Document N2ereGEaOdnvvznQG0x3o0pKQ

ATTACHMENT 10 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00001 SC_EVERSPLIT0002145 Attachment 10 DIPARTME- NT ECOLOGY st, : Li. of waalaneston Department of Ecology Statement of Basis (03/30/2018) Source Information: Air Operating Permit (AOP) No.: Source Name: County: Issued Date: Effective Date: Expiration Date: AFS Plant ID Number: 0003697 Boise White Paper L.L.C. Wallula, Washington Walla Walla March 29, 2018 April 1, 2018 March 31, 2023a 53/071/0003 Permitting Authority Information: Preparer: Ecology Program: Address: Phone: Fax: Robert Carruthers, P.E. Industrial Section 300 Desmond Drive PO Box 47600 Olympia, WA 98504-7600 (360) 407-6954 (360) 407-6102 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00002 SC_EVERSPLIT0002146 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 2 of 123 Table of Contents List of Abbreviations and Acronyms 4 Introduction 5 Permit Authority 5 Source Description 7 Overview of Significant Regulatory Changes and Significant Compliance Demonstration Procedures 11 Determination of Compliance 11 Specific Areas of Compliance 11 PM10 11 Compliance Assurance Monitoring (CAM) 11 Greenhouse Gas Reporting 30 Industrial Boiler MACT Standard, Subpart DDDDD 31 Reciprocating Internal Combustion Engines (RICE) MACT, 40 CFR 63 Subpart ZZZZ and 40 CFR 60 Subpart JJJJ 33 Pulp and Paper Industry NESHAP (MACT I), 40 CFR 64 Subpart S update 35 Pulping Process Condensates 36 High-Volume, Low-Concentration (HVLC) System 36 Pulp and Paper NESHAP, 40 CFR 63, Subpart S RTR 37 Pulp and Paper Industry NESHAP (MACT II), 40 CFR 63, Subpart MM 37 NSSC Pulping/Pink Liquor System 38 Printing and Publishing MACT, 40 CFR Part 63 Subpart KK 38 Best Available Retrofit Technology (BART) Inapplicability 38 Projects and Permit Approvals 39 Wallula Containerboard/Box Plant Projects 39 Ancillary and Support Operations 39 PSD Permit, Notices of Construction ("NOC"), State Orders, and Letters of Approval 40 Federal Air Quality Requirements: Applicability for MACT, NSPS, NESHAP, or CAM 42 State Air Quality Requirements: Applicability for BACT, PSD, LAER, or Acid Rain 42 Compliance/Enforcement History and Remedies 42 Emission Unit Description 43 State-Only vs. Federally Enforceable Requirements 44 Emission Limit Discussion 44 Monitoring and Gap Filling 44 Representative Source Tests 46 Discussion On Specific Permit Conditions 51 Discussion on General Conditions 79 Regulatory Orders and Permits 81 Streamlining 81 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00003 SC_EVERSPLIT0002147 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 3 of 123 Insignificant Emission Units 82 Operational Flexibility 101 Permit Shield 101 Permit History and Current Changes 101 Public Participation and Response to Comments 105 APPENDIX A - Existing Orders and Permits 118 APPENDIX B - Historical Emission Testing Results 119 APPENDIX C - Plant Schematic 123 Tables Table 1: Summary of Actual to Potential Emissions (tpy) 6 Table 2: Facility Information 6 Table 3: CAM Applicability 14 Table 4: Exemption from CAM Evaluation 20 Table 5 Smelt Dissolving Tank Particulate Matter Performance Test Data 28 Table 6: Hogged Fuel Boiler Particulate Matter Performance Test Data 29 Table 7: Hogged Fuel Boiler -- Boiler MACT Initial Performance Test (January 2016) 32 Table 8: Detroit Engine Performance Test 34 Table 9: Plant Number 53-071-00003 Emission Unit Control Devices 43 Table 10: Periodic Monitoring Evaluation 47 Table 11: Lime Kiln Sulfur Dioxide Surrogate Parameters Performance Tests 61 Table 12: Lime Kiln Particulate Surrogate Parameters Performance Tests 64 Table 13: No 2 Smelt Dissolving Tank Particulate Surrogate Parameters Performance Tests .... 67 Table 14: No.3 Smelt Dissolving Tank Particulate Surrogate Parameters Performance Tests .... 70 Table 15: Hogged Fuel Boiler Particulate Surrogate Parameters Performance Tests 71 Table 16: Chlorine Dioxide Generation Unit Surrogate Parameters Performance Tests 78 Table 17: Insignificant Emission Units 82 Figures Figure 1 RF #3 Opacity vs PM Graph 25 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00004 SC_EVERSPLIT0002148 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 4 of 123 LIST OF ABBREVIATIONS AND ACRONYMS Btu CAA CAM CEMS CFR CO COMS CO2 dscf Ecology EPA EU gr/dscf HAP hr IEU lb MACT mm NESHAP NOC NOx NSPS O2 PM PM10 ppmdv PSD PTE SCR SO2 SOx tpy VOC WAC British thermal units Clean Air Act [42 U.S.C. section 7401 et seq.] Compliance assurance monitoring Continuous emission monitoring system Code of Federal Regulations Carbon monoxide Continuous opacity monitoring system Carbon dioxide Dry standard cubic feet Washington State Department of Ecology United Stated Environmental Protection Agency Emission unit Grains/dry standard cubic foot (7,000 grains = 1 pound) Hazardous air pollutant Hour Insignificant emission unit Pound Maximum Achievable Control Technology One million National Emission Standards for Hazardous Air Pollutants (40 CFR Parts 61 and 63) Notice of Construction Oxides of nitrogen New source performance standards Oxygen Particulate matter Particulate matter with an aerodynamic diameter equal to 10 microns or less Parts per million, on a dry volume basis Prevention of significant deterioration Potential to emit Selective catalytic reduction Sulfur dioxide Oxides of sulfur Tons per year Volatile organic compound Washington Administrative Code 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00005 SC_EVERSPLIT0002149 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 5 of 123 INTRODUCTION This document, the statement of basis or support document summarizes the legal and factual basis for the permit conditions in the air quality operating permit issued by the Washington State Department of Ecology (Ecology) to the source. Unlike the air quality operating permit, this document is not legally enforceable. This statement of basis summarizes the emitting processes at the facility, air emissions, permitting and compliance history, the statutory or regulatory provisions that relate to the facility, and the steps taken to provide opportunities for public review of the permit. The Permittee is obligated to follow the terms of the permit. Any errors or omissions in the summaries provided here do not excuse the Permittee from the requirements of the permit. The format and content of this support document has changed over time to reflect the evolving thought about what constitutes an effective support document. EPA audited Ecology's Title V Permitting in 2006 and 2014. As a result of these audits, Ecology is currently developing a revamped support document format. The support document for this particular permit renewal effort follows the draft format for the statement of basis outline available at the time of this permit renewal effort. Very little has been added or changed in permit content from the previous permit iteration. The history of permit changes and what changes have been made during this renewal effort are explained beginning on page 77 of this Support Document. PERMIT AUTHORITY Title V of the Federal Clean Air Act Amendments required all states to develop a renewable operating permit program for industrial and commercial sources of air pollution. The Washington State Clean Air Act (RCW 70.94 Revised Code of Washington) was amended in 1991 and 1993 to provide Ecology and Local Air Agencies with the necessary authority to implement a state-wide operating permit program. The law requires all sources emitting one hundred tons or more per year of a criteria pollutant, ten tons of a hazardous air pollutant, or twenty-five tons in the cumulative of hazardous air pollutants, to obtain an operating permit. Criteria pollutants include sulfur dioxide, nitrogen oxides, particulate matter, carbon monoxide, and volatile organic compounds. Table 1 below summarizes the 2013 mill emissions for criteria pollutants. Chapter 173-401 of the Washington Administrative Code (WAC), which specified the requirements of Washington State's Operating Permit Regulation became effective November 4, 1993. United States Environmental Protection Agency (EPA) granted Washington's program interim approval December 9, 1994. Final approval of Washington's program was granted on August 13, 2001. The current version of the regulation was filed on September 16, 2002. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00006 SC_EVERSPLIT0002150 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 6 of 123 Table 1: Summary of Actual to Potential Emissions (tpy) Criteria Permitted Emission Allowance Pollutant (tpy) PM 663 CO 2,889 NOx 2,011 SO2 3,688 Lead 0.5 Ozone HAP's as 1,395 VOC's* *HAP's -- Major Annual Actual 2013 Emissions (tpy) 153 1,345 883 554 0.259 313 Table 2: Facility Information Company History and Information: Ownership: Responsible Official: Contacts: Location: Attainment Classification: Basis for Title V Applicability: Boise White Paper L.L.C. (2008-present) formerly Boise Cascade L.L.C. (2004-2008) formerly Boise Cascade Corporation (c. 1958-2004) Boise White Paper L.L.C. (a subsidiary of) Packaging Corporation of America 1955 West Field Court Lake Forest, IL 60045 Bert Brown -- Mill Manager PO Box 138 Wallula, WA 99363 Paul Butkus -- Environmental Manager PO Box 138 Wallula, WA 99363 (509) 545-3241 31831 West Highway 12 Wallula, WA 99363 The Wallula Area is "in attainment" for all regulated pollutants. The area was redesignated as "in attainment" for PM10 by way of direct final rule FR Volume 70, No. 65, 8/26/2005, Pages 50212-50214. The facility, by definition, is a major source. Source Industrial Classification -- 2621 NCAICS - 322121 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00007 SC_EVERSPLIT0002151 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 7 of 123 SOURCE DESCRIPTION General Facility The Boise White Paper LLC (Boise Wallula) Mill operates an integrated bleached Kraft pulp and paper mill, neutral sulfite semi-chemical (NSSC) pulping, corrugating medium and box plant. Primary products include but are not limited to market pulp, corrugating medium, fine white paper, label and release paper products and finished containerboard boxes. A schematic of the facility layout which identifies and locates the major emission units addressed in the AOP is included as Appendix C. Chip Handling The chip handling area includes unloading, transfer systems, chip storage piles, screening of wood chips, and ancillary support facilities such as maintenance shops, control rooms, and testing facilities. For this area of the facility, incoming chips are unloaded and allocated to the different pulping process chip storage piles. Trucks and rail cars unload wood chips through the appropriate chip dumper. Drag chains then convey the chips from the chip dumpers onto a conveyor belt system where flight conveyors and blow lines transfer the chips to the screening process. The screening process separates the chips by size into five categories: chips, pin chips, sawdust, gross overs, and knots and fines. The Kraft chips are sent to the Kamyr process line. The sawdust is sent to the No. 1 M&D sawdust pile, which feeds the No. 1 M&D process line. The knots and pins are sent to the neutral sulfite semi-chemical process (NSSC) chip pile, which feeds the NSSC process line. The gross-overs are chips that are unusable by the NSSC, M&D, and Kamyr process lines and subsequently are combusted in the hog fuel boiler. Pin chips can be feed independently to all the various digesters. The cottonwood chips are handled and stored separately for use in the No. 2 M&D digester. A portable chip dumper handles the 100% sawdust trucks and unloads the material to the No. 1 M&D sawdust and NSSC Digester storage piles. Incoming chips may also be separated, screened, and stored by wood species. Dependent on species, and the grades being produced in the facility, these segregated chips may go to any of the four digesters. Neutral Sulfite Semi-chemical Pulping The NSSC system produces pulp that is used to manufacture corrugated medium for the No. 2 Paper Machine (W2). Three systems make up the NSSC production facility. The NSSC digester, the pulping chemical make-up system, and the No. 2 paper machine. The pulping chemical called pink liquor, can either be purchased or produced for use in the NSSC digester. The on-site production process for pink liquor involves burning sulfur using ambient air in a special sulfur burner to produce sulfur dioxide. The sulfur dioxide is cooled using water in a direct contact cooling tower and then reacted with a caustic soda solution to produce pink liquor in a counter current absorption tower. Purchased pink liquor comes in bulk powder form and is mixed with water to a set concentration. Purchased pink liquor is currently the preferred method of making pink liquor for the NSSC digester. The pink liquor is stored in a bulk storage tank prior to use in the NSSC digester. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00008 SC_EVERSPLIT0002152 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 8 of 123 In the NSSC pulping process, chips for the NSSC are washed and steamed before entering the NSSC digester impregnation vessel. In the NSSC impregnation vessel, chips are combined with pink liquor and recycled brown liquor. Brown liquor comes from the pulp washing phase of the pulp manufacturing process. Following the NSSC impregnation vessel, the chips and pulping liquors in the digester are cooked at elevated temperature and pressure to remove lignin from the chips. From the digester process, the cooked chips pass through a defibrator to separate the pulp fibers. The pulp and liquor (dissolved wood lignin) are then separated in the No. 1 and No. 2 DKP presses. The brown liquor is pumped to the recovery process where it is mixed with weak black liquor, evaporated to a higher solids content, and combusted in the recovery furnaces. The pulp is distributed between No. 1 and No. 2 Raffinators, which refine the fibers. The pulp is then stored in high-density storage tanks for use in the production of corrugated medium on the No. 2 Paper Machine. Pulping, Washing, and Bleaching The pulping, washing, and bleaching systems produce bleached feedstock for the No. 1 and No. 3 paper machines. The Kamyr Digester, No. 1, and No. 2 M&D digester process lines produce and wash the pulp using similar methods. The type, size and potential species of wood chips may be different for each of the feed stocks going to the digesters. In the pulping process lines, chips are steamed and fed into impregnation vessels. In the impregnation vessels, white liquor (a solution of caustic, sodium carbonate, and sodium sulfide) from the white liquor multi-purpose tank is absorbed by the chips. This mix is then fed to the three separate digesters. Each digester has its own impregnation vessel. The digesters cook the chips and liquor mixture, then send the resulting pulp to their respective vacuum drum washer lines. These counter current washers extract the liquor and wash the pulp. The extracted liquid (dissolved wood lignin) called black liquor is pumped to the weak liquor storage tank. The washed pulp is screened in the screening system and dewatered on the deckers. After the deckers, the pulp is sent to high-density storage and eventually bleached in the bleach plant. In the bleach plant, the pulp is bleached in stages using hydrogen peroxide, oxygen, and chlorine dioxide and/or other chemicals in a series of towers and washers. The white liquor used as the pulping chemical is prepared on site in a closed loop system. Dissolved salts from the burning of the black liquor in the Recovery Boilers create a solution of sodium carbonate and sodium sulfide called green liquor. The green liquor is clarified and reacted with lime (calcium oxide) to produce the white liquor. The by-product of the reaction is calcium carbonate which is heated or burned in a lime kiln producing the lime to go back and react with the green to produce white liquor. This is explained in greater detail in the Power and Recovery description. Bleaching Chemical Production The chlorine dioxide generation process produces chlorine dioxide, a bleaching agent used in the pulp bleaching process. Sulfuric acid, methanol, and sodium chlorate solution react in the chlorine dioxide generator to create chlorine dioxide. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00009 SC_EVERSPLIT0002153 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 9 of 123 The chlorine dioxide is cooled and stored for use at the bleach plant. The salt cake byproduct from the chlorine dioxide generator is filtered and used as chemical makeup at the weak black liquor tank. Chemical Recovery and Steam Generation The power and recovery systems recover the chemicals used in the pulping process and produce energy in the form of steam for the Mill. The steam production system is composed of two recovery furnaces, two power boilers, and a hog fuel boiler. The recovery furnaces fire black liquor to produce steam and to recover pulping chemicals. Natural gas and fuel oil are fired in the recovery boilers as supplemental fuels. The power boilers fire natural gas or fuel oil to produce steam. The hog fuel boiler fires either natural gas, wood waste, and other supplemental/alternate fuels, or a combination thereof to produce steam. The chemical recovery process is responsible for recovering chemicals needed for the kraft pulping process. The recovery process starts by evaporating water from the weak black liquor obtained from the brownstock washers and the NSSC brown liquor filtrate tanks. The weak black liquor is pumped into three sets of evaporators. The evaporators consist of six stages or effects, which concentrate the liquor to approximately 50% black liquor solids. The liquor is further concentrated to approximately 63% black liquor solids in the concentrators. To replace sulfur and sodium that has been lost throughout the recovery loop, salt cake, a by-product from the production of chlorine dioxide, is added to the weak black liquor tank. The black liquor and salt cake solution is then combusted in the No. 2 and No. 3 Recovery Furnaces. Organics from the solution are oxidized producing various combustion gases and heat. Inorganics from the solution are collected at the bottom of the furnace as a molten mass (smelt) and fall into the No. 2 and No. 3 smelt dissolving tanks. In the smelt dissolving tanks, smelt is mixed with weak wash from the recausticizing process to produce green liquor. Green liquor is clarified and is then reacted with calcium oxide in the slaker to produce white liquor. To ensure a complete reaction of the green liquor and the calcium oxide, the solution is agitated in a series of mixing tanks called causticizers. The suspended solids remaining in the white liquor are separated from the liquor in a clarifier. The resulting clarified white liquor is stored for reuse in the pulp Mill. The separated solids or lime mud (calcium carbonate) is sent to a lime mud washer. Lime mud is mixed with hot condensates in the mud washer, producing weak wash and washed mud. Weak wash is stored and later used in the smelt dissolving tanks to produce green liquor. The washed mud is filtered to remove water and then disassociated into calcium oxide and carbon dioxide in the lime kiln. The calcium oxide (lime) is then stored in silos for use in the slaker, the first reaction vessel for initially starting to make the white liquor. Wastewater Treatment The wastewater treatment plant processes the effluent from the Mill before being discharged to an outfall in the Columbia River. The wastewater enters the primary clarifier settling the suspended solids and high-density material from the wastewater. The primary effluent is 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00010 SC_EVERSPLIT0002154 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 10 of 123 pumped to an aerated lagoon that biodegrades the waste materials before entering a quiescent zone. In the quiescent zone a portion of the biodegradation products and other solids settle to the bottom, and the clarified secondary effluent passing out of the quiescent zone is pumped to the outfall diffuser. Boise Trucking Boise Wallula owns a transportation service that is responsible for delivering wood chips to and distributing products from the Mill. A maintenance terminal is located across Highway 12 from the Mill. The terminal is responsible for maintenance, dispatching, and fueling of the trucks. De-ink Facility (Ponderosa) The deink facility remains under the control and ownership of the Mill but is shut down indefinitely. An office area of this facility has been modified into a new Technical Development Center for the Mill. This new lab focuses on new product development and testing. Container Plant The container plant uses corrugated medium to produce container boxes. This is accomplished by feeding two sheets of linerboard and one sheet of fluted corrugated medium through a corrugator. The corrugator forms the fluted or wavy middle sheet of boxboard and then glues the three sheets together to produce boxboard blanks. The boxboard is later cut to various sizes and shapes to create packaging boxes. Fiber Farm The facility previously owned an 850-acre cottonwood fiber farm adjacent to the Mill property but separated from the Mill property by State Highway 12 and the Union Pacific Railroad right-of-way. The farm had previously been included in the Mill's emission inventory, but is no longer included due to the sale on 10/3/2007. The farm provided cottonwood chips for the production of kraft hardwood pulp in the Mill's No. 2 M&D digester pulping system. Landfill and Composting The facility owns and operates a 50-acre limited purpose landfill, which is adjacent to the Mill. The landfill is separated from the Mill by State Highway 12 and the Burlington Northern Railroad right-of-way. The Mill's landfill incorporates a composting operation to convert the primary clarifier solids into compost. The waste materials in the landfill are being considered for various beneficial uses on a continuous and ongoing basis. The landfill operates under a dust control plan, which requires frequent watering of the unpaved roads during the dry months of the year or on an as needed basis. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00011 SC_EVERSPLIT0002155 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 11 of 123 OVERVIEW OF SIGNIFICANT REGULATORY CHANGES AND SIGNIFICANT COMPLIANCE DEMONSTRATION PROCEDURES Determination of Compliance Compliance determinations made in this Permit signify that Boise Wallula considers the facility currently in compliance with the stated applicable requirement and that it anticipates it will, in the future, remain in compliance with the applicable requirement. Due to unavoidable conditions, including startups, shutdowns, and malfunctions, Boise Wallula has experienced measured deviations from certain applicable requirements cited in this application. Boise Wallula has reported these deviations as required. Boise Wallula does not consider these deviations indicative of noncompliance, and where applicable, considers the sources in compliance with the applicable requirement. Compliance with numerical limits is evaluated by comparing actual emissions, rounded to the same number of significant digits as the numeric limit specified by rule, to the numeric limit itself. Emissions data forms the underlying basis for determinations of compliance with the applicable requirements. There is ongoing evaluation of the most recent emissions data available to evaluate compliance. Specific Areas of Compliance The following section provides discussion and details concerning specific process areas of the facility, key projects, and compliance discussion for key regulatory requirements. Greenhouse Gas Reporting, Boiler MACT, and RICE MACT are new regulations implemented from June 1, 2009 to the time of the permit application due date of January 1, 2015. Subpart S was modified also in 2012. PM10 On September 3, 2002, EPA made a "Finding of Attainment" that the Wallula Area had attained compliance with the PMio National Ambient Air Quality Standards by December 31, 2001, as required by the Clean Air Act. Ecology submitted to EPA an attainment plan on November 30, 2004 and a maintenance plan on March 29, 2005. EPA approved the plans on May 2, 2005 (70 FR 22597) and August 26, 2005 (70 FR 50212), respectively. Compliance Assurance Monitoring (CAM) The U.S. Environmental Protection Agency (EPA) promulgated the CAM rule with an effective date of November 21, 1995, to satisfy Title V and Title VII monitoring requirements of the Clean Air Act. The CAM rule applies to major sources required to obtain Title V operating permits. Specifically, the CAM rule applies to pollutant-specific emission units that are subject to an emission limitation or standard where a control device is used to achieve compliance with an applicable emission limitation or standard. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00012 SC_EVERSPLIT0002156 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 12 of 123 The CAM rule requires facilities to monitor compliance indicators for emission units to provide reasonable assurance for compliance with regulatory emission limitations. When monitoring indicates the occurrence of a parameter excursion or exceedance, the facility is required to take corrective action to restore the monitoring parameter to the parameter value range established as part of a source compliance or performance test. The facility is also required to document and report corrective actions, maintain monitoring records, and provide an annual certification of compliance to the delegated authority that administers the Title V operating permit program. Plan Content Pursuant to 40 CFR 64, EPA requires the following elements in a facility's CAM Plan: Applicability determination for pollutant-specific emission units Monitoring plan, including basis for selection of monitoring parameters and establishment of parameter values and averaging periods, and performance criteria for monitoring systems CAM reporting and recordkeeping requirements Ecology reviewed Boise Wallula Mill's CAM evaluation submitted as part of the 2014 permit renewal application. Emission limitations were reviewed to identify whether the CAM rule applied to individual emission units on a pollutant-by-pollutant basis. In performing this applicability determination, the Mill compiled a list of each regulated pollutant for each emission unit and evaluated each pollutant based on the following CAM criteria: 1. Is the emission unit subject to an emission limitation or standard for the applicable regulated air pollutant (or a surrogate thereof) other than an emission limitation or standard that is exempt under 40 CFR 64.2(b)(1)? 2. Does the emission unit use a control device to achieve compliance with the emission limitation or standard? 3. Does the emission unit have potential pre-control emissions of the applicable regulated air pollutant that are equal to or greater than 100 percent of the amount, in tons per year, required for the emission unit to be classified as a major source? For an emission unit to be subject to a CAM requirement for a given pollutant, the answer to all three of the above questions must be affirmative. A negative finding for any one of the three criteria alleviates the Wallula Mill from the requirement to propose a compliance assurance monitoring plan for a specific emission unit for a specific regulated pollutant. As specified in Criteria 1 above, the following CAM Rule exemption promulgated in 40 CFR 64.2(b)(1) was considered: 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00013 SC_EVERSPLIT0002157 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 13 of 123 The requirements of Part 64 shall not apply to emission limitations or standards proposed by EPA after November 15, 1990 pursuant to section 111 or 112 of the Clean Air Act (40 CFR 64.2(b)(1)(i)); and The requirements of Part 64 shall not apply to emission limitations or standards for which a Part 70 or 71 permit specifies a continuous compliance determination method as defined in 40 CFR 64.1 (40 CFR 64.2(b)(1)(vi)). The first exemption applies to emission limitations for air pollutants from New Source Performance Standards (NSPS) or National Emission Standards for Hazardous Air Pollutants (NESHAPs) proposed after November 15, 1990. The Wallula Mill operates several emission units subject to 40 CFR 63 Subpart S, 40 CFR 63 Subpart MM, and 40 CFR 63 Subpart DDDDD. As a result, the monitoring requirements prescribed in the applicable standard proposed by EPA after November 15, 1990 apply rather than the requirements of 40 CFR Part 64. A Title V Permit must include all applicable requirements even if redundant. Over time, several different requirements may become applicable for the same pollutant such as the different PM limits applicable for the No. 2 Recovery Furnace presented in Conditions A.1.a and A.1.b. Generally, the limit that is presented first, such as in Condition A.1.a, is more restrictive than the subsequent limit(s), such as Condition A.1.b. Rather than establish separate monitoring for each of the limits, the draft permit is written such that compliance with Condition A.1.b is assured by compliance with Condition A.1.a. This approach is implemented throughout the permit in similar situations. Ecology has included Tables 3 and 4 below which present the reasoning through the CAM applicability determination. The first column in Table 3 specifies the emission unit, the control device(s), and which pollutant(s) are controlled by the device. The second column includes the pollutants that have limits in the permit for the emission unit. The next three columns evaluate the three criteria specified above. The sixth column indicates if the limit is a state only requirement. The last column then evaluates whether the CAM requirements could apply to that pollutant specific emission unit. If the answer is yes in the final column, the pollutant is further evaluated in Table 4 to determine if the previously discussed exemptions apply to the applicable limit(s). 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00014 SC_EVERSPLIT0002158 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 14 of 123 Table 3: CAM Applicability Emission Unit and Pollutant Specific Emission Control Device(s) No.2 Recovery Furnace (High efficiency ESP for PM Control) No. 3 Recovery Furnace (High Efficiency ESP for PM Control) Lime Kiln (Wet scrubber for PM control) Addition of caustic for SO2 control No.2 Smelt Dissolving Tank (Medium efficiency wet scrubber for PM control) Regulated Pollutant PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS Subject to applicable emission limit or standard? Yes Yes Yes No No No Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No No No Yes Yes Yes No No No No No No.3 Smelt PM Yes Dissolving HAPs Yes Tank SO2 No (Medium NOx No efficiency wet CO No VOC No Control device to achieve compliance \y ith limit? Yes Yes No No Yes Yes No No No No No Yes Yes Yes No Yes Yes - Yes Yes - Precontrol emissions major? Federally_ Enforceable? Does CAM apply? If yes, see Table 2 Yes Yes Yes Yes Yes Yes - - No - - No - - No - - No - - No Yes Yes Yes Yes Yes Yes - - No Yes Yes No Yes Yes No Yes Yes No - - No Yes Yes Yes Yes Yes Yes No 1 - No - - No - - No - - No - - No Yes Yes Yes Yes Yes Yes - - No - - No - - No - - No - - No Yes Yes Yes Yes Yes Yes - - No - - No - - No - - No 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00015 SC_EVERSPLIT0002159 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 15 of 123 Emission Unit and Pollutant Specific Emission Control Device(s) scrubber for PM control) Hog Fuel Boiler (Multicyclone /demister followed by a wet ESP for PM control) No. 1 Power Boiler (No Emissions Control) No. 2 Power Boiler (No Emissions Control) Chlorine Dioxide Generator (Wet scrubber using water and white liquor for Cl and C1O2 control) No. 1 M&D Digester Regulated Pollutant TRS PM SO2 NOx CO VOC TRS HC1 Hg PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS Chlorine CLO2 PM HAPs SO2 Subject to applicable emission limit or standard? No Yes Yes Yes Yes No No Yes Yes Yes No Yes No Yes No No Yes No Yes No Yes No No No No No No No No No Yes Yes No Yes No Control device to achieve compliance with limit? - Yes No No No No No No No No No No No Yes Yes No - Precontrol emissions major? Federally Enforceable? Does CAM apply? If yes, see Table 2 - - No Yes Yes Yes - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No Yes No No Yes No No - - No - - No - - No 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00016 SC_EVERSPLIT0002160 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 16 of 123 Emission Unit and Pollutant Specific Emission Control Device(s) No. 2 M&D Digester Kamyr Digester No. 1 MultipleEffect Evaporator System No.2 MultipleEffect Evaporator System No.3 MultipleEffect Regulated Pollutant Subject to applicable emission limit or standard? NOx No CO No VOC No TRS Yes PM No HAPs Yes SO2 No NOx No CO No VOC No TRS Yes PM No HAPs Yes SO2 No NOx No CO No VOC No TRS Yes PM No HAPs Yes SO2 No NOx No CO No VOC No TRS Yes PM No HAPs Yes SO2 No NOx No CO No VOC No TRS Yes PM No HAPs Yes SO2 No Control device to achieve compliance with limit? No No No No No No - No No No No - Precontrol emissions major? Federally Enforceable? Does CAM apply? If yes, see Table 2 - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00017 SC_EVERSPLIT0002161 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 17 of 123 Emission Unit and Pollutant Specific Emission Control Device(s) Evaporator System Concentrator System Bleaching System (Wet scrubber using water and white liquor for Cl and C1O2 control) NSSC Digester Foul Condensate Tank) A-Row Pulp Washing System Regulated Pollutant NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS Chlorine PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 Subject to applicable emission limit or standard? No No No Yes No Yes No No No No Yes No No No No No No No No No Yes No No No No No No Yes No No No No No No Yes No Control device to achieve compliance with limit? No No No No No No - Precontrol emissions major? Federally Enforceable? Does CAM apply? If yes, see Table 2 - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00018 SC_EVERSPLIT0002162 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 18 of 123 Emission Unit and Pollutant Specific Emission Control Device(s) B-Row Pulp Washing System Cyclone Box Clipping Collection System (Baghouse for PM) Lime Kiln (Hot End) Starch SiloContainer Plant Starch SiloPaper Mill Regulated Pollutant NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 NOx CO VOC TRS PM HAPs SO2 NOx Subject to applicable emission limit or standard? No No No No No Yes No No No No No Yes No No No No No No No No No No No No No Yes No No No No No No Yes No No No Control device to achieve compliance with limit? No Yes No No - Precontrol emissions major? Federally Enforceable? Does CAM apply? If yes, see Table 2 - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No Yes Yes Yes - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No - - No 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00019 SC_EVERSPLIT0002163 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 19 of 123 Emission Regulated Subject to Control Pre- Federally Unit and Pollutant applicable device to control Enforceable? Pollutant emission achieve emissions Specific limit or compliance major? Emission standard? with limit? Control Device(s) CO No - - - VOC No - - - TRS No - - - NSSC Liquor PM No - - - Plant HAPs No - - - SO2 Yes No - - NOx No - - - CO No - - - VOC No - - - TRS No - - - 1. Justification provided in CAM Applicability/Monitoring Section below Does CAM apply? If yes, see Table 2 No No No No No No No No No No As discussed above, there are multiple exemptions to the CAM requirements specified by 40 CFR Part 64, including two that are applicable to this facility. The two applicable exemptions are: 1) emission limitations or standards proposed by EPA after November 15, 1990 pursuant to section 111 or 112 of the Clean Air Act, and 2) emission limits or standards for which a part 70 or 71 permit specifies a continuous compliance determination method. Table 4 below evaluates each emission limit for the regulated pollutants identified in Table 3 above to determine if the limit is exempt from the CAM requirements. Additional information discussing the applicable monitoring is provided in the paragraphs below the table. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00020 SC_EVERSPLIT0002164 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 20 of 123 Table 4: Exemption from CAM Evaluation Emission Unit Regulated Permit Pollutant Condition Permit Limit Basis No. 2 Recovery Furnace PM HAPs PM PM PM PM No. 3 Recovery Furnace PM (opacity standard) PM (opacity standard) PM PM HAPs Lime Kiln PM PM (opacity standard) PM (opacity standard) HAPs PM A.1.a A.1.a A.1.b A.2.a A.2.b A.2.c A.3.a A.3.b B.1.a. B.1.b. B.1.b B.1.c. B.2.a B.2.b C.1.a C.1.b PSD Permit CFR 63.862(a)(1)(i), 40 CFR 60.282(a)(1)(i) WAC PSD Permit Order DE 02AQ91S- 5019 Order DE 02AQ91S- 5019 NSPS Subpart BB NSPS Subpart Db WAC CFR 60.282(a)(1)(i) CFR 63.862(a)(1)(i) WAC NSPS Subpart BB NSPS Subpart Db CFR 63.862(a)(1)(i) CFR 60.282(a)(3) Emission Limit or Standard proposed by EPA after Nov 15, 1990? No Yes No No No No No Yes No No Yes No No Yes Yes No Permit specifies a continuous compliance determination method? No No No No No No Yes No No No No No Yes No No No Limit exempt from CAM? No Yes No No No No Yes Yes No No Yes No Yes Yes Yes No 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00021 SC_EVERSPLIT0002165 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 21 of 123 Emission Unit Regulated Permit Pollutant Condition No.2 Smelt Dissolving Tank PM PM PM PM (opacity standard) PM HAPs PM PM No.3 Smelt Dissolving Tank Hog Fuel Boiler PM (opacity standard) HAPs PM PM (opacity standard) PM PM PM PM PM (opacity standard) PM C.1.c C.1.d C.1.e C.2.a D.1.a D.1.a D.1.b D.2 D.3 E.1.a E.1.b E.2 F.1 F.2 F.3 F.4 F.5 F.14 Permit Limit Basis PSD Permit WAC PSD Permit WAC 40 CFR 60.282(a)(2) CFR 63.862(a)(1)(i) WAC Order DE 96- AQI078 WAC CFR 63.862(a)(1)(i WAC WAC Order DE 02AQIS-3588 WAC PSD Permit Order DE 02AQIS-3588 WAC CFR 63.7500(a)(1) Emission Limit or Standard proposed by EPA after Nov 15, 1990? No No No No Permit specifies a continuous compliance determination method? No No No No Limit exempt from CAM? No No No No No No No Yes No Yes No No No No No No No No No Yes No Yes No No No No No No No No No No No No No No No No No No No No No Yes No Yes Cyclone PM Box L.1 Order DE No 95AQI-84 No No 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00022 SC_EVERSPLIT0002166 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 22 of 123 Emission Unit Regulated Permit Permit Limit Pollutant Condition Basis Clipping PM L.2 Collection (opacity System standard) WAC Emission Limit or Standard proposed by EPA after Nov 15, 1990? No Permit specifies a continuous compliance determination method? No Limit exempt from CAM? No 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00023 SC_EVERSPLIT0002167 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 23 of 123 CAM Applicability/Monitoring Details As shown in Table 3 above, there are seven pollutant specific emission units (PSEUs) that are subject to CAM. For each of these PSEUs, 40 CFR 64.6 requires that the permit specify the following monitoring requirements: 1) The approved monitoring approach (including indicators to be monitored, the means or device for measuring the indicator, and the performance requirements for the monitoring device), 2) How an exceedance or excursion is defined for response and reporting purposes, 3) The obligation to conduct the required monitoring, and 4) Minimum data availability for valid data collection, if appropriate. The following sections discuss the specific information included in the permit for each of the PSEU's to meet the aforementioned monitoring requirements. Each of the PSEU's use certain parameters to measure the performance of the control device. The use of such parameters as a measure of control device performance is consistent with both US. EPA's Region 10's interpretation of the applicability of periodic monitoring and with the intent of the Compliance Assurance Monitoring Rule (40 CFR Part 64), that a reasonable assurance of compliance can be demonstrated through a control device performance indicator. With respect to the rolling average annual or other long term limits, the monitoring ensures that the pollution control devices are operated in a manner that ensures that the source tests used to calculate the emissions are representative of the actual emissions. For each parameter, the permit specifies the operating condition or conditions that will trigger the requirement for corrective action to restore operation of the control device to its normal or usual manner of operation as expeditiously as practicable. If corrective action is not taken, it may be considered a violation of the underlying requirements. In addition, if Ecology determines that acceptable corrective actions were not implemented, development of a quality improvement plan may be required. The following sections also include additional information for any PSEU that is not subject to CAM due to fact that the pre-control emissions for the PSEU do not exceed the major source thresholds. No. 2 Recovery Boiler -- Particulate/Opacity Boise Wallula uses an electrostatic precipitator to control particulate emissions from the No. 2 Recovery Boiler. CAM has been addressed by specifying continuous opacity monitoring. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00024 SC_EVERSPLIT0002168 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 24 of 123 Per AOP condition A.7, a COMS is operated as a performance indicator to show continuous operation of the pollution control device. The COMS system will at all times be operated in conformance with 40 CFR Part 60 (July 1, 1992), App. B and App. F, Per Spec. 1. The selected indicator range (average of ten consecutive 6 minute averages result in a measurement greater than 20% opacity) is the standard selected by EPA for continuous compliance assurance monitoring of recovery furnaces with an ESP in order to satisfy the Pulp & Paper Combustion Unit MACT standards [40 CFR 63.864(k)(1)(i)] that came into effect in 2004. This standard is the strictest particulate limit for this unit and will indicate compliance for the other limits as well. No. 3 Recovery Furnace -- Particulate/Opacity Boise Wallula uses an electrostatic precipitator to control particulate emissions from the No. 3 Recovery Furnace. CAM has been addressed by specifying a continuous opacity monitoring system. Per AOP condition B.3, a COMS is operated as a performance indicator to show continuous operation of the pollution control device. The COMS system will at all times be operated in conformance with 40 CFR Part 60 (July 1, 1992), App. B and App. F, Per Spec. 1. The selected indicator range (average of ten consecutive 6 minute averages result in a measurement greater than 20% opacity) is the standard selected by EPA for continuous compliance assurance monitoring of recovery furnaces with an ESP in order to satisfy the Pulp & Paper Combustion Unit MACT standards [40 CFR 63.864(k)(1)(i)] that came into effect in 2004. The graph below reflects the relationship between opacity and particulate emissions from No. 3 Recovery Furnace (RF #3) over the 1993 through 2016 timeframe. As demonstrated by the graph, the indicator range will assure compliance with the most restrictive PM limit applicable to RF #3 is 0.027 gr/dscf, as well as the less restrictive limits. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00025 SC_EVERSPLIT0002169 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 25 of 123 Figure 1 RF #3 Opacity vs PM Graph Lime Kiln -- Particulate/Opacity Boise Wallula uses a wet scrubber to control particulate emissions from the Lime Kiln. CAM has been addressed for applicable limits by referencing CAM exempt monitoring required for the most restrictive PM limit, which is continuous monitoring of wet scrubber pressure drop and recirculation flow rate (AOP Condition C.7.a). As the monitoring addresses the strictest particulate limit for this unit, it is assumed that it will indicate compliance for the other particulate limits as well. Flow rate and pressure drop across the scrubber are indicators of the performance of the scrubber in minimizing particulate emissions. By design, the unit is in compliance with the particulate and opacity standards when adequate flow and pressure drop are maintained across the scrubber unit. The surrogate setpoints, as indicators of control device performance, are based on historical evidence, source testing, and good engineering judgment. The permit requires that Boise Wallula continuously monitor pressure drop and the scrubber recirculation rate. Corrective action is required whenever the three-hour block average of either parameter is outside the range determined by the 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00026 SC_EVERSPLIT0002170 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 26 of 123 initial performance test or any subsequent performance test. The most recently established range is: Maintain three hour average of scrubber pressure drop >23 H2O when mud flow >200 gpm and >21.3 H2O when mud flow 200 gpm (based on performance test results from June 26-28, 2012) Ecology does not believe opacity limit exceedances are an issue based on years of on-site inspections where opacity as a detached plume has not been noticed to any significant degree. However, 40 CFR Part 64 requires that the facility establish an appropriate range(s) or designated condition(s) such that operation within the ranges provides a reasonable assurance of ongoing compliance with an emission limit. The lime kiln stack is a wet stack so a COM is not appropriate. As such, the Permittee will be required to conduct an EPA Method 9 evaluation within 180 days of permit renewal to verify that compliance with the opacity limit will be reasonably assured at the proposed surrogate set points. Lime Kiln -- Sulfur Dioxide Boise Wallula adds caustic to the wet scrubber medium to control sulfur dioxide from the Lime Kiln. CAM does not apply since the lime kiln pre-control emissions of SO2 (70 TPY) is less than the major threshold (100 TPY). The pre-control SO2 emissions can be calculated using AP-42 emission factor (0.3 lb/ADTP)* for uncontrolled SO2 emissions from lime kilns and the mill's potential production rate (1286 ADTP/day): pre-control SO2 (TPY) = 1286 ADTP/day x 0.3 lb/ADTP x 365 days/yr x 1 ton/2000 lbs pre-control SO2 (TPY) = 70 TPY * AP-42, Table 10.2-1 (Sept. 1990)for uncontrolled emissionsfrom lime kiln. Note that this emissionfactor has a rating of "A". No. 2 Smelt Dissolving Tank -- Particulate/Opacity Boise Wallula uses a wet scrubber to control particulate emissions from the No. 2 Smelt Dissolving Tank. CAM has been addressed for applicable limits by referencing CAM exempt monitoring required for the most restrictive PM limit, which is continuous monitoring of wet scrubber pressure drop and recirculation flow rate (AOP Condition D.5.a). As the monitoring addresses the strictest particulate limit for this unit, it is assumed that it will indicate compliance for the other limits as well. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00027 SC_EVERSPLIT0002171 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 27 of 123 Flow rate and pressure drop across the scrubber are indicators of the performance of the scrubber in minimizing particulate emissions. By design, the unit is in compliance with the particulate and opacity standards when adequate flow and pressure drop are maintained across the scrubber unit. The surrogate setpoints, as indicators of control device performance, are based on historical evidence, source testing, and good engineering judgment. The permit requires that Boise Wallula continuously monitor pressure drop and the scrubber recirculation rate. Corrective action is required whenever the three-hour block average of either parameter is outside the range determined by the initial performance test or any subsequent performance test. The most recently established ranges are summarized below. The test results are summarized on page 66 of this Support Document: Maintain a three hour average scrubber recirculation rate equal to or greater than 60 gpm, based on initial performance test results of 7/2/2004, and Maintain a three hour average pressure drop equal to or greater than 0.7 inches H2O, based on initial performance test results of 7/2/2004. Ecology does not believe opacity limit exceedances are an issue based on years of on-site inspections where opacity as a detached plume has not been noticed to any significant degree. However, 40 CFR Part 64 requires that the facility establish an appropriate range(s) or designated condition(s) such that operation within the ranges provides a reasonable assurance of ongoing compliance with an emission limit. The #2 smelt tank stack is a wet stack so an opacity COM is not appropriate. As such, the Permittee will be required to conduct an EPA Method 9 evaluation within 180 days of permit renewal and after the #2 smelt vent comes back into use to verify that compliance with the opacity limit will be reasonably assured at the proposed surrogate set points. No. 3 Smelt Dissolving Tank -- Particulate/Opacity Boise Wallula uses a wet scrubber to control particulate emissions from the No. 3 Smelt Dissolving Tank. CAM has been addressed for applicable limits by referencing CAM exempt monitoring required for the most restrictive PM limit, which is continuous monitoring of wet scrubber pressure drop and recirculation flow rate (AOP Condition E.3.a). As the monitoring addresses the strictest particulate limit for this unit, it is assumed that it will indicate compliance for the other limits as well. Flow rate and pressure drop across the scrubber are indicators of the performance of the scrubber in minimizing particulate emissions. By design, the unit is in compliance with the particulate and opacity standards when adequate flow and pressure drop are maintained across the scrubber unit. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00028 SC_EVERSPLIT0002172 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 28 of 123 The surrogate setpoints, as indicators of control device performance, are based on historical evidence, source testing, and good engineering judgment. The permit requires that Boise Wallula continuously monitor pressure drop and the scrubber recirculation rate. Corrective action is required whenever the three-hour block average of either parameter is outside the range determined by the initial performance test or any subsequent performance test. Stack tests done in 2004 indicate the surrogate setpoints summarized below assure compliance with the smelt tank particulate limit of 0.2 lbs/ton. Table 5 Smelt Dissolving Tank Particulate Matter Performance Test Data Date Scrubber Differential Pressure Inches of H2O Scrubber Flow gpm Particulate lb Ton BLSF 6/15/04 -2 25 0.20 6/15/04 -2 25 0.20 6/17/04 -2 25 0.14 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00029 SC_EVERSPLIT0002173 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 29 of 123 Based on these stack tests, the established ranges are as follows: Maintain a three hour average scrubber recirculation rate equal to or greater than 25 gpm, and Maintain a three hour average pressure drop equal to or greater than 2 inches H2O Ecology does not believe opacity limit exceedances are an issue based on years of on-site inspections where opacity as a detached plume has not been noticed to any significant degree. However, 40 CFR Part 64 requires that the facility establish an appropriate range(s) or designated condition(s) such that operation within the ranges provides a reasonable assurance of ongoing compliance with an emission limit. The #3 smelt tank stack is a wet stack so an opacity COM is not appropriate. As such, the Permittee will be required to conduct an EPA Method 9 evaluation within 180 days of permit renewal to verify that compliance with the opacity limit will be reasonably assured at the proposed surrogate set points. Hogged Fuel Boiler -- Particulate/Opacity Boise Wallula uses a wet electrostatic precipitator (wet ESP) to control particulate emissions from the Hogged Fuel Boiler. CAM has been addressed for applicable PM limits by referencing CAM exempt monitoring required for the most restrictive PM limit, which is continuous monitoring of wet ESP total secondary electric power input (AOP Condition F.12). As the monitoring addresses the strictest particulate limit for this unit, it is assumed that it will indicate compliance for the other limits as well. A performance test done in January 2016 as summarized below indicate the surrogate setpoint of 16 kVA on a 3-hr average assure compliance with the HFB particulate limit of 0.026 gr/dscf. Table 6: Hogged Fuel Boiler Particulate Matter Performance Test Data Run # Date Wet ESP Secondary Power (kVA) Particulate ((Yr dscf) 1 1/20/16 16 2 1/21/16 31 3 1/21/16 24 0.011 0.012 0.009 Opacity readings using Method 9 were also performed for 30 minutes on 1/20/16. The minimum total power input during any 6-minute interval was 19 kVA. The maximum 6minute opacity reading was 0%. In a WESP, electric fields are established by applying a direct-current voltage across a pair of electrodes: a discharge electrode and a collection electrode. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00030 SC_EVERSPLIT0002174 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 30 of 123 Particulate matter and water droplets suspended in the gas stream are electrically charged by passing through the electric field around each discharge electrode (the negatively charged electrode). The negatively charged particles and droplets then migrate toward the positively charged collection electrodes and is separated from the gas stream. Particulate is removed from the collection plates by an intermittent spray of water. The WESP power input (voltage and current) were selected as performance indicators because the power drops when a malfunction, such as grounded electrodes, occurs in the WESP. When the secondary power drops, less particulate is charged and collected. The surrogate setpoints are based on a performance testing. See "Comments on Specific Permit Conditions" for the setpoints. Cyclone Box Clipping Collection System -- Particulate (annual average)/Opacity Boise Wallula collects box clippings from it packaging plant and sends it back to be repulped and combined with virgin pulp. The box clippings go through a cyclone and into a bailer. The exhaust of the cyclone goes through a particulate filter before exhausting to the atmosphere. The box clipping collection system operates continuously when the packaging plant is in operation since a buildup of the clippings will shut down the converting machines. CAM applies since the pre-control emissions for PM could exceed the major threshold criteria. However, the allowed emissions are less than the major threshold. As such, the data collection frequency must be at least once per 24-hour period. Permit Conditions L.1 and L.2 requires that Boise Wallula install and maintain a pressure drop measurement device on the baghouse to monitor whether the baghouse is properly operating. The facility must also record the instantaneous pressure drop reading at least once per day. Corrective action is required if the pressure drop is less than or equal to four inches. Greenhouse Gas Reporting On October 30, 2009, EPA issued the Mandatory Greenhouse Gas Reporting Rule, specifically 40 CFR 98, which requires annual reporting of greenhouse gas (GHG) data and other relevant information from large sources (those with emissions greater than 25,000 metric tons of CO2 equivalent) to EPA beginning with reporting year 2010. Greenhouse gas reporting to EPA (40 CFR 98) is not considered an applicable requirement under Title V and does not need to be included in the Title V permit (see http://www.epa.govinseghgdocsighgpermittingguidance.pdf). Chapter 173-441 WAC, "Reporting of Emissions of Greenhouse Gases", is a mandatory greenhouse gas (GHG) reporting rule for: Any listed facility that emits at least 10,000 metric tons of CO2-equivalents (CO2e) of greenhouse gases annually in the state. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00031 SC_EVERSPLIT0002175 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 31 of 123 WAC 173-441 was adopted by Ecology on December 1, 2010 and became effective on January 1, 2011. This regulation applies to the facility because the facility emits at least 10,000 metric tons of CO2e of greenhouse gases per year. WAC 173-441 requires annual GHG inventories with reports due no later than March 31 of the following year for facilities that are also subject to 40 CFR 98. Under WAC 173-441, annual emissions shall be reported to Ecology beginning in calendar year 2012. This regulation is implemented in its entirety by Ecology and is considered an applicable requirement under the Title V program; as such, it is included as item 32 in the Facility-Wide General Requirements Section of the AOP for the facility. Industrial Boiler MACT Standard, Subpart DDDDD On January 31, 2013, the EPA published in the Federal Register the NESHAPs for boilers and process heaters at major sources of air toxics (Boiler MACT) -- 40 CFR 63 Subpart DDDDD. The Permittee made a good faith effort to include applicable Boiler MACT limits and work practices in their permit renewal application. However, during the course of this permit renewal process, certain Boiler MACT provisions have been changed with EPA's promulgation of the Boiler MACT Reconsideration Rule (November 2015) and more recently the DC District Court has issued an opinion with vacates and remands certain provisions of the rules yet to be clearly defined (July 29, 2016). EPA subsequently requested that the Court not vacate the standards and was granted that request in December 2016. As such, Ecology has included applicable Boiler MACT limitations and work practices in this permit. Boise Wallula has three boilers subject to the final Boiler MACT rule: Hog Fuel Boiler (HFB), No. 1 Power Boiler (PB #1), and No. 2 Power Boiler (PB #2). The HFB is a stoker design manufactured by George Kipper & Sons in 1979. The rated heat input capacity is 343 MMBtu/hr and is capable of burning both wood and natural gas. The HFB is classified as "stokers/sloped grate/other units designed to burn wet biomass/biobased solid" [40 CFR 63.7499(i)]. The power boilers are package boilers manufactured by Babcock and Wilcox. PB #1 was manufactured in 1958. PB #2 was manufactured in 1960. Both power boilers only burn natural gas but have the capability of burning fuel oil during periods of natural gas curtailment. The power boilers are classified as "units designed to burn gas 1 fuels" [40 CFR 63.7499(1)]. During the most recent permit term, the Mill did not burn fuel oil, despite being permitted to do so. However, the Mill remains permitted to burn oil in the power boilers should the Mill make a fuel switch from gas to oil and become subject to the limits for oil burning boilers. The Mill is permitted to burn either light liquid fuel or heavy liquid fuel in the power boilers. All pollutant limits are the same for either fuel with the exception of particulate matter, as noted in the permit. Initial compliance requirements with the Boiler MACT rule have been completed before issuance of this permit renewal and summarized below. Only the ongoing compliance requirements are incorporated in the permit. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00032 SC_EVERSPLIT0002176 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 32 of 123 Initial Notification - the required Initial Notification was submitted on January 19, 2012. Notification of Compliance Status [40 CFR 63.7545(e)]- the required Notification of Compliance Status Report was submitted on March 28, 2016. Initial Tune-ups [40 CFR 63.7510(e)] - initial tune-ups of the HFB, PB #1, and PB #2 were conducted on October 20, 2015, June 5, 2015, and June 6, 2015, respectively. One-Time Energy Assessment [40 CFR Part 63.7510(e) for requirement and Table 3 to Subpart DDDDD of Part 63 (Item 4) for specifics] -- The one-time energy assessment of the Wallula Mill was completed by a qualified energy assessor on January 21, 2016. CO and O2 CEMS Initial Certification (HFB only) -- The initial certification of the CO (PS-4) and O2 (PS-3) CEMS was conducted on March 9, 2016. The results were submitted to EPA and Ecology through the CEDRI/CDX program on April 28, 2016. Initial Performance Test (HFB only) -- The HFB initial performance test was conducted on January 20, 2016 for PM, HC1, and Hg. The results were submitted to EPA and Ecology through the CEDRI/CDX program on March 14, 2016. A summary of the results is shown below: Table 7: Hogged Fuel Boiler -- Boiler MACT Initial Performance Test (January 2016) Method 5/29 Parameter Criteria Run #1 Run Steaming Rate (klb/hr) Max 195 195 WESP Total Sec. Power (kVA) Min 16 31 PM (lb/mmBTU of Steam Output) 0.034 0.034 Hg (1b/mmBTU of Steam Output) 9.02E-07 1.23E-06 * Limit is 110% of maximum 1-hour load achieved during the test. Run _, 196 24 0.028 9.57E-07 Limit 214.5* 16 0.043 6.40E- 06 Method 26 Parameter Criteria Run # I Run #2 Steaming Rate (klb/hr) Max 194 195 WESP Total Sec. Power (kVA) Min 20 31 HC1 (1b/mmBTU of Steam Output) 2.10E-03 9.50E-04 * Limit is 110% of maximum 1-hour load achieved during the test. Run 43 195 23 5.10E-04 Limit 214.5* 20 0.025 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00033 SC_EVERSPLIT0002177 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 33 of 123 Wet ESP Total Secondary Power Calculation To show continuous compliance, the Boise Wallula Mill established the minimum total secondary electric input, as determined from the values of secondary voltage and secondary current to the electrostatic precipitator. The determination of the minimum total secondary power electric power input is as follows: 1) Collect 15-minute averages of secondary voltage (Vi, V2, and V3) and secondary amperage (Ai, A2, and A3) for each of the 3 Wet ESP cells. 2) Calculate secondary electric power input (P15) every 15 minutes: P15 = Vi Ai + V2 A2 V3 A3 3) Calculate secondary electric power input (P-lhr) every hour: P-1hr = (P151+ P152+ P153+ P154)/4 4) For Methods 5 (PM) and 29 (Hg), the lowest calculated 1-hr average (P-lhr) secondary power input for each run is shown in the table above. Reciprocating Internal Combustion Engines (RICE) MACT, 40 CFR 63 Subpart ZZZZ and 40 CFR 60 Subpart JJJJ Emergency RICE Boise Wallula uses stationary combustion engines to provide electricity and to power pumps and compressors during periods of emergency only: 318 HP Detroit diesel CI engine; Last rebuilt in 1986; Used to drive an emergency backup fire water pump. 318 HP Detroit diesel CI engine; Last rebuilt in 1998; Used to drive an emergency backup mill process water pump. 200 HP Ford propane SI back-up generator; manufactured in April 2004; back-up generator for providing electricity to the main office. 97 HP Generac propane SI back-up generator; manufactured in August 2013; back-up generator for providing electricity to the R8 generator. The first three in the list above are subject to 40 CFR 63 Subpart ZZZZ (NESHAPs for Stationary Reciprocating Internal Combustion Engines). The 97-HP Generac generator is subject to 40 CFR 60 Subpart JJJJ (NSPS for Stationary Spark Ignition Engines). The applicable work practice standards are included as Section R in the permit. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00034 SC_EVERSPLIT0002178 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 34 of 123 Existing non-emergency RICE From the time of the federal rule implementation through 12/31/2014, two engines were considered emergency units: 195 HP Detroit diesel engine; Installed in 1992; Used to drive an backup fire water pump 200 HP Hercules propane 4-stroke lean-burn auxiliary drive engine; manufactured in 1988; Used to drive the lime kiln when the electric drive is offline (replaced on June 2016 with a 80-HP Engine Distributors, Inc. Model MSG -425 engine manufactured in 2016) On 12/31/2014, the two engines surpassed the allowable annual non-emergency usage amount (50 hours) specified in the rule subpart. According to the Administrations Implementation Question and Answer Document, dated July 17, 2012, these two units are no longer considered emergency units. The first engine (195-HP Detroit Engine) is subject to compliance under 40 CFR Subpart 63 Subpart ZZZZ as an existing engine constructed prior to 6/12/2006 with a rating less than 500 HP. The applicable CO emission limit for this engine is included as Section R in the permit. On February 17, 2015, a performance test was conducted in the 195-HP Detroit Engine. The results were submitted to Ecology on April 16, 2015 and are summarized in the table below. Table 8: Detroit Engine Performance Test Pollutant CO (ppm @ 15% O2) Run I 80.3 195-HP Detroit Cl Engine Exhaust Run 2 Run 3 Average Subpart ZZZZ Emission Lim it 78.4 75.8 78.2 230 The performance test for the 200-HP Hercules Engine occurred on May 27, 2015. The test was abandoned because the existing engine failed to achieve compliance with the applicable CO limit for non-emergency engines. The applicable CO standard for the 200HP Hercules Engine is 47 ppmvd @ 15% oxygen (Item 10 of Table 2c to 40 CFR 63 Subpart ZZZZ). As a result of the failed compliance test, Boise Wallula replaced the 200-HP Hercules Engine with a new 80-HP MSG 425 engine from Engine Distributors, Inc. This engine is now subject to Subpart JJJJ. The new engine is certified to meet 40 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00035 SC_EVERSPLIT0002179 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 35 of 123 CFR Part 1048 and is operated per manufacturer's recommendation. There is no emission limit for this engine. Pulp and Paper Industry NESHAP (MACT I), 40 CFR 64 Subpart S update On April 15, 1998, EPA issued National Emission Standards for Hazardous Air Pollutants (NESHAPS) for the pulp and paper industry, specifically 40 CFR 63, Subpart S. These standards have been commonly referred to as the "Cluster Rules" or "MACT I." The compliance date for the regulations was April 16, 2001. The Mill requested and received a one-year extension for the pulping process condensate portion of the rule. On September 11, 2012, EPA eliminated the startup, shutdown, and malfunction (SSM) exemption in the rule and added affirmative defense option. The affirmative defense option is currently being reconsidered by EPA. These changes affect Section S of the existing AOP. MACT I rules regulate hazardous air pollutant emissions (as methanol) from five key areas of the Mill. The No. 1 M&D Digester chip/sawdust bin was determined to be an insignificant source of HAPS emissions and to be exempt from regulation under the MACT I regulatory requirements (Letter dated June 15, 2001). All of the systems must meet the "existing source" requirements of the MACT I rules: Bleach plant/scrubber; Bleaching chemical agent used in the bleach plant; Low-Volume, High-Concentrate (LVHC) Non-Condensable Gas (NCG) system; Hardpiped condensate collection system; and High-Volume, Low-Concentrate (HVLC) system or Clean Condensate Alternative (CCA). For the bleach plant scrubber, MACT I requires that operating parameter ranges be established as surrogates in order to demonstrate compliance with a chlorinated compound emission limit of 10 ppmvd, as chlorine. Initial performance test plans were submitted in advance of the performance test compliance demonstrations. Required surrogates used for compliance demonstration include ORP, scrubber recirculation flow, and scrubber fan operation (approved by EPA as an alternative to scrubber air flow). The bleach plant operation was altered so that elemental chlorine is no longer used as a bleaching agent. In December 2000, the Mill completed the conversion to bleaching with 100% chlorine dioxide substitution for chlorine. This bleaching configuration is known as elemental chlorine-free bleaching, or "ECF." This requirement to modify the bleaching configuration also assures compliance with the chloroform reduction requirements of the MACT I regulation. Low-Volume, High-Concentration (LVHC) Non-Condensable Gas (NCG) System MACT I require NCGs to be collected from applicable digester systems, evaporator systems, and regulated foul condensate tanks. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00036 SC_EVERSPLIT0002180 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 36 of 123 At Boise Wallula, this equipment includes the No. 1 and No. 2 M&D Digesters, the NSSC digester, the Kamyr digester, the No. 1 evaporator seal tank, No. 2 evaporator seal tank, No. 3 evaporator seal tank, foul condensate tank, lime kiln condensate collection tank, Hog fuel boiler condensate collection tank, and the LVHC condensate collection system. Boise Wallula monitors the vacuum of the LVHC system as well as the incineration source for these gases. The regulations provide for an allowance of up to 1% venting in addition to SSM events, as reported semiannually, to account for maintenance and repairs. Boise Wallula reports all venting events in its semiannual MACT report. The NCG system is inspected for leaks under the Leak Detection and Repair (LDAR) program at least every 30 days. Boise Wallula has requested and it has been approved that the 30-day monitoring frequency be changed to monthly monitoring in the Title V permit in order to facilitate better scheduling of department staff. In addition to the monthly inspection, the LVHC system is also leak-checked annually for leaks using a VOC detector on the positive pressure portion of the system. A detector reading of 500 ppm or greater indicates leaks that must be repaired. Pulping Process Condensates Hardpiping of foul condensates is used for compliance with the pulping process condensate requirements of the MACT I regulations. The Mill has elected to comply with collecting at least 11.1 lbs methanol per ton of kraft pulp production. Hardpiped condensates are discharged under the surface of a well-operated biological treatment system in order to remove the required 10.2 lbs of methanol per ton of kraft pulp production. The Mill completed initial performance tests as required by the MACT I regulations and also completes quarterly verification tests to demonstrate the ability of the wastewater treatment system to achieve the required methanol reductions. The Mill has established a 15-day averaging period for compliance demonstration with the hardpiping standard. The process pulping condensates that comprise the hardpipe condensate collection system at the Mill include: Kamyr digester surface condenser condensate; No. 1 and No. 2 M&D digester condensate; LVHC system condensate No. 1, No. 2, and No. 3 evaporator foul condensate tanks High-Volume, Low-Concentration (HVLC) System The MACT Subpart S rule requires that HAPs measured as methanol be collected from the brownstock washers or alternatively that the Mill demonstrates compliance with the provisions of the clean condensate alternative in 40 CFR 63.447. The deckers and screens have been determined to be below the applicability threshold. The Mill has very low concentrations of methanol in these units. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00037 SC_EVERSPLIT0002181 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 37 of 123 The Mill has tested brownstock washer emissions, and the total methanol emissions are below the thresholds established in the MACT I rule and are not required to be collected. The remaining brownstock pulp washer gases are very low in methanol concentration, and the Mill has completed an application in order to utilize the Clean Condensate Alternative (CCA) as provided in 40 CFR 63.447. Ecology approved the Mill's CCA plan in March 2003. CCA compliance demonstration requirements have been added to the monitoring, reporting, and recordkeeping provisions of the Title V Permit. Pulp and Paper NESHAP, 40 CFR 63, Subpart S RTR On September 11, 2012, EPA issued the residual risk and technology (RTR) rule for pulp and paper sources subject to the Subpart S NESHAP. One new applicable requirement in 40 CFR 63.457(a)(2) requires that a new performance test be conducted by September 7, 2015 for units regulated under 63.443, 63.444, and 63.445, and every 60 months thereafter. The new requirement has been added to the permit for the bleach plant performance test (63.445). Equipment regulated under 63.443 and 63.444 are satisfied through vent collection and incineration in a boiler or lime kiln meeting the regulatory requirements in 40 CFR 63.443(d)(4). Conduct of new performance testing and retesting is not required by the rule for the condensate collection and treatment system or the equipment included within the Mill's clean condensate alternative (CCA) alternative, 63.446 and 63.447, respectively, as those sections are not referenced in the 2012 RTR rule, 40 CFR 63.457(a)(2). Pulp and Paper Industry NESHAP (MACT II), 40 CFR 63, Subpart MM On January 12, 2001, EPA issued National Emission Standards for Hazardous Air Pollutants (NESHAPS) for the pulp and paper industry, specifically 40 CFR 63, Subpart MM -- National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semi-chemical Pulp Mills. The Subpart MM rules became effective on March 13, 2001, with a compliance date of March 13, 2004. These standards have been commonly referred to as "MACT II." MACT II rules regulate metals (particulate matter surrogate) emissions from five significant emission units and their respective control devices at the Mill. All of the units below must meet the "existing source" MACT II requirements: Lime kiln/scrubber No. 2 recovery furnace/electrostatic precipitator (ESP) No. 2 recovery smelt dissolving tank vent/scrubber No. 3 recovery furnace/ESP No. 3 recovery smelt dissolving tank vent/scrubber 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00038 SC_EVERSPLIT0002182 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 38 of 123 Lime kilns must achieve a particulate matter emission rate of 0.064 grains per dry standard cubic foot (gr/dscf) corrected to 10% oxygen. Recovery furnaces must achieve a particulate matter emission rate of 0.044 gr/dscf corrected to 8% oxygen, and smelt dissolving tank vents must achieve a particulate matter emission rate of 0.2 lbs/ton black liquor solids (BLS). The Mill completed initial performance test (IPT) plans and conducted the performance testing for each emission unit as required by the rules. Parametric monitoring requirements for each control device mentioned above were established pursuant to those IPTs and the rule. NSSC Pulping/Pink Liquor System A powdered sodium sulfite "synthetic liquor" system has been in place at the Boise Wallula Mill for the past several years. The sulfur burner system continues to be maintained and will be kept in place as a backup for generation of sulfite liquor for the NSSC process in situations where the powdered system malfunctions, in cases of raw material supply interruptions, or for other economic reasons. A letter was issued by Ecology dated December 7, 1998 determining that the NSSC digester is subject to comply with the control options that are set forth in 40 CFR 63.443, standard for pulping systems, under Subpart S that regulates the HAPs for pulp processes. HAP emissions from the existing LVHC system were required to achieve compliance as scheduled in 40 CFR 63.440(d). Boise Wallula is in compliance with this requirement. Printing and Publishing MACT, 40 CFR Part 63 Subpart KK The Wallula Containerboard/Box Plant, co-located with the pulp and paper mill, is subject to the requirements of the Printing and Publishing MACT, 40 CFR Part 63 Subpart KK. The facility emits fugitive emission of less than the regulatory threshold of 400 kg/month of organic HAPS, and as such is only subject to the monthly recordkeeping requirement of total ink used and the HAP content of the applied ink pursuant to Section 63.829(e) and 63.830(b)(1). All records are maintained and kept on site by Boise Wallula personnel. Because no specific Subpart KK emissions limit applies, a permit condition has not been proposed by Boise Wallula or Ecology for the Title V permit. Best Available Retrofit Technology (BART) Inapplicability After conferring with the Ecology Air Program regarding BART applicability for the Wallula mill, Boise Wallula submitted a BART eligibility review letter to the Air Program on August 8, 2005. Boise Wallula's review, which has been accepted by Ecology, concluded that BART was not applicable to the No. 2 Recovery Furnace, the No. 3 Recovery Furnace, the Hogged Fuel Boiler, the Lime Kiln or the No. 1 and No. 2 Power Boilers. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00039 SC_EVERSPLIT0002183 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 39 of 123 Documentation confirming that the No. 2 RF startup date occurred before February 1962, and prior to the August 7, 1962 BART applicability date was provided by Babcock and Wilcox. The No. 3 Recovery Furnace, Lime Kiln and Hogged Fuel Boiler were all permitted under PSD permit X-77-04 during 1977-1978, with start-up occurring in approximately 1980. As such, these units are not BART eligible units. The No. 1 and No. 2 Power Boilers are both rated at less than 250 MM BTU/hour and are also not BART eligible units. The Wallula mill has no operating combustion units that are subject to BART regulations. Projects and Permit Approvals During the current permit term from 12/1/09 to 1/1/15 the Wallula mill has submitted one notice of construction application and received the approval from the Department of Ecology. An outline permitting activities is provided below: Wallula Containerboard/Box Plant Projects The Wallula Box Plant, part of the company's packaging and newsprint division, is colocated on the site with the Wallula Kraft Pulp and Paper mill. The Wallula mill's No. 2 Paper Machine produces unbleached corrugating medium that is directly integrated with the box plant's production of corrugated containers. One key project was completed at the Mill during the 2009-2014 permit term. In May 2010, Boise submitted a NOC to Ecology to upgrade and modify the existing corrugator operations. On August 17, 2010, Ecology issued NOC Approval Order No. 7847 for this project. No new applicable requirements or limits were included in the approval; therefore, no new permit conditions need to be added to the Title V operating permit. The container plant has a starch silo bag house and is included in the emissions inventory. A letter of approval, dated April 1998, was issued by Ecology for a new flexo-gluer replacement project, which included an installation of a new "Mini-Martin 2" flexofolder/gluer as a replacement to the No. 1 Langston gluer at the Wallula container plant. The No. 1 Langston was reinstalled as a working spare to handle peak production demands. Ecology determined that the Langston reinstallation was exempt from new source review as stated in WAC 173-400-110(5). Ancillary and Support Operations Boise Trucking Fugitive emissions from Boise Wallula's adjacent trucking terminal are included in the Mill's Title V emissions inventory and permitting process. Ponderosa Delnk Plant and R&D Lab The Ponderosa fibers deink plant has been closed. Boise Wallula has retained ownership of the Ponderosa assets and now owns the equipment and buildings. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00040 SC_EVERSPLIT0002184 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 40 of 123 A portion of the plant is being used to store No. 2 paper machine's bleach market pulp and another portion of the plant has been used since 2008 for a research and technical development center associated with the label and release paper machine project for W3. Emissions from the laboratory are insignificant as defined in WAC 173-401-530, 531 and 533(3)(c). Landfill/Compost Operations The fugitive emissions inventory from the onsite landfill and compost operations is incorporated into the permitted inventory. Fugitive emissions estimates were updated as part of the PM10 attainment designation and provided to Ecology's Doug Schneider for use in development of the Wallula Area maintenance plan on 4/11/03. The Mill and its contractors have implemented an approved Dust Control Plan at the site. Fiber Farm The facility previously owned an 850-acre cottonwood fiber farm adjacent to the Mill property. The farm had previously been included in the Mill's emission inventory, but is no longer included due to the sale of the land on 10/3/2007. Boise Wallula considers the Fiber Farm as an insignificant emission unit per WAC 173401-532(34). PSD Permit, Notices of Construction ("NOC"), State Orders, and Letters of Approval Subsequent to the Mill's first Title V permit in 1996, the Mill has been issued a PSD permit, several notices of construction, state orders, and letters of approval, which are provided in Appendix A. Brief descriptions of the most significant permitting activities are listed below. Box Plant Corrugator Project, 2010-2011 In May 2010, Boise Wallula submitted a NOC to Ecology to upgrade and modify the existing corrugator operations. On August 17, 2010, Ecology issued NOC approval order 7847 for this project. No new applicable requirements or limits were included in the approval; therefore, no new permit conditions need to be added to the Title V operating permit. No. 3 Recovery Furnace/Hog Fuel Boiler PSD Permit, May 2002 The Mill has submitted a PSD application for the No. 3 Recovery Furnace upgrade and the hog fuel boiler upgrade and received the accompanying notices of construction and state orders. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00041 SC_EVERSPLIT0002185 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 41 of 123 The No. 3 Recovery Furnace has been permitted for an increase of throughput by approximately 15%, as well as the replacement of some of the boiler tubes and installation of tertiary air ports and controls. The hog fuel boiler has been permitted for an upgrade to over-fire air and for a production increase. Chlorine Dioxide C1O2 Upgrade Order Issued September 25, 2000 The R8 generator was upgraded for throughput to accommodate the increase usage of C1O2 associated with 100% chlorine substitution, to comply with the Cluster Rule regulations. No. 2 Recovery Furnace Administrative Order Issued November 19, 2002 An Administrative Order was issued for the No. 2 Recovery Furnace that provided a synthetic minor emissions cap and for the completion of necessary boiler tube repairs. Chip Flinger Installed October 1995 A new chip transfer system was installed to replace the older system. The new system, known as a chip flinger, was chosen to reduce fracturing and generation of pin chips in the old pneumatic chip blower system. The new system resulted in a net decrease in particulate emissions (PM/PM10) with the reduction of pin chips. Power Boilers Fuel Use -- PSD Permit Condition, May 2002 As part of the PSD permit issued in May 2002, the stipulation on use of fuel oil only during periods of gas curtailment was removed. However, the 2% sulfur content of oil and the annual sulfur limits remain in place. Used Oil Fuel Letter of Approval Issued December 18, 2002 The Mill has now been permitted to burn used oil provided that the used oil specifications provided in 40 CFR 279 are met. Lime Kiln Hot End Bag House Letter of Approval Issued December 15, 1998 A bag house was added to the hot end of the lime kiln in order to reduce lime dust emissions. The project was exempt from new source review under WAC 173-400110(5). Lime Kiln Stack Specialty Minerals Incorporated (SMI) uses the carbon dioxide gases from the lime kiln scrubber to produce calcium carbonate, an excellent way to reduce greenhouse gases. The SMI inlet connection to the lime kiln scrubber was found to interfere with the stack tests. Hence, the inlet to SMI was moved up the stack by approximately 20 feet. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00042 SC_EVERSPLIT0002186 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 42 of 123 No. 3 Recovery Furnace ESP 3rd Cell Order Issued March 3, 1996 A third cell was added to No. 3 recovery furnace ESP to allow maintenance to occur on the other primary cells while the furnace was still in operation. Fugitive Emissions Inventory In the previous 2004-2009 Title V, the most conservative emission factors were used for fugitive emission factors. The 2009-2014 permit, and the proposed renewal permit, use emission factors based on emission estimates both on the specific soils used and the mean versus maximum emission factors. Emission Inventory The conservative Title V emission inventory was updated for the 2009-2014 permit with an emission basis that more accurately reflected the facility emissions for annual emissions reporting, SARA Title III, emission releases, and permitting activities. Fugitive emissions estimates from the Boise Wallula fiber farm are no long included in the inventory since the site has been sold. Federal Air Quality Requirements: Applicability for MACT, NSPS, NESHAP, or CAM NESHAP Applicable: MACT Subparts S, MM, KK, JJJJ, ZZZZ, DDDDD NSPS Applicable: Subpart BB, Db (specific units only, as noted in permit) CAM: Non Applicable -- See Section 11 Attachments State Air Quality Requirements: Applicability for BACT, PSD, LAER, or Acid Rain PSD Applicable: Lime Kiln, No. 3 Recovery Furnace, Hog Fuel Boiler, No. 3 Evaporator Set LAER Applicable: Not Applicable BACT Applicable: Lime Kiln, No. 3 Recovery Furnace, Hog Fuel Boiler Compliance/Enforcement History and Remedies All emission units have been properly permitted and are operating in overall compliance with regulatory requirements at the time of the most recent Title V Air Permit Application renewal received on December 24, 2014. There are no outstanding enforcement actions nor have there been significant enforcement actions during the previous permit term. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00043 SC_EVERSPLIT0002187 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 43 of 123 EMISSION UNIT DESCRIPTION Emission Unit Control Device and Emission Inventory ID In keeping with the submission of the Facility Annual Air Inventory, the following table lists the point and segment number as per the Annual Air Inventory Report along with a brief description. Table 9: Plant Number 53-071-00003 Emission Unit Control Devices Point Number 01 02 03 04 10 21 22 23 24 25 26 27 28 Segment Number 01/02 01 01 01 01 01, 02 01, 02 01, 02 01, 02 01 01 01 01, 02, 03 Source and Control Description Lime Kiln -- High efficiency wet scrubber Smelt Tank Vent -- No.2 Recovery Furnace -- Medium efficiency wet scrubber Kraft No. 2 Recovery Furnace -- High efficiency electrostatic precipitators Smelt Tank Vent -- No. 3 Recovery Furnace -- Medium efficiency wet scrubber Kraft No. 3 Recovery Furnace -- High efficiency electrostatic precipitators No. 1 Boiler -- Natural gas and Oil No. 2 Boiler -- Natural gas and Oil Hog Fuel Boiler Fugitive Emissions Bleach Plant -- Medium efficiency scrubber Water Purification Plant Pulping and Washing -- CCA & Hard Pipe All other processes Modification History PSD-X77-04 Amend 2 6/14/05 NOC/Modification 3/18/05 Startup 12/1980 No modifications PSD-01-07 Amend 1 2/2/06 No modifications No modifications PSD-01-07 Amend 1 2/2/06 NA No modifications No modifications No modifications Coater Project -- Order No. 5408 Wet Lap Project -- 12/16/08 Container Project -- 2/17/05 Boxplant Corrugator Project -- 8/17/10, Order No. 7847 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00044 SC_EVERSPLIT0002188 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 44 of 123 STATE-ONLY VS. FEDERALLY ENFORCEABLE REQUIREMENTS The few permit conditions which are state-only and not federally enforceable requirements are identified as state-only within the permit itself. No further explanation is provided here on the assumption that the permit condition is self-explanatory. EMISSION LIMIT DISCUSSION Monitoring and Gap Filling Ecology has preferentially relied on direct source testing as the most robust and accurate method of determining compliance and, through frequency of testing, assuring compliance. Source testing is resource and time intensive. More frequent monitoring requires the use of some sort of indirect surrogate parameter. The frequency of direct source testing has been stipulated through Orders, which are included in Appendix F of this permit. Ecology has attempted to reconcile frequency of monitoring with accuracy of monitoring by relying on both direct periodic source testing and more frequent indirect monitoring using surrogate parameters. Acknowledging the surrogate monitoring parameters as compliance indicators but not necessarily compliance determinants addresses the qualitative concerns regarding surrogate monitoring parameters. Where surrogate monitoring parameters have been employed, the Permit has been structured such that noncompliance with the surrogate limitation requires corrective action. Failure to take corrective action and bring the surrogate parameter within bounds constitutes noncompliance with the need to follow good operation and maintenance as required by WAC 173-405-040(10). The Permit thus combines periodic direct source testing which definitively determines compliance with surrogate monitoring requirements indicating compliance to achieve an overall monitoring program intended to meet the Title V requirement of monitoring sufficient to assure compliance. The frequency of both direct source testing and the application of surrogate parameters intended to indirectly infer compliance with the underlying applicable requirement is based on best professional judgment of the historical probability of exceeding the imposed limitation and the potential magnitude of an exceedance. A summary of historical particulate emissions testing results which served as the basis for determining the frequency of monitoring is included in this document as Appendix B. Historical testing results for all parameters monitored is not included because this data is already on file available for public review and including it in this document would literally require hundreds of pages. Emission units such as the lime kilns and smelt tanks have wet scrubbers as emission control equipment or as part of the emission control equipment train. The requirement to monitor and maintain scrubber flow at certain set points was, prior to the advent of Title V Permits, initially imposed as an indicator of proper operation and maintenance regarding opacity and particulate emission minimization. Particulate source testing and visual observations of opacity indicate that the surrogate scrubbing parameters stipulated can be used as indicators of compliance with the opacity and particulate emission limits. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00045 SC_EVERSPLIT0002189 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 45 of 123 For some units, such as recovery furnaces, opacity is proposed as a compliance indicator for particulate emissions. At this time, Ecology does not know of a definitive relationship between opacity and particulate emissions for all emission units such that opacity could be used as a predictive emissions parameter. Nonetheless, there is a relationship such that the opacity levels selected, the opacity limits themselves, are believed to adequately function as surrogate indicators which infer compliance with the underlying applicable requirement. Incorporated into the Permit for the No. 2 and No. 3 Recovery Furnaces, Lime Kiln, and No. 2 and No. 3 Smelt Dissolving Tanks, is an allowance for a reduction in source testing frequency which may be allowed if particulate emission control meets certain criteria. Ecology has introduced this allowance as an incentive to encourage improved emission control. The first criterion, which must be met to allow consideration of source testing frequency reduction, is a proven history of performance. This requires a source to achieve six consecutive months of monthly source testing results that are not greater than 75% of the particulate emission limit. To maintain the reduction in testing frequency no subsequent testing results can be greater than the 75% threshold. If a test result is greater, the testing frequency reverts to a monthly basis until the next six consecutive monthly period of improved performance has occurred. Simply meeting the 75% threshold is not the only criteria for gaining a reduction in source testing frequency. Subjective criteria are also evaluated and ultimately best professional engineering judgment is exercised. Primary factors also considered include historical emission trends and degree of confidence in maintaining emission limit compliance between source testing events. For example, a unit from which particulate emissions have been historically increasing would probably not gain the source testing frequency allowance. It possibly could be argued that such a unit was already trending toward noncompliance with WAC 173-405-040(10) which requires operation and maintenance of a facility and emission that operated only periodically probably would not be granted a reduction in monitoring frequency because of possible problems developing from its "mothballed" status. A reduction in testing frequency would also be dependent on the strength of surrogate information available indicating limit compliance between testing events, if a surrogate parameter was deemed control equipment in a manner consistent with good air pollution control practices. Also a unit adequate for compliance indication when coupled with monthly testing but not adequate as a stand-alone compliance indicator, a reduction in testing frequency would not be granted despite achieving the 75% emission allowance threshold. Where the respective Order is the basis of authority for the required source testing and establishes the frequency of source testing, the mechanism for achieving a reduction in source testing frequency is modification of the underlying Order. The current wording in the Title V permit allowing the consideration of such a reduction is designed as a placeholder such that modification of the underlying Order will not require opening the Title V permit for modification. A 30-day public comment period will still occur associated with modification of the Order. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00046 SC_EVERSPLIT0002190 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 46 of 123 Representative Source Tests Boise Wallula source tests represent compliance with the standard because the time period over which the sources are tested is representative of the operation of the source throughout the compliance period. The period of source testing is representative of operations for the following reasons. Source tests are `blind' in nature. The only communication between the testers and operators is to verify that operating or production parameters meet or exceed the previous compliance period's average operating conditions. Boiler operators are not given long lead times by the source testers, in order that they may "tune-up" their boiler. Source tests are conducted at or above the previous compliance period's average operating parameters. Source tests are designed to utilize operating conditions that best emulate past plant operating parameters in order to show continuous compliance. To accomplish this, source tests are conducted at or above the previous compliance period's average operating ranges in terms of both production rates and unit operating configurations. It is assumed that the greater the operating parameters, the greater the mass emissions. Thus, if the operating parameters meet or exceed the previous compliance period's averages and still meet standards, the overall assessment is that the source test was representative and the system was in continuous compliance. Additional surrogate monitoring parameters. In addition to periodic direct source testing designed to definitely determine compliance, Ecology has proposed minimum operating conditions, where deemed appropriate, as a surrogate monitoring requirements intended to indicate compliance. The overall objective is to achieve a monitoring program that meets the Title V requirement of monitoring sufficient to assure compliance. Monitoring is not always required. The table below illustrates whether or not the following units and pollutants are subject to periodic monitoring as prescribed in 40 CFR 70.6(a)(3). Each requirement is identified by the Permit Condition designation. (e.g. A.1 for particulate for the No. 2 Recovery Furnace.) 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00047 SC_EVERSPLIT0002191 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 47 of 123 40 CFR Part 60 Requirements Table 10: Periodic Monitoring Evaluation Permit Condition A.1 Parameter Particulate A.3 A.6 C.6.a Opacity TRS TRS D.1 Particulate Applicable Requirement(s) 40 CFR 60.282(a)(1)(i) 40 CFR 60.282(a)(1)(ii) 40 CFR 60.284(e)(1)(ii) WAC 173-405-040(6) 40 CFR 60.283(a)(2) 40 CFR 60.284(e)(1)(i) 40 CFR 60.283(a)(5) 40 CFR 60.282(a)(2), WAC 173-405-040(2) Subject to Periodic Monitoring YES NO NO NO NO Justification 40 CFR 60.282(a)(1)(i) does not have any periodic monitoring or testing requirements. Periodic monitoring under section 70.6(a)(3)(i)(B) is required if "the applicable requirement does not require periodic testing or instrumental or noninstrumental monitoring," thus periodic monitoring is required. Monthly source testing is required in Consolidated Order DE 96-AQI078, thus fulfilling the 70.6(a)(3)(i)(B) requirement. The sections listed to the left are all regulated by 40 CFR 60.282 and 283. These sections contain emissions limits for opacity and TRS, respectively. 40 CFR 284 mandates continuous monitoring systems to monitor opacity levels and TRS emissions. Since periodic monitoring under section 70.6(a)(3)(i)(B) is only required if "the applicable requirement does not require periodic testing or instrumental or noninstrumental monitoring," no additional monitoring is applicable. The sections listed to the left are all regulated by 40 CFR 60.282 and 283. These sections contain emissions limits on black liquor solids. 40 CFR 284 mandates continuous 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00048 SC_EVERSPLIT0002192 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 48 of 123 Permit Condition D.4 Parameter TRS Applicable Requirement(s) 40 CFR 60.283(a)(4) Subject to Periodic Monitoring NO Justification monitoring systems to monitor pressure loss and scrubber pressure. Since periodic monitoring under section 70.6(a)(3)(i)(B) is only required if "the applicable requirement does not require periodic testing or instrumental or noninstrumental monitoring," no additional monitoring is applicable. WAC 173-405-040 Requirements Permit Condition A.4 B.1 B.2 B.5.b C.2.a C.3 D.3 E.1 E.2 F.5 G.1 H.1 Parameter SO2 Particulate Opacity SO2 Opacity SO2 Opacity Particulate Opacity Opacity Particulate Particulate Subject to Periodic NIonitoring NO NO NO NO NO NO NO NO NO NO NO NO Justification The sections listed to the left are all regulated by sub-sections of WAC 173-405040. Each of these sub-sections requires some form of emissions limit. In this same section, WAC 173-405-040(12) states that "To demonstrate compliance with this chapter, the provisions of WAC 173-400-105 shall apply to all sources to which this chapter is applicable." WAC 173-400-105 requires that the source "...upon notification by the director of ecology, maintain records on the type and quantity of emissions from the source and other information deemed necessary to determine whether the source is in compliance with the applicable emissions limitations and control measures." Ecology, in Consolidated Order No. DE 96AQI078, mandates periodic source testing. The underlying requirement already contains periodic source testing requirements in WAC 405 and 400, as carried out in the Consolidated Order. Since periodic monitoring under section 70.6(a)(3)(i)(B) is only required if "the applicable requirement does not require periodic testing or instrumental or noninstrumental monitoring," no additional monitoring is applicable. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00049 SC_EVERSPLIT0002193 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 49 of 123 Consolidated Order DE 96-AQI078 Requirements Permit Condition A.2 A.5 C.1 C.4 C.5 D.2 F.1 F.2 G.2 G.3 Parameter Particulate SO2 Particulate SO2 SO2 Particulate Particulate Particulate Particulate SO2 Subject to Periodic Monitoring NO NO NO NO NO NO NO NO NO NO Justification The sections listed to the left are all regulated by Consolidated Order DE 96AQI078. Each of these sections requires some form of emissions limit. Ecology, in Consolidated Order No. DE 96-AQI078, mandates periodic source testing. Since periodic monitoring under section 70.6(a)(3)(i)(B) is only required if "the applicable requirement does not require periodic testing or instrumental or noninstrumental monitoring," no additional monitoring is applicable. Non-Applicable Requirements Permit Condition P1arameter A.7 B.3 C.7.a D.5 D.7 Operation Operation Operation Operation Damper position E.3 Operation Applicable Requirement(s) WAC 173-405-040(10) WAC 173-405-040(10) WAC 173-405-040(10) WAC 173-405-040(10) DE 78-112 as consolidated in Order DE 96-AQI078 WAC 173-405-040(10) Subject to Periodic Monitoring N/A N/A N/A N/A N/A Justification The sections listed to the left are operational in nature and do not require monitoring. N/A 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00050 SC_EVERSPLIT0002194 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 50 of 123 Permit Condition E.5 Parameter Damper position F.10,11,1 2,22,,23,2 4,25 G.6 H.4 B.8.a Operation Operation Operation TRS C.9 TRS G.4 SO2 G.5 H.2 SO2 H.3 SO2 Applicable Requirement(s) DE 78-112 as consolidated in Order DE 96-AQI078 WAC 173-405-040(10) Order DE 96-AQI078 Order DE 96-AQI078 WAC 173-405040(1)(c) WAC 173-405040(3)(b) As consolidated in Order DE 96-AQI078. As consolidated in Order DE 96-AQI078. Subject to Periodic Monitoring N/A N/A N/A N/A N/A N/A N/A Justification State Only Requirement 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00051 SC_EVERSPLIT0002195 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 51 of 123 DISCUSSION ON SPECIFIC PERMIT CONDITIONS Throughout this support document, an asterisk (*) signifies that baseline frequencies specified in the permit may be changed to less frequent testing if conditions outlined in the footnotes of Appendix G of the permit are met. Opacity is an indicator of the performance of the electrostatic precipitator, the particulate matter control device. The use of this monitor as a measure of control device performance is consistent with both U.S. EPA Region 10's interpretation of the applicability of periodic monitoring l and with the intent of the Compliance Assurance Monitoring Rule (40 CFR Part 64), that a reasonable assurance of compliance can be demonstrated through a continuous monitoring program of the add-on control device. The relationship between particulate matter and opacity allows opacity to be used as a compliance indicator but not an absolute particulate emission predictor. For this reason and since no particulate matter continuous emissions monitor is required, direct particulate source testing in conjunction with continuous opacity monitoring system (COMS) will serve as the compliance demonstration method for the particulate matter standard. The Permittee is required to verify compliance with the numerous mass loading standards per unit of time at a required frequency as specified in the permit. As an example, Order DE96-AQI078 limits particulate matter emissions to 476 pounds per day on a rolling annual average reported monthly. There is more than one way to estimate the mass loading limit, including, but not limited to, the utilization of actual emissions factors from the numerous stack test results which were conducted over a long period of time. The other methods include the use of EPA's AP-42 Manual, or the data collected from continuous emission monitoring systems (CEMS) in addition to other certified data such as stack flow rate from the EPA Reference methods. The Permittee will choose the most reliable and economically reasonable method to verify compliance with the applicable requirements. However, a method may provide a good estimation until an emission unit is modified, or there is a change in the method of operation. The Permittee as the consequence may choose another method giving a more reliable and accurate estimation. In this following section, Ecology lists a recommended method to calculate the limit realizing that there may be other ways; therefore, during the course of the permit cycle, the Permittee will advise the Department when another method is selected. Ecology's review and approval are required when the new estimation method is proposed by the Permittee prior to utilization of the new calculation method. Condition A.3, B.2, C.2, D.3, E.2 A continuous opacity monitor system (COMS) may be used as a performance indicator for some emission units. If a COMS is used, the monitor shall take readings and convert the readings into six-minute block averages. For one hour, there shall be 1 Per presentation by US EPA Region 10's Elizabeth Waddell, at October 8, 1997 Title V workshop, and March 19, 1998 Compliance Assurance Monitoring workshop. Each of these workshops were sponsored by the Puget Sound Chapter of the Pacific Northwest International Section of the Air and Waste Management Association. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00052 SC_EVERSPLIT0002196 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 52 of 123 10 six-minute block averages. The first block average of an hour shall be for the time period from 00:00.00 to 00:05.59, the second block average of an hour from 00:06.00 to 00:11.59, and so forth. COMS measurements shall be evaluated once per hour. Corrective actions will commence if, of the 10 six minute block averages in the hour, two or more consecutive blocks are above the given opacity limit, when rounded to the same number of significant digits as the opacity limit. An important note is that deviations measured by the COM do not necessarily correspond to a violation of the underlying applicable requirement (e.g. opacity limit). The Permittee is required to take corrective action anytime opacity is outside of the levels established in the permit. What constitutes corrective action is intentionally left undefined because it is situation specific. Corrective action can include a visual evaluation of actual opacity in response to exceedance of a trigger mechanism. A visual opacity assessment, as used in this permit, is the use of an observer trained in general procedures for determining visible emissions, which could include DOE Method 9B or EPA Method 9. A trained observer does not need to have current certification in Method 9B. Under normal conditions, a trained observer is expected to be present at the facility, while a certified Method 9B observer may not always be readily available. Condition A.4, C.4 In 1980, Ecology initiated a requirement that, where continuous sulfur dioxide monitoring was not being performed, a monthly one-hour test for sulfur dioxide was required for recovery furnaces and lime kilns. Wording has been added to the cited permit conditions to clarify the sampling time duration. The one-hour test of DOE Method 6 is selected for the purpose of periodic monthly source test. For both No. 2 and No. 3 Recovery Furnaces and the Lime Kiln, more frequent monitoring required the use of a minimum operating condition. The frequency of both the application of minimum operating condition and direct source testing is intended to indirectly infer compliance with the permit limitation and is based on best professional judgment of the historical probability of exceeding the limitation and the potential magnitude of an exceedance. I. No. 2 Recovery Furnace Condition A.2 Order DE 96-AQ-I078 limits particulate matter (PM) emissions from the No. 2 Recovery Furnace to 476 pounds of PM per day on a rolling annual average. To show compliance with this limit, the Permittee , on a monthly* basis, evaluates the annual average particulate emissions from the No. 2 Recovery Furnace using actual emissions from previous stack test results. As an example to illustrate how mass loading limit is estimated, the following algorithm can be used. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00053 SC_EVERSPLIT0002197 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 53 of 123 Where: 7 A gr' 7 B dscf' 7 1 lb 1,440 mini lb PM x x x -- C dscf) min ) X 7,000 gr) day ) day A = volumetric grain loading results from the monthly* EPA Method 5 or equivalent samplings (one 1-hour test) B = dry standard air flow rate in cubic feet per minute during the monthly* sampling period C = monthly* average emission rate in pounds per day This monthly* value will then be averaged with the preceding year of readings in lb/day to determine the rolling annual average. Note that the current permit specifies source testing at least annually while the underlying basis of authority (PSD-X-77-04) initially specifies monthly source testing. PSD-X-77-04 allows modification to the source testing frequency. Condition A.4 Sulfur dioxide (SO2) emissions from the No. 2 Recovery Furnace are limited to 500 ppm, corrected to 8 percent oxygen, by WAC 173-405-040(11)(a). Many factors affect emissions of SO2 from recovery furnaces, including mill white liquor sulfidity, black liquor solids feed rate to furnace, furnace temperature, air distribution, and other operational parameters. Because of the numerous variables that affect SO2 emissions, it is difficult to identify parameters that will give some indication of the emissions. According to U.S. EPA-650/2-74-071-a, Improved Air Pollution Control for a Kraft Recovery Boiler: Modified Recovery Boiler No. 3-page 77, white liquor sulfidity is the primary variable affecting SO2 emissions. Over forty percent of SO2 emissions were directly correlated to sulfidity levels. This U.S. EPA study concluded that the best indicator for SO2 emissions is white liquor sulfidity level. Data for the Boise Wallula mill indicate that the No. 2 Recovery Furnace will have reasonable assurance of compliance with WAC 173-405-040(11)(a) when mill white liquor sulfidity does not exceed 33 percent. White liquor sulfidity greater than 33 percent requires the Mill to take corrective action, but is not an indicator of noncompliance. Conditions A.5.a Order DE 96-AQ-I078 limits sulfur dioxide (SO2) emissions from the No. 2 Recovery Furnace to 5,424 pounds per day on a rolling annual average. To show compliance with this requirement, the Permittee will, on a monthly* basis evaluate the annual average SO2 emissions from the No. 2 Recovery Furnace using actual emissions from previous stack test results. As an example to illustrate how mass loading limit is estimated, the following algorithm can be used. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00054 SC_EVERSPLIT0002198 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 54 of 123 Where: r D ppurive x ' B dscf lb S02 r1,440min = E lb S02 x 0.166 x 1x106 mini ft3 S02 , day i day B dry standard air flow rate in cubic feet per minute during monthly* sampling period D DOE Method 6, or equivalent, SO2 concentration based on monthly* sample (one 1-hour test) E monthly* average SO2 emission rate in pounds per day This value will then be averaged with the preceding year of monthly* calculated SO2 emission rates to determine the rolling annual average. The density of sulfur dioxide, 0.166 lb SO2 per cubic foot of SO2, is taken from Method 19. Condition A.7 Opacity is an indicator of the performance of the electrostatic precipitator, the particulate matter control device. The use of this monitor as a measure of control device performance is consistent with both US. EPA's Region 10's interpretation of the applicability of periodic monitoring and with the intent of the Compliance Assurance Monitoring Rule (40 CFR Part 64), that a reasonable assurance of compliance can be demonstrated through a control device performance indicator. With a R2 value of 0.6375 (See table in Appendix E), opacity is a good general indictor of control device performance but is not significant enough to make a direct linear correlation. Nevertheless, the correlation is strong enough to conclude that when the COM reads high opacity readings (above 35%), the control device and/or monitor should be promptly examined to ensure proper operation. Ecology has changed the basis of authority to a new federal regulation. The original condition had been created as part of the gap filling effort. Gap filling is only necessary where no existing regulation adequately addressed compliance. Also removed is the reference to good O&M. The new federal regulation is clear and stipulates compliance requirements. II. No. 3 Recovery Furnace Condition B.1.a Order DE 96-AQ-I078 limits particulate (PM) emissions from the No. 3 Recovery Furnace to 186 tons per year on a rolling annual average basis. To show compliance with this requirement, the Permittee will evaluate the annual average particulate 2 Per presentation by US EPA Region 10's Elizabeth Waddell, at October 8, 1997 Title V workshop, and March 19, 1998 Compliance Assurance Monitoring workshop. Each of these workshops were sponsored by the Puget Sound Chapter of the Pacific Northwest International Section of the Air and Waste Management Association. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00055 SC_EVERSPLIT0002199 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 55 of 123 emissions from the No. 3 Recovery Furnace on a monthly* basis using actual emissions from previous stack test results. As an example to illustrate how mass loading limit is estimated, the following algorithm can be used. (A x dscfi Where: B dscf" ( 1440 x min 1 day ( C ton day x ( 1 lb x ( 1 ton x ( D tons' = ) 7,000 gr) 2,000 lb, month) ton PM month A = volumetric grain loading from the monthly* EPA Method 5 or equivalent samplings (one 1-hour test per month) B = dry standard air flow rate in cubic feet per minute during PM sampling period C = tons of BLS fired in the No. 3 Recovery Furnace on the day sampling is performed D = tons of BLS fired in the No. 3 Recovery Furnace for the month* E = monthly* average emission rate in tons per month* This monthly* value will then be summed with the preceding year of readings to determine the rolling annual average. Condition B.3 Opacity is an indicator of the performance of the electrostatic precipitator, the particulate matter control device. The use of this monitor as a measure of control device performance is consistent with both US. EPA's Region 10's interpretation of the applicability of periodic monitoring3 and with the intent of the Compliance Assurance Monitoring Rule (40 CFR Part 64), that a reasonable assurance of compliance can be demonstrated through a control device performance indicator. Opacity is a good general indicator of control device performance but is not significant enough to make a direct linear correlation. Nevertheless, the correlation is strong enough to conclude that when the COM reads high opacity readings (above 35%), the control device and/or monitor should be promptly examined to ensure proper operation. Condition B.5.a Order DE 96-AQ-I078 limited sulfur dioxide (SO2) emissions from the No. 3 Recovery Furnace to 1,592 tons per year on an annual average basis. Subsequent PSD-01-07 limited SO2 to 1301 tpy as a 12-month rolling average .To show compliance with this requirement, the Permittee will evaluate the annual average SO2 3 Per presentation by US EPA Region 10's Elizabeth Waddell, at October 8, 1997 Title V workshop, and March 19, 1998 Compliance Assurance Monitoring workshop. Each of these workshops were sponsored by the Puget Sound Chapter of the Pacific Northwest International Section of the Air and Waste Management Association. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00056 SC_EVERSPLIT0002200 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 56 of 123 emissions from the No. 3 Recovery Furnace using actual test results and production data. As an example to illustrate how mass loading limit is estimated, the following algorithm can be used. r F ppmve x r B dscf` ( x 0.166 lb SO2 ( x 1 ton \ x r 60min\ x r G hrs \ = H ton SO2 1 x 106 J mill i \ ft 3 SO 2 1 \ 2,000 lb/ hr / month/ month Where: B = dry standard air flow rate in cubic feet per minute during most recent PM sampling period (see above Section II.A) F = SO2 concentration determined by stack test data. G = operating hours per month H = SO2 emission rate in tons per month At the end of the calendar year, the monthly values for the year will be summed to determine the annual average. The density of sulfur dioxide, 0.166 lb SO2 per cubic foot of SO2, is taken from Method 19. Condition B.6 Order DE 96-AQ-I078 (incorporating PSD-95-04) limits nitrogen oxides (NOx) emissions from the No. 3 Recovery Furnace to 825 tons per year on an annual average basis. To show compliance with this requirement, the Permittee will evaluate the annual average NOx emissions from the No. 3 Recovery Furnace using actual test results and CEM data. As an example to illustrate how mass loading limit is estimated, the following algorithm can be used. r I ppmvd' x 1 x 106 I Where: B G I J B dscf x 0.1194 lb NOx x r 60 min x r 1 ton x r G hours -- J ton NO x min / ft3 NOxi hr / X2,000 lb/ month / month dry standard air flow rate in cubic feet per minute during most recent PM sampling period (see above Section II.A) operating hours per month NOx concentration measured by a continuous emission monitoring system. The monthly average will be calculated based on the sum of valid individual hourly averages divided by the total number of valid hourly averages available. NOx emission rate in tons per month At the end of the calendar year, the monthly values for the year will be summed to determine the annual average. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00057 SC_EVERSPLIT0002201 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 57 of 123 The density of nitrogen oxide, 0.1194 lb NOx per cubic foot of NOx, is taken from Method 19. Condition B.7 Order DE 96-AQ-I078 (incorporating PSD-95-04) limits carbon monoxide (CO) emissions from the No. 3 Recovery Furnace to 1,355 tons per year on an annual average basis. To show compliance with this requirement, the Permittee will evaluate the annual average CO emissions from the No. 3 Recovery Furnace using actual test results and production data. As an example to illustrate how mass loading limit is estimated, the following algorithm can be used. ( K ppmve 1 x 106 / Where: B G K L x ( B dscf x (0.0728 lb CO x ( 60 mini x 1 ton x ( G hours -- L min / ft 3 CO) hr / 2,000 lb) month / dry standard air flow rate in cubic feet per minute during most recent PM sampling period (see above Section II.A) operating hours per month CO concentration measured by a continuous emission monitoring system. The monthly average will be calculated based on the sum of valid individual hourly averages divided by the total number of valid hourly averages available. CO emission rate in ton per month ton CO month At the end of the calendar year, the monthly values for the year will be summed to determine the annual average. The density of carbon monoxide, 0.0728 lb CO per cubic foot of CO, is based on a molecular weight of 28 lb/lb mol and an ideal gas volume of standard conditions of 385 ft3/lb mol. Condition B.9 Ecology requires that the compliance determination test be conducted at full load to maximize exhaust temperature and airflow, and thus VOC emissions. Based on best professional judgment, the test will be conducted under conservative conditions. VOC emissions during the normal operation are unlikely to exceed the emissions during the compliance test. During a 2014 Ecology sponsored workshop in Spokane and the last AOP Audit, EPA requested that Ecology specify the basis for the VOC value (e.g. carbon, propane, etc.). Wording has been added to conditions B.10 and B.11 requiring that the basis of the VOC value be specified. The reference method used to determine compliance, EPA Method 25A, allows VOCs to be expressed in terms of propane (or other appropriate organic calibration gas) or in terms of carbon per EPA Method 25A. EPA Method 25A also stipulates the algorithm for conversion from one prescribed form to another based on conversion factors. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00058 SC_EVERSPLIT0002202 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 58 of 123 Condition B.10 Order DE 96-AQ-I078 limits volatile organic compounds (VOC) emissions from the No. 3 Recovery Furnace to 179 tons per year on an annual average basis. To show compliance with this requirement, the Permittee will evaluate the annual average VOC emissions from the No. 3 Recovery Furnace on an annual basis using actual emissions from previous stack test. As an example to illustrate how mass loading limit is estimated, the following algorithm can be used. Where: M N P Condition B.8.b r M lb I N MMBtu r 1 ton x x ton VOC -- P MMBtu) year ) v 2,000 lb/ year VOC concentration in lb/MMBtu from sample test using Method 25A or equivalent method found to be acceptable by the Department, conducted once every five years. annual heat input to the No. 3 Recovery Furnace annual average emission rate in tons per year Order DE 96-AQ-I078 limits total reduced sulfur (TRS) emissions from the No. 3 Recovery Furnace to 27 tons per year on an annual average basis. To show compliance with this requirement, the Permittee will evaluate the annual average TRS emissions from the No. 3 Recovery Furnace using actual stack test information and CEM data. As an example to illustrate how mass loading limit is estimated, the following algorithm can be used. ( lb TRS (13 ppmvd) x r B dscf) x 0.0883 as H 2S 1 x 106 min ) ft 3 TRS I X r 60 mint X / 1 ton r G hrs ) x - hr \2,000 lb' month as H 2S j Where: ton TRS Q as H 2 S month B dry standard air flow rate in cubic feet per minute during PM sampling period G operating hours per month* P TRS concentration measured by a continuous emission monitoring system. The monthly average will be calculated based on the sum of valid individual hourly averages divided by the total number of valid hourly averages available. Q TRS emission rate in ton per month* At the end of the calendar year, the monthly* values for the year will be summed to determine the annual average. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00059 SC_EVERSPLIT0002203 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 59 of 123 The density of total reduced sulfur, 0.0883 lb TRS per cubic foot of TRS, is based on a molecular weight of 34 lb/lb mol and an ideal gas volume at standard conditions of 385 ft3/lb mol. III. Lime Kiln Condition C.1.a through e A performance test was conducted in June 26-28, 2012 to establish surrogate setpoints for maintaining compliance with particulate limits. The results are presented below: Date 6/26/12 run 1 6/26/12 run 1 6/26/12 run 3 Pressure Drop (" H2O) 23.1 23 22.9 Scrubber Lime Mud Recirculation Flow (3-hr avg) (gpm) 551 250 551 250 551 250 Test Result Filterable PM @10% O2 0.024 0.023 0.025 Most restrictive PM limit 0.064 gr/dscf @ 10% O2 6/27/12 run 1 6/27/12 run 2 6/27/12 run 3 22.0 560 200 0.029 22.0 559 200 0.032 22.0 557 200 0.032 6/28/12 run 1 6/28/12 run 2 6/28/12 run 3 21.0 551 200 0.038 21.0 551 200 0.038 22.0 557 200 0.038 Condition C.1.e Order DE 96-AQ-I078 limits particulate matter (PM) emissions from fuel oil combustion in the Lime Kiln to 906 lbs of PM per day on a rolling annual average basis. To show compliance with this limit, the Permittee will, on a monthly' basis, evaluate the annual average PM emissions from fuel oil combustion in the Lime Kiln using actual emissions from previous stack test results. If no fuel oil was fired during the test, results from the most recent test in which fuel oil was fired will be reported. As an example to illustrate how mass loading limit is estimated, the following algorithm can be used. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00060 SC_EVERSPLIT0002204 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 60 of 123 7 A gr' 7 B dscf' 7 1 lb 1,440 mini lb PM x x x -- C dscf) min ) X 7,000 gr) day ) day Where: A volumetric grain loading results from the monthly* EPA Method 5 or equivalent tests (one 1-hour test per month) with the Lime Kiln firing fuel oil B dry standard air flow rate in cubic feet per minute from the most recent monthly* sampling with the Lime Kiln firing fuel oil C monthly* average emission rate in pounds per day from the Lime Kiln when firing fuel oil This monthly* value will then be averaged with the preceding year of Lime Kiln fuel oil based readings to determine the rolling annual average. Order DE 96-AQ-I078 limits PM emissions from natural gas combustion in the Lime Kiln to 466 pounds of PM per day on a rolling annual average. To show compliance with DE 96-AQ-I078, the Permittee will, on a monthly* basis, evaluate the annual average PM emissions from natural gas combustion in the Lime Kiln using the actual emissions from previous stack test. If no natural gas was fired during the test, results from the most recent test in which natural gas was fired will be reported. 7 D gi- x 7 B dscf x 7 1 lb x 1,440 mini lb PM = E dscf) min ) X 7,000 gr) day ) day Where: D volumetric grain loading results from the monthly* EPA Method 5 or equivalent tests (one 1-hour test per month) with the Lime Kiln firing natural gas B dry standard air flow rate in cubic feet per minute from the most recent monthly* sampling with the Lime Kiln firing natural gas E monthly* average emission rate in pounds per day from the Lime Kiln when firing natural gas This monthly* value will then be averaged with the preceding year of Lime Kiln natural gas based readings to determine the rolling annual average. Condition C.2.a The same surrogates are used as ongoing compliance indicators for particulate. Opacity and particulate emissions are positively correlated so the MACT imposed surrogate monitoring for particulate emissions will indirectly limit opacity emissions well below the opacity limit. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00061 SC_EVERSPLIT0002205 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 61 of 123 The Permittee has agreed to verify the relationship between scrubber flow and opacity within 180 days of permit renewal. This will be done by comparing scrubber flow to opacity readings taken by a certified RM 9 observer. The intent of this effort is to verify that scrubber flow much less than the surrogate setpoint for particulate compliance indication is adequate to indicate ongoing opacity limit compliance. Condition C.3 Industry history and source testing have shown that there are no compliance issues with the 500 ppm hourly average SO2 limit due to the alkaline nature of the scrubbing liquid. The physical-chemical properties of the scrubbing medium (i.e. lime dust) and intrinsic design of the scrubber inherently allows for the removal of the SO2. Condition C.4 Lime kiln compliance with the long-term SO2 limit (5 ppm rolling annual average) is also addressed by the wet scrubber. Scrubber parameters that may affect the efficiency to control SO2 are differential pressure, recirculation flow rate, and maintaining sufficient alkalinity in the wet scrubber medium. Scrubber alkalinity is the primary factor affecting SO2 emissions. In April 2012, the lime kiln scrubber throat and recirculation flowrate were reduced to increase particulate capture efficiency. However, these changes also impacted SO2 scrubbing efficiency. As shown in the table below, the SO2 emissions increased to an average of 26.6 ppm @ 10% O2 after the changes (8/8/12 stack test) from an average of 0.6 ppm @ 10% O2 before the scrubber changes (11/8/11 stack test). In order to consistently achieve SO2 annual rolling average of less than 5 ppm, addition of caustic (15% NaOH solution) have been implemented. Several tests engineering tests (30-minute runs) and compliance (1-hour runs) have been run since 2012 to determine the appropriate scrubber parameters (caustic addition rate, differential pressure, and recirculation flow rate). Boise Wallula proposed that caustic addition flowrate be used as the indicator of the performance of the scrubber in minimizing SO2 emissions. Based on the results presented below, Boise Wallula proposed that caustic addition flowrate be maintained at a minimum of 0.25 gpm. Table 11: Lime Kiln Sulfur Dioxide Surrogate Parameters Performance Tests Date SO2 Emission ppm 0, 1 ft! 0 O2 Mud Flow O m 2/16/16 run 1 1.9 208 2/16/16 run 2 1.9 208 Scrubber Parameters Recirc. Flow gpm 700 700 Pressure Inches H2O 26.0 26.2 Caustic Flow gpm 0.25 0.25 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00062 SC_EVERSPLIT0002206 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 62 of 123 Date S02 Emission ppm @ 100 0 02 Mud Flow gpm 2/16/16 run 3 2.3 208 2/16/16 run 1 2.2 207 2/16/16 run 2 2.2 207 2/16/16 run 3 2.3 207 2/25/14 run 1 0.40 200 2/25/14 run 2 0.65 200 2/25/14 run 3 0.86 200 2/14/13 engr. 9.3 215 run 1 2/14/13 engr. 9.0 215 run 2 2/14/13 engr. 6.7 215 run 3 2/14/13 engr. 8.0 215 run 4 2/14/13 engr. 8.2 215 run 5 2/12/13 engr. 2.6 215 run 1 8/30/12 run 1.5 195 1 8/30/12 run 1.4 195 2 8/30/12 run 0.8 195 3 8/8/12 run 1 28.2 200 8/8/12 run 2 23.9 200 8/8/12 run 3 27.8 200 11/8/11 3- 0.6 255 run avg Scrubber Parameters Recirc. Flow gpm 700 Pressure Inches 1-12O 26.2 Caustic Fl OW gpm 0.25 700 26.1 0.50 700 25.7 0.25 550 23.0 0.25 720 28.0 1.0 720 28.0 0.5 550 23.0 0.5 701 25.0 0.0 751 25.0 0.0 801 25.0 0.0 850 25.0 0.0 850 30.0 0.0 710.7 26.0 1.0 726 29.9 1.0 725 30.5 1.0 725 30.5 1.0 725 28.3 0.0 725 30.5 0.0 725 30.2 0.0 1260 29.5 0.0 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00063 SC_EVERSPLIT0002207 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 63 of 123 Condition C.5 Order DE 96-AQ-I078 limits sulfur dioxide (SO2) emissions from the Lime Kiln to 19 pounds per day on a rolling annual average basis. To show compliance with this requirement, the Permittee will, on a quarterly basis, evaluate the annual average SO2 emissions from the Lime Kiln using the actual emissions from previous stack test. As an example of how the emission may be estimated using the actual stack test results, the following calculations may be used. Note that methods of estimation are not inclusive. Where: F ppmve x X B dscf` x 0.166 lb S02 (1,440 1x10 6 min ft3 S02) day = G lb S02 i day B dry standard air flow rate in cubic feet per minute during the most recent quarterly particulate sampling period F quarterly DOE Method 6 or equivalent SO2 concentrations (one 1-hour test per quarter) G quarterly average SO2 emission rate in pounds per day This value will then be averaged with the preceding year of readings to determine the rolling annual average. The density of sulfur dioxide, 0.166 lb SO2 per cubic foot of SO2, is taken from Method 19. Condition C.7.a Flow rate and pressure drop across the scrubber are indicators of the performance of the scrubber in minimizing particulate emissions. By design, the unit is in compliance with the particulate and opacity standards when adequate flow and pressure drop are maintained across the scrubber unit. The surrogate setpoints, as indicators of control device performance, are based on historical evidence, source testing, and good engineering judgment. The use of surrogate parameters as a measure of control device performance is consistent with both US. EPA's Region 10's interpretation of the applicability of periodic monitoring4 and with the intent of the Compliance Assurance Monitoring Rule (40 CFR Part 64), that a reasonable assurance of compliance can be demonstrated through a control device performance indicator. This monitoring method was approved by the U.S. EPA as alternate indicator for lime kiln scrubber performance. 4 Per presentation by US EPA Region 10's Elizabeth Waddell, at October 8, 1997 Title V workshop, and March 19, 1998 Compliance Assurance Monitoring workshop. Each of these workshops were sponsored by the Puget Sound Chapter of the Pacific Northwest International Section of the Air and Waste Management Association. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00064 SC_EVERSPLIT0002208 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 64 of 123 The most recent performance test establishing surrogate setpoints is presented below. Based on the results, Boise Wallula proposed that flow be maintained at a minimum of 550 gpm with a scrubber pressure differential depending on the mud flow rate: >23 "H2O when mud flow >200 gpm and >21.3 "H2O when mud flow 200 gpm. Test results with the surrogates maintained at the proposed setpoints met the most restrictive applicable PM standard of 0.064 gr/dscf. Table 12: Lime Kiln Particulate Surrogate Parameters Performance Tests Date 6/26/12 run 1 6/26/12 run 2 6/26/12 run 3 Method 5 PM gr/dscf 0.024 0.023 0.025 Mud Flow gP m 250 250 250 Scrubber Parameters Flow gpm 551 551 551 Pressure Inches H2O 23.1 23.0 22.9 6/28/12 run 1 6/28/12 run 2 6/28/12 run 3 0.038 0.038 0.035 200 551 21.0 200 551 21.0 200 557 22.0 In addition to the scrubber flow rate requirement, the Permittee will monitor the pressure drop as required by 40 CFR 284(b)(2)(i). Ecology has changed the basis of authority to a new federal regulation. The original condition had been created as part of the gap filling effort. Gap filling is only necessary where no existing regulation adequately addressed compliance. Also removed is the reference to good O&M. The new federal regulation is clear and stipulates compliance requirements. Condition C.9 WAC 173-405-040(3)(b) limits total reduced sulfur (TRS) emission concentrations from the Lime Kiln to 80 parts per million corrected to 10 percent oxygen on a period of two consecutive hours. 40 CFR 60.283(a)(5), reflected in Condition C.7.a, limits TRS emission concentrations from the Lime Kiln to 8 parts per million corrected to 10 percent oxygen. As identified in Order DE 96-AQ-I078, Boise Wallula will operate a continuous emission monitor for TRS on the Lime Kiln with a range of 0 to 30 ppmvd compliance with the 8 ppmvd limit. Boise Wallula will use the results of this monitoring to show compliance with the 80 ppmvd state-only applicable limit as well. Readings at or below 30 ppmvd will be considered in compliance with the 80 ppmvd limit. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00065 SC_EVERSPLIT0002209 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 65 of 123 IV. No. 2 Smelt Dissolving Tank Conditions D.1.a, D.1.b 40 CFR 60.282(a)(2) limits particulate matter (PM) emissions from the No. 2 SDT to 0.2 lb/ton BLS. To show compliance with this requirement, the Permittee will, on a monthly* basis, use results obtained from DOE Method 5 or equivalent. As an example of how the emission may be estimated using the actual stack test results, the following calculations may be used. Note that methods of estimation are not inclusive. IH lb MVP hr j = 'I ton BLS hr lb PM ton BLS Where: H = PM emission rate per hour from monthly* EPA Method 5 or equivalent (one 1-hour test) I tons of black liquor solids combusted in the No. 2 Recovery Furnace during the hour the grain loading sample was taken (daily ton BLS/hours of operation is acceptable) J emission factor in pounds per ton of black liquor solids, hourly average Order DE 96-AQ-I078 limits PM emissions from the No. 2 SDT to 71 pounds of PM per day on a rolling annual average. To show compliance with Order DE 96-AQI078, the Permittee will, on a monthly* basis, evaluate the annual average PM emissions from the No. 2 SDT using actual emissions from previous results. As an example of how the emission may be estimated using the actual stack test results, the following calculations may be used. Note that methods of estimation are not inclusive. 7 K gr 7 B dscf' / 1 lb 7 60 min' lb PM x x x = L dscf/ \ min i 7,000 gri hr i hr Where: B = dry standard air flow rate in cubic feet per minute during sampling period K = volumetric grain loading results from monthly* EPA Method 5 or equivalent sampling (one 1-hour test) L = monthly* average emission rate in pounds per day 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00066 SC_EVERSPLIT0002210 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 66 of 123 This value will then be averaged with the preceding year of readings to determine the rolling annual average. Condition D.3 Flow rate and pressure drop are indicators of the performance of the scrubber, the particulate matter control device. By design, the unit is in compliance with the particulate and opacity standards when adequate flow and pressure drop are maintained across the scrubber unit, as verified in previous source tests. The surrogate setpoints, as indicators of control device performance, are based on historical evidence, source testing, and good engineering judgment. The use of these surrogates as a measure of control device performance is consistent with both US. EPA Region 10's interpretation of the applicability of periodic monitorings and with the intent of the Compliance Assurance Monitoring Rule (40 CFR Part 64), that a reasonable assurance of compliance can be demonstrated through control device performance indicators. Condition D.4 WAC 173-405-040(2) and 40 CRF 60.283(a)(4) limit total reduced sulfur (TRS) emissions from the No. 2 SDT to 0.033 lbs/ton BLS annual average. To show compliance with this requirement, Boise Wallula will, on an annual basis, evaluate the annual TRS emissions from the No. 2 SDT using actual emissions from previous stack test results. As an example of how the emission may be estimated using the actual stack test results, the following calculations may be used. Note that methods of estimation are not exclusive. Where: M N P M lb TRS hr I = P lb TRS N ton BLS' ton BLS hr TRS emission rate per hour from annual testing using Method 16A/6C bag sample or equivalent method. tons of black liquor solids combusted in the No. 2 Recovery Furnace during the time the annual TRS sample was taken annual emission factor in pounds per ton of black liquor solids 5 Per presentation by US EPA Region 10's Elizabeth Waddell, at October 8, 1997 Title V workshop, and March 19, 1998 Compliance Assurance Monitoring workshop. Each of these workshops was sponsored by the Puget Sound Chapter of the Pacific Northwest International Section of the Air and Waste Management Association. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00067 SC_EVERSPLIT0002211 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 67 of 123 Condition D.5 Flow rate and pressure drop are indicators of the performance of the scrubber, the particulate matter control device. By design, the unit is in compliance with the particulate and opacity standards when adequate flow and pressure drop is maintained across the scrubber unit, as verified in previous source tests. The surrogate setpoints, as indicators of control device performance, are based on historical evidence, source testing, and good engineering judgment. The use of surrogates as a measure of control device performance is consistent with both US. EPA Region 10's interpretation of the applicability of periodic monitoring6 and with the intent of the Compliance Assurance Monitoring Rule (40 CFR Part 64), that a reasonable assurance of compliance can be demonstrated through a control device performance indicator. Stack tests done in 2004 indicate the surrogates summarized below assure compliance with the smelt tank particulate limit of 0.2 lbs/ton. Table 13: No 2 Smelt Dissolving Tank Particulate Surrogate Parameters Performance Tests Date Scrubber Differential Pressure (Inches H2O) Scrubber Flow (gPm) Particulate (IbiTon BLSF) 6/30/04 0.5 60 0.03 7/02/04 0.8 61 0.04 7/02/04 0.8 60 0.04 Ecology has changed the basis of authority to a new federal regulation. The original condition had been created as part of the gap filling effort. Gap filling is only necessary where no existing regulation adequately addressed compliance. Also removed is the reference to good O&M. The new federal regulation is clear and stipulates compliance requirements. 6 Per presentation by US EPA Region 10's Elizabeth Waddell, at October 8, 1997 Title V workshop, and March 19, 1998 Compliance Assurance Monitoring workshop. Each of these workshops was sponsored by the Puget Sound Chapter of the Pacific Northwest International Section of the Air and Waste Management Association. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00068 SC_EVERSPLIT0002212 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 68 of 123 V. No. 3 Smelt Dissolving Tank Conditions E.1.b WAC 173-405-040(2) limits particulate (PM) emissions from the No. 3 SDT to 0.3 lbs/ton BLS on an hourly average. To show compliance with this requirement, Boise Wallula will, on a monthly* basis, use results obtained from DOE Method 5 or equivalent. As an example of how the emission may be estimated using the actual stack test results, the following calculations may be used. Note that methods of estimation are not inclusive. Where: A B C iA lb PM` hr i - ( B ton BLS hr i C lb PM ton BLS PM emission rate per hour tons of black liquor solids combusted in the No. 2 Recovery Furnace during the hour the grain loading sample was taken (daily ton BLS/hours of operation is acceptable) emission factor in pounds per ton of black liquor solids, hourly average Condition E.2 The same surrogates are used as ongoing compliance indicators for particulate. Opacity and particulate emissions are positively correlated so the MACT imposed surrogate monitoring for particulate emissions will indirectly limit opacity emissions well below the opacity limit. The Permittee has agreed to verify the relationship between scrubber flow and opacity within 180 days of permit renewal. This will be done by comparing scrubber flow to opacity readings taken by a certified RM 9 observer. The intent of this effort is to verify that scrubber flow much less than the surrogate setpoint for particulate compliance indication is adequate to indicate ongoing opacity limit compliance. Condition E.3 Flow rate and pressure drop are indicators of the performance of the scrubber, the particulate matter control device. By design, the unit is in compliance with the particulate and opacity standards when adequate flow and pressure drop are maintained across the scrubber unit. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00069 SC_EVERSPLIT0002213 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 69 of 123 The surrogate setpoints, as indicators of control device performance, are based on historical evidence, source testing, and good engineering judgment. The use of surrogates as a measure of control device performance is consistent with both US. EPA Region '10's interpretation of the applicability of periodic monitoring and with the intent of the Compliance Assurance Monitoring Rule (40 CFR Part 64), that a reasonable assurance of compliance can be demonstrated through a control device performance indicator. This monitoring method was approved by the U.S. EPA as an alternate indicator for lime kiln scrubber performance and is appropriate to be used on the SDTV. Stack tests done in 2004 indicate the surrogate setpoints summarized below assure compliance with the smelt tank particulate limit of 0.2 lbs/ton. Per presentation by US EPA Region 10's Elizabeth Waddell, at October 8, 1997 Title V workshop, and March 19, 1998 Compliance Assurance Monitoring workshop. Each of these workshops were sponsored by the Puget Sound Chapter of the Pacific Northwest International Section of the Air and Waste Management Association. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00070 SC_EVERSPLIT0002214 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 70 of 123 Table 14: No.3 Smelt Dissolving Tank Particulate Surrogate Parameters Performance Tests Date Scrubber Differential Pressure (H 2 O) Scrubber Flovk (gpm) Particulate (lb/Ton BLSF) 6/15/04 -2 6/15/04 -2 6/17/04 -2 25 0.20 25 0.20 25 0.14 VI. Hogged Fuel Boiler The Boise Wallula mill received approval of the Hogged Fuel Boiler (HFB) and Wet ESP project as part of the No. 3 Recovery Furnace Tri-level Air and related projects PSD construction permit (PSD-01-07) issued June 20, 2002. Along with approval of the No. 3 Recovery Furnace upgrade, the permit included upgrade of the HFB combustion air system and installation of a WET ESP control device for compliance with the Boiler MACT requirements and PM/PM10 emissions limits. Boiler MACT has been incorporated into this AOP renewal effort. Construction of the overfire air and wet ESP project under PSD-01-07 was completed in August 2007 and Ecology was notified of startup of the project on 8/9/07. During this modification, the former wet scrubber was re-purposed as the pre-conditioner for the wet ESP. The scrubber throat was opened all the way and flowrate was decreased to limit the differential pressure across the scrubber but still allow full saturation of the exhaust gas. The low differential pressure and saturated gas allows the Wet ESP to function efficiently. New CEMs for NOx and CO were also installed and operational at the time of startup. Applicable limits for the modified HFB project were already incorporated into the 12/1/04 Title V Air Operating permit as an alternate operating scenario and were applicable following completion of the startup periods and compliance demonstration testing. On 11/29/06 the Boise Wallula Mill received approval from Ecology to burn up to but not more than 12 tons per day of mill derived waste, generated on the mill site. If the Mill determines that it wishes to continue burning mill-derived waste beyond the January 31, 2016 Boiler MACT compliance date, it will need to comply with any applicable Boiler MACT requirements. Other trial material burns have been approved by Ecology, however, the Mill has not submitted complete application materials for formal approval and utilization of these fuels. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00071 SC_EVERSPLIT0002215 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 71 of 123 Condition F.3 Order DE 96-AQ-I078 limits particulate (PM) emissions from the Hog Fuel Boiler to 459 pounds of PM per day on a rolling annual average basis. To show compliance with Order DE 96-AQ-I078, Boise Wallula will, on a quarterly basis, evaluate the annual average PM emissions from the Hog Fuel Boiler using actual emissions from previous stack test results. As an example of how the emission may be estimated using the actual stack test results, the following calculations may be used. Note that methods of estimation are not inclusive. Where: 7 D gr' 7 B dscf' 7 1 lb 1,440 min lb PM x x x - E dscf) min ) X 7,000 gr) day ) day B = dry standard air flow rate in cubic feet per minute during sampling period D = volumetric grain loading results from quarterly EPA Method 5 or equivalent (three 1-hour tests quarterly) E = quarterly average emission rate in pounds per day This value will then be averaged with the preceding year of readings to determine the rolling annual average. Condition F.12 Wet ESP secondary power (derived from measured current and kilovoltage) are indicators of the performance of the precipitator, the particulate matter control device. By design, the unit is in compliance with the particulate and opacity standards when adequate current and voltage are maintained, as verified in previous source tests. The surrogate setpoints, as indicators of control device performance, are based on source testing and good engineering judgment. A performance test done in January 2016 as summarized below indicate the surrogate setpoint of 16 kVA on a 30-day average assure compliance with the HFB particulate limit of 0.026 gr/dscf. Table 15: Hogged Fuel Boiler Particulate Surrogate Parameters Performance Tests Run # Date Wet ESP Secondary Power (kVA) Particulate (gr/dscf) 1 1/20/16 16 2 1/21/16 31 3 1/21/16 24 0.011 0.012 0.009 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00072 SC_EVERSPLIT0002216 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 72 of 123 Opacity readings using Method 9 were also performed for 30 minutes on 1/20/16. The minimum total power input during any 6-minute interval was 19 kVA. The maximum 6-minute opacity reading was 0%. VII. No. 1 and No. 2 Power Boilers On January 31, 2013, the EPA published in the Federal Register the NESHAPs for boilers and process heaters at major sources of air toxics (Boiler MACT) -- 40 CFR 63 Subpart DDDDD. The power boilers are package boilers manufactured by Babcock and Wilcox. No.1 Power Boiler was manufactured in 1958. No. 2 Power Boiler was manufactured in 1960. Both power boilers only burn natural gas but have the capability of burning fuel oil during periods of natural gas curtailment. The power boilers are classified as "units designed to burn gas 1 fuels" [40 CFR 63.7499(1)]. During the most recent permit term, the Mill did not burn fuel oil, despite being permitted to do so. However, the Mill remains permitted to burn oil in the power boilers should the Mill make a fuel switch from gas to oil and become subject to the limits for oil burning boilers. The Mill is permitted to burn either light liquid fuel or heavy liquid fuel in the power boilers. All pollutant limits are the same for either fuel with the exception of particulate matter, as noted in the permit. Boiler MACT has been incorporated into this AOP renewal effort. The No. 1 and No. 2 Power Boilers assure compliance when firing natural gas and fuel oil based on the following calculations: Conditions G.1, H.1 The No.1 and No.2 Power Boilers are limited to 0.1 gr/dscf corrected to 7%, hourly average. For particulate matter (PM) emissionsfrom natural gas: 5 lb PM/MMcf natural gas. (Taken from Table 1.4-2 of AP-42 (10/96) for natural gas combustion in a large industrial boiler.) Fd = 8,710 dscf/MMBtu for natural gas. ("F" factor from 40 CFR, Part 60, App. A, Method 19) Conversion factor of 1,035 MMBtu/MMcf natural gas 5 lb x 1MMcf x 1MMBtu x 7 000 gr x 20.9 -- 7.0 -- 0.003 gr MMcf 1,035 MMBtu 8,710 dscf ' lb 20.9 dscf Therefore, the maximum actual particulate emissions of 0.003 gr/dscf corrected to 7% O2 generated from natural gas combustion are less than the permit limit value of 0.1 gr/dscf. No ongoing compliance demonstration measures are required when firing natural gas. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00073 SC_EVERSPLIT0002217 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 73 of 123 For PM emissionsfromfuel oil: [9.19(S)+3.22] lb/1000 gallons fuel oil. (Taken from Table 1.3-1 of AP-42 (10/96) for fuel oil combustion in a utility boiler.) For 2 percent sulfur content, fuel oil this equates to a particulate matter emission factor of 21.6 lb/1000 gal Fd = 9,190 dscf/MMBtu for oil. ("F" factor from 40 CFR, Part 60, App. A, Method 19) Conversion factor of 141 MMBtu/1000 gallon fuel oil 21.6 lb 1000ga/ 1000 gal 141 MMBtu 1 MMBtu x 7,000 gr x 20.9 -- 7.0 - 0.08 gr 9,190 dscf lb 20.9 dscf Therefore, the maximum actual particulate emissions of 0.08 gr/dscf corrected to 7% O2 generated from fuel oil combustion are less than the permit limit value of 0.1 gr/dscf. No ongoing compliance demonstration measures are required for these permit conditions. Condition G.2 For PM lb/day emissionsfrom natural gas combustion alone: Boiler No. 1 is limited to 229 lb/day of particulate emissions. 5 lb MMcf 1MMcf x 4,718 MMBtu - 22.8 lb 1,035 MMBtu day day The maximum actual PM emissions of 22.8 lb/day are less than the permit limit of 229 lb/day. No ongoing compliance demonstration measures are required when firing natural gas. For PM lb/day emissionsfromfuel oil and natural gas combustion: DE 96-AQ-I078 limits PM emissions from the No. 1 Power Boiler to 229 pounds of PM per day. To show compliance with DE 96-AQ-I078, the Permittee will evaluate the PM emissions from the boiler at least annually using actual fuel uses and emission factors from AP-42 manual. As an example of how the emission may be estimated, the following calculations may be used. Note that methods of estimation are not inclusive. A lb PM day B MMcf X5 lb PM day MMcf Mgal r lb PM x [9.19M + 3.22] day Mgal Where: A = annual average daily PM emission rate in pounds per day (compliance parameter) 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00074 SC_EVERSPLIT0002218 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 74 of 123 B = day C = annual average daily usage of natural gas in million cubic feet per annual average daily usage of fuel oil in thousand gallons per day Emission factor of 5 pounds per million cubic of natural gas was taken from EPA's AP-42 (10/96), Table 1.4-2. Emission factor of 9.19(S) + 3.22 PM/1000 gallon taken from AP-42 (10/96), Table 1.3-1. Condition G.3 For sulfur dioxide (SO2) emissionsfrom natural gas combustion: 0.6 lb SO2/MMcf of natural gas. (Taken from Table 1.4-1of AP-42 (10/96) for natural gas combustion in a large industrial boiler.) lb SO2 0.6 MMcf 1MMcf MMBtu x4,718 1,035 MMBtu day lb SO2 2.7 day According to the calculations, the SO2 emissions based on maximum fuel input of 4,718 MMBtu/day of natural gas are less than the permit limit of 3,025 lbs SO2/day. Thus, no ongoing compliance demonstration measures are required when firing natural gas. For SO2 emissions in pounds per dayfromfuel oil and natural gas combustion: DE 96-AQ-I078, limits SO2 emissions from the No. 1 Power Boiler to 3,025 pounds per day of SO2. To show compliance with DE 96-AQ-I078, the Permittee will evaluate the SO2 emissions from the boiler at least annually using actual fuel uses and emission factor from AP-42 manual. As an example of how the emission may be estimated, the following calculations may be used. Note that methods of estimation are not inclusive Where: B C D S A lbSO2 -- B MMcf x 0.6 lbSO2 day day MMcf C Mgal x 157(S) lb SO2 day Mgal annual average daily usage of natural gas in million cubic feet per day annual average daily usage of fuel oil in thousand gallons per day annual average daily SO2 emission rate in pounds per day (compliance parameter) annual average sulfur content of fuel oil 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00075 SC_EVERSPLIT0002219 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 75 of 123 Emission factor of 0.6 pounds per million cubic of natural gas was taken from EPA's AP-42 (10-96), Table 1.4-1. Emission factor of 157(S) pounds per thousand gallons of fuel oil is from EPA' AP-42 (10/96, Table 1.3-1.) Condition G.3 and Condition H.4 DE 96-AQ-I078 limits combined SO2 emissions from the No. 1 and No. 2 Power Boiler to 8,750 pounds per day of SO2 on a daily basis. For natural gas only combustion Condition G.3 limits the maximum potential SO2 emissions from the No. 1 Power Boiler firing natural gas to 3025 lbs SO2/day. A similar calculation is performed here for the No. 2 Power Boiler: lb SO2 0.6 MMcf 1 MMcf MMBtu lb SO2 x 4,404 -- 2.6 1,035 MMBtu day day According to the calculations, the combined SO2 emissions from the No. 1 and No. 2 Power Boilers are less than the permit limit of 8,750 lbs SO2/day. Thus, no ongoing compliance demonstration measures are required when firing only natural gas in the No. 1 and No. 2 Power Boilers. To show compliance with DE 96-AQ-I078, the Permittee will, on a monthly* basis, evaluate the combined SO2 emissions for each day of the previous month which fuel oil is fired in the No. 1 and/or No. 2 Power Boiler(s) from actual fuel uses. As an example of how the emission may be estimated using the actual fuel uses, the following calculations may be used. Note that methods of estimation are not inclusive. lb SO2 ED1 day FOmi 1000 gal x157(s -- month hrs Teri month lb SO2 I 1000 gal x TDi hrs day FOm2 1000 gal x157(S) lb SO2 ED2 lb SO2 -- month 1000 gal x hrs day Tm2 hrs TD2 day month EDC = ED1 + ED2 Where: ED1, ED2 = daily average SO2 emission rate in pounds per day from the No. 1 Power Boiler or No. 2 Power Boiler, respectively EDC = the combined daily average SO2 emission rate in pounds per day from the No. 1 Power Boiler and No. 2 Power Boiler FOmi, FOM2 = total fuel oil fired from the previous month in the No. 1 Power Boiler or No. 2 Power Boiler, respectively 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00076 SC_EVERSPLIT0002220 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 76 of 123 S= TM1, TM2 = TD1, TD2 For example, if: average sulfur content of fuel oil in the previous month total hours in the previous month that fuel oil was fired in the No. 1 Power Boiler or No. 2 Power Boiler, respectively total hours in a particular day of the previous month that fuel oil was fired in the No. 1 Power Boiler or No. 2 Power Boiler, respectively the No. 1 Power Boiler fired 40,000 gallons of fuel oil for a total of 200 hours in the previous month, the No. 2 Power Boiler fired 25,000 gallons of fuel oil for a total of 175 hours in the previous month, and the sulfur content of the fuel oil is 2% Sulfur, The combined daily emission rate for a day in the previous month where the No. 1 Power Boiler fired fuel oil for 12 hours and the No. 2 Power Boiler fired fuel oil for 6 hours is calculated as follows: 1000 gal (1 lb SO2 40 x 157 2 month 1000 gal x 12 hrs ED1 200 hrs day month 1000 gal (1 lb SO2 25 x 157 2 month 1000 gal x 6 hrs ED2 175 hrs day month lb SO lb SO lb SO ED(' = 754 2 + 269 2 1,023 2 day day day 754 lb SO2 day 269 lb SO2 day Condition G.6 and Condition H.5 DE 96-AQ-I078 limits combined SO2 emissions from the No. 1 and No. 2 Power Boiler to 1,104 tons per year of SO2 on an annual average basis. For natural gas only combustion, under Condition G.3, the maximum potential SO2 emissions from the No. 1 Power Boiler firing natural gas are 2.7 lbs SO2/day. Similarly, under Condition H. 5 the maximum potential SO2 emissions from the No. 2 Power Boiler firing natural gas are 2.6 lbs SO2/day for natural gas only combustion. Thus, the combined annual average maximum potential SO2 emissions from the No. 1 and No. 2 Power Boilers are 0.97 tons/year (2.6 lbs/day + 2.7 lbs/day at 365 days/year and 2000 lbs/ton). Thus, no ongoing compliance demonstration measures are required when firing only natural gas in the No. 1 and No. 2 Power Boilers. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00077 SC_EVERSPLIT0002221 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 77 of 123 To show compliance with DE 96-AQ-I078, the Permittee will, on a monthly* basis, evaluate the combined annual average SO2 emissions from the No. 1 and No. 2 Power Boilers by calculating the sum of the previous 12 months' SO2 emissions. SO2 emissions will only be calculated for those months during which fuel oil was combusted in either the No. 1 and/or No. 2 Power Boilers. As an example of how the emission may be estimated, the following calculations may be used. Note that methods of estimation are not inclusive. ton SO2 _ ( 1000 gal 1000 gals lb SO2 EMC FO,,, + FOM2 xx 157(S) month --' month month 1 1000 gal ton SO2 EA year Where: ton SO2 12 Months Previous EMC month 2,000 lbs Emc = combined monthly* average SO2 emission rate in tons per month from the No. 1 Power Boiler and No. 2 Power Boiler EA - annual average SO2 emission rate in tons per month from the No. 1 Power Boiler and No. 2 Power Boiler FOmi, FOM2 = total fuel oil fired from the previous month in the No. 1 Power Boiler or No. 2 Power Boiler, respectively S = average sulfur content of fuel oil in the previous month Conditions G.4, G.5, and G.6 Conditions G.4, G.5, and G.6 are state-only requirements and are not federally enforceable under the federal Clean Air Act, per DE 95AQ1055 as consolidated in DE 96-AQ1078. Conditions G.11 to G.15 and H.10 to H.14 No fuel oil has been burned on the No. 1 Power Boiler and No. 2 Power Boiler since 2008 due to economic reasons. Permit Conditions G.11 to G.15 and H.10 to H.14 have been added to maintain Boise Wallula's flexibility to burn fuel oil. These conditions address additional compliance demonstration measures required by Subpart DDDDD Boiler MACT when firing fuel oil. VIII. KAMYR Digester and No. 3 Evaporator Set Conditions J.1 and J.2 The KAMYR Digester and No. 3 Evaporator set are subject to the TRS requirements of 40 CFR 60.283(a)(1). 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00078 SC_EVERSPLIT0002222 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 78 of 123 The rule specifies that gases from these units containing TRS in excess of 5 ppmvd, corrected to 10 percent oxygen, shall meet the conditions of 40 CFR 60.283(a)(1)(ivi). Gases from the KAMYR Chip Steaming Vessel do not contain TRS, and therefore do not require control. Gases from the KAMYR Digester, the KAMYR Blow Tank, and the No. 3 Evaporator Set are routed to the KAMYR Condenser. Gases that are not condensed in the KAMYR Condenser are routed to the NCG collection system, which delivers the gases to the Lime Kiln and/or Hog Fuel Boiler for combustion. The temperature and residence time requirements (1200 F for 0.5 seconds) of 40 CFR 60.283(a)(1)(iii) were considered in the design of the NCG collection system, and are met in the design of the Lime Kiln and Hog Fuel Boiler. IX. Chlorine Dioxide Generation Unit Condition K During the 2010 permit renewal effort, Ecology realized the relationship between the R8 scrubber surrogate parameter values and chlorine emissions were not well understood. The validity of the existing surrogate setpoints was in question. Boise Wallula conducted a performance test to clearly establish the relationship between R8 scrubber flow, scrubber medium pH, and scrubber exhaust chlorine emissions. The results are summarized as follows: Table 16: Chlorine Dioxide Generation Unit Surrogate Parameters Performance Tests Parameter Run 1 11/24/09 Run 4 12/2/09 Run 6 12/4/09 Run 7 12/4'09 C12 ppm 0 0 1.7 30.7 Flow gal/min 52.6 51.2 51.3 50.6 pH 13.2 12.6 12.3 11.9 X. Cyclone Box Clipping Collection System Condition L.1 The clippings cyclone unit at the boxplant is operated under a regulatory order with an applicable requirement under the State Implementation Plan (SIP). [WAC 173401-530(2)(c)]. The cyclone is a part of the corrugated paper clipping process and as such is not considered a control device. The particulate emissions from the filter baghouse exhaust are limited to 11.64 tons per year on an annual average. Ecology requires that the Permittee provide an inspection program to ensure compliance with the limitation for the cyclone. An Inspection log will be maintained and made available for review by Ecology. Ecology determines that the emission unit is insignificant compared to other larger units that are required much more effort for 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00079 SC_EVERSPLIT0002223 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 79 of 123 monitoring evaluation and compliance. Thus, Ecology believes that adherence to the inspection program assures ongoing compliance. In addition, when the particulate filter system malfunctions, the Permittee will take a corrective action within 72 hours. The Permittee will also report excursions and corrective action in the monthly report. The operation at the boxplant does not involve combustion so opacity is virtually nonexistent. The permit writer has never noticed emissions from this operation in many years of doing on-site compliance inspections. The vendor suggests that pressure drop be monitored as a performance indicator and Ecology has deferred to the expertise of the vendor. XI. Bleach Plant Condition M.2.b On 1/13/2003, Boise Wallula submitted a notice requesting the use of either pink liquor or white liquor as scrubbing mediums for control of HAPS from the bleaching system. The HAPS in this case is chlorine and the emission limit is 10 ppm. Based on the test results, Ecology approved a minimum scrubber flow of 400 gpm and maintenance of pink liquor ORP at a maximum of -54mv or maintenance of white liquor ORP at a maximum of -302 my. In both cases the scrubber exhaust fan is to be on. The maximum chlorine exhaust residual for both pink and white liquor during the test runs was undetectable at a detection limit of less than 1.13 dry ppm, as chlorine. On 8/20/2015, a performance test was conducted per 40 CFR 63 Subpart S. The results show compliance with the 10 ppm limit for chlorine with a minimum scrubber flow of 400 gpm and white liquor ORP at a maximum of -312 my. Pink liquor was not available during the performance test. DISCUSSION ON GENERAL CONDITIONS General Condition 8 Permit condition 8 is the generic opacity limitation from WAC 173-405-040(6), which addresses kraft mills. Permit conditions 9 and 12 work together to assure compliance with Condition 8 by requiring, first, that facility equipment be maintained and operated "in a manner consistent with good air pollution control practice" and, second, that the Permittee record and promptly respond to complaints received or possible noncompliance noticed by facility staff. Ecology believes that this is a practical and effective way to assure compliance because the emission units covered by this condition do not have control devices that can be monitored and they have a very low risk of producing visible emissions except during process upsets. The Mill is staffed around the clock and all staff are trained to notice and report unusual conditions, such as those associated with upsets. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00080 SC_EVERSPLIT0002224 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 80 of 123 It is a violation of the permit to fail to take corrective action when an instance of possible noncompliance has been reported and found to be valid. Ecology believes that imposing additional monitoring such as a weekly visual inspection would have little value in identifying noncompliance and would, by presence, possibly convey a false sense of compliance. General Condition 10 All fuel combustion units assure compliance when firing natural gas and fuel oil based on the following calculations: a. Sulfur Content Limit When Firing Fuel Oil Fd = 9,190 dscf/MMBtu for residual oil. ("F" factor from 40 CFR, Part 60, App. A, Method 19) (0.02 /bS / lb oil)(21b SO2 I lb S)(385 dscf SO2 / 64lbSO2 ) Cd = (18,750 Btu/ lb oll)(9,190 dscf / MMBtu) or, dscf SO2 C d = 0.00140 =1,400 ppmvd SO2 dscf flue gas Corrected to 7% O2: (1,400 ppmvd SO2 ) x 20.9 - 7.0 - 930 ppmvd SO2 at7%O2 20.9 Therefore, the sulfur content limit of 2% in the fuel oil assures compliance with 1000 ppmvd corrected to 7% O2 as required by WAC 173-405-040(11)(b). No ongoing compliance demonstration measures are required. b. Sulfur Content Limit When Firing Natural Gas 0.6 lb/MMcf of natural gas. (Taken from Table 1.4-1, 1.4-2, & 1.4-3 of AP42, for natural gas combustion in a large industrial boiler.) pV = mRT where, p = 14.7 psia (2166.8 lbf/ft2) R = 24.1 ft-lbf/lbm-R m = 64 lbm T = 538R then, V = 385 Sulfur dioxide emissions in parts per million: lb SO2 1 MMcf 1 MMBtu 385 dscf SO 7 dscf SO2 0.6 x x x 2 - 4 x 10- MMcf 1,035 MMBtu 8710 dscf 64 lb SO2 dscf flue gas =0.4 ppmv SO2 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00081 SC_EVERSPLIT0002225 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 81 of 123 According to the calculations, the sulfur dioxide emissions are less than the limit of 1000 ppmvd. No ongoing compliance demonstration measures are required. For sources other than fuel combustion, Ecology has not imposed monitoring for units unlikely to have a reasonable potential of exceeding SO2 emission limits. Surrogate monitoring for intervals between direct SO2 testing was not imposed because in practice mills do not adjust operating parameters to minimize SO2 emissions. There are no control devices or control strategies to allow this. Instead, SO2 emissions are largely a function of equipment and process design. The nature of the kraft process is optimized by system stability and continuity. Ecology has no basis to believe that process parameters fluctuate to a degree that results in SO2 emissions approaching the 1000 ppm limit and thus warranting surrogate monitoring. REGULATORY ORDERS AND PERMITS The Permittee is subject to several PSD permits and regulatory orders. Order DE 96-AQ-I078 consolidated all previous requirements from past state approvals, orders and letters, which were issued by the state up through October 17, 1996. The first PSD permit, Permit No. PSD-X-7704, was issued by the EPA Region 10 in February 1978. This permit imposes limits for particulate matter, opacity, and sulfur dioxide to limited emission units, including the No. 2 recovery furnace and No. 2 dissolver vent, the lime kiln, the decker hood, the hog fuel boiler, and the No.1 power boiler. The second PSD permit, Permit No. PSD-95-04, was issued by the Washington State Department of Ecology Air Program in September 1995 in accordance with WAC 173-400-141. Additional Orders of Approval and a PSD approval order were issued subsequent to the order consolidation effort completed on October 17, 1996. PSD-01-07 and Order DE 02AQIS-3588 were issued on June 20, 2002 and May 8, 2202 respectively and addressed proposed modifications to No. 3 Recovery Furnace and the Hog Fuel Boiler. STREAMLINING Streamlining is not applicable to the Boise Wallula mill because no streamlining has been done or proposed. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00082 SC_EVERSPLIT0002226 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 82 of 123 INSIGNIFICANT EMISSION UNITS The Table below summarizes the emission units identified by the Permittee in their Title V renewal application as meeting the criteria for insignificant emission units as defined by WAC 173-401-530. Ecology concurs that the units identified below meet the insignificant emission unit criteria. The facility-wide general requirements apply to the whole facility, including insignificant emission units and activities (IEUs), as required by the operating permit rule. The rule states, however, that IEUs are not subject to monitoring requirements unless the generally applicable requirements in the State Implementation Plan (SIP) impose them [WAC 173-401530(2)(c)]. The Washington SIP does not impose any specific monitoring-related requirements for the facility-wide requirements for IEUs at this source. The permit, therefore, does not require any testing, monitoring, reporting, or recordkeeping for insignificant emission units or activities. Table 17: Insignificant Emission Units SIGNIFICANCE* CI 3 CI 3 CI 3 CI 3 CI 4 CI 4 CI 4 CI 4 CI 4 CI 4 CI4 CI 4 CI 5 CI 9 EQUIPMENT NO. BCT-0002 BCT-0003 BCT-0004 BCT-0005 510-3631 510-3632 510-3640 510-3641 510-3642 510-3643 510-3644 940-3631 510-3657 411-3637 AREA NAME Boise Trucking Boise Trucking Boise Trucking Boise Trucking Evaporation & Concentration Evaporation & Concentration Evaporation & Concentration Evaporation & Concentration Evaporation & Concentration Evaporation & Concentration Evaporation & Concentration Water Supply Vent Evaporation & Concentration KAMYR Digester CI 9 411-3639 KAMYR Digester CI 9 412-3630 NSSC Digester CI 9 461-3638 Bleach Plant CI 9 461-3639 Bleach Plant CI 9 461-3640 Bleach Plant CI 9 461-3641 Bleach Plant SOURCE NAME Lubricating Oil Storage (275 gal) Lubricating Oil Storage (275 gal) Lubricating Oil Storage (550 gal) Waste Oil Storage (4000 gal) Soap Skim Tank Hole Soap Skim Tank Hole #3 Soap Skim Level Stand Pipe #1 Soap Skim Level Stand Pipe Soap Skim Tank Hole Soap Skim Tank Hole #2 Soap Skim Level Stand Pipe Potable H20 CLW. Tank Compressed or Instrument Air Vent KAMYR Building Wall Fan KAMYR Building Wall Fan NSSC Digester Wall Fan Exhaust Fan #8 Wall Fan Exhaust Fan #9 Wall Fan Exhaust Fan #10 Wall Fan Exhaust Fan #6 Wall Fan COMMENT Exempt by definition. Exempt by definition. Exempt by definition. Tank contains used motor oil taken from serviced trucks. Exempt by definition. Soap is a surfactant extracted from black liquor. (Also exempt as a weak liquor, CI 93.) Soap is a surfactant extracted from black liquor. (Also exempt as a weak liquor, CI 93.) Soap is a surfactant extracted from black liquor. (Also exempt as a weak liquor, CI 93.) Soap is a surfactant extracted from black liquor. (Also exempt as a weak liquor, CI 93.) Soap is a surfactant extracted from black liquor. (Also exempt as a weak liquor, CI 93.) Soap is a surfactant extracted from black liquor. (Also exempt as a weak liquor, CI 93.) Soap is a surfactant extracted from black liquor. (Also exempt as a weak liquor, CI 93.) Building Ventilation. No emission sources are vented here. Emissions will be calculated for the KAMYR Digester and Blow Tank separately. Building Ventilation. No emission sources are vented here. Emissions will be calculated for the KAMYR Digester and Blow Tank separately. Building Ventilation. No emission sources are vented here, Emissions will be calculated for the NSSC Digester and Blow Tank separately. Building Ventilation. No emission sources are vented here. Emissions will be calculated for each washer, tower, and the scrubber separately. Building Ventilation. No emission sources are vented here. Emissions will be calculated for each washer, tower, and the scrubber separately. Building Ventilation. No emission sources are vented here. Emissions will be calculated for each washer, tower, and the scrubber separately. Building Ventilation. No emission sources are vented here. Emissions will be calculated for each washer, tower, and the scrubber separately. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00083 SC_EVERSPLIT0002227 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 83 of 123 SIGNIFICANCE* EQUIPMENT NO. CI 9 461-3642 CI 9 461-3643 CI 9 461-3644 CI 9 461-3645 Cl 9 461-3646 CI 9 461-3647 CI 9 471-3632 CI 9 471-3633 CI 9 471-3634 CI 9 471-3652 Cl 9 471-3661 CI 9 522-3633 CI 9 540-3631 Cl 9 620-3653 CI 9 712-3640 CI 9 721-3633 CI 9 721-3634 CI 9 741-3643 CI 9 741-3644 CI 9 741-3654 AREA NAME Bleach Plant Bleach Plant Bleach Plant Bleach Plant Bleach Plant Bleach Plant Chemical Preparation Chemical Preparation Chemical Preparation Chemical Preparation Chemical Preparation #2 Recovery Boiler Lime Burning Plant Demineralizing Plant #2 Paper Machine Stock Preparation #1 Pulp Dryer Additive System #1 Pulp Dryer Additive System #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer SOURCE NAME Exhaust Fan #5 Wall Fan COMMENT Building Ventilation. No emission sources are vented here. Emissions will be calculated for each washer, tower, and the scrubber separately. Exhaust Fan #7 Wall Fan Building Ventilation. No emission sources are vented here. Emissions will be calculated for each washer, tower, and the scrubber separately. Exhaust Fan #2 Wall Fan Building Ventilation. No emission sources are vented here. Emissions will be calculated for each washer, tower, and the scrubber separately. Exhaust Fan #4 Wall Fan Building Ventilation. No emission sources are vented here. Emissions will be calculated for each washer, tower, and the scrubber separately. Exhaust Fan #3 Wall Fan Building Ventilation. No emission sources arc vented here. Emissions will be calculated for each washer, tower, and the scrubber separately. Exhaust Fan #1 Wall Fan Building Ventilation. No emission sources are vented here. Emissions will be calculated for each washer, tower, and the scrubber separately. C1O2 Building Air Exhaust Fan Building Ventilation. No emission sources are vented here. Emissions will be calculated for the C102 generator. Cooler, Tower and Scrubbers separately. #3 York Chiller Wall Fan Building Ventilation. Chiller is electric. No emissions sources vented here. C1O2 Building Vent Building Ventilation. No emission sources are vented here. Emissions will be calculated for the C102 generator. Cooler, Tower, and Scrubbers separately. Methanol Building Exhaust Fan Chiller Room Wall Fan Building Ventilation. No emission sources are vented here. Emissions are calculated for Methanol Storage Tank. Building Ventilation. No emission sources are vented here. Recovery #2 Roof Hole Lime Kiln Discharge Building Exhaust Pan Ceiling Fan Vent Building Ventilation. No emission sources are vented here. Emissions are calculated for Recovery Boiler #2 separately. Building Ventilation. No emission sources are vented here. Emissions are calculated for the Lime Kiln and Lime Silos separately. Building Ventilation. No emission sources are vented here. Save All Area Exhaust Pan ASA Wall Fan Building Ventilation. No emission sources are vented here. Save All system contains small pulp fibers. Building Ventilation. No emission sources are vented here. ASA Wall Fan Building Ventilation. No emission sources arc vented here. Paper Machine #1, #2 Wall Exhaust Fan Paper Machine #1, #3 Wall Exhaust Fan Old Starch Make Down Room Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00084 SC_EVERSPLIT0002228 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 84 of 123 SIGNIFICANCE* CI 9 CI 9 EQUIPMENT NO. 741-3655 741-3657 AREA NAME #1 Pulp Dryer #1 Pulp Dryer CI 9 741-3659 #1 Pulp Dryer CI 9 742-3637 #2 Paper Machine CI 9 742-3638 #2 Paper Machine CI 9 742-3639 #2 Paper Machine CI 9 742-3645 #2 Paper Machine CI 9 742-3646 #2 Paper Machine CI 9 742-3648 #2 Paper Machine CI 9 742-3649 #2 Paper Machine CI 9 742-3650 #2 Paper Machine CI 9 742-3651 #2 Paper Machine CI 9 743-3632 #3 Paper Machine CI 9 743-3635 #3 Paper Machine CI 9 743-3639 #3 Paper Machine CI 9 743-3640 #3 Paper Machine CI 9 743-3641 #3 Paper Machine CI 9 743-3643 #3 Paper Machine CI 9 743-3644 #3 Paper Machine CI 9 743-3645 #3 Paper Machine CI 9 743-3650 #3 Paper Machine CI 9 743-3656 #3 Paper Machine CI 9 910-3631 Finish Product Storage CI 9 910-3632 Finish Product Storage SOURCE NAME Pipe Through Roof Paper Machine # 1, #4 Wall Exhaust Fan Paper Machine #1, #3 Roof Exhaust Fan Vent in Paper Machine #2 Wall Paper Machine #2 Pipefitters Exhaust Fan Paper Machine #1 & #2 Aux. Roof Exhaust Fan Paper Machine #2 North Roof Exhaust Fan Paper Machine #2 South Roof Exhaust Fan Paper Machine #2 Silo Exhaust Fan Paper Machine #2 Wall Exhaust Fan North Paper Machine #2 Wall Exhaust Pan Center Paper Machine #2 Wall Exhaust Pan South Dry End Roof Exhaust Fan Size Press Roof Exhaust Fan #1 Main Roof Exhaust Fan False Ceiling Exhaust Fan #3 False Ceiling Exhaust Pan #2 False Ceiling Exhaust Fan H 1 Peculator Area Exhaust Fan Dry End Pulper Exhaust Fan 3 blade Metering Size Press Exhaust Fan Wet End Supply Fan Ceiling Exhaust Fan Ceiling Exhaust Fan COMMENT Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Pipefitters room is a storage area for carts and other tools used. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation, No emission sources are vented here. Building Ventilation. No emission sources are vented here. Contains only steam and heat. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Removes air (heat and steam) from head box. Building Ventilation. No emission sources are vented here. Applies starch to surface of paper. Contains only starch, heat, and steam. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. Building Ventilation. No emission sources are vented here. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00085 SC_EVERSPLIT0002229 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 85 of 123 SIGNIFICANCE* CI 9 CI 9 CI 9 CI 9 CI 9 CI 9 CI 9 CI 9 CI 9 EQUIPMENT NO. 910-3633 910-3634 910-3635 910-3636 910-3637 940-3632 940-3635 940-3639 950-3632 AREA NAME Finish Product Storage Finish Product Storage Finish Product Storage Finish Product Storage Finish Product Storage Water Supply Water Supply Water Supply Shops & Stores CI 9 950-3633 Shops &. Stores Cl 9 950-3635 Shops & Stores CI 9 950-3636 Shops & Stores CI 9 950-3637 Shops & Stores CI 9 950-3642 Shops & Stores CI 9 950-3643 Shops & Stores CI 9 950-3646 Shops & Stores CI 9 950-3647 Shops & Stores CI 9 950-3648 Shops & Stores CI 9 950-3649 Shops & Stores CI 9 950-3650 Shops & Stores CI 9 950-3651 Shops & Stores Cl 9 950-3652 Shops & Stores CI 9 950-3653 Shops & Stores Cl 9 950-3655 Shops & Stores CI 9 950-3656 Shops & Stores CI 9 950-3658 Shops & Stores CI 9 950-3659 Shops & Stores CI 9 950-3661 Shops & Stores SOURCE NAME Ceiling Exhaust Pan COMMENT Building Ventilation. No emission sources are vented here. Ceiling Exhaust Fan Building Ventilation. No emission sources are vented here. Ceiling Exhaust Fan Building Ventilation. No emission sources are vented here. Ceiling Exhaust Fan Building Ventilation. No emission sources are vented here. Exhaust Fan Building Ventilation. No emission sources are vented here. Room Vent Building Ventilation. No emission sources are vented here. Chlorinator MCC Room Vent Building Ventilation. No emission sources are vented here. Ceiling Exhaust Fan Building Ventilation. No emission sources are vented here. Bleach Plant Maintenance Shop Wall Fan Building Ventilation. No emission sources are vented here. Emissions for welding and painting will be addressed under the Bleach Plant Maintenance Shop Exhaust Fan. Bleach Plant Maintenance Shop Wall Fan Building Ventilation- No emission sources are vented here. Emissions for welding and painting will be addressed under the Bleach Plant Maintenance Shop Exhaust Fan. Stores Ceiling Exhaust Fan Building Ventilation. No emission sources are vented here. This building is a warehouse for parts. Machine Shop Ceiling Exhaust Fan Machine Shop Ceiling Exhaust Fan Engineering Office Vent Building Ventilation. No emission sources are vented here. Welding and painting activities will be addressed under the Machine Shop Hood Exhaust Vent. Building Ventilation. No emission sources are vented here. Welding and painting activities will be addressed under the Machine Shop Hood Exhaust Vent. Building Ventilation. No emission sources are vented here. Engineering Office Vent Building Ventilation. No emission sources are vented here. Engineering Office Vent Building Ventilation. No emission sources are vented here. Engineering Office Vent Building Ventilation. No emission sources are vented here. Engineering Office Vent Building Ventilation. No emission sources are vented here. Engineering Office Vent Building Ventilation. No emission sources are vented here. Engineering Office Vent Building Ventilation. No emission sources arc vented here. Engineering Office Vent Building Ventilation. No emission sources are vented here. Engineering Office Vent Building Ventilation. No emission sources tire vented here. Engineering Office Vent Building Ventilation. No emission sources are vented here. Stores Ceiling Exhaust Fan Building Ventilation. No emission sources are vented here. This building is a warehouse for parts. Stores Ceiling Exhaust Fan Building Ventilation. No emission sources are vented here. This building is a warehouse for parts. Paint Factory Air System Exchange Fan All painting emissions will be accounted for under the Paint Shop Hood Exhaust Fan. #2 Paint Factory Air System Exchange Fan All painting emissions wilt be accounted for under the Paint Shop Hood Exhaust Fan. #1 Paint Factory Wall Fan All painting emissions will be accounted for under the Paint Shop Hood Exhaust Fan. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00086 SC_EVERSPLIT0002230 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 86 of 123 SIGNIFICANCE* CI 9 CI 9 EQUIPMENT NO. 950-3662 950-3665 AREA NAME Shops & Stores Shops & Stores CI 9 950-3666 Shops & Stores CI 9 950-3667 Shops & Stores CI 9 950-3668 Shops & Stores CI9 CI 9 CI 32 CI 48 CI 48 CI 48 CI 48 CI 48 CI 48 CI 48 CI 48 CI 48 CI 48 CI 48 CI 48 CI 48 CI 61 CI 61 CI 61 CI 61 CI 61 CI 61 CI 69 CI 69 CP-3637 CP-3654 CP-3650 412-3641 412-3642 743-3630 743-3631 743-3654 743-3655 743-3664 950-3634 950-3641 950-3644 CP-3646 CP-3647 CP-3648 620-3534 620-3630 620-3632 620-3636 620-3654 620-3665 471-3656 471-3657 Corrugated Paper Corrugated Paper Corrugated Paper NSSC Digester NSSC Digester #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine Shops & Stores Shops & Stores Shops & Stores Corrugated Paper Corrugated Paper Corrugated Paper Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Chemical Preparation Chemical Preparation SOURCE NAME Paint Factory Wall Fan Electrical Shop Wall Fan Stores Ceiling Exhaust Fan Machine Shop Ceiling Exhaust Fan Machine Shop Ceiling Exhaust Fan Oil Room Air Exchange Condensate Room Exhaust Fan Wax Room Exhaust Fan Bathroom Vent With Hood Bathroom Vent Bathroom Vent Bathroom Vent Bathroom Vent Bathroom Vent #3 Paper Machine Bathroom Vent Purchasing Bathroom Vent Lab Bathroom Vent Engineering Bathroom Vent Old Bathroom Vent Bathroom Vent With Hood Bathroom Vent #2 Deaerator Tank Dome Vent #1 Deaerator Tank Dome Vent #1 Deaerator Tank Overflow #2 Deaerator Tank Overflow Demineralized Water Storage Tank Vent Degasifier Tank Vent Brim Slurry Tank Vent Brim Slurry Tank Hole COMMENT All painting emissions will be accounted for under the Paint Shop Hood Exhaust Fan. Building Ventilation. No emission sources are vented here. Emissions for welding and painting will be addressed under the Electrical Shop Ceiling Exhaust Fan. Building Ventilation. No emission sources are vented here. This building is a warehouse for parts. Building Ventilation. No emission sources are vented here. Welding and painting activities will be addressed under the machine Shop Hood Exhaust Vent. Building Ventilation. No emission sources are vented here. Welding and painting activities will be addressed under the machine Shop Hood Exhaust Vent. Building Ventilation. No emission sources are vented here. (Could be exempt under Storage of Lubricants, CI 69.) Building Ventilation. No emission sources are vented here. Similar to deaeration. Storage of Aqueous Salt Solution. Storage of Aqueous Salt Solution. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00087 SC_EVERSPLIT0002231 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 87 of 123 SIGNIFICANCE* EQUIPMENT NO. CI 87 400-3631 AREA NAME Pulp Mill CI 87 400-3632 Pulp Mill CI 87 400-3633 Pulp Mill CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 400-3634 400-3635 400-3636 400-3637 411-3630 411-3631 411-3635 430-3651 471-3637 Pulp Mill Pulp Mill Pulp Mill Pulp Mill KAMYR Digester KAMYR Digester KAMYR Digester "B" Row Washers Chemical Preparation CI 87 471-3639 Chemical Preparation CI 87 471-3641 Chemical Preparation CI 87 471-3643 Chemical Preparation CI 87 471-3645 Chemical Preparation CI 87 471-3646 Chemical Preparation CI 87 471-3651 Chemical Preparation CI 87 CI 87 CI 87 CI 87 471-3664 510-3648 510-3660 511-3631 Chemical Preparation Evaporation & Concentration Evaporation & Concentration #1 Evaporator CI 87 511-3632 #1 Evaporator CI 87 511-3633 #1 Evaporator CI 87 511-3634 #1 Evaporator SOURCE NAME COMMENT Low Pressure Steam Safety Valve Vent Low Pressure Steam Safety Valve Vent Low Pressure Steam Safety Valve Vent Low Pressure Steam Safety Valve Vent Low Pressure Steam Safety Valve Vent Low Pressure Steam Safety Valve Vent Low Pressure Steam Safety Valve Vent Flash Steam Vent Flash Steam Vent 160# Steam Vent 160# Steam Safety Valve Vent North C102 Storage Tank Explosion Vent North C102 Storage Tank Explosion Vent North C102 Storage Tank Explosion Vent North C102 Storage Tank Explosion Vent South C102 Storage Tank Explosion Vent South C102 Storage Tank Explosion Vent Methanol Storage Safety Valve Vent R8 Generator Explosion Vent Steam Vent Steam Vent Evaporator # 1 Effect #3 Safety Valve Vent Evaporator #1 Effect #2 Safety Valve Vent Evaporator #1 Effect #1 Safety Valve Vent 50# Steam Safety Valve Vent No emissions. This is a safety valve vent in case of over pressuring. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00088 SC_EVERSPLIT0002232 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 88 of 123 SIGNIFICANCE* CI 87 CI 87 a 87 EQUIPMENT NO. 511-3635 511-3637 512-3631 AREA NAME #1 Evaporator #1 Evaporator #2 Evaporator CI 87 512-3632 #2 Evaporator Cl 87 512-3633 HI Evaporator CI 87 CI 87 512-3635 513-3631 #2 Evaporator #3 Evaporator CI 87 CI 87 CI 87 513-3632 513-3633 513-3634 #3 Evaporator #3 Evaporator #3 Evaporator CI 87 513-3635 #3 Evaporator CI 87 CI 87 CI 87 Cl 87 513-3636 513-3637 513-3638 522-3631 #3 Evaporator #3 Evaporator #3 Evaporator #2 Recovery Boiler CI 87 522-3632 #2 Recovery Boiler CI 87 522-3634 #2 Recovery Boiler CI 87 CI 87 522-3635 522-3637 #2 Recovery Boiler #2 Recovery Boiler CI 87 522-3638 #2 Recovery Boiler CI 87 522-3639 #2 Recovery Boiler CI 87 522-3640 #2 Recovery Boiler CI 87 CI 87 CI 87 522-3641 522-3642 522-3643 #2 Recovery Boiler #2 Recovery Boiler #2 Recovery Boiler SOURCE NAME 50# Steam Safety Valve Vent Steam Vent Evaporator #2 Effect #3 Safety Valve Vent Evaporator #2 Effect #2 Safety Valve Vent Evaporator #2 Effect #1 Safety Valve Vent 50# Steam Safety Valve Vent Evaporator #3 Effect #1 Safety Valve Vent Steam Vent Steam Vent Evaporator #3 Effect #2 Safety Valve Vent Evaporator #3 Effect #3 Safety Valve Vent Steam Vent Steam Vent Relief Vent W\M. Vent #2 Recovery Boiler Safety Valve Vent COMMENT #2 Recovery Boiler Safety Valve Vent #2 Recovery Boiler Safety Valve Vent Steam Vent #2 Recovery Induced Draft Fan Safety Valve Vent #2 Recovery Induced Draft Fan Safety Valve Vent #2 Recovery Induced Draft Fan Safety Valve Vent #2 Recovery Induced Draft Fan Safety Valve Vent Steam Drain Vent 50# Steam Safety Valve Vent #2 Recovery Steam Safety Valve Vent 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00089 SC_EVERSPLIT0002233 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 89 of 123 SIGNIFICANCE* CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 Cl 87 CI 87 CI 87 Cl 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 EQUIPMENT NO. 522-3644 522-3646 523-3631 523-3632 523-3633 523-3634 523-3635 523-3637 523-3639 523-3640 523-3641 531-3634 532-3638 532-3639 532-3640 532-3647 620-3631 AREA NAME #2 Recovery Boiler #2 Recovery Boiler #3 Recovery Boiler #3 Recovery Boiler #3 Recovery Boiler #3 Recovery Boiler #3 Recovery Boiler #3 Recovery Boiler #3 Recovery Boiler #3 Recovery Boiler #3 Recovery Boiler White Liquor Making Pink Liquor Making Pink Liquor Making Pink Liquor Making Pink Liquor Making Demineralizing Plant CI 87 620-3635 Demineralizing Plant CI 87 CI 87 CI 87 Cl 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 620-3637 620-3638 620-3639 620-3640 620-3641 620-3642 620-3643 620-3644 620-3645 620-3646 620-3647 620-3648 620-3649 Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant SOURCE NAME 250# Steam Safety Valve Vent Natural Gas Vent Boiler Safety Valve Vent Superheated Safety Valve Vent #3 Recovery Boiler Safety Valve Vent #3 Recovery Boiler Safely Valve Vent #3 Recovery Boiler Safely Valve Vent #3 Recovery Boiler Safely Valve Vent 160# Steam Safely Valve Vent Steam Safety Valve Vent Steam Safety Valve Vent Boiler Flash Tank Vent Steam Trap Vent Steam Trap Vent Steam Safety Valve Vent Molten Sulfur Safety Valve Vent #1 Deaerator Tank Dome Safety Valve Vent #2 Deaerator Tank Dome Safety Valve Vent 50# Steam Safety Valve Vent 50# Steam Safety Valve Vent Steam Vent 70# 5 team Safety Valve Vent 70# Steam Safety Valve Vent 250# Header Safety Valve Vent 250# Steam Safety Valve Vent 400# Steam Safety Valve Vent 400# Steam Safety Valve Vent 250# Steam Safety Valve Vent 70# Steam Safety Valve Vent Hog Fuel Boiler Safety Valve Vent Hog Fuel Boiler Safety Valve Vent COMMENT Steam Release only. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00090 SC_EVERSPLIT0002234 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 90 of 123 SIGNIFICANCE* CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 EQUIPMENT NO. 620-3650 620-3651 620-3652 620-3655 620-3656 620-3659 620-3660 620-3661 620-3662 620-3663 620-3664 621-3631 AREA NAME Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant Demineralizing Plant #1 Power Boiler CI 87 621-3632 #1 Power Boiler CI 87 621-3633 #1 Power Boiler CI 87 CI 87 CI 87 621-3634 621-3635 622-3631 #1 Power Boiler #1 Power Boiler #2 Power Boiler CI 87 622-3632 H2 Power Boiler CI 87 622-3633 #2 Power Boiler CI 87 622-3634 #2 Power Boiler CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 741-3632 741-3633 741-3634 741-3635 741-3636 741-3637 741-3638 741-3639 741-3642 #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer SOURCE NAME Hog Fuel Header Safety Valve Vent 1 Hog Fuel Header Safety Valve Vent Steam Trap Vent Steam Safety Valve Vent Steam Trap Vent N.C.G. Pressure Safety Valve Vent 70# Steam Safety Valve Vent 70# Steam Safety Valve Vent 70# Steam Safety Valve Vent 50# Steam Safety Valve Vent 70# Steam Safety Valve Vent Power Boiler #1 Steam Safety Valve Vent Power Boiler #1 Steam Safety Valve Vent Power Boiler #1 Steam Safety Valve Vent 50# Steam Safety Valve Vent 50# Steam Safety Valve Vent Power Boiler #2 50# Steam Safety Valve Vent Power Boiler #2 50# Steam Safety Valve Vent Power Boiler #2 Steam Safety Valve Vent Power Boiler #2 Steam Safety Valve Vent 125# Steam Safety Valve Vent 125# Steam Safety Valve Vent 125# Steam Safety Valve Vent 125# Steam Safety Valve Vent 125# Steam Safety Valve Vent 125# Steam Safety Valve Vent 125# Steam Safety Valve Vent Flash Steam Safety Valve Vent 50# Steam Safety Valve Vent COMMENT 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00091 SC_EVERSPLIT0002235 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 91 of 123 SIGNIFICANCE* CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 37 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 CI 87 Cl 87 CI 87 CI 90 CI 92 CI 92 EQUIPMENT NO. 741-3648 741-3651 741-3652 741-3656 741-3658 742-3631 742-3632 742-3633 742-3634 742-3635 742-3636 742-3640 742-3641 742-3642 742-3643 743-3646 743-3647 743-3648 743-3651 743-3652 743-3653 743-3657 743-3658 743-3659 743-3662 743-3665 CP-3651 CP-3652 CP-3653 523-3638 410-3633 410-3634 AREA NAME #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer #2 Paper Machine #2 Paper Machine #2 Paper Machine #2 Paper Machine #2 Paper Machine #2 Paper Machine #2 Paper Machine #2 Paper Machine #2 Paper Machine #2 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine Corrugated Paper Corrugated Paper Corrugated Paper #3 Recovery Boiler Digester Plant Digester Plant SOURCE NAME 125# Steam Vent COMMENT 125# Steam Safety Valve Vent 125# Steam Safety Valve Vent 250# Steam Safety Valve Vent Steam Vent 125# Steam Safety Valve Vent Steam Vent 250# Steam Safety Valve Vent 125# Steam Safety Valve Vent Flash Steam Safety Valve Vent 125# Steam Safety Valve Vent 125# Steam Safety Valve Vent 125# Steam Safety Valve Vent 125# Steam Safety Valve Vent 125# Steam Safety Valve Vent 150# Steam Safety Valve Vent 150# Steam Safety Valve Vent 150# Steam Safety Valve Vent 150# Steam Safety Valve Vent 150# Steam Safety Valve Vent 150# Steam Safety Valve Vent 150# Steam Safety Valve Vent 150# Steam Safety Valve Vent 50# Steam Safety Valve Vent 150# Steam Safety Valve Vent 150# & 250# Safety Valve Vent 200# Steam Safety Valve Vent Condensate Tank Safety Valve Vent Condensate Safety Valve Vent Boiler Blowdown Collection Tank Vent Steam is blown into this unit. #1 M&D Pre Steamer Feed Vent #1 M&D digester is continuous, 6/15/01 letter from Ecology. #2 M&D Pre Steamer Feed Vent #2 M&D digester is continuous. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00092 SC_EVERSPLIT0002236 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 92 of 123 SIGNIFICANCE* EQUIPMENT NO. CI 92 411-3632 AREA NAME KAMYR Digester CI 92 411-3633 KAMYR Digester CI 92 CI 93 CI 93 CI 93 CI 93 CI 93 CI 93 CI 93 411-3634 410-3636 420-3635 420-3636 420-3637 430-3632 430-3633 510-3633 KAMYR Digester Digester Plant "A" Row Washers "A" Row Washers "A" Row Washers "B" Row Washers "B" Row Washers Evaporation & Concentration Cl 93 510-3634 Evaporation & Concentration CI 93 510-3635 Evaporation & Concentration CI 93 510-3637 Evaporation & Concentration CI 93 510-3638 Evaporation & Concentration CI 93 510-3639 Evaporation & Concentration CI 93 510-3647 Evaporation & Concentration CI 93 510-3654 Evaporation & Concentration CI 93 CI 93 CI 93 Cl 93 510-3655 530-3674 530-3677 530-3678 Evaporation & Concentration Liquor Making Plant Liquor Making Plant Liquor Making Plant SOURCE NAME Chip Bin Vent COMMENT Bin serves as a surge tank before the Digester so that production is not halted. Tank contains only chips and some steam from impregnator. The KAMYR digester is continuous. Chip Bin Blower Vent Bin serves as a surge tank before the Digester so that production is not halted. Tank contains only chips and some steam from impregnator. The KAMYR digester is continuous. Chip Dump Bin Vent Filtrate Tanks Foam Vent Bin serves as a surge tank before the Digester so that production is not halted. Tank contains only chips and some steam from impregnator. The KAMYR digester is continuous. The foam produced is a very weak black liquor solution. B-Row Vacuum Pump Vent M&D Row Foam Vent Discharges air and foam from the washer into the foam tanks. Foam consists of weak black liquor. (Could also be exempt as a Vacuum System Exhaust, CI 108.) Foam is off filtrate tanks and contains weak black liquor. M&D Filtrate Tank Vent Contains weak black liquor. Foam Tank Vent Foam is off filtrate tanks and contains weak black liquor. Foam Tank Vent Foam is off filtrate tanks and contains weak black liquor. Combined Condensate Tank Hole No emissions. Combined condensate consists of steam condensate with small amounts of black liquor. The solution is a very weak black liquor. Combined Condensate Tank Vent No emissions. Combined condensate consists of steam condensate with small amounts of black liquor. The solution is a very weak black liquor. Combined Condensate Tank Vent No emissions. Combined condensate consists of steam condensate with small amounts of black liquor. The solution is a very weak black liquor. Combined Condensate Tank Vent With No emissions. Combined condensate consists of steam condensate with small amounts of black Valve liquor. The solution is a very weak black liquor. Boil Out Tank Vent Catch reservoir for contaminated condensate during boil out. Contains only weak black liquor & contaminated condensate. Boil Out Tank Vent With Valve Catch reservoir for contaminated condensate during boil out. Contains only weak black liquor & contaminated condensate. Contaminated Condensate Tank Vent No emissions. Contaminated condensate consists of steam condensate with small amounts of black liquor. The solution is a very weak black liquor. Black Liquor Reclaim Tank Vent No emissions. This tank contains a very weak black liquor solution. This tank collects the wash water from evaporators when they are cleaned. Black Liquor Reclaim Tank Vent Stand Pipe Tank Vent No emissions. This tank contains a very weak black liquor solution. This tank collects the wash water from evaporators when they are cleaned. Black Liquor Storage Tank Vent Weak black liquor storage tank vent. Black Liquor Line Vent This vent is a vacuum break vent on a weak black liquor line. There are no emissions associated with this vent, it sucks air in to prevent siphoning of the tank. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00093 SC_EVERSPLIT0002237 Statement ofBasis for AOP No 0003697 Effective Date: April 1, 2018 Bse Whi PaperL.I Page 93 of123 SIGNIFICANCE* EJIPMITNO. CI 93 530-3679 CI 93 530-3680 CI 93 530-3681 Cl 93 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 94 CI 96 CI 97 CI 98 530-3682 430-3647 430-3649 430-3650 430-3654 430-3655 510-3653 940-3640 940-3641 940-3642 940-3643 741-7180 741-7181 742-7181 742-7182 742-7183 742-7184 742-7185 742-7189 742-7180 743-7180 743-7181 743-7183 743-3660 721-3639 412-3639 AREA NAME Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers Evaporation & Concentration Water Supply Water Supply Water Supply Water Supply Chemical Preparation Chemical Preparation #2 Paper Machine #2 Paper Machine #2 Paper Machine #2 Paper Machine #2 Paper Machine #2 Paper Machine #2 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #1 Pulp Dryer Additive System NSSC Digester SOURCE NAME Contaminated Condensate. Line Vent Black Liquor Line Vent Black Liquor Line Vent Black Liquor Line Vent Process H20 Tank Vent White Water Tank Vent White Water Tank Vent 110 deg H20 Tank Vent 110 deg H20 Tank Vent Cooling H20 Collection Tank Vent Clearwell Tank Vent Clearwell Tank Vent Clearwell Tank Vent Clearwell Tank Vent White Water Tank Couch Pit White Water Tank Couch Pit Waste Water Collection Tank Waste Water Collection Tank White Water Tank White Water Chest Foam Chest White Water Chest White Water Tank Broke And White Water Central Condensate Collection Tank Vent Alum Tank Vent NSSC Stock Vent CoMMENT This vent is a vacuum break vent on a weak black liquor line. There are no emissions associated with this vent, it sucks air in to prevent siphoning ofthe tank. This vent is a vacuum break vent on a weak black liquor line. There are no emissions associated with this vent, it sucks air in to prevent siphoning ofthe tank. This vent is a vacuum break vent on a weak black liquor line. There are no emissions associated with this vent, it sucks air in to prevent siphoning ofthe tank. This vent is a vacuum break vent on a weak black liquor line. There are no emissions associated with this vent, it sucks air in to prevent siphoning ofthe tank. White Water Storage Tank Clean Condensate Collection Pulp Storage tanks 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED 017426 00003078-00094 SC_EVERSPLIT0002238 Statement ofBasis for AOP No 0003697 Effective Date: April 1, 2018 Bse Whi PaperL.I Page 94 of123 SIGNIFICANCE* CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 Cl 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 CI 98 EJIPMITNO. 412-3640 420-3639 420-3640 420-3641 420-3642 420-3643 420-3644 430-3631 430-3634 430-3635 430-3638 430-3640 430-3641 430-3642 430-3643 430-3644 430-3645 430-3646 430-3648 430-3653 731-3631 743-3649 743-3661 743-3666 741-7184 742-7186 742-7187 AREA NAME NSSC Digester "A" Row Washers "A" Row Washers "A" Row Washers "A" Row Washers "A" Row Washers "A" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers "B" Row Washers Waste Paper Pulp #3 Paper Machine #3 Paper Machine #3 Paper Machine Chemical Preparation #2 Paper Machine #2 Paper Machine CI 98 CI 98 CI 99 CI 101 743-7185 743-7186 540-7180 530-3633 #3 Paper Machine #3 Paper Machine Lime Burning Plant Liquor Making Plant SOURCE NAME NSSC Stock Vent CoMMENT Pulp Storage tanks Broke Storage Tank Vent Pulp Storage, repulping tank Broke Storage Tank Vent Pulp Storage, repulping tank Broke Storage Tank Vent Broke Storage Tank Vent Pulp Storage, repulping tank Pulp Storage, repulping tank Broke Storage Tank Vent Pulp Storage, repulping tank Broke Stock Storage Tank Vent Pulp Storage Rotary Feeder Vent Brown Stock Storage Tank Vent Pulp handling equipment Pulp Storage Brown Stock Storage Tank Vent Pulp Storage #10 Hi Density Brown Stock Tank Vent Pulp Storage #6 Hi Density Brown Stock Tank Vent Pulp Storage #6 Hi Density Brown Stock Tank Vent Pulp Storage. #7 Hi Density Brown Stock Tank Vent Pulp Storage #7 Hi Density Brown Stock Tank Vent Pulp Storage #5 Hi Density Brown Stock Tank Vent Pulp Storage #5 Hi Density Brown Stock Tank Vent Pulp Storage #5 Hi Density Brown Stock Tank Vent Pulp Storage B-PRESRC. Chest Tank Vent Stock Chest Blend Pulp Storage Tank Vent Pulp Storage Pulper Hood Exhaust Fan Size Press Pulper Exhaust Fan Building Ventilation. No emission sources are vented here. #3 Paper Machine Press Pit Pulper Saveall Hood Exhaust Fan Repulping operation Bleached Stock Kraft Brown Stock and NSSC STOCK Kraft and NSSC Brown Stock and Broke Broke and Bleached Stock Dorr-Oliver, Brown Stock Saveall Vat Pulp handling equipment Pulp handling equipment Pulp handling equipment Pulp handling equipment Pulp Storage Lime Mud Drum Washer Lime Mud Water slurry Weak Wash Storage Tank Vent Lime Mud Water slurry 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED 017426 00003078-00095 SC_EVERSPLIT0002239 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 95 of 123 SIGNIFICANCE* EQUIPMENT NO. CI 101 530-3653 AREA NAME Liquor Making Plant CI 101 CI 101 Cl 102 530-3655 540-3634 530-3644 Liquor Making Plant Lime Plant Liquor Making Plant CI 102 530-3645 Liquor Making Plant CI 102 530-3646 Liquor Making Plant CI 102 530-3647 Liquor Making Plant CI 102 530-3648 Liquor Making Plant CI 102 530-3649 Liquor Making Plant CI 102 530-3650 Liquor Making Plant CI 102 530-3651 Liquor Making Plant CI 102 530-3652 Liquor Making Plant CI 102 530-3656 Liquor Making Plant CI 102 530-3657 Liquor Making Plant CI 102 530-3658 Liquor Making Plant CI 102 530-3659 Liquor Making Plant CI 102 530-3660 Liquor Making Plant CI 102 530-3661 Liquor Making Plant SOURCE NAME Lime Mud Storage Tank Hole #2 Lime Mud Storage Tank Hole Lime Kiln Mud Storage Tank Vent #1 Mud Washer Tank Vent #1 Mud Washer Headbox Vent #1 Mud Washer Tank Vent #1 Mid Washer Tank Vent #1 Mud Washer Tank Hole #1 Mud Washer Tank Vent #1 Mud Washer Tank Hole #1 Mud Washer Tank Vent #1 Mud Washer Tank Hole #1 Mud Washer Tank Vent Lime Mud Washer Tank Hole #2 Lime Mud Washer Tank Hole #2 Lime Mud Washer Tank Vent #2 Mud Washer Headbox Vent Mud Mix Tank Vent COMMENT Lime Mud Washer: contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Grits Washer, Cl 104.) Lime Mud Washer: contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Grits Washer, Cl 104.) Lime Mud Water slurry Lime Mud Washer; contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, Cl 104.) Lime Mud Washer: contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, CI 104.) Lime Mud Washer: contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer. CI 104.) Lime Mud Washer: contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, Cl 104.) Lime Mud Washer: contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, CI 104.) Lime Mud Washer: contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, CI 104.) Lime Mud Washer: contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer. CI 104.) Lime Mud Washer: contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, Cl 101 and Lime Grits Washer CI 104.) Lime Mud Washer: contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, Cl 104.) Lime Mud Washer: contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer. CI 104.) Lime Mud Washer; contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, CI 104.) Lime Mud Washer; contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, CI 104.) Lime Mud Washer; contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, CI 104.) Lime Mud Washer; contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, CI 104.) Lime Mud Washer; contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, CI 104.) 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00096 SC_EVERSPLIT0002240 Statement ofBasis for AOP No 0003697 Effective Date: April 1, 2018 Bse Whi PaperL.I Page 96 of123 SIGNIFICANCE* EJIPMITNO. CI 102 530-3667 AREA NAME Liquor Making Plant CI 102 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 CI 103 540-3632 530-3662 530.3663 530-3664 530-3665 530-3666 530-3671 530-3672 530-3673 530-3685 530-3686 530-3683 530-3684 531-3631 531-3632 531-3633 531-3635 531-3636 531-3637 531-3638 531-3639 531-3640 531-3641 531-3642 531-3643 531-3644 531-3645 531-3646 531-3647 Lime Burning Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making White Liquor Making SOURCE NAME Lime Mud Washer Tank Vent Lime Kiln Feed Building Exhaust Fan Green Liquor Clarifier Tank Hole Green Liquor Clarifier Tank Hole Green Liquor Clarifier Tank Hole Green Liquor Clarifier Tank Hole Green Liquor Clarifier Headbox Vent Causticizer #1 Tank Hole Causticizer #2 Tank Hole Causticizer #3 Tank Hole Causticizer #4 Tank Vent Causticizer #4 Tank Hole Multipurpose Liquor Clarifier Tank Vent Multipurpose Liquor Clarifier Stand Pipe White Liquor Clarifier #2 Tank Vent White Liquor Clarifier #2 Tank Vent White Liquor Clarifier #2 Tank Vent White Liquor Clarifier #2 Tank Vent White Liquor Clarifier #2 Tank Vent White Liquor Clarifier #2 Headbox Vent #1 White Liquor Clarifier Tank Hole #1 White Liquor Clarifier Tank Vent #1 White Liquor Clarifier Tank Vent #1 White Liquor Clarifier Tank Hole #1 White Liquor Clarifier Tank Hole #1 White Liquor Clarifier Tank Hole #1 White Liquor Clarifier Tank Hole #1 White Liquor Clarifier Tank Hole White Liquor Storage Tank Vent #4 White Liquor Clarifier Tank Vent CoMMENT Lime Mud Washer; contains Lime Mud Water and Lime Grits. (Could also be exempt under Lime Mud Water, CI 101 and Lime Grits Washer, CI 104.) Building contains the lime mud filter (precoat filter). Liquor Clarifier Liquor Clarifier Liquor Clarifier Liquor Clarifier Liquor Clarifier Reaction vessel for green liquor & lime to white liquor. Reaction vessel for green liquor & lime to white liquor. Reaction vessel for green liquor & lime to white liquor. Reaction vessel for green liquor & lime to white liquor. Reaction vessel for green liquor & lime to white liquor. Liquor Clarifier Liquor Clarifier 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED 017426 00003078-00097 SC_EVERSPLIT0002241 Statement ofBasis for AOP No 0003697 Effective Date: April 1, 2018 Bse Whi PaperL.I Page 97 of123 SIGNIFICANCE* EJIPMITNO. CI 103 531-3648 AREA NAME White Liquor Making CI 103 CI 103 CI 103 CI 103 531-3649 531-3650 53 1-36 532-3631 White Liquor Making White Liquor Making White Liquor Making Pink Liquor Making CI 103 532-3632 Pink Liquor Making CI 103 532-3633 Pink Liquor Making CI 103 532-3641 Pink Liquor Making CI 103 532-3642 Pink Liquor Making CI 103 532-3643 Pink Liquor Making CI 103 532-3644 Pink Liquor Making CI 103 532-3645 Pink Liquor Making CI 103 CI 104 CI 104 CI 104 CI 104 CI 104 CI 104 CI 104 CI 104 CI 104 CI 104 CI 104 CI 105 532-3646 530-3631 530-3632 530-3634 530-3635 530-3636 530-3638 530-3639 530-3640 530-3641 530-3642 530-3643 530-3668 Pink Liquor Making Liquor Making Plant Liquor Making Plan! Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant Liquor Making Plant SOURCE NAME #4 White Liquor Clarifier South Tank Vent White Liquor Tank Vent White Liquor Tank Vent White Liquor Flow Box Vent Pink Liquor Tank Vent Pink Liquor Storage Tank Vent Pink Liquor Tank Vent South Sulfiting Tank Vent South Sulfiting Tank Vent North Sulfiting Tank Hole North Sulfiting Tank Hole North Sulfiting Tank Hole North Sulfiting Tank Hole Dregs Washer Tank Vent Dregs Washer lank Vent Dregs Washer Tank Vent Dregs Washer Tank Hole Dregs Washer Tank Hole Dregs Washer Tank Vent Dregs Washer Tank Vent Dregs Washer Tank Hole Dregs Washer Tank Hole Dregs Washer Tank Hole Dreg's Mixer Tank Vent Hot End Scrubber Vent CoMMENT Acidic, inorganic salt solution. Equivalent to White Liquor Storage. (Could be exempt under inorganic salt solution, NC1 2s or weak liquor solution, CI 93.) Acidic, inorganic salt solution. Equivalent to White Liquor Storage. (Could be exempt under inorganic salt solution, NC1 2s or weak liquor solution. CI 93.) Acidic, inorganic salt solution. Equivalent to White Liquor Storage. (Could be exempt under inorganic salt solution, NCI 2s or weak liquor solution, CI 93.) Tank contains Pink Liquor. Acidic, inorganic salt solution. Equivalent to White Liquor Storage. (Could be exempt under inorganic salt solution, NC1 2s or weak liquor solution, CT 93.) Tank contains Pink Liquor. Acidic, inorganic salt solution. Equivalent to White Liquor Storage. (Could be exempt under inorganic salt solution,NC1 2s or weak liquor solution, CI 93.) Tank contains Pink Liquor. Acidic, inorganic salt solution. Equivalent to White Liquor Storage. (Could be exempt under inorganic salt solution, NCI 2s or weak liquor solution. CI 93.) Tank contains Pink Liquor. Acidic, inorganic salt solution. Equivalent to White Liquor Storage. (Could be exempt under inorganic salt solution, NCI 2s or weak liquor solution. CI 93.) Tank contains Pink Liquor. Acidic, inorganic salt solution. Equivalent to White Liquor Storage. (Could be exempt under inorganic salt solution,NC1 2s or weak liquor solution, CI 93.) Tank contains Pink Liquor. Acidic, inorganic salt solution. Equivalent to White Liquor Storage. (Could be exempt under inorganic salt solution,NC1 2s or weak liquor solution. CI 93.) Functionally equivalent to Lime Grits Washer. Functionally equivalent to Lime Grits Washer. Functionally equivalent to Lime Grits Washer. Functionally equivalent to Lime Grits Washer. Functionally equivalent to Lime Grits Washer. Functionally equivalent to Lime Grits Washer. Functionally equivalent to Lime Grits Washer. Functionally equivalent to Lime Grits Washer. Functionally equivalent to Lime Grits Washer. Functionally equivalent to Lime Grits Washer. Functionally equivalent to Lime Grits Washer. Common vent with Lime Silos and feed bins. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED 017426 00003078-00098 SC_EVERSPLIT0002242 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 98 of 123 SIGNIFICANCE* CI 105 CI 106 CI 107 EQUIPMENT NO. 530-3670 743-3642 740-3631 CI 107 740-3633 CI 107 740-3635 CI 107 740-3637 CI 107 740-3639 CI 107 740-3641 CI 107 CI 107 741-3631 742-3607 CI 107 742-3609 CI 107 742-3611 AREA NAME Liquor Making Plant #3 Paper Machine Paper Machine Paper Machine Paper Machine Paper Machine Paper Machine Paper Machine #1 Pulp Dryer #2 Paper Machine #2 Paper Machine #2 Paper Machine CI 107 CI 107 CI 107 CI 107 CI 107 CI 108 CI 108 743-3633 743-3634 743-3636 743-3637 743-3638 060-3633 410-3635 #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine #3 Paper Machine Waste Water Digester Plant CI 108 CI 108 CI 108 CI 108 CI 108 540-3633 741-3645 741-3646 741-3647 741-3649 Lime Burning Plant #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer SOURCE NAME Lime Storage Tank Vent COMMENT Vent from lime silos. Bel Baie Former Exhaust Fan Paper Forming operation. (Paper Machine) Paper Machine #1, #1 Hood Exhaust Fan Paper Machine #1, #2 Hood Exhaust Fan Paper Machine #2, #3 Hood Exhaust Fan Paper Machine #1, #4 Hood Exhaust Fan Paper Machine #1, #5 Hood Exhaust Fan Paper Machine #1, #6 Hood Exhaust Fan Pulp Dryer Beater Exhaust Fan Dryer Exhaust, only contains heat and steam. Dryer Exhaust, only contains heat and steam. Dryer Exhaust, only contains heat and steam. Dryer Exhaust, only contains heat and steam. Dryer Exhaust, only contains heat and steam. Dryer Exhaust, only contains heat and steam. Paper Machine #2, #1 Hood Exhaust Fan Paper Machine #2, #2 Hood Exhaust Fan Paper Machine #2, #3 Hood Exhaust Fan Main Hood Exhaust Fan After Dryer Hood Exhaust Fan Dryer Exhaust, contains only heat and steam. Dryer Exhaust, contains only heat and steam. Dryer Exhaust, contains only heat and steam. Dryer Exhaust, contains only heat and steam. Dryer Exhaust, contains only heat and steam. #3 Main Hood Exhaust Fan Dryer Exhaust, contains only heat and steam. #2A Main Hood Exhaust Fan Dryer Exhaust, contains only heat and steam. #2 Main Hood Exhaust Fan Dryer Exhaust, contains only heat and steam. Sludge Filter Vacuum Pump Vent Pneumatic Air Vent System is exactly like a bank drive through system. In this canister samples from the digester are sent to the lab. Mud Filter Vacuum Pump Vent Paper Machine #1, #2 Couch Vacuum Pump Vent Paper Machine #1, FLAT Box Vacuum Pump Vent Paper Machine 31, UHL Box Vacuum Pump Vent Paper Machine #1, 2ND Press Vacuum Pump Vent 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00099 SC_EVERSPLIT0002243 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 99 of 123 SIGNIFICANCE* EQUIPMENT NO. CI 108 741-3650 CI 108 742-3644 CI 108 CI 108 CI 108 743-3663 743-3667 CI 108 CI 109 CI 109 CI 114 CI 114 CI 115 NCI 2g 721-3632 743-7182 060-3631 060-3632 412-3637 940-3637 NCI 2h BCT-0001 NCI 2p NCI 2s NCI 2s NCI 2s NCI 2s NCI 2s NCI 2s NCI 2s NCI 2s NCI 2s NCI 2s NCI 2s NCI 2s NCI 2s 940-3633 400-3638 471-3653 471-3654 471-3655 471-3658 471-3659 471-3660 471-3662 471-3663 532-3634 722-3631 722-3632 722-3633 AREA NAME #1 Pulp Dryer #2 Paper Machine #3 Paper Machine #3 Paper Machine #1 Pulp Dryer #1 Pulp Dryer #1 Pulp Dryer Additive System #3 Paper Machine Waste Water Waste Water NSSC Digester Water Supply Boise Trucking Water Supply Pulp Mill Chemical Preparation Chemical Preparation Chemical Preparation Chemical Preparation Chemical Preparation Chemical Preparation Chemical Preparation Chemical Preparation Pink Liquor Making #2 Pulp Dryer Additive System #2 Pulp Dryer Additive System #2 Pulp Dryer Additive System SOURCE NAME Paper Machine #1, 3RD Press Vacuum Pump Vent Paper Machine #2 Vacuum Trench Vent Paper Machine #3 Vacuum Pump Vent COMMENT 2nd Stage Vacuum Pump Vent Paper Machine #1, Couch Vacuum Pump Vent Paper Machine #1 1ST Press Vacuum Pump Vent Cooked Starch Vent Cooked Starch Sludge Filter Building Exhaust Fan Sludge Filter Building Exhaust Fan Feed Screw Vent Transfers chips from steaming vessel to impregnation vessel. Contains only steam and chips. Diesel Engine Exhaust Supplies emergency power for #3 well pump and distribution area. Rated at 235 Hp @ 2100 RPM or 598263 BTU/hr which is < 1E6 BTU/hr exemption. (Also exempt under NCI 2n.) Waste Oil Burner Waste oil burner has a maximum heat input of 350,000 Btu/hr which is less than the 0.5 MMBtu/hr exemption. Chlorinator Room Exhaust Fan Sulfuric Acid Storage Tank Vent Chlorinating capacity is 17.7 MMgal/day which is less than the 20 MMgal/day exemption limit. Sulfuric Acid Concentration is <99% Sodium Chlorate Storage Tank Vent Inorganic Salt solution Sodium Chlorate Unloading Tank Vent Inorganic Salt solution 50% Caustic Tank Vent Storage of Base Solution 15% Caustic Soda Tank Hole Storage of Base Solution Caustic Soda Tank Vent Storage of Base Solution Sulfuric Acid Tank Vent Sulfuric Acid Concentration is <99% 50 % Caustic Soda Tank Vent Storage of Base Solution 15% Caustic Soda Tank Vent Storage of Base Solution Caustic Storage Tank Vent Storage of Base Solution Precipitated Calcium Carbonate Stack Vent Precipitated Calcium Carbonate Stack Vent Precipitated Calcium Carbonate Blending Tank Vent Inorganic salt solution. Inorganic salt solution. Inorganic salt solution. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00100 SC_EVERSPLIT0002244 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 100 of 123 SIGNIFICANCE* NCI 2z NCI 2z NCI 2z NCI 2z NCI 3c NCI 3c NCI 3c NCI 3c NCI 3c EQUIPMENT NO. 410-3630 412-3638 422-3630 400-7180 940-3634 950-3645 950-3638 950-3639 950-3640 721-3637 721-3638 NA AREA NAME Digester Plant NSSC Digester Brown Stock Screen Plant Pulp Mill Water Supply Shops & Stores Shops & Stores Shops & Stores Shops & Stores #1 Pulp Dryer Additive System # 1 Pulp Dryer Additive System #3 PM Coater, Coating Kitchen and Tanks SOURCE NAME M&D Washer Exhaust Fan Chip Washer Drum Chip Washer Exhaust Fan Chip Washer Drum Chlorinator Lab Hood Exhaust Fan A.A. Spero Photo Lab Hood Exhaust Fan Lab Hood Exhaust Fan Lab Hood Exhaust Fan Rosin Size Tank Vent Rosin Size Tank Vent COMMENT Chips are washed with water, contains no VOC. Chips are washed with water, contains no VOC. Chips are washed with water, contains no VOC. Chips are washed with water, contains no VOC. Part of the water Chlorinating Facility. Lab photo spectrometer. Tank has been empty and out of use for 10 years. Tank has been empty and out of use for ten years New installation - Ecology letter of insignificances 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00101 SC_EVERSPLIT0002245 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 101 of 123 OPERATIONAL FLEXIBILITY The Mill has requested maximum operational flexibility from the Department of Ecology. Operational flexibility includes production rate flexibility, fuel and raw materials substitution, and other common process changes. The Mill also requested that monitoring, record keeping, and reporting costs be kept to a level that is most cost effective, while still meeting all compliance demonstration and regulatory requirements. PERMIT SHIELD The Boise Wallula mill requested that a permit shield be granted for the renewal permit issued to the Mill. The 2015 proposed Title V Air Operating Permit contains permit shield language pursuant to WAC 173-401-640(1) and 40 CFR Part 70.6(f). PERMIT HISTORY AND CURRENT CHANGES Permit History to Date: The initial AOP was issued to Boise Wallula on December 30, 1998 and expired on December 30, 2003. A deliberate decision was made to let the initial permit carry forward after expiration to simplify the incorporation of new applicable federal standards which were not yet in effect at the permit expiration date. The first permit renewal was issued and became effective on 12/1/2004. The Support Document version 1/7/2005 corresponded to the first renewal of the Title V permit issued to Boise Cascade-Wallula. Boise Cascade subsequently transferred ownership of the Wallula mill to Boise White Paper, L.L.C. Corrections for accuracy, which were considered administrative, were incorporated into the permit on 1/7/2005. A permit modification effort began in 2007 to incorporate anticipated federal regulations referred to as Boiler MACT (40 CFR 63 Subpart DDDDD). The Mill's solid fuel boiler is subject to Boiler MACT because its design heat input is estimated at 362 MMBTU/hr which is greater than the proposed Boiler MACT heat input threshold of 10 MMBtu/hr. The Boiler MACT regulations were vacated by federal court in July 2008 and the permit modification effort was discontinued at that time. National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR 63, Subpart DDDDD) standards were promulgated again on March 21, 2011 per Federal Register 28662. On December 20, 2012, the U.S. EPA finalized a specific set of adjustment to the rules. These standards were effective upon publication in the Federal Register, Volume 78, dated January 31, 2013 (78 FR 1738). The Permittee will comply with the standards starting January 31, 2016 or the applicable standards at a later date if the rule (40 CFR 63 Subpart DDDDD) is again adjusted, or an extension is granted. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00102 SC_EVERSPLIT0002246 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 102 of 123 Permit Changes for the 2010 Renewal Permit: Conditions D.5.a, E.3.a, K.3, M.2.b, M.2.c were modified to better define the regulatory context of the surrogate setpoints, indicating the flexible nature of the surrogates. The surrogate setpoint value is determined through source testing but can be changed as a result of subsequent source testing or performance testing. The source testing used to establish the initial surrogate setpoint is referred to as the initial performance testing (IPT). The permit wording identifies by date the specific performance test establishing a given surrogate setpoint and implies that this setpoint can be changed through subsequent performance testing. The flexibility of changing a surrogate setpoint is set forth in 40 CFR 63.453(n). The NESHAPS reporting and recordkeeping requirements were spelled out further in Condition R. These requirements, as are other applicable requirements, do not have to be set forth in the permit to still be effective and applicable. The Mill suggested inclusion of key requirements in the 2010 Renewal. Condition F was modified to reflect the completion of the Hogged Fuel Boiler over-fire combustion air project. Permit Condition F addressing the Hogged Fuel Boiler had previously been split between pre and post over-fire air requirements. Condition 11 in the Facility-Wide General Requirements Section, previously reserved for future use, was used to include a credible evidence requirement. This was done at the request of local air authorities. Administrative Change as of August 17, 2010: An administrative change was made to permit condition L.1 to reflect changes to the applicable requirement. Order No. DE 95AQI-84 Modification 3 modified the PM emissions limit from the cyclone box clipping collection system baghouse. The corrected PM emissions estimate was brought to Ecology's attention by Boise Wallula as part of the overall corrugator modification project. Condition L.1 was changed to reflect the corrected PM limit of 11.64 tpy and to reflect the changed basis of authority for the limit. Modification and Administrative Changes as of May 3, 2012: Ecology modified the AOP to correct opacity regulations applicable to No. 2 and No. 3 Recovery Furnaces and to make administrative changes to correct regulation citation inaccuracies. No. 2 and No. 3 Recovery Furnaces are identical. A review of applicable opacity requirements indicated the requirements should be the same for both units. The current opacity requirements in the AOP differ and this is believed to be due to different permitting history for each recovery furnace. Both can utilize the same types of fuel but oil was addressed only for No. 3 Recovery Furnace in the current AOP. The proposed permit modifications make the applicable requirements for opacity the same for both recovery furnaces. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00103 SC_EVERSPLIT0002247 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 103 of 123 The proposed permit modifications also reorganize the opacity requirements in a manner intended to clarify and streamline the AOP opacity requirements for No. 2 and No. 3 Recovery Furnaces. Administrative changes were made to correct regulation citations. The permit included incorrectly cited federal standards due to permit condition renumbering since initial permit issuance. The standards themselves had not changed nor had the wording of the standards changed within the permit. Permit Changes for the Current Renewal: The bulk of the changes to the existing permit consisted of incorporation of new applicable requirements. Very minor administrative changes were made to correct citations, spelling, and fix cross referencing within the body of the permit. The new federal applicable requirements incorporated into this permit include Reciprocating Internal Combustion Engine (RICE) standards (40 CFR 63 Subpart ZZZZ and 40 CFR 60 Subpart JJJJ). Also incorporated into this permit are the applicable requirements of Boiler MACT Subpart DDDDD. The compliance date for the new Boiler MACT requirements was January 31, 2016. Condition S, which provides additional discussion of NESHAPS reporting and recordkeeping requirements, has been expanded to reference the requirements of additional NESHAP source categories, and it has been simplified to avoid confusion when describing the numerous requirements currently in effect and scheduled to go into effect. Greenhouse gas reporting to EPA (40 CFR 98) is not considered a federally applicable requirements under Title V and does not need to be included in the Title V permit (see http://www.epa.govinsr/ghgdocsighgpermittingguidance.pdf). WAC 173-441 was adopted by Ecology on December 1, 2010 and became effective on January 1, 2011. This regulation applies to the facility because the facility emits at least 10,000 metric tons of CO2e of greenhouse gases per year. WAC 173-441 requires annual GHG inventories with reports due no later than March 31 of the following year for facilities that are also subject to 40 CFR 98. Under WAC 173-441, annual emissions shall be reported to Ecology beginning in calendar year 2012. This regulation is implemented in its entirety by Ecology and is considered an applicable state-only requirement under the Title V program; as such, it is included as item 32 in the Facility-Wide General Requirements Section of the AOP for the facility. During the 2014 EPA audit of Ecology's implementation of the Title V Program, EPA noted that Ecology's permits had VOC limits but did not specify the basis for the VOC value (VOC as carbon, propane, ethylene, etc.). EPA expressed the interest in permits specifying both the limit and the compliance method. The state-only Permit Condition 33, under Facility-Wide General Requirements provides the linkage through the regulations which stipulate how emissions are calculated. Permit Condition 33 subheading titled "Emissions Calculations" refers to the GHG regulation WAC 173-441. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00104 SC_EVERSPLIT0002248 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 104 of 123 WAC 173-441-050(4) requires the use of calculation methodologies specified in the relevant sections of WAC 173-441 which is WAC 173-441 120 Table 120-1. For the pulp and paper sources this table incorporates methodology set forth in 40 CFR Part 98 Subpart AA. 40 CFR Part 98 Subpart AA sets forth the emission calculation methodology incorporated by a sequence of references in this permit. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00105 SC_EVERSPLIT0002249 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 105 of 123 PUBLIC PARTICIPATION AND RESPONSE TO COMMENTS The first 30-day public comment period for the renewal of this Boise, Wallula AOP took place October 30, 2015 through November 30, 2015. Comments were received only from EPA. The comments are presented below along with Ecology's response. The first 45-day EPA review of the proposed permit began March 29, 2016 and ended May 12, 2016. As a result of trying to resolve regulatory changes and EPA concerns expressed during and since the public comment period, Ecology decided to conduct a second 30-day public comment period. The second public comment period took place December 9, 2016 through January 9, 2017. EPA commented again and focused on how CAM was reflected in the permit. Ecology modified its approach to reflecting CAM in the AOP and a third comment took place October 27 through November 30, 2017. Comments received during the October 30, 2015 through November 30, 2015 public comment period are presented below: Ecology Comment: Ecology has included an additional CO monitoring option set forth in Condition F9 per the request of the Permittee. The monitoring option included is required by Boiler MACT which is incorporated into this permit. The option allows for the use of a continuous emission monitoring device (CEMs) for monitoring CO emissions. The permit had required periodic stack testing for CO using EPA Method 10/10B. The use of the CEM is considered no less restrictive and gives virtually real time compliance indication. Ecology also amended Conditions N.3 and P.1 to remove the phrase, "not including periods of startup, shutdown, and malfunction" to accurately reflect the federal wording of the underlying applicable requirement. The referenced wording had been removed from the federal regulation per court appeal resolution but this permit renewal inadvertently retained the previous wording through the 30-day public comment period. Ecology has amended Conditions F12 and F20. Initially the surrogate setpoints were set forth as separate monitoring of voltage and current. The new single setpoint is secondary power (kVA) which collectively reflects current and voltage. This was done per Boise's request as allowed as a compliance limit choice under the applicable requirement. Comments EPA (Doug Hardesty) submitted the comment below concerning the draft AOP. The comment was submitted by email on 11/24/2015. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00106 SC_EVERSPLIT0002250 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 106 of 123 EPA Comment 1: I see that the Boise White Paper, Wallula, Title V permit is out for public comment. It is my understanding that the Washington Attorney General's office opined that Ecology cannot add MACT requirements to Title V permits until they have been adopted, and that Ecology has not yet adopted the Boiler MACT (40 CFR Part 63, Subpart DDDDD). That explains why the Boiler MACT was not included in the Boise White Paper draft permit. It is EPA's position that you cannot issue a Title V permit that does not include all of the applicable requirements. Unfortunately, you will have to add any missing applicable requirements once adopted and repeat the public review process before sending a proposed permit to EPA. It is also my understanding that Ecology is considering how to get the MACT adoptions up to date. Hopefully that will get done without delaying this permit very long. Letting the adoption staff know that your permit is being delayed until the Boiler MACT is adopted, might help them prioritize the adoption effort. Ecology Response 1: Ecology adopted Boiler MACT on July 1, 2016 and has included the applicable Boiler MACT requirements with this permit renewal effort. Comments EPA (Doug Hardesty) submitted the comments below concerning the draft AOP Support Document. The comments were submitted by email on 11/24/2015. EPA Comment 2: On page 11, in the second paragraph of the CAM section, both sentences are incorrect. Emission units are not exempt for the reasons stated, emission limits that apply to emission units that meet the CAM applicability criteria are. You state this correctly in the middle of page 12 where you list the two exemptions considered. Ecology Response 2: The referenced paragraph on page 11 has been removed. Ecology will rely on the correctly stated wording on page 12 to address CAM exemptions. EPA Comment 3: The paragraph before the two bullets of CAM exemptions in the middle of page 12 is also misleading. A negative finding of any of the three applicability criteria means CAM does not apply to that emission limit, not that specific regulated pollutant. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00107 SC_EVERSPLIT0002251 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 107 of 123 For example, a source may be not subject to CAM for one PM emission limit, but subject to CAM for another PM emission limit. Ecology Response 3: Ecology has attempted to rewrite the referenced wording to clearly conform to EPA's comment intent. EPA Comment 4: The first paragraph after the two bullets of CAM exemptions in the middle of page 12 is also incorrect. Where an emission unit is subject to an NSPS proposed after November 15, 1990 (for example), the emission limits in that NSPS are exempt from CAM, not the emission unit that is subject to NSPS if that emission unit is still subject to other non-NSPS limits. Ecology Response 4: Ecology has attempted to rewrite the referenced wording to clearly conform to EPA's comment intent. EPA Comment 5: The emission limit streamlining discussion near the bottom of page 12 makes sense, except the permit must be written to clarify what the statement of basis implies. Either you need to repeat the monitoring for each limit or you can streamline the limits. To streamline, the citations for both limits can be listed for the more stringent limit while the less stringent limit is left out of the permit entirely and the statement of basis explains it all. In streamlining this way, the permit and statement of basis are consistent in that an exceedance of the most stringent requirement is an exceedance of all the less stringent requirements. Be sure the permittee understands how streamlined monitoring data will be used for compliance purposes because streamlining should be voluntary. We rarely see streamlining like this because it is easy enough to apply the same type monitoring to each of the limits, so compliance with each of the limits can be individually determined. Omitting monitoring requirements to shorten the permit length is not a good reason to streamline. Ecology Response 5: Ecology considers the existing proposed wording to closely conform with the intent of the comment. Where possible, the monitoring requirement has been repeated. This is not always possible because the basis ofauthorityfor the monitoring may not be applicablefor some limits. The AOP cannot create new applicable requirements or attempt to impose inapplicable monitoring requirements. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00108 SC_EVERSPLIT0002252 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 108 of 123 EPA Comment 6: The last paragraph on page 12 is misleading to say any "continuous monitoring requirement" prescribed by the permit is exempt. Only monitoring systems that are continuous compliance determination systems are exempt from CAM. That means that compliance is not just indicated, but determined, by the continuous monitoring system providing data either in units of the standard or correlated directly with the compliance limit consistent with the averaging period. Ecology Response 6: Ecology has attempted to rewrite the referenced wording to clearly conform to EPA's comment intent. Ecology has also changed the CAM evaluation section to show that continuous compliance is determined by the CMS. EPA Comment 7: Opacity, discussed on page 13, is considered a surrogate for particulate matter limits. If an emission unit is subject to CAM for PM emissions, then any applicable opacity limits are subject to CAM if they are not exempt. CAM applicability must be documented for every emission unit meeting CAM applicability for PM, PM10 or PM2.5 that is subject to an opacity limit. The discussion near the bottom of page 13 discusses testing planned for June 2015; this discussion should be updated to reflect the testing that was done or reflect new future test dates. Ecology Response 7: The discussion EPA is referring to within the Fact Sheet is generic. MACT itself often references opacity as a surrogate monitoring parameterfor particulate. Ecology has reviewed the monitoring within the permit. Surrogate monitoringfor particulate and opacity was revisitedfor No. 3 Recovery Furnace and the Lime Kiln as discussed in revised wording included in Permit Conditions B.3 and C.7.a. Other than these two units, the use of opacity as an ongoing surrogatefor PM or HAPs is allowed by the referenced MACT requirement which exempts CAM applicability. Tables 3 and 4 within this Support Document summarize the CAM applicability determination for the mill's emission units. Table 2 has been modified to better summarize the CAM review determinations made in this permit renewal effort. The testing referred to on page 13 has been completed and the results incorporated into the AOP andfact sheet. Thefact sheet has been adjusted accordingly. EPA Comment 8: Table 2 presents CAM applicability for each emission unit, but presents it by pollutant rather than by emission limit. The table should discuss each emission limit for each pollutant for which each emission unit is subject to CAM. Presenting the answer to each of the three applicability questions would enhance the table nicely. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00109 SC_EVERSPLIT0002253 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 109 of 123 For example, if the No 2 recovery furnace meets the three criteria for CAM applicability for PM, the table should discuss whether each PM (and surrogate) emission limit is subject to CAM. There could easily be several lines in the table addressing PM applicability for each emission unit. In most cases, one line should be for opacity. Where the table notes that the control device is not necessary for compliance or that there are no applicable emission limits for a particular pollutant, the table is adequate unless particular assumptions (e.g. whether an emission unit meets a limit without an existing control device) have not been documented. Where an emission unit does not meet the pre-control emission threshold, the statement of basis should document that analysis. Ecology Response 8: Table 3 and Table 4 have been modified to better summarize CAM review determinations made in this permit renewal effort. Ecology notes that thefact sheets themselves are not legally binding documents. Table 2 is a voluntary inclusion intended as an aid. Each permit writer and permit reviewer may have differing perspectives on how best to present information. EPA Comment 9: I can provide more detailed comments when additional explanations about CAM applicability are available. Ecology Response 9: Comment noted. Comments received during EPA's second 45-day review period are presented below: EPA (Doug Hardesty) sent the following e-mail, received on 6/7/16, concerning the Boise AOP Permit and Support Document. EPA Comment 10: I finally had a chance to look at your CAM analysis for the Boise White Paper permit that was retracted on May 5 to allow time for Ecology to update the MACT adoptions. I am including my previous comments on CAM in the email below as many of those comments still apply. After reading this, if you would like to discuss CAM in more detail, please let me know. I'd also be willing to review your next CAM analysis prior to seeing the next proposed permit if that helps. While you corrected some of the general statements in the statement of basis text about CAM, Table 2, documenting your CAM applicability decisions, has not addressed all of the applicable requirements and may be relying upon incorrect assumptions. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00110 SC_EVERSPLIT0002254 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 110 of 123 As noted in my second and third comments below, CAM applicability must be evaluated for each applicable requirement that applies to a pollutant-specific control device. If an emission unit is subject to a MACT standard as well as a SIP requirement, the emission unit could still be subject to CAM for the SIP requirement. That is the case even if the permit requires the same monitoring to assure compliance for both applicable requirements. Using the same monitoring for both emission units to satisfy CAM does not exempt the SIP requirement from CAM. An example is permit condition A.1.a which appears to be both a MACT standard as well as a PSD permit requirement. While the MACT standard is exempt (as noted in Table 2), the PSD permit requirement is not and should be addressed separately in Table 2. To that end, if you provide copies of the referenced PSD permits and their amendments, that will help facilitate our review. Streamlining requirements in the permit by identifying the most stringent requirement or monitoring and then referring other, less stringent, monitoring requirements to that requirement does not exempt the less stringent requirements from CAM. Using the same monitoring for both requirements is acceptable as long as the monitoring for the emission unit subject to CAM meets CAM. As noted in my sixth comment below, opacity is an applicable requirement that must be addressed in CAM. If an emission unit has a particulate control device and pre-control particulate emissions greater than 100 tons per year, CAM applies to the opacity limit unless that limit is exempt for some other reason. Your statement near the top of page 13 in the statement of basis that "opacity has no mass so applicability of CAM for opacity is not appropriate" is incorrect. The discussion that follows on page 13 regarding opacity compliance is good but does not belong in the CAM applicability analysis and does not justify exempting opacity from CAM. Table 2 in the statement of basis does not indicate whether there are controls, one of the key questions regarding CAM applicability. The only place I could find a description of controls was in a table on page 25 of the statement of basis, but that list did not look complete -- there were no controls listed for the hogged fuel fired boiler. I recommend adding a column describing the control device(s) and which pollutant(s) the device(s) control. That is a good first step in the CAM applicability decision tree. In Table 2, several CAM applicability explanations state "subject to requirements of Part 70 permit specifying a continuous compliance determination method" for emission units that do not have continuous compliance determination monitoring. I'd like to discuss this to understand your reasoning. Also in Table 2, where the explanation of the CAM decision states "pre-control emissions of specific pollutant would not classify as major source", there should be emissionrelated documentation to support that claim in the statement of basis. Table 1 in the statement of basis presents a summary of the actual to potential emissions for the plant. It includes a column labelled CAM Requirement, with "no" listed for each pollutant. As you know, CAM applicability is determined on the emission unit level basis. It is not clear what the purpose is of the CAM column in this table? 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00111 SC_EVERSPLIT0002255 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 111 of 123 The permit cites the CAM regulation as an authority for four different emission units: C.7.a, E.3.a, J.2 and L.1. Did you intent those emission units to be subject to CAM in Table 2 of the statement of basis? Assuming you will identify several emission units subject to CAM when you re-examine CAM applicability, you will then need a separate analysis in the statement of basis that explains what CAM is -- that is, the monitoring and other requirements being added to the permit to meet the CAM requirements in Part 64. While monitoring that already exists in the permit might satisfy CAM for some emission units and applicable requirements, the statement of basis should provide your justification for those decisions. Once you have re-examined CAM applicability, depending on the outcome, you may need to revise your responses to my original comments in the public participation section of the statement of basis. I believe Judy Schwieters in your office is working on a CAM guidance document. She presented her approach for making CAM applicability determinations at the 2014 Region 10 Title V Workshop held in Spokane and seemed to have some good ideas. She could be a good resource for examples of text and a table that efficiently documents CAM applicability. Please let me know if you like to discuss CAM in more details. Ecology Response 10: Ecology has worked to enhance the CAM evaluation and clarify the decisions made in evaluating CAM applicability. The Support Document has been enhanced and worked through both by Ecology and the Permittee to try and best address EPA's concerns. Comments received during the October 27 through November 30, 2017 public comment period are presented below: EPA Comment Thanks for sharing the draft Part 70 permit for the Boise White Paper Wallula facility again. As we discussed before the comment period began, I am providing my comments on the draft regarding the compliance assurance monitoring requirements that apply. Most of my comments suggest better documentation of the CAM analysis which concludes which pollutant specific emission units are subject to CAM and what the resulting compliance assurance monitoring should be. Without clear documentation, it is impossible to conclude whether the permit meets 40 CFR Parts 70 or 64. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00112 SC_EVERSPLIT0002256 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 112 of 123 Statement of Basis: 1. On page 12, under the subtitle Plan Content, the citation in the first sentence should just be 40 CFR 64, rather than 64.3. Ecology Response: The suggested change has been made. 2. On page 14, Table 3 should note that the control for the lime kiln is a wet scrubber (not an ESP). I also assume that the caustic addition controls both SO2 and TRS. If that is correct, the third column should say "yes" and additional analysis should be done to determine applicability. If the caustic addition is not needed to comply with the TRS emission limit, that should be explained. There is a chance that the precontrol TRS emissions do not exceed the CAM threshold. Whether the caustic addition is needed for TRS and whether the pre-control emissions exceed the CAM threshold can be explained in the CAM Applicability/Monitoring Details section of the statement of basis, on page 25, where the precontrol SO2 emissions are discussed. Ecology Response: The correction has been made in Table 3. Caustic is added to control SO2 but not TRS as the lime kiln itself thermally oxidizes introduced TRS. There is no additional control device for TRS as the oxidized result is the transformation of TRS into SO2 in the lime kiln. 3. In Table 4, permit condition A.1.a is missing the NSPS emission limit, 40 CFR 60.282(a)(1)(i). Adding that limit should not change anything. Ecology Response: The suggested change has been made. 4. In Table 4, permit conditions A.3.a, A.3.b, B.2.a and B.2.b do not require continuous compliance determination monitoring (column 6 should say "no"). Permit conditions A.3.b and B.2.b is still exempt from CAM because the limit was proposed after 1990. I suggest looking at the revisions to NSPS subpart BB to see whether the monitoring sections have been revised since 1990. If those sections have been revised, such that CAM-level monitoring was added, permit conditions A.3.a and B.2.a are also exempt (and column 5 would say "yes). If permit conditions A.3.a and B.2.a are not exempt, the opacity limits should be further evaluated for CAM. Ecology Response: Table 4 has been updated as indicated for Permit Conditions A.3.b. and B.3.b. Permit Conditions A.3.a and B.2.a have been clarified in the permit to indicate that EPA Method 9 is the reference test method for the performance test for opacity and that the facility must monitor continuously with a COMS. Therefore, the facility does have a continuous compliance determination method for the opacity standard under 40 CFR Part 60, Subpart BB. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00113 SC_EVERSPLIT0002257 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 113 of 123 5. In Table 4, permit condition C.1.b should be 40 CFR 60.282(a)(3). This looks like a typo. Ecology Response: The suggested change has been made. 6. On page 22, before the section on the #2 recovery boiler, you could note that the additional information you will be adding regarding my comment #2 above. Ecology Response: Comment noted but not implemented. See Response to Comment 2, above. 7. On page 22, the #2 recovery boiler PM/opacity section should: a. Use emission test data to show that the 20% opacity limit (parameter range) will assure that each applicable limit will be met. b. Demonstrate which limit is the most stringent if relating opacity to only one applicable emission limit. Ecology Response: Condition A.1.a sets the PM/HAP limit at 0.044 gr/dscf and EPA's own regulation (40 CFR 63.864(k)(1)(i)) cites opacity at 20% as the ongoing monitoring threshold for initiating corrective action. Condition A.1.a is a more restrictive limit than that set forth in Condition A.1.b (0.1 gr/dscf). Conditions A.2.a, b, and c are mass limits for which compliance is demonstrated using the source test results required by Condition A.1.a. Based on the fact that facility has maintained compliance with the mass limits previously, Ecology believes that compliance assurance monitoring associated with Condition A.1.a will continue to adequately assure compliance with the subsequent PM limitations. 8. On page 23, the #3 recovery boiler PM/opacity section should: a. Demonstrate that the grain loading limit is the most restrictive limit; if that is not possible, the opacity thresholds should be set for each applicable emission limit to assure compliance. Ecology Response: Wording has been added to Condition B.1.a clarifying that the results from the most recent source test will be used in determining mass loading. Condition B.1.a includes the most restrictive short term limit (0.021 gr/dscf at 8% O2), which is more restrictive than the short term limits set forth in Condition B.1.b (0.044 gr/dscf) and B.1.c (0.10 gr/dscf @ 8% O2). Condition B.1.a also includes a mass limit for which compliance is demonstrated using the source test results required by Condition B.1.a. Based on the fact that facility has maintained compliance with the mass limits previously, Ecology believes that compliance assurance monitoring associated with Condition B.1.a will continue to adequately assure compliance with all of the PM limitations. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00114 SC_EVERSPLIT0002258 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 114 of 123 9. On page 24, the lime kiln PM/opacity section should: a. Present the emission test data that shows that the scrubber parameter thresholds will assure that each applicable limit (including opacity) will be met. b. Demonstrate which limit is the most stringent if relating the scrubber parameters to only one applicable emission limit. Ecology Response: As indicated in Permit Condition C.7.a., the scrubber parameter thresholds are based on the performance test results from June 26-28, 2012. Please refer to the "Discussion on Specific Permit Conditions", Section III (Page 58) of this document for the measured emissions from that performance test. Condition C.1.e is a mass limit for which compliance is demonstrated using the source test results required by Condition C.1.c. Based on the fact that facility has maintained compliance with the mass limits previously, Ecology believes that compliance assurance monitoring associated with Condition C.7.a will continue to adequately assure compliance with the subsequent PM limitations. With respect to opacity, Condition C.2.a has been modified to require the mill to conduct an EPA Method 9 test to confirm the validity of relying on the surrogate parameters set forth in Condition C.7.a for ongoing compliance. 10. On page 25, a section similar to the lime kiln sulfur dioxide section could be added to address TRS -- whether the controls are needed and whether the pre-control TRS emissions meet the CAM applicability threshold. Ecology Response: Table 3 summarizes the conditions that must be met for CAM applicability. As discussed in Response to Comment 2 above, there is no control device added to the kiln to address TRS emissions. 11. On page 25, the #2 smelt dissolving tank PM/opacity section should: a. Present emission test data that shows that the scrubber parameter thresholds will assure that each applicable limit (including opacity) will be met or add different monitoring approach for the other limits. b. Demonstrate which limit is the most stringent if relating the scrubber parameters to only one applicable emission limit. Ecology Response: As indicated in Permit Condition D.5.a, the scrubber parameter thresholds were established from the initial performance test (IPT) that was conducted on July 2, 2004. A summary of the test results showing the relationship between the surrogate setpoints and the most restrictive limit has been included in Table 13 of this document. Refer to the discussion about the #2 smelt dissolving tank on page 66 for this table. Condition D.2 is a mass limit for which compliance is demonstrated using the source test 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00115 SC_EVERSPLIT0002259 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 115 of 123 results required by Condition D.1.a. Based on the fact that facility has maintained compliance with the mass limits previously, Ecology believes that compliance assurance monitoring associated with Condition D.5.a will continue to adequately assure compliance with the subsequent PM limitations. A requirement has been included into Condition D.3 affirming that opacity will be well below the 35% limit if the surrogate setpoints defined in Condition D.5.a are maintained. Ecology notes that currently the #2 recovery furnace and #2 smelt tank are in layup and not in current use. 12. On page 26, the #3 smelt dissolving tank PM/opacity section should: a. Present emission test data that shows that the scrubber parameter thresholds will assure that the opacity limit will be met or add different monitoring approach for opacity. b. Demonstrate which limit is the most stringent if relating the scrubber parameters to only one applicable emission limit. Ecology Response: As stated in Permit Condition E.t.a, the scrubber parameter thresholds were established with the IPT that was conducted on June 15, 2004. The results of that IPT are presented in Table 5 on page 27 of this document. The results of the test indicate that the facility is in compliance with both of the short term PM limits associated with #3 smelt dissolving tank. A requirement has been included into Condition E.2 affirming that opacity will be well below the 35% limit if the surrogate setpoints defined in Condition E.3.a are maintained. Remember that currently the #2 recovery furnace and #2 smelt tank are in layup and not in current use. 13. On page 27, the hogged fuel boiler PM/opacity section should: a. Demonstrate which limit is the most stringent if relating the control device parameters to only one applicable emission limit. Ecology Response: The PM limit of 0.026 gr/dscf presented in Conditions Fl is the most restrictive short term limit. Conditions F.3 and F.4 are mass limits for which compliance is demonstrated using the source test results required by Condition F.1. Based on the fact that facility has maintained compliance with the mass limits previously, Ecology believes that compliance assurance monitoring associated with Condition F.12 will continue to adequately assure compliance with the subsequent PM limitations. 14. On page 28, the cyclone box PM/opacity section should: 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00116 SC_EVERSPLIT0002260 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 116 of 123 a. Identify a monitoring approach that does not rely on pressure drop of the baghouse because pressure drop is not an adequate parameter for assuring compliance with a particulate emission limit. Baghouse leak detectors or visible emissions are alternative options you should consider. b. Present emission test data that shows that the selected parameter and range will assure compliance with the applicable particulate and opacity limits. Ecology Response: Ecology revisited the vendor provided information on baghouse operation. Pressure drop as a compliance indicator is the parameter proposed by the vendor. Ecology has deferred to the vendor expertise. An expanded explanation of the nature of the boxplant operation has been added to the Support Document. The boxplant operation does not involve combustion. Emissions collection goes through both a cyclone and baghouse. There is no practical reason to go further in evaluating opacity under existing mill scenario. 15. In general, when you do not have emission test data to establish operational parameters that will assure compliance, the permit should require the appropriate testing and establishment of compliance assurance monitoring. Ecology Response: Ecology notes the comment and has included additional monitoring for some emission units, as discussed in the response to comments above. Boise White Paper, L.L.C. comments During our meeting at your office last month, we indicated that we would likely be submitting a comment regarding the CAM applicability determination. After further review of the EPA comments, your responses to those comments, and the final incorporation into the permit, we feel that there is no need to comment further. We appreciate your efforts in working through the CAM comments and finding a resolution that works for all parties. We do have a few minor comments for the Statement of Basis as noted below: 16. Table 2 Facility Information, Page 6 of 115: Responsible Official: Sean Krajnik -- Mill Manager PO Box 138 Wallula, WA 99363 Replace with Bert Brown 17. Ecology Response 7, Page 106 of 115 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00117 SC_EVERSPLIT0002261 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 117 of 123 "Table 2 within this Support Document summarizes the CAM applicability determination for the mill's emission units. Table 2 has been modified to better summarize the CAM review determinations made in this permit renewal effort. The testing referred to on page 13 has been completed and the results incorporated into the AOP and fact sheet. The fact sheet has been adjusted accordingly." We believe this should reference Tables 3 and 4 where the potential CAM applicability is listed and then exemptions are applied, respectively. 18. Ecology Response 8, Page 107 of 115: Ecology has modified Table 2 to better clarify the CAM review determinations made in this permit renewal effort. Ecology notes that the fact sheets themselves are not legally binding documents. Table 2 is a voluntary inclusion intended as an aid. Each permit writer and permit reviewer may have differing perspectives on how best to present information. Same comment as above. Suggest wording, "Table 3 and Table 4 have been modified to better summarize CAM review determinations made in this permit renewal effort." Ecology Response to Comments 16 through 18: All the suggested changes or corrections submitted by Boise have been made. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00118 SC_EVERSPLIT0002262 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 118 of 123 APPENDIX A - EXISTING ORDERS AND PERMITS All of the following past permits and regulatory orders are applicable (included). Order 1614-AQ04 Order DE 96-AQ-I078 PSD-X-77-04 PSD-95-04 PSD-01-07 All of the following past permits and regulatory orders are inapplicable (not included). Regulatory Order 36-8 DE 78-112 DE 78-120 DE 88-112 DE 92-AQI045 DE 95-AQI053 Amendment 1 DE 95AQI055 DE 95AQI084 Modification 1 DE 96-AQI013 Regulatory Order/NOC 7847, 8/17/10 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00119 SC_EVERSPLIT0002263 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 119 of 123 APPENDIX B - HISTORICAL EMISSION TESTING RESULTS A summary of historical PM emissions is presented below. The entire emission history is not presented here for the sake of brevity. PM emissions are considered representative of overall mill environmental performance. There is a break in summarized history as there were several permit cycles when the emissions history was not updated. The earliest emissions are retained for perspective. A reduction in required testing frequency was initiated years ago as a performance incentive. The No. 2 Recovery Furnace and No. 2 Smelt Tank were idled in December 2012 to accommodate reduced pulp mill production rates. They have remained idle since then. They may be brought on-line in the future if needed, at which time source testing would resume. Source No. 2 Recovery Furnace Month 1 2 3 4 5 6 7 8 9 10 11 12 1996 0.004 0.010 0.011 Mill Down 0.033 0.012 0.012 0.015 0.031 0.027 0.026 0.027 Permit Limit: Particulate -- 1997 2012 0.014 0.015 0.014 0.011 (a) (a) 0.018 (a) (a) 0.003 0.014 (a) (a) 0.044 gr/dscf gr/dscf 2013 down down down down down down down down down down down down 2014 down down down down down down down down down down down down Source No. 3 Recovery Furnace Month 1 2 3 4 5 6 7 8 9 10 11 12 1996 0.006 0.005 0.009 1995 0.006 0.014 0.015 0.015 0.011 0.006 0.005 0.005 Permit Limit: Particulate -- 1997 2012 0.004 0.005 0.005 0.011 0.013 (a) 0.003 (a) (a) 0.002 0.004 (a) (a) 0.1 gr/dscf gr/dscf 2013 0.002 2014 0.003 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00120 SC_EVERSPLIT0002264 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 120 of 123 Source No. 2 Dissolver Tank Vent Month 1 2 3 4 5 6 7 8 9 10 11 12 1996 0.040 0.016 0.110 Mill Down 0.060 0.100 0.080 0.050 0.090 0.080 0.110 (a) Permit Limit: Particulate -- gr/dscf 1997 2012 2013 2014 la) down down 0.100 (a) (a) down down down down down down 0.090 (a) down down down down 0.190 down down 0.150 .12 down down 0.190 down down 0.160 down down 0.120 down down 0.110 down down 0.2 lbs/ton Black Liquor Solids (BLS) Fired Source No. 3 Dissolver Tank Vent Month 1 2 3 4 5 6 7 8 9 10 11 12 1996 0.030 0.060 0.090 Mill Down 0.070 0.200 0.260 0.120 0.110 0.120 0.080 0.100 Permit Limit: Particulate -- 1997 2012 0.150 0.110 0.110 (a) gr/dscf 2013 2014 0.140 (a) 0.190 (a) (a) 0.155 0.16 0.190 (a) (a) 0.062 0.3 lbs/ton Black Liquor Solids (BLS) Fired Source Lime Kiln Month 1 2 3 4 5 6 7 8 1996 0.026 0.021 0.030 Mill Down 0.036 0.037 0.030 0.047 Particulate -- 1997 2012 0.035 .038 0.024 .045 0.032 .041 0.045 .048 0.041 (a) .029 .031 0.016 (a) .022 gr/dscf 2013 0.022 2014 0.013 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00121 SC_EVERSPLIT0002265 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 121 of 123 Source Month 9 10 11 12 1996 0.060 0.033 0.052 0.046 Permit Limit: Particulate -- gr/dscf 1997 2012 2013 @) 0.038 (a) (a) 0.067 gr/dscf (Gas), 0.12 gr/dscf (Oil) Source Hog Fuel Boiler Month 1 2 3 4 5 6 7 8 9 10 11 12 1996 0.020 0.020 0.020 Mill Down 0.030 0.030 0.030 0.020 0.020 0.030 0.030 0.030 Permit Limit: Particulate -- 1997 2012 .0030 0.030 0.008 0.033 0.030 0.030 0.040 0.040 0.040 0.040 0.030 0.040 0.030 0.04 gr/dscf gr/dscf 2013 0.009 0.011 0.011 2014 2014 0.01 See Appendix G of the AOP which summarizes source testing frequency as function of performance. Monitoring is required only when emission unit is operating. If monitored emissions are equal to or less than 75% of the emission limitation for any six consecutive months, emissions will be monitored by three 1-hour test per quarter and reported quarterly. If monitored emissions are less than or equal to 65% of the emission limitation for any four consecutive quarters, emissions will be monitored by three 1-hour tests per year and reported annually. If monitored emissions are less than or equal to 50% of the emission limitation for any four consecutive quarters, emissions may be monitored by one 1-hour test per year and reported annually. Three 1-hour tests averaging less than or equal to 50% of the limitation qualify for the 1hour annual test per year option. 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00122 SC_EVERSPLIT0002266 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 122 of 123 The Permittee shall conduct source testing within 105 days between two consecutive quarterly tests. If monitored emissions exceed the current threshold, the monitoring frequency will revert to the previous frequency. [PSD-X-77-04, WAC 173-401-615, or underlying applicable air order as basis for testing frequency flexibility] 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00123 SC_EVERSPLIT0002267 Statement of Basis for AOP No 0003697 Effective Date: April 1, 2018 Boise White Paper L.L.C. Page 123 of 123 APPENDIX C - PLANT SCHEMATIC UMW P444 0 . 1 hiairanuem t S.rs dust Nadas ennedi Area Screen Room 'Wad, 11. Maw i) GM, Site Plan Boise White Paper L.L". Walltila, Washington Washington TAIT-11 Hog hid & Unload DI-10 DEINK LANDFILAI LFC-13 O NOONStorage Rocoadhielog O1O4 PWR-6 againMosaic eleCrd1100 anti k,S4, 11111.. TO FIBER FARM FF-12 TT, F UL INiij 2024-EPA-05254 Sierra Club FOIA 2024-EPA-05254 ED_017426_00003078-00124 SC_EVERSPLIT0002268