AQ_GEN_PLNG_20200903_SIP_SO2-NAAQS_Att2Model

Attachment 2

Air Permit Application for Incorporation of SO2 Emission
Limits into the Canton Mill’s Permit
February 2018
Updated March 2019

(This page intentionally left blank)
AIR PERMIT APPLICATION
FOR INCORPORATION OF SO2 EMISSION LIMITS INTO
THE CANTON MILL’S PERMIT
FEBRUARY 2018
UPDATED MARCH 2019

Prepared for:

Blue Ridge Paper Products LLC
175 Main Street
Canton, NC 28716

Prepared by:

AECOM Technical Services of North Carolina, Inc.
1600 Perimeter Park Drive, Suite 400
Morrisville, NC 27560
TABLE OF CONTENTS

ii
TABLE OF CONTENTS
1.0 Introduction ...................................................................................................................... 1-1
1.1 Permit Request ................................................................................................................ 1-1
1.2 Report Organization ......................................................................................................... 1-2
2.0 Facility Information ........................................................................................................... 2-1
2.1 Site Location ..................................................................................................................... 2-1
2.2 Description of Mill Operations ......................................................................................... 2-1
3.0 Mill SO2 Emissions ............................................................................................................. 3-2
3.1 Overview of Emission Factors .......................................................................................... 3-2
3.1.1 US EPA AP-42 Emission Factors .......................................................................... 3-2
3.1.2 NCASI Emission Factors ....................................................................................... 3-2
3.1.3 Site-Specific Data ................................................................................................ 3-2
3.1.4 Regulatory and Permit Limits ............................................................................. 3-2
3.2 SO2 Model Emission Rates ............................................................................................... 3-3
4.0 Modeling Analysis and Results ......................................................................................... 4-1
4.1 Air Dispersion Model Selection ........................................................................................ 4-1
4.2 Meteorological Data ........................................................................................................ 4-1
4.3 Good Engineering Practice (GEP) Stack Height Analysis .................................................. 4-1
4.4 Receptors ......................................................................................................................... 4-2
4.5 Sources ............................................................................................................................. 4-2
4.6 Emissions.......................................................................................................................... 4-3
4.7 Background Air Quality .................................................................................................... 4-3
4.8 Modeling Results ............................................................................................................. 4-4

List of Figures
Figure 1 Site Location
Figure 2 Surrounding Topography
Figure 3 SO2 Modeling Layout
Figure 4 Modeling Receptors

List of Appendices
Appendix A Permit Application Forms
Appendix B Emissions Calculations

Introduction

1-1 Updated March 2019
1.0 INTRODUCTION
Blue Ridge Paper Products LLC (BRPP) operates an integrated Kraft pulp and paper mill located in
Canton, North Carolina. The primary activities at the Canton Mill are pulp production (Standard
Industrial Classification [SIC] code 2611) and paper production (SIC code 2621). The primary process
operations at the site include wood pulping, pulp bleaching, pulp drying, and papermaking.
On June 22, 2010, the EPA revised the primary sulfur dioxide (SO2) National Ambient Air Quality
Standard (NAAQS) (75 FR 35520). The EPA promulgated a new 1-hour daily maximum primary SO2
standard at a level of 75 parts per billion (ppb), based on the 3-year average of the annual 99th
percentile of 1-hour daily maximum concentrations.
On May 13, 2014, the EPA proposed the Data Requirements Rule (DRR) for the 1-Hour SO2 NAAQS (79
FR 27445). The final DRR was promulgated on August 21, 2015 (80 FR 51051) and requires states to
gather and submit to the EPA additional information characterizing SO2 air quality in areas with larger
sources of SO2 emissions. In the DRR, air agencies have the choice to use either monitoring or modeling
to characterize SO2 air quality in the vicinity of priority SO2 sources, and submit the modeling and/or
monitoring to the EPA on a schedule specified by the rule. The Canton Mill elected to conduct
monitoring and installed an ambient monitor in close proximity to the mill.
The SO2 ambient monitor is located on Pace Street in Canton approximately 50 meters (m) from the
Canton Mill property line. After it was installed, the monitor began to show periodic SO2 concentrations
above the hourly standard of 75 ppb. In response, the Mill has investigated SO2 emissions reduction
strategies and made equipment and operational changes to reduce its ambient impact.
Blue Ridge Paper Products and North Carolina signed a Special Order of Consent requiring the Canton
Mill to submit a permit application and modeling analysis by March 1, 2018 to characterize the Mill’s
emission sources and develop allowable SO2 emission rates based on modeled predictions of ambient
SO2 concentrations. This report contains our SO2 emissions and modeling analyses and proposed
allowable emission rates.
1.1 Permit Request
Special Order of Consent SOC 2017-002, Paragraph II.C, requires BRPP to submit a complete permit
application including SO2 emission limits and modeling that will demonstrate compliance with the one
hour SO2 NAAQS by March 1, 2018. The SOC further stipulates the NCDAQ will issue a permit with SO2
emission limits containing a compliance date no earlier than December 31, 2018.
The Canton Mill is requesting that Title V Permit 08961T22 be revised to incorporate the changes
included in this application. The following information is included in this application as required under
NCAC 2Q .0305 for the permit review:
1) Completed permit application forms (Appendix A);
2) Emissions calculations (Appendix B);
Introduction

1-2 Updated March 2019
3) An application fee of $947 as required by 2Q .0200
Should the NCDAQ have any questions or comments regarding this application, please contact Mr. Dan
Meyer of BRPP Canton at [phone] or Ms. Amy Marshall of AECOM at [phone].
1.2 Report Organization
The remainder of this report is divided into the following sections:
Section 2.0: Facility Information
Section 3.0: Mill SO2 Emissions
Section 4.0: Modeling Analysis and Results
The Table of Contents contains a detailed listing of figures and appendices.

Mill SO2 Emissions

2-1 Updated March 2019
2.0 FACILITY INFORMATION
2.1 Site Location
The Canton Mill is located in Haywood County along the Pigeon River. The Mill site is located
approximately 25 kilometers (km) west of Asheville, North Carolina. The site is surrounded by complex
terrain with elevations of 1,220 meters (4,000 feet) within 5km of the Mill. Figure 1 shows the site
location and Figure 2 shows the surrounding topography.
2.2 Description of Mill Operations
The Canton Mill produces a mix of hardwood and softwood pulp from wood furnished by off-site chip
mills. The Kraft cooking process is used to separate the lignin and wood fiber to produce brown pulp
from wood chips. Chips are cooked in batch digesters and discharged into two blow tanks common to
hardwood and pine digesters, respectively. The Hardwood Fiberline is also referred to as the No. 1
Fiberline and the Softwood or Pine Fiberline is also referred to as the No. 2 Fiberline. The brown pulp is
separated from wood knots and washed. The softwood and hardwood pulps are delignified in oxygen
reactors. After oxygen delignification, the pulps are screened, washed, and bleached.
The organic or lignin laden filtrates (black liquor) from the pulping, brown stock washing, and oxygen
delignification processes are concentrated in multiple-effect evaporators to produce black liquor solids.
The concentrated black liquor is burned in recovery furnaces (No. 10 and No. 11) to produce smelt for
chemical regeneration and steam for energy generation and heat for the pulp and paper processes.
Smelt from each recovery boiler is dissolved in weak wash in a downstream smelt dissolving tank (SDT)
forming raw green liquor. Each recovery boiler has a dedicated downstream SDT. In the causticizing
and lime recovery area, the raw green liquor is clarified and mixed with lime (CaO) in the slaker to form
white liquor and lime mud. This white liquor/lime mud slurry is then clarified to separate the white
liquor from the lime mud. The white liquor is sent to the digester, and the lime mud is conditioned,
thickened, and burned in the lime kiln to produce reusable lime.
The mill utilizes multiple boilers to produce steam for energy generation and provide heat for the
pulping and paper making processes. Currently operating power boilers include two natural gas-fired
package boilers, two coal-fired boilers, and one coal/biomass fired boiler. The mill also operates two
recovery boilers. Through cogeneration by utilization of steam-driven turbines, the mill produces most
of the electricity and steam required to run internal operations.
Product paper is produced from the pulp on four paper machines. Paper produced on three of the
paper machines is packaged in a converting area and is shipped in roll form to final customers.
Paperboard produced on the fourth machine is trucked to BRPP’s Waynesville, North Carolina facility
where it is coated and shipped to BRPP-owned converting facilities or sold directly to customers.

Mill SO2 Emissions

3-2 Updated March 2019
3.0 MILL SO2 EMISSIONS
The Canton Mill has several sources of SO2 emissions. An overview of the emission factors and the
corresponding emissions calculations are presented in this section of the application. Detailed emission
calculations are provided in Appendix B.
3.1 Overview of Emission Factors
To facilitate calculation of SO2 emissions from the project, the Canton Mill determined the appropriate
emissions factors and throughputs. Emission factors were obtained using various methodologies and
sources, including:
• US EPA’s Compilation of Air Pollutant Emission Factors – AP-42 (5th Edition, Revised);
• NCASI published emission factors;
• Site-specific data; and
• Applicable state and federal regulatory limits.
The sources of information for emission factor determination and calculation methodologies are
discussed in greater detail below.
3.1.1 US EPA AP-42 Emission Factors
The Canton Mill relied on emission factors from US EPA’s AP-42 (5th edition) to calculate SO2 emissions
for the project where vendor or site specific data were not available or representative. The following AP-
42 sections were utilized for calculating emissions from fuel combustion sources at the mill:
• Chapter 1.1, Bituminous and Subbituminous Coal Combustion;
• Chapter 1.3, Fuel Oil Combustion; and
• Chapter 1.4, Natural Gas Combustion.
3.1.2 NCASI Emission Factors
The Canton Mill utilized SO2 emission factors published in NCASI Technical Bulletin 1020 for recovery
furnaces and smelt dissolving tanks because these factors are more representative than AP-42 emission
factors for the Kraft pulp mill sources.
3.1.3 Site-Specific Data
SO2 emissions from burning coal, oil, and natural gas were estimated based on typical sulfur and Btu
content for each type of fuel. The scrubbers on the No. 4 Power Boiler and Riley Coal Boiler were
assigned a nominal control efficiency of 90% to calculate conservative post-control SO2 emissions for the
air dispersion modeling demonstration. Similarly, the lime kilns were assumed to remove 95% of the
sulfur from the fuel oil. This is expected to be a very conservative over-estimate of SO2 emissions due to
the sulfur capture by the lime dust within the kiln. The NCASI emission factor for a lime kiln would result
in SO2 emissions more than ten times lower than the modeled emission rates for each lime kiln.
3.1.4 Regulatory and Permit Limits
For the Black Liquor Oxidation RTO the 2007 NOCS compliance test (0.25 lb/hr) was multiplied by a
factor of ten and used in the modeling analysis as a conservative assumption.
Mill SO2 Emissions

3-3 Updated March 2019
3.2 SO2 Model Emission Rates
The maximum short-term SO2 emission rates were modeled for each source. In the case of the recovery
furnaces two emission rates were modeled, the first during normal operation burning black liquor solids
and the second during startups and shutdowns when burning oil. The recovery furnace stack exit
temperatures and exit velocities are also different when firing black liquor solids and oil.
Table 3-1. Modeled Emission Rates
Permit ID Source ID Source Description Emission Rate
(lbs/hr) (grams/sec)
G08020 #10REC No. 10 Recovery Boiler 28.0 (BLS) 3.53 (BLS)
0.54 (ULSD) 0.068 (ULSD)
G08021 #11REC No. 11 Recovery Boiler 28.0 (BLS) 3.53 (BLS)
0.54 (ULSD) 0.068 (ULSD)
G08023 #10SDT No. 10 Smelt Dissolving Tank 0.42 0.053
G08024 #11SDT No. 11 Smelt Dissolving Tank 0.42 0.053
G09028 #4LIME No. 4 Lime Kiln 6.3 0.79
G09029 #5LIME No. 5 Lime Kiln 10.5 1.32
G11039 RLCOAL Riley Coal Boiler 61.3 7.73
G11040 NO4BOIL No. 4 Power Boiler 82.2 10.36
G11042 RLBARK Riley Bark Boiler 68.0 8.57
G12077 PM19NIP No. 19 Paper Machine Calendar Nip Heater 0.012 0.0015
16-CU-001 1850GEN 1850 hp Diesel Emergency Generator 0.022 0.0028
I-G23066.f-ire FP200#1 200 hp Firepump #1 0.0024 0.00031
I-G23066.f-ire FP200#2 200 hp Firepump #2 0.0024 0.00031
I-G23066.f-gen LKGEN64 64 hp Diesel Emergency Generators for Lime Kilns 0.00078 0.000098
I-G23066.f-gen LKGEN227 227 hp Diesel Emergency Generators for Lime Kilns 0.0028 0.00035
I-G23066.f-rec RFGENSET100 100 kW RF Emergency Generator 0.0014 0.00018
G08022 BLOXRTO RTO 2.5 0.32
G11050
G11051 225NGBLS Natural Gas Package Boilers (combined stack) 0.26 0.034

Note that the emission rates in Table 3-1 reflect full implementation of the Repowering Project and
startup of the recovery furnaces on No. 2 fuel oil instead of No. 6 fuel oil.
Modeling Analysis and Results
4-1 Updated March 2019
4.0 MODELING ANALYSIS AND RESULTS
This section describes the dispersion modeling performed with the requested SO2 permit limits to
demonstrate compliance for the Mill.
4.1 Air Dispersion Model Selection
The suitability of an air quality dispersion model for a particular application is dependent upon several
factors. The following selection criteria were evaluated:
•stack height relative to nearby structures;
•dispersion environment;
•local terrain; and
•representative meteorological data.
The United States Environmental Protection Agency (US EPA) “Guideline on Air Quality Models” (GAQM,
which is contained in 40 CFR Part 51, Appendix W) prescribes a set of approved models for regulatory
applications for a wide range of source types and dispersion environments. Based on a review of the
factors discussed above, the latest version of AERMOD (18081) was used to assess air quality impacts.
4.2 Meteorological Data
The Canton Mill is located in Canton, North Carolina approximately 25 kilometers west of Asheville in an
area of complex terrain. Meteorological data for this area is not available for download on the NC DAQ
website. AERMOD-ready meteorological data was created by processing surface data from the Asheville
Regional Airport, upper air data from the Peachtree City, Georgia National Weather Service (NWS) site,
and onsite meteorological data for the years 2012-2016.
An important step in the processing of the meteorological data is to determine the surface
characteristics surrounding the location of the meteorological tower. This is performed using the
AERSURFACE preprocessor. Three land use parameters that are calculated and input into AERMOD
meteorological data include surface roughness length, a measure of an area’s mean obstacle height;
Bowen Ratio, a measure of an area’s mean moisture content; and albedo, a measure of an area’s
surface reflectivity. Surface roughness length and albedo will be determined from the input land use
data. To determine the Bowen Ratio, AERSURFACE requires the characterization of the surface
moisture conditions at the site relative to climatological normals. This characterization was
determined by the use of the Divisional Precipitation Ranks map from the National Centers for
Environmental Information (https://www.ncdc.noaa.gov/temp-and-precip/us-maps/12/201212?
products[]=divisionalpcpnrank#us-maps-select). From these maps it was determined that the Canton
Mill had below average precipitation in 2012, 2014, and 2016, while 2013 and 2015 had above average
precipitation.
4.3 Good Engineering Practice (GEP) Stack Height Analysis
A Good Engineering Practice (GEP) stack height analysis was conducted to demonstrate compliance with
stack height regulations (40 CFR Part 51) and to determine the impacts to the sources by building wake
and downwash effects. The GEP analysis was conducted using the procedures outlined in the EPA
Modeling Analysis and Results

4-2 Updated March 2019
documents Guideline for Determination of Good Engineering Practice Stack Height (Technical Support
Document For the Stack Height Regulations) Revised (EPA-450/4-80-023R) and the User's Guide to the
Building Profile Input Program. The latest version of the Building Profile Input Program (BPIP) with
PRIME algorithms was used to determine calculated GEP stack heights and to develop direction-specific
building dimensions for use in the dispersion model. Figure 3 presents the Canton Mill layout of
buildings and sources that were included in the BPIP analysis.
4.4 Receptors
The dispersion modeling receptor grid was developed following procedures outlined in the North
Carolina PSD Modeling Guidance (January 2012). A preliminary Cartesian receptor grid system was
created to adequately assess air quality impacts in all directions to a distance of up to 10 kilometers
from the Canton Mill. This preliminary grid includes ambient air boundary receptors with a receptor
spacing of 50 meters, and will extend outward from the boundary to 1.5 kilometers at 100 meter
spacing, from 1.5 kilometers to 3 kilometers at 250 meter spacing, from 3 kilometers to 6 kilometers at
500 meter spacing, and from 6 kilometers to 10 kilometers from the plant at 1 kilometer spacing. An
additional grid of receptors spaced at 100 meter intervals centered on the previously modeled
maximum impacts and extending out to 500 meters was added. The grid systems were created using the
UTM coordinate system (Zone 17) using the NAD83 datum (Figure 4).
Receptor elevations and critical hill heights were determined using the current version of the AERMAP
processor (version 11103). National Elevation Data (NED) was downloaded from the National Map
Seamless Server for an area of approximately 25 kilometers from the Canton Mill.
4.5 Sources
There are multiple SO2 emissions sources present at the Canton Mill, all of which were modeled as point
sources.
The AERMOD model uses a steady-state Gaussian plume equation to model emissions from point
sources such as stacks and vents. All point sources were modeled using actual stack exhaust parameters.
The following parameters were used for modeling the point sources: emission rates (grams/sec), stack
height (m), stack diameter (m), stack exit velocity (m/sec), and stack exhaust temperature (K). Table 4-1
presents a list of the modeled facility point sources and their associated parameters. The source and
building layout for modeling is shown in Figure 3.
The recovery furnaces normally burn black liquor solids during normal operation. However, during
startup and shutdowns the recovery furnaces burn oil, as well as occasionally when issues firing black
liquor solids are experienced. During oil burning periods the stack exhaust temperatures and exit
velocities are different. To account for this the model was run for two scenarios, the recovery furnaces
burning ultra-low sulfur diesel (ULSD) and burning black liquor solids (BLS). The different fuels led to
differing stack exhaust temperatures and exit velocities, as shown in Table 4-1 below.
Modeling Analysis and Results

4-3 Updated March 2019
Table 4-1. Modeled Stack Parameters
Permit ID Source ID Source Description
Stack
Height
(m)
Temperature
(K)
Exit Velocity
(m/s)
Stack
Diameter
(m)
G08020 #10REC No. 10 Recovery Boiler 61.9 391.8 (BLS) 15.93 (BLS) 3.7 358.2 (ULSD) 16.11 (ULSD)
G08021 #11REC No. 11 Recovery Boiler 61.7 398.7 (BLS) 17.74 (BLS) 3.7 358.2 (ULSD) 16.47 (ULSD)
G08023 #10SDT No. 10 Smelt Dissolving
Tank 61.9 341.5 8.80 1.2
G08024 #11SDT No. 11 Smelt Dissolving
Tank 61.9 342.1 9.14 1.2
G09028 #4LIME No. 4 Lime Kiln 58.0 341.0 11.22 1.2
G09029 #5LIME No. 5 Lime Kiln 62.2 338.2 8.40 1.5
G11039 RLCOAL Riley Coal Boiler 79.2 327.6 18.70 2.4
G11040 NO4BOIL No. 4 Power Boiler 79.2 327.6 18.82 2.4
G11042 RLBARK Riley Bark Boiler 44.2 322.0 14.80 2.4
G12077 PM19NIP No. 19 Paper Machine
Calendar Nip Heater 19.2 356.0 14.87 0.9
16-CU-001 1850GEN 1850 hp Diesel Emergency
Generator 9.1 755.37 0.01 0.3
I-G23066.f-ire FP200#1 200 hp Firepump #1 3.4 755.37 0.01 0.2
I-G23066.f-ire FP200#2 200 hp Firepump #2 2.4 755.37 0.01 0.1
I-G23066.f-gen LKGEN64 64 hp Diesel Emergency
Generators for Lime Kilns 3.1 755.37 30.00 0.1
I-G23066.f-gen LKGEN227 227 hp Diesel Emergency
Generators for Lime Kilns 6.1 755.37 0.01 0.2
I-G23066.f-rec RFGENSET100 100 kW RF Emergency
Generator 2.7 755.37 0.01 0.1
G08022 BLOXRTO RTO 30.5 324.9 8.53 1.2
G11050
G11051 225NGBLS Natural Gas Package
Boilers (combined stack) 50.3 435.9 16.12 2.4

4.6 Emissions
Emissions used in the modeling analysis are discussed in Section 3 and Table 3.1.
4.7 Background Air Quality
Ambient air quality data is used to represent the contribution to total ambient air pollutant
concentrations from non-modeled sources. This data is used as background concentrations that are
added to modeled impacts.
Representative background concentrations were obtained from the EPA’s Design Value website. There
are three active SO2 monitors within 100 km of the Mill. Of these, only two have valid 2014-2016 design
Modeling Analysis and Results

4-4 Updated March 2019
values; Seneca and Greenville, SC. Of these two, the Greenville monitor has more sources in close
proximity to it, and is the more conservative option. The 1-hour design value for the Greenville ESC
monitor (45-045-0015) for the years 2014-2016 was used and is 8 µg/m3 (3 ppb).
4.8 Modeling Results
The model was run for two scenarios, the recovery furnaces burning ultra-low sulfur diesel (ULSD) and
burning black liquor solids (BLS). The different fuels led to differing stack exhaust temperatures and exit
velocities, as shown in Table 4-1 above.
The 99th percentile of 1-hour daily maximum modeled concentrations averaged over the 5-year period
was added to the background value from Section 4.7. This total concentration was then compared to
the NAAQS to determine compliance. Modeling results are shown in Table 4-2 below and show
compliance with the 1-hour SO2 NAAQS for both scenarios.
Table 4-2. Modeled Results
Pollutant/
Averaging
Period
Years
Recovery
Furnace
Scenario
Modeled
Concentration
(ppb)
Background
Concentration
(ppb)
Total Modeled
Concentration
(ppb)
NAAQS
(ppb)
% of
NAAQS
SO2
(1-hour) 2012-2016
ULSD 64
3
67
75
89
BLS 71 74 99

Figures

Updated March 2019
Figures
Figures

Updated March 2019

Figures

Updated March 2019

BLUE RIDGE PAPER
PRODUCTS LLC.
CANTON MILL
CANTON, NC
SURROUNDING
TOPOGRAPHY
PROJECT
NO.
60542860
1600 Perimeter Park Drive, Suite 400
Morrisville, North Carolina 27560
Telephone [phone]
FIG. NO.
2

Figures

Updated March 2019

BLUE RIDGE PAPER
PRODUCTS LLC.
CANTON MILL
CANTON, NC
SO2 MODELING
LAYOUT
PROJECT
NO.
60542860
1600 Perimeter Park Drive, Suite 400
Morrisville, North Carolina 27560
Telephone [phone]
FIG. NO.
3

Figures

Updated March 2019

Figures

Updated March 2019
Appendix A
Permit Application Forms

A
Appropriate Number of Copies of Application Application Fee (if required)
Responsible Official/Authorized Contact Signature P.E. Seal (if required)
Legal Corporate/Owner Name:Blue Ridge Paper Products LLC
Site Name:
Responsible Official/Authorized Contact:Invoice Contact:
Name/Title:
City:State:Zip Code:City:State:NC Zip Code:
Fax No.:
Facility/Inspection Contact:Permit/Technical Contact:
Name/Title:
City:State:Zip Code:City:State:NC Zip Code:
Fax No.:
New Non-permitted Facility/Greenfield Modification of Facility (permitted)Renewal Title V Renewal Non-Title V
Name Change Ownership Change Administrative Amendment Renewal with Modification
General Small Prohibitory Small Synthetic Minor Title V
Facility Coordinates:
Person Name:
X Signature(Blue Ink):
Name (typed): Stephen J Hutchins Title: General Manager, Canton and Waynesville Operations
Date:
Firm Name:
Mailing Address Line 2:
Zip Code:County:State:City:
Mailing Address Line 1:
Fax No.:Email Address:
SIGNATURE OF RESPONSIBLE OFFICIAL/AUTHORIZED CONTACT
Attach Additional Sheets As Necessary Page 1 of 2
Current/Previous Air Permit No. 08961T22 Expiration Date: 10/31/2021
Latitude: 82° 50' 32"Longitude: 35° 32' 07"
Primary SIC/NAICS Code: 2611, 2621
Canton
175 Main Street
PO Box 4000
175 Main Street
PO Box 4000
Canton
Canton
175 Main Street
PO Box 4000
175 Main Street
PO Box 4000
Canton
[phone]
[phone](828) 646-2945
Email Address:
Fax No.:[phone] Primary Phone No.:
Secondary Phone No.:
[e-mail]
Mailing Address Line 1:
Mailing Address Line 2:
Mailing Address Line 1:
Mailing Address Line 2:
NC 28716 28716
County:
NC
[e-mail]
Primary Phone No.:
Secondary Phone No.:
Email Address:
Secondary Phone No.:
[phone] Fax No.:[phone]
Name/Title:
Mailing Address Line 1:
Mailing Address Line 2:
NC 28716 28716
Phone No.:
CONTACT INFORMATION
Stephen J. Hutchins, General Manager, Canton and Waynesville Operations Dan Meyer, Environmental Manager
FACILITY (Plant Site) INFORMATION
PERSON OR FIRM THAT PREPARED APPLICATION
APPLICATION IS BEING MADE FOR
Dan Meyer, Environmental Manager
Primary Phone No.:[phone]
FACILITY CLASSIFICATION AFTER APPLICATION (Check Only One)
Describe nature of (plant site) operation(s): Integrated bleached Kraft pulp and paper mill.
Mailing Address Line 1:
Mailing Address Line 2:
Name/Title:
Email Address:[e-mail]
Primary Phone No.:
Secondary Phone No.:
[phone]
Email Address:[e-mail]
FORM A
GENERAL FACILITY INFORMATION
NCDEQ/Division of Air Quality - Application for Air Permit to Construct/Operate
NOTE- APPLICATION WILL NOT BE PROCESSED WITHOUT THE FOLLOWING:
GENERAL INFORMATION
Blue Ridge Paper Products LLC - Canton Mill
Haywood
Dan Meyer, Environmental Manager
***If yes, please contact the DAQ Regional Office prior to submitting this application.***
(See Instructions)
Facility ID No. 4400159
Does this application contain confidential
data?YES NO
Local Zoning Consistency Determination (new or modification only)
REVISED 09/22/16
Site Address (911 Address) Line 1:
Site Address Line 2:
City:
Zip Code:
175 Main Street
Canton
28716
State:

REVISED 09/22/16 A
(Company Name) hereby formally requests renewal of Air Permit No.
YES NO
YES NO
YES NO
If no, did you submit the inventory via AERO or by mail?Via AERO Mailed Date Mailed:
(Company Name)
hereby formally requests renewal of Air Permit No.(Air Permit No.) and further certifies that:
(1)The current air quality permit identifies and describes all emissions units at the above subject facility, except where such units are exempted under the
North Carolina Title V regulations at 15A NCAC 2Q .0500;
(2)
(3)
(4)
(5)
formed after reasonable inquiry, are true, accurate, and complete.
Former Facility Name:
In accordance with the provisions of Title 15A 2Q .0513, the responsible official of
New Facility Name:
Former Facility Name:
Is your facility subject to 40 CFR Part 68 "Prevnetion of Accidental Releases" - Section 112(r) of the Clean Air Act?
If yes, have you already submitted a Risk Manage Plan (RMP) to EPA?
Did you attach a current emissions inventory?
SECTION AA2- APPLICATION FOR TITLE V PERMIT RENEWAL
The responsible official (signature on page 1) certifies under the penalty of law that all information and statements provided above, based on information and belief
The current air quality permit cits all applicable requirements and provides the method or methods for determing compliance with the applicable
requirements;
The facility is currently in compliance, and shall continue to comply, with all applicable requiremetns. (Note: As provided under 15A NCAC 2Q .0512
For applicable requirements that become effective during the term of the renewed permit that the facility shall comply on a timely basis;
The facility shall fulfill applicable enhanced monitoring requirements and submit a compliance certification as required by 40 CFR Part 64.
compliance with the conditions of the permit shall be deemed compliance with the applicable requirements specifically identified in the permit);
SECTION AA3- APPLICATION FOR NAME CHANGE
Date Submitted:
SECTION AA1 - APPLICATION FOR NON-TITLE V PERMIT RENEWAL
There have been no modifications to the originally permitted facility or the operations therein that would require an air permit since the last permit was issued.
FORM A (continued, page 2 of 2)
GENERAL FACILITY INFORMATION
NCDEQ/Division of Air Quality - Application for Air Permit to Construct/Operate
An official facility name change is requested as described above for the air permit mentioned on page 1 of this form. Complete the other sections if there have been
modifications to the originally premitted facility that would requie an air quality permit since the last permit was issued and if ther has been an ownership change
associated with this name change.
SECTION AA4- APPLICATION FOR AN OWNERSHIP CHANGE
The transfer of permit responsibility, coverage and liability shall be effective
facility described on page 1 of this form has been or will be transferred on (date). There have been no modifications to the originally
(immediately or insert date.) The legal ownership of the
from the former owner to the new owner as described below.By this application we hereby request transfer of Air Quality Permit No.
SECTION AA5- APPLICATION FOR ADMINISTRATIVE AMENDMENT
Attach Additional Sheets As Necessary Page 2 of 2
Date:
Former Legal Corporate/Owner Name:
Date:
New Facility Name:
In lieu of the seller's signature on this form, a letter may be submitted with the seller's signature indicating the ownership change
permitted facility that would require an air quality permit since the last permit was issued.
Signature of New (Buyer) Responsible Official/Authorized Contact (as typed on page 1):
Signature of Former (Seller) Responsible Official/Authorized Contact:
Name (typed or print):
Title:
X Signature (Blue Ink):
X Signature (Blue Ink):
Describe the requested administrative amendment here (attach additional documents as necessary):
Per SOC 2017-002, Paragraph II.C, Blue Ridge Paper Products shall submit a complete permit application including SO2 emission limits and modeling that will demonstrate compliance with the one hour SO2 NAAQS by March 1, 2018.
DAQ w ill issue a permit w ith SO2 emission limits containing a compliance date no earlier than December 31, 2018.

REVISED 09/22/16
Air disperison modeling for sulfur dioxide (SO2) required by Special Order of Consent 2017-002, Paragraph II.C, demonstrating compliance
with the 1-hour SO2 NAAQS of 75 ppb. Note that the emission rates in Section 2 reflect full implementation of the Repowering Project and
startup of the recovery furnaces on No. 2 fuel oil instead of No. 6 fuel oil.
2. EMISSIONS DATA - Facility-wide emissions, by source, of all modeled toxics.
CRITERIA OR TOXIC AIR POLLUTANT (TAP)
MAXIMUM TOXIC AIR POLLUTANT (TAP) EMISSIONS (After Controls)
Emission Point ID Ibs/year lbs/day lbs/hr
Sulfur Dioxide G08021 (#11REC) - ULSD 0.5
Sulfur Dioxide G08024 (#11SDT)0.3
Sulfur Dioxide G09028 (#4LIME)6.3
Sulfur Dioxide G08022 (BLOXRTO)2.5
Sulfur Dioxide G08023 (#10SDT)0.3
FORM D3
MODELING REQUEST FORMS (3 pages)
NCDEQ/Division of Air Quality - Application for Air Permit to Construct/Operate D3-1
If the applicant desires, the NCDAQ/AQAB will perform the initial modeling compliance demonstration using EPA approved screening
and, if applicable and where possible, refined models. If the model results indicate the facility will be unable to demonstrate compliance
with applicable Acceptable Ambient Level(s) the applicant will be notified and will be required to perform the compliance demonstration
using established modeling protocol and modeling analysis requirements as defined in the North Carolina Administrative Code 15A NCAC
2D .1100 and 2Q .0700 and in the Guidelines for Evaluating the Impacts of Toxic Pollutants in North Carolina.
To perform the dispersion modeling compliance demonstration, the AQAB will require the following data:
1. INTRODUCTION
Sulfur Dioxide G08021 (#11REC) - BLS 28.0
Sulfur Dioxide G08020 (#10REC) - BLS 28.0
Sulfur Dioxide G08020 (#10REC) - ULSD 0.5
Sulfur Dioxide G11040 (NO4BOIL)82.2
Sulfur Dioxide G11042 (RLBARK)68.0
Sulfur Dioxide G09029 (#5LIME)10.5
Sulfur Dioxide G11039 (RLCOAL)61.3
Sulfur Dioxide G12077 (PM19NIP)0.0046
Sulfur Dioxide 16-CU-001 (1850GEN)0.0224
Sulfur Dioxide G11050 (225NGBLS)0.1
Sulfur Dioxide G11051 (225NGBLS)0.1
Sulfur Dioxide I-G23066G1 (LKGEN64)0.0008
Sulfur Dioxide I-G23066G2 (LKGEN227)0.0028
Sulfur Dioxide I-G23066F1 (FP200#1)0.0024
Sulfur Dioxide I-G23066F2 (FP200#2)0.0024
Sulfur Dioxide G23066G3 (RFGENSET100 0.0014
Attach Additional Sheets As Necessary Page 1 of 4

D3-2
POINT SOURCE
G08023
#10REC - BLS #10SDT
61.9 m
341.5 K
8.80 m/s
1.2 m
2,583 ft
Stack UTM Coordinates (m)E 332852.789
NAD version 27 / 83 (circle one)N 3934005.24
Zone 17
Latitude o N
Longitude o W
Rain Cap? (Y/N)N
Vertical Stack? (Y/N)Y
POINT SOURCE
G11042
RLBARK
44.2 m
322.0 K
14.80 m/s
2.4 m
2,598 ft
Stack UTM Coordinates (m)E 332980.247
NAD version 27 / 83 (circle one)N 3934079.12
Zone 17
Latitude o N
Longitude o W
Rain Cap? (Y/N)N
Vertical Stack? (Y/N)Y
POINT SOURCE
I-G23066
FP200#2
2.4 m
755.37 K
0.01 m/s
0.1 m
2,688 ft
Stack UTM Coordinates (m)E 333071.779
NAD version 27 / 83 (circle one)N 3934366.27
Zone 17
Latitude o N
Longitude o W
Rain Cap? (Y/N)N
Vertical Stack? (Y/N)N
ft- feet
m- meters
3. SOURCE DATA
Source data requirements are based on the appropriate source classification.
Each emission source is classified as a point, area, or volume source. Note: For
fugitive area or volume source data, contact DAQ/AQAB.
G08021 G08022
61.87 m
#10REC - ULSD
61.87 m
G08021
#11REC - ULSD
61.73 m
#11REC - BLS
61.73 m
BLOXRTO
30.5 m
N
Y
17
Stack Diameter (ft or m)
Stack Base Elevation (ft) - MSL
STACK DATA
Emission Point ID
Stack Description
Stack Height (ft or m) - AGL
Stack Temperature (oF or oK)
Stack Exit Velocity (ft/s or m/s)
G08020 G08020
422.16 K
17.9 m/s
358.15 K
16.1 m/s
3934087.1
2,583 ft
332853.889
3934025.54
332821.207
STACK DATA
Emission Point ID
Stack Description
Emission Point ID
Stack Description
Stack Height (ft or m) - AGL
Stack Diameter (ft or m)
79.2 m58.0 m 62.2 m 79.2 mStack Height (ft or m) - AGL 61.9 m
327.6 K
Stack Base Elevation (ft) - MSL 2,583 ft 2,583 ft 2,583 ft 2,580 ft 2,580 ft
STACK DATA
G11050 G11051
N
Y
N
Y
G08024 G11040
N
Y
Stack Exit Velocity (ft/s or m/s) 9.14 m/s 11.22 m/s
m/s- meters per second Kelvin (degrees)=273+((oF-32) x 5/9)
UTM- Universal Transverse Mercator MSL- Mean Sea Level
Attach Additional Sheets As Necessary Page 2 of 4
AGL- Above Ground level
3.66 m
2,583 ft
332859.165
3934015.12
NO4BOIL
324.9 K
8.53 m/s
1.2 m
2,584 ft
17
3934025.54
2,583 ft
332859.165
3934015.12
3.66 m
413.26 K
18.3 m/s
3.66 m
2,583 ft
332853.889
358.15 K
16.5 m/s
3.66 m
#11SDT
G09028
#4LIME
G09029
#5LIME
G11039
RLCOAL
17
N
Y
1717
Stack Diameter (ft or m)1.2 m 1.2 m 1.2 m 2.4 m 2.4 m
Stack Temperature (oF or oK)342.1 K 341.0 K 338.2 K 327.6 K
18.70 m/s 18.82 m/s8.40 m/s
17 17 17 17 17
332854.831 332849.036 332836.735 333057.859 333003.707
3934027.68 3934005.21 3934027.52 3933937.47 3933967.02
G12077 16-CU-001 I-G23066
225NGBLS 225NGBLS PM19NIP 1850GEN FP200#1
N N N N N
Y Y Y Y Y
Stack Exit Velocity (ft/s or m/s) 16.12 m/s 16.12 m/s 143.87 m/s 0.01 m/s 0.01 m/s
3.4 m
Stack Temperature (oF or oK)435.9 K 435.9 K 356.0 K 755.37 K 755.37 K
50.3 m 50.3 m 19.2 m 9.1 m
2.4 m 2.4 m 0.9 m 0.3 m 0.2 m
Stack Base Elevation (ft) - MSL 2,582 ft 2,582 ft 2,592 ft 2,599 ft
17 17 17 17
2,599 ft
333124.527 333124.527 333362.153 332540.977 333176.326
17
3934016.57 3934016.57 3933923.56 3933620.77 3934071.59
N N N N N
Y Y Y N N
O
O
O

D3-2
POINT SOURCE
Stack UTM Coordinates (m)E
NAD version 27 / 83 (circle one)N
Zone
Latitude o N
Longitude o W
Rain Cap? (Y/N)
Vertical Stack? (Y/N)
AREA SOURCE
(contact DAQ for clarification of
input data requirements)
Area Source UTM Coordinates (m E
NAD version 27 / 83 (circle one)N
Zone
Latitude o N
Longitude o W
VOLUME SOURCE
(contact DAQ for clarification of
input data requirements)
Volume Source UTM Coordinate E
NAD version 27 / 83 (circle one)N
Zone
Latitude o N
Longitude o W
ft- feet
m- meters
Stack Exit Velocity (ft/s or m/s)
Stack Diameter (ft or m)
Stack Base Elevation (ft) - MSL
(for each area source, submit a separate detailed description of the area source, to include
Volume Source Height (ft or m) -
Volume Source Length (ft or m)
Volume Source Bldg Height (ft o
Source base Elevation (ft) - MSL
UTM- Universal Transverse Mercator
3. SOURCE DATA
Source data requirements are based on the appropriate source classification.
Each emission source is classified as a point, area, or volume source. Note: For
fugitive area or volume source data, contact DAQ/AQAB.
STACK DATA
Stack Description
Stack Height (ft or m) - AGL
Attach Additional Sheets As Necessary Page 3 of 4
AGL- Above Ground level m/s- meters per second
Stack Temperature (oF or oK)
MSL- Mean Sea Level
(for each volume source, submit a separate detailed description of the volume source, to
include dimensions of the volume source where emissions begine to disperse.)
Emission Point ID
Source Description
Emission Point ID
Source Description
Area Source Height (ft or m) - AG
Area Source Length (ft or m)
Area Source Width (ft or m)
Source Base Elevation (ft) - MSL
VOLUME SOURCE DATA
Kelvin (degrees)=273+((oF-32) x 5/9)
dimensions of the area and elevations. Also include source on site map.)
AREA SOURCE DATA
Emission Point ID I-G23066 I-G23066 I-G23066
755.37 K
0.01 m/s 0.01 m/s 0.01 m/s
RFGENSET100
3.1 m 6.1 m 2.7m
LKGEN64 LKGEN227
755.37 K 755.37 K
0.1 m 0.2 m 0.1 m
2,582 ft 2,582 ft 2,583 ft
332853.247 332853.247 332821.075
3933977.47 3933977.47 3934084.1
17 17 17
Y Y Y
N N N
O
O
OO

D3-3
A detailed site diagram must be submitted and should include all of the information listed below:
- Property boundaries
- Scale and true north indicator
- All existing and proposed buildings or structures on site
- Locations of all emission sources (existing and proposed) listed in Section 2, Page 1 of Form D3
- All public rights-of-way traversing the property ( e.g. roads, railroad tracks, rivers, etc.)
- UTM coordinates or latitude/longitude of at least one point (e.g. source or building corner)
A USGS Contour Map must also be submitted with the location of your facility clearly designated.
A certified plat map from County Register of Deeds or a signed survey map.
see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME
see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME
see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME
see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME
see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME see BPIPPRIME
Recovery Furnace #10 and #11 SO2 emissions limited to 28.0 lb/hr each firing black liquor*
Recovery Furnace #10 and #11 limited to ultra low sulfur diesel when burning oil*
Riley Coal SO2 emissions limited to 61.3 lb/hr*
Power Boiler #4 SO2 emissions limited to 82.2 lb/hr*
Riley Bark SO2 emissions limited to 68.0 lb/hr*
Facility Name:
Facility
ID:4400159
Facility
Add
Street:
City:
County:
Point of
C
Name:
Title:
Phone:
Email:
* Note that the emission rates above reflect full implementation of the Repowering Project and startup of the recovery
furnaces on No. 2 fuel oil instead of No. 6 fuel oil.
Building Height (ft or m)
Building Description
4. SITE DATA
5. BUILDING DATA List each building. List tiers of different heights on a single building as separate buildings.
Building ID
[phone]
[e-mail]
Attach Additional Sheets As Necessary Page 4 of 4
Blue Ridge Paper Products LLC - Canton Mill
175 Main Street
Canton
Haywood
Dan Meyer
Environmental Manager
6. MISCELLANEOUS DATA
Facility Operating Limits
(Operating hours, fuel
limits, or other
enforceable limits)
7. FACILITY IDENTIFICATON
Building Width (ft or m)
Building Length (ft or m)

REVISED 09/22/16 D6-1
Facility Name:Consultant (if applicable):
Facility ID:
Address:
Contact Name:Contact Name:
Phone Number:Phone Number:
Email Address:Email Address:
Included
N/A
Included
N/A
Included
N/A
Included
N/A
Included
N/A
Included
N/A
Attach Additional Sheets as Necessary
INSTRUCTIONS: The modeling report supporting the compliance demonstration should include most of the information listed below. As appropriate,
answer the following questions or indicate by check mark the information provided or action taken is reflected in your report.
FACILITY INFORMATION
GENERAL INFORMATION
Blue Ridge Paper Products LLC - Canton Mill
Morrisville, NC 27560
4400159
175 Main Street
AECOM Technical Services of North Carolina, Inc.
1600 Perimeter Park Drive, Suite 400
Dan Meyer, Environmental Manager Andy Holland
[phone]
[e-mail]
Description of New Source or Source/Process Modification: Provide a short description of the new or modified source(s)
and a brief discussion of how this change affects facility production or process operation.
Canton, NC 28716
Page 1 of 2
[phone]
Source/Pollutant Identification: Provide a table of the affected pollutants, by source, which identifies the source type (point,
area, or volume), maximum pollutant emission rates over the applicable averaging period(s), and, for point sources, indicate if the
stack is capped or non-vertical (C/N).
Pollutant Emission Rate Calculations: Indicate how the pollutant emission rates were derived (e.g. AP-42 emission factors,
mass balance, etc.) and where applicable, provide the calculations
Included
Site/Facility Diagram: Provide a diagram or drawing showing the location of all existing and proposed emission sources, buildings
or structures, public right-of-ways, and the facility property (toxics)/fence line (criteria pollutants) boundaries. The diagram should
also include a scale, true north indicator, and the UTM or latitude/longitude of at least one point.
Certified Plat or Signed Survey: a certified plat (map) from the County Register of Deeds or a signed survey must be submitted
to validate property boundaries modeled.
Topographic Map: a topographic map covering approximately 5 km around the facility must be submitted. The facility boundaries
should be annotated on the map as accurately as possible.
Included
Included
Cavity Impact Analysis: no cavity analysis is required if using AERMOD. See Section 4.2
Background Concentrations (criteria Pollutant analyses only): Background concentrations must be determined for each pollutant
for each averaging period evaluated. The averaged background value used (e.g. high, high-second-high, high-third-high, etc.) is
based on the pollutant and averaging period evaluated. The background concentrations are added to the modeled concentrations,
which are then compared to the applicable air quality standard to determine compliance.
[e-mail]
Offsite Source Inventories (criteria pollutant analyses only): Offsite source inventories must be developed and modeled for all
pollutants for which onsite source emissions are modeled in excess of the specific pollutant significant impact levels (SILs) as
defined in the PSD New Source Review Workshop Manual. The DAQ AQAB must approve the inventories. An initial working
inventory can be requested from the AQAB.
FORM D6
NORTH CAROLINA MODELING PROTOCOL CHECKLIST (2 Pages)
NCDEQ/Division of Air Quality - Application for Air Permit to Construct/Operate
The North Carolina Modeling Protocol Checklist may be used in lieu of developing the traditional written modeling plan for North Carolina toxics and criteria
pollutant modeling. The protocol checklist is designed to provide the same level of information as requested in a modeling protocol as discussed in Chapter
2 of the Guideline for Evaluating the Air Quality Impacts of Toxic Pollutants in North Carolina . The modeling protocol checklist is submitted
with the modeling analysis. The above referenced Guideline can be found at the following web link:
Although most of the information requested in the modeling protocol checklist is self-explanatory, additional comments are provided, where applicable, and
are discussed in greater detail in the toxics modeling Guideline referenced above. References to sections, tables, figures, appendices, etc., in the
protocol checklist are found in the toxics modeling Guideline .
https://ncdenr.s3.amazonaws.com/s3fs-public/Air%20Quality/permits/mets/Guidance.pdf
D6-2
Simple
Complex
Electronic
Hard Copy
USGS NED
Other
AERMOD Version:
Modeling Files: Either electronic or hard copies of AERSCREEN output must be submitted.
Model: The latest version of AERMOD should be used. The use of other refined models must be approved by NCDAQ prior to
submitting the modeling report.
Source/Source Emission Parameters: Provide a table listing the sources modeled and the applicable source emission
parameters. See NC Form 3 - Appendix A.
AERSCREEN Version
18081
AERMOD Version
Terrain: Indicate the terrain modeled: simple (Section 4.4), and complex (Section 4.5 and NC Form 4 -- Appendix A). If complex
terrain is within 5 kilometers of the facility, complex terrain must be evaluated. Simple terrain must include terrain elevations if any
terrain is greater than the stack base of any source modeled. Mark the appropriate terrain type.
Meteorology: Refer to Section 4.1 for AERSCREEN inputs.
Receptors: AERSCREEN - use shortest distance to property boundary for each source modeled and use sufficient range to find
maximum [See Section 4.1(i) and (j)]. Terrain above stack base must be evaluated.
Source/Source Emission Parameters: Provide a table listing the sources modeled and the applicable source emission
parameters. See NC Form 3 - Appendix A.
Merged Sources: Identify merged sources and show all appropriate calculations. See Section 3.3
GEP Analysis: See Section 3.2 and NC Form 1 - Appendix A
SCREEN LEVEL MODELING
Attach Additional Sheets as Necessary Page 2 of 2
Coordinate System: Specify the coordinate system used (e.g. NAD27, NAD83, etc.) to identify the source, building, and receptor
locations. Note: Be sure to specify in the AERMAP input file the correct base datum (NADA) to be used for identifying source input
data locations. Clearly note in both the protocol checklist and the modeling report which datum was used.
NAD83
Receptors: The receptor grid should be of sufficient size and resolution to identify the maximum pollutant impact. See Section 5.3.
Blue Ridge Paper
Canton On-Site Data
(2012-2016)
If processing your own raw meteorology, then pre-approval from AQAB is required. Additional documentation files (e.g. AERMET
state processing files) will also be necessary. For NC toxics, the modeling demonstration requires only the last year of the standard
5-year data set (e.g. 2005) provided the maximum impacts are less than 50% of the applicable AAL(s).
Modeling Results: For each affected pollutant and averaging period, modeling results should be summarized and presented in
tabular format indicating compliance status with the applicable AAL, SIL, or NAAQS. See NC Form R5 - Appendix A.
Modeling Files: Submit input and output files for AERMOD. Also include BPIP-Prime files, AERMAP files, DEM files, and any
AERMET input and output files, including raw meteorological data.
Meteorology: Indicate the AQAB, pre-processed, 5-year data set used in the modeling demonstration: See Section 5.5 and
Appendix B)
The USGS NED database can be found at the following web address:
The latest version of AERMOD may be found at the following web address:
REFINED LEVEL MODELING
Cavity Impact Analysis: No separate cavity analysis is required when using AERMOD as long as receptors are placed in cavity
susceptible areas. See Section 4.2 and 5.2.
Terrain: Use digital elevation data from the USGS NED database. Use of other sources of terrain elevations or the non-regulatory
Flat Terrain option will require prior approval from DAQ AQAB.
http://viewer.nationalmap.gov/launch/
GEP Analysis: Use BPIP-Prime w ith AERMOD.
http://www.epa.gov/scram001/dispersion_prefrec.htm
Modeling Results: For each affected pollutant, modeling results should be summarized, converted to the applicable averaging
period (See Table 3), and presented in tabular format indicating compliance status with the applicable AAL, SIL, or NAAQS. See NC
Form S5 - Appendix A.
Model: The latest version of the AERSCREEN model must be used. The use of other screening models should be approved by
NCDAQ prior to submitting the modeling report.

Updated March 2019
Appendix B
Emissions Calculations
Appendix B

Updated March 2019

SO2 MAXIMUM EMISSION RATES
BLUE RIDGE PAPER PRODUCTS LLC - CANTON, NC
Control Efficency
Limit or Incorporated into Control Efficency Emission Emission Operating Emission
Permit Source Type of Emission Emissions Activity Emission Factor for Pre-Control Rate Rate Hours Rate
ID Description Control Device Source Factor Units Basis Factor Units (Yes/No)Emission Factors (lb/hr)(g/s)(hr/yr)(tpy)
G08020 No. 10 Recovery Furnace - BLS ESP Point 0.40 lb/TBLS 2019 SOC Stack Test (Highest 1-hr run)70 TBLS/hr No N/A 28.0 3.53 8760 122.6
G08020 No. 10 Recovery Furnace - ULSD ESP Point 0.2 lb/1000 gal AP-42 Table 1.3-1 (15 ppm S ULSD)382 MMBtu/hr No N/A 0.54 0.068 8760 2.4
G08021 No. 11 Recovery Furnace - BLS ESP Point 0.40 lb/TBLS 2019 SOC Stack Test (Highest 1-hr run)70 TBLS/hr No N/A 28.0 3.53 8760 122.6
G08021 No. 11 Recovery Furnace - ULSD ESP Point 0.2 lb/1000 gal AP-42 Table 1.3-1 (15 ppm S ULSD)382 MMBtu/hr No N/A 0.54 0.068 8760 2.4
G08023 No. 10 Smelt Dissolving Tank Wet scrubber Point 0.006 lb/TBLS NCASI TB 1020, Table 4.15 Median 70 TBLS/hr No N/A 0.4 0.053 8760 1.8
G08024 No. 11 Smelt Dissolving Tank Wet scrubber Point 0.006 lb/TBLS NCASI TB 1020, Table 4.15 Median 70 TBLS/hr No N/A 0.4 0.053 8760 1.8
G09028 No. 4 Lime Kiln Wet scrubber Point 314.0 lb/1000 gal AP-42 Table 1.3-1 (2.0%S #6 oil)60 MMBtu/hr No 95.00%6.3 0.79 8760 27.5
G09029 No. 5 Lime Kiln Venturi scrubber Point 314.0 lb/1000 gal AP-42 Table 1.3-1 (2.0%S #6 oil)100 MMBtu/hr No 95.00%10.5 1.32 8760 45.8
G11039 Riley Coal Boiler ESP + Scrubber Point 41.8 lb/ton AP-42 Table 1.1-3 (1.1%S)399 MMBtu/hr No 90.00%61.3 7.726 8760 268.6
G11040 No. 4 Power Boiler Multiple Point 41.8 lb/MMBtu AP-42 Table 1.1-3 (1.1%S)535 MMBtu/hr No 90.00%82.2 10.359 8760 360.1
G11042 Riley Bark Boiler Venturi scrubber Point Maximum hourly emission rate 68.0 8.568 8760 297.8
G12077 Calendar Nip Heaters None Point 6.00E-07 lb/scf AP-42 Table 1.4-2 20,000 scf/hr No N/A 0.012 0.0015 8760 0.05
16-CU-001 1850 hp Backup Diesel Generator None Point 1.21E-05 lb/hp-hr AP-42 Table 3.4-1 (15 ppm S ULSD)1850 hp No N/A 0.022 0.0028 500 0.0
I-G23066.f-ire 200 hp Fire Control Generator #1 None Point 1.21E-05 lb/hp-hr AP-42 Table 3.4-1 (15 ppm S ULSD)200 hp No N/A 0.0024 0.00031 500 0.0
I-G23066.f-ire 200 hp Fire Control Generator #2 None Point 1.21E-05 lb/hp-hr AP-42 Table 3.4-1 (15 ppm S ULSD)200 hp No N/A 0.0024 0.00031 500 0.0
I-G23066.f-gen 64 hp Lime Kiln Emergency Generator None Point 1.21E-05 lb/hp-hr AP-42 Table 3.4-1 (15 ppm S ULSD)64 hp No N/A 0.00078 0.000098 500 0.0
I-G23066.f-gen 227 hp Lime Kiln Emergency Generator None Point 1.21E-05 lb/hp-hr AP-42 Table 3.4-1 (15 ppm S ULSD)227 hp No N/A 0.0028 0.00035 500 0.0
I-G23066.f-rec 100 kW Recovery Furnace Emergency Generator None Point 0.0015 lb/MMBtu AP-42 Table 3.4-1 (15 ppm S ULSD)0.94 MMBtu/hr No N/A 0.0014 0.00018 500 0.0
G08022 Black Liquor Oxidation - RTO None Point 0.25 lb/hr 2007 RTO NOCS Stack Testing 10 multiplier No N/A 2.5 0.32 8760 11.0
G11050 No. 1 Natural Gas Package Boiler None Point 0.6 lb/MMscf AP-42 Table 1.4-2 225 MMBtu/hr No N/A 0.13 0.017 8760 0.6
G11051 No. 2 Natural Gas Package Boiler None Point 0.6 lb/MMscf AP-42 Table 1.4-2 225 MMBtu/hr No N/A 0.13 0.017 8760 0.6
Mill Total:289.0 36.4 1,266
FUTURE PERMIT

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