STATE OF NEW HAMPSHIRE DEPARTMENT OF … · STATE OF NEW HAMPSHIRE DEPARTMENT OF ENVIRONMENTAL SERVICES AIR RESOURCES DIVISION OFFSITE FULL COMPLIANCE EVALUATION ... reslurried with

STATE OF NEW HAMPSHIRE DEPARTMENT OF ENVIRONMENTAL SERVICES

AIR RESOURCES DIVISION

OFFSITE FULL COMPLIANCE EVALUATION RECORDS REVIEW

FRASER NH, LLC 72 CASCADE FLATS GORHAM, NH 03581

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REVIEW COMPLETED: September 17,2007

Report Drafted: September 17, 2007

Report Finalized: October 23, 2007

Fraser NH, LLC

Offsite FCE: September 17, 2007

Inspection

On September 17, 2007, the New Hampshire Department of Environmental Services, Air Resources Division ("DES") completed an offsite full compliance evaluation ("FCE") of Fraser NH, LLC ("Fraser"), located in Gorham, NH, in Coos County. DES' offsite records review was conducted in accordance with the EPA's Compliance Monitoring Strategy. DES last inspected Fraser on September 2 1-22, 2004. During the 2004 onsite inspection, there were no deficiencies found and the records appeared to be in order and up-to-date.

Offsite Review Completed Type of Inspection: Reviewed by: Source Contact:

September 17, 2007 Offsite Full Compliance Evaluation Alan H. Moulton Ryan Carrier, Environmental Engineer I (603) 342-3363 Francis Ramsey, Manager, Safety & Training (603) 342-3680

Fraser owns and operates a paper mill which produces specialty paper for books and stationery, and paper towels, from purchased bleached market pulp. The paper mill consists of all equipment and operations required to convert bleached market pulp to paper products. This includes the paper machines, broke handling system, finishing area, power boilers, and wastewater treatment. The dry bleached market pulp must be reslurried in pulpers prior to being fed into the paper machines. The broke system encompasses all the pulpers, chests, and equipment that collect and recycle trimmings from the paper machines during normal operation. Trimmings and rejected sheets are reslurried with white water from the paper machines. The finishing area wraps and warehouses the paper rolls in preparation for shipping and distribution.

Fraser, which is a publicly-owned company, purchased the pulp mill in Berlin and the paper mill in Gorham from Pulp & Paper of America, LLC in late May of 2002. The Berlin Burgess Pulp Mill and Cascade Paper Mill were originally built in 1909. In 1917, the company's name was changed to the Brown Company. The facility was acquired by James River in 1980 and then sold to Crown Vantage in 1995. American Tissue purchased the facility in July 1999 and renamed the company Pulp & Paper of America, LLC. In 2002, Fraser purchased the company. Fraser has since closed the pulp mill in April 2006.

Fraser employs 250-300 people at the paper mill and operates two 12-hour shifts per day, seven days per week for continuous operation.

Process Description

Fraser's paper mill ("the facility") consists of four fine paper grade paper machines and one towel grade paper machine, plus a steam plant that supplies process steam for the paper mill. The steam plant consists of Power Boilers #1, #2, #3, and #4, and a Temporary Package Boiler

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Fraser NH, LLC Offsite FCE: September 17, 2007

that is used during annual boiler maintenance outages at the paper mill.

III. Regulatory Compliance

CHAPTER Env-A 600 - Statewide Permit System

DES issued Title V Operating Permit TV-OP-048 ("the Permit") to Fraser on February 27, 2004, for its operation of both the pulp and paper mills. The Permit expires on February 28, 2009. On April 17, 2007, Fraser filed an application for a Temporary Permit and requested DES remove the requirement to maintain NOx continudus emission monitoring ("CEM") systems on Power Boilers #1, #2, and #3. As an alternative to using the CEM systems, Fraser will be required to conduct annual stack tests for NOx on each Power Boiler. In addition, Fraser will continue to operate continuous opacity monitoring systems and continuous fuel flow meters/totalizers for these three Power Boilers.

The annual stack testing on Power Boilers #1 and #2 will be used to determine if boiler tune-ups will be required. If the stack test results indicate that NOx emissions are at or below an emission rate of 0.40 lb NOx/MMBtu for Power Boiler#1 or 0.45 lb NOx/MMBtu for Power Boiler #2, then Fraser will not be required to perform tune-ups on these boilers. If the stack test results indicate that NOx emissions exceed either respective emission rate,then Fraser will be required to perform quarterly boiler tune-ups on that boiler until a subsequent stack test indicates that the emissions no longer exceed the limit. Fraser may perform stack tests more frequently than annually and discontinue quarterly tune-ups for that year after any test indicates the NOx emissions rate for that boiler is below the tune-up threshold. The emission rates for Power Boilers #1 and #2 are not enforceable limits, but are only being used to determine the necessity and frequency of boiler tune-ups.

The annual stack testing on Power Boiler #3 will be used to determine compliance with the NOx RACT 0.45 lb/MMBtu annual limit and 0.60 lb/MMBtu 24-hour limit, as stated in the Permit. If test results exceed the limits, then the same situation applies as above on Power Boilers #1 and #2.

DES is currently drafting the Temporary Permit.

PART Env-A 604.02 - Permit Terms and Conditions

Table I shows the permitted devices, the operating limits and/or device capacities, and Fraser's corresponding reported fuel usage data for calendar years 2004, 2005 and 2006, for the paper mill only. Table II shows Fraser's annual emissions for the paper mill only.

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Table I: Onerational Limits and Canacities

Emission Unit Maximum Allowable Permitted Reported Annual Fuel Usage

Capacity

PB1 128.6 MMBtu/hr on #6 fuel oil with 2004: 5,082,449.0 gallons #6 fuel oil Power Boiler #1 maximum of 1.5% sulfur by weight or on- 2005: 4,987,620.0 gallons #6 fuel oil Combustion Engineering spec used oil combined with #6 fuel oil 2006: 4,991,022.0 gallons #6 fuel oil Model #: Unknown with a maximum of 1.5% sulfur by weight. Serial #: Unknown Installation date: 1936 Maximum Design Fuel Flow Rate: 857 Boiler has low NOx burners. gallons/hr.

P132 162.4 MMBtu/hr on #6 fuel oil with 2004: 6,847,687.0 gallons #6 fuel oil Power Boiler #2 maximum of 1.5% sulfur by weight or on- 2005: 6,620,756.0 gallons #6 fuel oil Babcock & Wilcox spec used oil combined with #6 fuel oil 2006: 6,272,562.0 gallons #6 fuel oil Model #: Unknown with a maximum of 1.5% sulfur by weight. Serial #: Unknown Installation Date: 1937 Maximum Design Fuel Flow Rate: 1,083 Boiler has low NOx burners. gallons/hr.

Opacity: 20% PB3 68.6 MMBtu/hr on #6 fuel oil with 2004: 2,922,283.00 gallons #6 fuel oil Power Boiler #3 maximum of 1.5% sulfur by weight or on- 2005: 2,461,478.00 gallons #6 fuel oil Zurn spec used oil combined with #6 fuel oil 2006: 1,907,246.38 gallons #6 fuel oil Model #: Unknown with a maximum of 1.5% sulfur by weight. Serial #: Unknown Installation Date: 1962 Maximum Design Fuel Flow Rate: 457

gallons/hr.

Opacity: 40% PB4 12.5 MMBtu/hr on #6 fuel oil with This boiler has not operated since 1996. Power Boiler #4 maximum of 1.5% sulfur by weight. Cleaver Brooks Maximum Design Fuel Flow Rate for #6 Model #: Unknown fuel oil: 83 gallons/hr. Serial #: Unknown Installation Date: 1974 Or, #2 fuel oil with maximum of 0.4%

sulfur by weight. Maximum Design Fuel Flow Rate for #2 fuel oil: 88 gallons/br;

Or the equivalent gallons per hour of on- spec used oil combined with #2 or #6 fuel oil, as averaged over any calendar 24-hour period. S

Opacity: 20% TPB 100 MMBtu/hr on #6 fuel oil with maximum 2004: 111,000.0 gallons #2 fuel oil Temporary Package Boiler of 0.5% sulfur by weight. 2005: 0 gallons #6 fuel oil Mfr.: Various Maximum Design Fuel Flow Rate for #6 2006: 0 gallons #6 fuel oil Model #: Unknown fuel oil: 666 gallons/br. Serial #: Unknown Installation Date: Unknown Or, #2 fuel oil with maximum of 0.4%

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Fraser NH, LLC


Emission Unit Maximum Allowable Permitted Capacity

Reported Annual Fuel Usage

Boiler must have low NOx sulfur by weight. burners. Maximum Design Fuel Flow Rate for #2

fuel oil: 704 gallons/hr.

Opacity: 20% EG 4.2 MMBtu/hr on #2 fuel oil with 2004: 391.81 gallons #2 fuel oil Emergency Generator maximum of 0.4% sulfur by weight. 2005: 678.19 gallons #2 fuel oil Caterpillar 2006: 241.21 gallons #2 fuel oil Model #: D3409 Maximum Design Fuel Flow Rate: 30.9 Serial #: Unknown gallons/hr. Installation Date: Unknown

I Opacity: 20%

Table II: Annual Emissions (tons Permitted

Pollutant Emission 2004* 2005* 2006* Limits for Pulp and

L Paper_Mills Nitrogen Oxide 1,273.2 374.61 308.95 308.75 Sulfur Dioxide 2,948.1 1,138.61 1,016.14 896.51 Carbon Monoxide 6,602.2 4.40 3.73 3.23 Particulate Matter 731.0 90.19 83.76 76.38 VOCs 11 858.0 0.02 0 0

* Annual emissions listed are for paper mill only.

PART Env-A 609.03 - Exempt Activities

There are no exempt activities listed in the permit.

PART Env-A 609.04 - Insignificant Activities

There are no insignificant activities listed in the permit.

PART Env-A 618 - Additional Requirements in Non-Attainment Areas and the New Hampshire Portion of the Northeast Ozone Transport Region

Fraser is located in Coos County of New Hampshire and is in the Northeast Ozone Transport Page 5 of 14


Region. Coos County is not classified in this part. Fraser is an existing major stationary source, but in the last three years has not had any major modifications; therefore, this part is not applicable to the facility.

CHAPTER Env-A 400 - Acid Deposition Control Program

This chapter applies to those sources that emitted 100 tons or more of SO2 per year on average during the period 1979 through 1982. At that time, Fraser, which was then known as James River Corporation, met this criterion.

The Permit states that annual SO2 emissions from Class A sources, such as Fraser, shall not exceed 75% of the source's portion of the baseline emissions. Applicable sources under common ownership may combine emission rates of all such sources to demonstrate that total emissions do not exceed 75% of the baseline emissions.

The baseline emissions were the total SO2 emissions, in tons per calendar year, from all major sources averaged over the period of 1979 and 1982. During that time period, James River Corporation owned the current Fraser facilities in Berlin and Gorham. Also at that time, James River owned a facility in Groveton, NH, which is now owned by Wausau Papers of NH, Inc. Also located on the Groveton site is Groveton Paper Board, Inc., an independent company not associated with either James River or Wausau Papers. Until November 2001, Wausau Papers and Groveton Paper Board were served by a common energy plant consisting of four boilers (Boilers 91, #2, #4, & #5) and a steam-driven turbine. Boilers #1 and #2, and the small turbine are owned by Wausau Papers, and Boilers #4 and #5 are owned by GrOveton Paper Board. Wausau Papers operated the steam plant for the benefit of both parties under an operating agreement between the two parties, and all four boilers were permitted in Wausau Paper's name as the operating entity via the Title V Operating Permit TV-OP-02 1, issued on January 26, 2000. After November 2001, the operating agreement ended and then each party operated and permitted its own devices.

The portion of the total SO2 baseline assigned for the Berlin (pulp mill), Gorham (paper mill), and Groveton facilities is 8,760 tons SO 2 per year. The 75% level is 6,570 tons SO2 per year. As noted in Table III below, the combined SO2 emissions, in tons per year, are below the 75% baseline limit.

Table III - Average SO Emission Rates (tons) Facility/Year 2004 2005 2006

Berlin (pulp mill) 525.56 234.90 56.03

Gorham (paper miii) 1,138.61 1,016.14 896.51

Wausau Papers of NH, Inc. 10.69 11.09 25.14

Groveton Paper Board, Inc. 3.77 8.83 2.01

Totall 1,678.63 1,270.96 1 923.66

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Fraser NH, LLC


Fraser uses #6 fuel oil containing 1.5% sulfur by weight instead of #6 fuel oil containing 2.2% sulfur by weight to meet the 25% reduction requirement.

CHAPTER Env-A 500 - Standards Applicable to Certain New or Modified Facilities and Sources of Hazardous Air Pollutants

Fraser is subject to Env-A 503.01 and the New Source Performance Standard ("NSPS"), 40 CFR 60, subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units. See Section VII "Compliance with Federal Requirements" of this report. Fraser is not subject to any of the National Emission Standards fot Hazardous Air Pollutants ("NESHAP") specified in Env-A 504.01, or any of the National Emission Standards for Hazardous Air Pollutants for Source Categories (Maximum Achievable Control Technology, or MACT, Standards) specified in Env-A 505.01.

CHAPTER Env-A 800 - Testing and Monitoring Procedures

Fraser operates a Continuous Emissions Monitoring ("CEM") system at the paper mill and is required to perform periodic tests to show the system meets State and Federal requirements.

Fraser filed an application for a Temporary Permit, in which it requested DES remove the NOx continuous emission monitoring systems from Power Boilers #1, #2, and #3. Fraser will continue to operate continuous opacity monitoring systems and continuous fuel flow meters/totalizers for these three Power Boilers.

As required by the Permit, Fraser conducts annual Relative Accuracy Test Audits ("RATAs") of the three power boiler CEMs. A review of the test data shows that Fraser is conducting the required tests and is operating in accordance with the Permit.

Fraser continuously monitors for NOx, 02, volumetric flow and opacity from the power boilers. Fraser submits quarterly excess emission reports for the CEM system and DES' Testing and Monitoring Section reviews these reports. No excess emissions were noted for NOx or opacity in these reports. See the Full Compliance Evaluation Records Review at the end of this report.

CHAPTER Env-A 900 - Owner or Operator Recordkeeping

Fraser has submitted the records and documentation to DES that is required by the Permit. A review of Fraser's actual recordkeeping and data maintenance procedures will be conducted during the next onsite FCE of the facility in 2009.

The Full Compliance Evaluation Records Review is included as an attachment to this report. The attachment lists all the reports that were reviewed in order to complete this compliance evaluation. The records review attachment includes a determination of each report's timeliness

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with regard to the required submittal date, and if the report was acceptable in terms of its content.

Part Env-A 911 - Recordkeeping and Reporting Requirements for Permit Deviations

Fraser promptly reports to DES, usually by fax, any deviation that occurs during the operation of the facility. A list of deviations for each year is summarized in the Annual Compliance Certification and summarized semi-annually in the Semi-Annual Permit Deviation and Monitoring Reports.

CHAPTER Env-A 2000 - Fuel Burning Devices

Since this was an offsite evaluation, compliance with the visible emission standards for Fraser's fuel burning devices could not be verified.

CHAPTER Env-A 2100 - Particulate Matter and Visible Emissions Standards

Since this was an offsite evaluation, compliance with the particulate matter and visible emission standards for Fraser's manufacturing processes could not be verified.

CHAPTER Env-A 2500 - Pulp and Paper Industry: Particulate Matter and Visible Emission Standards

Since this was an offsite evaluation, compliance with the particulate matter and visible emission standards for Fraser's paper manufacturing facility could not be verified.

IV. Compliance with RACT

CHAPTER Env-A 1200 - Stationary Source Air Pollution

PART Env-A 1204 - Stationary Sources of VOCs

Fraser does not have any processes or devices with VOC emissions that subject it to the Reasonably Available Control Technology ("RACT") requirements for VOC RACT.

PART Env-A 1211 - Nitrogen Oxides

On September 24, 1997, DES issued NOx RACT Order ARD-97-003 to Fraser, which specified the emission standards and operational requirements in Env-A 1211 for Fraser to

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Fraser NH, LLC


comply with NOx RACT. These requirements have been incorporated into the Permit.

Air Toxics

CHAPTER Env-A 1400 - Regulation Toxic Air Pollutants

PART Env-A 1402 - Applicability and Part Env-A 1404 - Permit Requirements

On November 12, 2002, DES completed a review of the modeling of the emissions from Fraser's Berlin and Gorham facilities that was done by its consultants. This modeling was part of the Cluster Rule Project and included an air toxics compliance determination in accordance with Env-A 1400. The results of the modeling verified that Fraser is not exceeding the ambient air limits and is in compliance with the rule.

The fuel burning devices at Fraser that burn virgin fuels are exempt from the requirements of an Env-A 1400 compliance determination.

Compliance with Permit Fee System

PART Env-A 704.01 - Emission Based Fees

Fraser has paid its emission-based fees through 2006

Compliance with Federal Requirements

40 CFR 60 Subpart Dc

The requirements of Subpart Dc as they pertain to the Temporary Package Boiler require Fraser to:

Use fuel oil that contains sulfur at or less than 0.5% by weight; Submit notification of installation, anticipated startup, and actual startup of the boiler; Submit performance test data, as required, for SO2, opacity, and the CEMs; and Submit semi-annual reports on the fuel usage and the sulfur content of the fuel to EPA and to DES.

Fraser did not bring the Temporary Package Boiler on site in 2005 and 2006. In 2004, Fraser brought a Temporary Package Boiler on site and complied with the requirements of this subpart.

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Fraser NH, LLC


40 CFR 70.6 (a)(3) Permit Content, Monitoring, Record Keeping, and Reporting Requirements

Fraser is meeting its Title V permit requirements. See the Full Compliance Evaluation Records Review which is included as an attachment to this report for greater detail of Fraser's Title V reporting history and compliance status.

Compliance and Enforcement Status

Since the last onsite inspection, DES has had no enforcement actions against Fraser.

Conclusion and Recommended Actions

A review of all of the records submitted to DES by Fraser since the last onsite inspection demonstrates that Fraser is complying with its permits and with Env-A 100 et seq. There were no deficiencies found as a result of this offsite inspection.

Attachments:

Documents:

Full Compliance Evaluation Records Review

Alan H. Moulton Air Pollution Control Engineer Air Resources Division

filename: 07-09 17 Fraser NH. LLC FCE Offsite Report

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Full Compliance Evaluation Records Review

Facility: Fraser NH, LLC Date of FCE: September 17, 2007 Reviewer: Alan Moulton

Annual Emission Reports (mci. NOx, VOC etc.): ReportingPeriod When Rec'd? Report OK? In Database?

2004 4/04/05 Yes Yes 2005 4/13/06 Yes Yes 2006 2/08/07 Yes Yes

Annual Emissions-Based Fee Payments: Reporting Period When Rec'd? In Database?

2004 7/13/05 Yes, in Sonny's.spreadsheet. 2005 4/14/06 Yes, in Sonny's spreadsheet. 2006 2/08/07 Yes, in Sonny's spreadsheet.

TV Annual Compliance Certifications: Reporting Period When Rec'd? Report OK? In Database?

2004 4/18/05 Deficiencies found, Fraser corrected and sent revised copy 11/18/05.

Yes

2005 4/12/06 Yes Yes 2006 4/04/07 Yes Yes

TV Semi-Annual Permit Deviation and Monitoring Reports: Reporting Period When Rec'd? Report OK? In Database?

Jul - Dec 2004 2/01/05 Yes Yes Jan - Jun 2005 8/01/05 Yes Yes Jul - Dec 2005 2/03/06 Yes Yes Jan - Jun 2006 7/31/06 Yes Yes Jul - Dec2006 2/20/07 Yes Yes Jan - Jun 2007 7/23/07 Yes Yes

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Fraser NH, LLC


Individual Permit Deviations Reports:

Fraser has a long list of Permit Deviation Reports. Each report is faxed, usually within 48-hours of the incident, and is summarized in the Semi-Annual Permit Deviation and Monitoring Reports and in the Annual Compliance Certification Report. Once received at DES ARD, the Compliant Manager reviews the deviation and it is entered into the database. The faxes are then filed in the Source File.

Reporting Period When Rec'd? Report OK? In Database? See Files...

Ouarterlv Continuous EmissionMonitoring Excess Emission Reports (CEM EERs): Reporting Period When Rec'd? Report OK? In Database?

Jan - Mar 2004 5/18/2004 Yes No Apr - Jun 2004 8/16/2004 Yes Yes Jul - Sep 2004 11/01/2004 Yes Yes Oct - Dec 2004 2/01/2005 Yes Yes Jan - Mar 2005 5/03/2005 Yes Yes Apr - Jun 2005 8/01/2005 Yes Yes Jul - Sep 2005 10/31/2005 Yes Yes Oct - Dec 2005 2/01/2006 Yes Yes Jan - Mar 2006 5/01/2006 Yes Yes Apr - Jun 2006 7/31/2006 Yes Yes Jul - Sep 2006 10/31/2006 Yes Yes Oct - Dec 2006 1/31/2007 Yes Yes Jan - Mar 2007 4/23/2007 Yes Yes Apr - Jun 2007 7/30/2007 Yes Yes

CEM Audits (OPAs, CGAs. RAAs, RATAs): Reporting Period Rejort Type When Rec'd? Report OK? In Database?

2004 RATA - Boilers 12/0704 Yes Yes #1,#2,#3

2005 RATA - Boilers 1/23/06 Yes Yes #1,#2,#3

2006 RATA - Boilers 1/23/07 Yes Yes #1,#2, #3

2004— Qi Boilers #1, #2, #3: Opacity Audit Yes Yes CGA 4/26/04 Yes Yes Flow RAA Yes Yes

2004 - Q2 BOilers #1, #2, #3: Opacity Audit Yes Yes CGA 7/30/04 Yes Yes

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Fraser NH, LLC


Reporting Period Report Type When Rec'd? Report OK? In Database? Flow RAA Yes Yes

2004 - Q3 Boilers #1, #2, #3: Opacity Audit Yes Yes CGA 10/25/04 Yes Yes Flow RAA Yes Yes

2004 - Q4 Boilers #1, #2, #3: Opacity Audit 2/01/05 Yes Yes

2005 - Qi Boilers #1, #2, #3: Opacity Audit Yes Yes CGA 5/03/05 Yes Yes Flow RAA Yes Yes

2005 - Q2 Boilers #1, #2, #3: Opacity Audit Yes Yes CGA 8/01/05 Yes 'Yes Flow RAA Yes Yes

2005 - Q3 Boilers #1, #2, #3: Opacity Audit Yes Yes CGA 10/31/05 Yes Yes Flow RAA Yes yes


2006— Qi Boilers #1, #2, #3: Opacity Audit Yes Yes CGA 5/01/06 Yes Yes Flow RAA Yes Yes

2006—Q2 Boilers #1, #2, #3: Opacity Audit Yes Yes CGA 7/31/06 Yes Yes Flow RAA Yes Yes

2006 - Q3 Boilers #1, #2, #3: Opacity Audit Yes Yes CGA 10/31/06 Yes Yes Flow RAA Yes Yes


2007 - Qi Boilers #1, #2, #3: Opacity Audit Yes Yes CGA 4/23/07 Yes Yes Flow RAA Yes Yes

2007 - Q2 Boilers #1, #2, #3: Opacity Audit * Yes CGA ' 7/23/07 * Yes Flow RAA I I * Yes

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CGA: Cylinder Gas Audit RAA: Relative Accuracy Audit

* 2007 Quarter 2 test reports still being reviewed by DES Stack Test Section.

Stack Tests: Stack Test Date Device Tested When Rec'd? Report OK? In Database?

NTone.

Other renorts

Reporting Period Report Type When Rec'd? Report OK? In Database? 2004 NOx RACT 4/04/05 Yes Yes ** 2004 VOC RACT 4/04/05 Yes Yes ** 2005 NOx RACT 4/13/06 Yes Yes ** 2005 VOC RACT 4/13/06 Yes Yes ** 2006 NOx RACT 2/08/07 Yes Yes 2006 VOC RACT 2/08/07 Yes Yes **

** See Annual Emissions Report

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