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Home My WebLink AboutAQ_GEN_PLNG_20200903_SIP_SO2-NAAQS_BRPPSIPNar FINAL State of North Carolina Department of Environmental Quality Proposed Revision to State Implementation Plan Source-Specific State Implementation Plan for Evergreen Packaging/Blue Ridge Paper Products, LLC, Canton, Beaverdam Township, Haywood County, North Carolina for the 2010 1-Hour Sulfur Dioxide National Ambient Air Quality Standard (NAAQS) Prepared by North Carolina Department of Environmental Quality Division of Air Quality September 3, 2020 (This page intentionally left blank) Final Source-Specific SIP for Blue Ridge Paper Products, LLC i for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Table of Contents I. Executive Summary ................................................................................................................. 1 1. Purpose ................................................................................................................................. 1 2. Organization of this Document ............................................................................................ 2 II. Overview ................................................................................................................................. 2 1. Background .......................................................................................................................... 2 2. Attainment of the SO2 Standard ........................................................................................... 7 3. Legal Authority .................................................................................................................... 7 4. SIP Development Process .................................................................................................... 8 III. SO2 Attainment Analysis – Technical Document ................................................................... 9 1. Annual SO2 Emissions and Emission Reductions (2017 – 2019)........................................ 9 2. Ambient Air Quality Monitoring (2017 – 2019) ............................................................... 15 3. Permit Requirements .......................................................................................................... 15 4. Air Quality Modeling Demonstration for Facility ............................................................. 17 a. Facility Site Location ..................................................................................................... 17 b. Facility Operations ......................................................................................................... 17 c. Emission Source Modeling – Onsite Sources ................................................................ 20 d. Emission Source Modeling – Offsite Sources................................................................ 31 e. Modeling Receptor Grid................................................................................................. 32 f. Modeling Results............................................................................................................ 33 5. Air Quality Transport Modeling Demonstration ............................................................... 36 6. Conclusion ......................................................................................................................... 37 IV. Materials Proposed to be Incorporated into the SIP .............................................................. 38 V. Materials Proposed to be Excluded from the SIP .................................................................. 42 VI. Response to 40 CFR Part 51, Appendix V, Criteria for Determining the Completeness of Plan Submissions .......................................................................................................................... 45 1. Administrative Materials ................................................................................................... 45 2. Technical Support .............................................................................................................. 46 3. Exceptions .......................................................................................................................... 48 VII. Public Participation................................................................................................................ 49 1. Notice of Opportunity to Submit Comments and Participate in Public Hearing ............... 49 2. Pre-Hearing Draft Submittal Letter to EPA ....................................................................... 49 3. EPA No-Comment Letter .................................................................................................. 49 Final Source-Specific SIP for Blue Ridge Paper Products, LLC ii for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 List of Figures Figure 1. Location of Blue Ridge Paper Products LLC, Canton Mill, Canton, NC ...................... 3 Figure 2. Location of Blue Ridge Paper Products LLC, Canton Mill, Canton, NC, and Surrounding Topography .............................................................................................................. 18 Figure 3. Location of SO2 Emission Sources Included in Modeling Analysis for Blue Ridge Paper Products LLC ...................................................................................................................... 19 Figure 4. Modeling Grid Cell Receptors used in Facility Modeling Analysis for Blue Ridge Paper Products LLC ...................................................................................................................... 33 Figure 5. Modeling Grid Cell Receptors used in Transport Modeling Analysis for Blue Ridge Paper Products LLC ...................................................................................................................... 37 List of Tables Table 1. Trends in Actual Annual SO2 Emissions (2017 – 2019) and Comparison of 2019 Actual Annual SO2 Emissions to Permitted Maximum Allowable Emissions for BRPP Canton Mill.... 11 Table 2. Chronology of SO2 Emission Reduction Actions at Canton Mill (2017 – 2019) .......... 13 Table 3. Certified Ambient Air SO2 Monitoring Data (2017 – 2019) ......................................... 15 Table 4. Allowable SO2 Emission Limitations Modeled and Included in the Title V Permit ..... 16 Table 5. Modeled Allowable SO2 Emission Limitations ............................................................. 21 Table 6. Model Inputs for Recovery Furnaces Burning Ultra-Low Sulfur Diesel (ULSD) Modeling Scenario ........................................................................................................................ 23 Table 7. Model Inputs for Recovery Furnaces Burning Black Liquor Solids (BLS) Modeling Scenario......................................................................................................................................... 24 Table 8. Change in Allowable SO2 Emissions for Riley Coal, No. 4 Power, and Riley Bark Boilers ........................................................................................................................................... 27 Table 9. Annual SO2 Emissions Associated with Other Facilities in Haywood County ............. 31 Table 10. Source-Specific Modeling Results............................................................................... 34 Table 11. Updated Modeling Results for the One-Hour SO2 NAAQS Analysis for Blue Ridge Paper Canton, Haywood County, North Carolina ........................................................................ 35 Table 12. Materials Proposed to be Excluded from the SIP ........................................................ 42 Attachment 1 – Special Order by Consent (SOC 2017-002) Made and Entered into Pursuant to North Carolina General Statute 143-215.110 by and between Blue Ridge Paper Products, Inc., and the Environmental Management Commission Attachment 2 – Air Permit Application for Incorporation of SO2 Emission Limits into the Canton Mill’s Permit February 2018, Updated March 2019 Final Source-Specific SIP for Blue Ridge Paper Products, LLC iii for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Attachment 3 – North Carolina Division of Air Quality Review of Air Permit Application for Incorporation of SO2 Emission Limitations into the Canton Mill’s Permit (Revised February 5, 2020) Attachment 4 – Blue Ridge Paper Products Air Permit (No. 08961T29) Final Source-Specific SIP for Blue Ridge Paper Products, LLC iv for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 List of Acronyms Acronym Definition AERMAP American Meteorological Society / Environmental Protection Agency Regulatory Model Terrain Pre-Processor AERMOD American Meteorological Society/Environmental Protection Agency Regulatory Model AP-42 Compilation of Air Pollutant Emissions Factors BLS Black Liquor Solids BRPP Blue Ridge Paper Products LLC CAA Clean Air Act CAM Compliance Assurance Monitoring CaO Calcium Oxide (Lime) CaO3 Calcium Carbonate CFR Code of Federal Regulations CMS Continuous Monitoring Systems CY Calendar Year DAQ North Carolina Division of Air Quality DEP Duke Energy Progress DEQ North Carolina Department of Environmental Quality DRR Data Requirements Rule EPA United States Environmental Protection Agency ESP Electrostatic Precipitator gal Gallon gpm Gallons Per Minute HAP Hazardous Air Pollutant hp Horsepower hr Hour ID Identification Code No. km Kilometers kW Kilowatt lb Pound LLC Limited Liability Company m3 Cubic Meter MACT Maximum Achievable Control Technology MMBtu Million British thermal unit MMscf Million Standard Cubic Feet NAAQS National Ambient Air Quality Standard NAD83 North American Datum of 1983 NC North Carolina NCAC North Carolina Administrative Code NCASI National Council for Air and Stream Improvement NCGS North Carolina General Statute NED National Elevation Data NSPS New Source Performance Standards PM Particulate Matter ppb Parts Per Billion ppm Parts Per Million PTE Potential-to-Emit PSD Prevention of Significant Deterioration RF Recovery Furnace Final Source-Specific SIP for Blue Ridge Paper Products, LLC v for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Acronym Definition RTO Regenerative Thermal Oxidizer scf Standard Cubic Feet SDT Smelt Dissolving Tank SIP State Implementation Plan SO2 Sulfur Dioxide SOC Special Order by Consent TPY Tons Per Year TRS Total Reduced Sulfur µg Micrograms ULSD Ultra-Low Sulfur Diesel UTM Universal Transverse Mercator Final Source-Specific SIP for Blue Ridge Paper Products, LLC 1 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 I. Executive Summary 1. Purpose The North Carolina Department of Environmental Quality (DEQ), Division of Air Quality (DAQ), is proposing to revise North Carolina’s State Implementation Plan (SIP) under Section 110(a) of the Clean Air Act (CAA) to include a source-specific SIP for Blue Ridge Paper Products (BRPP) Limited Liability Company (LLC). North Carolina is requesting the United States Environmental Protection Agency (EPA) to approve into the SIP, through parallel processing, the sulfur dioxide (SO2) emission limits and associated compliance parameters for specific emission units in BRPP’s Title V operating permit (Permit No. 08961T29) to strengthen the SIP for complying with the 2010 1-hour SO2 National Ambient Air Quality Standard (NAAQS) in Beaverdam Township. On October 9, 2017, the North Carolina Environmental Management Commission and BRPP entered into a Special Order by Consent (SOC 2017-002) to implement process modifications, upgrade existing control equipment, and install new control equipment to control SO2 emissions and associated ambient concentrations below the 2010 1-hour NAAQS. BRPP has complied with the SOC and, as a result, reduced its annual emissions to 405 tons or by 93% (5,470 tons) from 2017 to 2019. These emission reductions have led to corresponding reductions in ambient SO2 concentrations near the facility. The annual 99th percentile of the SO2 1-hour daily maximum concentrations measured by the ambient monitor near the facility decreased from a high of 213.4 parts per billion (ppb) (285% of the NAAQS) in 2018 to 34.8 ppb in 2019 (46% of the NAAQS). As demonstrated through the permitting process, modeling of the emission limitations included in the permit show attainment of the NAAQS, and the monitoring, recordkeeping, and reporting requirements included in the permit support compliance with the emission limitations. Once EPA approves this proposed SIP revision, the SO2 emission limitations and associated monitoring, recordkeeping, and reporting requirements will be permanent and federally enforceable under Section 110(a) of the CAA to ensure that future ambient SO2 concentrations in Beaverdam Township will remain below the NAAQS. The EPA’s September 5, 2019, guidance to states for developing recommendations to EPA for designating all remaining areas for the 2010 primary 1-hour SO2 NAAQS provides an option to develop a source-specific SIP for a facility like BRPP to serve as a basis for designating an area “Attainment/Unclassifiable”.0F 1 Therefore, the DAQ is also submitting this source-specific SIP for EPA approval to not only strengthen the SIP for complying with the 1-hour SO2 standard in Beaverdam Township but also to qualify the Beaverdam Township area for an “Attainment/Unclassifiable” designation pursuant to EPA’s 2019 designation guidance. The SIP also documents supplemental air quality modeling information the DAQ has previously 1 Area Designations for the 2010 Primary Sulfur Dioxide National Ambient Air Quality Standard – Round 4, Memorandum from Peter Tsirigotis, Director, Office of Air Quality Planning and Standards, U.S Environmental Protection Agency, to Regional Air Division Directors, Regions 1 - 10, September 5, 2019. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 2 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 submitted to EPA to support approval of North Carolina's CAA Section 110(a)(2)(D)(i)(I) "Good Neighbor" SIP for the SO2 NAAQS.1F 2 2. Organization of this Document Section II provides background information on BRPP and a chronology of actions taken to significantly reduce SO2 emissions at the facility, and subsequently reduced ambient air concentrations near the facility below the NAAQS. Section III explains the SO2 attainment analysis completed for the emission sources at the facility. The attainment analysis summarizes changes to annual emissions and ambient concentrations from 2017 through 2019 and documents the modeling methodology and results showing that the allowable emission limitations in the permit will be protective of the NAAQS. For each emission source, this section also documents the technical basis for the allowable SO2 emission limitations and associated monitoring, recordkeeping, and reporting requirements proposed for inclusion in the SIP. Section IV identifies the SO2 emission limitations for the Riley Coal, Riley Bark and No. 4 Power Boilers; No. 10 and No. 11 Recovery Furnaces (for normal operation and startup); and No. 4 and No. 5 Lime Kilns and associated monitoring, recordkeeping, and reporting requirements proposed to be incorporated into the SIP. Section V identifies SO2 sources included in BRPP’s permit but proposed for exclusion from the SIP because they are operated intermittently or have very low SO2 emissions and have no or very low impacts on ambient SO2 concentrations modeled near the facility. Section VI addresses criteria for determining the completeness of plan submissions as specified in 40 Code of Federal Regulations (CFR) Part 51, Appendix V. Section VII documents the public participation process for this document and proposed SIP revision. II. Overview 1. Background Blue Ridge Paper Products LLC, a subsidiary of Evergreen Packaging, (Facility Identification (ID) Code No. 4400159) is located at 175 Main Street in the City of Canton, Beaverdam Township, Haywood County, North Carolina ("Facility") 25 kilometers (km) west of Asheville, North Carolina (see Figure 1). The facility is situated on the Pigeon River on a 200-acre site in downtown Canton. This facility is a vertically integrated pulp and paper mill that produces specialty paperboard packaging products. The facility’s primary operations are classified under North American Industry Classification System 322121 (Paper Except Newsprint Mills). On June 22, 2010, EPA revised the primary SO2 NAAQS.2F 3 The EPA adopted a new 1-hour standard of 75 ppb, measured as a three-year average of the annual 99th percentile of 1-hour daily maximum concentrations (40 CFR 50.17). The primary annual and 24-hour SO2 NAAQS are 2 “Revision to North Carolina’s Clean Air Act Section 110(a)(2)(D)(i)(I) “Good Neighbor” State Implementation Plan for the 2010 1-Hour Sulfur Dioxide Standard,” June 16, 2016. 3 Primary National Ambient Air Quality Standard for Sulfur Dioxide, Final Rule, 75 FR 35520, June 22, 2010. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 3 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 revoked in all townships of each county for which EPA has finalized a designation for the 1-hour SO2 standard in accordance with 40 CFR 50.4(e). Figure 1. Location of Blue Ridge Paper Products LLC, Canton Mill, Canton, NC On August 5, 2013, EPA published a final rule establishing air quality designations for 29 areas in the United States for the 2010 1-hour SO2 NAAQS based on recorded air quality monitoring data from 2009 through 2011 showing violations of the NAAQS (78 FR 47191). In that rulemaking, EPA committed to address, in separate future actions, the designations for all other areas for which EPA was not yet prepared to issue designations. At that time, North Carolina monitors showed attainment with the 2010 SO2 NAAQS but EPA deferred designation of the monitored areas for North Carolina until a later date. Following the initial August 5, 2013, designations, three lawsuits were filed against EPA in different U.S. District Courts, alleging EPA had failed to perform a nondiscretionary duty under the CAA by not designating all portions of the country by the June 2, 2013 deadline. In an effort intended to resolve the litigation in one of those cases, plaintiffs, Sierra Club and the Natural Resources Defense Council, and EPA filed a proposed consent decree with the U.S. District Court for the Northern District of California. On March 2, 2015, the court entered the consent Final Source-Specific SIP for Blue Ridge Paper Products, LLC 4 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 decree and issued an enforceable order for EPA to complete the area designations according to the court-ordered schedule.3F 4 According to the court-ordered schedule, EPA was required to complete the remaining designations by three specific deadlines. By no later than July 2, 2016 (16 months from the court’s order), EPA must designate two groups of areas: (1) areas that have newly monitored violations of the 2010 SO2 NAAQS and (2) areas that contain any stationary sources that had not been announced as of March 2, 2015, for retirement and that, according to EPA’s Air Markets Database, emitted in 2012 either (i) more than 16,000 tons of SO2, or (ii) more than 2,600 tons of SO2 with an annual average emission rate of at least 0.45 pound of SO2 per one million British thermal units (lb/MMBtu). North Carolina had one stationary source facility in Brunswick County that met the second criterion, and, subsequently, EPA designated all townships in the county “unclassifiable” on schedule (81 FR 45039, 40 CFR 81.334). The last two deadlines for completing remaining designations are December 31, 2017, and December 31, 2020. On August 21, 2015 (80 FR 51052), EPA promulgated the SO2 Data Requirements Rule (DRR) (40 CFR Part 51, Subpart BB) that specified requirements for state and local air agencies to provide additional monitoring or modeling information on a timetable consistent with these designation deadlines.4F 5 The DRR required air agencies to characterize air quality using either modeling of actual facility-wide emissions or using appropriately sited ambient air quality monitors for facilities with annual SO2 emissions of 2,000 tons or more. On January 15, 2016, North Carolina submitted to EPA a final list identifying facilities (including BRPP) with greater than 2,000 tons per year (TPY) of SO2 emissions. On June 30, 2016, North Carolina submitted to EPA its proposed approach for evaluating air quality around the facilities using modeling or monitoring. On January 13, 2017, North Carolina submitted to EPA recommendations for designating all remaining areas in the state except for three townships (Beaverdam Township (Haywood County), Cunningham Township (Person County), Limestone Township (Buncombe County)) for which North Carolina identified for monitoring.5F 6 On December 21, 2017, EPA designated all remaining areas in North Carolina as “attainment/ unclassifiable” except for the three townships (83 FR 1098; 40 CFR 81.334). For the three townships, North Carolina began monitoring on or before January 1, 2017 to collect data to establish a design value for calendar years (CY) 2017 through 2019 to determine compliance with the NAAQS. BRPP is the major SO2 emissions source in Beaverdam Township. The DAQ established a monitoring site approximately 150 feet west of the facility's fence line following EPA monitoring requirements and began operating the monitor on November 15, 2016. Subsequently, the monitor recorded exceedances of the 1-hour SO2 NAAQS. To address this issue, on October 9, 2017, the North Carolina Environmental Management Commission and 4 Northern District of California against U.S. EPA in Sierra Club v. McCarthy, Case No. 13-cv-03953-SI. 5 Data Requirements Rule for the 2010 1-Hour Sulfur Dioxide (SO2) Primary National Ambient Air Quality Standard (NAAQS), Final Rule, 80 FR 51052, August 21, 2015 (https://www.govinfo.gov/content/pkg/FR-2015-08- 21/pdf/2015-20367.pdf). 6 North Carolina’s Recommendation on Boundaries for the 2010 1-Hour Sulfur Dioxide (SO2) National Ambient Air Quality Standard, January 13, 2017. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 5 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 BRPP entered into SOC 2017-002 (see Attachment 1). The SOC required BRPP to submit a permit application and modeling analysis by March 1, 2018, to characterize the facility’s emission sources and develop allowable SO2 emission limitations based on modeled predictions of ambient SO2 concentrations. The SOC also contained a timeline for the facility to complete planned changes in order to comply with the CAA Section 112(d) boiler maximum achievable control technology (MACT) rule by May 20, 2019 per the CAA Section 112(j) requirements in its permit.6F 7 To comply with the boiler MACT Section 112(d) rule, the facility invested approximately $50 million in planned improvements to install two new natural gas-fired boilers, permanently shut down two coal-fired boilers, and install new wet scrubbers and rebuild the electrostatic precipitators (ESPs) on two additional coal-fired boilers. Although the MACT standards control hazardous air pollutants (HAPs), these investments in controls for HAPs also significantly reduced SO2 emissions. On February 28, 2018, BRPPs submitted to the DAQ a permit application for the significant modification of its Title V permit for its Canton, North Carolina facility to fulfill the requirements of the SOC. In response to this request, on September 12, 2019, the DAQ issued to BRPP a modification to its Title V permit (Permit No. 08961T26). BRPP’s Title V permit includes source specific SO2 emission limitations and associated monitoring, recordkeeping, and reporting requirements based on applicable requirements for which EPA has previously approved into North Carolina’s SIP. The applicable requirements are as follows: The General Condition II of the facility's permit addresses exceedances of ambient standards. II. Ambient Air Quality Standards [15A NCAC 02D .0501 (c)] In addition to any control or manner of operation necessary to meet emission standards specified in this permit, any source of air pollution shall be operated with such control or in such manner that the source shall not cause the ambient air quality standards in 15A NCAC 02D. 0400 to be exceeded at any point beyond the premises on which the source is located. When controls more stringent than named in the applicable emission standards in this permit are required to prevent violation of the ambient air quality standards or are required to create an offset, the permit shall contain a condition requiring these controls. The following North Carolina rules apply to the facility: 15A NCAC 02D .0401(c) states: (c) No facility or source of air pollution shall cause any ambient air quality standard in this Section to be exceeded or contribute to a violation of any ambient air quality standard in this Section except as allowed by Rules .0531 or .0532 of this Subchapter. 15A NCAC 02D .0402(e) states: (e) The one-hour primary standard is met at an ambient air quality monitoring site when the three-year average of the annual (99th percentile) of the daily maximum one-hour 7 40 CFR Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters (Sections 63.7480 - 63.7575). Final Source-Specific SIP for Blue Ridge Paper Products, LLC 6 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 average concentrations is less than or equal to 75 ppb, as determined in accordance with Appendix T of 40 CFR Part 50. Based on 3 years of monitoring data, the 3-year design value is 152 ppb or 202% of the NAAQS. However, the extensive modifications to and construction of processes and control equipment completed by BRPP have significantly reduced SO2 emissions and ambient SO2 concentrations. In CY 2019, the annual 99th percentile of the SO2 1-hour daily maximum concentrations measured by the ambient monitor near the facility is 34.8 ppb or 46% of the NAAQS. It is expected that ambient SO2 concentrations in Beaverdam Township will remain below the NAAQS going forward. On September 5, 2019, EPA issued guidance for states to follow in developing recommendations to EPA for designating all remaining areas based on ambient air quality monitoring data. This guidance provides an option for states to develop a source-specific SIP for a facility like BRPP to serve as a basis for designating an area Attainment/Unclassifiable rather than nonattainment. The guidance states: In general, for the purpose of being used in the Round 4 designations process, one common example to create a federally enforceable SO2 emissions limit is to establish a limit by using a SIP-approved new source review permit program, under which a permit’s limit is federally enforceable upon its issuance. Another less common example could be to establish a limit in a title V permit followed by incorporating that limit into the SIP, provided that establishment of the limit implements an “applicable requirement” as defined under 40 CFR 70.2 that already applies to the source, such as a generally applicable provision in an EPA-approved SIP that prohibits sources from causing violations of NAAQS. The DRR would not be such an applicable requirement as defined by EPA’s title V rules and should not serve as the authority for creating a title V permit limit.7F 8 Therefore, the DAQ is proposing to revise North Carolina’s SIP under Section 110(a) of the CAA to include a source-specific SIP for BRPP based on the “less common example” provided in EPA’s guidance. The SIP for BRPP incorporates emission limitations and monitoring, recordkeeping, and reporting requirements for sources of SO2 included in the Title V permit for the facility (Permit Number 08961). As demonstrated through the permitting process, modeling of the emission limitations and operating parameters included in the permit show attainment of the NAAQS, and the monitoring, recordkeeping, and reporting requirements will assure compliance with the emission limitations. Once approved by EPA, the SO2 emission limitations will be permanent and federally enforceable under Section 110(a) of the CAA. The DAQ is submitting this source-specific SIP for EPA approval to strengthen the SIP to support an “Attainment/Unclassifiable” designation for Beaverdam Township. In addition, the SIP also documents supplemental air quality modeling information the DAQ has previously submitted to EPA to support approval of North Carolina's CAA Section 110(a)(2)(D)(i)(I) "Good Neighbor" SIP for the 2010 SO2 NAAQS. 8 Area Designations for the 2010 Primary Sulfur Dioxide National Ambient Air Quality Standard – Round 4, Memorandum from Peter Tsirigotis, Director, Office of Air Quality Planning and Standards, U.S Environmental Protection Agency, to Regional Air Division Directors, Regions 1 - 10, September 5, 2019. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 7 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 2. Attainment of the SO2 Standard Based on modeling analyses and supported by monitoring data for CY 2019, the SO2 emissions controls that BRPP implemented to comply with the SOC and that are included in its Title V permit demonstrate attainment of the 2010 1-hour SO2 NAAQS. The emission limitations and monitoring, recordkeeping and reporting requirements that are incorporated into the permit (Permit Number 08961), and proposed for partial inclusion in the SIP, provide reasonable assurance that the entire Beaverdam Township area is now in attainment of the 2010 SO2 NAAQS and will continue to maintain compliance with the NAAQS in the future. In addition, the DAQ conducted modeling of the emission limitations included in BRPP’s permit to evaluate the SO2 impacts in the downwind states of South Carolina and Tennessee for the purpose of determining compliance with the Good Neighbor provisions of CAA Section 110(a)(2)(D)(i)(I). The modeling results show a maximum 1-hour increase of 1 ppb and 8 ppb for receptors located on the border of South Carolina and Tennessee, respectively. Thus, North Carolina believes that the emission limitations established in BRPP’s Title V permit will not likely contribute to nonattainment or interfere with maintenance of the NAAQS in South Carolina and Tennessee. 3. Legal Authority Chapter 143 of the North Carolina General Statute (NCGS) entitled, “State Departments, Institutions, and Commissions” provides the legal framework for the DEQ’s authority. The most recent version of the NCGS may be found online at https://www.ncleg.gov/Laws/GeneralStatutesTOC. The principal citations granting the DEQ authority to conduct actions with respect to this SIP are listed below. It is important to note that it is not the intent of the DEQ to have the text of the referenced NCGS incorporated into the SIP. The DEQ believes that North Carolina’s NCGS are not required to be adopted into the SIP based upon the EPA Federal Register notice on May 19, 2010, regarding California’s legal authority (75 FR 27938). In this final rule the EPA states, “We also noted that the actual statutory provisions and other legal documents relied upon to support a State's assurance of adequate legal authority need not be approved into the SIP under [Clean Air Act] section 110 or EPA's SIP regulations in 40 [Code of Federal Regulations] part 51 (although such provisions are required to be submitted with the plan). Thus, EPA could approve, consistent with [Clean Air Act] and EPA requirements, and did so in this instance, a wholesale revision to the original legal authority chapter without also approving the actual statutory provisions and other legal documents cited therein.” • NCGS 143-211. “Declaration of public policy.” • NCGS 143-215.3. “General powers of Commission and Department; auxiliary powers.” • NCGS 143-215.3A. “Water and Air Quality Account; use of application and permit fees; Title V Account; I&M Air Pollution Control Account; reports.” • NCGS 143-215.64. “Purpose.” • NCGS 143-215.65. “Reports required.” • NCGS 143-215.66. “Monitoring required.” • NCGS 143-215.67. “Acceptance of waste to disposal systems and air-cleaning devices.” • NCGS 143-215.69. “Enforcement procedures.” Final Source-Specific SIP for Blue Ridge Paper Products, LLC 8 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 • NCGS 143-215.105. “Declaration of policy; definitions.” • NCGS 143-215.106. “Administration of air quality program.” • NCGS 143-215.106A. “Assessments to establish Title V program.” • NCGS 143-215.107. “Air quality standards and classifications.” • NCGS 143-215.107D. “Emissions of oxides of nitrogen (NOx) and sulfur dioxide (SO2) from certain coal-fired generating units.” • NCGS 143-215.108. “Control of sources of air pollution; permits required.” • NCGS 143-215.108A. “Control of sources of air pollution; construction of new facilities; alteration or expansion of existing facilities.” • NCGS 143-215.110. “Special Orders.” • NCGS 143-215.111. “General powers of the Commission; auxiliary powers.” • NCGS 143-215.114A. “Enforcement procedures: civil penalties.” • NCGS 143-215.114B. “Enforcement procedures: criminal penalties.” • NCGS 143-215.114C. “Enforcement procedures: injunctive relief.” • NCGS 143B-279.2. “Department of Environmental Quality – duties.” • NCGS 143B-279.3. “Department of Environmental Quality – structure.” • NCGS 150B. “Administrative Procedure Act”. North Carolina’s air quality rules are codified in the North Carolina Administrative Code, Title 15A, Chapter 02, Subchapters 02D and 02Q. The current version of the North Carolina Administrative Code is located at http://reports.oah.state.nc.us/ncac.asp. Likewise, North Carolina’s federally approved rules under the CAA Section 110 SIP are located under 40 CFR Part 52, Subpart II (§52.1770). The Sections of North Carolina’s rules containing relevant CAA Section 110 SIP provisions for this submittal are as follows: • 15A NCAC 02D .0100, Definitions and References • 15A NCAC 02D .0200, Air Pollution Sources • 15A NCAC 02D .0300, Air Pollution Emergencies • 15A NCAC 02D .0400, Ambient Air Quality Standards • 15A NCAC 02D .0500, Emission Control Standards • 15A NCAC 02D .0600, Monitoring: Recordkeeping: Reporting • 15A NCAC 02D .2600, Source Testing • 15A NCAC 02Q .0100, General Provisions • 15A NCAC 02Q .0200, Permit Fees Other relevant air quality rules that are not included as part of North Carolina’s Section 110 SIP include: • 15A NCAC 02Q .0400, Acid Rain Procedures • 15A NCAC 02Q .0500, Title V Procedures 4. SIP Development Process North Carolina General Statute (NCGS) 143B-279.2(1) and (3) authorizes the DEQ to provide for the “protection of the environment;” and “management of the State’s natural resources.” As part of this statutory obligation, the North Carolina General Assembly transferred and vested all Final Source-Specific SIP for Blue Ridge Paper Products, LLC 9 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 “functions, powers, duties, and obligations” of the Environmental Management Commission to the DEQ by a Type II transfer pursuant to NCGS 143B-279.3(b)(10) and NCGS 143A-6, respectively. Therefore, the DEQ is granted authority to “prepare and develop, after proper study, a comprehensive plan or plans for the prevention, abatement and control of air pollution in the State or in any designated area of the State” pursuant to NCGS 143-215.107(a)(1). This statutory authority was used for the development and submission of the proposed source-specific SIP. On June 24, 2020, the DAQ issued a public notice announcement, in accordance with 40 Code of Federal Regulations (CFR) 51.102, indicating that the “Source-Specific State Implementation Plan for Evergreen Packaging/Blue Ridge Paper Products, LLC, Canton, Beaverdam Township, Haywood County, North Carolina for the 2010 1-Hour Sulfur Dioxide National Ambient Air Quality Standard (NAAQS)” was available for public comment and posted on the DAQ’s website for review. The public comment period for the proposed SIP was open from Wednesday, June 24, 2020 through Monday, July 27, 2020. The public notice announcement also indicated that anyone may request a public hearing on the source-specific SIP. Requests for a public hearing must be in writing and include a statement supporting the need for such a hearing, an indication of the person’s interest in the subject, and a brief summary of the information intended to be offered. To address current guidance to help minimize the spread of COVID-19, a digital public hearing via Cisco’s WebEx teleconferencing service was offered to be scheduled if a public hearing was requested. The public notice specified that a separate notice would be announced for the hearing including the date, time, and methods to access the WebEx meeting. The public notice requested that written requests for a public hearing be postmarked or submitted electronically to the DAQ no later than Friday, July 10, 2020. The DAQ did not receive electronically or by mail any requests for a public hearing. In addition to posting on the website, the public notice announcement for the source-specific SIP was sent to a number of email distribution lists managed by the DAQ that includes numerous stakeholders from industry and environmental groups. The DAQ has found that sending the public notice announcements to these groups is more effective than publishing notices in a few local newspapers and is consistent with the requirements described in the April 6, 2011, memorandum, “Regional Consistency for the Administrative Requirements of the State Implementation Plan Submittals and the Use of Letter Notices.” The public notice also indicated that, based on the current guidance to minimize the spread of COVID-19, all DAQ office locations are limiting public access to appointments only. As such, the pre-hearing draft of the source-specific SIP may only be reviewed in person after making an appointment at the DAQ’s Central Office and Asheville Regional Office. III. SO2 Attainment Analysis – Technical Document 1. Annual SO2 Emissions and Emission Reductions (2017 – 2019) For each of the SO2 emission units included in the BRPP Title V permit, Table 1 shows annual SO2 emissions for 2017-2019, maximum potential annual emissions, and annual emissions for 2019 as a percentage of maximum potential annual emissions. The actual emissions for 2019 Final Source-Specific SIP for Blue Ridge Paper Products, LLC 10 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 provide the best representation (relative to 2017 and 2018 emissions) of the Canton Mill’s operations after replacing two coal fired boilers with natural gas fired boilers and implementing other controls to reduce SO2 emissions. The table also provides SO2 control information for each of the emission units. Maximum potential emissions were calculated by multiplying the pound per hour (lb/hr) maximum allowable permit limit for each unit by the maximum hours of operation in a year. Except for the generators, maximum potential emissions were calculated using 8,760 hours per year. Maximum potential emissions for the generators were estimated assuming each generator is operated 500 hours per year. It is important to note that the maximum potential emissions represent worst-case emissions because processes cannot be operated at 100% capacity continuously for a whole year and all the processes are not operated at maximum emission limitations at the same time. Over the past 3 years (2017 through 2019), BRPP has completed significant capital investments in boilers and recovery furnaces (including new emissions controls) that have significantly reduced SO2 emissions by 93% (5,470 tons). These emissions units were chosen for emissions reductions because they had a more significant modeled impact on compliance with the SO2 NAAQS than other emission units at the mill. Much of the SO2 emission reductions has occurred during the past 2 years where the facility reduced emissions by 86% (2,497 tons). Table 2 provides a chronology of actions BRPP has completed since March 2015 that have reduced SO2 emissions at the Canton Mill. BRPP initially undertook capital improvements to comply with the boiler MACT which also reduced SO2 emissions. However, as required by the SOC, the facility further implemented process changes and improved controls to reduce SO2 emissions and corresponding ambient SO2 concentrations to comply with the NAAQS. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 11 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Table 1. Trends in Actual Annual SO2 Emissions (2017 – 2019) and Comparison of 2019 Actual Annual SO2 Emissions to Permitted Maximum Allowable Emissions for BRPP Canton Mill Annual SO2 Emissions (Tons) 2019 Annual Emissions as a Percent of Max. Allowable* SO2 Controls Permit ID Source Description 2017 2018 2019 Permitted Max. Allowable Emissions G08020 No. 10 Recovery Furnace – Black Liquor Solids (BLS) - normal operation 575.23 157.64 5.47 122.64 4 Furnace sodium salt fume provides SO2 control. G08020 No. 10 and No. 11 Recovery Furnace - Ultra-Low Sulfur Diesel (ULSD) - startup and shutdown 0.00 0.01 0.08 4.76 2 ULSD now used for startup and shutdown. G08021 No. 11 Recovery Furnace - BLS - normal operation 461.34 133.19 27.57 122.64 22 Furnace sodium salt fume provides SO2 control. G08022 Black Liquor Oxidation - Regenerative Thermal Oxidizer (RTO) 1.07 1.08 0.55 10.95 5 Wet scrubber. G08023 No. 10 Smelt Dissolving Tank 1.21 1.18 1.16 1.84 63 Wet scrubber. G08024 No. 11 Smelt Dissolving Tank 1.25 1.19 1.17 1.84 64 Wet scrubber. G09028 No. 4 Lime Kiln 1.31 1.11 1.41 27.51 5 Calcium in the kiln provides SO2 control along with the wet scrubber. G09029 No. 5 Lime Kiln 0.38 0.36 0.50 45.84 1 Calcium in the kiln provides SO2 control along with the wet scrubber. G11039 Riley Coal Boiler 1,388.41 833.39 115.08 268.58 43 Commenced initial operation of the new wet scrubbers on June 29, 2018. Adjusted reported 2018 emissions to account for scrubber SO2 control. The scrubber was operational when the boiler commenced operation following the shutdown required to install it. There was no delay between completion of construction and operation. G11040 No. 4 Power Boiler 1,561.36 1,168.63 195.21 360.12 54 Commenced initial operation of the new wet scrubbers on August 1, 2018. Adjusted reported 2018 emissions to account for scrubber SO2 control. The scrubber was operational when the boiler commenced operation following the shutdown required to install it. There was no delay between completion of construction and operation. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 12 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Annual SO2 Emissions (Tons) 2019 Annual Emissions as a Percent of Max. Allowable* SO2 Controls Permit ID Source Description 2017 2018 2019 Permitted Max. Allowable Emissions G11042 Riley Bark Boiler 687.09 602.20 55.07 297.84 18 Commenced monitoring of wet scrubber pH for SO2 control on September 10, 2018. Adjusted reported 2018 emissions to account for additional scrubber SO2 control. G11050 No. 1 Natural Gas Package Boilers 0.01 0.37 0.40 0.58 69 Startup on May 23, 2017. Permitted to burn only natural gas. G11051 No. 2 Natural Gas Package Boilers 0.01 0.43 0.41 0.58 71 Startup on May 23, 2017. Permitted to burn only natural gas. G12077 Calendar natural gas and/or propane hot oil heaters 0.01 0.01 0.01 0.05 20 Permitted to burn only natural gas or propane. 16-CU-001 One 1850 horsepower (hp), diesel- fired emergency generator 5.6E-03 5.6E-03 5.6E-03 5.6E-03 See note Permitted to burn only ULSD. Emissions conservatively estimated based on 500 hours per year of operation on 15 parts per million (ppm) sulfur diesel. Actual operating hours are less than 500. I- G23066.f- ire, I- G23066.f- rec, I- G23066.f- gen 200 hp Fire Control Generator #1; 200 hp Fire Control Generator #2; 64 hp Lime Kiln Emergency Generator; 227 hp Lime Kiln Emergency Generator; and 100-kilowatt (kW) Recovery Furnace Emergency Generator. 2.5E-03 2.5E-03 2.5E-03 2.5E-03 See note Permitted to burn only ULSD. Emissions conservatively estimated based on 500 hours per year of operation on 15 ppm sulfur diesel. Actual operating hours are less than 500. G11037 Big Bill coal-fired utility boiler (tons of bituminous coal/year) 538.11 0.00 0.00 0 0 Permanently shut down July 14, 2017. Removed from Permit No. 08961T28 in April 2020. G11038 Peter G-One Coal Fired utility boiler (tons of bituminous coal per year) 657.51 0.00 0.00 0 0 Permanently shut down Nov. 30, 2017. Removed from Permit No. 08961T28 in April 2020. Totals 5,875 2,901 405 1,266 Reduction (2018-2017) = 51% 2,973.51 Reduction (2019-2018) = 86% 2,496.70 Reduction (2019-2017) = 93% 5,470.21 * Represents maximum allowable emissions based on the maximum allowable permitted emission limitation x 8,760 hours per year divided by 2,000 lbs/ton (except for emergency engines, which are based on 500 hours per year). Final Source-Specific SIP for Blue Ridge Paper Products, LLC 13 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Table 2. Chronology of SO2 Emission Reduction Actions at Canton Mill (2017 – 2019) Date Action 3/28/2015 Mill begins operating under CAA Section 112(j) limits incorporated in Permit T16. Planning already in progress for major capital project (~$50 million) to meet 2019 Boiler MACT (Subpart DDDDD) compliance date. 8/21/2015 EPA promulgates Data Requirements Rule (DRR) for the 2010 1-Hour SO2 Primary NAAQS Standard [80 FR 51052, 8/21/15] 3/29/2016 DAQ issues Permit T18, which is a Part 1 Construction Permit allowing the facility to proceed with work planned to meet the Boiler MACT regulations 11/15/2016 Ambient SO2 monitor begins operation 1/1/2017 Ambient SO2 monitor - Start of data collection for 1-hour SO2 NAAQS 5/23/2017 Started Up No. 1 (East) Natural Gas Package Boiler 5/23/2017 Started Up No. 2 (West) Natural Gas Package Boiler 6/8/2017 The DAQ issued to BRPP an addendum to a previous notice of violation (dated 3/14/17, that was unrelated to SO2 emissions) and notified BRPP that the DAQ was planning to pursue additional enforcement action (civil penalty assessment) for the measured exceedances of the 1-hour SO2 NAAQS. 7/12/2017 Shut Down Big Bill Boiler (Coal-Fired) and removed from Permit No. 08961T28 in April 2020. Reduction in SO2 Emissions: 1,175 tons per year (TPY)* 10/9/2017 BRPP requested to enter into a special order by consent (SOC) agreement with the Environmental Management Commission to resolve SO2 NAAQS exceedances. SOC 2017-002 became effective 10/9/17 and required BRPP to take specific actions "…in order to memorialize (BRPP's) commitments to complete Boiler MACT improvements and, thereafter, to limit the facility's emissions of SO2." 11/17/2017 Installed natural gas startup burners on No. 4 Boiler 11/30/2017 Shut Down Peter G Boiler (Coal-Fired) and removed from Permit No. 08961T28 in April 2020. Reduction in SO2 emissions: 1,125 TPY* 6/29/2018 Started Operation of Riley Coal Wet Scrubber. The scrubber was operational when the boiler commenced operation following the shutdown required to install it. There was no delay between completion of construction and operation. Reduction in SO2 emissions: 2,050 TPY* 8/1/2018 Started Operation of No. 4 Boiler Wet Scrubber. The scrubber was operational when the boiler commenced operation following the shutdown required to install it. There was no delay between completion of construction and operation. Reduction in SO2 emissions: 1,775 TPY* 11/7/2018 Converted Recovery Furnace Auxiliary Fuel to ULSD from No. 6 Fuel Oil; Reduction in SO2 emissions: 1,050 TPY* 1/28/2019 Submitted SOC-Required Facility SO2 Emissions Report 5/20/2019 Mill begins operating under 40 CFR 63 Subpart DDDDD (Boiler MACT) 9/12/2019 NC DAQ issued Permit No. 08961T26 on 9/12/19 that incorporates NAAQS SO2 compliance language into Section 2.2 J of the permit (public comment period began 7/23/19 and closed 8/22/19. No comments were received on the permit). 12/31/2019 SOC 2017-002 Expires 1/10/2020 Permit No. 08961T27 modifications (Under NC 02Q .0516, this modification did not require public review/comment because the modification did not contradict or contravene any existing Title V permit conditions): • Modified configuration of condensate treatment for collected black liquor oxidation - RTO (G08022) system to hard pipe condensate to the biological treatment unit to reduce the amount of excess condensate diverted to the mill sewer system to reduce odors from the facility. • This permit revision did not affect SO2 emissions limits or monitoring, recordkeeping, reporting, or testing requirements specified in Section 2.2 J of the permit. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 14 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Date Action 5/22/2020 Permit No. 08961T28 modifications (public comment period began 2/29/20 and closed 3/15/20. EPAs original comment period ended March 30, 2020. On 4/6/20, EPA restarted their 45-day review that ended on 5/21/20.) • For Riley Coal Boiler (G11039), No. 4 Power Boiler (G11040), and Riley Bark Boiler (G11042), replaced CAA Section 112(j) Case-by-Case MACT requirements with 40 CFR Subpart MACT DDDDD (National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters) requirements. • Remove Big Bill (G11037) and Peter G. (G11038) Coal Boilers from permit. • Update language for 40 CFR Subpart MM (National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills). • Move two natural gas/propane hot oil heaters to the insignificant activities list (potential emissions less than 5 tons) • Incorporate minor modification request (application 4400159.20A) to revise the “Minimum Scrubber Liquid pH” parameter limit specified in Table 2.2 J.2 of the permit. • Clarified BLOX scrubber averaging period to be a 3-hour block average in Section 2.2 J. • Revised permit language regarding scrubber monitoring parameters for SO2 sources in Section 2.2 J to accommodate incorporation of requirements into the SIP. 6/02/2020 Permit No. 08961T29 modifications (Per 15 NCAC 2Q .0501(b)(2) and 2Q .0504, this modification was permitted using the two-step permitting process. Construction permit T29 was issued following the procedures in 2Q .0300 and did not trigger public participation requirements under 2Q .0306. Within twelve months of implementing the proposed change, the facility is required to apply for a revision of the Title V operating permit following the procedures in 15A NCAC 2Q .0500.): • Added two insignificant activities (these are not SO2 emissions sources): Causticizer (North) (ID No. I- G10036.10-TK-026) and White Liquor Pressure Disc Filter (ID No. I-G10036.10a). • Added footnotes indicating that the recausticizing area sources and the lime kiln scrubbers are modified under 15A NCAC 02D .0501(b)(2) as the first step of a two-step modification as proposed in Permit Application No. 4400159.20B. • Added a requirement to condition 2.1 O.1.b to conduct a particulate matter (PM) performance test within 180 days of normal operation after upgrades to lime kiln scrubbers as proposed in Permit Application No. 4400159.20B. • Added language to condition 2.1 O.1.e to specify that the No. 4 Lime Kiln Scrubber should be operated as previously permitted prior to the upgrades and that after upgrading the scrubber, the manufacturer- suggested operating parameters be used prior to the performance test and site-specific operating parameters be confirmed or reestablished during the initial performance test. • Added a footnote to the table in condition 2.1 O.5.d requiring that new minimum indicator ranges be established following the initial performance tests following upgrades to the lime kiln scrubbers. • Added recordkeeping and reporting condition 2.2 A.6 for projected actual emissions tracking (allowable emissions of SO2 did not increase with this modification and the lime kilns’ emissions will remain below the SO2 emissions limitations in condition 2.2 J.1). • Added condition 2.2 B.6 requiring a permit application to be submitted within one year from the date the upgraded No. 4 or No. 5 Lime Kiln Scrubbers resume normal operation or the completion of upgrades to the recausticizing sources as proposed in Application No. 4400159.20B, whichever is earlier. • Added condition 2.2 D.1.d.iv to require a performance test on the No. 5 Lime Kiln Scrubber within 180 days of resumption of normal operation after the scrubber upgrades. The upgraded No. 4 Lime Kiln Scrubber will be tested no later than October 13, 2020, per federal Subpart MM requirements. • Updated Table 2.2 D.2 to specify the operating parameter requirements before and after the scrubber upgrades to the No. 4 or No. 5 Lime Kiln Scrubbers. • Modified condition 2.2 J.1.c.iii to refer to the Federal Subpart MM lime kiln scrubber monitoring requirements in Section 2.2 D.1 instead of the State regulation requirements in Section 2.1 O.1. • Modified condition 2.2 J.1.d.i to add a requirement to conduct a performance test to demonstrate compliance with the SO2 emission limit following the modifications to the lime kiln scrubbers. * Estimated SO2 emission reduction calculated based on a review 2013-2016 reported actual emissions. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 15 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 2. Ambient Air Quality Monitoring (2017 – 2019) On November 15, 2016, the DAQ began operating an ambient air monitor near the facility. The monitoring site is located on Pace Street in Canton approximately 50 meters (164 feet) west of the facility’s fence line. The monitoring site was established and operated following EPA guidance and regulations for the purpose of establishing a 3-year design value to establish compliance with the NAAQS.8F 9, 9F 10, 10F 11, 11F 12, 12F 13 Table 3 shows the certified 99th percentile ambient SO2 concentrations recorded by the monitor for CY 2017, 2018, and 2019, and the 3-year design value. The 3-year design value for the site is 152 ppb which is well above the NAAQS. However, the 99th percentile value for CY 2019 reflects the significant SO2 emission reductions that have occurred at the facility after implementing modifications to boilers and recovery furnaces, construction of new gas-fired boilers, and installation of new control equipment on two boilers. Going forward, ambient SO2 concentrations are expected to remain below the NAAQS as shown by the monitoring results for CY 2019. Table 3. Certified Ambient Air SO2 Monitoring Data (2017 – 2019) 99th Percentile (ppb) Monitoring Site ID Monitor Name County / Township 2017 2018 2019 3-Year Design Value (2017-2019) Percent of the NAAQS (75 ppb) 370870013 Canton DRR Haywood / Beaverdam 206.8 213.4 34.8 152 202% 3. Permit Requirements BRPP’s Title V permit has been modified (Permit No. 08961T26 was issued September 12, 2019) to add Section 2.2 J to address requirements specified in the SOC and place the facility on track to meet the 2010 1-hour SO2 NAAQS on a 3-year design value basis. The legal basis for the permit requirements is rooted in North Carolina’s Rule 15A NCAC 02D .0501(c) (Compliance with the National Ambient Air Quality Standards). As stated in Section 2.2 J of the permit, pursuant to 15A NCAC 02D .0501(c), when controls more stringent than named in the 9 Data Requirements Rule for the 2010 1-Hour Sulfur Dioxide (SO2) Primary National Ambient Air Quality Standard (NAAQS), Final Rule, 80 FR 51052, August 21, 2015 (https://www.govinfo.gov/content/pkg/FR-2015-08- 21/pdf/2015-20367.pdf). 10 40 CFR 58, Ambient Air Quality Surveillance (https://www.ecfr.gov/cgi-bin/text- idx?SID=3167f9654633153ed439d0264f9fdb66&mc=true&node=pt40.6.58&rgn=div5). 11 Quality Assurance Project Plan for the North Carolina Division of Air Quality SO2 Data Requirements Rule Monitoring Program, December 20, 2016 (https://files.nc.gov/ncdeq/Air%20Quality/monitor/QAPlans/SO2_DRR_QAPP.pdf). 12 North Carolina Department of Environmental Quality 2016-2017 Final Network Monitoring Plan, Appendix E. Evergreen Packaging Canton Siting Analysis and Additional Site Information, July 1, 2016, available at http://xapps.ncdenr.org/aq/documents/DocsSearch.do?dispatch=download&documentId=13137. 13 SO2 NAAQS Designations Source-Oriented Monitoring Technical Assistance Document, U.S. EPA, Office of Air and Radiation, Office of Air Quality Planning and Standards, Air Quality Assessment Division, February 2016, Draft, available at https://www3.epa.gov/airquality/so2implementation/SO2MonitoringTAD.pdf. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 16 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 applicable emission standards in Section .0500 are required to prevent violation of the ambient air quality standards or are required to create an offset, the permit shall contain a condition requiring these controls. On February 28, 2018, BRPP submitted a permit application (No. 4400159.18E) to the DAQ detailing plans for complying with the SOC. The application included proposed emission limitations and a modeling analysis to demonstrate compliance with the 1-hour SO2 NAAQS. The SOC also required emissions testing for the No. 4 Coal Boiler, Riley Bark Boiler, Riley Coal Boiler, and the No. 10 and No. 11 Recovery Furnaces after improvements to these sources were completed. Therefore, the DAQ waited for the source test results and BRPP provided a revised modeling analysis on February 12, 2019, incorporating revised emission limitations based on the test results. The test results were also used as the basis for developing monitoring requirements to verify the emission limitations for the five sources tested. The DAQ approved the modeling analysis on April 2, 2019 and submitted a draft permit to BRPP for review and comment. The DAQ addressed BRPP’s comments and proceeded to take the draft permit to public comment from July 23, 2019 through August 22, 2019. No public comments or comments from EPA were received. The final permit was issued on September 12, 2019. Table 4 lists the emission sources and allowable SO2 emission limitations included in the final permit. Table 4 also identifies the emission sources proposed for inclusion in the SIP. Table 4. Allowable SO2 Emission Limitations Modeled and Included in the Title V Permit Permit ID Emission Source Description Allowable SO2 Emission Limitation, Pound per Hour (lb/hr) Proposed for Inclusion in SIP G08020 No. 10 Recovery Furnace - BLS - normal operation 28.0 Yes G08020 No. 10 Recovery Furnace - ULSD - startup and shutdown 0.54 Yes G08021 No. 11 Recovery Furnace - BLS - normal operation 28.0 Yes G08021 No. 11 Recovery Furnace - ULSD - startup and shutdown. 0.54 Yes G08023 No. 10 Smelt Dissolving Tank 0.42 No G08024 No. 11 Smelt Dissolving Tank 0.42 No G09028 No. 4 Lime Kiln 6.28 Yes G09029 No. 5 Lime Kiln 10.47 Yes G11039 Riley Coal Boiler 61.32 Yes G11040 No. 4 Power Boiler 82.22 Yes G11042 Riley Bark Boiler 68.00 Yes G12077 Calendar natural gas and/or propane hot oil heaters 0.012 No 16-CU-001 1850 hp Backup Diesel Generator (Engine) 0.022 No I-G23066.f-ire 200 hp Fire Control Generator #1 (Engine) 2.43E-03 No I-G23066.f-ire 200 hp Fire Control Generator #2 (Engine) 2.43E-03 No I-G23066.f-gen 64 hp Lime Kiln Emergency Generator (Engine) 7.77E-04 No I-G23066.f-gen 227 hp Lime Kiln Emergency Generator (Engine) 2.75E-03 No I-G23066.f-rec 100 kW Recovery Furnace Emergency Generator (Engine) 1.42E-03 No G08022 Black Liquor Oxidation - RTO 2.50 No G11050 No. 1 Natural Gas Package Boiler 0.13 No G11051 No. 2 Natural Gas Package Boiler 0.13 No Final Source-Specific SIP for Blue Ridge Paper Products, LLC 17 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 4. Air Quality Modeling Demonstration for Facility This section summarizes air quality modeling completed to demonstrate that the SO2 emission limitations in the permit will be protective of the 1-hour SO2 NAAQS in North Carolina and the downwind neighboring states of South Carolina and Tennessee. BRPP contracted with AECOM to perform emissions modeling to characterize the facility’s emission sources and develop allowable SO2 emission limitations based on modeled predictions of ambient SO2 concentrations for inclusion in its permit application. The DAQ and EPA reviewed the modeling analysis conducted by AECOM. AECOM addressed DAQ’s and EPA’s comments and a revised modeling analysis was submitted to DAQ. The DAQ subsequently approved the modeling analysis of allowable SO2 emission limitations for inclusion in the facility’s Title V permit. The following discussion is based on information provided in AECOM’s report and the DAQ’s review of the AECOM’s report (see Attachments 2 and 3). a. Facility Site Location The facility is located at 175 Main Street in the City of Canton, Beaverdam Township, Haywood County, North Carolina ("Facility") about 25 km (15.5 miles) west of Asheville, North Carolina (see Figure 1). The facility is situated on the Pigeon River on a 200-acre site in downtown Canton. The facility is surrounded by complex terrain with elevations of 1,220 meters (4,000 feet) within 5 km (3.1 miles) of the facility. Figure 2 shows the surrounding topography. Figure 3 shows the location of the SO2 emission sources at the facility included in the modeling analysis. b. Facility 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 (BLS). 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. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 18 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 The mill utilizes multiple boilers to produce steam for energy generation and provide heat for the pulping and paper making processes. The 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. Figure 2. Location of Blue Ridge Paper Products LLC, Canton Mill, Canton, NC, and Surrounding Topography Final Source-Specific SIP for Blue Ridge Paper Products, LLC 19 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Figure 3. Location of SO2 Emission Sources Included in Modeling Analysis for Blue Ridge Paper Products LLC Final Source-Specific SIP for Blue Ridge Paper Products, LLC 20 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 c. Emission Source Modeling – Onsite Sources American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) (v.18081) was used to assess air quality impacts following EPA guidance.13F 14 The AERMOD model uses a steady state Gaussian plume equation to model emissions from point sources such as stacks and vents. The Canton Mill is located in an area of complex terrain. 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 on-site meteorological data for the years 2012-2016. The 1-hour SO2 emission limitations were modeled for each source using 5 years of meteorological data. For each receptor, the 99th percentile of the max daily 1-hour concentration for each year was averaged over 5 years to estimate the maximum concentration for each receptor. To ensure the worst-case emissions and source parameterization, based on fuel type, was modeled, the model was run for all sources together under two scenarios: (1) the recovery furnaces burning ultra-low sulfur diesel (ULSD) during start-up and shut down, and (2) burning BLS during normal operation. These two scenarios were modeled because the different fuels for the recovery furnaces led to different stack exhaust temperatures and exit velocities. Table 5 shows the basis for developing the modeled emission limitations for each source. Further details documenting the emission factors are provided in the modeling memo (see Attachment 2). The SOC required emissions source testing of the No. 10 and No. 11 Recovery Furnaces burning BLS, Riley Coal Boiler, No. 4 Coal Boiler, and Riley Bark Boiler. The source test results were used to develop the emission limitations and establish parametric monitoring parameters to be used to verify compliance with the limitations for these five processes. Table 5 shows the allowable emission limitations and the relative contribution of each source to the total 1-hour maximum emission limitation for all SO2 sources. Tables 6 and 7 show the coordinates, stack parameters, and emission limitations modeled for the recovery furnaces burning ULSD and BLS, respectively. All sources were modeled as point sources using actual stack exhaust parameters. In accordance with modeling protocol, the actual stack heights modeled were all below the calculated Good Engineering Practice stack heights. The following provides information on each SO2 emission source; controls; and basis for the maximum allowable emission limitations modeled for the attainment demonstration; and monitoring, recordkeeping, reporting, and testing requirements. Emergency Generators These emergency generators burn 15 parts per million (ppm) sulfur diesel and are operated intermittently throughout the year. The units are not capable of burning any fuel other than diesel and there are no plans to burn anything other than 15 ppm sulfur diesel in these units in the future. 14 40 CFR Part 51, Appendix W, Guideline on Air Quality Models. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 21 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Table 5. Modeled Allowable SO2 Emission Limitations Permit ID Modeling Source ID Source Description SO2 Control Method Limit or Emission Factor, Pre- control Emissions Basis Activity Factor Control Efficiency for Pre- Control Emission Factors Highest Actual One Hour Emission Rate During Test, lb/hr 3-hour Average Emission Rate During Test, lb/hr Modeled Emissio n Rate, lb/hr % of Total Modeled Emission Limitation G08020 10REC No. 10 Recovery Furnace - BLS Furnace sodium salt fume provides SO2 control N/A 27.9 21.4 28.0 9.7 G08020 10REC No. 10 Recovery Furnace - ULSD ULSD now used for startup and shutdown 0.2 pound (lb)/1000 gallons (gal) AP-42 Table 1.3-1 (15 ppm S ULSD) 382 MMBtu/hr N/A N/A N/A 0.54 0.2 G08021 11REC No. 11 Recovery Furnace - BLS Furnace sodium salt fume provides SO2 control N/A 2.3 1.9 28.0 9.7 G08021 11REC No. 11 Recovery Furnace - ULSD ULSD now used for startup and shutdown 0.2 lb/1000 gal AP-42 Table 1.3-1 (15 ppm S ULSD) 382 MMBtu/ hr N/A N/A N/A 0.54 0.2 G08023 10SDT No. 10 Smelt Dissolving Tank Wet scrubber 0.006 lb/Total BLS NCASI TB 1020, Table 4.15 Median 70 Total BLS/hr N/A N/A N/A 0.42 0.1 G08024 11SDT No. 11 Smelt Dissolving Tank Wet scrubber 0.006 lb/Total BLS NCASI TB 1020, Table 4.15 Median 70 Total BLS/hr N/A N/A N/A 0.42 0.1 G09028 4LIME No. 4 Lime Kiln Calcium in the kiln provides SO2 control along with the wet scrubber 314.0 lb/1000 gal AP-42 Table 1.3-1 (2.0%S #6 oil) 60 MMBtu/hr 95% 0.40 0.31 6.28 2.2 G09029 5LIME No. 5 Lime Kiln Calcium in the kiln provides SO2 control along with the wet scrubber 314.0 lb/1000 gal AP-42 Table 1.3-1 (2.0%S #6 oil) 100 MMBtu/hr 95% 0.13 0.10 10.47 3.6 G11039 RLCOAL Riley Coal Boiler Wet scrubber N/A 56.4 54.5 61.32 21.2 G11040 NO4BOIL No. 4 Power Boiler Wet scrubber N/A 71.4 69.3 82.22 28.4 G11042 RLBARK Riley Bark Boiler Wet scrubber N/A 68.0 59.8 68.00 23.5 G12077 PM19NIP No. 19 Paper Machine including Nip heaters (natural gas fired) Wet Fire natural gas or propane only 6.00E-07 pound per standard cubic feet (lb/scf) AP-42 Table 1.4-2 20,000 standard cubic feet per hour (scf/hr) N/A N/A N/A 0.012 0.004 Final Source-Specific SIP for Blue Ridge Paper Products, LLC 22 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Permit ID Modeling Source ID Source Description SO2 Control Method Limit or Emission Factor, Pre- control Emissions Basis Activity Factor Control Efficiency for Pre- Control Emission Factors Highest Actual One Hour Emission Rate During Test, lb/hr 3-hour Average Emission Rate During Test, lb/hr Modeled Emissio n Rate, lb/hr % of Total Modeled Emission Limitation 16-CU- 001 1850GE N 1850 hp Backup Diesel Generator Fire ultralow sulfur diesel only 1.21E-05 pound per horsepower- hour (lb/hp- hr) AP-42 Table 3.4-1 (15 ppm S ULSD) 1850 hp N/A N/A N/A 0.022 0.008 I- G23066 .f-ire FP200#1 200 hp Fire Control Generator #1 Fire ultralow sulfur diesel only 1.21E-05 lb/hp-hr AP-42 Table 3.4-1 (15 ppm S ULSD) 200 hp N/A N/A N/A 0.00243 0.001 I- G23066 .f-ire FP200#2 200 hp Fire Control Generator #2 Fire ultralow sulfur diesel only 1.21E-05 lb/hp-hr AP-42 Table 3.4-1 (15 ppm S ULSD) 200 hp N/A N/A N/A 0.00243 0.001 I- G23066 .f-gen LKGEN 64 64 hp Lime Kiln Emergency Generator Fire ultralow sulfur diesel only 1.21E-05 lb/hp-hr AP-42 Table 3.4-1 (15 ppm S ULSD) 64 hp N/A N/A N/A 0.000777 0.0003 I- G23066 .f-gen LKGEN 227 227 hp Lime Kiln Emergency Generator Fire ultralow sulfur diesel only 1.21E-05 lb/hp-hr AP-42 Table 3.4-1 (15 ppm S ULSD) 227 hp N/A N/A N/A 0.00275 0.001 I- G23066 .f-rec RFGEN SET100 100 kW Recovery Furnace Emergency Generator Fire ultralow sulfur diesel only 0.0015 pound per million standard cubic feet (lb/MMscf) AP-42 Table 3.4-1 (15 ppm S ULSD) 0.94 MMBtu/ hr N/A N/A N/A 0.00142 0.0005 G08022 BLOXR TO Black Liquor Oxidation - RTO Wet scrubber 0.25 pound per hour (lb/hr) 2007 RTO NOCS Stack Testing 10 multiplie r N/A N/A N/A 2.5 0.9 G11050 225NGB LS No. 1 Natural Gas Package Boiler Fire natural gas only 0.6 lb/MMscf AP-42 Table 1.4-2 225 MMBtu/ hr N/A N/A N/A 0.13 0.05 G11051 225NGB LS No. 2 Natural Gas Package Boiler Fire natural gas only 0.6 lb/MMscf AP-42 Table 1.4-2 225 MMBtu/ hr N/A N/A N/A 0.13 0.05 Final Source-Specific SIP for Blue Ridge Paper Products, LLC 23 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Table 6. Model Inputs for Recovery Furnaces Burning Ultra-Low Sulfur Diesel (ULSD) Modeling Scenario Permit ID Modeling Source ID Source Description Easting (X) (meters) Northing (Y) (meters) Base Elevation (meters) Stack Height (feet) Temp. (°F) Exit Velocity (feet/sec.) Stack Diameter (feet) SO2 Emission Rate (lb/hr) G08020 10REC No. 10 Recovery Furnace 332,859 3,934,015 787 203 185 52.9 12.0 0.54 G08021 11REC No. 11 Recovery Furnace 332,854 3,934,026 787 203 185 54.0 12.0 0.54 G08023 10SDT No. 10 Smelt Dissolving Tank 332,853 3,934,005 787 203 155 28.9 4.0 0.42 G08024 11SDT No. 11 Smelt Dissolving Tank 332,855 3,934,028 787 203 156 30.0 4.0 0.42 G09028 4LIME No. 4 Lime Kiln 332,849 3,934,005 787 190 154 36.8 4.0 6.28 G09029 5LIME No. 5 Lime Kiln 332,837 3,934,028 787 204 149 27.6 5.0 10.47 G11039 RLCOAL Riley Coal Boiler 333,058 3,933,937 787 260 130 61.4 7.9 61.32 G11040 NO4BOIL No. 4 Boiler-Coal 333,004 3,933,967 787 260 130 61.8 7.9 82.22 G11042 RLBARK Riley Bark Boiler 332,980 3,934,079 792 145 120 48.6 7.9 68.00 G12077 PM19NIP No. 19 Paper Machine including Nip heaters (natural gas fired) Wet 333,362 3,933,924 790 63 181 48.8 2.9 0.012 16-CU-001 1850GEN 1850 hp Backup Diesel Generator 332,541 3,933,621 792 30 900 0.03 1.0 0.022 I-G23066.f-ire FP200#1 200 hp Fire Control Generator #1 333,176 3,934,072 792 11 900 0.03 0.5 0.00243 I-G23066.f-ire FP200#2 200 hp Fire Control Generator #2 333,072 3,934,366 819 8 900 0.03 0.3 0.00243 I-G23066.f-gen LKGEN64 Diesel emergency generators for lime kilns 332,853 3,933,977 787 10 900 98.4 0.2 0.000777 I-G23066.f-gen LKGEN227 Diesel emergency generators for lime kilns 332,853 3,933,977 787 20 900 0.03 0.5 0.00275 I-G23066.f-rec RFGENSET100 100 kW recovery furnace emergency generator 332,821 3,934,084 787 9 900 0.03 0.3 0.00142 G08022 BLOXRTO Black Liquor Oxidizer RTO 332,821 3,934,087 788 100 125 28.0 4.0 2.50 G11050/ G11051 225NGBLS 225 MMBtu/hr Natural Gas Package Boilers 1 and 2 Common Stack w/ economizer 333,125 3,934,017 787 165 325 52.9 7.9 0.26 Final Source-Specific SIP for Blue Ridge Paper Products, LLC 24 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Table 7. Model Inputs for Recovery Furnaces Burning Black Liquor Solids (BLS) Modeling Scenario Permit ID Modeling Source ID Source Description Easting (X) (meters) Northing (Y) (meters) Base Elevation (meters) Stack Heig ht (feet) Temp. (°F) Exit Velocity (feet/sec.) Stack Diameter (feet) SO2 Emission Rate (lb/hr) G08020 10REC No. 10 Recovery Furnace 332,859 3,934,015 787 203 245 52.3 12.0 28.0 G08021 11REC No. 11 Recovery Furnace 332,854 3,934,026 787 203 258 58.2 12.0 28.0 G08023 10SDT No. 10 Smelt Dissolving Tank 332,853 3,934,005 787 203 155 28.9 4.0 0.42 G08024 11SDT No. 11 Smelt Dissolving Tank 332,855 3,934,028 787 203 156 30.0 4.0 0.42 G09028 4LIME No. 4 Lime Kiln 332,849 3,934,005 787 190 154 36.8 4.0 6.28 G09029 5LIME No. 5 Lime Kiln 332,837 3,934,028 787 204 149 27.6 5.0 10.47 G11039 RLCOAL Riley Coal Boiler 333,058 3,933,937 787 260 130 61.4 7.9 61.32 G11040 NO4BOIL No. 4 Boiler-Coal 333,004 3,933,967 787 260 130 61.8 7.9 82.22 G11042 RLBARK Riley Bark Boiler 332,980 3,934,079 792 145 120 48.6 7.9 68.00 G12077 PM19NIP No. 19 Paper Machine including Nip heaters (natural gas fired) Wet 333,362 3,933,924 790 63 181 48.8 2.9 0.012 16-CU-001 1850GEN 1850 hp Backup Diesel Generator 332,541 3,933,621 792 30 900 0.03 1.0 0.022 I-G23066.f-ire FP200#1 200 hp Fire Control Generator #1 333,176 3,934,072 792 11 900 0.03 0.5 0.00243 I-G23066.f-ire FP200#2 200 hp Fire Control Generator #2 333,072 3,934,366 819 8 900 0.03 0.3 0.00243 I-G23066.f-gen LKGEN64 Diesel emergency generators for lime kilns 332,853 3,933,977 787 10 900 98.4 0.2 0.000777 I-G23066.f-gen LKGEN227 Diesel emergency generators for lime kilns 332,853 3,933,977 787 20 900 0.03 0.5 0.00275 I-G23066.f-rec RFGENSET100 100kW RF Emergency Generator 332,821 3,934,084 787 9 900 0.03 0.3 0.00142 G08022 BLOXRTO Black Liquor Oxidizer RTO 332,821 3,934,087 788 100 125 28.0 4.0 2.50 G11050/ G11051 225NGBLS 225 MMBtu/hr Natural Gas Package Boilers 1 and 2 Common Stack w/ economizer 333,125 3,934,017 787 165 325 52.9 7.9 0.26 Final Source-Specific SIP for Blue Ridge Paper Products, LLC 25 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Nos. 10 and 11 Recovery Furnaces The Nos. 10 and 11 recovery furnaces serve to recover pulping chemicals from spent pulping liquor (black liquor). In order to start the units up, fuel oil is burned for a period of time to warm up the furnace. The exhaust parameters during startup differ from that of normal operation - the exhaust flow and temperature are lower when only startup fuel is being fired. Therefore, two operating scenarios were modeled. As the furnace warms up, black liquor is introduced into the furnace and fuel oil is reduced, until the furnace meets full load firing black liquor. During startup, the sulfur in the fuel oil is oxidized to SO2 and emitted. During normal operation, after startup is completed, the sodium salt fume in the top of the furnace provides capture of SO2 produced from combustion of sulfur compounds in the black liquor. Some of the sulfur is captured as sodium sulfide in the smelt bed in the bottom of the furnace. Sodium sulfate particles generated from the reaction of SO2 and sodium in the furnace salt fume are captured in the ESP. For normal operation burning black liquor, the modeled emission limitations are conservative estimates based on source testing conducted in November 2018. The 28 lb/hr maximum allowable emission limitation modeled was derived from the highest one-hour emission rate test that was conducted on the No. 10 Recovery Furnace when the smelt bed in the bottom of the furnace was building back up after a period of ULSD firing during start-up. Thus, the emission limitation modeled is based on conditions that yield the highest SO2 emissions that would occur during a 1-hour period. Emissions would be lower after the smelt bed in the bottom of the furnace was fully established. This modeled emission limitation was also modeled for the No. 11 Recovery Furnace. It is expected that for the majority of operating time the furnaces will emit closer to 2.3 lb/hr as evidenced by the No. 11 recovery boiler test results. The Title V permit requires that the furnaces burn only ULSD during start-up and shutdown. The modeled emission limitation during start-up and shutdown was calculated using 15 ppm sulfur in ULSD from Compilation of Air Pollutant Emissions Factors (AP-42), Table 1.3-1. BRPP’s Title V permit requires the facility to conduct source tests annually to determine compliance with the emission limitations. Riley Coal Boiler, No. 4 Power Boiler, and Riley Bark Boiler These boilers are operated to produce steam for energy generation and provide heat for the pulping and paper making processes. The Riley Coal and No. 4 Power Boilers are controlled with caustic wet scrubbers while the Riley Bark Boiler is controlled with a venturi scrubber with caustic addition. The modeled emission limitation for each of the boilers is based on emission rates established by source testing after the wet scrubber. The wet scrubber on each boiler is required to be operated continuously and is considered a part of the physical and operational design of the boiler. Testing was conducted downstream of the scrubber while each boiler was burning coal to develop emission rates reflecting worst-case SO2 emissions after control. For the Riley Coal Boiler, the maximum emission limitation modeled and included in the permit is 8% higher than Final Source-Specific SIP for Blue Ridge Paper Products, LLC 26 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 the highest emission rate recorded during three separate 1-hour test runs, or 11% higher than the average emission rate for the three 1-hour test runs. For the No. 4 Power Boiler, the maximum emission limitation modeled and included in the permit is 13% higher than the highest emission rate recorded during three separate 1-hour test runs, or 16% higher than the average emission rate for the three 1-hour test runs. For the Riley Bark Boiler, the maximum emission limitation modeled and included in the permit is equal to the highest emission rate recorded during three separate 1-hour test runs, or 12% higher than the average emission rate for the three 1-hour test runs. The maximum emission limitation modeled for each boiler provides a margin of safety to ensure that each boiler will comply with the emission limitation and be protective of the NAAQS. Each scrubber is subject to monitoring, recordkeeping, reporting, testing, and compliance certification requirements specified in the Title V permit. The facility is required to continuously monitor the scrubber water pH and flow rate calculated as 3-hour block averages established based on three 1-hour source test runs to determine continuous compliance with the SO2 permit limit. As long as the 3-hour block averages for the pH and scrubber liquid flow are maintained, compliance with a 3-hour block average emission limitation will be maintained. For the Riley Coal and No. 4 Power Boilers, testing is required on an annual basis or, once a test is conducted such that the results of the test are less than 80% of the SO2 emission limitation, BRPP will be required to stack test only once every five years. This reduction in testing frequency for sources with control devices, monitored operating parameter limits, and large margins of compliance is consistent with the federal rules applicable to the facility (i.e., New Source Performance Standards (NSPS), MACT, Compliance Assurance Monitoring (CAM), and Title V). The scrubbers for the Riley Coal, Riley Bark, and No. 4 Power Boilers are also used to comply with the Boiler MACT. For consistency and quality data, the continuous monitoring system (CMS) used to measure pH and scrubber flow for purposes of determining compliance with the SO2 limits in the Title V permit are the same as the Boiler MACT CMS requirements for installation, operation, and maintenance. Table 8 shows the change in allowable SO2 emissions before and after installing and operating the wet scrubbers on the Riley Coal and No. 4 Power Boilers, and before and after requiring pH monitoring on the Riley Bark Boiler scrubber for SO2 control. The Riley Coal Boiler Potential- to-Emit (PTE) decreased from 4,019.5 TPY to 268.6 TPY (93.3%). The No. 4 Power Boiler PTE decreased from 2,812 TPY to 360.1 TPY (87.2%). The Riley Bark Boiler PTE decreased from 3,828.1 TPY to 297.8 TPY (92.2%). These calculations are based on the previous SO2 lb/MMBtu permit limits and boiler capacities versus the lb/hr SO2 emissions limits specified in Section 2.2 J of the Title V permit equivalent TPY based on 8,760 hours. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 27 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Table 8. Change in Allowable SO2 Emissions for Riley Coal, No. 4 Power, and Riley Bark Boilers Boiler Allowable SO2 Emissions per Permit Condition 2.2 J1 Allowable SO2 Emissions in Permit prior to Permit Condition 2.2 J Percent Reduction in Potential- to-Emit (PTE) SO2 Limit (lb/hr) Equivalent Annual Limit (TPY)2 Boiler Capacity (MMBtu/hr) SO2 Limit (lb/MMBt u heat input) Equivalent Annual Emissions (TPY)3 Riley Coal 61.32 268.6 399 2.3 4,019.5 93.3% No. 4 Power 82.22 360.1 535 1.2 2,812.0 87.2% Riley Bark 68 297.8 380 2.3 3,828.1 92.2% 1 Allowable SO limits added to the permit (No. 08961T26) to comply with the SOC. 2 ((SO2 limit (lb/hr)) x (8,760 hrs/year)) / (2,000 lb/ton). 3 ((Boiler capacity (MMBtu/hr)) * (SO2 limit (lb/MMBtu)) x (8,760 hrs/year)) / (2,000 lb/ton). Nos. 4 and 5 Lime Kilns The Nos. 4 and 5 lime kilns are part of the Kraft pulp mill chemical recovery cycle and following startup, they calcine lime mud (CaCO3) to produce lime product (CaO). During normal operation, the kilns emit very little SO2 because the calcium in the lime mud absorbs sulfur and the wet scrubbers that control kiln emissions also absorb sulfur. The wet scrubbers are primarily in place to control emissions of particulate matter (PM) and total reduced sulfur (TRS) but also control emissions of SO2 during startup and can provide some control of SO2 during normal operation. The kilns are equipped with TRS continuous emissions monitoring system and scrubber parameter monitors that ensure proper scrubber operation. The lime kilns burn a combination of No. 6 fuel oil and natural gas during both startup and normal operation, with the majority of the heat input coming from natural gas. The modeled emission limitation from the lime kilns represents worst-case hourly emissions during startup on No. 6 fuel oil (with the scrubbers operational), prior to introduction of lime mud into the kilns. The kilns go through startup approximately once per month for Kiln No. 4 and every other month for Kiln No. 5. If it is a warm startup (11 out of 12 months), startup takes less than 12 hours. Startup after the annual cold outage can take 24 to 30 hours with intermittent heat input so that the kiln does not warm up too quickly. The modeled emission limitation for each lime kiln was calculated using the SO2 emission factor for #6 fuel oil (314.0 pounds (lb)/1000 gallons (gal) using 2.0% sulfur) from AP-42, Table 1.3-1, the burner rating for each kiln, and 95% scrubber control. The modeled emission limitations are based on startup of the kilns on No. 6 fuel oil (while the scrubbers are in operation) that represent short-term, worst case emissions only achieved during startup. Source testing was conducted on each lime kiln during normal operation and the source test results showed that the emission rate for each kiln was many times lower than the emission rate calculated using the emission factor. Average values for No. 4 and No. 5 Lime Kilns during the most recent stack test were an order of magnitude lower than the permit limits, at 0.31 and 0.10 lb/hr SO2, respectively. For the Final Source-Specific SIP for Blue Ridge Paper Products, LLC 28 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 permitted emission limitation, it was decided to use the higher emission rate based on the emission factor to be conservative in the modeling. Normal emission rates are expected to be quite low, based on stack test results, and contribute little to the mill's ambient SO2 impact. For the scrubbers, BRPP’s Title V permit requires the facility to continuously operate and monitor scrubbing liquid flow rate and pressure drop established during source testing to comply with requirements under 15A NCAC 02D .0508 (Particulates From Pulp And Paper Mills); 02D .0614 (CAM); and 02D .1111 (MACT - 40 CFR 63 Subpart MM). As such, the facility is required to operate the scrubbers for PM control (which also results in SO2 control) by regulations that are in addition to the SO2 control requirements specified in Section 2.2 J of the Title V permit and also ensure compliance with the modeled SO2 emission limitations. The Subpart MM requirements are cross referenced in Section 2.2 J.1 of the permit. To verify the modeled emission limitations in Section 2.2 J of the permit, the facility is required to perform annual testing or, once a test is conducted such that the results of the test are less than 50% of the emission limitation, the facility is required to stack test only once every five years. This reduction in testing frequency for sources with control devices, monitored operating parameter limits, and large margins of compliance is consistent with the federal rules applicable to the facility (i.e., NSPS, MACT, CAM, and Title V). The upgrades to the Nos. 4 and 5 Lime Kilns scrubbers authorized by permit revision 08961T29 will not increase SO2 emissions above the allowable emissions rates. The scrubber upgrades do not increase the permitted capacity of the Nos. 4 and 5 Lime Kilns and therefore the allowable SO2 emissions rates remain unchanged as a result of the scrubber upgrades. As noted above, the actual Nos. 4 and 5 Lime Kilns SO2 emissions rates measured during the most recent compliance test in December 2019 were less than 5% of the allowable emissions rate. Nos. 10 and 11 Smelt Dissolving Tank These processes dissolve smelt from the recovery furnaces; they do not burn any fuel. A small amount of sulfur is formed as a result of chemical reactions in the tanks. The smelt dissolving tanks are controlled with wet scrubbers. Although the scrubbers are installed primarily for control of PM and TRS emissions, they also control SO2 emissions. Each smelt tank was modeled with a maximum allowable SO2 emissions of 0.42 lb/hr based on NCASI emissions data that ranges from non-detect to low, and these emissions are likely a result of either carryover from the recovery furnace or smelt/water interactions. The scrubbers are subject to monitoring, recordkeeping, reporting, testing, and compliance certification requirements specified in the Title V permit per North Carolina’s rules 15A NCAC 02D .0524 (NSPS Subpart BB); 02D .0614 (CAM); and 02D .1111 (MACT - 40 CFR 63 Subpart MM). To comply with these requirements, the permit requires continuous monitoring of the scrubbing liquid flow rate and pressure drop. Since it is expected that their operation will contribute to the reduction of SO2 emissions, the facility is required to operate these scrubbers for PM control (which also results in SO2 control) by regulations that are in addition to Section 2.2 J.1 that also ensure compliance with the modeled SO2 emission limitations. These requirements are cross referenced in Section 2.2 J.1 of the permit. No emission testing of the Final Source-Specific SIP for Blue Ridge Paper Products, LLC 29 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 scrubbers for SO2 is included in the permit because the maximum allowable emission limitation is very low. Calendar Natural Gas and/or Propane Hot Oil Heaters Two small natural gas heaters (3.9 MMBtu/hr each) are used to warm oil for the calendar that is used to roll paper. The heaters heat tubes through which oil is circulated; therefore, the oil does not come into direct contact with any flames from the heaters. The heaters are permitted to burn (and are only capable of burning) only natural gas and propane. The sulfur content of propane is over 70% lower than the sulfur content of natural gas. Therefore, potential maximum emissions were calculated assuming that the two heaters burn natural gas. The emission rates represent the maximum SO2 emissions that the sources could potentially emit based on their operational and physical design. There are no plans to modify these sources to burn any fuel other than gas due to requirements for operating the calendar (i.e., consistent, and clean heat). These small natural gas heaters, which have inherently low SO2 emissions, are not subject to any monitoring, recordkeeping, and reporting requirements. These sources are required to burn only natural gas or propane thus ensuring compliance with the emission limitations for these units. In addition, these units cannot burn fuels other than natural gas or propane because of their operational and physical design. Black Liquor Oxidation – Regenerative Thermal Oxidizer (RTO) The black liquor oxidation system is vented to an RTO and a caustic wet scrubber. Combustion of TRS compounds in the RTO creates SO2. The black liquor oxidation system itself does not combust any fuel; however, the RTO combusts a small amount of natural gas. The Title V permit requires the RTO to be controlled by a wet scrubber as part of a Prevention of Significant Deterioration (PSD) avoidance condition to limit SO2 emissions to less than 40 TPY. The wet scrubber is required to be operated continuously and is considered as a part of the physical and operational design of the black liquor oxidation system – RTO. Source testing downstream of the scrubber measured controlled emissions at approximately 0.25 lb/hr (all runs were less than 0.5 lb/hr). For attainment demonstration purposes, BRPP chose to model an emission rate of 2.5 lb/hr which is 10 times higher than the rate measured during source testing to be conservative. The scrubber is subject to monitoring, recordkeeping, reporting, testing, and compliance certification requirements specified in the Title V permit. The facility is required to continuously monitor the scrubber water pH and flow rate calculated as 3-hour block averages established based on three 1-hour source test runs to determine continuous compliance with the permit limit. As long as the 3-hour block average for the pH and scrubber liquid flow are maintained, compliance with a 3-hour block average emission limitation of 0.25 lb/hr will be maintained. Nos. 1 and 2 Natural Gas Package Boilers The two natural gas boilers each are rated at 225 MMBtu/hr maximum heat input rate. They were installed in May 2017 to replace two old coal fired boilers to reduce SO2 emissions. The two boilers are only permitted to burn natural gas and are not capable of firing oil, coal, or Final Source-Specific SIP for Blue Ridge Paper Products, LLC 30 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 biomass. The emission rates represent the maximum SO2 emissions that the sources could potentially emit based on their operational and physical design. Natural gas fired only combustion sources, which have inherently low SO2 emissions, are not subject to any monitoring, recordkeeping, and reporting requirements. These sources are required to burn only natural gas thus ensuring compliance with the emission limitations for these units. In addition, these units cannot burn fuels other than natural gas or propane because of their operational and physical design. Wet Scrubber Emissions Control and Parametric Monitoring The air emissions from the No. 4 and No. 5 lime kilns, and the Riley Bark, Riley Coal, and No. 4 Power boilers are all controlled by wet scrubber-type air emission control devices. The Riley Coal and No. 4 Power Boilers have recently installed (2018) caustic spray chambers for SO2 control. In this case, a caustic spray is injected by four spray bars into an empty chamber counter-current to the boiler gas stream to react with and remove the SO2 emissions. The spray injection rate, pH of the scrubbing solution, as well as other operating parameters are monitored to ensure proper operation the scrubber. The lime kilns and the Riley Bark boiler are equipped with a different type of wet scrubber called venturi-type scrubbers which differ in operating principle from spray chambers. These venturi devices were installed historically for the control of PM but do reduce SO2 emissions. In a venturi-type scrubber, a “throat” section in the duct forces the exhaust gas steam to accelerate as the duct constricts then expands. The scrubbing liquid is injected into the gas stream before the throat and is then atomized into small droplets by the turbulence of the throat. Through this turbulence the droplet/particle/gas stream interaction, and thereby air emissions control, is increased. In both scrubber types, the caustic scrubbing solution reacts with the SO2 for subsequent removal of the pollutant from the gas stream. Scrubbing solutions are generally recirculated but with some portion of the spent solution being removed from the system. A common method to ensure continuous compliance with an emissions limit in lieu of continuous direct sampling/monitoring of the subject pollutant, in this case SO2, is to conduct what is called “parametric monitoring.” This is a common regulatory approach used in various Federal Regulations such as the MACT and NSPS and Title V air permits for SIP regulations. In parametric monitoring, certain performance parameters that are critical to the proper operation of the emission control device are continuously monitored. For the boilers, for SO2 control, these parameters can include scrubber recirculation flow and pH. The compliance parameter minimum levels are typically established during emission source testing to ensure operating at those parameter levels meets the underlying emission control requirement. In the case of the Riley Coal, Riley Bark, and No. 4 Power Boiler scrubbers, the compliance parameters values for the wet scrubbers have been established during SO2 performance stack testing and are specifically written into the Title V air permit (Permit Table 2.2 J.2). These parameters are minimum recirculation flow in gallons per minute (gpm) and minimum pH of the scrubber solution. The parameters are continuously monitored, recorded, and reduced to 3-hour block averages for comparison to the established compliance values. Parameters must be maintained above the minimum established values. The CMS for recirculation flow and pH are Final Source-Specific SIP for Blue Ridge Paper Products, LLC 31 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 required to be properly installed, calibrated, and maintained per referenced regulations. Deviations from the established parameters must be reported to the DAQ. Periodic stack testing for SO2 is also required to confirm or re-establish these compliance parameters. In the case of the lime kilns, the parametric monitoring requirements for SO2 in the Title V air permit refer to pre-existing air permit and regulatory requirements for proper scrubber operation and air emissions control. The primary permit reference (Condition 2.2 D.1.) is the Federal MACT Standard 40 CFR 63 Subpart MM “National Emission Standards for Hazardous Air Pollutants (NESHAP) for Chemical Recovery Combustion Sources.” This regulation has been in effect for well over a decade and already requires continuous compliance parameter monitoring for the wet scrubbers installed on the No. 4 and No. 5 lime kilns. In the case of this regulation and permit condition, the company must install, calibrate, maintain, and operate a CMS that can be used to determine and record the pressure drop across each scrubber and the scrubbing liquid flow rates. These parameters are continuously monitored, recorded, and reduced to 3-hour averages for comparison to the established minimum compliance values. Parameters must be maintained above the minimum established values. Deviations from the established parameters must be reported to the DAQ. Periodic stack testing is also required to confirm or re-establish these compliance parameters. d. Emission Source Modeling – Offsite Sources Nearby, offsite, sources of SO2 emissions were evaluated for inclusion in the modeling. The DAQ reviewed the emission inventory data for Haywood County and identified five facilities with SO2 emissions during the period 2013 – 2018 (see Table 9). Four of the facilities are located outside of Beaverdam Township and one facility is located inside Beaverdam Township. The annual emissions for the four facilities located outside of Beaverdam Township were less than 3.34 tons. The annual emissions for the facility located inside Beaverdam Township were 0.10 ton. Based on this evaluation, no additional SO2 sources were identified in Haywood County that, in combination with SO2 emissions from BRPP, would change the modeling results for BRPP. Table 9. Annual SO2 Emissions Associated with Other Facilities in Haywood County Facility ID Facility Name Permit Class Annual Emissions (Tons) Year1 Located in Beaverdam Township 4400020 Harrison Construction Synthetic Minor 3.34 2013 No 4400163 Holston Environmental Services Synthetic Minor 0.39 2014 No 4400802 Giles Chemical Small 0.01 2014 No 4400819 Blue Ridge Paper Products - Waynesville Small 0.04 2014 No 4400181 Americarb, Inc. Synthetic Minor 0.10 2015 Yes 1 Low-emitting facilities such as the facilities in this table are required to report emissions when they renew their permit, and permit renewals are required once every 8 years under North Carolina’s Rule 15 NCAC 02Q .0308(c) (Final Action On Permit Applications). Final Source-Specific SIP for Blue Ridge Paper Products, LLC 32 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 The largest source of SO2 emissions anywhere near BRPP is Duke Energy Progress’ (DEP) Asheville Steam Electric Plant located in Buncombe County, Arden, North Carolina. This facility is located approximately 27.8 km (17.3 miles) southeast of BRPP’s Canton Mill with complex terrain (ridges) located between the two facilities. From 2017 – 2019, the facility operated two coal-fired boilers with emissions ranging from about 792 tons in 2017 to 710 tons in 2019. However, it was determined that SO2 emissions from this facility are unlikely to impact the airshed in the Canton area for the following reasons: • DEP has been monitoring SO2 emissions near its facility since January 1, 2017. Based on certified SO2 monitoring data for 2017 – 2019, the design value is 11 ppb or 15% of the 2010 1-hour SO2 NAAQS. • The Canton Mill is located in the Pigeon River Valley at an elevation of approximately 793 meters (2,600 feet) above mean sea level (MSL) and the Asheville Steam Electric Plant is located in the French Broad River Valley at approximately 671 meters (2,200 feet) above MSL. These two valleys are separated by approximately 19.3 km (12 miles) of complex terrain, including two ridge lines exceeding 914 meters (3,000 feet) and 1,219 meters (4,000 feet) above MSL. It unlikely that a plume from the Asheville Steam Electric Plant would rise above the French Broad River Valley, cross two ridge lines, then descend into the Pigeon River Valley. • On January 29, 2020, DEP permanently shut down the two coal-fired boilers at the Asheville Steam Electric Plant in accordance with Session Law 2015-110, Section 2.(c), of Senate Bill 716, enacted by the 2015 session of the North Carolina General Assembly. The two boilers have been replaced with natural gas combined-cycle units which will ensure that the SO2 emissions at the facility will remain low in the future. On February 6, 2020, DEP notified the Western North Carolina Regional Air Quality Agency that the two coal-fired units (Unit Nos. 1 and 2) have been officially retired with respect to the two referenced programs effective January 29, 2020, and submitted Retired Unit Exemption Forms in accordance with EPA’s Acid Rain and Cross State Air Pollution Rule Programs. DEP is in the process of dismantling the stack and the two coal fired boilers. The Title V permit will be revised to remove the coal fired boilers during the fall of 2020. e. Modeling Receptor Grid The dispersion modeling receptor grid was developed following procedures outlined in the North Carolina PSD Modeling Guidance (January 2012). A Cartesian receptor grid system was created to adequately assess air quality impacts in all directions up to 10 km (6.2 miles) from the facility. The grid included ambient air boundary receptors with a receptor spacing of 50 meters (164 feet) along the fence line, and extended outward from the boundary to 1.5 km (0.93 mile) at 100-meter (328-foot) spacing, from 1.5 km (0.93 mile) to 3 km (1.86 miles) at 250-meter (820-foot) spacing, from 3 km (1.86 miles) to 6 km (3.73 miles) at 500-meter (1,640-foot spacing, and from 6 km (3.73 miles) to 10 km (6.2 miles) from the plant at 1-km (0.62-mile) spacing. An additional grid of receptors was added and spaced at 100-meter (328-foot) intervals centered on the previously modeled maximum impacts and extending out to 500 meters (1,640 feet). The grid systems were created using the Universal Transverse Mercator (UTM) coordinate system Final Source-Specific SIP for Blue Ridge Paper Products, LLC 33 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 (Zone 17) using the North American Datum of 1983 (NAD83) (Figure 4). Receptor elevations and critical hill heights were determined using the current version of the American Meteorological Society/Environmental Protection Agency Regulatory Model Terrain Pre- Processor (AERMAP) processor (version 11103). National Elevation Data (NED) was downloaded from the National Map Seamless Server for an area of approximately 25 km (15.5 miles) from the facility. Figure 4. Modeling Grid Cell Receptors used in Facility Modeling Analysis for Blue Ridge Paper Products LLC f. Modeling Results Table 9 shows the impact of each source at the receptor with the maximum impact and at the receptor located at the site of the ambient monitor. The impacts are reported as the 99th percentile of 1-hour daily maximum modeled concentrations averaged over the 5-year period (2012-2016). The table also shows the percent contribution of each source to the total impact modeled for the receptor with the maximum impact and the receptor located at the site of the ambient monitor. The results are presented for both the recovery furnaces burning BLS during normal operation and burning ULSD during start-up and shutdown. Note that for some of the small emitting sources (e.g., smelt tanks, calendar heaters, gas-fired boilers, generators, and black liquor oxidation) the modeling analysis shows little to no impact for the modeled receptor Final Source-Specific SIP for Blue Ridge Paper Products, LLC 34 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 with the maximum impact. The permit limits are based on the modeled receptor with the maximum impact, not on the impact at the monitor. Representative background concentrations were obtained from the EPA’s Design Value website. There are three active SO2 monitors within 100 km (62 miles) of the Canton Mill. Of these, the Seneca and Greenville, SC have valid 2014-2016 design values. Of these two, the Greenville monitor has more sources in close proximity to it and, therefore, was selected as 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 micrograms per cubic meter (µg/m3) (3 ppb) as the background SO2 concentration for the modeling analysis. Table 10. Source-Specific Modeling Results Permit ID Modeling Source ID Source Description Impact per Source at Receptor Contribution per Source at Receptor Maximum (ppb) Monitor (ppb) Maximum (%) Monitor (%) BLS ULSD BLS ULSD BLS ULSD BLS ULSD G08020 10REC No. 10 Recovery Furnace 4.09 0.09 4.09 0.05 5.75 0.14 8.97 0.12 G08021 11REC No. 11 Recovery Furnace 3.31 0.09 3.27 0.05 4.65 0.13 7.18 0.11 G08023 10SDT No. 10 Smelt Dissolving Tank 0.02 0.02 0.21 0.24 0.03 0.03 0.46 0.60 G08024 11SDT No. 11 Smelt Dissolving Tank 0.02 0.02 0.20 0.25 0.03 0.04 0.44 0.62 G09028 4LIME No. 4 Lime Kiln 0.36 0.42 3.23 4.09 0.50 0.65 7.08 10.06 G09029 5LIME No. 5 Lime Kiln 0.48 0.88 5.19 6.46 0.67 1.39 11.39 15.90 G11039 RLCOAL Riley Coal Boiler 23.88 20.99 4.79 3.97 33.57 32.93 10.51 9.77 G11040 NO4BOIL No. 4 Power Boiler 31.58 27.69 8.48 6.34 44.39 43.40 18.62 15.59 G11042 RLBARK Riley Bark Boiler 7.34 13.52 15.10 18.06 10.32 21.21 33.14 44.44 G12077 PM19NIP No. 19 Paper Machine including Nip heaters (natural gas fired) Wet 0 0 0.001 0.002 0.00 0.00 0.00 0.00 16-CU- 001 1850GEN 1850 hp Backup Diesel Generator 0 0 0.000 0.000 0.00 0.00 0.00 0.00 I-G23066. f-ire FP200#1 200 hp Fire Control Generator #1 0 0 0.000 0.001 0.00 0.00 0.00 0.00 I-G23066. f-ire FP200#2 200 hp Fire Control Generator #2 0 0 0.000 0.000 0.00 0.00 0.00 0.00 I-G23066. f- en LKGEN64 64 hp Lime Kiln Emergency Generator 0 0 0.001 0.002 0.00 0.00 0.00 0.00 I- G23066.f- en LKGEN22 7 227 hp Lime Kiln Emergency Generator 0 0 0.003 0.004 0.00 0.00 0.01 0.01 I-G23066. f-rec RFGENSE T 100 kW Recovery Furnace Emergency Generator 0 0 0.002 0.002 0.00 0.00 0.00 0.01 G08022 BLOXRTO Black Liquor Oxidation - RTO 0 0.00 0.96 1.09 0.00 0.00 2.11 2.69 G11050 and G11051 225NGBLS No. 1 and No. 2 Natural Gas Package Boiler 0.06 0.05 0.03 0.03 0.09 0.08 0.08 0.06 Totals 71.14 63.77 45.57 40.63 100.00 100.00 100.00 100.00 Final Source-Specific SIP for Blue Ridge Paper Products, LLC 35 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 The 99th percentile of 1-hour daily maximum modeled concentrations averaged over the 5-year period was added to the background value of 3 ppb. This total concentration was then compared to the NAAQS to determine compliance. Table 10 shows the maximum ambient SO2 concentration modeled outside of the facility fence line associated with the maximum allowable emission limitations included in the facility’s Title V permit. The modeling results show compliance with the NAAQS. A review of the data suggests that the results at the location of the ambient monitor on Pace Street to be on the order of 60% of the maximum impacts shown above. Table 11. Updated Modeling Results for the One-Hour SO2 NAAQS Analysis for Blue Ridge Paper Canton, Haywood County, North Carolina Pollutant/ Averaging Period Years Recovery Furnace Scenario* Modeled Conc. (ppb) Background Conc. (ppb) Max. Conc. (ppb) NAAQS (ppb) % of NAAQS (75 ppb) SO2 (1-hour) 2012- 2016 ULSD 64 3 67 75 89% BLS 71 74 99% * Recovery furnaces burning ultra-low sulfur diesel (ULSD) and burning black liquor solids (BLS). The receptor at which the maximum modeled impact occurred is located about 3.2 km (1.98 miles) southeast of the facility’s fence line. Although BRPP has implemented significant process and control equipment changes at the facility that may affect dispersion characteristics, this does not mean that the ambient monitor is no longer sited in the correct location. As noted previously, the ambient monitor was sited following EPA guidance and regulations for the purpose of establishing a design value based on a 3-year average of the 99th percentile of 1-hour daily maximum concentrations. The monitor records SO2 concentrations based on actual operating conditions at the facility. The modeling is performed on emissions reflecting maximum allowable operating conditions (instead of actual emissions) using the 5-year average of the highest modeled value for each receptor. The modeling is conducted in this way to determine if the maximum allowable emission limitations will be protective of the NAAQS given a wide range of meteorological conductions that have occurred in the area from 2012-2016. Thus, the modeling analysis and the ambient monitor serve different purposes. The important conclusion is that the modeling demonstrates that the maximum allowable emission limitations will be protective of the NAAQS. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 36 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 5. Air Quality Transport Modeling Demonstration [Note: The DAQ previously submitted to EPA the following information to supplement North Carolina's CAA Section 110(a)(2)(D)(i)(I) "Good Neighbor" SIP for the 2010 1-hour SO2 NAAQS. This supplementary information is provided here because the information was not included in North Carolina’s original CAA Section 110(a)(2)(D)(i)(I) submittal to EPA.14F 15] The DAQ ran the model used for the facility attainment analysis for the SO2 emission limitations included in BRPP’s Title V permit to evaluate maximum 1-hour SO2 concentration at the borders of South Carolina and Tennessee. The modeling scenario includes all SO2 sources including the emission limitations for the recovery furnaces using BLS (because the emission limitations are higher than those associated with using ULSD during start-up and shutdown of the furnaces). For Tennessee, the modeling grid was modified to add receptors along the Tennessee state line and over the area of Tennessee that is within 50 km (31 miles) of the facility. Receptors were placed at one-degree radial increments, spaced at 2.5-km (1.55-mile) intervals, at distances between 30 km (18.6 miles) and 50 km (31 miles) from the center of the facility. Receptors were also placed along the boundary between North Carolina and Tennessee at 1 km (0.62 mile) or less intervals and at any significant terrain features between the state boundary and 50 km (31 miles) at any significant terrain features near the state boundary. For South Carolina, the modeling grid was an arc of receptors positioned along the South Carolina state line where the border is within is 50 km (31 miles) of the facility. Figure 5 shows the location of the receptors and maximum SO2 concentrations modeled for Tennessee and South Carolina. The maximum impact at any receptor was 8 ppb in neighboring Tennessee and 1 ppb in neighboring South Carolina. For context, 3 ppb is the nearest 2014-2016 one-hour design value for the Greenville ESC monitor (45-045-0015), the most representative monitor for background near Blue Ridge. Based on these modeling results, the DAQ concludes that the facility will not likely contribute to nonattainment or interfere with maintenance of the 2010 1-hour SO2 NAAQS in either of North Carolina’s neighboring states of Tennessee or South Carolina. 15 Revision to North Carolina's Clean Air Act Section 110(a)(2)(D)(i)(I) "Good Neighbor" State Implementation Plan for the 2010 1-Hour Sulfur Dioxide Standard, North Carolina Department of Environmental Quality, Division of Air Quality, June 16, 2016, available at https://deq.nc.gov/about/divisions/air-quality/air-quality-planning/state- implementation-plans/110a-infrastructure-certifications/2010-so2-110a-infrastructure-certification. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 37 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Figure 5. Modeling Grid Cell Receptors used in Transport Modeling Analysis for Blue Ridge Paper Products LLC 6. Conclusion BRPP has significantly reduced SO2 emissions at its Canton Mill in recent years as required by an SOC between BRPP and the North Carolina Environmental Management Commission. From 2017 through 2019, the facility reduced annual emissions to 405 tons or by 93% (5,470 tons). These emission reductions have led to corresponding reductions in ambient SO2 concentrations near the facility. The annual 99th percentile of the SO2 1-hour daily maximum concentrations measured by the ambient monitor near the facility decreased from a high of 213.4 ppb (285% of the NAAQS) in 2018 to 34.8 ppb in 2019 (46% of the NAAQS). Based on modeling analyses and supported by monitoring data for CY 2019, the SO2 emissions controls that BRPP implemented to comply with the SOC and are included in its permit demonstrate attainment of the 2010 1-hour SO2 NAAQS. The emission limitations and monitoring, recordkeeping and reporting requirements that are incorporated into the permit, and those proposed for inclusion in the SIP, provide reasonable assurance that the entire Beaverdam Township area is now in attainment of the 2010 SO2 NAAQS and will continue to maintain compliance with the NAAQS in the future. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 38 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 In addition, the DAQ conducted modeling of the emission limitations included in BRPP’s permit to evaluate the SO2 impacts in the downwind states of South Carolina and Tennessee for the purpose of determining compliance with the Good Neighbor provisions of CAA Section 110(a)(2)(D)(i)(I). The modeling results show a maximum 1-hour increase of 1 ppb and 8 ppb for receptors located on the border of South Carolina and Tennessee, respectively. Thus, North Carolina believes that the emission limitations established in BRPP’s Title V permit are protective of the NAAQS in South Carolina and Tennessee. IV. Materials Proposed to be Incorporated into the SIP This section identifies the materials the DAQ requests EPA include in the North Carolina SIP. These materials identify the emission sources; SO2 emission limitations and associated monitoring, recordkeeping, and reporting requirements specified in Section 2.2 J of Permit Number 08961T29 for BRPP’s Canton Mill for the coal-fired boilers, recovery furnaces, and lime kilns. North Carolina requests that EPA incorporate a portion of Table 2.2 J.1 from Permit 08961T29 to include the SO2 allowable emission rate limitations for seven SO2 emission units at BRPP. • Section 2.2 J.1.b - Emission Limitations - The following emission sources and emission limitations from Table 2.2 J.1: Table 2.2 J.1 Emission Source Permit No. Emission Source Description Allowable Emission Rate, lb/hr G08020 No. 10 Recovery Furnace - Black Liquor Solids (BLS) - Normal Operation 28.0 G08020 No. 10 Recovery Furnace - Ultra-Low Sulfur Diesel (ULSD) - Startup and Shutdown 0.54 G08021 No. 11 Recovery Furnace - BLS - Normal Operation 28.0 G08021 No. 11 Recovery Furnace - ULSD - Startup and Shutdown 0.54 G09028 No. 4 Lime Kiln 6.28 G09029 No. 5 Lime Kiln 10.47 G11039 Riley Coal Boiler 61.32 G11040 No. 4 Power Boiler 82.22 G11042 Riley Bark Boiler 68.00 Section 2.2 J.1.c - Operating Restrictions - To ensure the emission limitations in Table 2.2 J.1 will not be exceeded, the Permittee shall be subject to the following requirements:  Section 2.2 J.1.c.i  Section 2.2 J.1.c.iii Final Source-Specific SIP for Blue Ridge Paper Products, LLC 39 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 • Section 2.2 D.1 [Note: Only pertains to the No. 4 and No. 5 lime kilns and excludes any reference to the No. 10 and No. 11 Smelt Dissolving Tank Scrubbers (ID No. 08-CD-011-01 and ID No. 08- CD-012-01) and No. 10 or No. 11 Recovery Boilers (ID Nos. G08020 and G08021)] Table 2.2 D-2 provides interim minimum scrubber monitoring parameters associated with the No. 4 and No. 5 lime kilns based on the manufacturer’s recommendations, and requires BRPP to establish scrubber-specific minimum monitoring parameters for Liquid Flow and Pressure Drop through performance testing required under conditions 2.2 D.1.c, d, and h. The DAQ interprets condition 2.2 J.1.c.iii to require BRPP to meet the operating limits in Table 2.2 D-2, including any operating limits established under 2.2 D.1.h, in accordance with the monitoring exceedance provision 2.2.D.1.j., to ensure the SO2 emission limitations in Table 2.2 J.1 will not be exceeded for these lime kilns. The scrubber-specific minimum monitoring parameters from performance tests approved by the DAQ will supersede the manufacturer’s recommended limits without requiring a SIP revision. Table 2.2 D-2 Source Description Parameter Values No. 4 Lime Kiln Prior to upgrades to the scrubber (ID No. 09-CD-009-01): 1. Scrubber recirculation liquid flow shall be no less than 289 gpm (3-hour average), and 2. Scrubber differential pressure shall be no less than 20 in. H2O (3-hour average). After upgrades to the scrubber (ID No. 09-CD-009-01): 1. Scrubber recirculation liquid flow rate shall be no less than the minimum value recommended by the manufacturer. The Permittee shall establish site-specific minimum scrubber recirculation liquid flow during the performance test required in Section 2.2 D.1.d, above. 2. Scrubber differential pressure shall be no less than the minimum value recommended by the scrubber manufacturer. The Permittee shall establish site-specific minimum scrubber differential pressure during the performance test require in Section 2.2 D.1.d, above. No. 5 Lime Kiln Prior to upgrades to the scrubber (ID No. 09-CD-010-01): 1. Scrubber venturi liquid flow shall be no less than 224 gpm (3-hour average), 2. Scrubber quench liquid flow shall be no less than 152 gpm (3-hour average), and 3. Scrubber differential pressure shall be no less than 19.2 in. H2O (3-hour average). After upgrades to the scrubber (ID No. 09-CD-010-01): 1. Scrubber venturi liquid flow rate shall be no less than the minimum value recommended by the manufacturer. The Permittee shall establish a site-specific minimum venturi liquid flow rate during the performance test required in Section 2.2 D.1.d, above. 2. Scrubber quench liquid flow rate shall be no less than the minimum value recommended by the manufacturer. The Permittee shall establish a site-specific minimum quench liquid flow rated during the performance test required in Section 2.2 D.1.d, above. 3. Scrubber differential pressure shall be no less than the minimum value recommended by the manufacturer. The Permittee shall establish a site-specific minimum scrubber differential pressure during the performance test require in Section 2.2 D.1.d, above. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 40 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 o Section 2.2 D.1.f  Section 2.2 D.1.f.ii • Section 2.2 D.1.f.ii.A • Section 2.2 D.1.f.ii.B  Section 2.2 D.1.h • Section 2.2 D.1.h.i • Section 2.2 D.1.h.ii • Section 2.2 D.1.h.iii • Section 2.2 D.1.h.iv • Section 2.2 D.1.h.v  Section 2.2 D.1.i • Section 2.2 D.1.i.ii  Section 2.2 D.1.j • Section 2.2 D.1.j.ii  Section 2.2 D.1.l • Section 2.2 D.1.l.ii • Section 2.2 D.1.l.iii • Section 2.2 D.1.l.iv • Section 2.2 D.1.l.v • Section 2.2 D.1.l.vii • Section 2.2 D.1.l.viii  Section 2.2 D.1.m • Section 2.2 D.1.m.i • Section 2.2 D.1.m.ii o Section 2.2 D.1.m.ii.A o Section 2.2 D.1.m.ii.B • Section 2.2 D.1.m.iii  Section 2.2 D.1.n  Section 2.2 D.1.o  Section 2.2 D.1.p • Section 2.2 D.1.p.iii  Section 2.2 J.1.c.vii • Section 2.2 J.1.c.vii.A • Section 2.2 J.1.c.vii.B • Section 2.2 J.1.c.vii.C • Section 2.2 J.1.c.vii.D • Section 2.2 J.1.c.vii.E Final Source-Specific SIP for Blue Ridge Paper Products, LLC 41 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Table 2.2 J.2 is included in the SIP as a reference point only. As provided in Section 2.2 J.1.c.vii.E of the permit, BRPP may revise the Minimum Scrubber Recirculation Flow and/or Minimum Scrubber Liquid pH values in Table 2.2 J.2 based on the most recently conducted performance test approved by the DAQ at the time of permit issuance without requiring a SIP revision. Table 2.2 J.2 Source ID No. Source Description Control Device ID No. Description Minimum Scrubber Recirculation Flow, gpm Minimum Scrubber Liquid pH Date of Performance Test* G11039 Riley Coal Boiler 11-CD- 005-02 wet caustic scrubber 3,819 5.7 11/20/2018 G11040 No. 4 Power Boiler 11-CD- 006-03 wet caustic scrubber 4,395 6 12/18/2018 G11042 Riley Bark Boiler 11-CD- 016-02 venturi-type wet scrubber 1,084 6.1 12/19/2018 flow 11/1/2019 pH * Date upon which the operating parameter values are based, is the most recently conducted performance test approved by DAQ at the time of permit issuance. • Section 2.2 J.1.d - Testing Requirements - To ensure the emission limitations in Table 2.2 J.1 will not be exceeded, the Permittee shall be subject to the following requirements:  Section 2.2 J.1.d  Section 2.2 J.1.d.i  Section 2.2 J.1.d.ii  Table 2.2 J.3 (see below) Table 2.2 J.3 ID No. Source Description G08020 No. 10 Recovery Furnace - BLS - normal operation G08021 No. 11 Recovery Furnace - BLS - normal operation G09028 No. 4 Lime Kiln G09029 No. 5 Lime Kiln G11039 Riley Coal Boiler G11040 No. 4 Power Boiler G11042 Riley Bark Boiler  Section 2.2 J.1.e Final Source-Specific SIP for Blue Ridge Paper Products, LLC 42 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 • Section 2.2 J.1.g - Recordkeeping - To ensure the emission limitations in Table 2.2 J.1 will not be exceeded, the Permittee shall be subject to the following requirements: • Section 2.2 J.1.g • Section 2.2 J.1.g.i o Section 2.2 J.1.g.i.A o Section 2.2 J.1.g.i.B o Section 2.2 J.1.g.i.C o Section 2.2.J.1.g.i.D • Section 2.2 J.1.g.ii • Section 2.2 J.1.g.iii o Section 2.2 J.1.g.iii.A o Section 2.2 J.1.g.iii.B • Sections 2.2 J.1.h and 2.2 J.1.i - Reporting V. Materials Proposed to be Excluded from the SIP Table 12 identifies the SO2 emission sources for which the DAQ requests that EPA exclude from the North Carolina SIP. Table 12. Materials Proposed to be Excluded from the SIP Permit ID Emission Source Description Allowable Emission Rate, lb/hr 16-CU-001 1850 hp Backup Diesel Generator (Engine) 0.022 I-G23066.f-ire 200 hp Fire Control Generator #1 (Engine) 2.43E-03 I-G23066.f-ire 200 hp Fire Control Generator #2 (Engine) 2.43E-03 I-G23066.f-gen 64 hp Lime Kiln Emergency Generator (Engine) 7.77E-04 I-G23066.f-gen 227 hp Lime Kiln Emergency Generator (Engine) 2.75E-03 I-G23066.f-rec 100 kW Recovery Furnace Emergency Generator (Engine) 1.42E-03 G08023 No. 10 Smelt Dissolving Tank 0.42 G08024 No. 11 Smelt Dissolving Tank 0.42 G12077 Calendar natural gas and/or propane (Nip) hot oil heaters 0.012 G08022 Black Liquor Oxidation - RTO 2.50 G11050 No. 1 Natural Gas Package Boiler 0.13 G11051 No. 2 Natural Gas Package Boiler 0.13 The DAQ recommends that the emission sources in Table 12 be excluded from adoption into the SIP for the following reasons: 1. Actual and potential SO2 emissions from these sources are relatively minor; 2. Modeled impacts from these sources are minor to negligible; and 3. These sources are not anticipated to be modified or to change operation in any manner to increase actual or potential emissions. These small SO2 emission sources will be operated per the requirements in the Title V permit to ensure that they will not be allowed to operate in such a way that results in a violation of the 2010 1-hour SO2 NAAQS. At the maximum impact receptor, modeling of the maximum allowable emissions for these sources combined showed that they contributed up to only 0.10 Final Source-Specific SIP for Blue Ridge Paper Products, LLC 43 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 ppb or 0.14% of the total impact. For the receptor located at the monitor, together the sources contributed up to 1.62 ppb or up to 4% of the total impact modeled for all SO2 sources. For each emission source, the following provides a comparison of actual versus maximum allowable emissions and the contribution of each source to the maximum impact receptor and the receptor located at the ambient air quality monitor. Emergency Generators (16-CU-001, I-G23066.f-ire, I-G23066.f-gen, and I-G23066.f-rec) For modeling, emissions for the six generators were conservatively estimated based on 500 hours per year of operation on 15 ppm sulfur diesel. Actual operating hours are less than 500. At the maximum impact receptor, these six emission sources combined were estimated to have no contribution to the total modeled concentration for all SO2 sources. For the receptor located at the monitor, together the two sources were estimated to contribute from 0.006 ppb to 0.009 ppb or 0.01% to 0.02% of the total modeled concentration for all SO2 sources. These sources will not cause a violation of the 2010 1-hour SO2 NAAQS. The DAQ proposes to exclude these generators from the SIP because they have very low emissions and modeling shows that they contribute little to no impact to ambient concentrations at the receptor for the monitor and the receptor of maximum impact. This proposal is consistent with EPA’s policy regarding modeling of intermittent sources15F 16 and EPA’s 2016 SO2 NAAQS Designations Modeling Technical Assistance Document.16F 17 Modeling of the maximum potential emissions for the generators combined showed no impacts at the maximum impact receptor and very minimal impacts on the receptor located at the monitor. Furthermore, these units are not capable of burning any fuel other than diesel and there are no plans to burn anything other than 15 ppm sulfur diesel in these units in the future. These sources will not cause a violation of the 2010 1-hour SO2 NAAQS. No. 10 and 11 Smelt Dissolving Tank (G08023 and G08024) The smelt dissolving tanks dissolve smelt from the recovery furnaces; they do not burn any fuel. Actual emissions in 2019 for the smelt dissolving tanks were 63% to 64% of maximum potential emissions estimated for these two emission units. At the maximum impact receptor, these two emission sources combined were estimated to contribute about 0.04 ppb or up to 0.07% of the total modeled concentration for all SO2 sources. For the receptor located at the monitor, together the two sources were estimated to contribute from 0.41 ppb to 0.49 ppb or 0.9% to 1.22% of the total modeled concentration for all SO2 sources. These sources will not cause a violation of the 2010 1-hour SO2 NAAQS. 16 EPA’s policy on modeling of intermittent sources is discussed in a March 1, 2011, Memorandum titled: “Additional Clarification Regarding Application of Appendix W Modeling Guidance for the 1-hour N02 National Ambient Air Quality Standard.” https://www3.epa.gov/scram001/guidance/clarification/Additional_Clarifications_AppendixW_Hourly-NO2- NAAQS_FINAL_03-01-2011.pdf. 17 SO2 NAAQS Designations Modeling Technical Assistance Document, U.S. EPA, Office of Air and Radiation, Office of Air Quality Planning and Standards, Air Quality Assessment Division, Draft, August 2016, https://www.epa.gov/sites/production/files/2016-06/documents/so2modelingtad.pdf. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 44 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 Calendar natural gas and/or propane hot oil heaters (G12077) Actual emissions in 2019 for the two small natural gas heaters were 20% of maximum potential emissions estimated for the two heaters combined. At the maximum impact receptor, maximum potential emissions for the two heaters were modeled to have no contribution to ambient SO2 concentrations. For the receptor located at the monitor, maximum potential emissions for the two heaters were estimated to have negligible impact with modeled contributions of 0.001 to 0.002 ppb. These sources are required to burn only natural gas or propane thus ensuring compliance with the emission limitations for these units. In addition, these units cannot burn fuels other than natural gas or propane because of their operational and physical design. These sources will not cause a violation of the 2010 1-hour SO2 NAAQS. Black Liquor Oxidation – RTO (G08022) Actual emissions for the black liquor oxidation system – RTO in 2019 were only 5% of maximum potential emissions estimated for the black liquor oxidation system RTO. The wet scrubber is required to be operated continuously and is considered as a part of the physical and operational design of the black liquor oxidation system – RTO. At the maximum impact receptor, maximum potential emissions were modeled to have no contribution to ambient SO2 concentrations. For the receptor located at the monitor, maximum potential emissions were modeled to contribute from 0.96 to 1.09 ppb or 2.11% to 2.69% of the total modeled concentration for all SO2 sources. This source will not cause a violation of the 2010 1-hour SO2 NAAQS. No. 1 and 2 Natural Gas Package Boilers (G11050 and G11051) Actual emissions for 2019 were 71% of maximum potential emissions estimated for the two natural gas boilers combined. At the maximum impact receptor, these two boilers combined were estimated to contribute about 0.05 ppb to 0.06 ppb or up to 0.09% of the total modeled concentration for all SO2 sources. For the receptor located at the monitor, together the two boilers were estimated to contribute 0.03 ppb or up to 0.08% of the total modeled concentration for all SO2 sources. These sources are required to burn only natural gas thus ensuring compliance with the emission limitations for these units. In addition, these units cannot burn fuels other than natural gas or propane because of their operational and physical design. These sources will not cause a violation of the 2010 1-hour SO2 NAAQS. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 45 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 VI. Response to 40 CFR Part 51, Appendix V, Criteria for Determining the Completeness of Plan Submissions Pursuant to 40 CFR Part 51, Appendix V, the following shall be included in SIP submissions for review by EPA: 1. Administrative Materials a. A formal letter of submittal from the Governor or his designee, requesting EPA approval of the plan or revision thereof (hereafter “the plan”). A copy of the SIP submittal letter, signed by the Director of the DAQ/DEQ on behalf of the Governor of the State of North Carolina, is located at the front of this document. b. Evidence that the State has adopted the plan in the State code or body of regulations; or issued the permit, order, consent agreement (hereafter “document”) in final form. That evidence shall include the date of adoption or final issuance as well as the effective date of the plan, if different from the adoption/issuance date. See SO2 emission limitations and monitoring, recordkeeping, and reporting requirements for significant emission sources from the BRPP Title V Permit (Permit Number 08961) detailed under the “Materials Proposed to be Incorporated into the SIP” section of this submittal. c. Evidence that the State has the necessary legal authority under State law to adopt and implement the plan. DEQ has the necessary legal authority to adopt and implement this proposed revision to North Carolina’s SIP. References to the pertinent NCGS may be found in the “Legal Authority” section of this document. d. A copy of the actual regulation, or document submitted for approval and incorporation by reference into the plan, including indication of the changes made (such as, redline/strikethrough) to the existing approved plan, where applicable. The submittal shall be a copy of the official State regulation/document signed, stamped, and dated by the appropriate State official indicating that it is fully enforceable by the State. The effective date of the regulation/document shall, whenever possible, be indicated in the document itself. If the State submits an electronic copy, it must be an exact duplicate of the hard copy with changes indicated, signed documents need to be in portable document format, rules need to be in text format and files need to be submitted in manageable amounts (e.g., a file for each section or chapter, depending on size, and separate files for each distinct document) unless otherwise agreed to by the State and Regional Office. See SO2 emission limitations and monitoring, recordkeeping, and reporting requirements for significant emission sources from the BRPP Title V Permit (Permit Number 08961) Final Source-Specific SIP for Blue Ridge Paper Products, LLC 46 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 detailed under the “Materials Proposed to be Incorporated into the SIP” section of this submittal. e. Evidence that the State followed all of the procedural requirements of the State's laws and constitution in conducting and completing the adoption/issuance of the plan. The DAQ has complied with the requirements of NCGS 143-215.107(a)(3). Evidence of “proper study” may be found in the “SO2 Attainment Analysis – Technical Document” section of this submittal. f. Evidence that public notice was given of the proposed change consistent with procedures approved by EPA, including the date of publication of such notice. DEQ/DAQ has complied with all public notice requirements of 40 CFR 51.102. A copy of the public notice and the pre-hearing draft submittal letter to EPA is provided in Section VII (Public Participation) of this document. g. Certification that public hearing(s) were held in accordance with the information provided in the public notice and the State's laws and constitution, if applicable and consistent with the public hearing requirements in 40 CFR 51.102. Certification of compliance with all applicable public notice and hearing requirements is provided in the SIP submittal letter. h. Compilation of public comments and the State's response thereto. The DAQ did not receive any written comments during the public notice period. The EPA provided a no-comment letter that is included in Section VII (Public Participation) of this document. 2. Technical Support a. Identification of all regulated pollutants affected by the plan. This SIP revision addresses only the air pollutant SO2. b. Identification of the locations of affected sources including the EPA attainment/nonattainment designation of the locations and the status of the attainment plan for the affected areas(s). This SIP revision is to support EPA in completing the designation status for the 2010 1- hour SO2 NAAQS for Beaverdam Township located in Haywood County, North Carolina. BRPP is the only major source facility of SO2 emissions located within Beaverdam Township. The facility is located at 175 Main Street in the City of Canton, Beaverdam Township, Haywood County, North Carolina ("Facility") about 25 km (15.5 Final Source-Specific SIP for Blue Ridge Paper Products, LLC 47 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 miles) west of Asheville, North Carolina. The facility is situated on the Pigeon River on a 200-acre site in downtown Canton. c. Quantification of the changes in plan allowable emissions from the affected sources; estimates of changes in current actual emissions from affected sources or, where appropriate, quantification of changes in actual emissions from affected sources through calculations of the differences between certain baseline levels and allowable emissions anticipated as a result of the revision. See SO2 emission limitations and monitoring, recordkeeping, and reporting requirements for significant emission sources from the BRPP Title V Permit (Permit Number 08961) detailed under the “Materials Proposed to be Incorporated into the SIP” section of this submittal. d. The State's demonstration that the national ambient air quality standards, prevention of significant deterioration increments, reasonable further progress demonstration, and visibility, as applicable, are protected if the plan is approved and implemented. For all requests to redesignate an area to attainment for a national primary ambient air quality standard, under section 107 of the Act, a revision must be submitted to provide for the maintenance of the national primary ambient air quality standards for at least 10 years as required by section 175A of the Act. Because Beaverdam Township has yet to be designated by EPA with respect to the 2010 1-hour SO2 NAAQS, the CAA Section 107 requirements do not apply. However, the monitoring data provided in this document show that since CY 2017 BRPP has controlled its SO2 emissions to the extent that for CY 2019 the 99th percentile for the ambient monitoring site near the facility is 34.8 ppb, or 46% of the NAAQS. The modeling analysis of the SO2 emission limitations proposed for including in the SIP demonstrates compliance with the SO2 NAAQS. In addition, the modeling analysis also shows that BRPP will not contribute to a violation of the NAAQS in North Carolina’s neighboring states of Tennessee and South Carolina. Thus, the DAQ believes that the emission limitations and monitoring, recordkeeping, and reporting requirements proposed for inclusion in the SIP revision will be protective of the SO2 NAAQS. The EPA’s September 5, 2019, guidance to states for developing recommendations for designating all remaining areas for the 2010 SO2 NAAQS provides an option to develop a source-specific SIP for a facility like BRPP to serve as a basis for designating an area “Attainment/Unclassifiable.” The DAQ is submitting this source-specific SIP for EPA approval to strengthen the SIP to support an “Attainment/Unclassifiable” designation for Beaverdam Township. In addition, the SIP also documents supplemental air quality modeling information the DAQ has previously submitted to EPA to support approval of North Carolina's CAA Section 110(a)(2)(D)(i)(I) "Good Neighbor" SIP for the 2010 SO2 NAAQS. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 48 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 e. Modeling information required to support the proposed revision, including input data, output data, models used, justification of model selections, ambient monitoring data used, meteorological data used, justification for use of offsite data (where used), modes of models used, assumptions, and other information relevant to the determination of adequacy of the modeling analysis. See Section III.4 (Air Quality Modeling Demonstration for Facility), Section III.5 (Air Quality Transport Modeling Demonstration), and Attachments 2 and 3 of this submittal. f. Evidence, where necessary, that emission limitations are based on continuous emission reduction technology. See the “Sulfur Dioxide Attainment Analysis – Technical Document” section of this submittal. g. Evidence that the plan contains emission limitations, work practice standards and recordkeeping/reporting requirements, where necessary, to ensure emission levels. See SO2 emission limitations and monitoring, recordkeeping, and reporting requirements for significant emission sources from the BRPP Title V Permit (Permit Number 08961) detailed under the “Materials Proposed to be Incorporated into the SIP” section of this submittal. h. Compliance/enforcement strategies, including how compliance will be determined in practice. See SO2 emission limitations and monitoring, recordkeeping, and reporting requirements for significant emission sources from the BRPP Title V Permit (Permit Number 08961) detailed under the “Materials Proposed to be Incorporated into the SIP” section of this submittal. i. Special economic and technological justifications required by any applicable EPA policies, or an explanation of why such justifications are not necessary. Not applicable. 3. Exceptions Not applicable. Final Source-Specific SIP for Blue Ridge Paper Products, LLC 49 for 2010 1-Hour SO2 National Ambient Air Quality Standard September 3, 2020 VII. Public Participation This section provides copies of the following items: 1. Notice of Opportunity to Submit Comments and Participate in Public Hearing 2. Pre-Hearing Draft Submittal Letter to EPA 3. EPA No-Comment Letter NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY PURPOSE: COMMENT PROCEDURES: REQUESTS FORA PUBLIC HEARING: PUBLIC NOTICE The North Carolina Department of Environmental Quality, Division of Air Quality (DAQ), hereby gives notice regarding its pre-hearing draft of the State Implementation Plan (SIP) revision for the Source-Specific State Implementation Plan for Evergreen Packaging/Blue Ridge Paper Products, LLC, Canton, Beaverdam Township, Haywood County, North Carolina/or the 20101-Hour Su/far Dioxide National Ambient Air Quality Standard (NAAQS). By complying with a Special Order by Consent (SOC 2017-002) between the North Carolina Environmental Management Commission and Blue Ridge Paper Products, LLC, (BRPP), the facility has reduced its annual sulfur dioxide (SO2) emissions to 405 tons or by 93% (5,470 tons) from 2017 to 2019. These emission reductions have led to corresponding reductions in ambient SO2 concentrations near the facility. The annual 99th percentile of the SO2 1-hour daily maximum concentrations measured by the ambient monitor near the facility decreased from a high of 213.4 parts per billion (ppb) (285% of the NAAQS) in 2018 to 34.8 ppb in 2019 (46% of the NAAQS). Modeling of the emission limitations show attainment of the NAAQS. Once finalized, the DAQ will submit this source-specific SIP to the United States Environmental Protection Agency (EPA) requesting EPA approval into the North Carolina SIP the SO2 emission limits and associated compliance parameters for specific emission units in BRPP's Title V operating permit (Permit No. 08961 T29) to strengthen the SIP for complying with the 2010 1-hour SO2 NAAQS in Beaverdam Township. The DAQ will also request EPA approval of this source-specific SIP to qualify the Beaverdam Township area for an "Attainment/Unclassifiable" designation pursuant to EPA's September 5, 2019, designation guidance. The SIP also documents supplemental air quality modeling information the DAQ has previously submitted to EPA to support approval of North Carolina's Clean Air Act Section 110(a)(2)(D)(i)(I) "Good Neighbor" SIP for the SO2 NAAQS. Any person wishing to comment may submit a written statement for inclusion in the record of proceedings regarding the pre-hearing draft of the Source-Specific State Implementation Plan for Evergreen Packaging/Blue Ridge Paper Products, LLC, Canton, Beaverdam Township, Haywood County, North Carolina for the 2010 I-Hour Sulfur Dioxide National Ambient Air Quality Standard (NAAQS). Written comments should be submitted electronically or postmarked no later than July 27, 2020. Requests for a public hearing must be in writing and include a statement supporting the need for such a hearing, an indication of your interest in the subject, and a brief summary of the information intended to be offered. In order to address current guidance to help minimize the spread of COVID-19, a digital public hearing via Cisco's WebEx teleconferencing service will be scheduled if a public hearing is requested. A separate notice will be announced for the hearing including the date, time, and methods to access the W ebEx meeting. Written requests for a public hearing should be postmarked or submitted electronically no later than July I 0, 2020. INFORMATION: Copies of the pre-hearing draft of the Source-Specific State Implementation Plan for Evergreen Packaging/Blue Ridge Paper Products, LLC, Canton, Beaverdam Township, Haywood County, North Carolina for the 2010 1-Hour Sulfur Dioxide National Ambient Air Quality Standard (NAAQS) may be downloaded from the DAQ website at https://deg.nc.gov/about/divisions/air-quality/air-quality- planning/state-implementation-plans-sips/sulfur-dioxide-so2. Comments or requests for a public hearing can be submitted to: dag.publiccomments(a),ncdenr.gov (Please type "BRPP SIP" in the subject line). Alternatively, comments or requests for a public hearing can be mailed or faxed to: Randy Strait Fax: (919) 715-0718 NC Division of Air Quality 1641 Mail Service Center Raleigh, NC 27699-1641 Based on the current guidance to minimize the spread of COVID-19, all DAQ office locations are limiting public access to appointments only. As such, the pre-hearing draft of the SIP may only be reviewed in person after making an appointment at the following DAQ offices: Raleigh Central Office, Planning Section (919) 707-8403 Asheville Regional Office (828) 296-4500 Date: ~/J '-{ /)o <~ ~ ~A ~ A~czinskas, DAQ Director (This page intentionally left blank) ROYCOOPER NORTH CAROLINA Envfronmental Qua/tty Gcwemor MICHAELS. REGAN S!'cretary MICHAEL ABRACZINSKAS Director Mary S. Walker, Regional Administrator USEP A Region 4 Atlanta Federal Center 61 Forsyth Street, SW Atlanta, GA 30303-8960 June 24, 2020 Subject: Pre-Hearing Draft of Source-Specific State Implementation Plan Revision for Sources of Sulfur Dioxide Included in Evergreen Packaging/Blue Ridge Paper Products, LLC, Title V Operating Pennit (Permit No. 08961 T29) Dear Ms. Walker: I am pleased to submit the pre-hearing draft of the Source-Specific State Implementation Plan for Evergreen Packaging/Blue Ridge Paper Products, LLC, Canton, Beaverdam Township, Haywood County, North Carolina for the 20 IO ]-Hour Sulfur Dioxide National Ambient Air Quality Standard (NAAQS). Enclosed is the complete package containing the proposed State Implementation Plan (SIP) revision uploaded into the State Planning Electronic Collaboration System (SPeCS) for SIPs interface for your staff to review. I would like the United States Environmental Protection Agency (EPA) to consider this submission for parallel processing for approval. On October 9, 2017, the North Carolina Environmental Management Commission and Evergreen Packaging/Blue Ridge Paper Products, LLC (BRPP) entered into a Special Order by Consent (SOC 2017-002) to implement process modifications, upgrade existing control equipment, and install new control equipment to reduce sulfur dioxide (SO2) emissions and keep associated ambient concentrations below the 2010 I-hour NAAQS. BRPP has complied with the SOC and, as a result, reduced its annual S02 emissions to 405 tons or by 93% (5,470 tons) from 2017 to 2019. These emission reductions have led to corresponding reductions in ambient SO2 concentrations near the facility. The annual 991b percentile of the S 02 1-hour daily maximum concentrations measured by the ambient monitor near the facility decreased from a high of 213.4 parts per billion (ppb) (285% of the NAAQS) in 2018 to 34.8 ppb in 2019 (46% of the NAAQS). North Carolina is requesting EPA approve into the SIP, through parallel processing, the SO2 emission limits and associated compliance parameters for specific emission units in BRPP's Title V operating permit (Permit No. 08961 T29) to strengthen the SIP for complying with the 2010 1-hour S02 NAAQS in Beaverdam Township. North Carolina Departml!!nt of Envlronmental Quality I DMslon of Air Ql.lallty 217 Wt!stjonl!!s Street I 1641 Mall Service Ct-nter I RalC!'lgh, North Caroltna 27699-1641 91<1.707.8400 Mary S. Walker June 24, 2020 Page2 As demonstrated through the State's Title V permitting process, modeling of the emission limitations included in the permit show attainment of the NAAQS, and the monitoring, recordkeeping, and reporting requirements included in the permit support compliance with the emission limitations. Once EPA approves this proposed SIP revision, the S02 emission limits and associated monitoring, recordkeeping, and reporting requirements will be permanent and federally enforceable under Section 1 l0(a) of the Clean Air Act (CAA) to ensure that future ambient SO2 concentrations in Beaverdam Township will remain below the NAAQS. The EPA's September 5, 2019, guidance to states for developing recommendations for designating all remaining areas for the 2010 SO2 NAAQS provides an option to develop a source-specific SIP for a facility like BRPP to serve as a basis for designating an area "Attainment/Unclassifiable." Therefore, the Division of Air Quality (DAQ) is also submitting this source-specific SIP for EPA's approval to not only strengthen the SIP for complying with the 1-hour SO2 standard in Beaverdam Township, but also to qualify the Beaverdam Township area for an "Attainment/ Unclassifiable" designation pursuant to EPA's 2019 designation guidance. The SIP also documents supplemental air quality modeling information the DAQ has previously submitted to EPA to support approval of North Carolina's CAA Section 110(a)(2)(D)(i)(I) "Good Neighbor" SIP for the SOz NAAQS. The DAQ will issue a public notice announcement, in accordance with 40 CFR 51.102, indicating that the Source-Specific State Implementation Plan for Evergreen Packaging/Blue Ridge Paper Products, LLC, Canton, Beaverdam Township, Haywood County, North Carolina for the 20101-Hour Sulfar Dioxide National Ambient Air Quality Standard (NAAQS) is available for public comment and posted on the DAQ website for review. The public notice announcement will indicate that anyone may request a public hearing. The public hearing location, date, and time will be established and properly noticed if a public hearing is requested. The public comment period will be open from Wednesday, June 24 through Monday, July 27, 2020. The DAQ intends to submit the final version of this pre-hearing draft by Friday, August 14, 2020, after considering relevant public comments. In addition to posting on the website, the public notice announcement will be sent to a number of email distribution lists managed by the DAQ, which will include numerous stakeholders from industry and environmental groups. The DAQ has found that sending the public notice announcements to these groups is more effective than publishing the notices in a few local newspapers and is consistent with the requirements described in the April 6, 2011, memorandum, "Regional Consistency for the Administrative Requirements of the State Implementation Plan Submittals and the Use of Letter Notices. " The document will also be made available for in person review during normal business hours at the DAQ Central Office in Raleigh and the Asheville Regional Office. Based on the current guidance to minimize the spread of COVID-19, all DAQ office locations are limiting public access to appointments only. As such, the Pre-Hearing Draft of the demonstration may only be reviewed in person after making an appointment at the DAQ Central Office in Ra]eigh or the Asheville Regional Office. North Carolina Department of Environmental Quality I Division of Air Ql.lality 217 West Jones Street I 1641 Mall Servlce Center I Raleigh, North Carollna 27699-1641 919.707.8400 Mary S. Walker June 24, 2020 Page3 If you should have any questions, please contact Randy Strait of my staff at (919) 707-8721 or randy.strait@,ncdenr.gov. MAA/mfd Enclosures cc: Michael Pjetraj, DAQ Brendan Davey, DAQ Randy Strait, DAQ Evan Adams, USEP A Lynorae Benjamin, USEPA Jane Spann, USEP A Twunjala Bradley, USEP A· Sincerely, Michael A. Abraczinskas, Director Division of Air Quality, NCDEQ North Carolina DepartlllE'nt of Environmental Quality I Division of Air Quality 217 West Jones Street I 1641 Mail St-rvlce Cent<"r I Raleigh, North Carol!na 271,qq-lt,4 I ':ll';l.707.8400 (This page intentionally left blank) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW ATLANTA, GEORGIA 30303-3104 July 23, 2020 Mr. Michael Abraszinskas, Director Division of Air Quality North Carolina Department of Environmental Quality 1641 Mail Service Center Raleigh, North Carolina 27699-1641 Dear Mr. Abraszinskas: Thank you for your letter dated June 24, 2020, transmitting a prehearing package regarding the Source- Specific State Implementation Plan (SIP) Revision for Sources of Sulfur Dioxide Included in Evergreen Packaging/Blue Ridge Paper Products, LLC, Title V Operating Permit (Permit No. 08961T29). No public hearing was requested at this time and written comments are due by the close of business on July 27, 2020. We have completed our review of the package and offer no comments at this time. We appreciate North Carolina working with us so proactively on this SIP revision, and we look forward to continuing to work with you and your staff. If you have any questions, please contact Ms. Jane Spann, Acting Chief, Air Regulatory Management Section at (404) 562-9029, or your staff contact Mr. Evan Adams at (404) 562-9009. Sincerely, Lynorae Benjamin Acting Chief Air Planning and Implementation Branch cc: Randy Strait, DAQ Patrick Knowlson, DAQ Joelle Burleson, DAQ