HomeMy WebLinkAboutExhibit 08_PTPC Air OperatingPermitIssuance Date: August 17, 2022
Effective Date: September 1, 2022
Expiration Date: August 31, 2027
AIR OPERATING PERMIT 0000922
In compliance with the provisions of The State of Washington
Clean Air Act Chapter 70.94 Revised Code of Washington
Port Townsend Paper Corporation
100 Mill Road
Port Townsend, Washington 98368
Is authorized to operate in accordance with the terms and conditions
of this permit.
Issued by:
State of Washington
Department of Ecology
P.O. Box 47600
Olympia, Washington 98504-7600
Shingo Yamazaki, P.E.
Environmental Engineer
Solid Waste Management Program
James DeMay, P.E.
Industrial Section Manager
Solid Waste Management Program
Page 2 of 116
Table of Contents
INTRODUCTION AND LEGAL AUTHORITY .................................................................................. 3
EMISSION UNIT SPECIFIC REQUIREMENTS [WAC 173-401-600] ................................................. 4
A. RECOVERY FURNACE (RF) ............................................................................................. 5
B. SMELT DISSOLVER TANK (SDT) .....................................................................................13
C. LIME KILN (LK) .............................................................................................................20
D. POWER BOILER #10 (PB10) ..........................................................................................29
E. PACKAGE BOILER (PKB)................................................................................................48
F. DIGESTERS, MULTI-EFFECT EVAPORATORS, WASHERS ..................................................58
G. LOW VOLUME HIGH CONCENTRATION (LVHC) SYSTEM ................................................60
H. HIGH VOLUME LOW CONCENTRATION (HVLC) SYSTEM ................................................63
I. PULPING PROCESS CONDENSATES AND CLEAN CONDENSATE ALTERNATIVE .................67
J. PAPER MACHINE 2 (PM2) ............................................................................................72
K. OLD CORRUGATED CONTAINER (OCC) PLANT ...............................................................73
L. RECIPROCATING INTERNAL COMBUSTION ENGINES (RICE) ...........................................74
M. MILLWIDE EMISSION LIMITS AND REQUIREMENTS.......................................................80
N. GREENHOUSE GAS (GHG) REPORTING..........................................................................82
O. COMPLIANCE ASSURANCE MONITORING (CAM)...........................................................83
FACILITY-WIDE GENERAL REQUIREMENTS [WAC 173-401-600] ................................................86
STANDARD TERMS & CONDITIONS ..........................................................................................99
PERMIT SHIELD ..................................................................................................................... 102
Appendix A – Permit Shield and Inapplicable Requirements................................................... 103
Appendix B – Formulas for Emission Calculations .................................................................. 112
Appendix C – Applicable Permits and Orders ......................................................................... 113
Appendix D – Definitions of Abbreviations ............................................................................ 114
Appendix E – Footnote Key ................................................................................................... 114
Page 3 of 116
INTRODUCTION AND LEGAL AUTHORITY
This Air Operating Permit is authorized under the Operating Permit Regulation, Chapter 173-
401 Washington Administrative Code (WAC). The provisions of this permit describe the
emissions limitations, operating requirements, monitoring and recording requirements, and
reporting frequencies for the permitted source.
Port Townsend Paper Corporation (PTPC) requires a Title V Air Operating Permit because it
emits, or has the potential to emit, 100 tons per year or more of one or more air pollutants
(WAC 173-401-300(1)).
During the drafting of this permit, Ecology has attempted to incorporate requirements using
the exact language of the law, regulation, or order. In some cases, this has not been possible.
Where there is a difference in language, this difference is presented in this permit only for
clarification of the underlying requirement. The legal requirement remains the underlying
applicable requirement cited in the “Applicable Requirements” column of the tables and the
citations contained in brackets at the end of each requirement. Any conflict between the
permit and an underlying requirement will be resolved by referring to the cited applicable
requirement. Unless otherwise stated, the effective date of referenced regulations or
statutes is that of the provision in effect on the date of permit issuance. Compliance with
underlying requirements shall be demonstrated using the methods specified in this permit.
The Title V Air Operating Permit consists of all parts of this assembled document including all
footnotes and Appendices, but does not include the accompanying Statement of Basis or the
Title V permit application materials submitted by the facility.
The definitions of terms contained in WAC 173-401-200, and as defined in all referenced
regulations, apply to this permit unless otherwise defined in the permit.
Any federal test method referenced, unless specifically stated otherwise within the body of
the permit, is that which is contained in 40 CFR Part 60, Appendix A. Any state test method
referenced, unless specifically stated otherwise within the body of the permit, is that which
is contained in the “Ecology Source Test Manual” as of July 12, 1990.
Page 4 of 116
EMISSION UNIT SPECIFIC REQUIREMENTS [WAC 173-401-600]
PTPC requires a Title V Air Operating Permit because it emits or has the potential to emit, 100
tons per year or more of one or more air pollutants (WAC 173-401-300(1)). The emission units
identified in Conditions A through L are subject to the emission unit specific requirements set
forth in Conditions A through L. These units are also subject to the facility-wide applicable
requirements. The associated monitoring, recordkeeping, and reporting requirements, for
these limits are in the Facility-Wide section of this permit. Unless specified otherwise, the
basis of authority for the type and frequency of monitoring imposed in Conditions A through L
is WAC 173-401-615.
The reference test method (RM) or compliance determination algorithm is identified under
the column titled, “Monitoring and Reporting.” The identified reference test method or
compliance determination algorithm is the compliance determination method which is
intended to be the default or absolute determinant of compliance. It may or may not also be
the method by which ongoing compliance is indicated.
Insignificant emission units (IEUs) are subject to the applicable requirements contained in the
Facility-Wide section, however they are not subject to testing, monitoring, recordkeeping, or
reporting requirements unless the generally applicable requirements in the State
Implementation Plan (SIP) impose them. [WAC 173-401-530(2)(c)]
Appendix A contains the emission estimate algorithms. These algorithms set forth the manner
by which emissions are calculated for those requirements for which the RM itself does not
directly result in an emission estimate. Unless otherwise required by the applicable
requirement, minor modifications to the test method may be used with the advanced
approval of Ecology. In addition, the Permittee may use an equivalent alternative method
with written approval from Ecology. Failure to obtain prior written approval for any test
changes may invalidate the use of the test result(s) for Title V compliance purposes.
Page 5 of 116
A. RECOVERY FURNACE (RF)
The emission unit shall comply with the General Requirements of 40 CFR 63 as listed in Table 1 of Subpart MM.
RF Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
A.1a Particulate
(PM)
0.08 gr/dscf
@ 8% O2, 1-
hr average
Performance Testing:
Sample M/Q/S/A3 using EPA RM 5 using at least three runs of at least one
hour per run.
See Facility-wide General Requirement, Condition 37 for notification
requirements.
Reporting:
Submit source test results in the monthly air report, due after results
received by the Permittee. Include the following elements:
1. Average opacity during each source test run.
2. Sufficient data to allow verification of source test results.
3. Air flow split between ESP chambers.
4. Average black liquor flow rate, density, and % solids during source
test.
5. As alternative to #4, PTPC can estimate the total solids fired during
the source test run.
6. Log, every hour during the source test, primary and secondary
voltage and current, and spark rate (if available) for each TRC unit.
7. Exhaust stack percent O2.
See Facility-wide General Requirement, Condition 38 for additional source
test report requirements.
Compliance Assurance Monitoring:
Order 2892-05AQ,
Modification 2 for
limit, operating
parameter
recordings, and
reporting
requirements
40 CFR 70.6(c)(1) for
M/Q/S/A source
testing frequency
40 CFR 64.2 and 64.6
through 64.9 for
respective PM CAM
monitoring and
reporting/recordkeep
ing
Page 6 of 116
RF Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
The Permittee shall comply with the general CAM requirements in Condition
O. The Permittee must comply with the monitoring, corrective action, and
violation determination requirements in Condition A.3b.
CAM reporting required on at a minimum semiannual basis.
A.1b PM 0.10 gr/dscf
@ 8% O2, 1-
hr average
Same as for Condition A.1a. WAC 173-405-
040(1)(a) for limit
40 CFR 64.2 and 64.6
through 64.9 for
respective PM CAM
monitoring and
reporting/recordkeep
ing
A.2 HAP
Metals (PM
as
surrogate)
0.044 gr/dscf
@ 8% O2
Performance Testing:
Sample every 5 years using EPA RM 5. Water must be used as the cleanup
solvent instead of acetone in the sample recovery procedure. First periodic
performance test must be conducted by October 13, 2020 and thereafter
every 5 years following the previous performance test. Performance testing
to be conducted in accordance with 40 CFR 63.865.
Representative Conditions:
Performance tests shall be conducted based on representative performance
during the period being tested. The owner/operator must record the process
information that is necessary to document operating conditions during the
test and include in such record an explanation to support that such
conditions represent normal operation. Upon request, the owner/operator
40 CFR
63.862(a)(1)(i)(A) for
standard
40 CFR 63.863(c)(1)
for 5-year periodic
performance test
compliance date
40 CFR 63.865 for
performance testing
requirements
40 CFR 63.9(e) and
40 CFR 63.7(b) for
Page 7 of 116
RF Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
shall make available such records as may be necessary to determine the
conditions of performance tests.
60-day notification:
The Permittee must notify Ecology in writing of their intention to conduct a
performance test at least 60 calendar days before the performance test is
initially scheduled to begin.
Recordkeeping:
The Permittee must maintain records of:
1) All results of performance tests;
2) The process information that is necessary to document operating
conditions during the test and include in such record an explanation
to support that such conditions represent normal operation;
3) Documentation of supporting calculations for compliance
determinations made under 40 CFR 63.865(a) through (d);
4) For each failure to meet the emission limit, the number of failures,
the date, start time, and duration of each event;
5) For any failure to meet the emission limit, record an estimate of the
quantity of each regulated pollutant emitted over the emission limit
and a description of the method used to estimate the emissions.
Reporting:
Report failures to meet the applicable standard in the Semi-Annual Excess
Emissions and Continuous Monitoring Systems Performance or Summary
Report in accordance with 40 CFR 63.867(c), delivered or postmarked by July
30 or January 30 following the end of the respective calendar half (or on a
more frequent basis as determined necessary by Ecology).
performance test
notification
40 CFR 63.865 and 40
CFR 63.866 for
recordkeeping
40 CFR 63.867(d) for
electronic reporting
Page 8 of 116
RF Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
Within 60 days after the date of completing each performance test, submit
the results of the performance test electronically via EPA’s Compliance and
Emissions Data Reporting Interface (CEDRI) in accordance with 40 CFR
63.867(d).
Include source test results in the monthly air report, due after results
received by the Permittee.
A.3a Opacity 35% average
for more
than 6
consecutive
minutes in
any 60
minute
period
Compliance demonstrated with COMS and EPA RM 9 is the reference test
method.
Monitor continuously using a Continuous Opacity Monitoring System
(COMS) that conforms to 40 CFR Part 60, Appendix F and Appendix B,
Performance Specification 1.
See Facility-wide General Requirement, Condition 26 for continuous
monitoring system (CMS) operating requirements.
Report daily maximum six-minute average opacity, daily average opacity,
and exceedances in the monthly air report.
WAC 173-405-040(6)
for opacity limit
WAC 173-401-615 for
monitoring
A.3b HAP
Metals
(Opacity as
surrogate)
Operating
Limit
Opacity
greater than
35% for 2%
or more of
operating
time during a
semiannual
period
Monitoring:
Monitor opacity using a COMS which is installed, calibrated, maintained, and
operated in accordance with Performance Specification 1 (PS-1) in appendix
B to 40 CFR Part 60 and the provisions in §63.6(h) and §63.8 and
§63.864(d)(3) and (4).
See Facility-wide General Requirement, Condition 28 for CMS data recovery
requirements.
Monitoring Exceedances:
40 CFR 63.864 for
monitoring
requirements
40 CFR 63.864(k) for
ongoing compliance
and violation
determination
40 CFR 63.866 for
recordkeeping
requirements
Page 9 of 116
RF Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
The Permittee is required to implement corrective action if the average of
ten consecutive 6-minute averages results in a measurement greater than 20
percent opacity.
Violation Determination:
A violation of the underlying HAP Metals standard in Condition A.2 occurs
when opacity is greater than 35 percent for 2 percent or more of operating
time during a semiannual period while spent pulping liquor is fed.
Recordkeeping:
The Permittee must maintain records of:
1) Black liquor solids firing rates in units of Mg/d or ton/d;
2) Any occurrence when corrective action is required and when a
violation is noted;
3) For each failure to meet the opacity operating limit, the number of
failures, the date, start time, and duration of each event;
4) For each failure to meet the opacity operating limit, an estimate of
the quantity of each regulated pollutant emitted over the emission
limit and a description of the method used to estimate the emissions;
5) Record actions taken to minimize emissions in accordance with
§63.860(d) and any corrective actions taken to return the affected
unit to its normal or usual manner of operation.
Reporting:
Report monitoring exceedances (as defined above) and associated corrective
action monthly to Ecology.
The Permittee must submit a Semi-Annual Excess Emissions and Continuous
Monitoring Systems Performance or Summary Report in accordance with 40
CFR 63.10(e)(3) and 40 CFR 63.867(c), delivered or postmarked by July 30 or
40 CFR 63.867(c) for
excess emission
reporting
requirements
Page 10 of 116
RF Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
January 30 following the end of the respective calendar half (or on a more
frequent basis as determined necessary by Ecology).
A.4a SO2 200 ppm @
8% O2, 1-
hour average
Performance Testing:
Sample M/Q/S/A3 using EPA modified RM 6.
See Facility-wide General Requirement, Condition 37 for notification
requirements.
Reporting:
Submit source test results in the monthly air report due after results
received by the facility. See Facility-wide General Requirement, Condition 38
for source test report requirements.
PSD-I, Condition 2 for
limit
WAC 173-401-615 for
test method,
frequency, and
reporting
A.4b SO2 500 ppm @
8% O2, 1-hr
average
Same as above. WAC 173-405-
040(9)(a) for limit
A.5 HAPs N/A The Permittee must maintain proper operation of the electrostatic
precipitator’s automatic voltage control (AVC).
The Permittee must maintain records demonstrating compliance with the
requirement to maintain proper operation of an electrostatic precipitator
AVC.
40 CFR 63.864(e)(1)
for AVC requirement
40 CFR 63.866(c)(8)
for recordkeeping
A.6 Operations
and
Maintenan
ce
N/A At all times, the owner or operator must operate and maintain any affected
source, including associated air pollution control equipment and monitoring
equipment, in a manner consistent with safety and good air pollution control
practices for minimizing emissions. The general duty to minimize emissions
does not require the owner or operator to make any further efforts to
reduce emissions if levels required by the applicable standard have been
40 CFR 63.860(d)
Page 11 of 116
RF Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
achieved. Determination of whether a source is operating in compliance with
operation and maintenance requirements will be based on information
available to the Administrator which may include, but is not limited to,
monitoring results, review of operation and maintenance procedures, review
of operation and maintenance records, and inspection of the source.
A.7 Operations
and
Maintenan
ce
N/A Operations and maintenance manual for the Recovery Furnace shall be
developed and followed. A copy of the manual shall be available to Ecology
upon request. Emissions that result from a failure to follow the requirements
of the manual may be considered proof that the equipment was not properly
operated and maintained.
Order 2892-05AQ,
Modification 1,
Condition 11
The following state-only Recovery Furnace requirements are not federally enforceable under the federal Clean Air Act.
RF Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
A.8 PM 0.05 gr/dscf
@ 8% O2, 1-
hour
average
Performance Testing:
Sample M/Q/S/A3 using EPA RM 5.
See Facility-wide General Requirement, Condition 37 for notification
requirements.
Reporting:
Submit source test results in the monthly air report due after results
received by the facility. See Facility-wide General Requirement, Condition
38 for source test report requirements.
Order 2892-05AQ,
Modification 2,
Appendix A,
Condition A.2
40 CFR 70.6(c)(1) for
performance testing
frequency
Page 12 of 116
RF Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
A.9 Total Reduced
Sulfur (TRS)
5.0 ppm @
8% O2, 24-
hour
average
Monitoring:
Monitor continuously using an approved CEMS that conforms to 40 CFR
Part 60, App. F and to App. B, Perf. Spec. 5.
See Facility-wide General Requirement, Condition 26 for CMS operating
requirements.
Reporting:
Report calendar day 24-hour averages and limit exceedances monthly.
WAC 173-405-
040(1)(c) for limit
Order 2892-05AQ,
Modification 2 for
monitoring and
reporting
WAC 173-401-615 for
additional monitoring
A.10
a
O2 No limit -
required to
correct TRS
data
Monitor continuously using an approved CEMS that conforms to 40 CFR
Part 60, App. F and to App. B, Perf. Spec. 3.
See Facility-wide General Requirement, Condition 26 for CMS operating
requirements.
Order 2892-05AQ,
Modification 2,
Appendix A,
Condition A.4
A.10
b
O2
(Operation
and
Maintenance)
13% O2 daily
average for
3-
consecutive
days
(corrective
action
trigger)
Monitoring same as Condition A.10a. If monitoring indicates daily average
O2 in excess of 13% for three consecutive days from the RF exhaust stack,
the Permittee must inspect the RF system for ducting holes or other
sources of dilution air within 3 days and begin corrective action as
necessary. Report excursions, inspection results, and corrective actions
monthly.
WAC 173-405-040(8)
for operation and
maintenance
WAC 173-401-
615(1)(b) for
monitoring
requirement
Page 13 of 116
B. SMELT DISSOLVER TANK (SDT)
The emission unit shall comply with the General Requirements of 40 CFR 63 as listed in Table 1 of Subpart MM.
SDT Parameter Limit (shall
not exceed) Monitoring & Reporting Applicable
Requirements
B.1 PM 0.30 lb/ton of
black liquor
solids (TBLS),
1-hour
average
Performance Testing:
Sample M/Q/S/A3 using EPA RM 5.
See Facility-wide General Requirement, Condition 37 for notification
requirements.
Reporting:
Include source test results in the monthly air report, due after results
received by the Permittee. See Facility-wide General Requirement,
Condition 38 for source test report requirements.
Compliance Assurance Monitoring:
The Permittee shall comply with the general CAM requirements in
Condition O. The Permittee must comply with the monitoring,
corrective action, and violation determination requirements in
Condition B.3.
CAM reporting required on at a minimum semiannual basis.
WAC 173-405-040(2)
WAC 173-401-615 for
performance testing and
reporting
40 CFR 64.2 and 64.6
through 64.9 for
respective PM CAM
monitoring and
reporting/recordkeeping
B.2 HAP Metals
(PM as
surrogate)
0.20 lb/TBLS
(0.10 kg/Mg
of black liquor
solids fired)
Performance Testing:
Sample every 5 years using EPA RM 5. Water must be used as the
cleanup solvent instead of acetone in the sample recovery procedure.
First periodic performance test must be conducted by October 13,
2020 and thereafter every 5 years following the previous performance
test. Performance testing to be conducted in accordance with 40 CFR
63.865.
40 CFR 63.862(a)(1)(i)(B)
for standard
40 CFR 63.863(c)(1) for
5-year periodic
performance test
compliance date
Page 14 of 116
SDT Parameter Limit (shall
not exceed) Monitoring & Reporting Applicable
Requirements
Representative Conditions:
Performance tests shall be conducted based on representative
performance during the period being tested. The owner/operator
must record the process information that is necessary to document
operating conditions during the test and include in such record an
explanation to support that such conditions represent normal
operation. Upon request, the owner/operator shall make available
such records as may be necessary to determine the conditions of
performance tests.
60-day notification:
The Permittee must notify Ecology in writing of their intention to
conduct a performance test at least 60 calendar days before the
performance test is initially scheduled.
Recordkeeping:
The Permittee must maintain records of:
1) All results of performance tests;
2) The process information that is necessary to document
operating conditions during the test and include in such record
an explanation to support that such conditions represent
normal operation;
3) Documentation of supporting calculations for compliance
determinations made under 40 CFR 63.865(a) through (d);
4) For each failure to meet the emission limit, the number of
failures, the date, start time, and duration of each event;
5) For any failure to meet the emission limit, record an estimate
of the quantity of each regulated pollutant emitted over the
40 CFR 63.865 for
performance testing
requirements
40 CFR 63.9(e) and 40
CFR 63.7(b) for
performance test
notification
40 CFR 63.865 and 40
CFR 63.866 for
recordkeeping
40 CFR 63.867(d) for
electronic reporting
Page 15 of 116
SDT Parameter Limit (shall
not exceed) Monitoring & Reporting Applicable
Requirements
emission limit and a description of the method used to
estimate the emissions.
Reporting:
Report failures to meet the applicable standard in the Semi-Annual
Excess Emissions and Continuous Monitoring Systems Performance or
Summary Report in accordance with 40 CFR 63.867(c), delivered or
postmarked by July 30 or January 30 following the end of the
respective calendar half (or on a more frequent basis as determined
necessary by Ecology).
Within 60 days after the date of completing each performance test,
submit the results of the performance test electronically via EPA’s
Compliance and Emissions Data Reporting Interface (CEDRI) in
accordance with 40 CFR 63.867(d).
Include source test results in the monthly air report, due after results
received by the Permittee.
B.3 Opacity 35% average
for more than
6 consecutive
minutes in
any 60 minute
period
EPA RM 9 is the reference test method.
Compliance Assurance Monitoring:
The Permittee shall comply with the general CAM requirements in
Condition O.
The Permittee must maintain and properly operate a monitoring
device (in accordance with manufacturer specifications) for the
continuous measurement of the scrubbing liquid flow rate.
The Permittee must maintain scrubbing liquid flow rate ≥50 gpm. An
excursion is defined as any hour in which scrubber flow is <50 gpm for
more than six consecutive minutes. Take corrective action
WAC 173-405-040(6)
40 CFR 64.2 and 64.6
through 64.9 for
respective PM CAM
monitoring and
reporting/recordkeeping
Page 16 of 116
SDT Parameter Limit (shall
not exceed) Monitoring & Reporting Applicable
Requirements
immediately following an excursion. Failure to take corrective action
within 24 hours is a violation.
The Permittee must reconfirm the existing scrubber liquid flow rate
operational parameter or establish an updated scrubber liquid flow
rate operational parameter. Reconfirmed or reestablished scrubber
operational parameter and updated CAM plan (as needed) must be
submitted to Ecology within 180 days of issuance of the permit
renewal. The updated operational parameter will become effective
upon approval by Ecology.
The Permittee must comply with Conditions B.5, B.6, and B.7 for
compliance assurance monitoring.
Reporting:
Report excursions in the monthly report.
CAM reporting required on at a minimum semiannual basis.
B.4 HAP Metals
(Scrubber
Operating
Limits as
surrogate)
Five
monitoring
parameter
values below
the minimum
operating
limits during
any
semiannual
reporting
period
Monitoring:
The Permittee must calibrate, maintain, and operate a continuous
parametric monitoring system (CPMS) that can be used to determine
and record the scrubbing liquid flow rate at least once every
successive 15-minute period using the procedures in 40 CFR 63.8(c), as
well as the procedures in 40 CFR 63.864(e)(10)(i) and (ii).
The Permittee must install, maintain, and operate a monitoring device
for measurement of scrubber fan amperage.
The Permittee must establish operating limits for scrubbing liquid flow
rate and fan amperage based on performance testing in accordance
with 40 CFR 63.864(j).
40 CFR 63.860 for
requirement to minimize
emissions
40 CFR 63.864 for
monitoring requirements
40 CFR 63.864(k) for
ongoing compliance and
violation determination
40 CFR 63.866 for
recordkeeping
requirements
Page 17 of 116
SDT Parameter Limit (shall
not exceed) Monitoring & Reporting Applicable
Requirements
See Facility-wide General Requirement, Condition 28 for CMS data
recovery requirements.
Scrubbing liquid flow rate is to be maintained ≥99 gpm (3-hr avg) or as
established in the most recent performance test.
Scrubber fan amperage is to be maintained ≥45 amps (3-hr avg) or as
established in the most recent performance test.
Monitoring Exceedance:
The Permittee is required to implement corrective action when the 3-
hr average parameter value is below the minimum operating limit
established, during times when spent pulping liquor is fed.
Violation Determination:
A violation occurs when six or more 3-hour average parameter values
within any 6-month reporting period are below the minimum
operating limits established.
For purposes of determining the number of monitoring exceedances,
no more than one exceedance will be attributed to any given 24-hour
period.
Recordkeeping:
The Permittee must maintain records of:
A. Any occurrence when corrective action is required and when a
violation is noted;
B. Records of parameter monitoring data required under
§63.864, including any period when the operating parameter
levels were inconsistent with the levels established during the
performance test, with a brief explanation of the cause of the
40 CFR 63.867(c) for
excess emission
reporting requirements
Page 18 of 116
SDT Parameter Limit (shall
not exceed) Monitoring & Reporting Applicable
Requirements
monitoring exceedance, the time the monitoring exceedance
occurred, the time corrective action was initiated and
completed, and the corrective action taken;
C. Records of parameter operating limits established for each
affected source or process unit;
D. For each failure to meet the operating limits, the number of
failures, date, start time, and duration of each event;
E. For each failure to meet an operating limit, maintain sufficient
information to estimate the quantity of each regulated
pollutant emitted over the emission limit. This information
must be sufficient to provide a reliable emissions estimate if
requested by the Administrator; and
F. Record actions taken to minimize emissions in accordance with
§63.860(d) and any corrective actions taken to return the
affected unit to its normal or usual manner of operation.
Reporting:
Report minimum daily 3-hour average scrubbing liquid flow, minimum
daily 3-hour average fan amperage, and monitoring exceedances and
associated corrective actions monthly to Ecology.
The Permittee must submit a Semi-Annual Excess Emissions and
Continuous Monitoring Systems Performance or Summary Report in
accordance with 40 CFR 63.10(e)(3) and 40 CFR 63.867(c), delivered or
postmarked by the 30th day following the end of each calendar half
(or on a more frequent basis as determined necessary by Ecology).
Page 19 of 116
SDT Parameter Limit (shall
not exceed) Monitoring & Reporting Applicable
Requirements
B.5 Damper
Inspections
N/A The Permittee must visually inspect the Smelt Dissolver Tank damper
indicator arm position at a minimum of once per day of operation.
If the damper indicator arm is noted to be in the open position, the
following corrective actions must be taken:
1) Close the damper as soon as possible to prevent further bypass
of the air pollution control equipment;
2) Investigate the cause of the opening of the damper and correct
any deficiencies or failures of the equipment to prevent
recurrence; and
3) Proved details regarding date, time, estimated duration of
bypass, corrective actions, and estimated emission in the
appropriate monthly report.
Maintain records of visual inspection. Records must be maintained on-
site and available for inspection by Ecology for a period of five years.
Compliance Order
18124, Condition 1 and 5
B.6 Annual
Damper
Testing
N/A The Permittee must perform non-destructive tests on the Smelt
Dissolver Tank damper welds and ensure the u-bolts are sufficiently
tightened to maintain the damper arm in the closed position.
Maintain records of annual damper testing. Records must be
maintained on-site and available for inspection by Ecology for a period
of five years.
Compliance Order
18124, Condition 2 and 5
Page 20 of 116
SDT Parameter Limit (shall
not exceed) Monitoring & Reporting Applicable
Requirements
B.7 Observation
Hatch
N/A Install and maintain an observation hatch that can be used to visually
inspect or physically verify the damper position.
On a weekly basis, visually inspect or physically verify the damper is
properly positioned and functioning.
In the event that improper damper position or function is observed,
corrective action must be taken. Report details regarding date, time,
estimated duration of bypass, corrective actions taken, and estimated
emission to Ecology in the monthly air report.
Maintain records of visual inspection. Records must be maintained on-
site and available for inspection by Ecology for a period of five years.
Compliance Order
18124, Condition 3, 4,
and 5
C. LIME KILN (LK)
The emission unit shall comply with the General Requirements of 40 CFR 63 as listed in Table 1 of Subpart MM.
LK Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
C.1 PM 0.13 gr/dscf
@ 10% O2, 1-
hr average
Performance Testing:
Sample M/Q/S/A3 using RM 5.
See Facility-wide General Requirement, Condition 37 for notification
requirements.
Reporting
Submit source test results in the monthly air report, due after results
received by the Permittee. See Facility-wide General Requirement,
Condition 38 for source test report requirements.
WAC 173-405-040(3)(a)
WAC 173-401-615 for
performance testing and
reporting
40 CFR 64.2 and 64.6
through 64.9 for
respective PM CAM
monitoring and
reporting/recordkeeping
Page 21 of 116
LK Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
Compliance Assurance Monitoring:
The Permittee shall comply with the general CAM requirements in
Condition O. The Permittee must comply with the monitoring,
corrective action, and violation determination requirements in
Condition C.3.
CAM reporting required on at a minimum semiannual basis.
C.2 HAP Metals
(PM as a
surrogate)
0.064 gr/dscf
(0.15
g/dscm)
@10% O2
Performance Testing:
Sample every 5 years using EPA RM 5. Water must be used as the
cleanup solvent instead of acetone in the sample recovery procedure.
First periodic performance test must be conducted by October 13,
2020 and thereafter every 5 years following the previous performance
test. Performance testing to be conducted in accordance with 40 CFR
63.865.
Representative Conditions:
Performance tests shall be conducted based on representative
performance during the period being tested. The owner/operator
must record the process information that is necessary to document
operating conditions during the test and include in such record an
explanation to support that such conditions represent normal
operation. Upon request, the owner/operator shall make available
such records as may be necessary to determine the conditions of
performance tests.
60-day notification:
40 CFR 63.862(a)(1)(i)(C)
for standard
40 CFR 63.865 for
performance testing
requirements
40 CFR 63.9(e) and 40
CFR 63.7(b) for
performance test
notification
40 CFR 63.865 and 40
CFR 63.866 for
recordkeeping
40 CFR 63.867(d) for
electronic reporting
Page 22 of 116
LK Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
The Permittee must notify Ecology in writing of their intention to
conduct a performance test at least 60 calendar days before the
performance test is initially scheduled.
Recordkeeping:
The Permittee must maintain records of:
1) All results of performance tests;
2) The process information that is necessary to document
operating conditions during the test and include in such record
an explanation to support that such conditions represent
normal operation;
3) Documentation of supporting calculations for compliance
determinations made under 40 CFR 63.865(a) through (d);
4) For each failure to meet the emission limit, the number of
failures, the date, start time, and duration of each event;
5) For any failure to meet the emission limit, record an estimate
of the quantity of each regulated pollutant emitted over the
emission limit and a description of the method used to
estimate the emissions.
Reporting:
Report failures to meet the applicable standard in the Semi-Annual
Excess Emissions and Continuous Monitoring Systems Performance or
Summary Report in accordance with 40 CFR 63.867(c), delivered or
postmarked by July 30 or January 30 following the end of the
respective calendar half (or on a more frequent basis as determined
necessary by Ecology).
Within 60 days after the date of completing each performance test,
submit the results of the performance test electronically via EPA’s
Page 23 of 116
LK Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
Compliance and Emissions Data Reporting Interface (CEDRI) in
accordance with 40 CFR 63.867(d).
Include source test results in the monthly air report, due after results
received by the Permittee.
C.3 Opacity 35% average
for more
than 6
consecutive
minutes in
any 60
minute
period
EPA RM 9 is the reference test method.
Compliance Assurance Monitoring:
The Permittee shall comply with the general CAM requirements in
Condition O.
Ongoing compliance indicated by maintaining venturi pressure drop
≥8 inches of H2O (gauge). The pressure drop operating parameter
must be updated or reconfirmed and submitted to Ecology within 180
days of issuance of the permit renewal. An excursion is defined as any
hour in which the pressure drop is <8 inches of H2O (gauge) for more
than six consecutive minutes. Take corrective action immediately
following an excursion. Failure to take corrective action within 24
hours is a violation.
The Permittee must establish and submit for Ecology approval a
scrubber liquid flow rate operating parameter and updated CAM Plan
that assures compliance with the emission standard within 180 days
of issuance of the permit renewal.
Continuous parameter monitors must be maintained and operated in
accordance with manufacturer specifications.
The Permittee may use updated venturi pressure drop and/or
scrubber liquid flow rate values to demonstrate continuous
compliance upon approval from Ecology.
WAC 173-405-040(6)
40 CFR 64.2 and 64.6
through 64.9 for
respective PM CAM
monitoring and
reporting/recordkeeping
Page 24 of 116
LK Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
Monitoring and Reporting:
Monitor scrubber pressure drop and scrubber liquid flow rate (once
established) continuously; record continuously; report excursions in
the monthly report.
CAM reporting required on at a minimum semiannual basis.
C.4 HAP Metals
(Scrubber
Operating
Limit as a
surrogate)
Five
monitoring
parameter
values below
(for either
the pressure
drop across
the scrubber
or the
scrubber
liquid flow
rate) the
minimum
operating
limits during
any
semiannual
reporting
period
Monitoring:
The Permittee must calibrate, maintain, and operate a CPMS that can
be used to determine and record the pressure drop across the
scrubber and the scrubbing liquid flow rate at least once every
successive 15-minute period using the procedures in 40 CFR 63.8(c), as
well as the procedures in 40 CFR 63.864(e)(10)(i) and (ii).
The Permittee must establish operating limits for pressure drop across
the scrubber and the scrubbing liquid flow rate based on performance
testing in accordance with 40 CFR 63.864(j).
See Facility-wide General Requirement, Condition 28 for CMS data
recovery requirements.
Monitoring Exceedance:
The Permittee is required to implement corrective action when any 3-
hr average parameter value is below the minimum operating limit
established, during times when lime mud is fed, with the exception of
pressure drop during startup and shutdown.
Violation Determination:
A violation of the underlying HAP Metal standard in Condition C.2
occurs when six or more 3-hour average parameter values within any
6-month reporting period are below the minimum operating limits
40 CFR 63.860 for
requirement to minimize
emissions
40 CFR 63.864 for
monitoring requirements
40 CFR 63.864(k) for
ongoing compliance and
violation determination
40 CFR 63.866 for
recordkeeping
requirements
40 CFR 63.867(c) for
excess emission
reporting requirements
Page 25 of 116
LK Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
established, with the exception of pressure drop during startup and
shutdown.
For purposes of determining the number of monitoring exceedances,
no more than one exceedance will be attributed to any given 24-hour
period.
Recordkeeping:
The Permittee must maintain records of:
1) CaO production rates in units of Mg/d or ton/day;
2) Any occurrence when corrective action is required and when a
violation is noted;
3) Records of parameter monitoring data required under
§63.864, including any period when the operating parameter
levels were inconsistent with the levels established during the
performance test, with a brief explanation of the cause of the
monitoring exceedance, the time the monitoring exceedance
occurred, the time corrective action was initiated and
completed, and the corrective action taken;
4) Records of parameter operating limits established for each
affected source or process unit;
5) For each failure to meet the operating limits, the number for
failures, date, start time, and duration of each event;
6) For each failure to meet an operating limit, maintain sufficient
information to estimate the quantity of each regulated
pollutant emitted over the emission limit. This information
must be sufficient to provide a reliable emissions estimate if
requested by the Administrator.
Page 26 of 116
LK Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
7) Record actions taken to minimize emissions in accordance with
§63.860(d) and any corrective actions taken to return the
affected unit to its normal or usual manner of operation.
Reporting:
Report minimum daily 3-hour average pressure drop, minimum daily
3-hour average scrubber liquid flow rate, and monitoring exceedances
and associated corrective actions monthly to Ecology.
The Permittee must submit a Semi-Annual Excess Emissions and
Continuous Monitoring Systems Performance or Summary Report in
accordance with 40 CFR 63.10(e)(3) and 40 CFR 63.867(c), delivered or
postmarked by the 30th day following the end of each calendar half
(or on a more frequent basis as determined necessary by Ecology).
C.5 SO2 500 ppm @
10% O2, 1-hr
average
Performance Testing:
Sample M/Q/S/A3 using EPA modified RM 6.
See Facility-wide General Requirement, Condition 37 for notification
requirements.
Reporting:
Include source test results in the monthly air report due after results
received by the facility. See Facility-wide General Requirement,
Condition 38 for source test report requirements.
WAC 173-405-040 (11)(a)
for limit
WAC 173-401-615 for
performance testing and
reporting
C.6a TRS
(as H2S)
8 ppmdv @
10% O2, 12-
hour average
Monitoring:
Monitor continuously using a CEMS that conforms to 40 CFR Part 60,
Appendix F and Appendix B, PS-5. See Facility-wide General
Requirement, Condition 26 for CMS data recovery requirements.
Order 2892-05AQ,
Modification 2, Appendix
2, Condition B.1
Page 27 of 116
LK Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
Calculate and record on a daily basis 12-hour average TRS and oxygen
concentrations pursuant to Condition C.7 for two consecutive periods
of each operating day. Each 12-hour average shall be determined as
the arithmetic mean of the appropriate 12 contiguous 1-hour average
TRS concentrations provided by the CEMS using the following
equation:
Ccorr = Cmeas × (21− X)/(21− Y)
where:
Ccorr = the concentration corrected for oxygen
Cmeas = the concentration uncorrected for oxygen
X = the volumetric oxygen concentration in percentage to be
corrected to (8 percent for recovery furnaces and 10 percent for
lime kilns, incinerators, or other devices)
Y = the measured 12-hour average volumetric oxygen
concentration.
Reporting:
Report daily maximum concentrations, 12-hr average concentrations,
maximum monthly 12-hr concentrations, and exceedances monthly.
for compliance with
incineration of waste
gases from NSPS units
(Condition F)
Page 28 of 116
LK Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
C.6b TRS Temperature
≥ 1,200 F and
retention
time ≥ 0.5
seconds
when
burning
NCGs
See Condition C.6a for compliance demonstration when burning
NCGs.
40 CFR 60.283(a)(1)(iii)
for limit
WAC 173-401-615(1)(b)
for monitoring gap filling
C.7 O2 No limit –
required for
O2 correction
Monitor and record the percent oxygen by volume on a dry basis,
using a CEMS that conforms to 40 CFR Part 60, Appendix F and
Appendix B, PS-3.
See Facility-wide General Requirement, Condition 26 for continuous
emission monitoring system-operating requirements.
Calculate and record on a daily basis 12-hour average oxygen
concentrations for the two consecutive periods of each operating day.
These 12-hour averages shall correspond to the 12-hour average TRS
concentrations in Condition C.6a and shall be determined as an
arithmetic mean of the appropriate 12 contiguous 1-hour average
oxygen concentrations provided by the continuous monitoring system.
Order 2892-05AQ,
Modification 2, Appendix
A, Condition B.2
C.8 Stack Height N/A Stack Height shall be ≥31 meters before production exceeds 650
tons/D unbleached pulp. PTPC has certified stack height is ≥31 meters.
Report if stack is shortened.
PSD-I
Page 29 of 116
LK Parameter Limit (shall
not exceed) Monitoring & Reporting1 Applicable
Requirements
C.9 Operations
and
Maintenance
N/A Operations and maintenance manual for the Lime Kiln shall be
developed and followed. A copy of the manual shall be available to
Ecology upon request. Emissions that result from a failure to follow
the requirements of the manual may be considered proof that the
equipment was not properly operated and maintained.
Order 2892-05AQ,
Modification 1, Condition
11
The following state-only requirements are not federally enforceable under the federal Clean Air Act:
LK Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
C.10 TRS 20 ppm @ 10%
O2, 24-hr
average
Same as Condition C.6a. WAC 173-405-
040(3)(c) for limit
C.11 TRS 80 ppm H2S @
10% O2 for
more than 2
consecutive
hours
Monitor TRS continuously using an approved CEMS that conforms to 40
CFR 60, App. F and App. B, Perf. Spec. 511. Report excursions monthly (if
the upper range of the monitor is less than 80 ppm, all off scale
measurements shall be considered >80 ppm). All TRS monitored is
considered H2S for this limit.
WAC 173-405-
040(3)(b) for limit
Order 2892-05AQ
(Table 1, C.4) for basis
of monitoring
D. POWER BOILER #10 (PB10)
The source shall also comply with the General Requirements of 40 CFR Part 60, including:
40 CFR 60.7(b) & (f) concerning recordkeeping,
40 CFR 60.7(c), (d), & (e) concerning reporting,
40 CFR 60.11(d) concerning operation and maintenance,
40 CFR 60.12 concerning concealment,
40 CFR 60.13 concerning monitoring,
Page 30 of 116
40 CFR 60.19 concerning notification and reporting.
PB10 shall comply with the General Requirements of 40 CFR Part 63 as listed in Table 10 of Subpart DDDDD.
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
D.1a Particulate
(PM)
0.10 lb/mmBtu,
1-hr average
Performance Testing:
Sample M/Q/S/A3 using EPA RM 5. Performance testing to be
conducted in accordance with 40 CFR 60.46.
See Facility-wide General Requirement, Condition 37 for
notification requirements.
Continuous compliance demonstrated by compliance with
Condition D3.a.
Reporting:
Include source test results in the monthly air report due after
results received by the facility. See Facility-wide General
Requirement, Condition 38 for source test report
requirements.
40 CFR 60.42(a)(1) for
limit
40 CFR 60.46(b)(2) for
test method
D.1b PM 0.2 grains/dscf @
7% O2
Same as above.
Compliance Assurance Monitoring:
The Permittee must comply with the monitoring requirements
in Condition D.3a. Take corrective action immediately
following an exceedance as defined in Condition D.3a. Failure
to take corrective action within 24 hours is a violation of the
limit.
The Permittee shall comply with the general CAM
requirements in Condition O.
WAC 173-405-040(5)(a)
40 CFR 64.2 and 64.6
through 64.9 for
respective PM CAM
monitoring and
reporting/recordkeeping
Page 31 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
CAM reporting required on a semiannual basis, at a minimum.
D.2 HAP metals
(Filterable PM
as a surrogate)
3.7 E-02
lb/MMBtu of
heat input
(Boiler MACT
Emission Limit)
Performance Testing:
Reference Test Method is EPA RM 5. Collect a minimum of 2
dscm per run.
Performance tests to be conducted in accordance with the
requirements in 40 CFR 63.7520.
Conduct tests annually, no more than 13 months after the
previous performance test. If performance tests for at least 2
consecutive years show that emissions are at or below 75
percent of the emission limit and there are no changes in the
operation of the boiler, performance tests may be performed
every third year.
Operating limits (see conditions D.11, D.12, D.13, and D.17)
must be confirmed or reestablished during performance tests.
Develop a site-specific test plan in accordance with 40 CFR
63.7520(a). Upon Ecology request, the Permittee shall submit
the site-specific test plan for approval.
60-day Notification:
Notification of Intent to conduct a performance test must be
provided to the Administrator 60 days before the performance
test is scheduled to begin.
Recordkeeping:
The Permittee must keep records of all performance tests.
40 CFR 63.7500(a)(1) and
Table 2 (Item 7b) for
emission limit
40 CFR 63.7515(a) and
(b) for testing frequency
40 CFR 63.7520 and
Table 5 (Item 1) for
performance testing
requirements
40 CFR 63.7540(a)(1) and
Table 7 (footnote a) for
operating limit
confirmation/reestablish
ment
40 CFR 63.7520(a) for
site-specific test plan
requirement
40 CFR 63.7545(d) for
performance test
notification
40 CFR 63.7555(a)(2) for
recordkeeping
Page 32 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
Reporting:
Semi-annual compliance reporting in accordance with 40 CFR
63.7550.
Within 60 days after the date of completing each performance
test, submit the results of the performance test electronically
via EPA’s Compliance and Emissions Data Reporting Interface
(CEDRI) in accordance with 40 CFR 63.7550(h).
Include source test results in the monthly air report due after
results received by the facility.
40 CFR 63.7515(f) and
63.7550 for reporting
Order 11025, Condition
1.1f (Boiler MACT order)
D.3a PM
(opacity as a
surrogate)
20% except for
one six-minute
period per hour
of not more than
27% opacity
Continuous compliance indicated by maintaining scrubber
recirculation flow ≥ 1553 gpm, scrubber pressure drop (dP) ≥ 6
inches H2O, and precipitator total secondary power ≥ 11.6 kW.
An exceedance is defined as any hour in which scrubber
recirculation flow, scrubber pressure drop, or precipitator total
secondary power are below established compliance values for
more than six consecutive minutes.
See Facility-wide General Requirement, Condition 27 for CMS
operating requirements.
Reporting:
Report minimum 6-minute average scrubber recirculation flow,
minimum 6-minute average scrubber pressure drop, minimum
6-minute average total secondary power, and exceedances
monthly to Ecology.
The Permittee must submit a Semi-Annual Excess Emissions
and Continuous Monitoring Systems Performance or Summary
40 CFR 60.42(a)(2) for
basis of limit
40 CFR 60.45(a) and
60.13(i)(1) for basis of
monitoring
Page 33 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
Report in accordance with 40 CFR 60.7(c) and 40 CFR 60.45(g),
postmarked by July 30 or January 30 following the end of the
respective calendar half (or on a more frequent basis as
determined necessary by Ecology).
D.3b Opacity 20% average for
more than 6
consecutive
minutes in any 60
minute period
EPA RM 9 is the reference test method.
Compliance Assurance Monitoring:
The Permittee must comply with the monitoring requirements
in Condition D.3a. Take corrective action immediately
following an exceedance as defined in Condition D.3a. Failure
to take corrective action within 24 hours is a violation.
The Permittee shall comply with the general CAM
requirements in Condition O.
CAM reporting required on at a minimum semiannual basis.
WAC 173-405-040(6) for
limit
40 CFR 64.2 and 64.6
through 64.9 for
respective PM CAM
monitoring and
reporting/recordkeeping
D.4a SO2 0.80 lb/MMBtu of
heat input
Monitor emissions using fuel sampling and analysis. Analyze
fuel using ASTM D 4294 (Standard Test Method for Sulfur in
Petroleum and Petroleum Products by Energy-Dispersive X-Ray
Fluorescence Spectrometry).
For RFO: analyze fuel shipments for sulfur content. All fuel
fired must be ≤0.76% sulfur by weight. Report all occasions
when fuel with S content >0.76% is burned. Maintain fuel
sulfur analysis records.
For other liquid fuels: analyze fuel shipments for sulfur content
and heat value. Calculate expected SO2 emission rate. Report
results exceeding the limit. Maintain fuel sulfur and heat value
analysis records. Ecology may approve a % sulfur by weight
40 CFR 60.43(a)(1) for
emission limit
40 CFR 60.45(b)(2) for
monitoring
WAC 173-401-615(b)
analytical method and
compliance
specifications
Page 34 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
requirement in lieu of heat value measurements and emission
calculations based on acceptable heat value data.
D.4b SO2 1000 ppm @ 7%
O2, 1-hr average Maintain records of fuel analysis showing all oil fired was ≤2%
sulfur. Report all occasions when fuel with sulfur content >2%
burned.
WAC 173-405-040 (9)(b)
for basis of limit
WAC 173-401-615(1)(b)
compliance
specifications
D.5 NOx
(as NO2)
0.30 lb/MMBtu of
heat input, 3-hr
average
Monitoring:
Monitor continuously using an approved CEMS that conforms
to 40 CFR 60, App. F and App. B, Perf. Spec. 2. Monitor
emission in accordance with 40 CFR 60.45.
See Facility-wide General Requirement, Condition 27 for CEMS
operating requirements.
Reporting:
Report daily maximum 3-hr averages, daily averages, and
excursions monthly.
The Permittee must submit a Semi-Annual Excess Emissions
and Continuous Monitoring Systems Performance or Summary
Report in accordance with 40 CFR 60.7(c) and 40 CFR 60.45(g),
postmarked by July 30 or January 30 following the end of the
respective calendar half (or on a more frequent basis as
determined necessary by Ecology).
40 CFR 60.44(a)(2) for
limit.
40 CFR 60.45(g)(3) for
averaging interval.
40 CFR 60.45(a) and 40
CFR 60.13(d) for
monitoring.
Page 35 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
D.6 TRS Temperature
≥1,200°F and
retention time ≥
0.5 seconds when
burning NCGs
from NSPS
emission units
Monitoring not required. 40 CFR 60.283(a)(1)(iii)
for standard
D.7 O2 No limit –
required for O2
correction
Monitor continuously using an approved CEMS that conforms
to 40 CFR 60, App. F and App. B, Perf. Spec. 3.
See Facility-wide General Requirement, Condition 27 for CEMS
operating requirements.
40 CFR 60.45(a) for
oxygen monitoring
D.8 Stack Height N/A Stack Height shall be ≥53 meters before production exceeds
650 tons/D unbleached pulp. The Permittee has certified stack
height is ≥53 meters. Report if stack is shortened.
PSD-I, Condition 3
D.9 Salty Hog Fuel N/A Monitor hog fuel shipments. Report any salty hog fuel (hog
fuel from logs transported and/or stored in salt water) burned
in monthly report.
WAC 173-401-615
D.10 Urban Wood
Acceptance
Program
N/A All urban wood purchased by the Permittee must meet an
urban wood acceptance program included as part of the PB10
operations and maintenance manual (Condition D.23). The
acceptance program must include acceptance criteria which, at
a minimum, prohibits wood treated with creosote,
pentachlorophenol, or copper-chrome-arsenic; municipal
waste; hazardous material contaminants (asbestos, lead,
mercury); lead painted items; and plastic coatings.
Order 11025, Condition 5
Page 36 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
Any changes to the acceptance program must be submitted to
Ecology prior to instituting the changes.
D.11 CO 720 ppm by
volume on a dry
basis @ 3% O2,
30-day rolling
average
Monitoring
The Permittee must you must install, certify, operate, and
maintain a CO CEMS and an oxygen analyzer according to the
applicable procedures under Performance Specification 4, 4A,
or 4B at 40 CFR Part 60, Appendix B; the site-specific
monitoring plan developed according to 40 CFR 63.7505(d);
and the requirements in 40 CFR 63.7540(a)(8) and 40 CFR
63.7525(a).
The Permittee must follow the quality assurance procedures
(e.g., quarterly accuracy determinations and daily calibration
drift tests) of Procedure 1 of Appendix F to 40 CFR Part 60. The
measurement span value of the CO CEMS must be two times
the applicable CO emission limit, expressed as a concentration.
Complete a minimum of one cycle of CO and oxygen (or CO2)
CEMS operation (sampling, analyzing, and data recording) for
each successive 15-minute period. Collect CO and oxygen (or
CO2) data concurrently. Collect at least four CO and oxygen (or
CO2) CEMS data values representing the four 15-minute
periods in an hour, or at least two 15-minute data values
during an hour when CEMS calibration, quality assurance, or
maintenance activities are being performed.
Reduce the CO CEMS data as specified in 40 CFR 63.8(g)(2).
Calculate one-hour arithmetic averages, corrected to 3 percent
oxygen (or corrected to a CO2 percentage determined to be
40 CFR 63.7500(a)(1) and
Table 2 (Item 7a) for
emission limit
40 CFR 63.7525(a) for
monitoring
40 CFR 63.7540 and
63.7555(b) for
recordkeeping
40 CFR 63.7550 and
Table 9 for reporting
Order 11025, Condition
1.1e (Boiler MACT order)
Page 37 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
equivalent to 3 percent oxygen) from each hour of CO CEMS
data in parts per million CO concentration. The one-hour
arithmetic averages required shall be used to calculate the 30-
day rolling average emissions. Use Equation 19-19 in Section
12.4.1 of Method 19 of 40 CFR Part 60, Appendix A-7 for
calculating the average CO concentration from the hourly
values.
For purposes of collecting CO data, operate the CO CEMS as
specified in §63.7535(b). You must use all the data collected
during all periods in calculating data averages and assessing
compliance, except that you must exclude certain data as
specified in §63.7535(c). Periods when CO data are unavailable
may constitute monitoring deviations as specified in
§63.7535(d).
See Facility-wide General Requirement, Condition 28 for CEMS
operating requirements.
Recordkeeping
Keep records of CO levels according to §63.7555(b).
Reporting
Report daily 30-day rolling average CO (ppmdv @ 3% O2) in the
monthly report. Report exceedances monthly.
Semi-annual compliance reporting in accordance with 40 CFR
63.7550. The Permittee must submit a semi-annual compliance
report and performance evaluations of CMS through CEDRI in
the EPA’s CDX.
Page 38 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
D.12 HAP Metals
and Mercury
(WESP
Operating
Limit)
Maintain the 30-
day rolling
average total
secondary
electric power
input of the
electrostatic
precipitator at or
above the
operating limits
established
during the
performance test
demonstrating
compliance with
the PM or
Mercury emission
limit
Monitoring:
The Permittee shall install sensors to measure (secondary)
voltage and current to the precipitator collection plates.
Develop a site-specific monitoring plan in accordance with 40
CFR 63.7505(d). Upon Ecology request, the Permittee shall
submit the site specific monitoring plan for approval.
Performance evaluations of the electric power monitoring
system must be conducted in accordance with the monitoring
plan at the time of each performance test but no less
frequently than annually.
Continuous compliance demonstrated in accordance with 40
CFR 63.7540 and Table 8 (Item 7) in the subpart.
See Facility-wide General Requirement, Condition 28 for CMS
data recovery requirements.
Establishing Operating Limit:
Secondary power operating limit to be established according
to Table 7 (Item 1b) in the subpart. Operating limit must be
confirmed or reestablished during performance tests.
Minimum total secondary electric power input must be set at
the higher of the minimum values established during the
performance tests for HAP metals and mercury.
Recordkeeping:
The Permittee shall keep records of all monitoring data and
calculated averages for secondary power.
40 CFR 63.7525(h)
40 CFR 63.7500(a)(2) and
Table 4 (Item 4b) for
operating limit
40 CFR 63.7540 and
Table 8 (Item 7) for
monitoring requirements
40 CFR Part 63, Subpart
DDDDD, Table 7 (Item
1b) for establishing
operating limit
40 CFR 63.7555 for
recordkeeping
40 CFR 63.7550 and
Table 9 for reporting
Page 39 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
Reporting:
Report daily 30-day rolling average total secondary electric
power input of the electrostatic precipitator in the monthly
report. Semi-annual compliance reporting in accordance with
40 CFR 63.7550.
D.13 HAP Metals
and Mercury
(Scrubber
Operating
Limit)
Maintain the 30-
day rolling
average pressure
drop at or above
the lowest one-
hour average
pressure drop
measured during
the performance
test
demonstrating
compliance with
the PM or
mercury emission
limit
Monitoring:
Continuously monitor the scrubber pressure drop using a
pressure monitoring system according to 40 CFR 63.7525(f).
Demonstrate continuous compliance in accordance with 40
CFR 63.7540 and Table 8 (Item 4) of the subpart.
Develop a site-specific monitoring plan in accordance with 40
CFR 63.7505(d). Upon Ecology request, the Permittee shall
submit the site-specific monitoring plan for approval.
See Facility-wide General Requirement, Condition 28 for CMS
data recovery requirements.
Establishing Operating Limit:
Pressure drop to be established according to Table 7 (Item 1a)
in the subpart. Operating limit must be confirmed or
reestablished during performance tests. Minimum pressure
drop must be set at the higher of the minimum values
established during the performance test for HAP metals and
mercury.
Recordkeeping:
40 CFR 63.7525(f)
40 CFR 63.7540 and
Table 8 (Item 4) for
monitoring requirements
40 CFR 63.7500(a)(2) and
Table 4 (Item 1) for
operating limit
40 CFR 63.7505(d) for
site-specific monitoring
plan
40 CFR Part 63, Subpart
DDDDD, Table 7 (Item 1)
for establishing
operating limit
40 CFR 63.7555 for
recordkeeping
40 CFR 63.7550 and
Table 9 for reporting
Page 40 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
The Permittee shall keep records of all monitoring data and
calculated averages for scrubber pressure drop.
Reporting:
Report daily 30-day rolling average pressure drop in the
monthly report. Report exceedances monthly.
Semi-annual compliance reporting in accordance with 40 CFR
63.7550.
D.14 HAP Metals
and Mercury
(Scrubber
Operating
Limit)
Maintain the 30-
day rolling
average liquid
flow rate at or
above the lowest
one-hour average
liquid flow rate
measured during
the performance
test
demonstrating
compliance with
the PM or
mercury emission
limit
Monitoring:
Continuously monitor the scrubber liquid flow rate using a flow
monitoring system according to 40 CFR 63.7525(e).
Demonstrate continuous compliance in accordance with 40
CFR 63.7540 and Table 8 (Item 4) of the subpart.
Develop a site-specific monitoring plan in accordance with 40
CFR 63.7505(d). Upon Ecology request, the Permittee shall
submit the site-specific monitoring plan for approval.
See Facility-wide General Requirement, Condition 28 for CMS
data recovery requirements.
Establishing Operating Limit:
Scrubber liquid flow rate to be established according to Table 7
(Item 1) in the subpart. Operating limit must be confirmed or
reestablished during performance tests. Minimum liquid flow
rate must be set at the higher of the minimum values
established during the performance tests for HAP metals and
mercury.
40 CFR 63.7525(e)
40 CFR 63.7540 and
Table 8 (Item 4) for
monitoring requirements
40 CFR 63.7500(a)(2) and
Table 4 (Item 1) for
operating limit
40 CFR 63.7505(d) for
site-specific monitoring
plan
40 CFR Part 63, Subpart
DDDDD, Table 7 (Item 1)
for establishing
operating limit
40 CFR 63.7555 for
recordkeeping
Page 41 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
Recordkeeping:
The Permittee shall keep records of all monitoring data and
calculated averages for scrubber liquid flow rate.
Reporting:
Report daily 30-day rolling average scrubber liquid flow rate in
the monthly report. Report exceedances monthly.
Semi-annual compliance reporting in accordance with 40 CFR
63.7550.
40 CFR 63.7550 and
Table 9 for reporting
D.15 HCl 2.2 E-02 lb per
MMBtu of heat
input
(Boiler MACT
Emission Limit)
Performance Testing:
Reference Test Method is EPA RM 26 or 26A.
Performance tests to be conducted in accordance with the
requirements in 40 CFR 63.7520.
Conduct tests annually, no more than 13 months after the
previous performance test. If performance tests for at least 2
consecutive years show that emissions are at or below 75
percent of the emission limit and there are no changes in the
operation of the boiler, performance tests may be performed
every third year.
Develop site-specific test and fuel monitoring plans in
accordance with 40 CFR 63.7520(a) and 40 CFR 63.7521(b).
Upon Ecology request, the Permittee shall submit the test and
monitoring plan for approval.
60-day Notification:
40 CFR 63.7500(a)(1) and
Table 2 (Item 1a) for
emission limit
40 CFR 63.7515(a) and
(b) for testing frequency
40 CFR 63.7545(d) for
performance test
notification
40 CFR 63.7520 and
Table 5 (Item 3) for
performance testing
requirements
40 CFR 63.7520(a) for
site-specific test plan
requirement
Page 42 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
Notification of Intent to conduct a performance test must be
provided to the Administrator 60 days before the performance
test is scheduled to begin.
Recordkeeping:
The Permittee must keep records of all performance tests.
Reporting:
Semi-annual compliance reporting in accordance with 40 CFR
63.7550.
Within 60 days after the date of completing each performance
test, submit the results of the performance test electronically
via EPA’s Compliance and Emissions Data Reporting Interface
(CEDRI) in accordance with 40 CFR 63.7550(h).
Include source test results in the monthly air report due after
results received by the facility.
40 CFR 63.7521(b) for
site-specific fuel
monitoring plan
40 CFR 63.7555 for
recordkeeping
40 CFR 63.7515(f) and
63.7550 for reporting
Order 11025, Condition
1.1c (Boiler MACT Order)
D.16 Mercury 5.7 E-06 lb per
MMBtu of heat
input
(Boiler MACT
Emission Limit)
Performance Testing:
Reference Test Method is EPA RM 29, 30A, 30B, or alternate
method listed in 40 CFR Part 63, Subpart DDDDD Table 5, Item
4e.
Performance tests to be conducted in accordance with the
requirements in 40 CFR 63.7520.
Conduct tests annually, no more than 13 months after the
previous performance test. If performance tests for at least 2
consecutive years show that emissions are at or below 75
percent of the emission limit and there are no changes in the
40 CFR 63.7500(a)(1) and
Table 2 (Item 1b) for
emission limit
40 CFR 63.7515(a) and
(b) for testing frequency
40 CFR 63.7545(d) for
performance test
notification
40 CFR 63.7520 and
Table 5 (Item 4) for
Page 43 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
operation of the boiler, performance tests may be performed
every third year.
Develop site-specific test and fuel monitoring plans.
60-day Notification:
Notification of Intent to conduct a performance test must be
provided to the Administrator 60 days before the performance
test is scheduled to begin.
Recordkeeping:
The Permittee must keep records of all performance tests.
Reporting:
Semi-annual compliance reporting in accordance with 40 CFR
63.7550.
Within 60 days after the date of completing each performance
test, submit the results of the performance test electronically
via EPA’s Compliance and Emissions Data Reporting Interface
(CEDRI) in accordance with 40 CFR 63.7550(h).
Include source test results in the monthly air report due after
results received by the facility.
performance testing
requirements
40 CFR 63.7520(a) for
site-specific test plan
requirement
40 CFR 63.7521(b) for
site-specific fuel
monitoring plan
40 CFR 63.7555 for
recordkeeping
40 CFR 63.7515(f) and
63.7550 for reporting
Order 11025, Condition
1.1d (Boiler MACT Order)
Page 44 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
D.17 Mercury and
HCl
Equal to or lower
fuel input of
chlorine and
mercury than the
maximum values
calculated during
the most recent
performance test
Keep records of monthly fuel use, including type(s) of fuel and
amount(s) used.
Maintain a copy of all calculations and supporting
documentation for maximum chlorine and mercury fuel input.
Any plans to burn a new fuel or new mixture of fuels require
that the maximum mercury and HCl input be recalculated.
Compliance reporting in accordance with 40 CFR 63.7550.
40 CFR 63.7540(a)(2)(ii)
for continuous
compliance
demonstration
40 CFR 63.7555(d) for
recordkeeping
40 CFR 63.7540(a)(4) and
(6) for new fuel
recalculation
40 CFR 63.7550 for
reporting
D.18 Any pollutant
for which
compliance is
demonstrated
by a Boiler
MACT
performance
test (Operating
Limit)
Maintain 30-day
rolling average
operating load ≤
110% of the
highest hourly
average
operating load
recorded during
the performance
test
Collect operating load data or steam generation data every 15
minutes. Reduce the data to 30-day rolling averages.
See Facility-wide General Requirement, Condition 28 for CMS
data recovery requirements.
Report daily 30-day rolling average operating load in the
monthly report. Report exceedances monthly.
Compliance reporting in accordance with 40 CFR 63.7550.
40 CFR 63.7500(a)(2) and
Table 4 (Item 7) for
operating limit
40 CFR 63.7520 and
Table 7 (Item 5) for
establishing operating
limit; Table 7 (footnote
a) for operating limit
confirmation/reestablish
ment
40 CFR 63.7540 and
Table 8 (Item 10) for
boiler operating load
data collection
requirements
Page 45 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
40 CFR 63.7550 for
reporting
D.19 Work Practice
Standard
Tune-up For a boiler or process heater with a continuous oxygen trim
system that maintains an optimum air to fuel ratio, the
boiler/process heater tune-up must be performed as specified
in 40 CFR 63.7540(a)(12) and Table 3.
If the boiler/process heater removes the continuous oxygen
trim system, the boiler/process heater tune-up must be
performed annually as specified in 40 CFR 63.7540(a)(10) and
Table 3.
Report in accordance with 40 CFR 63.7550(c)(1).
40 CFR 63.7540(a)(12)
and Table 3 (Item 1) for
once every five year
tune-ups (continuous
oxygen trim system)
40 CFR 63.7540(a)(10)
and Table 3 (Item 3) for
annual tune-ups
40 CFR 63.7550(c)(1) for
reporting
D.20 Startup (Work
Practice
Standard)
The Permittee
must comply with
all applicable
emission limits at
all times except
for startup
periods
conforming with
this work practice
standard
All CMS must be operated during startup.
The Permittee must use one or a combination of clean fuels as
listed in 40 CFR Part 63, Subpart DDDDD, Table 3 (Item 5.b).
Once firing non-clean fuels during startup, emissions must be
vented to the main stack(s) and all emission control devices
must be engaged.
Monitoring data must be collected during startup, as specified
in 40 CFR 63.7535(b).
Records must be kept during periods of startup as specified in
40 CFR 63.7555.
Reporting in accordance with 40 CFR 63.7550.
40 CFR 63.7500(f) and
Table 3 (Item 5)
40 CFR 63.7535(b) for
monitoring requirements
40 CFR 63.7555(d)(9) and
(10) for recordkeeping
40 CFR 63.7550 for
reporting
40 CFR 63.7575 for
definition of startup
Page 46 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
D.21 Shutdown
(Work Practice
Standard)
The Permittee
must comply with
all applicable
emission limits at
all times except
for shutdown
periods
conforming with
this work practice
standard.
All CMS must be operated during shutdown.
While firing non-clean fuels during shutdown, emissions must
be vented to the main stack(s) and all emission control devices
must be engaged.
Monitoring data must be collected during shutdown, as
specified in 40 CFR 63.7535(b).
Records must be kept during periods of shutdown as specified
in 40 CFR 63.7555.
Reporting in accordance with 40 CFR 63.7550.
40 CFR 63.7500(f) and
Table 3 (Item 6)
40 CFR 63.7535(b) for
monitoring requirements
40 CFR 63.7555(d)(9) and
(10) for recordkeeping
40 CFR 63.7550 for
reporting
40 CFR 63.7575 for
definition of startup
D.22 Startup/Shutd
own
Recordkeeping
N/A The Permittee must maintain startup/shutdown records
regarding the following:
1) The calendar date, time, occurrence and duration of each
startup and shutdown;
2) The type(s) and amount(s) of fuels used during each
startup and shutdown.
40 CFR 63.7555
D.23 Operations
and
Maintenance
Manual
N/A The Permittee must follow and maintain an operations and
maintenance manual for PB10 and associated monitoring and
air pollution control equipment. A copy of the manual must be
available to Ecology during inspections and upon request.
Order 11025, Condition 7
Page 47 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
D.24 Operations
and
Maintenance
N/A At all times, the Permittee must operate and maintain any
affected source, including associated air pollution control
equipment and monitoring equipment, in a manner consistent
with safety and good air pollution control practices for
minimizing emissions. Determination of whether such
operation and maintenance procedures are being used will be
based on information available to the Administrator that may
include, but is not limited to, monitoring results, review of
operation and maintenance procedures, review of operation
and maintenance records, and inspection of the source.
General Recordkeeping:
The Permittee must maintain records of:
1) The occurrence and duration of each malfunction of
the boiler or process heater, or of the associated air
pollution control and monitoring equipment; and
2) Actions taken during periods of malfunction to
minimize emissions in accordance with the general duty
to minimize emissions in §63.7500(a)(3), including
corrective actions to restore the malfunctioning boiler
or process heater, air pollution control, or monitoring
equipment to its normal or usual manner of operation.
40 CFR 63.7500(a)(3)
40 CFR 63.7555(d)(6) and
(7) for recordkeeping
D.25 Monitoring
Data Collection
N/A The Permittee shall operate the monitoring system and collect
data at all required intervals at all times that the boiler is
operating and compliance is required, except for periods of
monitoring system malfunctions or out of control periods (see
40 CFR 63.8(c)(7)), and required monitoring system quality
assurance or control activities, including, as applicable,
40 CFR 63.7535
Page 48 of 116
PB10 Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
calibration checks, required zero and span adjustments, and
scheduled CMS maintenance as defined in your site-specific
monitoring plan. A monitoring system malfunction is any
sudden, infrequent, not reasonably preventable failure of the
monitoring system to provide valid data. Monitoring system
failures that are caused in part by poor maintenance or
careless operation are not malfunctions. You are required to
complete monitoring system repairs in response to monitoring
system malfunctions or out-of-control periods and to return
the monitoring system to operation as expeditiously as
practicable.
E. PACKAGE BOILER (PKB)
The source shall also comply with the General Requirements of 40 CFR Part 60, including:
40 CFR 60.7(b) & (f) concerning recordkeeping,
40 CFR 60.7(c), (d), & (e) concerning reporting,
40 CFR 60.11(d) concerning operation and maintenance,
40 CFR 60.12 concerning concealment,
40 CFR 60.13 concerning monitoring,
40 CFR 60.19 concerning notification and reporting.
PKB Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
E.1a Particulate
(PM)
0.01 lb/mmBtu, 30-
day rolling average
Performance Testing:
Initial compliance determined in accordance with 40 CFR Part 60,
Appendix A, Reference Method 5, or an approved alternative
PSD 96-01A,
Amendment 1,
Condition III.B for
limit
Page 49 of 116
PKB Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
method; if the initial test is under the limit, no further testing is
required.
Monitoring:
Continuous compliance is determined through burning only
natural gas and good combustion controls.
PSD 96-01A,
Amendment 1,
Condition IV.B for
monitoring
E.1b PM 0.1 gr/dscf @ 7% O2,
1-hr average
Same as previous limit. WAC 173-405-
040(5)(c)
E.1c PM 10 tpy, calendar year
total
Report calendar year total annually. PSD 96-01A,
Amendment 1,
Condition III.B
E.2a Opacity 15% averaged over 6
consecutive minutes
Monitor continuously using a COMS that conforms to 40 CFR Part
60, App. F and App. B, Perf. Spec. 1. Compliance may also be
determined using EPA RM 9. Report excursions monthly.
See Facility-wide General Requirement, Condition 26 for CEMS
operating requirements.
Report exceedances and daily maximum 6-minute average
opacities in the monthly report.
PSD 96-01A,
Amendment 1,
Condition VI.C for
monitoring
Condition VII.A.3 for
reporting
E.2b Opacity Average 20% opacity
for more than 6
consecutive minutes
in any 60 minute
period
EPA RM 9 is the reference test method.
Continuous monitoring same as above.
The alternative opacity standards in WAC 173-400-040(2)(a) apply
for soot blowing and grate cleaning activities.
WAC 173-405-040(6)
for limit
Page 50 of 116
PKB Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
E.3a SO2 1000 ppm @ 7% O2,
1-hr average
Performance Testing:
Sample once every five years/annually/monthly4 using EPA RM 6,
6a, 6b, or 6c. See Facility-wide General Requirement, Condition
37 for notification requirements.
Reporting:
Include source test results in the monthly air report due after
results received by the facility. Report excursions from the
identified good combustion practices in the monthly report.
See Facility-wide General Requirement, Condition 38 for source
test report requirements.
Order DE 97AQ-I030,
Second Revision,
Condition 1.a for
performance testing
WAC 173-405-
040(9)(b)
E3.b SO2 Only natural gas, as
defined in 40 CFR 72.2
may be used as fuel
Operate the boiler in accordance with the good combustion
practices identified in the Operations and Maintenance Manual
(Condition E.11).
The Permittee must obtain and maintain fuel receipts (such as a
current, valid purchase contract, tariff sheet, or transportation
contract) from the supplier of the natural gas that will be
combusted in the package boiler that certifies that the gaseous
fuel meets the definition of natural gas as defined in 40 CFR
60.41b. Compliance shall be demonstrated by certifying that only
natural gas was combusted in the package boiler during that
month in the monthly report submitted.
Reporting:
Report excursions from the identified good combustion practices
in the monthly report.
Order DE 97AQ-I030,
Second Revision,
Condition 1.a and 2
PSD 96-01A,
Amendment 1,
Condition V.C
Page 51 of 116
PKB Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
E.4a NOx (as NO2) 0.2 lb/MMBtu, 30-day
rolling average
Performance Testing:
Initial compliance determined using EPA Method 7E.
Monitoring:
Continuous compliance is determined by a CEMS for NOx and an
oxygen meter. The concentration determined by the CEMS (ppm)
shall be used to determine the emission rate (lb/MMBtu). The
conversion of measured concentration to emission rate in
lb/MMBtu shall be by using the formula found in 40 CFR Part 60,
Appendix A, Method 19, Section 2.1.
See Facility-wide General Requirement, Condition 26 for CEMS
operating requirements.
Reporting:
For each steam generating day, submit a report within 15 days of
the end of each calendar month which includes:
1) Calendar date;
2) Average hourly NOx emission rate in lb/MMBtu;
3) 30-day rolling average NOx emission rate in lb/MMBtu;
4) Identification of each day the 30-day rolling average is in
excess of the NOx standard, including reasons for the
excess and description of the corrective action taken;
5) Identification of any steam generating days for which NOx
data were not obtained, including reasons for not
obtaining sufficient data and description of corrective
actions taken;
PSD 96-01A,
Amendment 1,
Condition III.A and 40
CFR 60.44b for limit
PSD 96-01A,
Amendment 1,
Condition V.D for
source testing
PSD 96-01A,
Amendment 1,
Condition VI.E for
monitoring
PSD 96-01A,
Amendment 1,
Condition VII.A for
recordkeeping and
reporting
Page 52 of 116
PKB Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
6) Identification of times emission data are excluded from
the calculated average emission rate and the reasons for
excluding the data;
7) Identification of the “F” factor used for calculations, the
method of determining the factor, and the type of fuel
combusted.
E.4b NOx
(as NO2)
0.2 lb/MMBtu, 30-day
rolling average
Monitoring:
Monitor continuously using an approved CEMS that conforms to
40 CFR Part 60, App. F and App. B, Perf. Spec. 2 and in accordance
with 40 CFR 60.48b.
See Facility-wide General Requirement, Condition 27 for CEMS
operating requirements.
Recordkeeping:
The Permittee must maintain records of the following
information for each steam generating day:
1) Calendar date;
2) The average hourly NOx emission rates (expressed as
NO2)(ng/J or lb/MMBtu heat input) measured or
predicted;
3) The 30-day average NOx emission rates (ng/J or lb/MMBtu
heat input) calculated at the end of each steam generating
unit operating day from the measured or predicted hourly
nitrogen oxide emission rates for the preceding 30 steam
generating unit days;
4) Identification of the steam generating unit operating days
when the calculated 30-day average NOx emission rates
40 CFR 60.44b(a) for
limit
40 CFR 60.48b for
monitoring
40 CFR 60.49(b)(i)
and 40 CFR 60.7(c)
for reporting
Page 53 of 116
PKB Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
are in excess of the NOx emission standard, with the
reasons for such excess emissions as well as a description
of corrective actions taken;
5) Identification of the steam generating unit operating days
for which pollutant data have not been obtained,
including reasons for not obtaining sufficient data and a
description of corrective actions taken;
6) Identification of the times when emission data have been
excluded from the calculation of average emission rates
and the reasons for excluding data;
7) Identification of “F” factor used for calculations, method
of determination, and type of fuel combusted;
8) Identification of the times when the pollutant
concentration exceeded full span of the CEMS;
9) Description of any modification to the CEMS that could
affect the ability of the CEMS to comply with PS-2 or 3;
and
10) Results of daily CEMS drift test and quarterly accuracy
assessments.
Reporting:
The Permittee must submit a Semi-Annual Excess Emissions and
Continuous Monitoring Systems Performance or Summary Report
in accordance with 40 CFR 60.7(c), postmarked by the 30th day
following the end of each six-month period (or on a more
frequent basis in accordance with the criteria in 40 CFR 60.7(c)).
Page 54 of 116
PKB Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
E.4c NOx 50 tpy, calendar year
total
Report monthly the daily and accumulated mass per calendar
year of NOx.
PSD 96-01A,
Amendment 1,
Condition III.A for
limit
PSD 96-01A,
Amendment 1,
Condition VII.A for
reporting
E.5 O2 N/A - No limit Monitor continuously using an approved CEMS that conforms to
40 CFR Part 60, App. F and App. B, Perf. Spec. 3.
See Facility-wide General Requirement, Condition 26 for CEMS
operating requirements.
PSD 96-01A,
Amendment 1,
Conditions VI.E
E.6 Fuel
Consumption
497,250 MMBtu/year
(5,664 MMBtu/day)
Fuel shall be natural gas. Reprocessed fuel oil (RFO) shall not be
used as fuel for the Package Boiler.
The maximum amount of fuel burned in the boiler shall not
exceed 497,250 MMBtu/year and 5,664 MMBtu/day.
Monitoring:
Monitor in standard cubic feet/hr and MMBtu/hr using a meter
capable of measuring the flow rate with an accuracy of +/- 0.5%.
The meter shall be calibrated using the method and frequency
specified by the manufacturer.
Reporting:
Report monthly the amount of fuel burned daily in standard cubic
feet and MMBtu/day, the total amount of fuel burned during the
PSD 96-01A,
Amendment 1,
Condition V.A
Order DE 97AQ-I030,
Second Revision,
Condition 1.d for fuel
consumption limit,
monitoring, and
reporting
Page 55 of 116
PKB Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
month in standard cubic feet and MMBtu/month, and the
cumulative total of fuel burned during the previous twelve
months in standard cubic feet and MMBtu/year.
E.7a CO 0.0359 lb/MMBtu, 1-
hr average
Performance Testing:
Sample once every five years/annually/monthly4 using EPA RM
10. See Facility-wide General Requirement, Condition 37 for
notification requirements.
Monitoring:
Operate the boiler in accordance with the good combustion
practices identified in the Operations and Maintenance Manual
(Condition E.11).
Reporting:
Include source test results in the monthly air report due after
results received by the facility. Report excursions from the
identified good combustion practices in the monthly report.
See Facility-wide General Requirement, Condition 38 for source
test report requirements.
Order DE 97AQ-I030,
Second Revision,
Condition 1.b
E.7b CO 8.9 tpy Report annually. Calculate emissions in tons per year using the
following equation:
Tons/year = (measured concentration in ppmdv x source test air
flow rate in dscfm x molar mass in lb per lbmol x 385 scf per lbmol
x time adjustment)/2000 lbs
Order DE 97AQ-I030,
Second Revision,
Condition 1.b
Page 56 of 116
PKB Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
E.8a VOC (as
carbon)
0.002 lb/MMBtu, 1-hr
average
Performance Testing:
Sample once every five years/annually/monthly4 using EPA RM
25A. See Facility-wide General Requirement, Condition 37 for
notification requirements.
Monitoring:
Operate the boiler in accordance with the good combustion
practices identified in the Operations and Maintenance Manual
(Condition E.11).
Reporting:
Include source test results in the monthly air report due after
results received by the facility. Report excursions from the
identified good combustion practices in the monthly report.
See Facility-wide General Requirement, Condition 38 for source
test report requirements.
Order DE 97AQ-I030,
Second Revision,
Condition 1.c
E.8b VOC (as
carbon)
0.50 tpy Report annually. Calculate emissions in tons per year using the
following equation:
Tons/year = (measured concentration in ppmdv x source test air
flow rate in dscfm x molar mass in lb per lbmol x 385 scf per lbmol
x time adjustment)/2000 lbs
Order DE 97AQ-I030,
Second Revision,
Condition 1.c
Page 57 of 116
PKB Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
E.9 Work
Practice
Standard
Boiler Tune-up The Permittee must perform boiler tune-ups every five years as
specified in 40 CFR 63.7540(a)(12) and Table 3.
If the unit is not operating on the required date for a tune-up, the
tune-up must be conducted within 30 calendar days of startup.
Five-year compliance report required in accordance with 40 CFR
63.7550(b) and (c)(1).
40 CFR 63.7510(j) for
initial compliance
requirements
40 CFR 40 CFR
63.7540(a)(12) and
Table 3 (Item 1) for
tune-ups
40 CFR 63.7550(b)
and (c)(1) for
reporting
E.10 Operations
and
Maintenance
Manual
N/A Within 90 days of initial start-up of the boiler on natural gas, the
Permittee shall identify boiler operational parameters and
practices that have been described as “good combustion
practices.” Such identification shall be included in an operation
and maintenance (O&M) manual for the boiler. The O&M manual
shall also include a description of records that will be maintained
to insure the continuous application of “good combustion
practice.”
The Package Boiler must be operated and maintained in a manner
consistent with safety and good air pollution control practices for
minimizing emissions at all times. The operation and maintenance
manual must be followed. A copy of the manual must be available
to Ecology during inspections and upon request.
PSD 96-01A,
Amendment 1,
Condition VI.D
Order DE 97AQ-I030,
Second Revision,
Condition 4
Page 58 of 116
PKB Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
E.11 PSD CEMS
Reporting
N/A A quarterly report, within 30 days after the end of each calendar
quarter, shall be submitted to Ecology which includes the
following CEMS data:
a) Days for which data was not collected;
b) Reasons for which data was not collected;
c) Identification of times when the pollutant concentration
exceeds span of the CEMS;
d) Description of any modifications to the CEMS that could
affect the ability of the system to comply with
Performance Specifications 2 or 3;
e) Results of any CEMS drift tests.
PSD 96-01A,
Amendment 1,
Condition VII.A.4
F. DIGESTERS, MULTI-EFFECT EVAPORATORS, WASHERS
The MEE E-set, C-washer, and Digesters #10, 11, and 12 are NSPS applicable units (40 CFR Part 60, Subpart BB). These sources shall
comply with the general requirements of 40 CFR Part 60, including:
40 CFR 60.7(b) & (f) concerning recordkeeping,
40 CFR 60.7(c), (d), & (e) concerning reporting,
40 CFR 60.11(d) concerning operation and maintenance,
40 CFR 60.12 concerning concealment,
40 CFR 60.13 concerning monitoring,
40 CFR 60.19 concerning notification and reporting.
Digesters,
MEE, and
Washers
Parameter Limit (shall not
exceed) Monitoring & Reporting Applicable
Requirements
F.1 TRS 5 ppmdv @ 10 %
O2, unless
The Permittee must combust gases from NSPS Subpart BB
applicable units in the Lime Kiln or Power Boiler 10. Gases must
40 CFR 60.283(a)(1) for
emission limit
Page 59 of 116
Digesters,
MEE, and
Washers
Parameter Limit (shall not
exceed) Monitoring & Reporting Applicable
Requirements
combusted in the
lime kiln or Power
Boiler 10
be subjected to a minimum temperature of 1200 °F for at least
0.5 seconds.
Monitoring:
Compliance with Condition C.6a or D.6 shall be used to
demonstrate compliance with this requirement.
40 CFR 60.284(d) for
reporting
The following state-only requirements are not federally enforceable under the federal Clean Air Act:
Digesters
and MEE Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirements
F.2 TRS Treat noncondensable
gases to reduce TRS
emissions equal to
reduction achieved by
thermal oxidation in a
lime kiln; install a
backup treatment
system to ensure
continual treatment.
Treat noncondensable gases from the digesters and
evaporators to reduce TRS emissions equal to reduction
achieved by thermal oxidation in a lime kiln; install a backup
treatment system to ensure continual treatment.
To provide continual treatment:
- The NCG collection and treatment system shall be
properly operated and maintained at all times;
- Venting shall be minimized; and
- Venting necessary for safe/proper system operation
and maintenace shall be less than 10 hours per month.
Report venting duration and cause in the monthly air report.
WAC 173-405-040(4)
for treatment
requirement
Order 2892-05AQ,
Modification 1 for
continuous treatment
WAC 173-401-615(3)
for reporting
Page 60 of 116
G. LOW VOLUME HIGH CONCENTRATION (LVHC) SYSTEM
The LVHC system includes: batch digester systems, “D” and “E” multi effect evaporator systems, batch digester blow tank, foul
condensate collection tank, blow heat condenser system, and turpentine collection system, including the turpentine after
condenser.
LVHC Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
G.1 HAPs:
Collection and
Treatment
LVHC non-condensable gas source group emissions shall be enclosed and vented into a
closed-vent system and routed to the Lime Kiln and/or Power Boiler #10 for destruction.
Introduce LVHC gases with the primary fuel or into flame zone of Power Boiler #10 or the
Lime Kiln.
40 CFR 63.443(c)
40 CFR 63.443(d)
G.2 HAPs:
Enclosures
Each enclosure shall maintain negative pressure at each enclosure or hood opening as
demonstrated by the procedures in 40 CFR 63.457(e). Each enclosure or hood opening
that was closed during the initial performance test shall be maintained in the closed
position at all times except when necessary to open for sampling, inspection,
maintenance, or repairs.
Monthly Inspections:
For each enclosure opening, a visual inspection of the closure mechanism shall be
performed at least once every 30 days to ensure the opening is maintained in the closed
position and sealed. For this condition, 30 days shall be interpreted to mean: at least once
per calendar month with no two consecutive inspections occurring within 14 days.
Annual Inspections:
Demonstrate annually that each enclosure opening is maintained at negative pressure as
specified in 40 CFR 63.457(e).
40 CFR 63.450(a)
and (b)
40 CFR
63.453(k)(1) for
monthly
inspections
40 CFR
63.453(k)(4) for
annual
inspections
G.3 HAPs: Each component of the closed-vent system used to control LVHC non-condensable gas
source group emission that is operated at positive pressure and located prior to a control
device shall be designed for and operated with no detectable leaks as indicated by an
40 CFR 63.450(c)
40 CFR
63.453(k)(2) for
Page 61 of 116
LVHC Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
Closed-vent
system
instrument reading of less than 500 ppmv above background, as measured by 40 CFR Part
60, Appendix A, Method 21.
Monthly Inspections:
Each closed vent system (reasonably accessible ductwork, piping, enclosures, and
connections to covers in the collection system for the LVHC non-condensable gas source
group) shall be visually inspected for visible defects every 30 day or as requested by
Ecology. For this condition, 30 days shall be interpreted to mean: at least once per
calendar month with no two consecutive inspections occurring within 14 days.
Annual Inspections:
Measure annually components of closed-vent systems under positive pressure for
detectable leaks as specified in 40 CFR 63.457(d).
monthly
inspections
40 CFR
63.453(k)(3) for
annual
inspections
G.4 HAPs:
Collection and
Treatment
Each bypass line in the closed-vent system that could divert vent streams containing HAPs
to the atmosphere without meeting the emission limitations in 40 CFR 63.443 shall
comply with either of the following requirements:
(1) On each bypass line, the owner or operator shall install, calibrate, maintain, and
operate according to the manufacturer's specifications a flow indicator that is capable of
taking periodic readings as frequently as specified in §63.454(e). The flow indicator shall
be installed in the bypass line in such a way as to indicate flow in the bypass line; or
(2) For bypass line valves that are not computer controlled, the owner or operator shall
maintain the bypass line valve in the closed position with a car seal or a seal placed on the
valve or closure mechanism in such a way that valve or closure mechanism cannot be
opened without breaking the seal.
Monthly Inspections:
40 CFR 63.450(d)
40 CFR
63.453(k)(5) for
monthly
inspections
Page 62 of 116
LVHC Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
The valve or closure mechanisms specified in (2) above shall be inspected at least once
every 30 days to ensure that the valve is maintained in the closed position and the
emission point gas stream is not diverted through the bypass line.
G.5 HAPs:
Inspection
Corrective
Action
If an inspection of the LVHC non-condensable gas collection system identifies visible
defects, or if an instrument reading of 500 ppmv or greater above background is
measured by 40 CFR Part 60, Appendix A, Method 21 in accordance with the procedures
in 40 CFR 63.457(d), or if enclosure openings are not maintained at negative pressure,
take the following corrective actions as soon as practicable.
Make first effort repair to correct the closed-vent system as soon as practicable but no
later than 5 calendar days after the problem is identified.
Complete the repair or corrective action no later than 15 days after the problem is
identified. Delay of repair or corrective action is allowed if the repair or corrective action
is technically infeasible without a process unit shutdown or if the Permittee determines
that the emissions resulting from immediate repair would be greater than the emission
likely to result from delay of repair. Repair of such equipment shall be completed by the
end of the next process shutdown.
40 CFR
63.453(k)(6) and
40 CFR 63.457(d)
G.6 HAPs:
Recordkeeping
For each applicable enclosure opening, closed vent system, and closed collection system,
prepare and maintain a site-specific inspection plan, including a drawing or schematic of
the components of applicable affected equipment and shall record the following
information for each inspection:
(1) Date of inspection;
(2) Equipment type and identification;
(3) Results of negative pressure tests for enclosures;
(4) Results of leak detection tests;
(5) The nature of the defect or leak and the method of detection;
40 CFR 63.454(b)
Page 63 of 116
LVHC Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
(6) The date the defect or leak was detected and the date of each attempt to repair
the defect or leak;
(7) Repair methods applied in each attempt to repair the defect or leak;
(8) Reason for the delay if the defect or leak is not repaired within 15 days;
(9) Expected date of successful repair of the defect or leak if the repair is not
completed within 15 days;
(10) Date of successful repair of the defect or leak;
(11) Position and duration of opening of bypass line valves and the condition of any
valve seals; and
(12) Duration of the use of manual or computer-controlled bypass valves.
G.7 HAPs:
Excess
Emissions
Records shall be maintained for all periods of excess emissions.
Periods of excess emissions from the LVHC non-condensable gas source group are not
violations of Condition G.1 and 40 CFR 63.443(c) and (d) provided that the time of excess
emissions from the LVHC system divided by the total process operating time in a semi-
annual reporting period does not exceed one (1) percent.
40 CFR
63.443(e)(1)
H. HIGH VOLUME LOW CONCENTRATION (HVLC) SYSTEM
Applies to to following systems: C-side washers and filtrate tanks.
The Permittee submitted information to satisfy Clean Condensate Alternative (CCA) criteria in 40 CFR 63.447 which allows use of the
CAA to meet HVLC collection and treatment requirements for some HVLC emission units. The B-side washers emissions are not
collected and treated as part of the HVLC system; the Permittee has chosen to alternatively comply with the CCA. See Condition I for
condensate requirements.
Page 64 of 116
HVLC Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
H.1 HAPs:
Collection and
Treatment
HVLC non-condensable gas source group emissions shall be enclosed and vented into a
closed-vent system and routed to the Lime Kiln for destruction.
Introduce HVLC gases with the primary fuel or into flame zone of the Lime Kiln.
40 CFR 63.443(c)
40 CFR 63.443(d)
H.2 HAPs:
Enclosures
The HVLC system shall maintain negative pressure at each enclosure or hood opening as
demonstrated by the procedures specified in 40 CFR 63.457(e). Each enclosure or hood
opening closed during the initial performance test specified in 40 CFR 63.457(a) shall be
maintained in the same closed and sealed position as during the performance test at all
times except when necessary to use the opening for sampling, inspection, maintenance,
or repairs.
Monthly Inspections:
For each enclosure opening, a visual inspection of the closure mechanism shall be
performed at least once every 30 days to ensure the opening is maintained in the closed
position and sealed.
For this condition, 30 days shall be interpreted to mean: at least once per calendar
month with no two consecutive inspections occurring within 14 days.
Annual Inspections:
Demonstrate annually that each enclosure opening is maintained at negative pressure as
specified in 40 CFR Part 63.457(e).
40 CFR 63.450(a) and
(b)
40 CFR 63.453(k)(1)
for monthly
inspections
40 CFR 63.453(k)(4)
for annual inspections
H.3 HAPs:
Closed-vent
system
Each component of the closed-vent system used to control HVLC non-condensable gas
source group emission that is operated at positive pressure and located prior to a control
device shall be designed for and operated with no detectable leaks as indicated by an
instrument reading of less than 500 ppmv above background, as measured by 40 CFR
Part 60, Appendix A, Method 21.
Monthly Inspections:
40 CFR 63.450(a) and
(c)
40 CFR 63.453(k)(2)
for monthly
inspections
Page 65 of 116
HVLC Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
Each closed vent system (reasonably accessible ductwork, piping, enclosures, and
connections to covers in the collection system for the HVLC system) shall be visually
inspected for visible evidence of defects every 30 days or as requested by Ecology.
For this condition, 30 days shall be interpreted to mean: at least once per calendar
month with no two consecutive inspections occurring within 14 days.
Annual Inspections:
Measure annually components of closed-vent systems under positive pressure for
detectable leaks as specified in 40 CFR 63.457(d).
40 CFR 63.453(k)(3)
for annual inspections
H.4 HAPs:
Collection and
Treatment
Each bypass line in the closed-vent system that could divert vent streams containing HAP
to the atmosphere without meeting the emission limitations in §§63.443 shall comply
with either of the following requirements:
(1) On each bypass line, the Permittee shall install, calibrate, maintain, and operate
according to the manufacturer's specifications a flow indicator that is capable of
taking periodic readings as frequently as specified in 40 CFR 63.454(e). The flow
indicator shall be installed in the bypass line in such a way as to indicate flow in the
bypass line (note: monitoring bypass valve position is a satisfactory flow indicator);
or
(2) For bypass line valves that are not computer controlled, the Permittee shall maintain
the bypass line valve in the closed position with a car seal or a seal placed on the
valve or closure mechanism in such a way that valve or closure mechanism cannot be
opened without breaking the seal
Monthly Inspections:
The valve or closure mechanisms specified in (2) above shall be inspected at least once
every 30 days to ensure that the valve is maintained in the closed position and the
emission point gas stream is not diverted through the bypass line.
40 CFR 63.450(d)
40 CFR 63.453(k)(5)
for monthly
inspections
Page 66 of 116
HVLC Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
H.5 HAPs:
Inspection
Corrective
Action
If an inspection of the HVLC system identifies visible defects, or if an instrument reading
of 500 ppmv or greater above background is measured by 40 CFR Part 60, Appendix A,
Method 21 in accordance with the procedures in 40 CFR 63.457(d), or if enclosure
openings are not maintained at negative pressure, take the following corrective action as
soon as practicable.
Make a first effort to repair or correct the closed-vent system as soon as practicable, but
no later than 5 calendar days after the problem is identified.
Complete the repair or corrective action no later than 15 days after the problem is
identified. Delay of repair or corrective action is allowed if the repair or corrective action
is technically infeasible without a process unit shutdown or if the Permittee determines
that the emissions resulting from immediate repair would be greater than the emission
likely to result from delay of repair. Repair of such equipment shall be completed by the
end of the next process shutdown.
40 CFR 63.453(k)(6)
40 CFR 63.457(d)
H.6 HAPs:
Recordkeeping
For each applicable enclosure opening, closed vent system, and closed collection
system, prepare and maintain a site-specific inspection plan, including a drawing or
schematic of the components of applicable affected equipment and shall record the
following information for each inspection:
(1) Date of inspection;
(2) Equipment type and identification;
(3) Results of negative pressure tests for enclosures;
(4) Results of leak detection tests;
(5) The nature of the defect or leak and the method of detection;
(6) The date the defect or leak was detected and the date of each attempt to repair
the defect or leak;
(7) Repair methods applied in each attempt to repair the defect or leak;
(8) Reason for the delay if the defect or leak is not repaired within 15 days;
40 CFR 63.454(a) and
(b)
Page 67 of 116
HVLC Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
(9) Expected date of successful repair of the defect or leak if the repair is not
completed within 15 days;
(10) Date of successful repair of the defect or leak;
(11) Position and duration of opening of bypass line valves and the condition of any
valve seals; and
(12) Duration of the use of manual or computer-controlled bypass valves.
H.7 HAPs:
Recordkeeping
Records shall be maintained for all periods of excess emissions. Periods of excess
emissions from the HVLC system are not violations of 40 CFR 63.443(c) and (d) provided
that the time of excess emissions divided by the total process operating time in a
semiannual reporting period does not exceed four (4) percent.
40 CFR 63.443(e)(2)
I. PULPING PROCESS CONDENSATES AND CLEAN CONDENSATE ALTERNATIVE
Emission units and processes for which pulping process condensate requirements apply include: batch digester condensates,
digester condensate tank, “D” and “E” evaporator foul condensate off primary feed effects, turpentine collection system,
concentrator condensate, LVHC NCG condensates, and foul condensate collection tank.
PTPC has chosen to comply with the Clean Condensate Alternative (CCA) which allows for the collection and treatment of additional
condensates as an alternative to collecting and treating NCGs from specific HVLC emission units, specifically the B-side washers.
Condensates Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
I.1 HAPs:
Collect at least
7.2 lb of total
HAPs /ODTP
Collected pulping process condensates from the equipment listed in 40 CFR
63.446(b)(1) through (5) must contain a total HAP mass of 7.2 pounds or more
per oven-dry ton of unscreened brownstock.
40 CFR
63.446(c)(3)
Page 68 of 116
Condensates Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
I.2 HAPs:
Remove at least
6.6 + 0.12 lb of
total HAPs /ODTP
Pulping process condensates must be discharged below the liquid surface of a
biological treatment system and must be biologically treated to remove 6.6
pounds of total HAPs or more per ton of unscreened oven-dried brownstock
pulp.
Treat an additional 0.12 lb of total HAPs/ODTP to demonstrate compliance with
the CCA.
40 CFR
63.446(e)(2) and
(4)
40 CFR 63.447(b)
for Clean
Condensate
Alternative
I.3 HAPs:
Monitoring and
Testing
Quarterly Performance Test
Conduct a performance test as specified in §63.457(l) within 45 days after the
beginning of each quarter and meet the applicable emission limit in 40 CFR
63.446(e)(2) and 40 CFR 63.447. The test conducted in the first quarter
(annually) shall be performed for total HAPs as specified in §63.457(g) and meet
the mass removal emission limit specified in Condition I.2.
The remaining quarterly tests shall be performed in the same manner, except
that the Permittee may use the applicable methanol procedure in 40 CFR
63.457(l)(2) and the value of r determined during the first quarter test instead of
measuring the additional HAPs to determine a new value of r.
Daily Parameter Monitoring [alternative to 40 CFR 63.453(j)(1)]
Maintain aeration consisting of at least:
- Two blowers operating; or
- One blower and at least eight surface aerators during periods of blower
maintenance or failure.
Use mill computer tracking system continuously to monitor ASB blower
operations. Monitoring parameters may be reestablished using the procedures
in 40 CFR 63.453(n).
40 CFR
63.453(j)(3) and 40
CFR 63.457(g) for
quarterly testing
requirement
40 CFR 63.457(l)
for calculation
40 CFR
63.453(j)(2) and
(n) for alternative
daily monitoring
40 CFR 63.453(p)
for monitoring
parameter
excursion
requirements
40 CFR 63.455(h)
for reporting
Page 69 of 116
Condensates Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
Monitoring Parameter Excursion
A parameter excursion is not a violation of the applicable emission standard if
the Permittee chooses to conduct a performance test to demonstrate
compliance with the applicable emission limit and the results of a performance
test conducted as specified in 40 CFR 63.453(p)(2) demonstrates compliance
with the emission limit in Condition I.2. All sampling and measurements
necessary for the performance test must be conducted before:
1) Steps are taken to repair or adjust the operation of the process to end
the parameter excursion period; and
2) Steps are taken to minimize total HAP emissions to the atmosphere
during the parameter excursion period.
Reporting
Report results of the performance test before the close of business on the 60th
day following the completion of the performance test, unless approved
otherwise in writing by Ecology.
I.4 HAPs:
Condensate
Collection
Pulping process condensates must be conveyed in a closed collection system
that meets the individual drain system requirements specified in 40 CFR 63.960,
63.961, and 63.962, except for closed vent systems and control devices shall be
designed and operated in accordance with 40 CFR 63.443(d) and 63.450, instead
of in accordance with 40 CFR 63.693 as specified in 40 CFR 63.962(a)(3)(ii),
(b)(3)(ii)(A), and (b)(5)(iii).
40 CFR
63.446(d)(1)
I.5 HAPs:
Condensate
Collection Tank
(CCT)
The Condensate Collection Tank (CCT) shall be equipped so that the fixed roof
and all openings are operated with no detectable leaks, as indicated by an
instrument reading of less than 500 ppmdv above background as measured by
40 CFR Part 60, Appendix A, Method 21 in accordance with the procedures in 40
CFR 63.457(d).
40 CFR
63.446(d)(2) for
CCT
40 CFR 63.962
(b)(2)(i)(A) per 40
Page 70 of 116
Condensates Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
Each opening will be maintained in a closed, sealed position at all times that the
tank contains condensate, except when necessary to use the openings for
sampling, removal, or for equipment inspection, maintenance or repair.
The CCT shall be equipped with a water seal device on the overflow line.
The CCT shall be vented to a closed vent system meeting the requirements in 40
CFR 63.450. CCT vent gases shall be incinerated in Lime Kiln and/or Power Boiler
#10.
CFR 63.446(d)(1)
for collection
system
requirements
40 CFR
63.446(d)(2)(i) for
venting to closed
collection
I.6 HAPs:
Condensate
Collection System
Inspections
Monthly Inspections
The condensate closed collection system shall be visually inspected every 30
days. Follow the inspection requirements found in 40 CFR 63.964(a)(1)(i)(A),
63.964(a)(1)(v), and 63.964(b)(1) and (2) including:
(1) The unburied portion of the collection system piping shall be visually
inspection to verify that there are no defects.
(2) The inspection shall include verification that appropriate liquid level in
the water seals in the CCT are being maintained and identify any other
defects that could reduce water seal control effectiveness.
For this condition, 30 days shall be interpreted to mean: at least once per
calendar month with no two consecutive inspections occurring within 14 days.
Annual Inspections
Condensate Collection Tank shall be inspected for detectable leaks initially and
annually using the procedures in 40 CFR 63.457(d).
Inspection Corrective Action
If an inspection identifies visible defects in the closed collection system, or if an
instrument reading of 500 ppm or greater above background is measured by 40
40 CFR 63.453(l),
40 CFR
63.964(a)(1)(iii),
and 40 CFR
63.964(a)(1)(i)(A)
for monthly
inspection
40 CFR 63.453(l)(2)
for annual
inspections
40 CFR 63.453(l)(3)
and 63.964(b)(1)
and (2) for
corrective actions
Page 71 of 116
Condensates Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
CFR Part 60, Appendix A, Method 21 in accordance with the procedures in 40
CFR 63.457(d), then the Permittee must follow the corrective action
requirements found in 40 CFR 63.964(a)(1)(i)(A), 63.964(a)(1)(v), and
63.964(b)(1) and (2) including:
(1) The first effort to repair a defect shall be no later than 5 calendar days
after detection.
(2) Repair shall be completed as soon as practicable but no later than 15
calendar days after detection unless the repair of the defect requires
emptying or temporary removal from service of the collection system.
(3) If repair of the defect requires emptying or temporary removal of the
condensate collection system from service, the defect will be repaired
the next time the process equipment generating the condensate stops
operation. The repair of the defect will be completed before the process
resumes operation.
I.7 HAPs:
Inspection
Recordkeeping
For the condensate closed collection system, the Permittee must prepare and
maintain a site-specific inspection plan including a drawing or schematic of the
components of applicable affected equipment and shall record the following
information for each inspection:
(1) Date of inspection;
(2) The equipment type and identification;
(3) Results of leak detection tests;
(4) The nature of the defect or leak and the method of detection (i.e., visual
inspection or instrument detection);
(5) The date the defect or leak was detected and the date of each attempt to
repair the defect or leak;
(6) Repair methods applied in each attempt to repair the defect or leak;
(7) The reason for the delay if the defect or leak is not repaired within 15 days
after discovery;
40 CFR
63.453(l)(1)(i) and
40 CFR 63.454(b)
Page 72 of 116
Condensates Parameter Limit, Monitoring, Reporting, Recordkeeping Applicable
Requirements
(8) The expected date of successful repair of the defect or leak if the repair is not
completed within 15 days; and
(9) The date of successful repair of the defect or leak.
J. PAPER MACHINE 2 (PM2)
PM2 Parameter Monitoring & Reporting Applicable
Requirement
J.1 VOC PM2 must be operated in a manner consistent with good pollution control practices,
including minimizing usage rates and VOC contents of additive chemicals. Additives
used in the papermaking process on these paper machines shall be “low-VOC.”
The Permittee shall annually submit a list of additive used in the paper-making
process on PM2 and indentify those that are not “low-VOC.”
Order 10453,
Condition 3
J.2 Operations
and
Maintenance
An operation and maintenance manual for PM2 must be updated, maintained, and
followed. A copy of the manual must be available to Ecology upon request.
Order 10453,
Condition 4
J.3 Operations
Consistent
with
Application
Any activity or operation which is undertaken by the Permittee or others, in a manner
which is inconsistent with the Notice of Construction application dated December 3,
2013 and Order 10453 shall be subject to Ecology enforcement.
Order 10453,
Condition 5
Page 73 of 116
K. OLD CORRUGATED CONTAINER (OCC) PLANT
OCC Parameter Monitoring & Reporting Applicable
Requirement
K.1 Acetaldehyde,
chloroform,
formaldehyde
Within one year of startup or within alternative Ecology approved timeline, PTPC must
conduct a representative source test at the OCC pulper to quantify emissions of
acetaldehyde, chloroform, and formaldehyde.
NCASI/Weston Heated SUMMA Canister Method, NCASI Method IM/CAN/WP-99.01,
or other Ecology approved method must be used.
PTPC must notify Ecology in writing of its intention to conduct the source test and
provide a source test plan for approval at least 60 calendar days before the source
test is initially scheduled to begin.
Source test report and results must be submitted to Ecology within 90 days of
completion of the test. Any analytical results in addition to the specified TAPs must be
included in the submitted report.
NOC Order
16293,
Condition 1
K.2 OCC
Production
PTPC shall report to Ecology on a monthly basis, maximum daily OCC pulp production
in oven-dried tons per day.
NOC Order
16293,
Condition 2
K.3 Operations
and
Maintenance
The OCC pulper must be operated and maintained in a manner consistent with safety
and good air pollution control practices for minimizing emissions at all times. An
operation and maintenance manual for the OCC pulper must be prepared to ensure
emissions are minimized. The operation and maintenance manual must be followed.
A copy of the manual must be available to Ecology during inspections and upon
request.
NOC Order
16293,
Condition 3
K.4 Project
Completion
Notification
PTPC shall notify Ecology in writing within thirty days of completion of the OCC Pulper
Upgrade project.
NOC Order
16293,
Condition 4
Page 74 of 116
L. RECIPROCATING INTERNAL COMBUSTION ENGINES (RICE)
EXISTING EMERGENCY COMPRESSION IGNITION RICE (≤500 HP)
The facility has three existing emergency compression ignition (CI) RICE: Main Pump Stationand Clarifier Bypass Pump #2. The
conditions below apply to existing emergency compression ignition RICE (≤ 500 hp) which are subject to the requirements of 40 CFR
Part 63, Subpart ZZZZ.
Emergency
RICE Monitoring, Recordkeeping, Reporting Applicable
Requirement
L.1 Change the oil and filter every 500 hours of operation or annually, whichever comes first. An oil
analysis program may be used to extend the specified oil change requirement in accordance with
40 CFR 63.6625(i) or (j), as applicable.
Inspect the air cleaner every 1,000 hours of operation or annually, whichever comes first, and
replace as necessary.
Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first, and
replace as necessary.
40 CFR Part 63,
Subpart ZZZZ,
Table 2c
L.2 Minimize the engine's time spent at idle, and minimize the engine's startup time at startup to a
period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after
which time the non-startup emission limitations apply.
40 CFR
63.6625(h)
L.3 There is no time limit on the use of emergency stationary RICE in emergency situations.
Emergency RICE may operate for up to 100 hours per year for maintenance checks and readiness
testing or other periods defined in 40 CFR 63.6640(f).
Emergency RICE may operate for up to 50 hours per year in non-emergency situations not
mentioned above. This time will count toward the 100 hours per year previously mentioned.
40 CFR
63.6640(f)
Page 75 of 116
Emergency
RICE Monitoring, Recordkeeping, Reporting Applicable
Requirement
L.4 Records of the hours of operation of the engine that is recorded through the nonresettable hour
meter must be maintained. Records must include how many hours are spent for emergency
operation, including what classified the operation as an emergency, and how many hours are
spent for nonemergency operation. If the engines are used for demand response operation,
maintain records of the notification of the emergency situation and the time the engine was
operated as part of demand response. Records must be kept and readily available for five (5)
years following the date of each occurrence, measurement, maintenance, corrective action
report, or record.
40 CFR 63.6655
for
recordkeeping
40 CFR 63.6660
for records
retention
L.5 The stationary RICE must be operated and maintained according to the manufacturer's emission-
related operation and maintenance instructions; or
A maintenance plan must be developed and followed which provides to the extent practicable for
the maintenance and operation of the engine in a manner consistent with good air pollution
control practice for minimizing emissions.
Records must be retained of the operation and maintenance of the engines according to the
manufacturer's emission-related instructions or according to the developed maintenance plan
consistent with good air pollution control practice for minimizing emissions. Records must be
kept and readily available for five (5) years following the date of each occurrence, measurement,
maintenance, corrective action report, or record.
40 CFR Part 63
Subpart ZZZZ,
Table 6
40 CFR 63.6655
for
recordkeeping
40 CFR 63.6660
for records
retention
L.6 Beginning January 1, 2015, existing emergency compression ignition (CI) stationary RICE with a
site rating of more than 100 brake hp and a displacement of less than 30 liters per cylinder that
uses diesel fuel, and operates or is contractually obligated to be available for more than 15 hours
per calendar year for the purposes specified in §63.6640(f)(2)(ii) and (iii), or that operates for the
purpose specified in §63.6640(f)(4)(ii), must use diesel fuel that meets the requirements in 40 CFR
80.510(b) for nonroad diesel fuel, except that any existing diesel fuel purchased (or otherwise
obtained) prior to January 1, 2015, may be used until depleted.
40 CFR
63.6604(b)
Page 76 of 116
EXISTING NON-EMERGENCY COMPRESSION IGNITION RICE (100 ≤ HP ≤ 500)
The facility has one existing non-emergency compression ignition RICE (100 ≤ hp ≤ 500): Diesel Fire Pump. The conditions below
apply to existing non-emergency compression ignition RICE (100 ≤ hp ≤ 500) which are subject to the requirements of 40 CFR Part
63, Subpart ZZZZ.
Non-
Emergency
RICE
Parameter Limit (shall
not
exceed)
Monitoring, Recordkeeping, Reporting Applicable
Requirement
L.7 CO 230 ppmdv
@ 15% O2
Performance Testing:
Initial compliance performance test completed on 12/13/2018.
Recordkeeping:
Maintain records in accordance with 40 CFR 63.6655.
Reporting:
Submit a semi-annual compliance report in accordance with 40 CFR
63.6650, delivered or postmarked by July 31 or January 31 following
the end of the respective calendar half.
40 CFR
63.6602 and
Table 2c for
limit
40 CFR
63.6650 for
reporting
L.8 Recordkeeping N/A Maintain records in accordance with 40 CFR 63.6655. 40 CFR
63.6655 for
recordkeeping
L.9 Emissions
Minimization
N/A Minimize the engine's time spent at idle, and minimize the engine's
startup time at startup to a period needed for appropriate and safe
loading of the engine, not to exceed 30 minutes, after which time
the non-startup emission limitations apply.
40 CFR
63.6625(h)
L.10 Good air
pollution
N/A At all times you must operate and maintain any affected source,
including associated air pollution control equipment and monitoring
equipment, in a manner consistent with safety and good air
40 CFR
63.6605(b)
Page 77 of 116
Non-
Emergency
RICE
Parameter Limit (shall
not
exceed)
Monitoring, Recordkeeping, Reporting Applicable
Requirement
control
practices
pollution control practices for minimizing emissions. The general
duty to minimize emissions does not require you to make any
further efforts to reduce emissions if levels required by this
standard have been achieved. Determination of whether such
operation and maintenance procedures are being used will be
based on information available to the Administrator which may
include, but is not limited to, monitoring results, review of
operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source.
RICE NEW SOURCE PERFORMANCE STANDARDS
The facility has three emergency compression ignition RICE for which new source performace standards in 40 CFR Part 60, Subpart
IIII apply: Clarifier Bypass Pump #3, Lime Kiln Auxilary Drive and Mud Storage Agitator Backup Generator.
RICE Parameter Monitoring, Reporting, Recordkeeping Applicable
Requirements
L.11 Emission
Standards
The Permittee must comply with the emission standards for new nonroad CI engines
in 40 CFR 60.4202, for all pollutants, for the same model year and maximum engine
power for their 2007 model year and later emergency stationary CI ICE.
Compliance must be demonstrated by keeping records of engine manufacturer data
indicating compliance with the applicable emission standards.
40 CFR 60.4205(b), 40
CFR 89.112 and 89.113
L.12 Operations In order for the engines to be considered an emergency stationary ICE under this 40
CFR Part 60, Subpart IIII, any operation other than emergency operation,
maintenance and testing, emergency demand response, and operation in non-
40 CFR 60.4211(f)
Page 78 of 116
RICE Parameter Monitoring, Reporting, Recordkeeping Applicable
Requirements
emergency situations for 50 hours per year, as described in paragraphs (1) through
(3) of this condition, is prohibited. If you do not operate the engine according to the
requirements in paragraphs (1) through (3) of this condition, the engine will not be
considered an emergency engine and must meet all requirements for non-
emergency engines.
(1) There is no time limit on the use of emergency stationary ICE in emergency
situations.
(2) You may operate your emergency stationary ICE for any combination of the
purposes specified in paragraphs (i) through (iii) of this condition for a maximum of
100 hours per calendar year. Any operation for non-emergency situations as allowed
by paragraph (3) of this condition counts as part of the 100 hours per calendar year
allowed by this paragraph (2).
(i) Emergency stationary ICE may be operated for maintenance checks and readiness
testing, provided that the tests are recommended by federal, state or local
government, the manufacturer, the vendor, the regional transmission organization
or equivalent balancing authority and transmission operator, or the insurance
company associated with the engine. The owner or operator may petition the
Administrator for approval of additional hours to be used for maintenance checks
and readiness testing, but a petition is not required if the owner or operator
maintains records indicating that federal, state, or local standards require
maintenance and testing of emergency ICE beyond 100 hours per calendar year.
(ii) Emergency stationary ICE may be operated for emergency demand response for
periods in which the Reliability Coordinator under the North American Electric
Reliability Corporation (NERC) Reliability Standard EOP-002-3, Capacity and Energy
Emergencies (incorporated by reference, see §60.17), or other authorized entity as
Page 79 of 116
RICE Parameter Monitoring, Reporting, Recordkeeping Applicable
Requirements
determined by the Reliability Coordinator, has declared an Energy Emergency Alert
Level 2 as defined in the NERC Reliability Standard EOP-002-3.
(iii) Emergency stationary ICE may be operated for periods where there is a deviation
of voltage or frequency of 5 percent or greater below standard voltage or frequency.
(3) Emergency stationary ICE may be operated for up to 50 hours per calendar year in
non-emergency situations. The 50 hours of operation in non-emergency situations
are counted as part of the 100 hours per calendar year for maintenance and testing
and emergency demand response provided in paragraph (f)(2) of 60.4211. Except as
provided in paragraph (f)(3)(i) of 60.4211, the 50 hours per calendar year for non-
emergency situations cannot be used for peak shaving or non-emergency demand
response, or to generate income for a facility to an electric grid or otherwise supply
power as part of a financial arrangement with another entity.
L.13 Operations
and
Maintenance
The Permittee must: operate and maintain the stationary CI internal combustion
engines and control devices according to the manufacturer's emission-related
written instructions; change only those emission-related settings that are permitted
by the manufacturer; and meet the requirements of 40 CFR Parts 89, 94 and/or 1068,
as applicable.
40 CFR 60.4211(a)
L.14 Fuel
Requirements
The Permittee must use diesel fuel that has a maximum sulfur content of 15 ppm and
a minimum cetane index of 40 or a maximum aromatic content of 35 percent by
volume.
40 CFR 60.4207(b) for
fuel requirements
Page 80 of 116
M. MILLWIDE EMISSION LIMITS AND REQUIREMENTS
Millwide limits, except for TRS limits, apply to aggregate emissions from the Recovery Furnace, Smelt Dissolver Tank, Lime Kiln, and
Power Boiler #10. Millwide TRS emission limits apply to the aggregate emissions from the Recovery Furnace, Smelt Dissolver Tank,
Lime Kiln, Power Boiler #10, evaporators, and washers.
Millwide Parameter Limit (shall not
exceed) Monitoring & Reporting1 Applicable
Requirement
M.1 Particulate 729 tons/yr Monitoring and reporting method 1. Order 2892-05AQ,
Modification 2
M.2 Particulate 1007 tons/yr Monitoring and reporting method 1. PSD-I
M.3 Particulate 5590 lbs/d Monitoring and reporting method 3. PSD-I
M.4 NOx 645 tons/yr Monitoring and reporting method 1. PSD-I
M.5 NOx 3580 lbs/d Monitoring and reporting method 2. PSD-I
M.6 CO 6204 tons/yr Monitoring and reporting method 1. PSD-I
M.7 CO 34500 lbs/d Monitoring and reporting method 3. PSD-I
M.8 VOC 182 tons/yr Monitoring and reporting method 1. PSD-I
M.9 VOC 1010 lbs/d Monitoring and reporting method 3. PSD-I
M.10 TRS 31.7 tons/yr Monitoring and reporting method 1. PSD-I
M.11 TRS 176 lbs/d Monitoring and reporting method 2. PSD-I
M.12 SO2 1300 tons/yr Monitoring and reporting method 1. Order 2892-05AQ,
Modification 2
M.13 Pulp
Production
N/A Report average daily production of air dried unbleached
pulp from chips and from the OCC process.
Order 2892-05AQ,
Modification 2
M.14 Wind
Speed and
Direction
N/A Wind speed and direction shall be continuously
measured and recorded. Any change in location of the
sensory equipment shall be approved by Ecology.
Monitoring records shall be maintained at the mill.
Order 2892-05AQ,
Modification 2
Monitoring and reporting methods:
1. Compliance determined by adding calendar year emission from all applicable units. Emissions from a unit for which the
pollutant is measured shall be calculated using the average of test results collected during the year.
Page 81 of 116
Emissions from a unit for which the pollutant is not measured shall be calculated using emission factors and production data
or fuel consumption. Report annually within 30 days of the end of the calendar year.
2. Compliance determined by adding daily emissions from all applicable units. Emissions from a unit for which the pollutant is
measured through source testing or continuous emission monitoring shall be calculated using the most recent test results
adjusted for production/hours of operation. Emissions from a unit for which the parameter is not directly measured shall be
calculated using emission factors and daily production or fuel consumption data. Report monthly.
3. Compliance determined by complying with the annual limit. If annual emissions are greater than 60% of the annual limit,
during the following year, compliance shall be demonstrated by monitoring and reporting according to monitoring and
reporting method 2.
N. GREENHOUSE GAS (GHG) REPORTING
The following state-only GHG requirements are not enforceable under the federal Clean Air
Act.
1. Reporting Schedule. The Permittee must submit the report required under Chapter 173-
441 WAC to Ecology no later than March 31 of each calendar year for GHG emissions in
the previous calendar year. Unless otherwise stated, if March 31 falls on a weekend or
state holiday, the report must be submitted by the next business day.
Reporting requirements begin for Calendar Year 2012 and each subsequent calendar
year.
The report and certificate or representation must be submitted electronically in
accordance with the requirements of WAC 173-441-050 and 173-441-060 and in a
format specified by Ecology.
The Permittee must submit a revised annual GHG report within 45 days of discovering
that an annual GHG report previously submitted contains one or more substantive
errors.
[WAC 173-441-050(2), WAC 173-441-070, WAC 173-441-050(7)]
2. Report Content. Each annual GHG report shall contain the content specified in WAC
173-441-050(3).
Each GHG emission report and any other submission under Chapter 173-441 WAC shall
be certified, signed, and submitted by the designated representative or any alternate
designated representative.
Each such submission shall include the following certification statement signed by the
designated representative or any alternate designated representative: "I am authorized
to make this submission on behalf of the owners and operators of the facility or supplier,
as applicable, for which the submission is made. I certify under penalty of law that I have
personally examined, and am familiar with, the statements and information submitted in
this document and all its attachments. Based on my inquiry of those individuals with
primary responsibility for obtaining the information, I certify that the statements and
information are to the best of my knowledge and belief true, accurate, and complete. I
am aware that there are significant penalties for submitting false statements and
information or omitting required statements and information, including the possibility of
fine or imprisonment."
All requests, notifications, and communications to Ecology pursuant to Chapter 173-441
WAC, other than submittal of the annual GHG report, shall be submitted to the
following address:
Page 83 of 116
Greenhouse Gas Report
Air Quality Program
Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
[WAC 173-441-050(3), WAC 173-441-060(5), WAC 173-441-100]
3. Emissions Calculations. Use the calculation methodologies specified in the relevant
sections of Chapter 173-441 WAC. Use the same calculation methodology throughout a
reporting period unless you provide a written explanation of why a change in
methodology was required.
Calibration and accuracy requirements: The Permittee must meet the applicable flow
meter calibration and accuracy requirements of WAC 173-441-050(8). The accuracy
specifications in this subsection do not apply where either the use of company records
(as defined in WAC 173-441-020(3)) or the use of “best available information” is
specified in an applicable subsection of Chapter 173-441 WAC to quantify fuel usage
and/or other parameters. Further, the provisions of this subsection do not apply to
stationary fuel combustion units that use the methodologies in 40 CFR Part 75 to
calculate CO2 mass emissions.
[WAC 173-441-050(4), WAC 173-441-050(8)]
4. Recordkeeping. Keep records as specified in WAC 173-441-050(6). Retain all records for
at least three years. The records shall be kept in an electronic or hard copy format (as
appropriate), and recorded in a form that is suitable for expeditious inspection and
review. Upon request by Ecology, the records required under this section must be made
available to Ecology. Records may be retained offsite if the records are readily available
for expeditious inspection and review. For records that are electronically generated or
maintained, the equipment or software necessary to read the records shall be made
available, or, if requested by Ecology, electronic records shall be converted to paper
documents.
[WAC 173-441-050(6)]
O. COMPLIANCE ASSURANCE MONITORING (CAM)
The Permittee is required to submit a CAM Plan per 40 CFR Part 64. PTPC submitted a CAM Plan
with the AOP renewal permit application and an additonal updated CAM plan in December
2020. A final CAM plan was submtted to Ecology by PTPC on DATE and is included in the
permit’s Statement of Basis.
CAM is applicable to the Recovery Furnace (PM), Smelt Dissolver Tank (PM and opacity), Lime
Kiln (PM, opacity), Power Boiler 20 (PM, opacity).
General CAM requirements:
O.1 Obligation to monitor and data availability requirement.
Page 84 of 116
Except for, as applicable, monitoring malfunctions, associated repairs, and required
quality assurance or control activities (including, as applicable, calibration checks and
required zero and span adjustments), the owner or operator shall conduct all monitoring
in continuous operation (or shall collect data at all required intervals) at all times that the
pollutant-specific emissions unit is operating. Data recorded during monitoring
malfunctions, associated repairs, and required quality assurance or control activities shall
not be used for purposes of this part, including data averages and calculations, or fulfilling
a minimum data availability requirement, if applicable. The owner or operator shall use all
the data collected during all other periods in assessing the operation of the control device
and associated control system. A monitoring malfunction is any sudden, infrequent, not
reasonably preventable failure of the monitoring to provide valid data. Monitoring failures
that are caused in part by poor maintenance or careless operation are not malfunctions.
[40 CFR 64.7(c)]
O.2 Excursions.
The Permittee shall report excursions as defined in the unit specific monitoring
requirements. An excursion does not necessarily indicate an exceedence of the applicable
particulate emission standards referenced above, nor does evidence of an excursion
precluded the Permittee from certifying continuous compliance as provided in Facility
Wide Condition 40 of this permit if the Permittee has other data on which to base a
determination of compliance during the reporting period in which the excursion occurred.
(40 CFR 64.6(c)(2)(10/22/97); 40 CFR 70.6(c)(iii)(C) (6/27/03)
O.3 Response to an excursion.
Upon detecting an excursion or exceedance, the owner or operator shall restore
operation of the pollutant-specific emissions unit (including the control device and
associated capture system) to its normal or usual manner of operation as expeditiously as
practicable in accordance with good air pollution control practices for minimizing
emissions. The response shall include minimizing the period of any startup, shutdown or
malfunction and taking any necessary corrective actions to restore normal operation and
prevent the likely recurrence of the cause of an excursion or exceedance (other than
those caused by excused startup or shutdown conditions). Such actions may include initial
inspection and evaluation, recording that operations returned to normal without operator
action (such as through response by a computerized distribution control system), or any
necessary follow-up actions to return operation to within the indicator range, designated
condition, or below the applicable emission limitation or standard, as applicable. [40 CFR
64.7(d)]
O.4 Quality Improvement Plan (QIP).
If Ecology or U.S. EPA Region 10 determines, based on the frequency of excursions
reported, review of operation and maintenance procedures and records, and reports on
corrective action taken in response to an excursion, that the Permittee’s corrective action
procedures are not consistent with good air pollution control practice for minimizing
emissions, Ecology or U.S. EPA Region 10 may require the Permittee to develop and
implement a Quality Improvement Plan. (40 CFR 64.8 and 64.6(c)(3) (10/22/97))
O.5 Reporting.
Page 85 of 116
A monitoring report required by this section shall submitted at a minumum semiannually
and shall include:
(a) Summary information on the number, duration and cause (including unknown cause, if
applicable) of each excursion and the corrective action taken;
(b) Summary information on the number, duration and cause (including unknown cause, if
applicable) for monitor downtime incidents (other than downtime associated with zero
and span or other daily calibration checks, if applicable); and; and
(c) A description of the actions taken to implement a QIP during the reporting period, if
required. Upon completion of a QIP, the Permittee shall include in the next monthly
report documentation that the implementation of the plan has been completed and
reduced the likelihood of similar levels of excursions occurring. [40 CFR 64.9(a)]
O.6 Recordkeeping.
The recordkeeping required by this section shall include records of the monitoring data
described in this section, corrective actions taken pursuant to this section, any QIP
prepared under Condition O.4, and any activities taken to implement a QIP. Instead of
paper records, the Permittee may maintain records on alternative media, such as
microfilm, computer files, magnetic tape disks, or microfiche, provided that the use of
such alternative media allows for expeditious inspection and review. (40 CFR 64.9(b) and
64.6(c)(3) (10/22/97))
Page 86 of 116
FACILITY-WIDE GENERAL REQUIREMENTS [WAC 173-401-600]
These generally applicable requirements apply facility-wide, including insignificant
emission units or activities. Insignificant emission units or activities, however, are not
subject to monitoring, testing, recordkeeping, reporting, or compliance certification
requirements.
1. Varying Emission Rate. The Permittee cannot vary the rate of emission of a pollutant
according to atmospheric conditions or ambient concentration of that pollutant, except
as directed according to air pollution episode regulations. [WAC 173-400-205]
2. Emissions Detrimental to Persons or Property. The Permittee shall not cause or permit
emission of any contaminant if it is detrimental to the health, safety, or welfare of any
person, or causes damage to property or business. [WAC 173-400-040(6)]
3. Concealment and Masking. The Permittee shall not install or use any means that
conceal or mask an emission of an air contaminant that would otherwise violate
provisions in this permit. [WAC 173-400-040(8)]
4. Fugitive Emissions. The Permittee shall take reasonable precautions to prevent the
release of air contaminants from emission units engaged in material handling,
construction, demolition, or any other operation that is a source of fugitive emissions.
Reasonable precautions include, but are not limited to, application of water as
necessary to control fugitive dust or the timely removal or coverage of material piles.
[WAC 173-400-040(4)(a)]
5. Fugitive Dust. The Permittee shall take reasonable precautions to prevent fugitive dust
from becoming airborne and maintain and operate the source to minimize emissions.
Reasonable precautions include but are not limited to application of water to paved
areas and debris piles as necessary to control fugitive dust or the timely removal or
coverage of material piles. [WAC 173-400-040(9)(a)]
6. Fallout. The following condition is state only and is not federally enforceable under the
Clean Air Act: No deposit of particulate matter beyond property line so as to interfere
unreasonably with use and enjoyment of the property upon which the material is
deposited. [WAC 173-400-040(3)]
7. Odors. The following condition is state only and is not federally enforceable under the
Clean Air Act: Any person causing odor which may unreasonably interfere with use and
enjoyment of property must use recognized good practice and procedures to reduce
odors to a reasonable minimum. [WAC 173-400-040(5)]
8. Opacity. The Permittee may not cause or allow the emission of a plume, from any
emissions unit other than a Kraft recovery furnace, smelt dissolver tank, or lime kiln,
which has an average opacity greater than twenty percent for more than six
Page 87 of 116
consecutive minutes in any sixty minute period. The emissions unit shall comply with
the alternative visible emission standard for:
a. Soot blowing or grate cleaning in WAC 173-400-040(2)(a);
b. Hog fuel or wood fired boiler in operation before January 24, 2018, in WAC 173-
400-040(2)(e); and/or
c. Furnace refractory in WAC 173-400-040(2)(f).
These provisions shall not apply when the presence of uncombined water is the only
reason for the opacity in the plume to exceed the applicable maximum. [WAC 173-405-
040(6)]
9. Complaints. Except where specific requirements are defined elsewhere, the
Permittee shall assure compliance with Conditions 1 through 8 by recordkeeping
of actions taken by the Permittee in response to complaints received by the
Permittee or of possible noncompliance noticed by the facility staff in day-to-day
operations. The Permittee shall assess the validity of each complaint and
commence corrective action, if warranted, as soon as possible, but no later than 3
working days of receiving the complaint. The Permittee shall keep records of the
following: complaints received; the assessment of validity, and what, if any,
corrective action is taken in response to the complaint. [WAC 173-401-630]
The Permittee shall include a basic log of all complaints received during the month
with each monthly report. The log must include the date and time the cause of the
complaint was noted, the date and time the complaint was made, and the nature
of the complaint. [WAC 173-401-615] This paragraph specifies state-only
requirements which are not federally enforceable under the federal Clean Air Act.
For odor complaints: PTPC shall continue to track odor complaints from members
of the community specifically identifying the date, time, and nature of the
complaint. The information collected will include: address where the odor
occurred, time the odor was first detected, duration of the odor, description of the
odor. PTPC shall investigate each complaint and determine the wind direction,
speed, and ambient temperature at the time of the incident, and operating
conditions in the mill at the time of the incident (e.g. equipment start-ups, shut
downs, or malfunctions – time and duration of noncondensable gas (NCG) venting
3 hours before the incident). PTPC shall log actions to investigate the complaint,
the status of the plant operations and emissions during the complaint period, and
the corrective actions taken. Complaint logs shall be kept for a minimum of five
year after the complaint occurred. [Agreed Order 5771]
10. Credible Evidence. For the purpose of submitting compliance certifications or
establishing whether or not a person has violated or is in violation of the
applicable requirements cited in this requirement, nothing in this permit shall
preclude the use, including the exclusive use, of any credible evidence or
information relevant to whether a source would have been in compliance with
applicable requirements if the appropriate performance or compliance test or
procedure had been performed. [40 CFR 51.212; 40 CFR 52.12; 40 CFR 52.33; 40
CFR 60.11; 40 CFR 61.12]
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11. Sulfur Dioxide Emissions. The emission of sulfur dioxide from any emission unit other
than a recovery furnace or lime kiln shall not exceed 1,000 parts per million for an
hourly average, corrected to 7% oxygen for combustion units. [WAC 173-405-040(9)]
12. Operation and Maintenance. The Permittee shall at all times, including periods of
abnormal operation and upset conditions, to the extent practicable, maintain and
operate any affected facility, including associated air pollution control equipment, in a
manner consistent with good air pollution control practice. Determination of whether
acceptable operating and maintenance procedures are being used will be based on
information available to Ecology which may include, but is not limited to, monitoring
results, opacity observations, review of operating and maintenance procedures, and
inspection of the source. [40 CFR 60.11(d), 40 CFR 63.6(e)(1), WAC 173-405-040(8)]
13. Chemical Accidental Release Program. The Permittee does not meet the
applicability standards for Accidental Release Prevention Provisions under 40 CFR
68. The Permittee has a general duty to: identify hazards which may result from
accidental releases using appropriate hazard assessment techniques; to design
and maintain a safe facility taking such steps as are necessary to prevent releases;
and to minimize the consequences of accidental releases that do occur. [40 CFR
Part 68]
14. Ozone Protection.
a. The Permittee shall comply with the applicable standards for recycling and
emissions reductions pursuant to 40 CFR Part 82, Subpart F except as
provided for Motor Vehicle Air conditions (MVACs) in Subpart B:
i. Persons opening appliances for maintenance, service, repair, or
disposal must comply with the required practices pursuant to
Section 82.156.
ii. Equipment used during the maintenance, service, repair, or disposal
must comply with standards for recycling and recovery equipment
pursuant to Section 82.158.
iii. Persons performing maintenance, service, repair, or disposal of
appliances must be certified by an approved technician certification
program pursuant to Section 82.161.
iv. Persons disposing of small appliances, MVACs, and MVAC-like
appliances must comply with recordkeeping requirements pursuant
to Section 82.166. ("MVAC-like appliance" is defined at Section
82.152.)
v. Persons owning commercial or industrial process refrigeration
equipment must comply with the leak repair requirements pursuant
to Section 82.156.
vi. Owners/operators of appliances normally containing 50 or more
pounds, or refrigerant purchased and added to such appliances
must do so in compliance with Section 82.166.
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b. Permittee may switch from any ozone-depleting substance to any
alternative approved pursuant to the Significant New Alternatives Program
(SNAP), 40 CFR Part 82, Subpart G, without a permit revision but shall not
switch to a substitute listed as unacceptable pursuant to such program. [40
CFR 82.174]
c. Any certified technician employed by Permittee shall keep a copy of their
certification at their place of employment. [40 CFR 82.166(1)]
d. The following condition is state only and is not federally enforceable under
the Clean Air Act: The Permittee shall not willfully release any regulated
refrigerant and shall use refrigerant extraction equipment to recover
regulated refrigerant that would otherwise be released into the
atmosphere. [RCW 70A.15.6410(2), 6410(4)]
e. Compliance with this term and condition will be demonstrated by using a
certified contractor or employee.
15. Insignificant Emission Units. The generally applicable requirements that apply to
IEUs are WAC 173-405-040(5), WAC 173-400-040, WAC 173-400-050(1) & (3), and
WAC 173-400-060. [WAC 173-401-530(2)(b)]
16. Used Oil Burning. The following condition is state-only and is not federally
enforceable under the Clean Air Act: The Permittee can burn used oil if it meets
the standards prescribed in RCW 70A.15.4510(1). This condition shall not apply to
used oil burned in space heaters if the space heater has a maximum heat output
of not greater than 0.5 million BTUs per hour or used oil burned in facilities
permitted by Ecology. [RCW 70A.15.4510]
17. Asbestos. The Permittee shall comply with the applicable requirements of 40 CFR
Part 61, Subpart M and WAC 173-400-075 when conducting any renovation or
demolition at the facility. [40 CFR Part 61 Subpart M, WAC 173-400-075]
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18. New Source Review. The Permittee shall not construct new sources or make
modifications required to be reviewed under WAC 173-400-110, WAC 173-400-
560, WAC 173-400-720, WAC 173-400-820, or WAC 173-460-040 before the
Permittee obtains written final approval from Ecology in accordance with those
regulations, pays the appropriate fees required by WAC 173-455-120, and pays
the cost of public notice described in WAC 173-400-171. [WAC 173-400-110, WAC
173-400-171, WAC 173-400-560, WAC 173-400-720, WAC 173-400-820, 173-460-
040]
19. Replacement or Substantial Alteration of Emission Control Technology. The
following condition is state-only and is not federally enforceable under the Clean
Air Act: Prior to replacing or substantially altering emission control technology
subject to review under WAC 173-400-114, the permittee shall file for and obtain
approval from Ecology according to that regulation. The permittee shall pay the
appropriate fees required by WAC 173-455-100(4) prior to commencing
construction. [WAC 173-400-114]
20. Nonroad Engines. The following condition is state-only and is not federally
enforceable under the Clean Air Act: Prior to installation or operation of a
nonroad engine, as defined in WAC 173-400-030, the permittee shall meet the
requirements of WAC 173-400-035. If the nonroad engine(s) has a cumulative
maximum rated brake horsepower greater than 500, a notification of intent to
operate will be submitted to Ecology. If the nonroad engine(s) has a cumulative
maximum rated break horsepower greater than 2,000, the permittee will not
operate the engine(s) unless Ecology issues written approval to operate. [WAC
173-400-035]
Monitoring Requirements [WAC 173-401-630(5)(b)]
21. Unit-Specific Requirements. The Permittee shall conduct routine monitoring of
emissions in accordance with the program of monitoring or testing required by
specific emission unit conditions of this permit. [WAC 173-405-072].
22. Representative Conditions. The Permittee must conduct stack tests during
representative operating conditions unless required operating conditions during
testing is otherwise specified. [40 CFR 60.8(c), 40 CFR 63.7(e), WAC 173-401-
630(1), 40 CFR 70.6(c)(1)]
23. Unavoidable Excess Emissions. This condition applies, where applicable, to excess
emissions that are claimed to be unavoidable pursuant to WAC 173400-107. The
Permittee may include in its reports demonstrations that excess emissions were
unavoidable, consistent with the requirements of WAC 173-400-107. The
Permittee shall have the burden to prove that deviations from permit terms were
unavoidable. Excess emissions that are unavoidable are excused and not subject
to penalty. [WAC 173-400-107]
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After the effective date of WAC 173-400-109, the Permittee may include in its
reports demonstrations that excess emissions were unavoidable, consistent with
the requirements of WAC 173-400-109. The Permittee shall have the burden to
prove that deviations from permit terms were unavoidable. Excess emissions that
are unavoidable are not subject to penalty. Claim of unavoidable excess emissions
does not apply to exceedance of an emission standard in 40 CFR Parts 60, 61, 62,
63, and 72, or Ecology’s adoption by reference of these standards. [WAC 173-400-
109]
24. Violation Duration. A violation of an emission limit is presumed to commence at
the time of the testing, recordkeeping, or monitoring indicating noncompliance,
and to continue until the time of retesting, recordkeeping, or monitoring that
indicates compliance. This presumption may be defeated if credible evidence
shows that the violation was of longer duration, that there were intervening days
during which no violation occurred, or that that violation was not continuing in
nature. [42 U.S.C. 7413(e)(2)]. The Permittee may conduct monitoring or testing
more frequently than required by this permit.
25. Insignificant Emission Units. The Permittee is not subject to any testing,
monitoring, reporting, or recordkeeping requirements for insignificant units or
activities listed. [WAC 173-401-530(2)(c)]
26. Continuous Emission Monitoring System Operating Requirements (for CEMS
required by an Order, PSD Permit, or Ecology regulation). Continuous emission
monitoring systems (CEMS) required under an order, PSD permit, or regulation
issued by Ecology and not subject to CEMS performance specifications and data
recovery requirements imposed by 40 CFR Parts 60, 61, 62, 63, or 75 must meet
the following CEMS performance specifications:
a. The Permittee shall recover valid hourly monitoring data for at least 95
percent of the hours that the equipment (required to be monitored) is
operated during each calendar month except for periods of monitoring
system downtime, provided that the Permittee demonstrated that the
downtime was not a result of inadequate design, operation, or
maintenance, or any other reasonable preventable condition, and any
necessary repairs to the monitoring system are conducted in a timely
manner.
b. The Permittee shall install a continuous emission monitoring system that
meets the performance specification in 40 CFR Part 60, Appendix B in
effect at the time of its installation, and shall operate this monitoring
system in accordance with the quality assurance procedures in Appendix F
of 40 CFR Part 60 in effect on May 1, 2012, and the U.S. EPA’s
"Recommended Quality Assurance Procedures for Opacity Continuous
Monitoring Systems" (EPA) 340/ 1-86-010.
c. Monitoring data commencing on the clock hour and containing at least
forty-five minutes of monitoring data must be reduced to one hour
averages. Monitoring data for opacity is to be reduced to six minute block
averages unless otherwise specified in the order of approval or permit. All
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monitoring data will be included in these averages except for data
collected during calibration drift tests and cylinder gas audits, and for data
collected subsequent to a failed quality assurance test or audit. After a
failed quality assurance test or audit, no valid data is collected until the
monitoring system passes a quality assurance test or audit.
d. Except for system breakdowns, repairs, calibration checks, and zero and
span adjustments required under subsection (a) of this section, all
continuous monitoring systems shall be in continuous operation.
i. Continuous monitoring systems for measuring opacity shall
complete a minimum of one cycle of sampling and analyzing for
each successive ten second period and one cycle of data recording
for each successive six minute period.
ii. Continuous monitoring systems for measuring emissions other
than opacity shall complete a minimum of one cycle of sampling,
analyzing, and recording for each successive fifteen minute period.
e. The Permittee shall retain all monitoring data averages for at least five
years, including copies of all reports submitted to the permitting authority
and records of all repairs, adjustments, and maintenance performed on
the monitoring system.
f. The Permittee shall submit a monthly report (or other frequency as
directed by terms of an order, air operating permit or regulation) to the
permitting authority within thirty days after the end of the month (or
other specified reporting period) in which the data were recorded. The
report required by this section may be combined with any excess emission
report required by WAC 173-400-108. This report shall include:
i. The number of hours that the monitored emission unit operated
each month and the number of valid hours of monitoring data that
the monitoring system recovered each month;
ii. The date, time period, and cause of each failure to meet the data
recovery requirements of (a) of this subsection and any actions
taken to ensure adequate collection of such data;
iii. The date, time period, and cause of each failure to recover valid
hourly monitoring data for at least 90 percent of the hours that the
equipment (required to be monitored) was operated each day;
iv. The results of all cylinder gas audits conducted during the month;
and
v. A certification of truth, accuracy, and completeness signed by an
authorized representative of the owner or operator.
[WAC 173-400-105(7)]
27. NSPS CMS Data Recovery. Except for system breakdowns, repairs, calibration checks,
and zero and span adjustments required under 40 CFR 60.13(d), all continuous
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monitoring systems shall be in continuous operation. All CEMS and COMS shall meet
the following minimum frequency of operation requirements:
a. All COMS shall complete a minimum of one cycle of sampling and analyzing
for each successive 10-second period and one cycle of data recording for
each successive 6-minute period.
b. All CEMS shall complete a minimum of one cycle of operation (sampling,
analyzing, and data recording) for each successive 15-minute period.
[40 CFR 60.13(e)]
The Permittee shall make every effort to acquire, maintain, and recover valid monitoring
data. CMS downtime and resulting monitoring data loss due to malfunctions shall be
less than 10% of the monthly unit operating time. Report CMS downtime in excess of
10% as a percentage of unit operating time in the monthly report. An explanation for
the loss of monitoring data must be provided in the monthly report. Periods when CMS
data is not recovered due to daily calibration, zero and span checks are not considered
nor reported as CMS downtime in the monthly report. Records of daily calibration, zero
and span checks shall be kept for a period of five years and made available upon request
to Ecology.
[40 CFR 70.6(c)(1)]
28. MACT CMS Data Recovery. Except for system breakdowns, out-of-control periods,
repairs, maintenance periods, calibration checks, and zero (low-level) and high
calibration drift adjustments, all CMS (including CEMS and COMS) shall be in
continuous operation. All CEMS and COMS shall meet the following minimum
frequency of operation requirements:
a. All COMS shall complete a minimum of one cycle of sampling and analyzing
for each successive 10-second period and one cycle of data recording for
each successive 6-minute period.
b. All CEMS shall complete a minimum of one cycle of operation (sampling,
analyzing, and data recording) for each successive 15-minute period.
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[40 CFR 63.8(c)(4)]
The Permittee shall make every effort to acquire, maintain, and recover valid monitoring
data. CMS downtime and resulting monitoring data loss due to malfunctions shall be
less than 10% of the monthly unit operating time. Report CMS downtime in excess of
10% as a percentage of unit operating time in the monthly report. An explanation for
the loss of monitoring data must be provided in the monthly report. Periods when CMS
data is not recovered due to daily calibration, zero and span checks are not considered
nor reported as CMS downtime in the monthly report. Records of daily calibration, zero
and span checks shall be kept for a period of five years and made available upon request
to Ecology.
[40 CFR 70.6(c)(1)]
29. Calibration of Continuous Parameter Monitoring Systems (CPMS). Unless otherwise
specified, any CPMS used to show compliance with a permit condition shall be
calibrated once per calendar year or as recommended by the manufacturer. Records of
calibration must be kept for 5 years.
[40 CFR 70.6(c)(1)]
30. Source Test Methods. Minor modifications to a source test method may be used with
the advanced approval of Ecology. In addition, the Permittee may use an equivalent
alternative method with written approval from Ecology. Failure to obtain prior written
approval for any test changes may invalidate the use of the test result(s) for Title V Air
Operating Permit compliance purposes. [40 CFR Part 60 Subpart A and 40 CFR Part 63
Subpart A]
Recordkeeping Requirements
31. Monitoring Records. The Permittee shall keep records of any periodic and
continuous monitoring required by this permit. These records shall include the
following, where applicable:
a. The date, place as defined in requirement, and time of sampling or
measurement;
b. The date(s) analysis was performed;
c. The company or entity that performed the analysis;
d. The analytical techniques or methods used;
e. The results of such analysis;
f. The operating conditions existing at the time of sampling or measurement.
[WAC 173-401-615(2)(a); WAC 173-400-105]
32. Inspection Checklists. Where the permittee is required to use and maintain an
inspection checklist, the checklist must contain, at a minimum, the following
information:
a. The person conducting the inspection;
b. The date/time of the inspection
c. Location of the inspection;
d. The observations made during the inspection;
e. Corrective actions taken if any; and
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f. The date and time corrective action was initiated and completed.
[WAC 173-401-615(1)(b)]
33. Changes at Source. The Permittee shall keep records describing 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. [WAC 173-401-724(5)]
34. Records Retention. The Permittee shall retain records of all required monitoring
data and support information for a period of five (5) years from the date of
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 this permit. [WAC 173-401-615(2)(c)]
35. Recording Permit Deviations. The Permittee shall maintain a contemporaneous
record of any deviation from the requirements of this permit. [WAC 173-401-
615(3)(b)]
Reporting Requirements [WAC 173-401-520, -615(3), & -710]
36. Unit Reporting Requirements. In addition to any emission unit specific reporting
requirements identified below, emission unit specific reporting requirements are
identified in specific unit conditions of this permit.
37. Production reporting. Report within 15 days of the end of each month average
daily production of air-dried unbleached pulp. [WAC 173-405-072(4)]
38. Monthly Reporting. Monthly monitoring reports required by this permit must be
submitted to Ecology within 15 days of the end of each calendar month. [WAC
173-405-072].
All reports must clearly identify all instances of deviations from permit requirements
and the corrective actions taken to address those deviations. [WAC 173-401-615(3)(a)]
39. Notification of Planned Source Test. The Permittee must notify Ecology of all
source tests at least 30 days prior to the planned date of the test, unless
otherwise specified in applicable regulations or approved by Ecology.
Notification must include the unit to be tested, parameter(s) to be tested, date(s)
of testing, and test methods to be used during the testing, at a minimum. The
Permittee must provide a copy of the source test plan for review upon Ecology
request. [WAC 173-400-105(4), WAC 173-401-630(1), 40 CFR 70.6(c)(1)]
40. Source Testing Reports. Source test reports must be submitted to Ecology within
60 days of completion of each source test. [WAC 173-405-072]
Source test reports must be submitted to Ecology electronically via EPA’s
Compliance and Emissions Data Reporting Interface (CEDRI). EPA’s Electronic
Reporting Tool (ERT) may be used for reporting source testing results in CEDRI.
Alternate submittal format may be used upon Ecology approval.
The following minimum information must be included in the source test report:
a. Date, place, and time of sampling or measurements.
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b. General identification information for the facility, including a mailing
address, the physical address, and the owner or operator or responsible
official (where applicable) and their email address.
c. Purpose of the test including the applicable regulation(s) and permit
condition(s) requiring the test, the pollutant(s) and other parameters being
measured, the applicable emission standard and any associated process
parameter component, and a brief process description.
d. Description of the emission unit tested including fuel burned, control
devices, and vent characteristics; the appropriate source classification code
(SCC; the permitted maximum process rate (where applicable); and the
sampling location.
e. Description of sampling and analysis procedures used and any
modifications to standard procedures, quality assurance procedures and
results, record of process operating conditions that demonstrate the
applicable test conditions are met, and values for any operating
parameters for which limits were being set during the test.
f. Date(s) analyses were performed and company or entity that performed
the analyses.
g. Where a test method requires recording or reporting, the following shall be
included: Record of preparation of standards, records of calibrations, raw
data sheets for field sampling, raw data sheets for field and laboratory
analyses, chain-of-custody documentation, and example calculations for
reported results.
h. Identification of the company conducting the performance test including
the primary office address, telephone number, and the contact for the test
program including their email address.
i. Results of sampling and analyses.
j. Operating conditions existing at the time of sampling or measurement.
41. Providing Additional Data. For Ecology to evaluate a facility’s emissions or
emission control program, the Permittee shall furnish other data requested by
Ecology. [WAC 173-405-072(5)]
42. Emission Inventory. Submit an inventory of emissions from the source each year
no later than 105 days after the end of the calendar year; maintain records of
information necessary to substantiate any reported emissions. [WAC 173-400-
105(1)]
43. CEMS and COMS Data Assessment Report. For CEMS and COMS subject to the
requirements of 40 CFR Part 60, submit a Data Assessment Report (DAR)
quarterly (postmarked by April 15th, July 15th, October 15th, and January 15th) with
the Monthly Air Monitoring Report. Include data for the previous three calendar
months. The report must contain:
a. Source owner or operator.
b. Identification and location of monitors in the CEMS or COMS.
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c. Manufacturer and model number of each monitor in the CEMS or COMS.
d. Assessment of CEMS data accuracy and date of assessment as determined
by the RATA, RAA, or CGA. The assessment must include:
i. The RA for the RATA or the A for the RAA or CGA;
ii. The RM results;
iii. The cylinder gas certified values;
iv. The CEMS responses; and
v. Calculations.
If results show the CEMS to be out-of-control, report both the audit results
showing the CEMS to be out-of-control and the results of the audit
following corrective action.
e. Assessment of COMS data accuracy as determined by the quarterly
performance audit or annual zero alignment, COMS responses, and
calculations. If results show the COMS to be out-of-control, report both
the audit results showing the COMS to be out-of-control and the results of
the audit following corrective action.
f. A summary of CEMS out-of-control periods as determined by CDs.
g. A summary of COMS out-of-control periods as determined by the daily
zero drift and upscale drift checks.
h. A summary of all corrective actions taken when a CEMS or COMS was
determined to be out-of-control.
[40 CFR Part 60 Appendix F]
44. Permit Deviations and Excess Emissions. The Permittee shall promptly submit a
report of any deviations from permit conditions. [WAC 173-401-615(3)(b)]
a. For purposes of this permit, submitting a report "promptly" means the
following: (a) If the deviation presents a potential threat to human health
or safety, the report shall be made as soon as possible but no later than 12
hours after the discovery of the deviation; (b) for other deviations,
"promptly" means that the deviations are identified in the respective
monthly report.
b. Reports shall describe the probable cause of such deviations, and any
corrective actions or preventive measures taken. [WAC 173-401-615(3)].
The Permittee may include in its reports demonstrations that excess
emissions were unavoidable, consistent with the requirements of WAC
173-400-107, or WAC 173-400-108 and WAC 173-400-109, as applicable.
45. Certification of truth, accuracy, and completeness. Any application form, report,
or compliance certification required to be submitted by this permit or by Chapter
173-401 WAC shall contain certification by a responsible official of truth,
accuracy, and completeness. [WAC 173-401-520]
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46. Report Address. All reports and renewal applications required by this permit shall
be submitted to:
Department of Ecology
Industrial Section
P.O. Box 47600
Olympia, WA 98504-7600
47. Annual Compliance Certification. The Permittee shall submit an annual report to
the Department of Ecology and to EPA Region 10 by April 15 each year, certifying
compliance with the terms and conditions contained in this permit for the year
the certification covers. The certification shall describe the following for all terms
and conditions in this permit:
a. The permit term or condition that is the basis of the certification;
b. the compliance status;
c. whether compliance was continuous or intermittent; and
d. the methods used for determining compliance.
[WAC 173-401-630(5)]
Where a permit does not require testing, monitoring, recordkeeping, and
reporting for insignificant emission units or activities, the Permittee may certify
continuous compliance if there were no observed, documented, or known
instances of noncompliance during the reporting period. [WAC 173-401-
530(2)(d)]
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STANDARD TERMS & CONDITIONS
1. Duty to Comply. The Permittee must comply with all conditions of this permit. Any
permit noncompliance constitutes a violation of Chapter 70A.15 RCW and, for
federally enforceable provisions, a violation of the FCAA. Such violations are
grounds for enforcement action; for permit termination, revocation and
reissuance, or modification; or for denial of a permit renewal application. [WAC
173-401-620(2)(a)]
2. Need to Halt or Reduce Activity Not a Defense. 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 this permit. [WAC 173-401-620(2)(b)]
3. Permit Actions. This 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. [WAC 173-401-620(2)(c)]
4. Reopening for Cause. This permit shall be reopened and revised under any of the
following circumstances:
a. Additional applicable requirements become applicable to a major Chapter
401 source with a remaining permit term of three 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 date on which the
permit is due to expire, unless the original permit or any of its terms and
conditions have been extended pursuant to WAC 173-401-620(2)(j);
b. Additional requirements (including excess emissions requirements)
become applicable to an affected source under the acid rain program.
Upon approval by the administrator, excess emissions offset plans shall be
deemed to be incorporated into the permit;
c. The permitting authority or the administrator 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; or
d. The administrator or the permitting authority determines that the permit
must be revised or revoked to assure compliance with the applicable
requirements.
Procedures to reopen and issue a permit shall follow the same procedures
as apply to initial permit issuance and shall affect only those parts of the
permit for which cause to reopen exists. [WAC 173-401-730]
5. Property Rights. This permit does not convey any property rights of any sort, or
any exclusive privilege. [WAC 173-401-620(2)(d)]
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6. Duty to Provide Information. The Permittee shall furnish to the permitting
authority, within a reasonable time, any information that the permitting authority
may request in writing to determine whether cause exists for modifying, revoking,
and reissuing, or terminating the permit, or to determine compliance with the
permit. Upon request, the Permittee shall also furnish to the permitting authority
copies of records required to be kept by the permit or, for information claimed to
be confidential, the Permittee may furnish such records directly to the EPA
administrator along with a claim of confidentiality. Permitting authorities shall
maintain confidentiality of such information in accordance with RCW 70A.15.2510.
[WAC 173-401-620(2)(e)]
7. Permit Fees. The Permittee shall pay fees as a condition of this permit in
accordance with the permitting authority's fee schedule. Failure to pay fees in a
timely fashion shall subject the Permittee to civil and criminal penalties as
prescribed in RCW 70A.15.2510. [WAC 173-401-620(2)(f)]
8. Emissions Trading. No permit revision shall be required, under any approved
economic incentives, marketable permits, emissions trading, and other similar
programs or processes for changes that are provided for in this permit. [WAC 173-
401-620(2)(g)]
9. Severability. If any provision of this permit is held to be invalid, all unaffected
provisions of the permit shall remain in effect and be enforceable. [WAC 173-401-
620(2)(h)]
10. Permit Appeals. This permit or any conditions in it may be appealed only by filing
an appeal with the Pollution Control Hearings Board and serving it on the
permitting authority within 30 days of receipt pursuant to RCW 43.21B.310. This
provision for appeal in this section is separate from and additional to any federal
rights to petition and review under § 505(b) of the FCAA. [WAC 173-401-620(2) (i)]
11. Permit Continuation. This permit is issued for a 5-year term; however, this permit
and all terms and conditions contained therein, including any permit shield
provided under WAC 173-401-640, shall not expire until the renewal permit has
been issued or denied if a timely and complete application has been submitted. An
application shield granted pursuant to WAC 173-401-705(2) shall remain in effect
until the renewal permit has been issued or denied if a timely and complete
application has been submitted. [WAC 173-401-620(2)(j)]
12. Application and Issuance of a Renewal Permit. The Permittee shall submit a
complete permit renewal application to Ecology no later than six months, but no
earlier than 18 months, prior to the expiration date of the existing permit. Permits
being renewed are subject to the same procedural requirements, including those
for public participation, affected state and EPA review that apply to the initial
permit. [WAC 173-401-710(1) and (2)]
The Permittee shall submit, with the permit application form, a compliance plan
with a statement that:
a. The Permittee will continue to comply with applicable requirements with
which the Permittee is in compliance. [WAC 173-401-510(2)(h)(ii)(A)]
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b. The Permittee will meet applicable requirements which become effective
during the permit period on a timely basis. [WAC 173-401-510(2)(h)(ii)(B)]
13. Inspection and Entry. Upon consent of the Permittee or upon presentation of
credentials and other documents as may be required by law, the Department of
Ecology or an authorized representative shall be allowed to:
a. Enter the source;
b. Have access to and copy at reasonable times any records that must be kept
under this permit;
c. Inspect at reasonable times any facilities, equipment (including monitoring
and air pollution control equipment), practices, or operations regulated or
required under this permit; and
d. As authorized by WAC 173-400-105 and the FCAA, sample or monitor, at
reasonable times, substances or parameters for the purpose of assuring
compliance with the permit or other applicable requirements. [WAC 173-
400-105(3); WAC 173-401-630(2)]
14. Federally Enforceable Requirements. All terms and conditions of this permit,
including any provisions designed to limit potential to emit, are enforceable by
EPA and citizens under the FCAA, unless they are specifically designated as not
federally enforceable. [WAC 173-401-625]
15. Tampering and False Statements. No person shall make any false material
statement, representation, or certification in any form, notice, or report required
in this permit. No person shall render inaccurate any monitoring device or method
required under this permit. [WAC 173-400-105(7) and 40 CFR 70.11(a)]
16. Transfer of Ownership or Operational Control. The Permittee must notify Ecology
of any changes in ownership or operational control. The notification must include
a written agreement containing a specific date for transfer of permit responsibility,
coverage, and liability between the current and new permittee. [WAC 173-401-
720]
Page 102 of 116
PERMIT SHIELD
Pursuant to WAC 173-401-640(1), compliance with the terms and conditions of this
permit is deemed to constitute compliance with applicable requirements as contained in
this permit on which the term or condition is based, as of the date the permit is issued.
This permit shield does not exempt the Permittee from requirements, determined to be
applicable, enacted after the permit issuance date. This permit shield shall not apply to
any insignificant emission unit or activity designated under WAC 173-401-530. [WAC 173-
401-530(3)]
Pursuant to WAC 173-401-640(2), the Department of Ecology has determined that the
requirements listed in Appendix A do not apply to the facility, as of the date the
permit is issued, for the reasons specified.
Page 103 of 116
Appendix A – Permit Shield and Inapplicable Requirements
CITE BRIEF DESCRIPTION REASON
40 CFR 64 Compliance
Assurance Monitoring
CAM requirements do not apply
to the following pollutant
specific emission units: Recovery
Boiler SO2 and TRS, Lime Kiln
SO2 and TRS, Power Boiler #10
SO2 and NOx, Package Boiler
PM, SO2, NOx, CO and VOC,
Digester TRS
CAM applies to emission units that use a
control device to achieve compliance with
an applicable emission limitation or
standard. 40 CFR 64.2(a)(2). The listed
units do not rely on a control device to
meet the listed applicable requirements.
40 CFR 64 Compliance
Assurance Monitoring
CAM requirements do not apply
to the following pollutant
specific emission units: Recovery
Boiler PM surrogate HAP limit,
smelt tank PM surrogate HAP
limit, lime kiln surrogate HAP
limit, Digester HAP limitations
CAM exempts emission limits or standards
proposed by EPA after November 15, 1990.
40 CFR 64.2(b)(1)(i). This category includes
all requirements imposed through 40 CFR
Part 63, Subpart MM.
40 CFR 64 Compliance
Assurance Monitoring
CAM requirements do not apply
to the millwide tonnage limits
listed in Section H of the permit.
CAM applies to individual emission units,
per 40 CFR 64.2(a). A plant-wide tonnage
limit is not a “pollutant specific emission
unit” as that term is defined in 40 CFR
64.1.
WAC 173-400-040 Meet most restrictive standard
where 2 or more units are
connected to a common stack,
and unit-specific emissions data
is not provided.
Facility does not have any emission units
with different emission limits connected to
a common stack.
WAC 173-400-040(1) No visible emissions over 20%
opacity for 3 minutes in any one
hour, with 4 exceptions.
Opacity standards in the Kraft Pulping Mill
regulations
(Chapter 173-405 WAC) take precedence
over the general emission standards of
Chapter 173-400 WAC.
WAC 173-405-040.
WAC 173-400-040
(3)(b)
Any emissions unit identified as
a significant contributor to
nonattainment must use
reasonable and available control
methods to control emissions of
contaminants for which area is
designated nonattainment.
No emissions units at the facility have been
identified as a significant contributor to
nonattainment.
Page 104 of 116
CITE BRIEF DESCRIPTION REASON
WAC 173-400-040(6) General limit of 1,000 ppmdv
SO2
SO2 standards for emissions units at kraft
pulping mills in the Kraft Pulping Mill
regulations.
(Chapter 173-405 WAC) take precedence
over the general emission standards of
WAC 173-400.
WAC 173-405-040.
WAC 173-400-040
(8)(b)
Sources of fugitive dust
identified as significant
contributors to a PM-10
nonattainment area must use
RACT to control fugitive dust
emissions.
Facility not located near a PM-10
nonattainment area.
WAC 173-400-050(1) No particulate emissions in
excess of 0.1 grain/dscf from
combustion units, except no
particulate emissions in excess
of 0.2 grain/dscf from units
combusting wood derived fuels
for production of steam.
Particulate standards for combustion
sources in the Kraft Pulping Mill
regulations (Chapter 173-405 WAC) take
precedence over the general emission
standards of WAC 173-400. WAC 173-405-
040.
WAC 173-400-070
(2)(a)
Hog fuel boilers must meet
requirements of WAC 173-400-
040 and -050(1), with
exceptions.
Specific emission standards for combustion
sources in the Kraft Pulping Mill
regulations
(Chapter 173-405 WAC) take precedence
over the general emission standards of
Chapter 173-400 WAC.
WAC 173-405-040.
WAC 173-400-100
Registration
Registration required for listed
sources, excluding sources
subject to the operating permit
program, after EPA grants
interim or final approval to the
state program.
Facility is subject to the operating permit
program; EPA has granted interim approval
for the state program.
Page 105 of 116
CITE BRIEF DESCRIPTION REASON
WAC 173-400-105
(5)(a)
Continuous opacity & SO2
monitoring & recording required
for fossil fuel-fired steam
generators that are not subject
to an NSPS, except where
capacity is <250 million BTU/hr
heat input or where there is an
annual avg. capacity factor of
≥30%.
#10 Power Boiler is subject to an NSPS
review.
WAC 173-400-105
(5)(d)
Continuous opacity monitoring
& recording required for wood
residue fuel-fired steam
generators w/ capacity of ≥100
million BTU/hr heat input that
are not subject to an NSPS.
#10 Power Boiler is subject to an NSPS
review.
WAC 173-400-105(6) Applies to sources that are not
subject to operating permit
program.
Facility is subject to the operating permit
program.
WAC 173-400-151
Retrofit requirements
for visibility protection
BART required for sources to
which significant visibility
impairment of a Class 1 area is
reasonably attributable.
Facility has not been identified as a source
impacting a Class I area.
WAC 173-405-040(7)
[STATE ONLY, NOT
FEDERALLY
ENFORCEABLE]
Continuously employ best
practicable operation and
maintenance procedures for
recovery furnaces or lime kilns
with an alternative opacity limit.
Facility does not have any alternative
opacity limits for recovery furnace or lime
kiln.
WAC 173-405-077 Provisions of WAC 173-400-
105(5) (Report of startup,
shutdown, etc.) apply.
Old WAC 173-400-105(5) has been deleted
from state regulations and the SIP.
Chapter 173-410 WAC;
Sulfite Pulping Mills
Facility is not a sulfite pulping mill.
Chapter 173-433 WAC;
Solid Fuel Burning
Devices
Applies to wood stoves and
fireplaces.
Facility does not operate such devices.
Page 106 of 116
CITE BRIEF DESCRIPTION REASON
WAC 173-435-040(1) Major source, when requested
in writing by Ecology must
prepare a Source Emission
Reduction Plan (SERP) for
reducing emissions during
ambient air pollution episodes.
Facility has not been requested by Ecology
to prepare a SERP.
WAC 173-435-060(5) Cannot refuse entry or access to
appropriate enforcement
personnel determining
compliance with a SERP.
Facility is not required to have a SERP.
Chapters 173-470, 474,
475, 480, 481 WAC;
Ambient Air Quality
Standards
WAC 173-401-200(4)(xii) states that AAQS
apply to only temporary sources.
Chapter 173-490 WAC;
Emission Standards and
Controls for Sources of
VOCs
Applies only to facility types specified in
the regulation; pulp and paper mills are
not specified.
40 CFR Part 52.21 (j) PSD Best Available Control
Technology Review for GHGs
Applies only to facilities that have a
modification to an existing major source
after July 1, 2011.
40 CFR Part 60
Subpart D
NSPS for fossil fuel fired steam
generators constructed after
August 17, 1971.
Recovery furnace constructed in 1968.
Since then, there was no occurrence of a
physical change or change in method of
operation which increased pollutants to
which a standard applied.
40 CFR Part 60
Subpart Db
NSPS for steam generators
constructed after June 19, 1984
with a heat input rating
>100 mmBtu/hr.
Recovery furnace constructed in 1968.
Power boiler #10 constructed in 1977.
Since then, there was no occurrence of a
physical change or change in method of
operation which increased pollutants to
which a standard applied.
Page 107 of 116
CITE BRIEF DESCRIPTION REASON
40 CFR Part 60
Subpart Dc
NSPS for steam generators
constructed after June 9, 1989,
with design heat input rating of
>10 mmBtu/hr and <100
mmBtu/hr.
Recovery furnace constructed in 1968.
Power boiler #10 constructed in 1977.
Since then, there was no occurrence of a
physical change or change in method of
operation which increased pollutants to
which a standard applied.
40 CFR Part 60
Subpart BB and BBa
NSPS for Kraft Pulp Mill recovery
furnaces constructed or
modified after 9/24/76.
Recovery furnace was installed in 1968 and
not modified after 9/24/76.
40 CFR Part 60
Subpart BB and BBa
NSPS for Kraft Pulp Mill smelt
dissolver tanks constructed or
modified after 9/24/76.
Smelt dissolver tank was installed in 1968
and not modified after 9/24/76.
40 CFR Part 60
Subpart BB and BBa
NSPS for Kraft Pulp Mill lime
kilns constructed or modified
after 9/24/76.
Lime kiln was installed in 1975 and not
modified after 9/24/76
40 CFR Part 60
Subpart BB and BBa
NSPS for Kraft Pulp Mill including
gases from digester systems,
brown stock washer systems, or
multiple-effect evaporator
systems constructed or modified
after 9/24/76.
Digesters 1-9 were installed prior to and
not modified after 9/24/76. All MEE’s,
except E-set, and all washers, except C-
washers, were installed prior to and not
modified after 9/24/76.
Order No. DE93-AQI057 Concerning electrostatic
precipitator replacement.
Rescinded by Ecology, 7/6/93.
40 CFR 60.4214(c) Concerning stationary CI internal
combustion engine equipped
with a diesel particulate filter.
Facility does not have CI internal combustion
engines equipped with diesel particulate
filters.
40CFR 60.42b(b) Subpart Db SO2 emission limits. Package boiler does not combust coal.
40 CFR 60.42b(c) Subpart Db SO2 emission limits. Package boiler does not use emerging
technology.
40 CFR 60.42b(d) Subpart Db SO2 emission limits. Package boiler does not combust oil other
than very low sulfur oil.
40 CFR 60.42b(f) Subpart Db SO2 emission limits
average basis.
Package boiler is not limited to annual
capacity factor of 10% or less.
40 CFR 60.43b(c) Subpart Db PM emission limits. Package boiler does not combust wood.
Page 108 of 116
CITE BRIEF DESCRIPTION REASON
40 CFR 60.43b(d) Subpart Db PM emission limits. Package boiler does not combust solid
waste.
40 CFR 60.44b(a)(2)(i) Subpart Db NOx emission limits. Package boiler does not combust oil with a
low heat release rate.
40 CFR 60.44b(a)(4) Subpart Db NOx emission limits. Package boiler does not use duct burner in
a combined cycle system.
40 CFR 60.44b(b)
and(c) and (d) and (e)
Subpart Db NOx emission limits. Package boiler does not simultaneously
combust mixtures of coal, oil, natural gas,
solid waste, or by-product/waste.
40 CFR 60.44b(j) Subpart Db NOx emission limit
average basis.
Package boiler is not limited to annual
capacity factor of 10% or less.
40 CFR 60 Subpart K NSPS for petroleum storage
vessels constructed or modified
after 6/11/73 and prior to
5/19/78.
Fuel oil storage tank constructed in 1932
and not since modified.
40 CFR 60 Subpart Ka NSPS for petroleum storage
vessels constructed or modified
after 5/18/78 and prior to
7/23/84.
Fuel oil storage tank constructed in 1932
and not since modified.
40 CFR 60 Subpart Kb NSPS for petroleum storage
vessels constructed or modified
after 7/23/84.
Fuel oil storage tank constructed in 1932
and not since modified.
40 CFR 60 Subpart Kb NSPS for petroleum storage
vessels constructed or modified
after 7/23/84.
Two oil storage tanks installed in 2014
have maximum true vapor pressure ≤.12
kPa.
40 CFR 63.450(d)(1)
40 CFR 63.454(e)
MACT 1 LVHC Non-condensable
Gas Source Group: Requirement
to install a flow indicator on
computer controlled bypass line
valves and record flow every 15
minutes
PTPC does not have any computer
controlled bypass line valves.
Order DE 93-AWI063 Concerning limiting emissions
from the recovery furnace
corresponding with issuance of a
Certificate of Emission Reduction
Credit
Superseded and repealed by Order 2892-
05AQ.
Page 109 of 116
CITE BRIEF DESCRIPTION REASON
Order DE 88-195 NOC Order requiring installation
of a Waterloo scrubber at Power
Boiler #10 and setting
appropriate conditions.
Superseded and repealed by Order 2892-
05AQ.
Order DE 87-107 Order requiring demonstration
of backup boiler start up in
compliance with opacity limits.
Superseded and repealed by Order 2892-
05AQ.
Order DE 85-209 Order requiring monthly
particulate source testing at
Power Boiler #10.
Superseded and repealed by Order 2892-
05AQ.
Order DE 84-390
(not including Appendix
A, PSD I)
Order and NOC limiting mill
emissions and emissions
associated with a mill expansion
to produce approximately 650
tons per day of unbleached Kraft
pulp and paper. Appendix A of
the Order is PSD-I which
addresses PSD issues associated
with the mill expansion. PSD-I
was not modified and is included
as Appendix A to Order 2892-
05AQ dated March 16, 2000.
Superseded and repealed by Order 2892-
05AQ.
Note: This Order contains PSD-I in its
Appendix A.
Order DE 82-291 Concerning noncondensible gas
(NCG) venting.
Superseded and repealed by Order 2892-
05AQ.
All Orders issued prior
to 1984
Order issued prior to 1984 were
superseded and repealed.
Superseded and repealed by Order 2892-
05AQ.
40 CFR 63.443(a)(1)(v) Control HAP emissions from
oxygen delignification systems
by April 17, 2006.
PTPC does not have an oxygen
delignification system.
40 CFR 63.443(c), as
applied to B-side
washers
Pulp washing system to be
enclosed, vented to a closed-
vent system and routed to
control device. (Note: B-side
washers were the only HLVC
source requiring collection -
other sources were less than the
emission threshold).
PTPC elected to implement clean
condensate alternative as provided in 40
CFR 63.447.
Page 110 of 116
CITE BRIEF DESCRIPTION REASON
40 CFR 63.443(d)(1),
(2), and (3)
Control devices used to reduce
LVHC HAP emissions.
PTPC has implemented
40 CFR 63.443(d)(4) as the method of
choice to reduce HAP emissions.
40 CFR 63.446(c) (1),
and (2)
HAP-containing pulping process
condensates from equipment
systems.
PTPC has implemented
40 CFR 63.446(c)(3) as the method of
choice.
40 CFR 63.453
(b),(c),(d),(e),(f),(g), and
(h)
40 CFR Part 63 Subpart S
monitoring requirements.
PTPC does not operate a thermal oxidizer,
gas scrubber, bleaching system, or steam
stripper.
40 CFR 63.457(a) and
63.7(g) for reporting
deadline
Conduct Initial Performance Test
of kraft pulping condensate
control system and clean
condensate alternative control
system and report results within
60 days.
IPT performed and test report submitted
12/1/06.
40 CFR 63.6600 Emissions and operating
limitations for stationary RICE
greater than 500 BHP.
PTPC does not operate stationary RICE
with BHP greater than 500.
40 CFR 63.6655(a)(5) Document actions taken during
periods of malfunction to
minimize emissions and the
corrective actions to restore
malfunctioning processes.
Facility does not operate emergency
engines with an emission limit. Therefore,
this requirement, which applies to
“malfunctions” is not applicable.
40 CFR 63.9(e) Notify Ecology at least 60 days in
advance of intent to perform
Part 63 Initial Performance Test.
Notice provided 6/13/06 of performance
test of kraft pulping condensate control
system and clean condensate alternative
control system.
Order No. 2892-05AQ,
Table 1, E.1 & E.2.
Power Boiler #2 limits. Power Boiler #2 has been
decommissioned.
WAC 173-400-050(4) Standards for Commercial and
Industrial Solid Waste
Incineration (CISWI) units
Power Boiler #10 does not qualify as a
CISWI unit because it employs energy
recovery (in the form of steam generation)
when combusting any fuel type and does
not combust fuels classified as solid waste.
Page 111 of 116
CITE BRIEF DESCRIPTION REASON
WAC 173-434 Standards for Solid Waste
Incinerator facilities
The OCC rejects and urban wood burned in
Power Boiler #10 is usable fuel rather than
solid waste and satisfies the wood waste
exemption included in the definition of
solid waste referenced within WAC 173-
434-030.
40 CFR 60 Subpart
CCCC
Standards of performance for
commercial and industrial solid
waste incinerator units
constructed after November 30,
1999 or Modified or
Reconstructed after June 1, 2001
Power Boiler #10 does not burn solid
waste as defined in EPA’s Non-Hazardous
Secondary Material rule in 40 CFR Part
241, and therefore is not subject to the
standards for commercial and industrial
solid waste incinerator units.
40 CFR 60 Subpart
DDDD
Standards of performance for
commercial and industrial solid
waste incinerator units
constructed before November
30, 1999
Power Boiler #10 does not burn solid
waste as defined in EPA’s Non-Hazardous
Secondary Material rule in 40 CFR Part
241, and therefore is not subject to the
standards for commercial and industrial
solid waste incinerator units.
Page 112 of 116
Appendix B – Formulas for Emission Calculations
Permit Conditions E.1c and M.1 through M.12
lb/day = concentration x air flow rate x unit conversion factor x time adjustment
Concentration is measured using a reference method or continuous monitor. Particulate
concentrations are in gr/dscf and chemical concentrations are in ppm.
Air Flow Rate must be representative of operation. Air flow measured during the test or
a “f” factor from the federal register times heat input may be used.
Unit Conversion Factor is case specific. For partiulcate conversions 1 lb = 7,000 grains.
For ppm measurements, molar mass and molar volume for the chemical being
measured are used. PM10 as a fraction of PM is based on either historical test data or
AP-42 factors.
Time Adjustment is case specific and is dependent on the flow rate time unit. The
measured unit is multiplied by the concersion factor to attain the desired time unit.
Tons/year = ∑ lbs/day for the calendar year x unit conversion factor
Unit conversion factor is 1 ton = 2,000 pounds
Page 113 of 116
Appendix C – Applicable Permits and Orders
Compliance Order 18124
NOC Order 16293 (OCC Pulper Upgrade Project)
NOC Order 11025 (Boiler MACT)
NOC Order 10453 (Paper Machine No. 12 Refiner Project)
NOC Order No. DE 97AQ-I030, Second Revision
PSD-96-01A, Amendment 1
Order No. 2892-05AQ, First Modification
PSD-I
Page 114 of 116
Appendix D – Definitions of Abbreviations
Abbreviation Definition
Btu British thermal units
BACT Best Available Control Technology
CAA Clean Air Act [42 U.S.C. section 7401 et seq.]
CAM Compliance assurance monitoring
CEMS Continuous emission monitoring system
CFR Code of Federal Regulations
CMS Continuous monitoring system
CO Carbon Monoxide
COMS Continuous opacity monitoring system
CO2 Carbon dioxide
CPMS Continuous parametric monitoring system
dscf Dry standard cubic foot
Ecology Washington State Department of Ecology
EPA United States Environmental Protection Agency
EU Emission Unit
gr/dscf Grains/dry standard cubic foot (7,000 grains = 1 pound)
gpm Gallons per minute
HAP Hazardous air pollutant
hr Hour
IEU Insignificant emission unit
lb Pound
MACT Maximum Achievable Control Technology
mm One million
NESHAP National Emission Standards for Hazardous Air Pollutants (40 CFR 61 and 63)
NOC Notice of Construction
NOx Oxides of nitrogen
NSPS New source performance standards
O2 Oxygen
PM Particulate matter
PM10 Particulate matter with an aerodynamic diameter ≤ 10 microns
ppmdv Parts per million, on a dry volume basis
PSD Preventions of Significant Deterioration
PTE Potential to emit
RM Reference Method
SCR Selective catalytic reduction
SO2 Sulfur dioxide
SOx Oxides of sulfur
tpy Tons per year
TBLS Tons of black liquor solids
tBACT Toxics Best Available Control Technology
VOC Volatile organic compounds
WAC Washington Administrative Code
Appendix E – Footnote Key
Page 115 of 116
1. Monitoring is required only when the emision unit is operating.
2. RESERVED
3. Source Test Frequency (M/Q/S/A):
Quarterly (Q): Quarterly testing must be conducted each calendar quarter between 45 and 105
days following the previous test, or as otherwise approved by Ecology. Calendar quarters are
the respective periods of three consecutive calendar months starting on January 1, April 1, July
1, and October 1.
If the permittee is testing on a quarterly cycle and any single source test result exceeds
the emissions limitation, the source test frequency shall increase to monthly**. Monthly
source testing shall commence within 60 days of the source test which exceeded the
emissions limitation.
If quarterly source test results are less than or equal to 50% of the emissions limitation
for four consecutive quarters, source testing may be performed on a semiannual basis.
Semiannual (S): Semiannual source testing must be conducted each calendar half between 4
and 8 months following the previous test, or as otherwise approved by Ecology. Calendar halves
are the two respective periods of six consecutive calendar months beginning January 1st and
July 1st.
If the permittee is testing on a semiannual cycle and any single source test result
exceeds the emissions limitation, the source test frequency shall increase to monthly**.
Monthly source testing shall commence within 60 days of the source test which
exceeded the emissions limitation.
If the permittee is testing on a semiannual cycle and any single source test exceeds 50%
of the emissions limitation, source test frequency shall revert to quarterly**. Quarterly
source testing must commence the calendar quarter following the source test which
exceeded 50% of the emission limit.
If semiannual source test results are less than or equal to 25% of the emissions
limitation for four consecutive calendar halves, source testing may be performed on an
annual basis. Previous consecutive quarterly testing below 25% of the emissions
limitation may be counted towards the “four consecutive calendar halves.”
Annual (A): Annual source testing must be conducted each calendar year between 8 and 14
months following the previous test, or as otherwise approved by Ecology.
If the permittee is testing on an annual cycle and any single source test result exceeds
the emissions limitation, the source test frequency shall increase to monthly**. Monthly
source testing shall commence within 60 days of the source test which exceeded the
emissions limitation.
If the permittee is testing on an annual cycle and any single source test exceeds 50% of
the emissions limitation, source test frequency shall revert to quarterly**. Quarterly
Page 116 of 116
source testing must commence the calendar quarter following the source test which
exceeded 50% of the emission limit.
If the permittee is testing on an annual cycle and any single source test exceeds 25% of
the emissions limitation, source test frequency shall revert to semi-annually**. Semi-
annual source testing must commence the calendar half following the source test which
exceeded 25% of the emission limit.
Monthly (M): A source test must be performed in any month that the emission unit was
operated more than 216 hours. If an emission unit is not operated for more than 216 hours in a
month, a source test must be performed prior to the emissions unit having been operated a
total of 720 hours since the end of the month of the last source test.
If monthly source test results are lower than the emissions limitation for 3 consecutive
months, source testing may be performed on a quarterly basis. To qualify for quarterly
source testing following an exceedance of an emissions limitation, the first of the three
monthly tests with measured emissions less than the emissions limitation must not
occur in the same calendar month as an emissions exceedance.
*If an emissions unit is not in operation for 180 consecutive days, the emission unit must
perform a stack test within 30 days of start-up, unless otherwise approved by Ecology.
Testing must begin at a quarterly frequency, unless otherwise approved by Ecology.
4. Once every five years/annually/monthly means source test is to be performed once every
five years. If any single source test exceeds 75% of the limitation, source testing shall be
performed annually until three consecutive year’s tests are below 75% of the limitation,
after which source testing may return to once every five years. If any single source test
exceeds the limitation, source testing shall be performed monthly until six consecutive
month tests are below the limit, after which source testing may return to once per year.