Document 8JKra5rgqgZLDoY1nXRRG6NZ

SENT VIA ELECTRONIC MAIL Paula Wentzell Environmental Manager Clearwater Paper Augusta 4278 Mike Padgett Highway Augusta, Georgia 30906 Paula.wentzell@clearwaterpaper.com Dear Paula Wentzell: On June 25-27, 2024, the U.S. Environmental Protection Agency Region 4 Air Enforcement Branch conducted a partial compliance inspection at Clearwater Paper, located in Augusta, Georgia. Enclosed is a copy of the final report generated by the U.S. Environmental Protection Agency's Region 4, South Air Enforcement Section. Should you have questions regarding this inspection report, contact me at (404) 562-8837, or by email at Slade.Daniel@epa.gov. Sincerely, Digitally signed by DANIEL DANIEL SLADE SLADE Date: 2024.08.19 11:50:13 -04'00' Daniel Slade Environmental Engineer South Air Enforcement Section CC: Sean Taylor, GA EPD Lauren Wheeler, GA EPD Adrienne Tabor, GA EPD Whitney DeMoor, GA EPD Gerson Martinez, GA EPD United States Environmental Protection Agency (EPA) Region 4 Air Enforcement Branch Draft Inspection Report I. GENERAL INFORMATION Facility Name: Clearwater Paper Location (Address): 4278 Mike Padgett Highway Augusta, Georgia 30906 Inspection Dates: June 25-27, 2024 Type of Inspection (Full or Partial Compliance Evaluation): Partial Compliance Evaluation PROGRAMMATIC ID: GA0000001324500006 PERMIT NUMBER: Permit # 2631-245-0006-V-05-0 EPA Region 4 Investigator(s)/Inspector(s): 1. Daniel Slade, Environmental Engineer 2. Kevin Taylor, Environmental Engineer 3. Andrew Mills, Environmental Engineer State/Local Investigator(s)/Inspector(s): 1. Lauren Wheeler, GA EPD 2. Adrienne Tabor, GA EPD 3. Whitney DeMoor, GA EPD 4. Gerson Martinez, GA EPD Person(s) Contacted at Facility (Name and Title): 1. Paula Wentzell, Environmental Manager 2. Chris Wellman, Environmental Engineer 3. Dean Messner, EHS Manager 4. Dylan Stewart, Environmental 360 Contractor Report Prepared by: Daniel Slade Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 1 of 13 II. FACILITY INFORMATION A. Facility and Permit Information Facility and Permit Information Comments 1. Type of facility (e.g., chemical plant, refinery, cement manufacturer, etc.). 2. Air permit number(s) and type of permit (e.g., Title V, PSD, Synthetic Minor, etc.). 3. Air permit issuance date. Bleached Kraft Pulp and Paperboard Mill Permit # 2631-245-0006-V-05-0 February 15, 2021 4. Air permit expiration date. February 15, 2026 5. Facility classification (Major, Synthetic Minor/Conditional Major, Minor). 6. Major source pollutants (if applicable). 7. Applicable regulations (e.g., State Implementation Plan, MACT Subpart FFFF, NSPS Subpart EEEE, etc.). Major Particulate Matter (PM) Sulfur Dioxide (SO2) Hazardous Air Pollutants (HAPs) Volatile Organic Compounds (VOCs) Nitrogen Oxides (NOx) Carbon Monoxide (CO) Total Reduced Sulfur (TRS) 40 C.F.R. Part 60, Subpart A 40 C.F.R. Part 60, Subpart BB 40 C.F.R. Part 60, Subpart BBa 40 C.F.R. Part 60, Subpart Db 40 C.F.R. Part 60, Subpart IIII 40 C.F.R. Part 60, Subpart Y 40 C.F.R. Part 61, Subpart A 40 C.F.R. Part 61, Subpart E 40 C.F.R. Part 63, Subpart A 40 C.F.R. Part 63, Subpart S 40 C.F.R. Part 63, Subpart MM Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 2 of 13 Facility and Permit Information Comments 8. Types of air emission points (e.g., tanks, process vents, boilers, etc.). 9. Types of air pollution control equipment (e.g., baghouse, scrubber, afterburner, etc.). 40 C.F.R. Part 63, Subpart DDDDD 40 C.F.R. Part 63, Subpart ZZZZ State Implementation Plan (SIP) Tanks, Process Vents, Boilers, Kilns, Wastewater Treatment Ponds Baghouses, Scrubbers, Electrostatic Precipitators, Cyclones, Boilers, Kilns B. Process Description Clearwater Paper is a bleached Kraft pulp and paperboard mill in Augusta, Georgia. The facility has recently changed ownership, on May 1, 2024, from previously Graphic Packaging International to Clearwater Paper. The facility processes log and chipped hardwood and softwood to make rolls of stock paper to be sent to other facilities to finish into consumer products. III. INSPECTION ACTIVITIES Activity Opening Meeting 1. Date and time entered the facility. 2. Credentials presented to facility personnel (include name and title). Yes No NA Y Y Comments The EPA Region 4 inspection team and GA EPD personnel arrived at the facility on June 25, 2024, at 9:00 AM EDT. Upon arrival, the inspection team presented credentials to Paula Wentzell, Environmental Manager. Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 3 of 13 Activity 3. Conducted an opening meeting to explain the purpose and objectives of the inspection. Yes No NA Y 4. Discussed safety issues. Y 5. Discussed which records to be Y reviewed. 6. Discussed the facility walk- Y through and the areas to be observed in the facility. 7. Discussed facility policy Y regarding photographs or video (if applicable). Comments The inspection team held an opening conference to discuss inspection objectives. An opening meeting was conducted around 9:17 AM EDT in a facility conference room on June 25, 2024. The inspection team informed facility representatives that the inspection would occur over three days with the first day consisting of a review of records and general process overview/walkthrough and the remaining two days to be spent in the process conducting Method 21 and sensory leak monitoring. The inspection team discussed appropriate personal protective equipment prior to going to process areas. Steel-toe boots, hardhats, visibility vests, safety glasses, ear protection, and gloves were required at the facility. The inspection team discussed which records would be reviewed onsite and that additional records would be obtained through an information request following the inspection. The inspection team discussed the Facility operations each day prior to entering the process. The inspection team stated the plan to monitor as much of the LDAR components as time permitted. The inspection team notified facility staff when photographs or videos were taken during the walk-through. All photographs are considered Confidential Business Information (CBI) until reviewed by facility staff. Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 4 of 13 Activity 8. Discussed the use of the infrared camera, TVA, PID, and any other equipment. Yes No NA Y 9. Discussed CBI. Y Records Reviewed at the Facility 10. The types of records reviewed, Y and the time period reviewed. Facility Walk-Through Observations Comments The inspection team indicated that FLIR cameras, toxic vapor analyzer (TVA), and QRAE 4-gas monitors would be used during the process walkthrough. The inspection team indicated that any material claimed to be CBI would be treated in accordance with regulations. The inspection team reviewed the following records on-site: 1. Monthly LDAR records from January 2024 to June 2024. 2. Annual LDAR report from August 2023 3. Daily lime production, mud flow, mud density and percent solids records from January 2024 to June 2024 4. Daily black liquor firing rate and percent black liquor solids from January 2024 to June 2024 5. 15 Day rolling average for methanol collection from January 2024 to June 2024 Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 5 of 13 11. The process equipment Y observed and the associated operational rate observed (e.g., Furnace 1 production rate was 5 lbs/hr on 1/1/15, at 2:00 pm - permit requires max rate at 6 lbs/hr). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. On June 25, 2024, at approximately 1:27 PM EDT, a general overview tour of the facility began. The inspection team used FLIR GF77 and GF320 IR cameras to view process and control equipment to identify any leaks or areas that may need additional monitoring the following days of the inspection. No major areas of concern were noted during the general walkthrough. The path taken during the walkthrough started at the No.1 and No. 2 Lime Kilns then proceeded to the No. 3 Digestor where the inspection team got a bird's eye view of the facility from the top of the digestor. One image (FLIR0021) was taken from the top of the digestor showing the wastewater treatment ponds. The next areas visited were the No. 3 Paper Machine (PAPR) and Brown Stock Washers (BSW3). The walkthrough of process equipment concluded with a visit to the boilers and No. 2 and No. 3 Evaporator sets. On the walk back to the office, a video (MOV_1274) was taken showing an intermittent plume exiting from the Digestor Heater Relief Stack. The last area viewed before leaving the facility was the wastewater treatment ponds. The first day concluded at 4:20 PM EDT. On June 26, 2024, at approximately 10:05 AM EDT, the inspection team, facility personnel and facility LDAR contractor began LDAR monitoring at the Main Foul Condensate Tank conducting sensory monitoring for the nonMethod 21 components. The morning monitoring was only sensory checks and viewing of components with the GF320 as the LDAR contractor's TVA2020 had not arrived at the facility at the time of the first monitoring. Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 6 of 13 The other areas monitored during the morning were the No. 2 and No. 3 Evaporator sets and the Innovations Condensate Tank. One leak was noted at component T-18097 and a video (MOV_1276) was taken showing a leak at the valve on a condensate line. One photo (DC_1275) was taken of discoloration on a valve (MV-19028) in the condensate collection system. In the afternoon, the monitoring resumed at approximately 2:30 PM EDT at the low volume high concentration (LVHC) gases at the No. 1 and No. 2 Power Boilers. One leak was found at component SE14009. The inspection team's TVA recorded a reading of 981 ppm and this exceedance was confirmed by the contractor's TVA reading of 700 ppm. A video (MOV_1278) of the leak was taken showing what appeared to be multiple leaks coming from the bolts on a flange. Monitoring in the area continued until the TVA plugged around 3:20 PM EDT. The second day concluded around 4:20 PM EDT. On June 27, 2024, at approximately 8:45 AM EDT, the inspection team, facility personnel and facility LDAR contractor began LDAR monitoring of the remaining components. The inspection team used the GF320 and TVA during the monitoring beginning in the Lime Kiln area. Then the Main Condensate Tank was revisited to monitor the Method 21 applicable components. The final areas monitored were the digestors and bleach plants. No leaks were found with the GF320 or TVA and no detectable odors or visual leaks were noted during the monitoring. Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 7 of 13 Activity Yes No NA 12. The type of process parametric Y monitoring observed and the associated value observed (e.g., Furnace 1 flux injection rate was 200 lbs/batch at 1/1/15, at 2:00 pm - permit requires max rate at 225 lbs/batch). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 13. If process equipment or Y parametric monitoring equipment was not operating, state the reason by facility personnel why the equipment was not operating. Comments Any noted pictures or videos can be found in appendix A and collected operational data can found in appendix C. Refer to Item 11 for the description of the process walk through and collected parametric data can found in appendix C. During the inspection, the No. 1 Lime Kiln was down as replacement of a slaker was being done. Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 8 of 13 Activity 14. The type of air pollution control equipment, the process equipment it is controlling, and the associated parametric monitoring value observed (e.g., baghouse pressure drop, temperature, scrubber flow rate, etc.). Yes No NA Y (For example - RTO 1 controlling furnace 1, 1,500 degrees F on 1/1/15, at 2:00 pm - permit requires 1,400 degree F or higher). Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. Comments Refer to Item 11 for the description of the process walk through and collected control equipment data can be found in Appendix C. Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 9 of 13 Activity 15. Continuous emissions monitoring devices and values observed. (e.g., CEMS, COMs, etc.). Yes No NA N/A Provide the date and time the information was recorded by the inspector. Identify the permit limit (if applicable). An attachment may be used for a large amount of information. 16. If air pollution control N/A equipment was not operating, state the reason by facility personnel why the equipment was not operating. 17. Capture and collection system N/A (enclosures and hoods) observations, if applicable (e.g., the magnitude and duration of emission escaping capture from the hood). Comments Refer to Item 11 for the description of the process walk through and collected continuous emissions monitoring data can be found in Appendix C. White Liquor Scrubber A (WLSA) controlling emissions from the LVHC Gas Control System was not in operation during the inspection. Gases were being routed through White Liquor Scrubber B (WLSB). When combusting concentrated TRS stream in the No. 1 and No. 2 Power Boilers, the gases shall be scrubbed in one of the White Liquor Scrubbers. Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 10 of 13 Activity 18. Ductwork transferring the emissions to the air pollution control device observations, if applicable (e.g., the magnitude and duration of emission escaping from the ductwork, holes or deterioration in ductwork, no deterioration observed, etc.). 19. Any existing unpermitted emission points, new unpermitted emission points, or non-permitted construction activities observed. (if yes, describe in the comments field). 20. Were any visible emissions observed? (if yes, identify the location and equipment). 21. Was a Method 9 reading performed? (if yes, identify the location and equipment). 22. Was the cause of the visible emissions investigated and the information documented? 23. Was a Method 22 performed for visible emissions? (if yes, identify the location and equipment). 24. Identify the cause of the visible emissions as explained by facility personnel, if applicable. Yes No NA N/A N N N N N N/A Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 11 of 13 Comments Activity 25. Was the infrared camera used? If so, attach the video log (which includes the equipment ID, and the date and time the video was recorded) and videos to this report. Yes No NA Y 26. Was the TVA used? If so, Y identify the equipment monitored and the results. Provide the date and time the information was recorded by the inspector. Include actual instrument readings for each piece of equipment monitored above the leak definition and/or where the infrared camera identified a release. An attachment may be used for a large amount of information. 27. Was the PID used? If so, N identify how the PID was used and the results. Provide the date and time the information was recorded by the inspector. An attachment may be used for a large amount of information. Closing Meeting Comments The inspection team used IR cameras all three days of the inspection. The first day the FLIR GF77 and GF320 were both used during the initial walkthrough of the Facility. The GF320 was used during the remaining days of the inspection during the NCG and condensate LDAR monitoring. All videos and pictures can be found in Appendix A. The inspection team used a TVA to monitor LDAR components that require Method 21 monitoring. Any component that is subject to sensory checks that had any concerns of a possible leak was also checked with the TVA. One leak was found at Tag # SE-14009 on the LVHC gases at the No. 1 and No. 2 Power Boilers. The inspection team's TVA recorded a reading of 981 ppm and this exceedance was confirmed by the contractor's TVA reading of 700 ppm. A video (MOV_1278) of the leak was taken showing what appeared to be multiple leaks coming from the bolts on a flange. Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 12 of 13 Activity 28. Conducted a closing meeting. 29. Summarize any additional information needed, if applicable? 30. Accept a declaration of CBI, if applicable? 31. Discussed observations. 32. Discussed next steps, if applicable? 33. Date and time inspection concluded. Miscellaneous 34. Include any additional observations, if applicable. Yes No NA Y N/A N/A Y Y Y N/A Comments The inspection team conducted a closing meeting on June 27, 2024, at 1:30 PM EDT with facility personnel. Facility claimed no CBI after review of the draft report. The inspection team thanked facility staff for their time. The team discussed the facility walkthrough and monitoring activities. A final inspection report from EPA Region 4 will be sent to the company within a 60-day timeframe. The inspection concluded on June 27, 2024, at 2:00 PM EDT. EPA Investigator/Inspector Signature: Digitally signed by DANIEL DANIEL SLADE SLADE Date: 2024.08.19 11:51:24 -04'00' ___________________________________ EPA Supervisor Signature & Title: Digitally signed by TODD TODD GROENDYKE GROENDYKE ___________________D_at_e:_2_02_4_.08_.1_9_1_2:_42_:4_2_-0_4_'00' Chief, South Air Enforcement Section Project Name: Clearwater Paper Augusta ICIS/Project No GA0000001324500006 -2024 Document Number: AEBFORM-012-R0 Title: Inspection Report Effective Date: May 14, 2019 Page 13 of 13 Appendix A Inspection Picture and Video Log During the June 25-27, 2024, inspection EPA Region 4 staff used a FLIR GF77 and GF320 camera to take pictures and videos at Clearwater Paper, located in Augusta, Georgia. Below is an inventory of the pictures and videos. All times are in Eastern Daylight Time (EDT). File Name FLIR0021 Device GF77 Videographer/ Photographer Daniel Slade Date 6/25/2024 MOV_1274 DC_1275 MOV_1276 GF320 GF320 GF320 Andrew Mills Andrew Mills Andrew Mills 6/25/2024 6/26/2024 6/26/2024 MOV_1278 GF320 Andrew Mills 6/26/2024 Approximate Time 1:50 PM 3:45 PM 10:30 AM 10:45 AM 2:30 PM Description View of Wastewater ponds from the top of the No. 3 Digestor Digestor Heater relief valve stack Discoloration at valve (MV-19028) Leaking valve (T-18097) at the #2 Evaporator set Leak at flange on component (SE14009) LVHC gases to #1 & #2 Power Boilers Appendix B Calibration Data Instrument Information Instrument Type Informal Identifier TVA 2020 TVA 1 Formal Identifier Property Tag # B10375 Calibration Checks TVA Date/Time Gas Concentration (ppm) 6/26/2024 9:04 AM 500 1000 10000 6/26/2024 12:55 PM 500 1000 10000 6/27/2024 8:12 AM 500 1000 10000 TVA 1 Reading (ppm) 497 1005 9900 515 1030 10000 534 1042 10000 The instrument was calibrated according to Method 21 and manufacturer instructions with the gases listed below. Calibration Gases Team Gas Type Team 2 Zero Methane Methane Methane Concentration (ppm) 500 1000 10000 Lot # 304-402834783-1 304-402851118-1 304-402606646-1 304-402606645-1 Expiration Date 9/21/2027 9/21/2027 12/2/2026 12/2/2026 Emission Unit No. 1 Lime Kiln (LK1A) Control Device None Scrubber (LK1B) No. 2 Lime Kiln None (LK2A) Scrubber (LK2B) No. 3 Recovery Boiler (RB3A) None No. 3 Smelt Tank (ST3A) ESP (RB3B) Scrubber (ST3B) No. 1 Power Boiler (PB1A) None Scrubber (PB1B) North Scrubber (PB1C) South No. 2 Power Boiler (PB2A) No. 3 Power Boiler (PB3A) None None No. 2 Bleach Plant (BP2B) ESP (PB3B) Scrubber (BP2B) Appendix C Daily Operating Data Parameter Monitored TRS (ppm) Oxygen (%) Pressure Drop (in H2O) Flow Rate (gpm) Visible Emissions (%) TRS (ppm) Oxygen (%) Pressure Drop (in H2O) Flow Rate (gpm) Visible Emissions (%) TRS (ppm) Oxygen (%) Opacity (%) BLS Firing Rate (MMlb/h) BLS Concentration (%) Total Secondary Power (kW) Flow Rate (gpm) Fan Current (amps) Visible Emissions (%) Clarifier Sludge Feed Rate Oxygen (%) Pressure Drop (in H2O) Flow Rate (gpm) Visible Emissions (%) Pressure Drop (in H2O) Flow Rate (gpm) Visible Emissions (%) Visible Emissions (%) Opacity (%) NOx (lb/MMBtu) Oxygen (%) Clarifier Sludge Feed Rate Secondary Power (kW) Pressure Drop (in H2O) Influent Flow Rate (gpm) Fan Load (amps) Liquid Ox/Re Potential (mV) Visible Emissions (%) Permit Limit <40 ppm - >25 in H2O* >240 gpm* <40% <8 ppm >23.4 in H2O* >540 gpm* <40% <5 ppm <20% - >370.5 kW* >340 gpm >68 A <40% >8.5 in H2O* >315 gpm* <40% >9.3 in H2O* >315 gpm* <40% <40% <20% <0.3 lb/MMBtu >82.3 kW* >17.8 in H2O* >460 gpm* >60 A* <-280 mV* <40% 6/25/24 6/26/24 6/27/24 Down 3.05 9 48 700 0 0.1 5.6 15 4.24 69.8 507 424 121 0 0 9.4 NG** NG** 5.3 0.2 5.7 0 212.6 10.5 521 110 -430 0 5.95 8.4 48 700 0 0.1 5.7 6.3 2.83 70.3 752 434 124 0 0 9.4 10.4 300 0 11.6 300 0 Down 5.7 0.2 6.5 0 217.8 10.8 516 112 -468 0 2.33 5.3 48 700 0 0.1 9.1 7.6 2.39 68.8 703 428 126 0 0 8.4 10.3 300 0 11.6 300 0 6.7 0.2 5.8 0 215.5 10.6 519 110 -476 0 Emission Unit No. 3 Bleach Plant (BP3B) Chlorine Dioxide Generator (R10A) LVHC Control Device Scrubber (BP3B) Scrubber (R10B and R2AB) (R2AB only recorded when being used as the primary control device per permit) White Liquor Scrubber (WLSA) White Liquor Scrubber (WLSB) Parameter Monitored Pressure Drop (in H2O) Influent Flow Rate (gpm) Fan Load (amps) Liquid Ox/Re Potential (mV) Visible Emissions (%) Pressure Drop (in H2O) Recirculation Rate (gpm) Liquid Ox/Re Potential (mV) Visible Emissions (%) Pressure Drop (in H2O) Flow Rate (gpm) Visible Emissions (%) Pressure Drop (in H2O) Flow Rate (gpm) Visible Emissions (%) Permit Limit >1.2 in H2O* >1350 gpm* >90 A* <-280 mV* <40% >5.7 in H2O* >64 gpm* <-350 mV* <40% >3.2 in H2O* >22.6 gpm* <40% >3.2 in H2O* >22.6 gpm* <40% 6/25/24 10.7 2242 147 -484 0 6/26/24 Down 6/27/24 Down 8.6 73 Down Down -581 0 Down 20.7 25 0 Down 20.7 25 0 Down 20.7 25 0 * The listed limit in the Permit but limits can be changed through setting a new Georgia EPD approved limit when conducting performance testing. ** The No. 1 Power Boiler was operating on natural gas so emission control through scrubbers PB1B and PB1C is not required so no parameters were recorded.