NC0003298_CORRESPONDENCE_20030903

NPD65 DOCYN6NT SCANNING COVER SlIBBT I
NPDES Permit:
NC0003298
Riegelwood Paper Mill
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Correspondence
Monitoring Report
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date:
-September 3, 2003
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` NCDENR
North Carolina Department of Environment and Natural Resources
Division of Air Quality
Michael F. Easley, Governor
September 3, 2003
Mr. Howard D. Lienert, P.E.
Manager, Environmental Regulatory Affairs
International Paper
6400 Poplar Avenue
International Place, Tower lI 05 053
Memphis, TN 38197
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William G. Ross, Jr., Secretary
B. Keith Overcash, P.E., Director
Div sEP Q 8 2003OF p
DIREC AR7SR QUAL17y
OFF/(�E
Subject: Riegelwood Mill Further Compliance Date Extension for Pulp and Paper Maximum
Achievable Control Technology (MACT) I Phase II Rule [40 CFR 63.443]
Dear Mr. Lienert:
The Division of Air Quality (DAQ) has received and reviewed your August 18, 2003 request -for
a further 2-month extension to the compliance deadlines for the Pulp and Paper MACT I Phase II Rule
[40 CFR 63.443] for your Riegelwood Facility. Based upon the progress of your Environmental
Innovation Proposal and our judgement of its potential to achieve superior environmental results, the
DAQ grants International Paper (IP) an additional extension of 2 months to the MACT I Phase II
compliance deadline, making the new termination date December 16, 2006:
The MACT I Phase II sources include brown stock washers and several clean and recycled water
streams. The 1-year MACT II (combustion sources) extension previously granted to the Riegelwood
facility in my April 14, 2003 letter is not affected by this MACT I Phase II further extension.
DAQ grants IP the further extensions provided you revise your Title V permit application to
incorporate the conditions of the compliance extension and fulfill requirements related to the compliance
extension and innovation proposal. As noted in my April 14, 2003 letter, the 180-day extension request
for MACT I Phase II compliance testing was denied because testing is an inherent and integral part of
compliance. Please recall that meeting the extended compliance deadline includes the requirements of
holding test results demonstrating each affected source's compliance with the emission standard.
The reason for the compliance extension is to allow IP the necessary time to complete
development of an Environmental Innovation Project at the Riegelwood facility jointly with the
Department of Environment and Natural Resources (DENR) and EPA Region IV. Without the time
extension, IP would have to abandon the innovation proposal. Even though some of IP's previous
expectations have been modified, such projects are expected to provide superior environmental results
over conventional MACT standard controls. DAQ still expects to see greater emission reductions for
odor, hazardous air pollutants (HAPs), and toxic air pollutants, including hydrogen sulfide, using novel
process improvements and controls, than would be attained otherwise by conventional measures.
1641 Mail Service Center, Raleigh, North Carolina 27699-1641 - 2728 Capital Blvd. Raleigh, North Carolina 27604
Phone: [phone] Fax: [phone] Internet: httpaldaq.state•nc.usl
( [[I t Ut:v
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper

Mr. Howard D. Lienert, P.E.
IP Riegelwood Facility
September 3, 2003
Page 2
Regulatory Requirements
DAQ considers such HAP emission reduction gains beyond the MACT requirements important
and worthy of this further compliance extension and the partnering relationship with IP and EPA. North
Carolina has other regulatory criteria that will need to be considered, notably our rules about toxic air
pollutants, odors, and delegated EPA programs (including New Source Performance Standards and
Prevention of Significant Deterioration). In addition, DAQ is particularly interested in including
hydrogen sulfide (H2S) as a key toxic air pollutant to track and evaluate whether it would be better
controlled under innovative measures. As you know, proposed revision(s) to the Acceptable Ambient
Level (AAL) guidelines for HzS are currently under consideration by the NC Environmental Management
Commission, Given that current measures are inadequate and -conventional controls are very costly to
meet the current HzS AAL, DAQ agrees with IP that a sensible alternative is to continue to study, define,
and engineer innovative controls designed to provide superior and affordable environmental results.
Compliance Milestones
As part of this agreement, IP must fulfill requirements related to the compliance extension and the
nature of innovative experimentation, including:
1. Completion of Innovative Plan by December 1, 2003. The evaluation / selection process of the
innovative measures (either specified process changes or emission controls) must be completed
and fully defined by December 1, 2003.
2. Innovative Plan Better than MACT. DAQ must determine that the innovative measures will
produce superior environmental results than would be attained otherwise by conventional MACT
controls. Without the time extension, IP stated that it would have to abandon the innovation
proposal. It is understood that the key purpose and prerequisite for approval of a successful
regulatory innovation is to find new, better, and more efficient and effective ways to improve
environmental and public health protection.
3. Return to Original MACT I technology approach if Items I and 2 not met. In your March 18,
2003 meeting with the DENR Secretary and staff, you stated that all work on the MACT I Phase
II compliance would not stop while the innovation plan was being developed. Also, as an
innovations exit strategy, IP could return to the MACT control approach should you be unable to
complete the innovations plan. If by December 1, 2003 IP elects not to pursue the innovative
plan, or if other factors preclude implementing the plan, then IP must implement the original
MACT standard. However, this would be on a compliance schedule extended by the eight months
granted by this letter.
The new termination date for the MACT I Phase II compliance extension is December 16, 2006,
eight months from the date in the rule. Compliance must be demonstrated by this date. The following
dates serve as deadlines for the steps taken toward MACT I Phase II compliance:
• Submit final plans for DAQ approval of any innovation projects by December 1, 2003.
• Commence on -site construction by February 16, 2006;
• Complete on -site construction by October 16, 2006;

Mr. Howard D. LieneM P.E.
IP Riegelwood Facility
September 3, 2003
Page 3
Complete performance testing and hold test results for compliance determination with the MACT
I Phase II regulations by December 16, 2006.
Should the innovation plan be better than MACT, we will still entertain a request from IP should
additional time (up to 4 months) be needed to install controls.
DAQ remains hopeful that your innovative plan may realize the potential benefits in results. if
you have any questions or comments, please contact Lee Daniel at [phone] or me.
Sincerely,
B. Keith Overcash, P.E.
BK011ad
cc: William G. Ross, Jr., Secretary, NC DENR
Robin Smith, Assistant Secretary Planning/Policy, NC DENR
James Carter, Assistant Secretary Operations and Development, NC DENR
James Palmer, Regional Administrator, EPA Region IV
Gary Hunt, Director, Division of Pollution Prevention and Environmental Assistance
--Alaff Klimek, Director, Division of Water Quality
Wayne Cook, Supervisor, Wilmington Regional Office
Ernie Fuller, Supervisor, Raleigh Regional office
Lee Daniel, Supervisor, Technical Services Section
Laura Butler, Supervisor, Permitting Section