scrubber liquid

flow rate in gallons per minute. One daily reading of this parameter is required for each day that the cooking liquor preparation

system operates and such readings shall be taken during actual process operation.

A parameter gauge was installed, calibrated, and operational to measure scrubber cooking liquor flow rate. Readings were taken

for more than 30 days after the gauge was properly operating and were taken on days in which both the process and control

device were operational. The data was submitted by the permittee to the Division in a letter dated October 20, 2003. Based on

Division review and discussions with the facility, a value of 10 gallons per minute represents the acceptable minimum value of

scrubber liquor flow rate.

Readings shall only be taken on days when the process is operational. Daily readings shall be reported semiannually in

accordance with Condition E2(a)(1) and the following log (Log 7) shall be kept. Based on the established minimum acceptable

value for cooking liquor scrubber liquid flow rate, if readings fall below this level, relevant comments and any action taken shall

be noted by the recorder on the daily log. Such values shall be reported as deviations in the semiannual report and reported in

accordance with Condition E2(a)(1).

LOG 7

COOKING LIQUOR SCRUBBER LIQUID FLOW RATE

Month ________ Year ________

Date Scrubber liquid flow

rate

(gal/min)

Greater than 10 gallons per

minute ?

If less than 10 gallons per minute,

why and what actions are being

taken?

A monthly log of maintenance and repair of the scrubber shall be kept on site in accordance with Condition E3-1. The log shall

denote what maintenance and what repair was done, when it was done, by whom, and when problems were rectified showing

date accomplished. The following maintenance log (Log 8) shall be kept. Semiannual reports are not necessary for this

maintenance log.

LOG 8

MONTHLY MAINTENANCE LOG OF COOKING LIQUOR SCRUBBER

Month ________ Year ________

Date Scrubber ID Repair/Maintenance Performed Person making log entry

E6-2. Visible emissions from the cooking liquor scrubber shall not exhibit an opacity in excess of twenty percent for an aggregate of

more than five minutes in any one hour or more than twenty minutes in any twenty-four hour period as specified in Rule

1200-03-05-.01 of the Tennessee Air Pollution Control Regulations (aggregate count). Visible emissions from stacks will be


35

determined by Tennessee Visible Emission Evaluation Method 2 as adopted by the Tennessee Air Pollution Control Board on

August 24, 1984.

TAPCR 1200-03-05-.01


dated June 18, 1996, and amended September 11, 2013, using TVEE Method 2 that is enclosed as Attachment 1.



requirements.

43-0010-10 Paper machine and

associated operations

Wood pulp from the NSSC and recycle pulp are blended at an annualized average of

75,000 pounds per hour of machine dry pulp. The material is sent through screening,

headbox, Fourdrinier, presses, dryers, and then wound on reels resulting in a final

product of paper. VOCs, ammonia, and HAPs are released to the atmosphere.


E7-1. This emission source predates reasonable and proper gaseous emission control (April 3, 1972) under TAPCR 1200-03-07-.07(2);

therefore, there are no regulatory VOC or ammonia allowable emission limits for this source. HAP and VOC emissions are

billable pollutants pursuant to 1200-03-26-.02(2)(i)(12) of TAPCR. In accordance with 1200-03-26-.02(2)(d)3, for pollutants

with no specific allowable emission rate, the allowable emissions are based on maximum actual emissions expected at full

design capacity operating at 24 hours per day, every day, or expected at the operating time specified in a legally enforceable

permit. Pollutants are not to be double-counted for fees so that HAP-VOC emissions are not to be counted twice as VOC

emissions but are a subset of the VOC emissions previously listed. The remaining HAP emissions are to be categorized as non-

VOC gaseous HAPs and particulate matter HAPs. For this emission source, the following values shall be utilized for fee billing

purposes based on maximum actual emissions as described above:

Based on the September 4, 2001 VOC and HAP submittal, the following values are relevant for this source: VOC emissions of

101.3 tons per year, 97.9 tons per year of VOC HAP emissions included in the VOCs, 0.14 tons per year of non-VOC gaseous

HAP emissions. There are no particulate matter HAPs.

TAPCR 1200-03-26-.02(2)(d)3. and 1200-03-26-.02(2)(i)(12)

E7-2. Visible emissions from the stack emission points in the paper machine process shall not exhibit an opacity in excess of twenty

percent for an aggregate of more than five minutes in any one hour or more than twenty minutes in any twenty-four hour

period as specified in Rule 1200-03-05-.01 of the Tennessee Air Pollution Control Regulations (aggregate count). Visible

emissions from stacks will be determined by Tennessee Visible Emission Evaluation Method 2 as adopted by the Tennessee Air

Pollution Control Board on August 24, 1984.

TAPCR 1200-03-05-.01





requirements.

E7-3. Paper machine production shall not exceed 407,340 bone-dry tons during any period of 12 consecutive months.

This operating limitation was set as part of a PSD review in order to limit emissions from the paper machine and from increased

utilization of other non-modified sources. The relevant increase in paper machine production is from the 2003/2004 average of

277,710 bone-dry tons per year to the new maximum level of 407,340 bone-dry tons per year.

TAPCR 1200-03-09-.01(4) and construction permit 958331P issued April 21, 2006


36

Compliance Method A log of production rate for this source, in bone-dry tons per month and bone-dry tons per 12

consecutive months, must be maintained at the source location and kept available for inspection by the Technical Secretary or

his representative. The log required by this condition shall be used to certify compliance with this condition and in the

requirements of Condition E2. This log must be retained for a period of not less than five years. Reports and certifications

shall be submitted semiannually in accordance with Condition E2(a)(1) of this permit.

E7-4. VOC emissions shall not exceed 41.95 lb/hr. In order to achieve compliance with this emission limitation, pulp must be washed

with hot water in a counter current fashion prior to sending it to the paper machine. These emission and operation limitations are

established as BACT for this source.

TAPCR 1200-03-09-.01(4)(j) and construction permit 958331P issued April 21, 2006

Compliance Method Compliance is based on a source test conducted on a non-kraft semichemical paper machine as

described in NCASI Technical Bulletin 683, which resulted in an emission factor of 0.812 pounds per air-dried ton of product.

At 0.9 tons of bone-dried ton of product per air-dried ton of product, this corresponds to 41.95 lb/hr for a production of 407,340

bone-dry tons during any period of 12 consecutive months.

43-0010-11 Pulp mill including

NSSC blow tank and

other associated

equipment and

operations, and OCC

Wood pulp from the wood chip steaming vessel is processed with anhydrous ammonia

and cooking liquor in an impregnator, continuous digester, primary refiner, blow tank,

washer and repulpers, filtrate tanks, and to secondary refiners. The maximum

throughput is 101,010 pounds per hour resulting in NSSC pulp and weak spent liquor.

VOCs, HAPs, ammonia, and sulfur dioxide are released to the atmosphere.



therefore, there are no regulatory VOC or ammonia allowable emission limits for this source. HAP and VOC emissions are

billable pollutants pursuant to 1200-03-26-.02(2)(i)(12) of TAPCR. In accordance with 1200-03-26-.02(2)(d)3, for pollutants

with no specific allowable emission rate, the allowable emissions are based on maximum actual emissions expected at full

design capacity operating at 24 hours per day, every day, or expected at the operating time specified in a legally enforceable

permit. Pollutants are not to be double-counted for fees so that HAP-VOC emissions are not to be counted twice as VOC

emissions but are a subset of the VOC emissions previously already listed. The remaining HAP emissions are to be categorized

as non-VOC gaseous HAPs and particulate matter HAPs. For this emission source, the following values shall be utilized for

billing purposes based on maximum actual emissions as described above:


78.9 tons per year, 72.6 tons per year of VOC HAP emissions included in the VOCs, 0.03 tons per year of non-VOC gaseous

HAP emissions. There are no particulate matter HAPs.

TAPCR 1200-03-26-.02(2)(d)3. and 1200-03-26-.02(2)(i)(12)

E8-2. Visible emissions from stack emission points on the NSSC pulp mill shall not exhibit an opacity in excess of twenty percent for

an aggregate of more than five minutes in any one hour or more than twenty minutes in any twenty-four hour period as

specified in Rule 1200-03-05-.01 of the Tennessee Air Pollution Control Regulations (aggregate count). Visible emissions from

stacks will be determined by Tennessee Visible Emission Evaluation Method 2 as adopted by the Tennessee Air Pollution

Control Board on August 24, 1984.

TAPCR 1200-03-05-.01





requirements.

E8-3. Sulfur dioxide emissions shall not exceed 50 PPM (dry basis) for all vents other than the continuous digester and blow tank

serving this process. These two operations route NCG emissions to the LVHC system for incineration and have no separate


37

stack exit and thus no allowable. For the other vents within this process, the following stack emission points are subject to 50

PPM of sulfur dioxide (dry basis). Corresponding flow rates and equivalent allowable for each stack are shown in the table

below.

Stack Description Stack/vent

ID

Flow rate

(dscf/min)

Allowable

SO2

concentration

(PPM)

Allowable SO2

emission rate

at flow rate

shown

(lbs/hr)

Pulp mill washers

& repulpers

2130SA 15,700 50 7.83

Pulp mill washers

& repulpers

2130SB 15,700 50 7.83

No. 1 Filtrate tank 2140S 3,740 50 1.87

No. 2 Filtrate tank 2145S 1,040 50 0.52

Total 18.05

A total of 18.05 pounds per hour of allowable emissions results from combining all process stacks for this source based on the

application of record at the maximum flow rate for each stack shown above. This corresponds to a total of 79.06 tons of sulfur

dioxide during all intervals of twelve consecutive months and this value shall be assigned as the total allowable sulfur dioxide

tonnage for fee purposes.

A reduction in allowable emissions from 100 to 50 PPM was set as part of a PSD review for this permit.

TAPCR 1200-03-09-.01(4) and 1200-03-19-.14-(1)(c)7.(iv) and construction permit 958331P issued April 21, 2006

Compliance Method: Compliance is assured by November 7, 2001 SO2 testing by the permittee using a calibrated

SO2/H2S meter. Actual test results for the 2 washer vents indicated 0.3 PPM and filtrate tank vents at 1.5 PPM and 12.4 PPM

for Filtrate tanks No. 1 and No. 2, respectively.

E8-4. Pulp mill production shall not exceed 176,700 bone-dry tons during any period of 12 consecutive months. This operating

limitation was set as part of a PSD review for this permit.

TAPCR 1200-03-09-.01(4) and construction permit 958331P issued April 21, 2006






43-0010-12 Wastewater treatment

plant

Process sewer water and ash slurry are processed for wastewater treatment.

Condition E9-1 applies to source 43-0010-12


therefore, there are no regulatory VOC allowable emission limits for this source. HAP and VOC emissions are billable

pollutants pursuant to 1200-03-26-.02(2)(i)(12) of TAPCR. In accordance with 1200-03-26-.02(2)(d)3, for pollutants with no

specific allowable emission rate, the allowable emissions are based on maximum actual emissions expected at full design

capacity operating at 24 hours per day, every day, or expected at the operating time specified in a legally enforceable permit.

Pollutants are not to be double-counted for fees so that HAP-VOC emissions are not to be counted twice as VOC emissions but

are a subset of the VOC emissions previously already listed. The remaining HAP emissions are to be categorized as non-VOC

gaseous HAPs and particulate matter HAPs. For this emission source, the following values shall be used utilized for billing

purposes based on maximum actual emissions as described above:


38


101.4 tons per year, 101.4 tons per year of VOC HAP (methanol) emissions included in the VOCs, 0.0 tons per year of non-

VOC gaseous HAP emissions. There are no particulate matter HAPs.

TAPCR 1200-03-26-.02(2)(d)3. and 1200-03-26-.02(2)(i)(12)

43-0010-13 Secondary Fiber

Recycle Pulp Mill

(BACT: VOC)

This Secondary Fiber Recycle Pulp Mill recycles old corrugated container (OCC) and

double kraft liner (DKL) into pulp for use in the paper machine. The existing secondary

fiber recycle pulp mill includes an OCC pulper, and a Thickening Process, all of which

are considered emission units as this term is defined in TAPCR 1200-03-09-.04(5)(a)1.

This source has no pollution control, and is not subject to 40 CFR Part 63 Subpart S.

This Secondary Fiber Recycle Pulp Mill includes an OCC pulper and associated

screening equipment, as well as a waste thickener.


E10-1. Secondary Fiber Recycle Pulp Mill production shall not exceed 230,640 bone-dry tons during any period of 12 consecutive

months.

This operating limitation was set as part of a PSD review.

TAPCR 1200-03-09-.01(4) and construction permit 958331P issued April 21, 2006 and amended May 9, 2007






E10-2. Volatile organic compounds (VOC) emitted from the OCC plant shall not exceed 0.49 pounds per hour. In order to achieve

compliance with this emission limitation, no VOC-containing additives or solvents will be used in the pulping process in the

Secondary Fiber Recycle Pulp Mill. These emission and operation limitations are established as BACT for this source.

TAPCR 1200-03-09-.01(4)(j) and construction permit 958331P issued April 21, 2006 and amended May 9, 2007

Compliance Method: Compliance is based on an emissions factor of 0.0185 pounds per bone-dry ton of pulp from a source

test performed on a similar unit on July 19,1994.

E10-3. Visible emissions from this source shall not exhibit greater than twenty percent opacity, except for one six-minute period in any

one hour period, and for no more than four six-minute periods in any twenty-four hour period. Visible emissions from this

source shall be determined by EPA Method 9, as published in the current 40 CFR 60, Appendix A (six-minute average).

TAPCR 1200-03-05-.01(1) and 1200-03-05-.03(6)

Compliance Method: Compliance with this opacity limitation shall be certified through utilization of the Division’s

Opacity Matrix dated June 18, 1996, and amended September 11, 2013, using EPA Method 9 that is enclosed as Attachment 1.



requirements.

END OF PERMIT NUMBER: 575065

Permit Number: 575065 Expiration Date: Month day , 2025

ATTACHMENT 1

OPACITY MATRIX DECISION TREE for

VISIBLE EMISSION EVALUATION for TVEE Method 2 and EPA Method 9,

dated JUNE 18, 1996 and Amended September 11, 2013



VISIBLE EMISSION EVALUATION METHOD 2

dated September 11, 2013


Is Emission Unit an

Equipment Leak?

Natural Gas or No. 2 Oil-

fired Combustion Source?

Is Each Allowable Emission

less than or equal to 10 TPY?

Is Each Allowable Emission greater than 10 TPY from Colorless Pollutants (e.g.

Colorless VOCs, CO, HCl, HF, Ammonia, or Methane)?

Within one year following Title V permit issuance date conduct an initial 30-minute VEE during normal

process operation

Is the highest individual reading greater than or equal to the applicable opacity

standard plus 15% opacity (e.g. 35% for a

20% standard)?

Conduct a one-hour VEE

Are there 3 or less individual readings greater than or equal to the

opacity standard plus 15% opacity

(e.g. 35% for a 20% standard)?*

Conduct VEEs monthly

One hour duration

Are there 21 or more individual

readings greater than or equal to the applicable opacity standard plus 15%

opacity (e.g. 35% for a 20%

standard)?

Report deviations from Permit

requirements in periodic reports and periodic compliance certifications as

required by the Major Source Operating

Permit.

No opacity reading required



No opacity reading

required

Within one year

prior to Title V permit expiration

date conduct

another 30-minute VEE during normal

process operation

Has a semi-annual VEE yielded 4 or

more individual readings greater than or equal to the applicable opacity standard

plus 15% opacity (e.g. 35% for a 20%

standard)?

Have 3 consecutive month VEEs

yielded 3 or less individual readings per evaluation that are

greater than or equal to the

applicable opacity standard plus 15% opacity (e.g. 35% for a 20%

standard)?

Yes

Yes

Yes

Yes

No

No

No

No

No

Yes

Yes

Yes

No No

Yes No

Yes

Conduct VEEs

Semi-annually

No

Notes:

PM = Periodic Monitoring required by

1200-03-09-.02(11)(e)(iii).

This Decision Tree outlines the criteria

by which major sources can meet the periodic monitoring and testing

requirements of Title V for

demonstrating compliance with the

visible emission standard in Rule 1200-

03-05-.01. It is not intended to

determine compliance requirements for EPA’s Compliance Assurance

Monitoring (CAM) Rule (formerly

referred to as Enhanced Monitoring – Proposed 40 CFR 64).

Examine each emission unit using this Decision Tree to determine the PMT

required.

Use of continuous emission monitoring

systems eliminates the need to do any

additional periodic monitoring.

Visible Emission Evaluations (VEEs) are to be conducted utilizing Tennessee

Visible Emission Evaluation Method 2.

The observer must be properly certified according to the criteria specified in

EPA Method 9 to conduct TVEE

Method 2 evaluations.

Typical Pollutants

Particulates, VOC, CO, SO2, NOx, HCl, HF, HBr, Ammonia, and Methane.

Initial observations are to be repeated within 90 days of startup of a modified

source, if a new construction permit is

issued for modification of the source.

A VEE conducted by TAPCD personnel

after the Title V permit is issued will also constitute an initial reading.

Reader Error TVEE Method 2: The TAPCD declares

non-compliance when 21 observations

are read at the standard plus 15% opacity (e.g. 35% for a 20% standard).

*The rationale for this is the fact that Rule 1200-03-05-.01 allows for an

exemption of 5 minutes (20 readings)

per hour and up to 20 minutes (80 readings) per day. With 4 or more

excessive individual readings per hour

the possibility of a daily exceedance exists.

Note: A company could mutually agree to have all of its sources regulated by

EPA Method 9. Caution: Agreement to

use Method 9 could potentially place some sources in non-compliance with

visible emission standards. Please be

sure before you agree.

Dated June 18, 1996

Amended September 11, 2013

Decision Tree PM for Opacity for

Sources Subject to Rule 1200-03-05-.01

Utilizing TVEE Method 2



VISIBLE EMISSION EVALUATION METHOD 9

dated September 11, 2013


Yes

No

Is the highest 6-minute average**greater

than 50% of the applicable opacity standard (e.g. 11% opacity for a source

having a 20% standard) and less than

100% of the applicable opacity standard?

Is the highest 6-minute average**

greater than or equal to the

applicable opacity standard & out of compliance taking both round

& reader error into consideration?

Yes

No

Is Emission Unit an

Equipment Leak?

Natural Gas or No. 2 Oil-fired

Combustion Source?

Is Each Allowable Emission

less than or equal to 10 TPY?

Is Each Allowable Emission greater than 10 TPY from Colorless Pollutants

(e.g. Colorless VOCs, CO, HCl, HF,

Ammonia, or Methane)?

Within one year following Title V permit issuance

date conduct an initial 30-minute VEE during

normal process operation

Is the highest 6-minute average** less than or equal to 50% of the applicable

opacity standard (e.g. 10% opacity for

a source having a 20% standard)?

Within one year prior to

Title V permit expiration date conduct another 30-

minute VEE during normal

process operation

Conduct 30-minute VEEs

monthly

Report deviations from Permit requirements in periodic reports and periodic compliance

certifications as required by the Major Source Operating Permit.





Has a semi-annual VEE highest 6-

minute average** been greater than or equal to the applicable

opacity standard?

Have 3 consecutive month VEEs highest 6-minute average** been

less than the applicable opacity

standard?

Yes

No

No

No

No

No

Yes

Yes

No

No

Yes

Conduct VEEs

Semi-annually

Yes

Yes

Yes

Decision Tree PM for Opacity for

Sources Utilizing EPA Method 9*

Notes:

PM = Periodic Monitoring required by

1200-03-09-.02(11)(e)(iii).

This Decision Tree outlines the criteria

by which major sources can meet the

periodic monitoring and testing requirements of Title V for

demonstrating compliance with the

visible emission standards set forth in the permit. It is not intended to determine

compliance requirements for EPA’s

Compliance Assurance Monitoring (CAM) Rule (formerly referred to as

Enhanced Monitoring – Proposed 40

CFR 64).

Examine each emission unit using this

Decision Tree to determine the PM required.*

Use of continuous emission monitoring systems eliminates the need to do any

additional periodic monitoring.

Visible Emission Evaluations (VEEs) are

to be conducted utilizing EPA Method 9.

The observer must be properly certified

to conduct valid evaluations.

Typical Pollutants Particulates, VOC, CO, SO2, NOx, HCl,

HF, HBr, Ammonia, and Methane.

Initial observations are to be repeated

within 90 days of startup of a modified

source, if a new construction permit is issued for modification of the source.

A VEE conducted by TAPCD personnel after the Title V permit is issued will

also constitute an initial reading.

Reader Error

EPA Method 9, Non-NSPS or NESHAPS

stipulated opacity standards: The TAPCD guidance is to declares non-

compliance when the highest six-minute

average** exceeds the standard plus 6.8% opacity (e.g. 26.8% for a 20%

standard).

EPA Method 9, NSPS or NESHAPS

stipulate opacity standards: EPA guidance is to allow only

engineering round. No allowance for

reader error is given.

*Not applicable to Asbestos

manufacturing subject to 40 CFR 61.142

**Or second highest six-minute average,

if the source has an exemption period stipulated in either the regulations or in

the permit.

Dated June 18, 1996

Amended September 11, 2013


ATTACHMENT 2

THE BEAUFORT SCALE

OF

WIND SPEED EQUIVALENTS Term General Description Limits of Velocity

33 feet (10 m)

Above level ground

(MPH)

Calm Smoke rises vertically.

Direction of wind shown by smoke drift but not by wind

vane.

Under 1

1 to 3

Light Wind felt in face; leaves rustle; ordinary vane moved by

wind.

4 to 7

Gentle Leaves and small twigs in constant motion; wind extends

light flag.

8 to 12

Moderate Raises dust and loose paper; small branches are moved.

13 to 18

Fresh Small trees in leaf begin to sway; crested wavelets form on

inland waters.

Large branches in motion; whistling heard in telegraph

wires; umbrellas used with difficulty.

19 to 24

25 to 31

Strong Whole trees in motion; inconvenience felt in walking

against wind.

Breaks twigs off trees; generally impedes progress.

32 to 38

39 to 46

Gale Slight structural damage occurs (chimney pot and slate

removed).

Trees uprooted; considerable structural damage occurs.

47 to 54

55 to 63


Whole Gale Rarely experienced; accompanied by widespread damage.

64 to 75

Hurricane Above 75

Prepared for:

Hood Container Corporation

2877 Scepter Road, New Johnsonville, TN 37314 9/21/2018

Title V Permit Application Renewal

New Johnsonville Mill


Table of Contents Page

1.0 Summary Index Form

2.0 Introduction 001

3.0 Package Boiler (43-0010-02) 012

4.0 Wood Refuse Boiler (43-0010-07) 022

5.0 Cooking Liquor Preparation System (43-0010-08) 040

6.0 Paper Machine (43-0010-10) 055

7.0 NSSC Pulp Mill (43-0010-11) 075

8.0 Waste Treatment Facility (43-0010-12) 098

9.0 Recycle Facility (43-0010-13) 104

Exhibit A – Application Completeness Checklist

CN- 1397 RDA 1298

State of Tennessee Department of Environment and Conservation Division of Air Pollution Control William R. Snodgrass Tennessee Tower 312 Rosa L. Parks Avenue, 15th Floor Nashville, TN 37243 Telephone: (615) 532-0554

APC Index

TITLE V PERMIT APPLICATION

INDEX OF AIR POLLUTION PERMIT APPLICATION FORMS

Section 1: Identification and Diagrams

This application contains the following forms:

APC Form 1, Facility Identification

APC Form 2, Operations and Flow Diagrams

Section 2: Emission Source Description Forms

Total number of this form

This application contains the following forms (one form for each incinerator, printing operation, fuel burning installation, etc.):

APC Form 3, Stack Identification

APC Form 4, Fuel Burning Non-Process Equipment

APC Form 5, Stationary Gas Turbines or Internal Combustion Engines

APC Form 6, Storage Tanks

APC Form 7, Incinerators

APC Form 8, Printing Operations

APC Form 9, Painting and Coating Operations

APC Form 10, Miscellaneous Processes

APC Form 33, Stage I and Stage II Vapor Recovery Equipment

APC Form 34, Open Burning

Section 3: Air Pollution Control System Forms

Total number of this form

This application contains the following forms (one form for each control system in use at the facility):

APC Form 11, Control Equipment - Miscellaneous

APC Form 13, Adsorbers

APC Form 14, Catalytic or Thermal Oxidation Equipment

APC Form 15, Cyclones/Settling Chambers

APC Form 17, Wet Collection Systems

APC Form 18, Baghouse/Fabric Filters

(OVER)

Included

Included

11

0

2

22

5

0

0

0

0

0

1

0

0

0

2

0

CN- 1398 RDA 1298


APC 1


FACILITY IDENTIFICATION

SITE INFORMATION

1. Organization’s legal name For APC Use Only

APC company point no.

2. Site name (if different from legal name) APC Log/Permit no.

3. Site address (St./Rd./Hwy.) NAICS or SIC Code

City or distance to nearest town Zip code

County name

4. Site location (in Lat./Long) Latitude Longitude

CONTACT INFORMATION (RESPONSIBLE OFFICIAL)

5. Responsible official contact Phone number with area code

6. Mailing address (St./Rd./Hwy.) Fax number with area code

City State Zip code Email address

CONTACT INFORMATION (TECHNICAL)

7. Principal technical contact Phone number with area code



CONTACT INFORMATION (BILLING)

11. Billing contact Phone number with area code



TYPE OF PERMIT REQUESTED

13. Permit requested for: Initial application to operate : __________ Minor permit modification : __________ Permit renewal to operate : __________ Significant modification : __________ Administrative permit amendment : __________ Construction permit : __________

(OVER)


2877 Scepter Road 322130New Johnsonville 37134 Humphreys

36.064065 -87.923984

Jimmy Gibson (931) 535-4285

2877 SCEPTER ROADWAVERLY TN 37185 [email protected]

Mike Goodman 931-535-4214

2877 SCEPTER ROAD

WAVERLY TN 37185 [email protected]

Mike Goodman 931-535-4214

2877 SCEPTER ROAD

WAVERLY TN 37185 [email protected]

✔

CN- 1398 RDA 1298

APC 1 HAZARDOUS AIR POLLUTANTS, DESIGNATIONS, AND OTHER PERMITS ASSOCIATED WITH FACILITY

14. Is this facility subject to the provisions governing prevention of accidental releases of hazardous air contaminants contained in Chapter 1200-03-32 of the Tennessee Air Pollution Control regulations?

__________ Yes __________ No If the answer is Yes, are you in compliance with the provisions of Chapter 1200-03-32 of the Tennessee Air Pollution Control regulations?

__________ Yes __________ No

15. If facility is located in an area designated as “Non-Attainment” or “Additional Control”, indicate the pollutant(s) for the designation.

16. List all valid Air Pollution permits issued to the sources contained in this application [identify all permits with most recent permit numbers and emission source reference numbers listed on the permit(s)].

17. Page number : Revision number: Date of revision:

N/A

2

Title V Permit for the facility Permit Number 560438 Emission Source Reference No.43-0010 Minor modification #1 issued on November 16, 2015. Emission Source Reference No.43-0010-02

✔

✔

CN – 1399 RDA 1298

State of Tennessee

Department of Environment and Conservation

Division of Air Pollution Control William R. Snodgrass Tennessee Tower


Nashville, TN 37243

Telephone: (615) 532-0554

APC 2


OPERATIONS AND FLOW DIAGRAMS

1. Please list , identify, and describe briefly process emission sources, fuel burning installations, and incinerators that are contained in this application. Please attach a

flow diagram for this application.

2. List all insignificant activities which are exempted because of size or production rate and cite the applicable regulations.

3. Are there any storage piles? YES __________ NO __________

4. List the states that are within 50 miles of your facility.

5. Page number: Revision Number: Date of Revision:

X

Kentucky

3

Number Identification Description 43-0010-02 Package boilers #2 & #3 192 MM BTU/hr each, backup for wood refuse boiler & LVHC 43-0010-07 Refuse Boiler 527 MM BTU/hr boiler firing wood refuse, ammonium sulfite spent liquor, sludge, OCC rejects, facility waste oil, natural gas/No. 2 fuel oil for producing plant steam and combusting LVHC gases with venturi scrubber and tray absorption scrubber control 43-0010-08 Cooking Liquor Prep. System Cooking liquor preparation with wet scrubber 43-0010-10 Paper Mill Paper machine and associated operations 43-0010-11 NSSC Pulp Mill Pulp mill operations and associated equipment 43-0010-12 Wastewater Treatment Receives mill process sewer water for treatment and disposal 43-0010-13 Recycle Facility Re pulps waste old corrugated containers and double kraft liner

1. 58 Strong Black Liquor Tanks: TAPCR 1200-3-9-.04(5)(f)58(xxxvi) 2. 1000 gal diesel storage tank next to the admin building: TAPCR 1200-3-9-.04(4)(d)14 3. Woodyard: TAPCR 1200-3-9-.04(5)(f)58 4. Liquor loading station next to boiler: TAPCR 1200-3-9.04 5(5) 81 5. Loading and unloading aqueous caustic solutions: TAPCR 1200-3-9-.04(5)(f)80 6. Emergency Generator for River Water Pump: TAPCR 1200-03-09-.04(5)(f)(37) 7. Emergency Fire Water Pump: TAPCR 1200-03-09-.04(5)(f)(37)

Woodyard (Figure 2)

NSSC Pulp Mill (Figure 7)

Recycle Facility (Figure 10)

Paper Machine (Figure 6)

Cooking Liquor Preparation System

(Figure 5)

Wood Refuse Boiler (Figure 4)

Wastewater Treatment System

(Figure 9)

Chips

Pulp

Clarifier Sludge

Ash Slurry

Heavy SpentLiquor

Heavy Spent Liquor Storage & Liquor Shipped Offsite

Sulfur, Ammonia, & Natural Gas

Wastewater from Mill Sewers

Wood Chips & Wood Refuse

Paper to Shipping

Natural Gas & No. 2 Fuel Oil

Landfill

Effluent to Tennessee

River

OCC Rejects

Stack Vent =

Process Flow =

Fugitive Emission =

Process =

Control Device =

Figure 1: Process Overview (43-0010)

Page 4

Chip StorageFulghumScreen

Chip WasherChip

ConveyerChip Screen

Truck Dump

Hog

Oversize BarkScreen

Truck Dump

Hog

Storage Pile Fuel House

Purchased Wood Chips

Bark to Wood Refuse

(Figure 6)

Rejects to Powerhouse

Water & Condensate from

Evaporator Set

Chips to Digester

(Figure 7)

Chip Cycle

Bark Cycle

Purchased Bark Fuel

Stack Vent =

Process Flow =

Fugitive Emission =

Process =

Control Device =

Figure 2: Woodyard (43-0010-09)

Page 5

CN – 1424 RDA 1298


APC 29


EMISSION SUMMARY FOR THE FACILITY OR FOR THE SOURCES CONTAINED IN THIS APPLICATION

GENERAL IDENTIFICATION AND DESCRIPTION 1. Facility name:

EMISSIONS SUMMARY TABLE – CRITERIA AND SELECTED POLLUTANTS

2. Complete the following emissions summary for regulated air pollutants at this facility or for the sources contained in this application.

Summary of Maximum Allowable Emissions Summary of Actual Emissions

Air Pollutant Tons per Year

Reserved for State use (Pounds per Hour- Item 4, APC 28)

Tons per Year Reserved for State use

(Pounds per Hour- Item 4, APC 28)

Particulate Matter (TSP)

Sulfur Dioxide

Volatile Organic Compounds

Carbon Monoxide

Lead

Nitrogen Oxides

Total Reduced Sulfur

Mercury

Asbestos

Beryllium

Vinyl Chlorides

Fluorides

Gaseous Fluorides

Greenhouse Gases in CO2 Equivalents

( Continued on next page )

Hood Container Corporation, New Johnsonville, TN

379.7 245.29

576.4 29.9

453.5 175.12

492.19

863.9 362.74

CN – 1424 RDA 1298

APC 29 ( Continued from previous page )

EMISSIONS SUMMARY TABLE – HAZARDOUS AIR POLLUTANTS 3. Complete the following emissions summary for regulated air pollutants that are hazardous air pollutant(s) at this facility or for the sources contained in this application.

Summary of Maximum Allowable Emissions Summary of Actual Emissions Air Pollutant & CAS





4. Page number: Revision number: Date of revision:

Total 112{b) HAPs 97.76

7

CN- 1425 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 30


CURRENT EMISSIONS REQUIREMENTS AND STATUS

GENERAL IDENTIFICATION AND DESCRIPTION

1. Facility name:

2. Emission source number

3. Describe the process emission source / fuel burning installation / incinerator.

EMISSIONS AND REQUIREMENTS

4. Identify if only a part of

the source is subject to this requirement

5. Pollutant 6. Applicable requirement(s): TN Air Pollution Control

Regulations, 40 CFR, permit restrictions, air quality based standards

7. Limitation 8. Maximum actual

emissions

9. Compliance status

( In/Out )

10. Other applicable requirements (new requirements that apply to this source during the term of this permit)


Hood Container Corporation, Johnsonville TN 43-0010 Facility Wide

General Facility- all sources

Fugitive Dust43-0010

General reporting43-0010

43-0010

43-0010 Reporting

Visible emissions are not present for more than 5 minutes per hour beyond fenceline

Required logs must be kept

TAPCR 1200-3-8-.01

N/A

40 CFR 63 Subpart DDDDDNCG

TAPCR 1200-03-09-.02(11)(e)1.(iii)

Incineration of LVHC NCG

Maintenance and Repair records kept on all control devices N/A

INN/A

INN/A

INN/A

INN/A

IN

43-0010

43-0010

43-0010

Open Burning TAPCR 1200-3-4 Allowed between 9 am and 2 pm 5 days per week on non-windy days

SO2 N/AEquation for calculation of SO2 emissions

using ppm from the refuse boiler

HAP 40 CFR 63 Subpart DDDDD Conduct boiler tune up and perform an energy audit

N/A IN

N/A IN

8

CN- 1425 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 30




1. Facility name:









emissions


( In/Out )



Hood Container Corporation, Johnsonville TN 43-0010 Facility Wide

General Facility- all sources

N/A43-0010

N/A43-0010

43-0010

43-0010 N/A

Record Keeping

Record Keeping Schedule

40 CFR 241.4(a)4

TAPCR 1200-03-09

TAPCR 1200-03-09-.01(4)Sulfur

TAPCR 1200-03-09-.01(4)

0.05%

8.23 million gal/12 months N/A

INN/A

INN/A

INN/A

INN/A

IN

43-0010

43-0010

43-0010

43-0010

43-0010

N/A TAPCR 1200-03-32-.03(1) Record Keeping

N/A TAPCR 1200-03-20 Air pollution control devices

Opacity TAPCR 1200-03-05-.03(6) and TAPCR 1200-03-05-.01(1)

N/A 40 CFR Part 64

N/A Permit No. 560438 Operating Permit

N/A

20% Opacity

N/A IN

N/A

N/A

N/A

IN

IN

IN

9

CN- 1426 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 31


COMPLIANCE PLAN AND COMPLIANCE CERTIFICATION


1. Facility name:

2. List all the process emission source(s) or fuel burning installation(s) or incinerator(s) that are part of this application.

COMPLIANCE PLAN AND CERTIFICATION

3. Indicate that source(s) which are contained in this application are presently in compliance with all applicable requirements, by checking the following: ______ A. Attached is a statement of identification of the source(s) currently in compliance. We will continue to operate and maintain the source(s)

to assure compliance with all the applicable requirements for the duration of the permit. ______ B APC 30 form(s) includes new requirements that apply or will apply to the source(s) during the term of the permit. We will meet such

requirements on a timely basis.

4. Indicate that there are source(s) that are contained in this application which are not presently in full compliance, by check ing both of the following: ______ A. Attached is a statement of identification of the source(s) not in compliance, non-complying requirement(s), brief description of the problem,

and the proposed solution. ______ B. We will achieve compliance according to the following schedule:

Action Deadline

Progress reports will be submitted:

Start date: ________________________ and every 180 days thereafter until compliance is achieved.

5. State the compliance status with any applicable compliance assurance monitoring and compliance certification requirements that have been promulgated under section 114(a)(3) of the Clean Air Act as of the date of submittal of this APC 31.



43-0010-02 Package Boilers; 43-0010-07 Wood Refuse Boiler; 43-0010-08 Cooking Liquor Prep; 43-0010-10 Paper Machine; 43-0010-11 Pulp Mill; 43-0010-12 Wastewater Treatment Plant; 43-0010-13 Secondary Fiber Recycle Pulp Mill

X

N/a

N/a

In compliance. The MACT rule negates the need for a CAM plan.

10

Number Identification

43-0010-02 Package Boilers

43-0010-07 Wood Refuse Boiler

43-0010-08 Cooking Liquor Prep

43-0010-10 Paper Machine

43-0010-11 NSSC Pulp Mill

43-0010-12 Waste Treatment Facility

43-0010-13 Recycle Facility

emily.phillips

Typewritten Text

Page 11

emily.phillips

Typewritten Text

emily.phillips

Typewritten Text

emily.phillips

Typewritten Text

emily.phillips

Typewritten Text

emily.phillips

Typewritten Text

emily.phillips

Cross-Out

CN – 1401 RDA 1298


APC 4


FUEL BURNING NON-PROCESS EQUIPMENT


2. Stack ID or flow diagram point identification (s):

FUEL BURNING EQUIPMENT DESCRIPTION

3. List all fuel burning equipment that is at this fuel burning installation (please complete an APC 4 form for each piece of fuel burning equipment).

4. Fuel burning equipment identification number:

5. Fuel burning equipment description:

6. Year of installation or last modification of fuel burning equipment. 7. Furnace type: 8. Manufacturer model number (if available):

9. Location of this fuel burning installation in UTM coordinates: UTM Vertical: _______________ UTM Horizontal: ________________

10. Normal operating schedule:_______ Hrs./Day ________ Days/Wk.________ Days/Yr.

FUELS, CONTROLS, AND MONITORING DESCRIPTION

11. Maximum rated heat input capacity (in million BTU/Hour)

12. If wood is used as a fuel, specify the amount of wood used as a fraction of total heat input.

13. Fuels: Primary fuel Backup fuel #1 Backup fuel #2 Backup fuel #3

Fuel name

Actual yearly consumption

14. If emissions from this fuel burning equipment are controlled for compliance, please specify the type of control:

15. If emissions from this fuel burning equipment are monitored for compliance, please specify the type of monitoring:

16. Describe any fugitive emissions associated with this process, such as outdoor storage piles, open conveyors, material handling operations, etc. (please attach a separate sheet if necessary).



5100S

Package Boilers No. 2 & 3

5100FA & 5100FB

No. 2 Package Boiler & No. 3 Package Boiler Natural Gas And No, 2 Fuel Oil 192 MM Btu/Hr each boiler Back-Up Low Volume High Concentration (LVHC) Gas Control Device

1970

N/a Babcock and Wilcox

3993.393 415.966

24 1 30

192 per boilerN/A

No. 2 Fuel Oil (curtailment only)Natural Gas

135,900 MCF 0

N/a

Log hours of operation.

N/A

12

No. 2 package Boiler

5100FA

No. 3 Package Boiler

5100FB

5100S

Natural GasNo. 2 Fuel Oil

Air to Boiler

NCG’s from LVHC Collection System

(Figure 7)

Air to Boiler

Stack Vent =

Process Flow =

Fugitive Emission =

Process =

Control Device =

Figure 3: Package Boiler (43-0010-02)

Page 13

CN – 1400 RDA 1298


APC 3


STACK IDENTIFICATION


1. Facility name:

2. Emission source (identify):

STACK DESCRIPTION

3. Stack ID (or flow diagram point identification):

4. Stack height above grade in feet:

5. Velocity (data at exit conditions): ___________________ (Actual feet per second)

6. Inside dimensions at outlet in feet:

7. Exhaust flow rate at exit conditions (ACFM):

8. Flow rate at standard conditions (DSCFM):

9. Exhaust temperature: ___________________ Degrees Fahrenheit ( F)

10. Moisture content (data at exit conditions): Grains per dry standard cubic __________ Percent __________ foot (gr./dscf.)

11. Exhaust temperature that is equaled or exceeded during ninety (90) percent or more of the operating time ( for stacks subject to diffusion equation only): ________________________ ( F )

12. If this stack is equipped with continuous pollutant monitoring equipment required for compliance, what pollutant(s) does this equipment monitor (e.g., Opacity, SO2, NOx, etc.)?

Complete the appropriate APC form(s) 4, 5, 7, 8, 9, or 10 for each source exhausting through this stack.

BYPASS STACK DESCRIPTION

13. Do you have a bypass stack? ________ Yes ________ No If yes, describe the conditions which require its use & complete APC form 4 for the bypass stack. Please identify the stack n umber(s) of flow diagram point

number(s) exhausting through this bypass stack.



43-0010-02 Back-Up Oxidizer, LVHC Gas Oxidizer (No.2/Boiler Only)

5100S

121.0

34.0 3.0

50,400 32,000

269 14.1 N/A

n/a

n/a

X

14

CN- 1414 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 19


COMPLIANCE CERTIFICATION - MONITORING AND REPORTING

DESCRIPTION OF METHODS USED FOR DETERMINING COMPLIANCE All sources that are subject to 1200-03-09-.02(11) of the Tennessee Air Pollution Control Regulations are required to certify compliance with all applicable requirements by including a statement within the permit application of the methods used for determining compliance. This statement must include a description of the monitoring, recordkeeping, and reporting requirements and test methods. In addition, the application must include a schedule for compliance certification submittals

during the permit term. These submittals must be no less frequent than annually and may need to be more frequent if specified by the underlying applicable requirement or the Technical Secretary.


1. Facility name: 2. Process emission source, fuel burning installation, or incinerator (identify):

3. Stack ID or flow diagram point identification(s):

METHODS OF DETERMINING COMPLIANCE

4. This source as described under Item #2 of this application will use the following method(s) for determining compliance with applicable requirements (and special operating conditions from an existing permit). Check all that apply and attach the appropriate form(s)

______ Continuous Emission Monitoring (CEM) - APC 20 Pollutant(s):

____________________________________________________________________________

______ Emission Monitoring Using Portable Monitors - APC 21 Pollutant(s):

____________________________________________________________________________

______ Monitoring Control System Parameters or Operating Parameters of a Process - APC 22 Pollutant(s):

____________________________________________________________________________

______ Monitoring Maintenance Procedures - APC 23 Pollutant(s):

____________________________________________________________________________

______ Stack Testing - APC 24

Pollutant(s):

____________________________________________________________________________

______ Fuel Sampling & Analysis (FSA) - APC 25

Pollutant(s):

____________________________________________________________________________

______ Recordkeeping - APC 26

Pollutant(s):

____________________________________________________________________________

______ Other (please describe) - APC 27

Pollutant(s):

____________________________________________________________________________

5. Compliance certification reports will be submitted to the Division according to the following schedule:

Start date: _______________________________________________________________________________________ And every ______ days thereafter.

6. Compliance monitoring reports will be submitted to the Division according to the following schedule: Start date: _______________________________________________________________________________________

And every ______ days thereafter.



43-0010-02 Package Boilers 2 and 3- 5100FA, 5100FB

5100S

Operating Log

Opacity

Ongoing

365

15

✔

✔

CN- 1421 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 26


COMPLIANCE DEMONSTRATION BY RECORDKEEPING Recordkeeping shall be acceptable as a compliance demonstration method provided that a correlation between the parameter value recorded and the applicable

requirement is established.


1. Facility name:



MONITORING AND RECORDKEEPING DESCRIPTION

4. Pollutant(s) or parameter being monitored:

5. Material or parameter being monitored and recorded:

6. Method of monitoring and recording:

7. Compliance demonstration frequency (specify the frequency with which compliance will be demonstrated):


Hood Container Corporation, New Johnsonville, TN 5100S

43-0010-02 Package boilers No. 2 and 3

Operating hours

Operating hours

Once per permit term

16

Log of boiler operating hours for each operating condition: stand-by and back-up.

CN- 1422 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 27


COMPLIANCE DEMONSTRATION BY OTHER METHOD(S)


1. Facility name:



MONITORING DESCRIPTION


5. Description of the method of monitoring:




43-0010-02 Package Boilers 2 and 3

Opacity

N/A

17

Visible emissions will be addressed utilizing TDEC's Opacity Decision Tree .

CN- 1423 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 28


EMISSIONS FROM PROCESS EMISSION SOURCE / FUEL BURNING INSTALLATION / INCINERATOR


1. Facility name:


3. Process emission source / Fuel burning installation / Incinerator (identify):

EMISSIONS SUMMARY TABLE – CRITERIA AND FUGITIVE EMISSIONS

4. Complete the following emissions summary for regulated air pollutants. Fugitive emissions shall be included. Attach calculations and emission factor references.

Maximum Allowable Emissions Actual Emissions

Air Pollutant


(Pounds per Hour - Item 7, APC 30 )


(Pounds per Hour- Item 8, APC 30 )

Particulate Matter ( TSP )

( Fugitive Emissions )

Sulfur Dioxide


Volatile Organic

Compounds


Carbon Monoxide


Lead


Nitrogen Oxides




Mercury




5.844

Included Above

0.374

Included Above

.0408

Included Above

1.032

Included Above

1.98

70.50

0.75

Included Above

11.39

Included Above

0.001

Included Above

38.02

Included Above

Included Above

Included Above

3.4E-5

Included Above

21.43

Included Above

43-0010-02 Package Boilers 2 and 3

CN- 1423 RDA 1298

APC 28 ( Continued from last page )


AIR POLLUTANT





Asbestos


Beryllium


Vinyl Chloride


Fluorides


Gaseous Fluorides



EMISSIONS SUMMARY TABLE – FUGITIVE HAZARDOUS AIR POLLUTANTS

5. Complete the following emissions summary for regulated air pollutants that are hazardous air pollutant(s). Fugitive emissions shall be included. Attach calculations and emission factor references.


Air Pollutant & CAS





6. Page number: Revision number: Date of revision

Total 112(b) HAPs N/A 0.01

19

CN- 1425 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 30




1. Facility name:









emissions


( In/Out )



Hood Container Corporation, New Johnsonville, TN 43-0010-02 Package Boilers No.2 & No. 3

Package Boilers No. 2 and No. 3 Natural Gas or No.2 Fuel Oil fired boilers with a heat input rating of 192 mmBTU/hr (produces process steam and also a back up to LVHC incineration)

Hours of operation43-0010-02

Opacity43-0010-02

43-0010-02

43-0010-02 SO2

6000 hrs total both boilers during 12 month period

20% opacity

1200-3-9-.01(4)

1200-3-5-.03(6)

TAPCR 1200-3-6-.02(1) & 1200-3-9-.01(4) PM

TAPCR 1200-3-19-14(1)(b)(5)

8.23 TPY

29.21 TPY 0.041 TPY

IN0.13 TPY

IN1658 hrs

IN<20%

IN0.4 TPY

IN

43-0010-02

43-0010-02

43-0010-02

43-0010-02

43-0010-02

VOC TAPCR 1200-03-26-.02(2)(d)3 3.1 TPY (rolling)

NOx TAPCR 1200-03-26-.02(2)(d)3 171 TPY (rolling)

Sulfuric Acid Mist TAPCR 1200-03-26-.02(2)(d)3

SO2 TAPCR 1200-3-14-.01(3)

NOx TAPCR 1200-3-6-.01(7) 7.43 lb/hr; 5.3 TPY while burning NCG

8.27 lb/hr; 6 TPY while burning NCG

1.5 TPY (rolling)

21.4 TPY IN

<1.5 TPY

0

0

IN

IN

IN

20

CN- 1425 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 30




1. Facility name:









emissions


( In/Out )



Hood Container Corporation, New Johnsonville, TN 43-0010-02 Package Boilers No.2 & No. 3

Package Boilers No. 2 and No. 3 Natural Gas or No.2 Fuel Oil fired boilers with a heat input rating of 192 mmBTU/hr (produces process steam and also a back up to LVHC incineration)

N/A43-0010-02

N/A43-0010-02

43-0010-02

43-0010-02 CO

Annual boiler tune up

Notification Compliance Status Report

40 CFR 63 Subpart DDDDD

40 CFR 63 Subpart DDDDD

TAPCR 1200-03-09-.01(4)Fuel oil

TAPCR 1200-3-6-.01(7)

8.23 million gallons per 12 months

2.33 lb/hr; 1.7 TPY while burning NCG <2.33 lb/hr; <1.7 tpy

INN/A

INN/A

INN/A

IN

21

CN – 1401 RDA 1298


APC 4


FUEL BURNING NON-PROCESS EQUIPMENT



FUEL BURNING EQUIPMENT DESCRIPTION

3. List all fuel burning equipment that is at this fuel burning installation (please complete an APC 4 form for each piece of fuel burning equipment).

4. Fuel burning equipment identification number:

5. Fuel burning equipment description:

6. Year of installation or last modification of fuel burning equipment. 7. Furnace type: 8. Manufacturer model number (if available):

9. Location of this fuel burning installation in UTM coordinates: UTM Vertical: _______________ UTM Horizontal: ________________


FUELS, CONTROLS, AND MONITORING DESCRIPTION

11. Maximum rated heat input capacity (in million BTU/Hour)

12. If wood is used as a fuel, specify the amount of wood used as a fraction of total heat input.

13. Fuels: Primary fuel Backup fuel #1 Backup fuel #2 Backup fuel #3

Fuel name

Actual yearly consumption

14. If emissions from this fuel burning equipment are controlled for compliance, please specify the type of control:

15. If emissions from this fuel burning equipment are monitored for compliance, please specify the type of monitoring:

16. Describe any fugitive emissions associated with this process, such as outdoor storage piles, open conveyors, material handling operations, etc. (please attach a separate sheet if necessary).



43-0010-07

Refuse Boiler

5000F

Spreader-stoker wood refuse boiler, wood refuse, ammonium sulfite spent liquor, primary sludge, old corrugated container (OCC) rejects, Natural gas and no. 2 fuel oil, 527 mm Btu/hr Primary low volume high concentration (LVHC) gas control device Venturi/tray type absorption scrubber

1979

Spreader-Stoker Babcock and Wilcox Co.

3993.393 415.966

24 7 365

Natural Gas No. 2 Fuel OilWood Refuse,

Ammonia Base Liquor, Sludge, OCC Rejects

1,989,246 MMBtu 669,804 MMBtu

2,659,050 MMBtu 202,711 MCF 45,214 Gal

Dust Collector and High Efficiency Venturi scrubber followed by tray type absorption scrubber

Sulfur Dioxide and opacity continuous emissions monitor.

Purchased wood refuse unloading, hogging and screening, conveying, storage piles, and storage pile reclaim.

22

Purchased Wood Refuse

Unloading

Wood Refuse Hogging & Screening

Wood Refuse Storage Piles

Reclaim Hoppers

Wood Refuse Boiler5100F

Dust Collector

Venturi Scrubber

Pre-Scrubber Pre-Cooler

Loaded Wood Refuse Truck

Rejects from Woodyard(Figure 2)

OCC Rejects

Dewatered Sludge from Waste Treatment(Figure 9)

Ash to Waste Treatment(Figure 9) Natural Gas

Fuel Oil

Spent Heavy Liquor from

Pulp Mill

Water

Anhydrous Ammonia

Water & Ammonia to Wastewater Treatment

To Package Boiler No. 2 as Backup

(Figure 3)

NCG Gases from LVHC Collection

System(Figure 7)

5000S

Stack Vent =

Process Flow =

Fugitive Emission =

Process =

Control Device =

Figure 4: Wood Refuse Boiler (43-0010-07)

Page 23

Absorber

ESP

Water

Anhydrous Ammonia

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION

















43-0010-07 wood refuse boiler, dust collector, LVHC gas oxidizer, venturi type absorption scrubber Plus ESP

5000S

130.0

33 10.7

176,000 113,000

149 25 N/A

n/a

SO2,O2

x

24

CN- 1403 RDA 1298


APC 6


STORAGE TANKS


2. Process emission source (identify):

STORAGE TANK DESCRIPTION

3. Storage tank identification: 4. Location of the storage tank or tank farm in UTM coordinates: UTM Vertical: ____________ UTM Horizontal: ____________

5. Storage tank capacity: (Gallons)

6. Year of installation: 7. Tank height (Feet)

8. Tank diameter: (Feet)

9. Color of tank: ________ White ________ Other Specify______________________________________________________________

10. Is this tank equipped with a submerged fill pipe? ________ Yes ________ No 11. Type of storage tank: ________Open top tank ________Fixed roof ________Fixed roof w/internal floating roof ________Other (specify) ________Pressurized tank ________External floating roof ________Variable vapor space _______________________ 12. For fixed roof tanks: A. Tank configuration (check one):: ________Vertical (upright cylinder) ________Horizontal B. Tank roof type: ________Cone roof – indicate tank roof height ________(ft) (check one) ________Dome roof – indicate tank roof height ________(ft) Indicate shell radius________(ft)

FLOATING ROOF TANK DESCRIPTION

13. For Floating Rook tanks (both internal and external) – shell condition (check one): ________ Light rust ________ Dense rust ________ Gunite lined

14. For External Floating Roof tanks: A. Tank construction (check one): ________ Welded tank ________ Riveted tank B. Rim Seal system description (check one): _____Shoe Mounted Primary _____Vapor Mounted Primary _____Liquid Mounted Primary _____Shoe Primary, Rim Secondary _____Vapor Primary, Rim Secondary _____Liquid Primary, Rim Secondary _____Liquid Primary w/Weather Shield _____Shoe Primary and Secondary _____Vapor Primary w/Weather Shield C. Roof type (check one): : ________ Pontoon roof ________ Double Deck roof D. Roof fitting types (indicate the number of each type): Access Hatch (24” Diameter well) Unslotted Guide-Pole Well Gauge-Float Well (20” Diameter) _____Bolted cover, gasketed (8” Diameter Unslotted Pole, 21” Dia. Well) _____Unbolted cover, ungasketed _____Unbolted cover, gasketed _____Ungasketed sliding cover _____Unbolted cover, gasketed _____Unbolted cover, ungasketed _____Gasketed sliding cover _____Bolted cover, gasketed Gauge-Hatch/Sample Well (8” Dia.) Vacuum Breaker (10” Dia. Well) Roof Drain _____Weighted Mechanical _____Weighted Mechanical _____Open Actuation Gasketed Actuation Gasketed _____ Weighted Mechanical _____ Weighted Mechanical _____ 90% Closed Actuation Ungasketed Actuation Ungasketed Slotted Guide-Pole/Sample Well Roof Leg (3” Dia.) Roof Leg (2 ½” Dia.) (8” Slotted Pole, 21” Dia. Well) _____Adjustable, Pontoon area _____Adjustable, Pontoon area _____Ungasketed Sliding Cover, without Float _____Adjustable, Center area _____Adjustable, Center area _____Ungasketed Sliding Cover, with Float _____Adjustable, Double-Deck roofs _____Adjustable, Double-Deck roofs _____Gasketed Sliding Cover, without Float _____Fixed _____Fixed _____ Gasketed Sliding Cover, with Float


No. 2 Fuel Oil Storage

5210T No. 2 Fuel oil Tank

3993.393 415.966

1970

x Grey

x

x

X

X 1.320.5

300,000 31 41

CN- 1403 RDA 1298

APC 6

15. For Internal Floating Roof tanks: A. Rim Seal system description: _____ Liquid Mounted Primary _____ Liquid Mounted Primary plus Secondary Seal _____ Vapor Mounted Primary _____ Vapor Mounted Primary plus Secondary Seal B. Number of Columns: _______ D. Deck Type (check one): _____ Welded _____ Bolted C. Effective Column diameter: _______ (Feet) E. Total Deck Seam length: __________ (Feet) F. Deck Area: ________________ (Square Feet) G. Deck Fitting types (indicate the number of each type): Access Hatch (24” Dia.) Automatic Gauge Float Well Column Well _____ Bolted cover, gasketed _____ Bolted cover, gasketed ____ Built-up Column-Sliding cover, gasketed _____ Unbolted cover, gasketed _____ Unbolted cover, gasketed ____ Built-up Column-Sliding cover, ungasketed _____ Unbolted cover, ungasketed _____ Unbolted cover, ungasketed ____ Pipe Column-Flexible fabric sleeve seal ____ Pipe Column-Sliding cover, gasketed ____ Pipe Column-Sliding cover, ungasketed Ladder well Sample Pipe and Well Roof Leg or Hanger Well _____ Sliding cover, gasketed _____ Slotted Pipe-Sliding cover, gasketed _____ Adjustable _____ Sliding cover, ungasketed _____ Slotted Pipe-Sliding cover, ungasketed _____ Fixed _____ Sample Well-Slit fabric seal, 10% open area _____ Stub Drain, 1 inch diameter Vacuum Breaker _____ Weighted Mechanical Actuation, gasketed _____ Weighted Mechanical Actuation, ungasketed

16. For variable vapor space tanks: Volume expansion capacity______________________ (Gallons)

TANK CONTENTS AND OPERATION DESCRIPTION

17. Complete the flowing table for materials to be stored in this tank:

Material or component stored

Wt. %

Material Annual Throughput (Gal./Yr.)

Material stored Daily Average (Gallons)

Component Molecular weights (Lb./Lb. Mole)

Component Vapor Pressures (PSIA)

Material storage pressure( PSIA )

Material average storage temp. (Deg. F)

Multipurpose tank with variable composition: ________ Yes ________ No 18. Describe the operation this tank will serve:


100 9,125 138,000 Unknown 0.008 Atm

X

26

No. 2 Fuel Oil Ambient

No.2 fuel oil storage for fuel burning installation.

CN- 1403 RDA 1298


APC 6


STORAGE TANKS














No. 2 Fuel Oil Storage

5220T No.2 Fuel Oil Tank3993.393 415.966

1974X Grey

X

X

XX 1.3

20.5

300,000 31 41

CN- 1403 RDA 1298

APC 6






Wt. %









100 9,125 138,000 Unknown 0.008 Atm

X

28

No. 2 Fuel Oil Ambient

CN- 1411 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 15


CONTROL EQUIPMENT - CYCLONES/SETTLING CHAMBERS


1. Facility name: 2. Emission source (identify):


CYCLONE/SETTLING CHAMBER DESCRIPTION

4. Describe the device in use. List the key operating parameters of this device and their normal operating range.

5. List of pollutants (s) to be controlled and the expected control efficiency for each pollutant.

Pollutant Efficiency (%) Source of data

6. Discuss how collected material is handled for reuse or disposal.

7. Gas flow rate (ACFM):

8. If this control equipment is in series with some other control equipment, state and specify the overall efficiency.


Hood Container Corporation, New Johnsonville, 1N 43-0010-07 Wood Refuse Boiler Dust Collector

5000S

60

Collected material to ash ponds.

175,000

Equipment operated in series: Dust Collector, Venturi/Tray Type Absorption Scrubber plus ESP Overall Particulate Matter Control Efficiency:> 95 %

29

Medium efficiency settling chamber (mechanical dust collector).

Particulate Matter Vendor

CN- 1412 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 17


CONTROL EQUIPMENT - WET COLLECTION SYSTEMS




WET COLLECTION SYSTEM DESCRIPTION

4. Describe the device in use. List the key operation parameters of this device and their normal operating range.

5. Manufacturer and model number (if available): 6. Year of installation:

7. List of pollutant (s) to be controlled and the expected control efficiency for each pollutant.


8. Discuss how collected material and effluent is handled for reuse or disposal..

9. Scrubbing medium (water, sodium hydroxide slurry, etc.):



Hood Container Corporation, New Johnsonville, TN 413-0010-07 Refuse Boiler 413-0010-02 Package Boiler No.2

NCG Gas Pre-scrubber

Lundberg 2001

93

Effluent from the scrubber will be routed to the mill's wastewater treatment system. The scrubbed gas stream will be routed to the refuse boiler (primary device) or one of the two package boilers (secondary devices).

90

Water

30

The device is a wet scrubber used to remove so2 & nitrogen-bearing compounds from the mill’s collected LVHC stream. The scrubber is being installed as part of the LVHC collection· system in order to protect the metallurgy of the boilers. The scrubber will also remove any soluble organic compounds found in the LVHC stream.

SO2 (as sulfur)

VOC (soluble)

Engineering Design

Estimate

CN- 1412 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 17


CONTROL EQUIPMENT - WET COLLECTION SYSTEMS




WET COLLECTION SYSTEM DESCRIPTION

4. Describe the device in use. List the key operation parameters of this device and their normal operating range.

5. Manufacturer and model number (if available): 6. Year of installation:

7. List of pollutant (s) to be controlled and the expected control efficiency for each pollutant.


8. Discuss how collected material and effluent is handled for reuse or disposal..

9. Scrubbing medium (water, sodium hydroxide slurry, etc.):



Hood Container Corporation, New Johnsonville, TN 43-0010-07 Wood Refuse Boiler Venturi Scrubber

5000S

Air Pol 1978

95

Effluent recycled to scrubber & bleed lines to ash ponds.

90

Ammonia, Water

Equipment In Series: Mechanical Dust Collector, Venturi/Tray Type Absorption Scrubber Overall Particulate Matter Control Efficiency:> 95%

31

High Efficiency Venturi/Tray Type Absorption Wet Scrubber Venturi Pressure Differential: 15 -16 in.

Particulate Matter

Sulfur Dioxide

Vendor

Vendor

CN- 1414 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 19











____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________







43-0010-07 Refuse Boiler

5000S

SO2, O2, NCG flow rate to boiler

Particulate CO

Opacity

Ongoing

365

32

✔

✔

✔

CN- 1415 RDA 1298


APC 20


COMPLIANCE DEMONSTRATION BY CONTINUOUS EMISSIONS MONITORING



3. Process emission source or fuel burning installation or incinerator:

MONITOR DESCRIPTION

4. Description of equipment monitoring pollutant: Pollutant being monitored: _______________________________ 4A. Name of Manufacturer:

4B. Model number:

4C. Installation year

4D. Type: ______In situ ______Extractive ______Dilution ______Other (Specify): __________________

4E. Describe how the monitor works:

5. Description of equipment monitoring diluent: Diluent being monitored: _______________________________ 5A. Name of manufacturer:

5B. Model number:


5D. Type: ______In situ ______Extractive ______O2 ______CO2 ______Other (Specify): _______________

5E. Describe how the monitor works:

6. Description of equipment monitoring flow: Amount of flow (DSCFM): _______________________________ 6A. Name of manufacturer:

6B. Model number:


6D. Type: ______ Differential pressure ______ Thermal ______ Other (Specify): __________________

7. Opacity (or use of visible emission evaluations in lieu of opacity monitoring) 7A. Indicate which is used. * For “Visible emission evaluation” choice, procedures will be specified as a condition in the ______ Monitor ______ Visible emission evaluations* source’s operating permit.

7B. Opacity monitor (state the name of manufacturer, model number, and year of installation):



5000S 43-0010-07 Wood Refuse Boiler

Graesby - STI

Sulfur dioxide APE I SO Oxygen servomax

1992

Clean Instrument Air

Quartz orifice

1992

Orifice Plate (Checked Annually With Flow Meter)

TBD

33

✔

✔

CN- 1419 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 24


COMPLIANCE DEMONSTRATION BY STACK TESTING The performance of an appropriate EPA stack test method for demonstrating compliance with an emission limitation has always been acceptable. EPA test methods

contain quality assurance procedures that shall be strictly adhered to by the source.


1. Facility name:



STACK TESTING DESCRIPTION

4. Pollutant(s) being monitored:

5. Test method:




5000S


Particulates

Once per permit term

34

Particulate: EPA Method 5 CO: EPA Method 10

CN- 1422 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 27




1. Facility name:










Opacity

TBD

35

Visible Emissions-will be addressed utilizing TDEC's opacity decision tree

CN- 1423 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 28




1. Facility name:






Air Pollutant







Sulfur Dioxide


Volatile Organic

Compounds


Carbon Monoxide


Lead


Nitrogen Oxides




Mercury




486

Included Above

11.1

Included Above

27.80

Included Above

37

Included Above

85.4

462

30.8

Included Above

3,065

Included Above

Included Above

692

Included Above

Included Above

341

Included Above

43-0010-07 Wood Refuse Boiler and No. 2 Fuel Oil Storage

CN- 1423 RDA 1298



AIR POLLUTANT





Asbestos


Beryllium


Vinyl Chloride


Fluorides


Gaseous Fluorides






Air Pollutant & CAS






342,609 MT 15,296 MT

Total 112(b) HAPs n/a 0.32

37

CN- 1425 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 30




1. Facility name:









emissions


( In/Out )



Hood Container Corporation, New Johnsonville, TN 43-0010-07 Wood Refuse Boiler

The Wood Refuse Boiler is the main generator of process steam for the facility and burns bark, black liquor, gas and oil and is also the primary device for incineration of NCG gases. The unit is rated at 527 mmBTU/hr

SO2Boiler

OpacityBoiler

Boiler

Boiler N/A

0.2 lb/MMBtu; 105.4 lb/hr

20% opacity for 6 min

TAPCR 1200-3-9-.01(4), 40 CFR Subpart D.

TAPCR 1200-3-16-(6)(g)1

TAPCR 1200-3-16-.02(5)(a), 40CFR60.44NOx

TAPCR 1200-03-16-.02(3)(a)1

0.3 lb/mmBTU; 692.5 TPY

Maintain log when ammonium sulfite is burned N/A

INN/A

IN129 TPY

INN/A

IN0.24 lb/mmBTU

IN

Boiler

Boiler

Boiler

Boiler

Boiler

SO2 TAPCR 1200-03-10-.02(1)(a) Monitoring System

SO2 TAPCR 1200-03-10-.02(1)(a) Quality Assurance

SO2 TAPCR 1200-03-10-.02(2), 1200-03-09-.02(11)(e)1(iii)

SO2 TAPCR 1200-03-10-.02(2), 1200-03-09-.02(11)(e)1(iii)

N/A 40 CFR 63 Subpart S Incineration of LVHC NCG

N/A

Semiannual Reports

N/A IN

N/A

N/A

N/A

IN

IN

IN

38

CN- 1425 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 30




1. Facility name:









emissions


( In/Out )



Hood Container Corporation, New Johnsonville, TN 43-0010-07 Wood Refuse Boiler

The Wood Refuse Boiler is the main generator of process steam for the facility and burns bark, black liquor, gas and oil and is also the primary device for incineration of NCG gases. The unit is rated at 527 mmBTU/hr

NOxBoiler

SO2Boiler

Boiler

Boiler VOC, HAP

7.3 lb/hr due to burning NCG

0.83 lb/hr due to burning NCG

TAPCR 1200-3-14-.01(3)

TAPCR 1200-3-14-.01(3)

TAPCR 1200-03-09-.02(11)(e)1.(iii)Fuel

TAPCR 1200-03-26-.02(2)

1000 gal/month

30.8 TPY, 20.3 TPY 11.2, N/A

INN/A

INN/A

INN/A

IN0 gal/month

IN

Boiler

Boiler

Boiler

Boiler

Boiler

CO TAPR 1200-3-14-.01(3) 2.33 lb/hr due to burning NCG

HCl 40 CFR 63 Subpart DDDDD 0.022 lb/mmBTU

Mercury 40 CFR 63 Subpart DDDDD

Fuel Oil TAPCR 1200-3-9-.01(4)

N/A 40 CFR 63 Subpart DDDDD OPC Limits

8.23 million gallons per 12 months

5.7E-06 lb/mmBTU

22 TPY IN

.006 TPY

N/A

Within Limits

IN

IN

IN

39

CN- 1407 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 10


MISCELLANEOUS PROCESSES


1. Facility name:


3. Stack ID or flow diagram point identification (s): 4. Year of construction or last modification:

If the emissions are controlled for compliance, attach an appropriate Air Pollution Control system form.


6. Location of this process emission source in UTM coordinates: UTM Vertical : ____________ UTM Horizontal: ____________ 7. Describe this process (Please attach a flow diagram of this process) and check one of the following: ________ Batch________ Continuous

PROCESS MATERIAL INPUT AND OUTPUT

8. List the types and amounts of raw materials input to this process:

Material Storage/Material handling process Average usage (units) Maximum usage (units)

9. List the types and amounts of primary products produced by this process:


10. Process fuel usage:

Type of fuel Max heat input (106 BTU/Hr.) Average usage (units) Maximum usage (units)

11. List any solvents, cleaners, etc., associated with this process:

If the emissions and/or operations of this process are monitored for compliance, please attach the appropriate Compliance Demonstration form.

12. Describe any fugitive emissions associated with this process, such as outdoor storage piles, open conveyors, open air sand blasting, material handling operations,

etc. (please attach a separate sheet if necessary).



43-0010-08 Cooking Liquor Preperation System

2010S- Cooking Liquor Preparation System 1970

24 7 365

3393.393 415.966

Railcar & Truck Unloading, Storage Tank

Railcar & Truck Unloading, Storage Tank 1.14 TPY

Storage Tanks

Storage Tank 19,955,168 GPY

N/a N/a

None

None

40

✔

Sulfur Dioxide

Ammonia

Water

Virgin Cooking Liquor

None N/a

Sulfur BurnerGas

CoolerAbsorption

System

Cooking Liquor

StorageSulfur Storage

Sulfur from Trucks or Railcars

Water Treatment

Fresh Water & NCG Pre-

Scrubber Water

2010S

AmmoniaStorage

Ammonia Unloading

Truck

Water

Stack Vent =

Process Flow =

Fugitive Emission =

Process =

Control Device =

Figure 5: Cooking Liquor Preparation (43-0010-08)

Page 41

CN- 1403 RDA 1298


APC 6


STORAGE TANKS














43-0010-08 Cooking Liquor Prep. System

2010T-Molten Sulfur Tank3993.393 415.966

1996X Grey

X

X

XX Unknown

8.5

34,000 20 17

CN- 1403 RDA 1298

APC 6






Wt. %









100 505,913 18,678 Unknown 0.11 @284F Atmospheric

X

43

Sulfur 280

Molten sulfur storage for cooking liquor plant.

CN- 1403 RDA 1298


APC 6


STORAGE TANKS













Hood Container Corporation43-0010-08 Cooking Liquor Prep. System

2020 T -Anhydrous Ammonia Storage Tank

3993.393 415.966

1970

X

X

X

30,000 68.33 9

CN- 1403 RDA 1298

APC 6






Wt. %









100 1,212,186 22,200 17.03 94 psig@ 60 125 psig

X

45

Anhydrous Ammonia 60

Ammonia storage for cooking liquor plant and sulfur dioxide scrubbing for refuse boiler.

CN- 1403 RDA 1298


APC 6


STORAGE TANKS














2025 T-Anhydrous Ammonia Storage Tank

3993.393 415.966

1970

X

X

X

30,000 68.33 9

CN- 1403 RDA 1298

APC 6






Wt. %









100 1,212,186 22,200 17.03 94 psig@ 60 125 psig

X

47

Anhydrous Ammonia 60

Ammonia storage for cooking liquor plant and sulfur dioxide scrubbing for refuse boiler.

CN- 1403 RDA 1298


APC 6


STORAGE TANKS














2030 T-Cooking Liquor Tank

3993.393 415.966

1970

X Grey

X

X

X

X Unkown12

50,000 16 24

CN- 1403 RDA 1298

APC 6






Wt. %









100 13,008,600 38,916 Unknown Unknown Ahnospheric

X

49

Cooking Liquor 110

Cooking liquor storage for cooking liquor plant.

CN- 1414 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 19











____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________








2010S

Sulfur Dioxide

Opacity

Ongoing

365

50

✔

✔

CN- 1422 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 27




1. Facility name:









43-0010-08 Cooking Liquor Preparation System

Opacity

TBD Using Opacity Decision Tree

51

Visible emissions will be addressed utilizing TDEC's opacity decision tree.

CN- 1423 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 28




1. Facility name:






Air Pollutant







Sulfur Dioxide


Volatile Organic

Compounds


Carbon Monoxide


Lead


Nitrogen Oxides




Mercury




Included Above

1.146.48

Included Above


CN- 1423 RDA 1298



AIR POLLUTANT





Asbestos


Beryllium


Vinyl Chloride


Fluorides


Gaseous Fluorides






Air Pollutant & CAS






53

CN- 1425 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 30




1. Facility name:









emissions


( In/Out )



Hood Container Corporation, New Johnsonville, TN 43-0010-08 Cooking Liquor Prep

In this process area cooking liquor is prepared for the digester using sulfur and ammonia

OpacityScrubber

Scrubber

Scrubber SO2

20% in 5 minutesTAPCR 1200-3-5-.01

TAPCR 1200-3-9-.01(4)SO2

TAPCR 1200-3-19-.14(1)( c)(7) & 1200-3-26.02(2)(d)(3)

6.48 TPY

100 ppm <100 ppm

INN/A

IN1.14 TPY

IN

54

CN- 1407 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 10




1. Facility name:




















4010S, 4020S, 4030S1-3, 4040S1-3, 4045S1-5 1990

24 7 365

3993.393 415.966

104,848 TPY

131,956 TPY

256,726 TPY (875 TPD)

N/a N/a

Polymers, Wetting Agents, Felt Cleaners, Kerosene (Hand Application)

None

55

✔

NSSC Pulp

Recycle Pulp

176,500 BDTPY

230,640 TPY

Paper 319,375 TPY (1,300 TPD)

None N/a

Blend ChestTickler

RefinersMachine

ChestPrimary Screen

HeadboxFourdrinier

Wet EndPresses

Vacuum Trench

Wet End Pulper

Saveall

Broke Chest

Dry End Pulper

DryersReelRewinderPaper to Shipping

4030S1 – 4030S3

4045S1 – 4045S5

4040S1-4040S3

4020S

4010S

Pulp from NSSC

(Figure 7)

Pulp from Recycle

(Figure10)

Stack Vent =

Process Flow =

Fugitive Emission =

Process =

Control Device =

Figure 6: Paper Machine (43-0010-10)

Page 56

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION

















43-0010-10 Paper Machine Fourdrinier Wet End

4010S

67.0

35.4 5.0

695.0

114 7 22

N/a

N/a

X

57

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION

















43-0010-10 Paper Machine Fourdrinier Wet End

4020S

66.0

21.0 4.0

264.0

114 unknown unknown

n/a

n/a

X

58

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION

















43-0010-10 Paper Machine Dryers

4030S1

41.2

50.9 5.0

999.0

133 6 18

n/a

n/a

X

59

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















4030S2

41.2

50.9 5.0

999.0

133 6 18

N/a

n/a

X

60

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















4030S3

41.2

50.9 5.0

999.0

133 6 18

n/a

n/a

X

61

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION

















43-0010-10 Paper Machine Wet End Roof Vent

4040S1

55.0

35.4 3.0

250.0

114 6.9

n/a

n/a

X

62

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















4040S2

55.0

35.4 3.0

250.0

114 6.9

n/a

n/a

X

63

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















4040S3

55.0

35.4 3.0

250.0

114 6.9

n/a

n/a

X

64

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION

















43-0010-10 Paper Machine Dry End Roof Vent

4045S1

55.0

35.4 3.0

250.0

114 6.9

n/a

n/a

X

65

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















4045S2

55.0

35.4 3.0

250.0

114 6.9

n/a

n/a

X

66

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















4045S3

55.0

35.4 3.0

250.0

114 6.9

N/A

N/A

X

67

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















4045S4

55.0

35.4 3.0

250.0

114 6.9

N/A

N/A

X

68

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















4045S5

55.0

35.4 3.0

250.0

114 6.9

N/A

N/A

X

69

CN- 1414 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 19











____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________








4010S, 4020S, 4030S1-3, 4040S1-3, 4045S1-5

N/a

N/a

N/a

N/a

N/a

N/a

N/a

Opacity

Ongoing

365

70

✔

CN- 1422 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 27




1. Facility name:








Hood Container Corporation, New Johnsonville, TN 4010S, 4020S, 4030S1, 4030S2, 4030S3, 4030S4, 4030S5, 4030S6


Opacity

n/a

71


CN- 1423 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 28




1. Facility name:






Air Pollutant







Sulfur Dioxide


Volatile Organic

Compounds


Carbon Monoxide


Lead


Nitrogen Oxides




Mercury



Hood Container Corporation, New Johnsonville, TN 4010S, 4020S, 4030S1-3, 4040S1-3, 4045S1-5

Included Above

41.29101.3

Included Above


CN- 1423 RDA 1298



AIR POLLUTANT





Asbestos


Beryllium


Vinyl Chloride


Fluorides


Gaseous Fluorides






Air Pollutant & CAS






Total 112(b) HAPs N/a 78.69

73

CN- 1425 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 30




1. Facility name:









emissions


( In/Out )



Hood Container Corporation, New Johnsonville, TN 43-0010-10 Paper Machine

Paper Machine

VOC & HAP43-0010-10

OpacityStack Emissions

43-0010-10

43-0010-10 VOC

407,340 MDTPY

20% in 5 minutes

TAPCR 12000-3-9-.01(4)

TAPCR 1200-3-5-.01

TAPCR 1200-3-26-.02(2)(d)3HAP

TAPCR 1200-3-26-.02(2)(d)3

N/A

N/A 101.3 TPY

INN/A

IN386,052 MDTPY

IN<20%

IN97.9 TPY

IN

43-0010-10 VOC TAPCR 12000-3-9-.01(4) 41.95 lb/hr

74

CN- 1407 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 10




1. Facility name:




















2130SA, 2130SB, 2I40S, 2145S, 2160S 1970

24 7 365

3993.393 415.966

Railcar & Truck Unloading, Storage Tanks

Storage Bin

TPY

349,607 TPY

Storage Tanks

Storage Tanks

Storage Tanks

Storage Tanks/Chests

4.185 TPY

88.1 Gal/Yr

88.1 Gal/Yr

164,159 MDT/yr

N/a

Storage Tanks 15.8 MM Gal/yr x3 tanks

N/a

N/a

Equipment leaks.

75

✔

Wood Chips

Virgin Cooking Liquor

Anhydrous Ammonia

Weak Spent Liquor

470,412 TPY

96,378 TPY

4,599 TPY

102.6 Gal/Yr

NSSC Pulp

Weak Spent Liquor

Heavy Spent Liquor

177,500 TPY, 600 TPD

102.6 Gal/Yr

18.4 MM Gal/yr x3 tanks

None N/a

ImpregnatorContinuous Disgester

Primary Refiner

Blow TankChip Steaming

Vessel

Chips From Woodyard

Cyclone (Figure 2)

Fresh Water & NCG Pre-

Scrubber Water

Cooking Liquor Heater

Cooking Liquor from Cooking Liquor

Preparation System(Figure 5)

NCG Gases to LVHC Collection System &

Incineration (Figure 3 & 4)

Anhydrous Ammonia



Washers & Repulpers

Secondary Refiners

Filtrate Tanks

Weak Liquor Storage

(Figure 8)

NSSC Pulp to Paper Machine(Figure 6)

2130SA2130SB

2140S2145S

Stack Vent =

Process Flow =

Fugitive Emission =

Process =

Control Device =

Figure 7: NSSC Pulp Mill (43-0010-11)

Page 76

EvaporatorVacuum

CondenserBoil Out Tank

Steam Ejector

Weak Liquor Storage

From NSSC Pulp Mill(Figure 7)

Scale Inhibit Chemical

Cooling Water to Cooling

Tower

Cooling Water from Cooling

Tower



Hotwell

Water Reclaim Tank

To Blow Tank (Figure 7)

Water Treatment Plant

(Figure 9)

Steam


Incineration (Figure 8 & 9)2160S

To Chip Washer (Figure 2)

To Water Treatment (Figure 9)

Stack Vent =

Process Flow =

Fugitive Emission =

Process =

Control Device =

Figure 8: Black Liquor System (43-0010-06)

Page 77

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION

















43-0010-11 NSSC Pulp Mill Washers And Repulpers

2130SA

72.8

43.1 3.0

302.0

107.0 9.5 23

N/a

N/a

X

78

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















2130SB

72.8

43.1 3.0

302.0

107.0 9.5 23

N/a

N/a

X

79

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION

















43-0010-11 NSSC Pulp Mill No. I filtrate tank

2140S

16.9

16.8 0.5

170.0

189.0 50 146

N/a

N/a

X

80

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION

















43-0010-11 NSSC Pulp Mill No.2 filtrate tank

2145S

16.8

2.4 0.5

2.5

151.0 50 54

N/a

N/a

X

81

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















2160S

55

Unknown 2.0

Unknown Unknown

Unknown Unknown Unknown

N/a

N/a

X

82

CN- 1403 RDA 1298


APC 6


STORAGE TANKS














43-0010-11

2170T-Weak. Spent Liquor Tank

1970X Grey

X

X

X

X unkown

100,000 27 25

CN- 1403 RDA 1298

APC 6






Wt. %









100 88,128,000 51,408 unkown Unkown Atm

X

84

Weak Spent Liquor 180

Weak spent liquor storage for NSSC pulp mill evaporator set.

CN- 1403 RDA 1298


APC 6


STORAGE TANKS














43-0010-11

2180T Boil-Out Tank3993.393 415.966

1970

X Grey

X

X

X unknown

12,700 15 12

CN- 1403 RDA 1298

APC 6






Wt. %









100

3,500100

88,128,00 51,408

Unknown0

Unknown

1

Unknown atm

atm

X

86

Weak Spent Liquor 180

Boil-out Chemicals Ambient

Weak spent liquor and boil-out chemical feed tank for NSSC pulp mill evaporator set.

CN- 1403 RDA 1298


APC 6


STORAGE TANKS














43-0010-11

2210T- Product Liquor Tank3993.393 415.966

1970X Grey

X

X

X

X unknown

12,700 15 12

CN- 1403 RDA 1298

APC 6






Wt. %









100 15,695,000 43,600 Unknown Unkown atm

X

88

Spent Liquor 180

Spent liquor storage prior to disposal.

CN- 1403 RDA 1298


APC 6


STORAGE TANKS














43-0010-11

2220T- Heavy Spent Liquor Tank3993.393 415.966

1970X Grey

X

X

X

X 4.4

200,000 33 33

CN- 1403 RDA 1298

APC 6






Wt. %









100 15,695,000 43,600 Unknown Unknown atm

X

90

Heavy Spent Liquor 210

Heavy spent liquor storage prior to disposal.

CN- 1403 RDA 1298


APC 6


STORAGE TANKS














43-0010-11

2225T3993.393 415.966

1985X Grey

X

X

X

X 4.4

200,000 33 33

CN- 1403 RDA 1298

APC 6






Wt. %









100 15,695,000 43,600 Unknown Unknown atm

X

92

Heavy spent liquor 210

Heavy spent liquor storage prior to disposal.

CN- 1414 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 19











____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________








2130SA, 2130SB, 2140S, 2145S, 2160S

Opacity

Ongoing

365

93

✔

CN- 1422 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 27




1. Facility name:








Hood Container Corporation, New Johnsonville, TN 2130SA, 2130SB, 2140S, 2145S, 2160S


Opacity

TBA

94


CN- 1423 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 28




1. Facility name:






Air Pollutant







Sulfur Dioxide


Volatile Organic

Compounds


Carbon Monoxide


Lead


Nitrogen Oxides




Mercury



Hood Container Corporation, New Johnsonville, TN 2130SA, 2130SB, 2140S, 2145S, 2160S

Included Above

71.1

Included Above

0.923779.1

78.9

Included Above

Included Above


CN- 1423 RDA 1298



AIR POLLUTANT





Asbestos


Beryllium


Vinyl Chloride


Fluorides


Gaseous Fluorides






Air Pollutant & CAS






Total 112(b) Hazardous Air Pollutant N/a 53.97

96

CN- 1425 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 30




1. Facility name:









emissions


( In/Out )



Hood Container Corporation, New Johnsonville, TN 43-0010-11 Pulp Mill

In this process area pulp is produced in digesters from wood chips and cooking liquor then the resulting pulp is washed and processed

Production (bone dry)

43-0010-11

SO2Vents

Stack Emission

43-0010-11 VOC & HAP

176,700 TPY

50 ppm

TAPCR 12000-3-9-.01(4)

TAPCR 12000-3-9-.01(4)

TAPCR 1200-3-5-.01Opacity

TAPCR 1200-3-26-.02(2)(d)3

20% in 5 minutes

No limitation N/A

IN148,564 TPY

IN12.4 ppm

IN<20%

IN

97

CN- 1407 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 10




1. Facility name:



















43-0010-12 Wastewater Treatment Plant

None (All Fugitive Emissions) 1983

24 7 365

3993.393 415 966

Pumped

Gravity Flow 1,766 Mm Gal/yr

Gravity Flow

Conveying

1,766 Mm Gal/yr

n/a n/a

Phosphoric Acid (75%)

Screening, clarifying, aerating, storage and holding ponds.

98

✔

Process Sewer Water

Ash Slurry

1,853 Mm Gal/yr

164.3 Mm Gal/yr

Clarifier Sludge

Treated Wastewater

17,520 Mm Gal/yr

1,898.0 Mm Gal/yr

None n/a

Bar Screen Clarifier Anaerobic Basin Aerobic Basin Holding Ponds Bar Screen

Ash Ponds

Sludge Pond

Sludge Holding Tank

Solids Mix TankRotary

ThickenerScrew Press

Ash from Wood Refuse Boiler

(Figure 4)

MillProcessSewer

Effluent to Tennessee

River

Dewatered Sludge to Wood Refuse Boiler or

Dumpsters(Figure 4)

Stack Vent =

Process Flow =

Fugitive Emission =

Process =

Control Device =

Figure 9: Wastewater Treatment Facility (43-0010-12)

Page 99

CN- 1414 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 19











____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________








None, All Tanks

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Ongoing

365

100

CN- 1423 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 28




1. Facility name:






Air Pollutant







Sulfur Dioxide


Volatile Organic

Compounds


Carbon Monoxide


Lead


Nitrogen Oxides




Mercury



Hood Container Corporation, New Johnsonville, TN None (All Fugitive Emissions)

Included Above

30101.4

Included Above

Small Amounts Small Amounts


CN- 1423 RDA 1298



AIR POLLUTANT





Asbestos


Beryllium


Vinyl Chloride


Fluorides


Gaseous Fluorides






Air Pollutant & CAS






797.16 797.16

Total 112(b) HAPs N/A 30

102

CN- 1425 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 30




1. Facility name:









emissions


( In/Out )



Hood Container Corporation, New Johnsonville, TN 43-0010-12 Wastewater Treatment

The wastewater treatment process biologically treats the organic material in the wastewater before discharging it into the rive

43-0010-12 VOC & HAP TAPCR 1200-3-26-.02(2)(d)3 none 101.4 TPY IN

103

CN- 1407 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 10




1. Facility name:



















43-0010-13 Secondary Fiber Recycle Pulp Mill

3010S, 3020S

24 7 365

3993.393 415.966

Railcar & Truck Unloading, Storage

Railcar & Truck Unloading, Storage

25,903 TPY

118,632 TPY

Storage Tanks & Chests 104,848 TPY (650 TPD)

N/a N/a

None

DKL Pulping, OCC Rejects Press

104

✔

OCC Waste

DKL Waste

149,285 TPY

70,080 TPY

Recycle Pulp 230,750 TPY (750 TPD)

None N/a

High Density Cleaners

Primary Holes Screen

Medium Density

Cleaners

Secondary Holes Screen

OCC PulperOCC from Storage

Vibrating Screen

3010S

DKL Clippings

Hycor Screen Freeman Press

Solids for Disposal

Solids for Disposal

3020S

Pulp to Paper

Machine(Figure 7)

Primary Slotted Screens

Reverse Screens

Waste Thickeners

Float Purger

Hydra Purge Screen

Ultra Sorter

Secondary Slotted Screens

Tertiary Slotted Screens

Thru Flow Cleaners

Skim TankDKL

Clippings Pulper

Stack Vent =

Process Flow =

Fugitive Emission =

Process =

Control Device =

Figure 10: Recycle Facility (43-0010-13)

Page 105

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















3010S

35.0

22.3 4.1

280.0

100.0 5 14

N/a

N/a

X

106

CN – 1400 RDA 1298


APC 3




1. Facility name:


STACK DESCRIPTION


















3020S

32.8

3.3 3.3

27.7

70.0 Unknown Unknown

N/a

N/a

X

107

CN- 1414 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 19











____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________


Pollutant(s):

____________________________________________________________________________








3010S, 3020S

N/a

N/a

N/a

N/a

N/a

N/a

N/a

N/a

Ongoing

365

108

CN- 1423 RDA 1298

State of Tennessee




Nashville, TN 37243

Telephone: (615) 532-0554

APC 28




1. Facility name:






Air Pollutant







Sulfur Dioxide


Volatile Organic

Compounds


Carbon Monoxide


Lead


Nitrogen Oxides




Mercury



Hood Container Corporation, New Johnsonville, TN 3010S, 3020S

Included Above

1.882.15

Included Above


CN- 1423 RDA 1298



AIR POLLUTANT





Asbestos


Beryllium


Vinyl Chloride


Fluorides


Gaseous Fluorides






Air Pollutant & CAS






Total 112 (b) HAPs N/a 0.79

110

CN- 1425 RDA 1298

State of Tennessee





Nashville, TN 37243

Telephone: (615) 532-0554

APC 30




1. Facility name:









emissions


( In/Out )



Hood Container Corporation, New Johnsonville, TN 43-0010-13 Secondary Fiber Recycle Pulp Mill

In this process area pulp is produced from recycled old corrugated cardboard by mixing it with water no other volatile additives are used

Opacity43-0010-13

OCC Pulper

43-0010-13 Production

20% in 5 minutesTAPCR 1200-03-05-.01(1) & 1200-03-05-.03(6)

TAPCR 12000-3-9-.01(4)VOC

TAPCR 12000-3-9-.01(4)

0.49 lb/hr

230,640 bone dry tons/yr N/A

IN<20%

INN/A

IN

111

CN-1430 RDA 1298

State of Tennessee




312 Rosa L. Parks Avenue, 15th Floor Nashville, TN 37243

Telephone: (615) 532-0554

APC 35


APPLICATION COMPLETENESS CHECK LIST

Note to Applicants: The Application Completeness Check List is required by Division Rule 1200-03-09-.02(11)(d)1(ii)(I) and is used by Division staff to determine whether or not an application is complete. This checklist will be used to resolve any dispute between the applicant and the Division regarding the

completeness of an application.

Section 1: Identification and Diagrams (APC 1 and APC 2)

Requirement Complete Incomplete

Site Information

Contact Information (Responsible Official)

Contact Information (Technical)

Contact Information (Billing)

Type of Permit Requested

Accidental Release Information

Nonattainment/Additional Control Area Designation

List of Valid Permits

List and description of process emission sources, fuel burning installations, and incinerators

Flow diagram attached?

List of Insignificant Activities

List of Storage Piles

List of States within 50 Miles

Section 2: Emission Source Description Forms

Forms are complete as received:

Forms are incomplete (one or more application forms not submitted)

Forms are incomplete (missing information on the following application forms):

APC Form 3, Stack Identification

APC Form 4, Fuel Burning Non-Process Equipment

APC Form 5, Stationary Gas Turbines or Internal Combustion

Engines

APC Form 6, Storage Tanks

APC Form 7, Incinerators

APC Form 8, Printing Operations

APC Form 9, Painting and Coating Operations

APC Form 10, Miscellaneous Processes

APC Form 33, Stage I and Stage II Vapor Recovery Equipment

APC Form 34, Open Burning

CN-1430 RDA 1298

APC 35

Section 3: Air Pollution Control System Forms



Forms are incomplete (missing information on the

following application forms):

APC Form 11, Control Equipment - Miscellaneous

APC Form 13, Adsorbers

APC Form 14, Catalytic or Thermal Oxidation Equipment

APC Form 15, Cyclones/Settling Chambers

APC Form 17, Wet Collection Systems

APC Form 18, Baghouse/Fabric Filters

Section 4: Compliance Demonstration Forms



Forms are incomplete (missing information on the following application forms):

APC Form 19, Compliance Certification - Monitoring and

Reporting - Description of Methods for Determining Compliance

APC Form 20, Continuous Emissions Monitoring

APC Form 21, Portable Monitors

APC Form 22, Control System Parameters or Operating

Parameters of a Process

APC Form 23, Monitoring Maintenance Procedures

APC Form 24, Stack Testing

APC Form 25, Fuel Sampling and Analysis

APC Form 26, Recordkeeping

APC Form 27, Other Methods

APC Form 28, Emissions from Process Emissions Sources / Fuel Burning Installations / Incinerators

APC Form 29, Emissions Summary for the Facility or for the Source Contained in This Application

APC Form 30, Current Emissions Requirements and Status

APC Form 32, Air Monitoring Network

Section 5: Statement of Completeness and Certification of Compliance

Requirement Complete Incomplete Not Applicable

Certification of Truth, Accuracy, and Completeness (Form APC 1, Section 5)

General Identification and Description (Form APC 31, Items 1 and 2)

Compliance Certification for Sources Currently in Compliance

(Form APC 31, Item 3A)

Compliance Certification for New Applicable Requirements

(Form APC 31, Item 3B)

Identification of Sources Currently Not in Compliance (Form APC 31, Item 4A)

Compliance Schedule for Sources Currently Not in Compliance (Form APC 31, Item 4B)

Compliance Certification for Enhanced Monitoring (Form APC 31, Item 5)

CN-1430 RDA 1298

APC 35

Section 6: Miscellaneous Information

Item Included Not Included

For T itle V modifications, is a description of the modification included?

Request for Permit Shield

Calculations on which emissions-related information are based

Identification of alternative operating scenarios, as applicable

Explanation of any proposed exemptions from

otherwise applicable requirements

Other information needed for completeness (explain

in comments)

Section 7: Comments

Describe any missing information below or in a separate attachment:

Section 8: Application Completeness

Application is Complete

Application is Incomplete

Documents

Hood Container Corporation has applied to the …...Hood Container Corporation has applied to the Tennessee Air Pollution Control Division (TAPCD) for an existing major source operating