Domtar Paper Company, LLC (Domtar) is an integrated Kraft pulp mill located in Plymouth, Martin County,
North Carolina. Domtar currently holds Title V Permit No. 04291T46, with an expiration date of the earlier of September 30, 2022, or renewal of Permit No. 04291T42. The permitting action addresses the following permit
applications:
• Permit Application No. 5900069.16A, received May 3, 2016. The purpose of this permit application was
the second step of a two-step significant modification submitted under 15A NCAC 02Q .0501(b)(2). Permit Application No. 5900069.14F was submitted to DAQ on October 21, 2014 and amended on June
2, 2015, as the first step of a two-step significant modification to add a soap storage tank, a black liquor
separation tank, and railcar load out station, as well as remove peroxide stages from the No. 7 Bleach
Plant Scrubber. Permit No. 04291T42 was issued on July 10, 2015. Per 15A NCAC 02Q .0501(b)(2), a Title V permit application is required within 12 months after commencing operation of the new processes.
Operation of these sources commenced on August 24, 2015; therefore, Permit Application No.
5900069.16A addresses these sources and satisfies the 15A NCAC 02Q .0501(b)(2) requirement to submit a complete Title V air permit application within 12 months after commencing operation. The
permit review document associated with Permit Application No. 5900069.16A and Permit No. 04291T42
is included in Attachment 1 of this review.
• Permit Application No. 5900069.17B, received April 28, 2017. The purpose of this permit application was a one-step significant modification submitted under 15A NCAC 02Q .0501(c)(2). This permit
application requests modification to the permit to change inspection frequencies for the multiclones
associated with the Nos. 1 and 2 Hog Fuel Boilers, and the dry electrostatic precipitators (ESPs)
associated with the No. 5 Recovery Boiler.
• Permit Application No. 5900069.18B, received March 26, 2018. The purpose of this permit application was to notify DAQ of a 502(b)(10) change involving the replacement of three tanks in the lignin solids
removal plant (LSRP). The tanks will keep the same permit ID numbers.
• Permit Application No. 5900069.18C, received October 31, 2018. The purpose of this permit application
was the second step of a two-step significant modification submitted under 15A NCAC 02Q .0501(b)(2). Permit Application No. 5900069.17A was submitted to DAQ on March 27, 2017, as the first step of a
two-step significant modification for two unrelated projects: the installation of a steam box on the NC-5
pulp drying machine and a secondary turpentine decanting system. Permit No. 04291T44 was issued on
October 31, 2017. Per 15A NCAC 02Q .0501(b)(2), a Title V permit application is required within 12 months after commencing operation of the new processes. According to their permit application,
Domtar has not yet begun construction of the turpentine decanter system; however, operation of the steam
box commenced on November 17, 2017; therefore, Permit Application No. 5900069.18C addresses only the steam box and satisfies the 15A NCAC 02Q .0501(b)(2) requirement to submit a complete Title V air
permit application within 12 months after commencing operation. The permit review document associated
with Permit Application No. 5900069.18C and Permit No. 04291T44 is included in Attachment 2 of this review.
The permit applications identified above were consolidated into a single application. One-step significant
modifications take precedent over all others, so Permit Application Nos. 5900069.16A, 18B, and 18C were all consolidated and processed under 5900069.17B.
In addition to the above permit applications, DAQ is also modifying the permit to incorporate changes to the national emission standards for hazardous air pollutants (NESHAP) for Chemical Recovery Combustion Sources
at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills under 40 CFR Part 63, Subpart MM
(Subpart MM).
II. Project Description
As discussed in Section I, above, this permit review addresses several permit applications submitted by Domtar. The following discussion briefly describes the projects associated with each permit application.
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A. Second Step Permit Application for No. 5 Soap Tank, Black Liquor Separation Tank, Railcar Loadout Station, and No. 7 Bleach Plant Changes
The first step of the two-step process was submitted to DAQ on June 2, 2015 as Permit Application No. 5900069.14F. The project requested a modification of the permit for: (1) the construction and operation of a new
420,000-gallon soap storage tank, 34,000-gallon black liquor separator tank and associated railcar load out
station; and (2) reducing the load on the No. 7 Bleach Plant Scrubber by removing control of the peroxide stages to lower energy consumption. In the second step application (No. 5900069.16A), Domtar did not request changes
to the permit, indicating that the project was constructed as it was presented in the June 2015 permit application.
The Permit Review associated with Permit Application No. 5900069.14F is included as Attachment 1 and
contains full discussions of the modifications and the associated regulatory analysis.
B. Permit Application for Changes in Control Device Inspection Requirements
Permit Application No. 5900069.17B was submitted to request a permit modification to relax the inspection
frequencies associated with the multiclones installed on the Nos. 1 and 2 Hog Fuel Boilers and the ESPs installed
on the No. 5 Recovery Boiler. Currently the permit requires annual inspections of the structural integrity of each hog fuel boiler multiclone (Section 2.1 A.3.j.ii) for compliance with new source performance standards (NSPS)
filterable particulate matter (PM) limits under 15A NCAC 02D .0524 (Standards of Performance for Fossil-Fuel-
Fired Steam Generators under 40 CFR Part 60, Subpart D) and annual internal inspections of each recovery boiler
ESP (Section 2.1 C.1.e) for compliance with total suspended particulate (TSP) under 15A NCAC 02D .0508.
North Carolina’s Department of Labor (NC DOL) regulations govern the proper use and operation of all existing
boilers. Under these regulations, annual internal and external boiler inspections are required. The NC DOL regulations allows modification of the boiler inspection frequency if it is determined that due to unique conditions
the new frequency would provide for the safety attained by the normal inspection frequency.
Internal inspections for the hog fuel boiler multiclones and the recovery boiler ESPs require the boilers to be shut down. To allow for operational flexibility, Domtar is requesting that the permit be modified to allow for internal
control device inspections to be conducted when the boilers are shut down for internal operating certificate
inspections, rather than annually. As a result, if and when Domtar receives a relaxation of internal boiler inspection frequency as allowed under NC DOL regulations, they would not be required to shut the boiler down
only to conduct an internal inspection of the control devices.
C. 502(b)(10) Notification for Lignin Tank Replacement
Permit Application No. 5900069.18B was submitted as a 502(b)(10) notification of the replacement of three tanks
in the lignin solids removal plant (LSRP): LRP 40% Black Liquor Tank (40% BL Tank), Agitated Conditioning Tank (AC Tank), and Agitated Buffer Tank (AB Tank). According to Domtar’s notification, the 40% BL Tank
and the AC Tank are experiencing corrosion and need to be replaced in order to avoid failure. The AB Tank is
located adjacent to the AC Tank and Domtar stated that it was easier to replace both tanks at the same time. A detailed description of the project was submitted in a Permit Applicability Determination Request received
December 21, 2017 (No. 3192). The following describes the proposed changes:
• LRP 40% Black Liquor Tank (ES-09-27-1000)
o No change in size, vent characteristics, or location; o Adding agitation to prevent solids buildup.
• Agitated Conditioning Tank (ES-09-27-1800)
o Replacing a tank with a 10-foot diameter and a height of 12 feet with a tank with a 10-foot diameter and
height of 24 feet.
o No change in vent characteristics (source is vented to the HVLC mill system for incineration).
• Agitated Buffer Tank (ES-09-27-2000) o Replacing a tank with an 8-foot diameter and a height of 9 feet with a tank with an 8-foot diameter and
height of 24 feet.
o No change in vent characteristics (source is vented to the HVLC mill system for incineration).
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D. Second Step Permit Application for Installation of New Steam Box on NC5
The first step of the two-step process was submitted to DAQ on March 27, 2017, as Permit Application No. 5900069.17A. The project requested a modification of the permit for two unrelated projects: the installation of a
steam box on the NC5 pulp drying machine and a secondary turpentine decanting system. As stated above, the
construction has not commenced for the turpentine decanting system, therefore, this second step application only addresses the steam box installation. Domtar did not submit any requests for changes to the permit, indicating that
the project was constructed as it was presented in the March 2017 permit application. The Permit Review
associated with Permit Application No. 5900069.17A is included as Attachment 2 and contains full discussions of
the modifications and the associated regulatory analysis.
E. Incorporation of Changes to Subpart MM
On October 11, 2017, EPA issued final amendments to the NESHAP for Subpart MM. In an email received on
April 25, 2019, Domtar requested that DAQ incorporate the Subpart MM amendments as a part of this permit
modification for all affected sources, including: No. 5 Recovery Boiler, North and South Smelt Tanks, and No. 5 Lime Kiln. Theses changes are discussed in detail in Section IV, below.
III. Application History
May 3, 2016 DAQ received Permit Application No. 5900069.16A.
July 27, 2016 DAQ received Permit Application No. 5900069.16B for the renewal of the Title V permit.
October 25, 2016 DAQ received Permit Application No. 5900069.16C for a retroactive PSD permit
application for the installation of the LSRP process.
January 13, 2017 DAQ received Applicability Determination Application No. 2978 requesting a
determination whether an air permit was necessary for the lignin dewatering trials.
January 26, 2017 DAQ issued a response to Permit Applicability Determination No. 2978 that a permit was
not required.
March 2, 2017 DAQ received Applicability Determination Application No. 3009 requesting a
determination whether an air permit was necessary for the reintroduction of crude tall oil
into the liquor stream prior to the concentrators.
March 8, 2017 DAQ issued a response to Permit Applicability Determination No. 3009 that a permit was
not required.
March 27, 2017 DAQ received Permit Application No. 5900069.17A for the first step of a two-step
significant permit application for the installation of a steam box on the NC-5 pulp machine and installation of a secondary turpentine decanting system.
April 28, 2017 DAQ received Permit Application No. 5900069.17B.
June 22, 2017 DAQ received Applicability Determination Application No. 3088 requesting a
determination whether an air permit was necessary for two projects: (1) replacement of
two green liquor clarifiers and one green liquor storage tank with one large green liquor clarifier; and (2) replacement of one white liquor clarifier with a new white liquor
clarifier.
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July 31, 2017 DAQ issued a response to Permit Applicability Determination No. 3088 that the proposed changes can be addressed as a 502(b)(10) change notification.
October 17, 2017 DAQ received Applicability Determination Application No. 3143 requesting a determination whether smelt tank replacement projects would trigger NSPS Subpart BBa
applicability.
October 31, 2017 DAQ issued Permit T44, associated with the March 27, 2017, Permit Application No.
5900069.17A.
November 13, 2017 DAQ received Applicability Determination Application No. 3166 requesting a determination whether a mill optimization project, the lignin solids removal plant (LSRP)
project, and a confidential project are separate projects with respect to prevention of
December 21, 2017 DAQ received Applicability Determination Application No. 3192 requesting a
determination whether certain LSRP tank replacement would require a permit application and modification to the air permit.
January 18, 2018 DAQ issued a response to Permit Applicability Determination No. 3143 that if sufficient
documentation could not be provided to demonstrate that the cost of the reconstructed tank does not exceed 50 percent of the cost of a new tank, the reconstructed tank would
be subject to NSPS Subpart BBa and a permit would be required.
February 1, 2018 DAQ issued a response to Permit Applicability Determination No. 3166 that that the mill
optimization project, the LSRP project, and the confidential project are separate projects
with respect to PSD/NSR applicability and may be addressed with separate permit
applications.
February 15, 2018 DAQ received Applicability Determination Application No. 3221 providing additional
documentation supplementing the October 17, 2017, request for a determination whether a South Smelt Tank replacement project would trigger NSPS Subpart BBa applicability.
March 6, 2018 DAQ received Permit Application No. 5900069.18A, for the mill optimization project.
March 7, 2018 DAQ issued a response to Permit Applicability No. 3192 that PSD applicability of the
replacement tank project would need to be evaluated. If the emission increases were
above PSD significance levels, a permit modification would be required. If not, the project could be considered a 502(b)(10) change.
March 20, 2018 DAQ issued a response to Permit Applicability Determination No. 3221 that the replacement South Smelt Tank was not subject to NSPS Subpart BBa, but Domtar would
need to address PSD applicability and a permit modification may still be required
depending on the analysis.
March 26, 2018 DAQ received a 502(b)(10) notification (assigned as Permit Application No.
5900069.18B).
August 15, 2018 DAQ issued Permit T45, associated with the March 6, 2018, Permit Application No.
5900069.18A.
September 4, 2018 DAQ received Applicability Determination Application No. 3305 requesting a
determination whether a smelt tank replacement project would trigger NSPS Subpart BBa
applicability.
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October 4, 2018 DAQ issued a response to Permit Applicability Determination No. 3305 that the replacement North Smelt Tank was not subject to NSPS Subpart BBa, and the
information provided in Permit Application No. 5900069.18A addressed PSD
applicability and Permit T25, issued in August 2018 included the appropriate modification.
October 31, 2018 DAQ received Permit Application No. 5900069.18C.
April 18, 2019 DAQ issued Permit T46 associated with the PSD Permit Application No. 5900069.16B.
April 25, 2019 Phone conversation between Ms. Sands and Diane Hardison, Domtar, to discuss the expired authorization for boiler inspection frequency extension. Domtar agreed that
changing the permit language to align with the operating certificate inspections would
meet their needs.
April 25, 2019 Domtar submitted a request, via email, that DAQ: (1) incorporate revisions to Subpart
MM with this permit modification and (2) revise the annual inspection requirement language for the boiler air quality control systems to specify either calendar year or
consecutive 12-months.
May 6, 2019 DAQ and Domtar communicated via email regarding an update to Permit Application No. 5900069.17B to clarify Domtar’s request given a change in the internal boiler
inspection frequencies for their operating certificate.
IV. Permit Modifications
Table 1 describes the changes to the current permit as a part of this modification.
Insert table from permit
V. Regulatory Review
This permit modification potentially impacts several regulations applicable to the sources associated with each
permit application. The following discussion summarizes the regulatory review and necessary permit modifications on a source- specific basis.
A. No. 5 Soap Tank, Railcar Loadout Station, and No. 7 Bleach Plant (Application No. 5900069.16A)
The sources affected by this permit modification (No. 5 Soap Storage Tank, Black Liquor Separator Tank, Railcar
Loadout Station and the non-chlorinated stages in the No. 7 Bleach Plant) are subject to the following regulations:
• 15A NCAC 02D .0530: Prevention of Significant Deterioration; and
• 15A NCAC 02D .1100: Control of Toxic Air Pollutants.
As there are no changes to these regulatory requirements since the first step application, a review of these regulations will not be included in this document. See Attachment 1 of this permit review for details on the
regulatory analysis for these sources.
B. Nos. 1 and 2 Hog Fuel Boilers and No. 5 Recovery Boiler (Application No. 5900069.17B)
The sources affected by this permit application are the Nos. 1 and 2 Hog Fuel Boilers and the No. 5 Recovery
Boiler. As described in Section II, above, Domtar is requesting a modification to the frequency of the internal control device inspections to coincide with the internal inspections that Domtar is required to conduct for each
boiler to receive its operating certificate. The following is a regulatory analysis discussion for these sources and
summarizes how the requested change in internal inspections of the hog fuel boiler multiclones and the recovery boiler ESPs will need to be addressed in the permit.
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1. Hog Fuel Boilers – Modification to Internal Multiclone Inspection Frequency
The following is a summary of the applicable hog fuel boiler State regulations and an analysis of how the requested changes in the internal multiclone inspection frequencies will be addressed in the permit.
• 15A NCAC 02D .0503: Particulates from Fuel Burning Indirect Heat Exchangers. This regulation only
applies when the hog fuel boilers burn natural gas and No. 2 fuel oil alone. There are no inspection
requirements in this condition and no change in the permit is required.
• 15A NCAC 02D .0504: Particulates from Wood Burning Indirect Heat Exchangers. This regulation applies when wood is burned in the hog fuel boilers. Because the boiler is also subject to an NSPS, this condition
cross-references the NSPS inspection requirements for the control devices; therefore, no changes to this
condition as a result of changes in inspection requirements are required.
• 15A NCAC 02D .0516: Sulfur Dioxide Emissions from Combustion Sources. The requested inspection
changes do not impact this regulation and no changes to the permit are required.
• 15A NCAC 02D .0524: New Source Performance Standards (40 CFR Part 60, Subpart D). The No. 1 and 2 Hog Fuel Boilers are subject to NSPS under Subpart D. This condition contains annual internal inspection
requirements for the multiclones installed on the boilers. The annual frequency required in the permit for
internal control device inspections is not a requirement specified in Subpart D. The NC DOL regulations that specify the required inspections necessary for Domtar to obtain the boiler operating certificate as discussed
above require frequency of internal boiler inspections to not exceed three years. When the approved
frequency extension expires, Domtar is required to renew their request for a less frequent internal boiler inspection. At the time the permit application was submitted, Domtar had received authorization from NC
DOL to extend the internal No. 2 Hog Fuel Boiler inspection frequency for two years. This authorization has
since expired (September 2018), and Domtar has indicated that they are currently operating under the original
annual internal boiler inspection schedule.1 In subsequent conversations, Domtar has requested that DAQ revise the permit language to align the internal control device inspections with the operating certificate
inspections. DAQ agrees that this revision would not violate NSPS requirements and DAQ believes that
internal control device inspections that would occur at least every three years would still ensure compliance. Therefore, Section 2.1 A.5.j of the permit will be revised to require internal inspections of the structural
integrity of each multiclone be conducted when each boiler is internally inspected to receive its operating
certificate.
• 15A NCAC 02D .0530: Prevention of Significant Deterioration. Under this regulation, the Nos. 1 and 2 Hog
Fuel Boilers are subject to best available control technology (BACT) limits under PSD. The No. 1 Hog Fuel Boiler is subject to a BACT limit for carbon monoxide (CO). The inspection frequency of the multiclone does
not affect this BACT limit and no changes to the permit will be necessary for this condition. The No. 2 Hog
Fuel Boiler is subject to a BACT limit for PM less than 10 micrometers (PM10). This condition does not have specific control device inspection requirements but instead refers to the NSPS compliance requirements;
therefore, no changes to this condition as a result of changes in inspection requirements are required.
• 15A NCAC 02Q .0317: Avoidance Conditions for PSD. This regulation contains a PSD avoidance limit for
nitrogen oxide (NOX) emissions. Therefore, the requested inspection changes do not impact this regulation and no changes to the permit are required.
• 15A NCAC 02D .0614: Compliance Assurance Monitoring. The Nos. 1 and 2 Hog Fuel Boilers are subject to
compliance assurance monitoring (CAM) for PM. See Section VI, below, for a detailed discussion regarding
this regulation.
• 15A NCAC 02D .1109: CAA §112(j); Case-by-Case MACT for Boilers and Process Heaters. The 112(j)
requirements expired on May 20, 2019 and no longer apply. Therefore, this condition will be removed from the permit as a part of this permitting action. The condition will be reserved for this permit modification but
will need to be removed when the permit renewal application is processed.
• 15A NCAC 02D .1111: Maximum Achievable Control Technology (40 CFR Part 63, Subpart DDDDD). The
No. 1 and 2 Hog Fuel Boilers are subject to maximum achievable control technology (MACT) standards under Subpart DDDDD. This condition does not contain inspection requirements for the multiclones installed
on the boilers. Therefore, no changes to the permit will be necessary.
1 See discussion on 04/25/2019 phone conversation between Heather Sands, DAQ and Diane Hardison, Domtar described in Section III, above.
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2. No. 5 Recovery Boiler - Modification to Internal ESP Inspection Frequency
The following is a summary of the applicable recovery boiler State regulations and an analysis of how the requested changes in the internal ESP inspection frequencies will be addressed in the permit.
• 15A NCAC 02D .0508: Particulates from Pulp and Paper Mills. The No. 5 Recovery Boiler is subject to 02D
.0508. The associated permit condition contains annual internal inspection requirements for the ESPs installed
on the recovery boiler. The annual frequency required in the permit for internal control device inspections is not a requirement specified in 02D .0508. As with the hog fuel boilers, NC DOL requires internal boiler
inspection frequency not to exceed three years and Domtar is required to request a less frequent internal boiler
inspection when the previous extension expires. At the time the permit application was submitted, Domtar
had received authorization from NC DOL to extend the internal No. 5 Recovery Boiler inspection frequency for 18 months. This authorization has since expired (October 2017), and similar to the hog fuel boilers,
Domtar has indicated that they are currently operating under the original annual internal boiler inspection
schedule.1 Domtar requested that DAQ revise the permit language to align the internal control device inspections with the operating certificate inspections. DAQ agrees that this revision would not be in conflict
with the 02D .0508 requirements and that internal control device inspections that would occur at least every
three years would still ensure compliance. Section 2.1 C.1.e of the permit will be revised to state that internal inspections of the structural integrity of each ESP shall be conducted when the boiler is internally inspected to
receive its operating certificate.
• 15A NCAC 02D .0516: Sulfur Dioxide Emissions from Combustion Sources. The requested inspection
changes do not impact this regulation and no changes to the permit are required.
• 15A NCAC 02D .0524: New Source Performance Standards (40 CFR Part 60, Subpart BB). The No. 5
Recovery Boiler is subject to this regulation, which includes limits for PM, visible emissions, and total reduced sulfur (TRS). The permit condition associated with Subpart BB cross references the Subpart MM (see
below) requirements. Therefore, no changes to this condition will be required.
• 15A NCAC 02D .0530: Prevention of Significant Deterioration. Under this regulation, the No. 5 Recovery
Boiler is subject BACT limits under PSD for CO, NOX, SO2 and sulfuric acid mist. The inspection frequency of the ESP does not affect these BACT limits and no changes to the permit will be necessary for this
condition.
• 15A NCAC 02D .1109: CAA §112(j); Case-by-Case MACT for Startup, Shutdown, or Malfunction Conditions
in 40 CFR Part 63, Subpart MM Requirements. The requested inspection changes do not impact this
regulation and no changes to the permit are required.
• 15A NCAC 02D .1111: Maximum Achievable Control Technology (40 CFR Part 63, Subpart MM). No. 5
Recovery Boiler are subject to MACT standards under Subpart MM. This condition does not contain
inspection requirements for the ESPs installed on the recovery boiler. Therefore, no changes to the permit will
be necessary. Changes to the 02D .1111 conditions resulting from amendments to Subpart MM are summarized in Section VI, below.
C. Lignin Solids Removal Process Replacement Tanks (Permit Application No. 5900069.18B)
As described above, Domtar submitted a 502(b)(10) notification in accordance with the specifications in 15A
NCAC 02Q .0523(a)(1). Per 02Q .0523(a)(1), a permittee may make Section 502(b)(10) changes without having
the permit revised if:
• the changes are not a modification pursuant to 15A NCAC 02D or Title I of the federal Clean Air Act;
• the changes do not cause the emissions allowed in the permit to be exceeded;
• the permittee notifies the Director and EPA in writing at least seven days before the change is made;
• and the permittee attaches the notice to the relevant permit
Domtar originally submitted Applicability Determination Request No. 3192 for this project. On March 7, 2018,
DAQ responded that because Domtar is a major stationary source under prevention of significant deterioration (PSD) regulations, and because the lignin tanks are undergoing physical changes, Domtar is required to evaluate
whether the proposed project would be considered a major modification by comparing emission increases
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resulting from the project to the significant emission rates (SERs) under PSD.2 DAQ further instructed Domtar to calculate the emissions increases using baseline actual emissions (BAE) and potential to emit (PTE) of the
replacement tanks.3
With the 502(b)(10) notification, Domtar provided a PSD applicability analysis as instructed by DAQ. The
emissions increase calculation is presented in Table 2, below. Domtar provided calculations for potential
emissions from the 40% Black Liquor Tank and the contribution to emissions from the No. 2 Hog Fuel Boiler, which is the HVLC control device for the Agitated Conditioning and Agitated Buffer Tanks. Baseline emissions
were not provided because the PTE alone, as shown in Table 2, did not exceed the PSD SERs. As shown in Table
2 the PSD SERs were not exceeded and DAQ agrees that the project is not considered a major modification under
PSD.
The following are the regulations applicable to the LSRP tanks and a discussion summarizing how the proposed
project will impact the associated permit conditions.
• 15A NCAC 02D .0530: Prevention of Significant Deterioration. The LSRP is subject to BACT limits that limit TRS and H2S emissions from the process. Compliance with these limits is demonstrated by comparing
actual emissions to the limits and demonstrating that the TRS and H2S limits have not been exceeded. The
replacement of the three LSRP tanks does not change these limits and Domtar will be required to continue to demonstrate compliance by maintaining records of the actual emission calculations. No changes to the permit
are required for the proposed project.
• 15A NCAC 02D .0530(u): Use of Projected Actual Emissions. When the LSRP was initially constructed,
Domtar relied on projected actual emissions for the purposes of demonstrating that the LSRP project did not
result in a significant increase in emissions over baseline actual emissions. Therefore, the permit requires Domtar to maintain records of pulp production through the fiberlines. The replacement of the LSRP tanks
does not change this requirement and no changes to the permit are required for the proposed project.
• 15A NCAC 02D .1100: Control of Toxic Air Pollutants. In the original applicability determination request
(No. 3192), Domtar stated that there will be no increase in production through the LSRP. The installation of taller conditioning and buffer tanks will provide surge capacity but will not result in increases in annual
throughput. Prior to replacement of the tanks, the alkaline side of the plant is shut down if a piece of
equipment is offline because there is no extra room for the slurry. The extra tank volume will allow Domtar to
have operational flexibility to address operational issues without having to shut the process down. Therefore there are no changes in actual emissions. The conditioning and buffer tanks are collected in the HVLC system
and primarily controlled in the No. 2 Hog Fuel Boiler and do not have toxics limits in the permit. The 40%
Black Liquor Tank has toxics limits in the current permit. Because the new 40% Black Liquor Tank is being installed in the same location with the same outer dimensions, there would be no changes to the modeling
parameters. Therefore, no changes to the toxics limits will be required for the proposed project.
The discussion above demonstrates that the replacement tank project are not modifications under Title I and do
not cause emissions in the permit to be exceeded. As such, DAQ agrees that this project was correctly determined
to be a 502(b)(10) change. No changes to existing permit conditions are required.
D. NC-5 Pulp Machine Steam Box (Permit Application No. 5900069.18C)
The sources affected by this permit modification (NC-5 Line Building Fugitives including the dryer hoods and inside/outside vacuum pumps) are subject to the following regulations:
• 15A NCAC 02D .0530: Prevention of Significant Deterioration; and
• 15A NCAC 02D .1100: Control of Toxic Air Pollutants.
As there are no changes to these regulatory requirements since the initial first step application was submitted, a
review of these regulations will not be included in this document. See Attachment 2 of this permit review for details on the regulatory analysis for these sources.
2Letter from Willets, William D., Chief, Permitting Section, Division of Air Quality, NCDEQ to Bohn, Allen, Vice President/Mill Manager, Domtar Paper
Company, LLC. Permit Applicability Determination, Applicability Determination Application No. 3192 (received December 21, 2017). March 7, 2018. 3 In the March 7, 2018 letter (Footnote 2), DAQ presented the conclusion that the replaced tanks were not identical to (two of the tanks were proposed as
having a larger storage volume) or functionally equivalent to (one tank will be fitted with an agitator) the existing tanks. Therefore, the tanks were
considered new tanks for the purposes of PSD and emission increases should be based on a comparison of baseline to potential emissions.
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Table 2. Summary of Emission Increases for Lignin Tank Replacement Project and PSD Applicability
Emissions Increases (tpy)
VOC SO2 CO H2S TRSb CO2e
40% Black Liquor Tank PTE 1.48 Not
Emitted
Not
Emitted 0.214 0.894 Not
Emitted
Agitated Conditioning Tank PTEa 0.0294 35.2 9.73e-04 0.542 0.571 1.40
NOTE: Slight differences may be due to rounding. aTanks are vented through the HVLC system and are primarily controlled in the No. 2 Hog Fuel Boiler. SO2, CO, and CO2e
emissions occur from combustion of HVLC gases in the control device. Other combustion-related compounds are not impacted by
the tank replacements.
bTRS calculated as the sum of the constituent compounds.
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VI. Regulatory Review - Federal Rules
The Domtar mill is subject to several federal rules, but this permitting action only affects sources subject to the
NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills under 40 CFR Part 63, Subpart MM. On October 11, 2017, EPA published final amendments to
subpart MM. The following discussion summarizes the amendments and the permit was modified to reflect the
amended regulation.
Changes due to technology review
EPA conducted a technology review and determined that there were developments in practices, processes, and control technologies that warranted revisions Subpart MM. The following describes how Subpart MM revisions
impact the sources at the Domtar mill.
• The opacity monitoring allowance for the No. 5 Recovery Furnaces was revised from 6 percent to 2 percent;
and
• Domtar is required to maintain proper operation of the No. 5 Recovery Furnace ESP automatic voltage control (AVC).
Changes to address emissions during periods of startup, shutdown and malfunction
The Subpart MM amendments eliminated the startup, shutdown, and malfunction (SSM) exemption and the
Subpart MM standards apply at all times. EPA revised Table 1 to Subpart MM of Part 63 (General Provisions
applicability table) to change several references related to requirements that apply during periods of SSM. EPA eliminated or revised certain recordkeeping and reporting requirements related to the eliminated SSM exemption,
including the requirement for an SSM plan. EPA also made changes to the rule to remove or modify language that
is no longer applicable due to the removal of the SSM exemption. With the amendments to the Subpart MM monitoring requirements described above, EPA determined that pulp and paper facilities can meet the applicable
Subpart MM emissions standards at all times, including periods of startup and shutdown and did not include
additional standards to address emissions during these periods.
The Subpart MM monitoring requirements were adjusted to ensure that continuous compliance can feasibly be
demonstrated during periods of startup and shutdown. Subpart MM requires continuous opacity monitoring to
indicate ongoing compliance with the PM emission limits. EPA removed the requirement to consider wet scrubber pressure drop during startup and shutdown because pressure drop is dependent on gas flow, which is
transient (changing) during startup and shutdown. Therefore, continuous compliance is based on scrubber liquid
flow rate monitoring during startup and shutdown instead of both pressure drop and liquid flow rate. EPA also limited the times when corrective actions are implemented, or violations are recorded to times when spent pulping
liquor or lime mud is fed (as applicable). The final rule specifies that corrective action can include completion of
transient startup and shutdown conditions as expediently as possible.
Other Changes to the NESHAP
Other changes to the NESHAP that do not fall into the categories in the previous sections include:
• Requiring periodic air emissions performance testing, with the first of the tests to be conducted no later than October 31, 2020, and thereafter no longer than 5 years following the previous performance test;
• Specifying procedures for establishing operating limits based on data recorded by CPMS, including the
frequency for recording parameters and the averaging period for reducing the recorded readings;
• Reducing the frequency for submitting excess emissions reports from quarterly to semiannually in
conjunction with requiring electronic reporting of excess emissions;
• Requiring the submission of electronic copies of performance test reports;
• Requiring the submission of initial notifications and notifications of compliance status electronically; and
• Various technical and editorial corrections.
P a g e | 12
The compliance date for the Subpart MM amendments is October 11, 2019. Therefore, the permit modifications to incorporate these amendments do not take effect until that date. Additionally, the current permit contains 112(j)
conditions to address SSM for the Subpart MM affected sources. Once Subpart MM amendments take effect, the
112(j) condition will no longer be applicable. Therefore, a sunset date of October 11, 2019 was added to the condition. This condition will need to be removed in the next permitting action after the October 11, 2019
compliance date.
VII. Facility Wide Air Toxics
Domtar previously triggered a toxics analysis and compliance with the acceptable ambient levels (AALs) was
demonstrated for the toxic air pollutants (TAPs) with emissions greater than the TAP permitted emission rate (TPER). Compliance was demonstrated on a source-by-source basis for the facility and the current permit
contains both facility wide and source-by-source TAP limits.
In a permit application received March 6, 2018 (Permit Application No. 5900069.18A), Domtar submitted a
complete facility-wide analysis to determine which TAPs were emitted in amounts greater than the TPER for each
averaging period after proposed mill optimization modifications. As a part of that analysis, Domtar determined that 29 compounds exceed the associated TPER and submitted a modeling analysis for those 29 TAPs. The
baseline modeling was conducted to represent current emission factors and equipment throughputs. Twenty-nine
TAPs were modeled from point, area, and volume sources. Revised optimization factors for each TAP were
developed such that the maximum modeled output is 98 percent of the AAL. DAQ reviewed the provided modeling analysis and determined that the results demonstrate compliance assuming the source parameters and
pollutant emissions rates are correct. The modeling was approved on April 30, 2018 and associated TAP limits
were incorporated into Permit No. 04291T45, issued August 15, 2018.
The sources affected by this permit action do not change emissions of TAPs. Therefore, because the emissions
modeled represent the most current facility emission sources, no changes to the TAP limits in the permit are
necessary as a part of this permitting action.
VIII. Facility Emissions Review
The table on the first page of this permit review presents the criteria pollutant (plus total HAP) from the latest
available reviewed facility emissions inventory (2017). Domtar has requested the permit modifications associated
with this permit action and does not estimate any increases in emissions above these 2017 levels.
IX. Facility Compliance Status
NC DAQ has reviewed the compliance status of this facility. The most recent full inspection was completed during site visits between October 10, 2017, and September 30, 2018. Betsy Huddleston of the WaRO indicated
that the facility appeared to be in compliance with all applicable requirements, except for the No. 2 Hog Fuel
Boiler south electroscrubber voltage monitoring violation (see below for further discussion).
The following is the five-year compliance history for Domtar.
• A Notice of Violation/Notice of Recommendation for Enforcement (NOV/NRE) was issued on June 19,
2014, for NESHAP Subpart S violations pertaining to operation of condensate stripper that was damaged in mid-February 2014. Methanol concentration exceeded the limit for 10 days in March 2014. A civil
penalty in the amount of $11,542, including costs, was issued on December 11, 2014. The civil penalty
was paid in full on December 29, 2014.
• A Notice of Violation (NOV) was issued August 25, 2014, for NESHAP Subpart S violations for running
the No. 7 Bleach Plant chlorine scrubber for three hours after startup. No Notice of Recommendation for Enforcement (NRE) was issued and this violation has been considered resolved.
• A NOV/NRE was issued on February 20, 2015, for operation of LSRP Process without a PSD permit.
Domtar entered into SOC 2015-01 with interim deliverables to bring the facility into compliance. A civil
penalty in the amount of $100,000 was issued and Domtar was required to pay $1,000 per month until the
P a g e | 13
SOC is closed when a PSD permit was issued. A PSD permit was issued on April 18, 2019, and at that time, the SOC was closed.
• A Notice of Deficiency (NOD) was issued on August 28, 2015, because downtime of the NOX continuous
emissions monitoring system (CEMS) installed on the No. 2 Hog Fuel Boiler exceeded the DAQ
guideline level of 6 percent for demonstration of proper operation and maintenance practices. The NOD has been resolved.
• A NOD was issued on August 30, 2016, for two MACT Subpart S and Subpart MM related deviations
related to the No. 6 Bleach Plant Third Stage Tower and Recovery Boiler corrective action plan check
sheets. The NOD has been resolved.
• A NOV was issued on December 9, 2016, because downtime of the NOX CEMS installed on the No. 2 Hog Fuel Boiler exceeded the DAQ guideline level of 6 percent for demonstration of proper operation
and maintenance practices. The NOV was resolved as of January 11, 2017.
• A NOV was issued on February 24, 2017, because downtime of the NOX CEMS installed on the No. 1
Hog Fuel Boiler exceeded the DAQ guideline level of 6 percent for demonstration of proper operation
and maintenance practices. The NOV was resolved as of February 24, 2017.
• A NOV/NRE was issued on September 8, 2017, for exceedance of the NSPS Subpart BB TRS limit on the No. 5 Lime Kiln, exceedance of the NSPS Subpart D NOX limit on the No. 1 Hog Fuel Boiler, and
exceedance of the NSPS Subpart D opacity limit on the No. 1 Hog Fuel Boiler. A civil penalty in the
amount of $19,837, including costs, was issued on December 13, 2017. The civil penalty was paid in full and the NOV/NRE was closed on March 3, 2018.
• A NOV was issued on September 7, 2018, for incomplete records associated with secondary voltage
monitoring of the No. 2 Hog Fuel Boiler electroscrubber modules. A civil penalty in the amount of
$9,456 was paid in full and the NOV was closed on April 2, 2019.
• A NOV was issued on November 28, 2018, because downtime of the TRS CEMS installed on the No. 5 Lime Kiln exceeded the DAQ guideline level of 6 percent for demonstration of proper operation and
maintenance practices. The NOV was resolved as of January 11, 2019.
• An NOV/NRE was issued on March 4, 2019, for exceedances of the NSPS opacity emission standards
applicable to the No. 1 Hog Fuel Boiler and No. 2 Hog Fuel Boiler NOX CEM downtime. This issue has
not been resolved as of this permitting action.
The signed Title V Compliance Certifications (Form E5) included with permit applications 5900069.16A, .17B,
and .18C, indicated that the facility was not in compliance with all applicable requirements. Specifically, Domtar referred to SOC 2015-01, under which they were operating, for operation of the LSRP Process without a PSD
permit. The required Emission Source Compliance Schedule (Form E4) was also included, stating that a
compliance would be followed as specified in SOC 2015-01. On April 18, 2019, DAQ issued PSD Permit No. 04291T46, which satisfied the permitting requirements of SOC 2015-01. On May 1, 2019, SOC 2015-01 was
closed.
X. Draft Permit Review Summary
The Permittee was sent copies of the draft permit and permit review on XXXX YY, 2019. Editorial comments
from the Permittee were received on XXXX YY, 2019. Summarize comments received
Copies of the draft permit and permit review were sent to the WaRO on XXXX YY, 2019. Comments from the
WaRO were received on XXXX YY, 2019. Summarize comments received
XI. Public Notice/EPA and Affected State(s) Review
A notice of the DRAFT Title V Permit shall be made pursuant to 15A NCAC 02Q .0521. The notice will provide for a 30-day comment period, with an opportunity for a public hearing. Consistent with 15A NCAC 02Q .0525,
the EPA will have a concurrent 45-day review period. Copies of the public notice shall be sent to persons on the
Title V mailing list and EPA. Pursuant to 15A NCAC 02Q .0522, a copy of each permit application, each proposed permit and each final permit pursuant shall be provided to EPA. Also, pursuant to 02Q .0522, a notice of
P a g e | 14
the DRAFT Title V Permit shall be provided to each affected State at or before the time notice is provided to the public under 15A NCAC 02Q .0521 above.
The Commonwealth of Virginia is an affected area within approximately 50 miles of the facility.
Notice of the DRAFT Title V Permit to Affected States ran from XXXX YY, 2019, to XXXX YY, 2019.
Summarize comments from Affected States.
Public Notice of the DRAFT Title V Permit ran from XXXX YY, 2019, to XXXX YY, 2019. Summarize public
comments.
EPA’s 45-day review period ran concurrent with the 30-day Public Notice, from XXXX YY, 2019, to XXXX
YY, 2019. Summarize comments from EPA and U.S. EPA Region 4 regarding the DRAFT Title V Permit.
XII. Conclusions, Comments and Recommendations
PE Seal
Pursuant to 15A NCAC 2Q .0112 “Application requiring a Professional Engineering Seal,” a professional
engineer’s seal (PE Seal) is required to seal technical portions of air permit applications for new sources and
modifications of existing sources as defined in Rule .0103 of this Section that involve:
(1) design;
(2) determination of applicability and appropriateness; (3) or determination and interpretation of performance; of air pollution capture and control systems.
A professional engineer’s seal (PE Seal) was NOT required for this modification.
Zoning
A Zoning Consistency Determination per 2Q .0304(b) was NOT required for the Permit Application No. 5900069.17B because there was no construction involved with this permit modification. The appropriate Zoning
Consistency Determinations were submitted for the first step applications associated with Permit Applications
Nos. 5900069.16A and 5900069.18C. See Attachments 1 and 2 for details.
Recommendations
This permit modification application has been reviewed by NC DAQ to determine compliance with all procedures and requirements. NC DAQ has determined that this facility appears to be complying with all applicable
requirements.
WaRO has received a copy of this permit and submitted comments that were incorporated as described in
Section XI.
Recommend Issuance of Permit No. 04921T47.
ATTACHMENT 1
Air Permit Review for Permit Application No. 5900069.14F and Permit No. 04291T42
Attachment 1, Page 2
July 10, 2015 Air Permit Review T42
CAROLINA DIVISION OF
AIR QUALITY
Air Permit Review
Permit Issue Date: July 10, 2015
Region: Washington Regional Office
County: Martin
NC Facility ID: 5900069
Inspector’s Name: Betsy Huddleston
Date of Last Inspection: 09/02/2014 Compliance Code: B / Violation - emissions
Facility Data
Applicant (Facility’s Name): Domtar Paper Company, LLC
Facility Address:
Domtar Paper Company, LLC
NC Highway 149 North
Plymouth, NC 27962
SIC: 2611 / Pulp Mills
NAICS: 322121 / Paper (except Newsprint) Mills
Facility Classification: Before: Title V After: Title V Fee Classification: Before: Title V After: Title V
Benzene Annual 859.36 6.99e-1 860.06 5,706 No 6.63
1,3-Butadiene Annual 214.49 8.71e-1 215.36 17,484 No 81.2
Carbon disulfide 24-hour 51.62 2.4e-1 51.86 762 No 14.7
Carbon tetrachloride Annual 666.42 1.19e-1 666.54 50,270 No 75.4
Choroform Annual 5501.42 1.46e-2 5502.43 29,060 No 5.28
1,2-Dichloroethane Annual 1675.62 2.65 1678.27 324,491 No >100
Formaldehyde 1-hour 1.46 2.00e-4 1.46 18.5 No 12.67
Methylene chloride Annual 4465.21 4.66e-3 4465.21 318,755 No 71.4
1-hour 0.51 1.94e-4 0.51 27.0 No 52.9 a The new optimization factor was calculated by dividing the permitted emission rate by the new PTE after the project. This new factor will
replace the optimization factor in the existing permit.
For H2S and MMC, Domtar submitted a dispersion modeling analysis to the Air Quality Analysis
Branch (AQAB). This submittal was in support of pending enforcement action due to violations of
permit conditions involving H2S and MMC. One purpose of the modeling demonstration was to show
that a proposed control scenario would demonstrate compliance with the AALs for H2S and MMC.
The controlled scenario included routing emissions from the lignin removal process (LRP) stage 2
filtrate tank 2 (ID No. ES-09-27.3200) to the facility’s high volume low concentration (HVLC)
collection system which is then controlled in the No. 2 hog fuel boiler, with the No. 1 hog fuel boiler
as a secondary control. Using this controlled scenario, the maximum impacts were demonstrated to
be in compliance with the AAls, see Table 5. Attachment 1 provides a facility wide emission
summary of the modeled H2S and MMC emission rates both before the project and after the project
(including the controlled LRP stage 2 filtrate tank 2). Based on the modeled emissions, Table 2.2
E.2.a of the permit will be revised to include the new H2S and MMC emission limits. The revised
limits are also shown in Table 5.
Table 5. Maximum Impacts “Controlled Scenario” (Domtar - Plymouth, NC)5
TAP
Averaging
Period
Maximum
Concentration
(µg/m3)
AAL
(µg/m3) % of AAL
Revised Facility Wide
Permit Limit
(lb/averaging period)
H2S 24-hour 103.38 120 86 316
MMC 1-hour 28.31 50 57 2.85 a Revised facility wide permit limit as calculated in Attachment 1.
5 See Footnote 4.
Attachment 1, Page 12
July 10, 2015 Air Permit Review T42
Page 12
Need to add a discussion on any changes to the source by source limits.
VIII. Facility Emissions Review
The table above (in the review summary) represents the criteria pollutant (plus total HAP) from the
latest available reviewed facility emissions inventory (2013).
IX. Facility Compliance Status
At the time of the last inspection on September 2, 2014, the facility appeared to be in compliance. However, on
February 20, 2015, the Regional Office sent the facility a NOV/NRE and as a result the facility has entered into an
SOC. The control of the Stage 2 Filtrate tank 2 (lignin) is in part to the SOC.
X. Draft Permit Review Summary
A copy of the draft permit was submitted to the WaRO on July 7, 2015.
XI. Public Notice/EPA and Affected State(s) Review
Public notice not required at this time. This permit action is for the first step of a two-step process as
per 15A NCAC 2Q .0501(c)(2).
XII. Conclusions, Comments and Recommendations
PE Seal
Pursuant to 15A NCAC 2Q .0112 “Application requiring a Professional Engineering Seal,” a
professional engineer’s seal (PE Seal) is required to seal technical portions of air permit applications
for new sources and modifications of existing sources as defined in Rule .0103 of this Section that
involve:
(1) design;
(2) determination of applicability and appropriateness; or
(3) determination and interpretation of performance; of air pollution capture and control systems.
A professional engineer’s seal (PE Seal) was NOT required for this modification.
Zoning
A Zoning Consistency Determination per 2Q .0304(b) was required for this modification. This
requirement was discussed in Section V, above.
Recommendation
This permit modification application has been reviewed by NC DAQ to determine compliance with
all procedures and requirements. NC DAQ has determined that this facility appears to be complying
with all applicable requirements.
The draft permit has been reviewed by Betsy Huddleston of the Washington Regional Office and the
Raleigh Central Office. The NC DAQ recommends issuance of Title V Permit No. 04291T42.
Attachment 1, Page 13
July 10, 2015 Air Permit Review T42
Page 13
ATTACHMENT 1
The following tables show the modeled emission rates and a calculation of the revised permit limits
for H2S and MMC emissions based on the modeling analysis. (See Memorandum from Anderson, T.,
Supervisor, AQAB to Sheila Holman, Director, DAQ and Michael Pjetraj, Supervisor, SSCB.
Review of Dispersion Modeling Analysis for Domtar Paper Co. – Plymouth Mill.” May 7, 2015.)
Table A. Facility Wide H2S and MMC Emissions Prior to Project
Emission Point Description
Hydrogen
Sulfide (g/s)
Hydrogen
Sulfide (lb/24-
hour)
Methyl
Mercaptan
(g/s)
Methyl
Mercaptan
(lb/hr)
No. 2 Hog Fuel Boiler 0.677 129 0.0142 0.113
LRP Secondary Filtrate Tank 0.498 94.8 9.05E-03 0.0718
All other emission sources 0.805 153 0.344 2.73
LRP Building Fugitives 0.163 31.1 1.66E-06 1.32E-05
Total Facility Emissions 1.98 377 0.367 2.91
NOTE: Slight differences due to rounding
Table B. Facility Wide H2S and MMC Emissions After Project
Emission Point Description
Hydrogen
Sulfide (g/s)
Hydrogen
Sulfide (lb/24-
hour)
Methyl
Mercaptan
(g/s)
Methyl
Mercaptan
(lb/hr)
No. 2 Hog Fuel Boiler 0.677 129 0.0142 0.113
Controlled LRP Secondary
Filtrate Tank (98% emission
reduction)
9.95E-03 1.90 1.81E-04 1.44E-03
All other emission sources 0.805 153 0.344 2.73
LRP Building Fugitives 0.163 31.1 1.66E-06 1.32E-05
New Sources
Peroxide - - 5.01E-05 3.98E-04
No 5 Soap Storage Tank 4.88E-04 9.29E-02 5.17E-04 4.10E-03
New Liquor Sep Tank 4.88E-04 9.29E-02 5.17E-04 4.10E-03
Total Facility Emissions 1.66 316 0.359 2.85
NOTE: Slight differences due to rounding
ATTACHMENT 2
Air Permit Review for Permit Application No. 5900069.17A and Permit No. 04291T44
Attachment 2, Page 2
October 31, 2017 Air Permit Review T44
NORTH CAROLINA DIVISION OF
AIR QUALITY
Application Review
Issue Date: October 31, 2017
Region: Washington Regional Office County: Martin NC Facility ID: 5900069 Inspector’s Name: Betsy Huddleston Date of Last Inspection: 04/18/2017
Compliance Code: B / Violation - emissions
Facility Data
Applicant (Facility’s Name): Domtar Paper Company, LLC Facility Address:
Domtar Paper Company, LLC NC Highway 149 North Plymouth, NC 27962 SIC: 2611 / Pulp Mills NAICS: 322121 / Paper (except Newsprint) Mills Facility Classification: Before: Title V After:
Fee Classification: Before: Title V After:
Permit Applicability (this application only)
SIP: NSPS: NESHAP:
PSD: PSD Avoidance: NC Toxics: 112(r): Other:
No new regulations with this permit action.
Contact Data Application Data
Application Number: 5900069.17A Date Received: 03/27/2017 Application Type: Modification
Application Schedule: TV-Sign-501(c)(2) Part I Existing Permit Data
Review Engineer’s Signature: Date: October 31, 2017
Comments / Recommendations:
Issue 04291/T44 Permit Issue Date: October 31, 2017 Permit Expiration Date: September 30, 2022
Attachment 2, Page 3
October 31, 2017 Air Permit Review T44
I. Purpose of Application
Domtar Paper Company, LLC (Domtar) currently holds Title V Permit No. 04291T43, with an expiration date the
earlier of (Enter date five years from Date of Issuance = last day of previous month plus 5 years) or the renewal of Permit No. 04291T43 has been issued or denied, for a Kraft pulp mill located in Plymouth, Martin County,
North Carolina. On March 27, 2017, Domtar submitted a permit application (No. 5900069.17A) for the first step
of a two-step significant modification to their permit for the installation of a steam box on the NC5 pulp drying machine and a secondary turpentine decanting system. An amendment was submitted on July 11, 2017, to update
emissions from the turpentine railcar unloading process. Another amendment was submitted on July 18, 2017, to
update the steam box project specifications and emissions.
II. Project Description
Domtar is requesting a permit modification for two unrelated projects: (1) the addition of a secondary turpentine recovery system and (2) the addition of a steam box for heating the pulp sheet as it passes over the couch roll on
the NC5 Fluff Pulp Machine. The following is a summary of the description provided in Permit Application No.
5900069.17A.
A. Secondary Turpentine Recovery System
The mill has determined that a significant portion of the potential turpentine yield is not being extracted by the existing turpentine system and is being burned with the black liquor. Therefore, Domtar is proposing to install a
secondary turpentine recovery system, which will have a similar designed to the existing system in the fiberline
area. This system will be integrated into the evaporator condensate system to ensure extraction of more of the turpentine. The secondary turpentine system could produce 175,000 to 350,000 gallons of turpentine per year.
Adding the secondary turpentine decanting system splits the turpentine extraction between two locations, in an
effort to improve its recovery efficiency. Emissions will be collected in the low volume high concentration (LVHC) system and controlled primarily in the No. 5 Lime Kiln, with the No. 2 Hog Fuel Boiler (HFB) as a
backup. With the new configuration, exhausts of any LVHC generated from turpentine extraction are split
between two locations and fed into the existing LVHC collection system instead of entering at one location.
According to Domtar, the concentration of volatile compounds in the LVHC exhausted to control will be reduced since they will be extracted into the turpentine.
The Secondary Turpentine Recovery System equipment to be installed are listed in Table 1. The estimated emissions from the system are also presented in Table 1. As shown in the table, the estimated emissions for
Turpentine Railcar Unloading are less than 5 tons per year of VOC (0.324 tpy). This estimate represents the
maximum turpentine production from the existing turpentine system and the proposed system. Therefore, the railcar unloading with be added to the insignificant activities list. In addition, during the permitting process,
Domtar indicated that the existing railcar loading emissions were also less than 5 tpy of VOC. Therefore, the
existing railcar system was also moved to the insignificant activities list.
Table 1. Secondary Turpentine Recovery System Emission Sources
Emission
Source
ID No.
Emission
Source
Description
Control
Device
ID No. Control Device Description
Pollutants
Emitted
Potential
Emissions (tpy)
ES-09-TURPDECANT Secondary
Turpentine Decanter Tank
ES -65-25-0310 or CD-14-55-2020 and ES-14-60-3000
LVHC collection system to:
No. 2 Hog Fuel Boiler or LVHC White Liquor Scrubber (80 gallons per minute minimum white liquor injection rate) followed by the No. 5 Lime Kiln
VOC Routed to LVHC
system and
controlled.6
6 Domtar has indicated that controlling the Secondary Turpentine Recovery System will not increase the annual emissions from either the No. 2 HFB or the
No. 5 Lime Kiln.
Attachment 2, Page 4
October 31, 2017 Air Permit Review T44
Emission
Source
ID No.
Emission
Source
Description
Control
Device
ID No. Control Device Description
Pollutants
Emitted
Potential
Emissions (tpy)
ES-09-TURPWEIR Secondary
Turpentine Decanter Weir
ES -65-25-0310 or CD-14-55-2020 and ES-14-60-3000
LVHC collection system to:
No. 2 Hog Fuel Boiler or LVHC White Liquor Scrubber (80 gallons per minute minimum white liquor injection rate) followed by the No. 5 Lime Kiln
VOC Routed to LVHC
system and controlled.6
ES-09-TURPUND Secondary Turpentine Underflow Tank
ES -65-25-0310 or CD-14-55-2020 and ES-14-60-3000
LVHC collection system to: No. 2 Hog Fuel Boiler or LVHC White Liquor Scrubber (80 gallons per minute minimum white liquor injection rate) followed by the No. 5 Lime Kiln
VOC Routed to LVHC system and controlled.6
ES-09-TURPSTOR Secondary Turpentine Storage Tank
ES -65-25-0310 or CD-14-55-2020 and ES-14-60-3000
LVHC collection system to: No. 2 Hog Fuel Boiler or LVHC White Liquor Scrubber (80 gallons per minute minimum white liquor injection rate) followed by the
No. 5 Lime Kiln
VOC Routed to LVHC system and controlled.6
IES-09-TURPRAIL Turpentine Railcar Loading
N/A N/A VOC 0.324 tpy
B. NC5 Fluff Pulp Machine Steam Box
Domtar currently operates two machines to convert high density bleached softwood stock into fluff pulp (NC2
and NC5). Neither of these machines operate full time because they are limited by the fiberline production
capacity. The NC2 machine was typically scheduled to be nonoperational on Saturdays and Sundays. However,
due to market demand, the NC2 machine has recently been operated one Saturday shift per month. Domtar has determined that an efficiency project would result in a small hourly throughput increase on the NC5 machine,
eliminate the need for the Saturday shift for NC2, and reduce operating costs. By performing this efficiency
project, Domtar anticipates being able to permanently shut down and decommission NC2 by the end of 2017.
This project includes the addition of a new steam box to be positioned near the couch roll on the NC5 Fluff Pulp
Machine. The steam box maintains steam heat to the sheet as it passes over the couch roll to increase initial drying
of the sheet prior to the dryer section of the machine, allowing for 2 percent increase in hourly throughput. Domtar has estimated that the steam box will use approximately 5,000 pounds per hour (lb/hr) or less, annual
average, of 20-pound per square inch (psi) waste steam from the condensate tanks at NC5.7 According to Domtar,
the 150 psi steam from the hog fuel boilers would be used during startup or process upsets, if at all. The 5,000-lb/hr increase in steam usage represents less than 1 percent of the total steam generation at the mill
(1 million to 1.5 million lb/hr depending on the season) and is below the accuracy of the steam meters (+/- 2
percent accuracy).
According to Domtar, the annual production on the NC5 Fluff Pulp Machine will be limited by the fiberline
production capacity. Therefore, increased hourly emissions associated with the project, will be primarily from the
hourly increase in production through the NC5 emission sources, including: the dryer hood exhaust, vacuum pumps, roof vents, and high and low density stock tanks.
7 Email dated July 14, 2017 from Diane Hardison to Heather Sands, DAQ. Domtar provided a description of a refined design plan for the steam box.
Attachment 2, Page 5
October 31, 2017 Air Permit Review T44
III. Application History
March 27, 2017 DAQ received Permit Application No. 5900069.17A for the Pulp Machine Steam Box
and Secondary Turpentine Decanting System Projects.
July 5, 2017 DAQ submitted questions via phone and email to Ms. Amy Marshall (AECOM) to
request additional information regarding the secondary turpentine system.
July 6, 2017 DAQ submitted questions via email to Ms. Amy Marshall and Ms. Clair Galie (AECOM)
to request additional information regarding the emissions related to the NC5 Steam Box Project.
July 11, 2017 In response to the July 5, 2017, additional information request, DAQ received revised
calculations for emissions from Turpentine Recovery System Railcar Unloading. The railcar unloading handles turpentine for both the existing system and the new system.
Based on the calculations, this emission source is an insignificant activity.
July 18, 2017 DAQ received a response to the July 6, 2017, additional information request. Domtar
revised the design description of the NC5 Steam Box Project and provided revised
emission calculation tables to reflect the change.
July 19, 2017 DAQ submitted questions via email to Ms. Claire Gaile and Mr. Mark Yoder (AECOM)
to clarify inconsistencies with emissions calculations and the emissions used for
modeling.8
August 1, 2017 Domtar responded to the July 19th request for clarification on the emissions calculations.
Revisions to the modeling were submitted with this response.
August 4, 2017 Domtar requested guidance on issues with modeling. Modeling conducted in 2012 and
the emissions calculated for the NC5 Steam Box Project were not calculated using the
same pulp production rates. A number of TAP were not modeled as being emitted from the NC5 Pulp Machine in 2012 but, based on revised emission factor data, are being
August 7, 2017 DAQ requested additional information on the August 4th email requesting guidance on
the modeling.
August 24, 2017 Domtar requested guidance on how to respond to the August 7th questions from DAQ.
Domtar submitted modeling conducted for benzene and methylene chloride emissions
from just the NC5 Pulp Machine and then added these results to modeling conducted in 2012. Domtar also provided a demonstration that Facility wide emissions are below the
TAP permitted emission rates for chlorobenzene, methyl ethyl ketone, methyl isobutyl
ketone, styrene, toluene, and xylene.
August 28, 2017 DAQ participated in a meeting with representatives from Domtar and AECOM to discuss
future projects at the mill. While in the meeting, the NC5 Steam Box Project was
discussed, and DAQ requested revisions to clarification on how potential emissions from the NC5 Pulp Machine were calculated.
8 NOTE: Modeling is being revised for methyl mercaptan and hydrogen sulfide in conjunction with a PSD Permit Application No. 5900069.16C. Because
the Steam Box Project impacts methyl mercaptan and hydrogen sulfide emissions, updates to the modeling for the PSD application will be incorporated as
part of the modifications to the permit being made in relation to the Steam Box Project.
Attachment 2, Page 6
October 31, 2017 Air Permit Review T44
August 30, 2017 Domtar provided a revised emissions calculation of potential emissions from the NC5
Pulp Machine. Emissions were recalculated using maximum capacity of the pulp machine
assuming 8,760 hours per year.
August 31, 2017 Methyl mercaptan and hydrogen sulfide modeling results were approved by Matt Porter,
Air Quality and Analysis Branch (AQAB).
September 13, 2017 Domtar submitted modeling results for benzene and methylene chloride emissions from
the NC2 and NC5 Fluff Pulp Machines.
September 19, 2017 Benzene and methylene chloride modeling results were approved by Matt Porter, Air
Quality and Analysis Branch (AQAB).
September 19, 2017 Claire Galie (AECOM), confirmed Domtar agreed that it was appropriate to remove the
optimization factors from the Section 2.2 E.2.a table of the permit, in addition to toxic air
pollutants emitted from MACT sources only. This was in response to a phone conversation between Heather Sands and Ms. Galie on September 18, 2017.
October 4, 2017 Draft Permit and Permit Review submitted to applicant and WaRO for review.
October 5, 2017 WaRO comments were received. Comments were editorial in nature and were addressed
as recommended.
October 13, 2017 Comments from applicant were received. Comments were mostly editorial or responses
to questions posed during the review process, except for outstanding questions.
October 18, 2017 DAQ requested some clarification on the comments received October 13th.
October 19, 2017 Domtar responded to questions sent on October 19th. All issues were resolved.
October 31, 2017 Permit Issued
IV. Permit Modifications
Table 2 describes the changes to the current permit as a part of this modification.
Table 2. Summary of Changes to Permit No. 04291T43
Pages Section Description of Changes
Cover letter NA • Updated permit revision and dates.
Cover Letter Attachment
Insignificant Activities list and
Summary of changes
to permit
• Updated summary of changes to permit.
• Added Secondary Turpentine Railcar loading to insignificant
activities list (in Evaporator Area).
• Added turpentine railcar loading to insignificant activities list (from
Section 1).
Permit Cover NA • Revised permit application number and dates.
1 – 110 All • Updated Permit Revision Number in header.
• Updated permit language to match permit shell.
Attachment 2, Page 7
October 31, 2017 Air Permit Review T44
Pages Section Description of Changes
3 – 14 Section 1 • Updated page numbers.
• Added Secondary Turpentine Decanter Tank and Weir, Underflow
Tank, and Storage Tank.
• Moved turpentine railcar loading (this source was moved to the
insignificant activities list in the Fiberlines Area).
• Updated Emission Source Descriptions to be consistent with the sources listed in Table 2.2 E.2.b.
• Added a footnote identifying the secondary turpentine sources as
being added as a 02Q .0501(c)(2) modification and the requirement
to file a permit application within 12-months of commencing
operation.
51 Section 2.1 J • Corrected ID numbers in condition header.
52 Section 2.1 K • Added secondary turpentine sources to condition header.
67 – 74 Section 2.2 A • Added secondary turpentine sources to the table of affected sources.
82 – 87 Section 2.2 E • Added the modeling received with the Steam Box Application (No.
sulfide, and methyl mercaptan limits from Table 2.2 E.2.a so that
the table only represents TAP for which the modeling analysis
demonstrated compliance at 9.8 percent of the AAL or less.
• Removed optimization factor from Table 2.2 E.2.a.
• Removed facility wide limits for hexachlorocyclopentadiene and
sulfuric acid from Table 2.2 E.2.a because these TAP are only emitted from MACT sources which are exempt from TAP under
02Q .0702.
• Updated Table 2.2 E.2.b to reflect most recent modeling. Added
Emission Source IDs and Modeling IDs to table so future modeling
demonstrations are more readily reviewed. Made sure that emission
source descriptions were consistent with the descriptions in Section
1.
• Removed formaldehyde from Table 2.2 E.2.b because the modeling
analysis demonstrated compliance with the AAL for formaldehyde
at less than 9.8 percent.
88 Section 2.2 F • Added section “Permit Application Submittal Requirement” and
added conditions requiring that, within 12 months of the beginning of operation, a permit application be submitted for the sources being
added under 02Q .0501(c)(2).
89 – 97 Section 3 • Updated General Conditions to current Version 5.1, dated
08/03/2017.
V. Regulatory Review – State Rules
As described above, Domtar is proposing to install a new Secondary Turpentine Recovery System and modify the
NC5 Fluff Pulp Machine by adding a new steam box. The following discussion summarizes the State rules that
could potentially apply to these sources and any necessary changes to be made with this permit modification. In their permit application, Domtar provided a regulatory analysis for the State rules that may apply. The analysis is
summarized in Table 3. Table 3 also incorporates a summary of regulations not included in the Domtar analysis.
As shown, the State rules that will apply to the Secondary Turpentine Recovery Project and the NC5 Fluff Pulp
Machine Project will be:
• 02D .0530 – Prevention of Significant Deterioration;
Attachment 2, Page 8
October 31, 2017 Air Permit Review T44
• 02D .1100 – Control of Toxic Air Pollutants;
• 02D .1111 – Maximum Achievable Control Technology; and
• 02Q .0113 - Notification in Areas Without Zoning.
These rules are discussed in further detail in Sections VI, VII, and XII, below.
Table 3. Summary of Potentially Applicable State Regulations
Regulation
15A NCAC Title Applicability
Applicability to Secondary Turpentine
Recovery System Project and
NC5 Fluff Pulp Machine Project
02D .0521 Control of Visible Emissions
Applies to fuel burning operations and industrial processes that may have visible emissions.
This rule does not apply. The Secondary Turpentine Recovery System and the NC5 Fluff Pulp Machine sources do not have visible emissions.
02D .0524 New Source Performance Standards
Applies to sources subject to regulations under 40 CFR Part 60.
This rule does not apply. The Secondary Turpentine Recovery System and NC5 Fluff Pulp Machine are not subject to NSPS. See Section VI for a detailed discussion.
02D .0528 Total Reduced Sulfur from Kraft Pulp Mills
Applies to recovery furnaces, digester systems, multiple-effect evaporator systems, lime kilns, smelt dissolving tanks, and condensate
stripping systems of kraft pulp mills
This rule does not apply. The Secondary Turpentine Recovery System and NC5 Fluff Pulp Machine are not regulated units under this
regulation.
02D .0530 Prevention of Significant Deterioration
Applies to facilities subject to PSD regulations. See Section VI for a detailed discussion on this regulation.
02D .0614 Compliance Assurance
Monitoring
Applies to facilities that meet specific criteria unless exempted via other specified criteria.
This rule does not apply. See Section VI for a detailed discussion on this regulation.
02D .0948
VOC Emissions from Transfer Operations
Applies to facilities that transfer VOC (excludes gasoline) from a storage tank to tank-trucks, trailers, or railroad tank cars and limits the transfer to 20,000 gallons/day of VOC with a vapor pressure of 1.5 psi or more unless submerged loading is used.
This rule does not apply. The Secondary Turpentine Recovery System includes railcar transfer of the turpentine byproduct. The vapor pressure of turpentine is approximately 0.44 psia, which is well below the 1.5 psia cutoff. The NC5 Fluff Pulp Machine does not have regulated emission units.
02D .0949 Storage of Miscellaneous VOCs
Applies to storage of VOC (excludes gasoline and petroleum liquids) in stationary tanks, reservoirs, or other containers with a capacity greater than 50,000 gallons and requires controls for tanks storing liquid with a vapor pressure of 1.5 psi or more.
This rule does not apply. As stated above, the turpentine byproduct has a vapor pressure less than 1.5 psia and the turpentine storage tanks are not regulated by this rule. The NC5 Fluff Pulp Machine does not have regulated emission units.
02D .0958 Work Practices for Sources of VOC
Applies to facilities that use VOC as solvents, carriers, etc. and are located in moderate nonattainment areas.
This rule does not apply. Domtar is not located in one of the specified nonattainment areas.
02D .1100 Control of Toxic Air Pollutants
Requires facilities that emit TAPs at levels greater than the TAP Permitted Emission Rates specified in 02Q .0700.
Domtar has triggered permitting of TAP. See Section VII for a detailed discussion.
02D .1111 Maximum Achievable Control Technology
Applies to sources subject to MACT standards under 40 CFR Part 63.
Domtar is subject to several MACT standards. See Section VI for a detailed discussion.
02Q .0113 Notification in Areas without Zoning
Applies to facilities located in areas without zoning and requires public notice.
Domtar is located in an area without zoning. See Section XII for a detailed discussion.
VI. Regulatory Review - Federal Rules (NSPS, NESHAP/MACT, NSR/PSD, CAM)
A. New Source Performance Standards
Attachment 2, Page 9
October 31, 2017 Air Permit Review T44
Domtar is subject to several new source performance standards (NSPS) under 40 CFR Part 60. For these projects,
the only potentially applicable NSPS are the Standards of Performance for Kraft Pulp Mills Affected Sources for
Which Construction, Reconstruction, or Modification Commenced After May 23, 2013, under 40 CFR Part 60,
Subpart BBa (Subpart BBa), and the Standards of Performance for Fossil-Fuel-Fired Steam Generators under 40 CFR Part 60, Subpart D (Subpart D).
The affected sources under Subpart BBa are as follows: digester system (digesters and associated flash tanks, blow tanks, chip steamers, and condensers), brown stock washer system (washers and associated knotters,
vacuum pumps, and filtrate tanks), multiple-effect evaporator system (evaporators and associated condensers and
hotwells), recovery furnace, smelt dissolving tank, lime kiln, and condensate stripper system. The emission units being installed as part of the Secondary Turpentine Recovery System are not affected sources under Subpart BBa.
The No. 2 HFB is currently subject to Subpart D. This project will not result in a measurable increase in
utilization of the boiler. Therefore, this project is not considered a modification or reconstruction.
B. National Emissions Standards for Hazardous Air Pollutants
Domtar is currently subject to several national emissions standards for hazardous air pollutants (NESHAP) under
40 CFR Part 63. For the proposed projects the only NESHAP potentially applicable is the NESHAP from the Pulp
and Paper Industry under 40 CFR Part 63, Subpart S (Subpart S). Subpart S applies to the pulping system, which
is defined as all process equipment, beginning with the digester system, and sources up to and including the last piece of pulp conditioning equipment prior to the bleaching system, including treatment with ozone, oxygen, or
peroxide before the first application of a chemical bleaching agent. Therefore, the Secondary Turpentine
Recovery system is part of the pulping system and therefore will be subject to Subpart S.
The standards for the pulping system specify that each low volume high concentration system (LVHC) be
controlled. Subpart S defines the LVHC system as including the digesters, turpentine recovery, evaporators, and steam stripper systems. Domtar currently meets the requirements of Subpart S by reducing HAP emissions from
the LVHC system using the No. 5 Lime Kiln or No. 2 HFB, as allowed under 40 CFR 63.443(d)(4). In their
permit application, Domtar stated that they will comply with Subpart S by routing the Turpentine Decanter Tank,
Turpentine Decanter Weir, Secondary Turpentine Underflow Tank, and Secondary Turpentine Storage Tank through the LVHC system to the No. 5 Lime Kiln or the No. 2 HFB.
Pulping process condensates include condensates from each digester system, each turpentine recovery system, each evaporator system condensate (from vapors from each stage where weak liquor is introduced and each
evaporator vacuum system for each stage where weak liquor is introduced), each high volume low concentration
(HVLC) collection system, and each LVHC collection system. The pulping condensate standards under Subpart S require the mill to collect pulping condensates that have at least 11.1 pounds of HAP per oven dried ton of pulp
(lb/ODTP) [40 CFR 63.446(c)(3)]. Condensates are required to be collected and conveyed in a closed collection
system and controlled by reducing HAP emissions by at least 92 percent or removing at least 10.2 lb/ODTP of
HAP. Domtar will continue to collect pulping process condensates as required.
The permit will be revised to add the new Secondary Turpentine Recovery System sources to the affected sources
table in Section 2.2 A of the permit.
C. Prevention of Significant Deterioration
The prevention of significant deterioration (PSD) regulations apply to new major stationary sources or existing major sources that propose a major modification. Kraft paper mills are listed as one of the 28 source categories
under federal PSD regulation as being subject to regulation with potential emissions greater than 100 tpy of any
PSD-regulated pollutant. As such, the Domtar mill is a major source under PSD.
Attachment 2, Page 10
October 31, 2017 Air Permit Review T44
A project is considered a major modification if there is a physical change in or a change in the method of
operation of a major stationary source that would result in both a significant emission increase and a significant
net emission increase. In order to determine whether a project results in a significant increase, the NC regulations
under 15A NCAC 02D .0530 allow for project netting. Under project netting, emission increases and decreases from all emission units at the source that are defined as the project are used and compared to the significant
emission rates. Table 4 presents the significant emission rates for the regulated pollutants being impacted by this
project.
Table 4. Project Netting for Secondary Turpentine System and
Is Project Net Increase > PSER? NO NO NO NO NO aIn Permit Application No. 5900069.17A, Domtar provided TRS emissions as H2S. For PSD, TRS emissions are calculated as the sum of the TRS
pollutant components. Therefore, TRS emissions were recalculated to represent total TRS emissions. The sources of TRS emissions are the Dryer Hood
Exhaust, Vacuum Pumps, and Roof Vents. These sources only emit methyl mercaptan. bAnnual average baseline actual emissions for each pollutant are calculated for the 24-month period that represents the highest emissions over the five
years prior to the project. For these projects, Domtar has used calendar years 2015 and 2016. cBAE was not provided for the Turpentine Railcar Unloading in Permit Application No. 5900069.17A. BAE was calculated using the emission factor
provided for the potential to emit and the volume of turpentine unloaded as reported in the annual emission inventory for 2015 and 2016. dDomtar has elected to use PTE for the project increases associated with the NC5 Fluff Pulp Machine Steam Box and Secondary Turpentine System. eEmissions represent railcar loading for all turpentine handled at the facility
A significant increase in emissions of a regulated PSD pollutant is projected to have occurred if the difference
between the emission after the project and the baseline actual emissions (BAE) before the project are greater than the significant emission rate for that pollutant. When a new emissions unit at a major source is being installed,
the emissions after the project are based on the potential to emit (PTE) of the new unit.
Domtar provided emission increase calculations for the sources being impacted by these projects: Dryer Hood
Exhaust, Vacuum Pumps, Roof Vents, High and Low Density Stock Tanks, and Turpentine Railcar Unloading.
These units are not sources of the following PSD pollutants (therefore netting is not required for these pollutants):
The emissions prior to the project are BAE. As required by 15A NCAC 02D .0530, BAE is calculated as the
average rate, in tons per year, at which the emissions unit emitted the pollutant during any consecutive 24-month period selected by the owner or operator within the five-year period immediately preceding the date that a
complete permit application is received. As shown in Table 4, Domtar has selected the 24-month period of
calendar year 2015 through 2016.
Attachment 2, Page 11
October 31, 2017 Air Permit Review T44
Under 40 CFR 51.166(r)(6) and 15A NCAC 02D .0530, for projects involving existing emissions units at a major
stationary source, the owner or operator may elect to use projected actual emissions (PAE) to represent the
emissions after the project. Projected actual emissions mean the maximum annual rate, in tons per year, at which
an existing emissions unit is projected to emit a regulated pollutant in any one of the 5 years (12-month period) following the date the unit resumes regular operation after the project, or in any one of the 10 years following that
date, if the project involves increasing the emissions unit’s design capacity or its potential to emit that regulated
NSR pollutant. Under 02D .0530(u), if a facility elects to use PAE, they are required to track emissions
For the Secondary Turpentine Recovery System and the NC5 Fluff Pulp Machine projects, Domtar has elected to
use only PTE for their netting. By comparing PTE to BAE, the resulting emissions increase provides a conservative estimate because the machine is bottlenecked by the fiberline production capacity and Domtar does
not anticipate an increase in annual emissions as a result of this project. Because the emission increases were
calculated using PTE, no emissions tracking is required.
As shown in Table 4, the net PM (including PM10 and PM2.5), VOC, and TRS emissions impact from the
Secondary Turpentine Recovery and the NC5 Fluff Pulp Machine projects is less than the significant emission
rate for each pollutant and no further PSD analysis is required.
VII. Facility Wide Air Toxics
Domtar previously triggered toxics analysis and compliance with the acceptable ambient levels (AALs) was demonstrated for 31 TAP.9,10 Compliance was demonstrated on a source-by-source basis for the facility and the
current permit contains both facility wide and source-by-source TAP limits. To allow for operational flexibility,
the permitted emission rates were developed for each source by optimizing the emissions such that the peak modeled concentration would be no higher than 98 percent of the applicable AAL. The permitted emission rates
were developed by developing an optimization factor by dividing 98 percent of the AAL by the maximum
modeled concentration. Because compliance was demonstrated on a source-by-source basis, the permit limits are normally established on source-by-source bases; in this case however, where the optimization factor is greater
than 10 (meaning that the facility wide maximum modeled concentration was 9.8 percent or less of the AAL), the
compliance margin was considered to be sufficiently high to ensure compliance with the AAL on a facility wide
basis. Therefore, facility wide emission limits were established for TAP for which the maximum modeled concentration was 9.8 percent or less of the AAL. The following summarizes changes to the toxics condition in
the permit.
A. Toxics Analysis for Turpentine Recovery System
The new turpentine recovery system will be subject to the pulp and paper NESHAP under 40 CFR Part 63, Subpart S. Therefore, the addition of these new sources does not require a toxics analysis. Furthermore, a no
unacceptable risk determination was not needed for these sources because, as discussed in Section II.A, the new
turpentine system will be controlled in the LVHC system and emissions will not increase. Turpentine railcar
unloading is not a source of TAP emissions.
B. Toxics Analysis for NC5 Steam Box Project
The NC5 Fluff Pulp Machine is not subject to MACT standards and is currently regulated under the NC TAP
rules and has individual source emission limits for chloroform and formaldehyde.11 An analysis of the increases in
9 Memorandum from Anderson, T., AQAB, to C.Yirka, RCO, and Permit Coordinator, WaRO. Review of Dispersion Modeling Analysis for Domtar Paper
Co. – Plymouth Mill, Plymouth, NC, Martin County. April 2, 2012. Facility wide analysis. 10 Memorandum from Anderson, T., AQAB to Kelvington, J., RCO, and Permit Coordinator, WaRO. Review of Dispersion Modeling Analysis for Domtar
Paper Co. – Plymouth Mill, Plymouth, NC, Martin County. February 20, 2014. Ammonia and Phenol. 11 While editing the permit for this modification, it was discovered that the NC5 Fluff Pulp Machine was omitted from the source description column of
Table 2.2 E.2.b. The chloroform and formaldehyde limits were included under the NC2 Fluff Pulp Machine. This was corrected as a part of this permit
modification.
Attachment 2, Page 12
October 31, 2017 Air Permit Review T44
emissions associated with the Steam Box Project is presented in Table 5. As discussed above, the Steam Box
Project will result in short term increases in production but not long term increases, because the pulp machine is
bottlenecked by the fiberlines. The existing facility wide potential to emit (PTE) presented in Table 5 represents
the unoptimized and bottlenecked emissions from only the TAP emitted from the NC5 Sources and Stock Tanks as the facility exists prior to the project. Increases in emissions from the NC5 Sources (including the building
fugitives, vacuum pumps, and dryer hoods) and the NC5 High and Low Density Stock Tanks were added to the
facility wide PTE. The new PTE was then compared to the TPER. As shown in Table 5, none of the TAP emitted facility wide in levels less than the associated TPER prior to the project will exceed the TPER after to the project.
Table 5 also shows that the current facility wide permit limits do not need to be revised because the facility wide
PTE plus the Steam Box Project PTE do not exceed the current permit limit.
For the TAP presented in Table 5, the maximum modeled concentration for benzene, chloroform, and methyl
mercaptan, the optimization factor was less than 10 (this corresponds to a maximum modeled concentration that is
greater than 9.8 percent of the AAL). Therefore, permitted emission limits for these TAP are not included in the facility wide limits table. Chloroform has an annual averaging period, and as Domtar anticipates there to be no
annual increases in production due to the NC5 Steam Box Project, the chloroform emission limits in the permit
for the NC5 Sources (including the building fugitives, vacuum pumps, and dryer hoods) and the NC5 High and Low Density Stock Tanks were not adjusted for this project. Additional details regarding the benzene and methyl
mercaptan emission limits will be discussed below.
1. New Toxic Air Pollutant Emissions from NC5 Sources
When estimating emissions from the NC5 Sources, Domtar updated several emission factors based on the latest
published emission factors for paper and fluff pulp machines.12 As a result, several TAP were found to be emitted from NC5 Sources (including building fugitives, vacuum pumps, and dryer hoods), as well as similar sources for
the NC2 Fluff Pulp Machine, that had not been previously modeled: benzene, chlorobenzene, methylene chloride,
methyl ethyl ketone (MEK), methyl isobutyl ketone (MIBK), styrene, toluene, and xylenes. As shown in Table 5, when adding the NC5 Sources to the existing facility wide PTE, the new facility wide PTE chlorobenzene, methyl
ethyl ketone, methyl isobutyl ketone, styrene, toluene, and xylene remained below the TPER and no further
analysis was necessary. It should be noted that although emissions from NC2 sources are not included in this
table, the new PTE calculated with the NC5 sources remain less than 30 percent of the TPER (ranging from 1 percent for xylenes and toluene to 30 percent for methyl ethyl ketone). Therefore, it can be assumed that adding
emissions from NC2 sources to the facility wide PTE would not increase emissions above the TPER.
Domtar previously triggered a toxics analysis for methylene chloride. Methylene chloride emissions (annual and hourly) were included in the previously approved 2012 modeling analysis13 and Table 2.2 E.2.a of the current
permit has facility wide methylene chloride emission limits. To be conservative, Domtar provided a modeling
analysis of just methylene chloride emissions from the NC2 and NC5 paper machines and added the maximum modeled impacts from NC2 and NC5 to the maximum facility wide modeled impacts in the approved analysis.13
Table 6 presents the results of the modeling performed by Domtar. The 2012 maximum methylene chloride
concentration in Table 6 corresponds to the permitted emission rates of 26.86 lb/hr and 318,771 lb/12-months and
is 1.4 to 1.9 percent of the AAL. As shown in Table 6, adding the NC2 and NC5 methylene chloride modeled emissions to the 2012 modeled emissions results in maximum impact that remains than 10 percent of the AAL
(2.53 percent for the annual standard and 2.26 percent for the hourly standard). Because the current facility wide
methylene chloride emission limits represent a large margin of compliance, no changes to the methylene chloride limits were made to add the NC2 and NC5 emissions.
12 National Council of the Paper Industry for Air and Stream Improvement (NCASI) Technical Bulletin No. 973, February 2010. Compilation of 'Air Toxic'
and Total Hydrocarbon Emissions Data For Pulp and Paper Mill Sources - A Second Update. Table 4.34 pg. 140, Summary of Air Toxic Emissions from
Bleached Kraft Pulp and Paper Machines, unless otherwise noted. 13 Memorandum from Anderson, T., AQAB, to C.Yirka, RCO, and Permit Coordinator, WaRO. Review of Dispersion Modeling Analysis for Domtar Paper
Co. – Plymouth Mill, Plymouth, NC, Martin County. April 2, 2012.
Attachment 2, Page 13
October 31, 2017 Air Permit Review T44
Also presented in Table 6 are the benzene modeling results. The 2012 facility wide maximum benzene
concentration was 14.8 percent of the AAL. The NC2 and NC5 benzene modeled concentration was
approximately 0.03 micrograms per cubic meter (µg/m3) which, when added to the 2012 facility wide maximum
concentration, resulted in a new facility wide maximum concentration of approximately 0.05 µg/m3, which is 43.6 percent of the AAL. A new optimization factor of 2.25 was calculated by dividing the 98 percent by 43.6
percent.
Because the maximum benzene concentration was greater than 9.8 percent of the AAL, as modeled in the 2012
analysis, source-by-source permitted emission rates have already been established for sources of benzene
emissions. Therefore, permitted emission rates were added for benzene emissions from the NC2 and NC5 Sources. The modeled emission rates for benzene emissions from the NC2 and NC5 Fluff Pulp Machine Sources
are presented in Table 7. The modeled emission rate pounds per year (lb/yr) was multiplied by the optimization
factor in Table 6 to develop the optimized benzene emission rates for the NC2 and NC5 Fluff Pulp Machine.
These optimized permitted emission rates are also shown in Table 7: the benzene permitted emission limit for the NC2 Sources is 123 lb/yr and the NC5 machine benzene permitted emission limit is 325 lb/yr.
2. Modeling for Methyl Mercaptan and Hydrogen Sulfide
As discussed in their permit application, an updated modeling analysis was submitted with Permit Application
No. 5900069.16C for methyl mercaptan and hydrogen sulfide. This modeling was approved on August 31, 2017.14
The modeling results are presented in Table 8. Tables 9 and 10 present the permitted emission rates for each nonexempt source of methyl mercaptan and hydrogen sulfide. These rates are based on the data provided in
Attachment 2.
3. Other Changes to Modeling Tables
In addition to the changes discussed above, the following changes were made to the modeling tables:
• To be conservative, the permitted emission limits in Table 2.2 E.2.a represent emissions of specific TAP for all sources facility wide, including sources exempt from modeling under 15A NCAC 02Q .0702(b). The
sources of hexachlorocyclopentadiene are the hog fuel boilers. The only sources of sulfuric acid are the hog
fuel boilers, the recovery furnace and lime kiln. The boilers, recovery furnace and lime kiln are all subject to
MACT standards and therefore exempt from modeling [15A NCAC 02QA .0702(a)(27)]. Therefore, these TAP will be removed from Table 2.2 E.2.a as they have been determined to pose no unacceptable risk.
• The 2012 formaldehyde modeling demonstration resulted in a maximum modeled concentration less than
9.8 percent of the AAL. However, Table 2.2 E.2.b of the current permit has source-specific formaldehyde
emissions limits for the NC2 and NC5 Sources, Wastewater Treatment, and several lignin removal sources. Therefore the source-specific limits were removed from Table 2.2 E.2.b.15
VIII. Facility Emissions Review
The table above (in the review summary) represents the criteria pollutant (plus total HAP) from the latest
available reviewed facility emissions inventory (2015).
IX. Facility Compliance Status
DAQ has reviewed the compliance status of this facility. Due to the size and complexity of the paper mill, the inspections at Domtar are conducted in phases. The most recent inspections covering the Fiberline, Recovery
14 Memorandum from Porter, M., AQAB, to H. Sands, RCO, and Permit Coordinator, WaRO. Review of Dispersion Modeling Analysis for Domtar
Plymouth Lignin Solids Removal Process and other Energy Improvements, Domtar Paper Company – Plymouth Mill, Plymouth, NC, Martin County.
August 31, 2017. Methyl mercaptan and hydrogen sulfide. 15 NOTE: In our August 28, 2017, meeting with representatives from Domtar, they indicated that the entire toxics analysis would need to be updated in the
near future. When the toxics modeling is updated during the next permit modification, all of the source-by-source limits will be updated and facility wide
emission limits should be removed from the permit at that time.
Wastewater Treatment, Maintenance, Landfill, and Emergency Engine Operations occurred between February 17,
2017, and August 22, 2017, by Betsy Huddleston of the Washington Regional Office (WaRO). No problems
were discovered during the physical inspection of the sources and during records review at the mill. During the onsite inspection, the facility status in compliance. Domtar is currently operating under a Special Order by
Consent (SOC) for PSD violations, but is currently in compliance with the interim deliverables of the SOC.
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October 31, 2017 Air Permit Review T44
Table 5. Toxic Air Pollutant Permitted Emission Rate Analysis
aPTE is from Soap Tank Project, Permit Application No. 5900069.14F. See July 7, 2015, email from Brad Justus, AECOM (See Attachment 1). bPhenol emissions were included in Permit Application No. 5900069.14F. The permit limit was divided by the optimization factor in the current permit to obtain the Existing Facility wide PTE for phenol. cMethyl mercaptan emissions were modeled for Permit Application 6900069.16C and includes the increased emissions from the NC5 steam box. Therefore, only PTE is presented in this table. See discussion on methyl
mercaptan and hydroge sulfide modeling.
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October 31, 2017 Air Permit Review T44
Table 6. Benzene and Methylene Chloride Model Resultsa
aModeling results from September 9, 2017, email from Galie, C., AECOM, to H. Sands, RCO. Re: Draft Permit and Review – Domtar
Comments.
Table 7. Modeled Benzene Emission Rates
Emission
Source ID
Emission Source
Description
Modeling
ID
Modeled
Emissions
(g/s)
Modeled
Emissions
(lb/yr)
Optimized
Emissions
(lb/yr)
ES-32-93-0100 NC-2 Line Building Roof Vents
NC1_2_A 6.04E-05 4.20 9.44
NC1_2_B 6.04E-05 4.20 9.44
NC1_2_C 6.04E-05 4.20 9.44
NC1_2_D 6.04E-05 4.20 9.44
NC1_2_E 6.04E-05 4.20 9.44
NC1_2_F 6.04E-05 4.20 9.44
NC1_2_G 6.04E-05 4.20 9.44
NC1_2_H 6.04E-05 4.20 9.44
NC1_2_I 6.04E-05 4.20 9.44
NC1_2_J 6.04E-05 4.20 9.44
NC1_2_K 6.04E-05 4.20 9.44
NC1_2_L 6.04E-05 4.20 9.44
NC1_2_M 6.04E-05 4.20 9.44
Total NC-2 Line Building Roof Vent Emissions 54.6 123
ES-45-93-1000 NC-5 Line Building
Fugitives
NC4_5_A 2.60E-04 18.1 40.6
NC4_5_B 2.60E-04 18.1 40.6
NC4_5_C 2.60E-04 18.1 40.6
NC4_5_D 2.60E-04 18.1 40.6
NC4_5_E 2.60E-04 18.1 40.6
NC4_5_F 2.60E-04 18.1 40.6
NC4_5_G 2.60E-04 18.1 40.6
NC4_5_H 2.60E-04 18.1 40.6
Total NC-5 Line Building Roof Vent Emissions 145 325
aModeling Analysis received September 13, 2017, from AECOM for Benzene and Methylene Chloride emissions from the NC2 and NC5 Machines. Modeling approved in September 19, 2017 memorandum.
Attachment 2, Page 17
October 31, 2017 Air Permit Review T44
Table 8. Methyl Mercaptan and Hydrogen Sulfide Modeling Resultsa
Copies of the draft permit and permit review were sent to the WaRO and the Permittee on October 4, 2017.
Comments from the WaRO were received on October 5, 2017. No major comments were received.
XI. Public Notice/EPA and Affected State(s) Review
Public notice not required at this time. This permit action is for the first step of a two-step process as per 15A
NCAC 2Q .0501(c)(2).
XII. Conclusions, Comments and Recommendations
PE Seal
Pursuant to 15A NCAC 2Q .0112 “Application requiring a Professional Engineering Seal,” a professional
engineer’s seal (PE Seal) is required to seal technical portions of air permit applications for new sources and modifications of existing sources as defined in Rule .0103 of this Section that involve:
(1) design; (2) determination of applicability and appropriateness; or
(3) determination and interpretation of performance; of air pollution capture and control systems.
A professional engineer’s seal (PE Seal) was required for this modification and was provided on Form D5.
Zoning
Domtar is located in an area without zoning. Therefore, a Zoning Consistency Determination per 2Q .0304(b) was
required for this modification. Before submitting a permit application for a new or expanded facility in an area
without zoning, the Permittee is required to provide public notification by publishing a legal notice and to post a sign on their property where the new or expanded source is located.
The legal notice is required to be published in a newspaper of general circulation in the area where the source is or
will be located at least two weeks before submitting the permit application for the source. The notice must include: the name of the affected facility; the name and address of the permit applicant; and the activity or
activities involved in the permit action.
The sign must meet the following as specified by 2Q .0113:
1. The sign shall be at least six square feet in area;
2. It shall be set off the road right-of-way, but no more than 10 feet from the road right-of-way. 3. The bottom of the sign shall be at least six feet above the ground;
4. It shall contain the following information: the name of the affected facility; the name and address of the
permit applicant; and the activity or activities involved in the permit action;
5. Lettering shall be a size that the sign can be read by a person with 20/20 vision standing in the center of the road; and
6. The side with the lettering shall face the road, and sign shall be parallel to the road.
In Appendix C of the March 2017, Domtar provided an affidavit and proof of publication that the legal notice
required under this rule was published in the Enterprise & Weekly Herald on December 23, 2016. Domtar also
provided a picture of the posted sign meeting the requirements specified above and Domtar stated that the sign was posted on January 25, 2017.
Attachment 2, Page 24
October 31, 2017 Air Permit Review T44
Recommendations
This permit modification application has been reviewed by NC DAQ to determine compliance with all procedures
and requirements. NC DAQ has determined that this facility appears to be complying with all applicable
requirements.
Recommend Issuance of Permit No.04291T44. WaRO has received a copy of this permit and submitted
comments that were incorporated as described in Section IX.
Attachment 2, Page 25
October 31, 2017 Air Permit Review T44
Attachment 1
Updated TAP Modeling Tables for Section 2.2 E.2
Email from Hardison, D. (Domtar) to H. Sands (RCO) on July 7, 2015
July 1995 Stack Testing (Increased by 7.58% due to
additional condensate sewering March 2013)
818
ODTP/day
2.96E+01
1.55E-01
3.67E+01
1.93E-01
07-31-1180
F30
No. 7 Bleach Plant Scrubber
2.15E-02
lb/ODTP
Sep 1995 Stack Testing (Increased by 7.58% due to
additional condensate sewering March 2013)
1,278
ODTP/day
2.75E+01
1.44E-01
3.42E+01
1.79E-01
05-30-1300
F60
Hot Water Tank
2.05E-03
lb/hr
Sep 1998 Stack Testing (Same as Combined
Condensate Tank)
24
hr/day
4.93E-02
2.59E-04
6.12E-02
3.21E-04
08-40-1000 F35 No. 32 High Density Pulp Tank 2.35E-03 lb/hr NCASI SR 14-01 Table 3-6- Addendum to TB 973 24 hr/day 5.64E-02 2.96E-04 7.00E-02 3.68E-04
14-05-0050
R03
North Smelt Tank
5.97E-03
lb/TBLS
NCASI TB 973 Table 4.28 - Emissions from Kraft
Smelt Dissolving Tanks
1,661
TBLS/day
9.92
5.21E-02
12.32
6.47E-02
14-05-0300
R04
South Smelt Tank
5.97E-03
lb/TBLS
NCASI TB 973 Table 4.28 - Emissions from Kraft
Smelt Dissolving Tanks
1,661
TBLS/day
9.92
5.21E-02
12.32
6.47E-02
14-10-0400 R14, R18, R19 GL Process Area 1.93E-05 lb/T CaO 1991 Stack Testing. A factor of 1.9 is applied. 533 T CaO/day 1.95E-02 1.03E-04 2.43E-02 1.27E-04
14-15-0600
R09,R13,R10,
R12
Dregs Sources
2.58E-04
lb/T CaO
1991 Stack Testing
533
T CaO/day
1.37E-01
7.21E-04
1.71E-01
8.96E-04
14-30-0310
R46
Lime Mud Mix Tank
2.37E-04
lb/T CaO
NCASI Technical Bulletin No. 973, February 2010,
Table 4.32 Causticizing Area Sources -
Causticizer/Slaker Combination Emissions. A
multiplier of 2 is applied. Based on 1991 test data, an
H2S to MMC ratio of 0.32 was applied to the NCASI
MMC factor. Data points reported as non-detect
treated as zero.
533
T CaO/day
1.26E-01
6.63E-04
1.57E-01
8.23E-04
14-30-5040,
14-30-6040
R65, R66
East and West Lime Mud Vacuum
4.80E-05
lb/T CaO
NCASI Technical Bulletin No. 858, February 2003,
Table A-17 Precoat Filter Vacuum Pump Exhausts
Based on 1991 test data, an H2S to MMC ratio of
0.32 was applied to the NCASI MMC factor.
533
T CaO/day
2.56E-02
1.34E-04
3.17E-02
1.67E-04
10-25-0110
PO01C
No. 5 Recovery Boiler
7.72E+00
lb/hr
Emission Rate estimated using permit limit of 5 TRS
as H2S ppm @ 8%O2 and 2014 test flow scaled up to
max production. Ratio applied from NCASI TB 973
Table 4.23 to speciate TRS compounds. See
supporting file: "Limits ppm calcs 2016.xlsx"
24
hr/day
1.85E+02
9.73E-01
2.30E+02
1.21E+00
14-60-3000
R01A
No. 5 Lime Kiln
2.83E+00
lb/hr
Emission Rate estimated using permit limit of 8 TRS
as H2S ppm @ 10%O2 and 2014 test flow scaled up
to max production. Ratio applied from NCASI TB
973 Table 4.25 to speciate TRS compounds. See
supporting file: "Limits ppm calcs 2016.xlsx"
24
hr/day
67.92
3.57E-01
84.35
4.43E-01
64-25-0290
PO01A
No. 1 HFB NCG Combustion
1.58E-04
lb/ADTP
NCASI Technical Bulletin No. 973, February 2010,
Table 4.18 - Kraft NCG Thermal Oxidizers p. 76
2,426
ADTP/day
3.83E-01
2.01E-03
4.76E-01
2.50E-03
65-25-0310
PO13A-1
No. 2 HFB NCG Combustion
5.13E+00
lb/hr
Energy Savings and Sustainability Project Report,
February, 2006.
24
hr/day
123.12
6.46E-01
152.91
8.03E-01
Various mill
PO13A-2
Main HVLC Combined Header
6.87E-01
lb/hr
Engineering Testing Conducted in April 2014 and a
50% safety margin of compliance is conservatively
applied to entire mill header to account for temporal
and process fluctuations that impact volatilization
rates expected at the lignin plant.
24
hr/day
16.48
8.65E-02
20.47
1.07E-01
TABLE F-4
HYDROGEN SULFIDE EMISSION RATES
DOMTAR PAPER COMPANY,
PLYMOUTH, NC
Revised 8/1/2017
Attachment 2, Page 3
October 31, 2017 Air Permit Review T44
Emission
Source ID
Model ID
Source Description
Emission
Factor
Units
Reference
Activity
Factor
Units
Potential Emission Rate Optimized Emission
Rate
(lb/day) (g/s) (lb/day) (g/s)
09-27-3200
PO13A-3
LRP Secondary Filtrate Tank
2.48E+00
lb/hr
Testing Conducted in August/September 2014.
Controlled through the No. 2 HFB at 98%. A 50%
safety margin of compliance is conservatively applied
to entire mill header to account for temporal and
process fluctuations that impact volatilization rates
expected at the lignin plant.
24
hr/day
1.19
6.24E-03
1.48
7.75E-03
65-25-0310
PO13A
Total Through No. 2 HFB
140.79
7.39E-01
174.86
9.18E-01
09-10-0450
5SOAP
No. 5 Soap Storage Tank
3.87E-03
lb/hr
NCASI 973 Database 2013 - Recovery Black Liquor
Tank Weak </=20% Soilds
24
hr/day
9.29E-02
4.88E-04
1.15E-01
6.06E-04
09-10-0500
LIQSEP
New Liquor Separator Tank
3.87E-03
lb/hr
NCASI 973 Database 2013 - Recovery Black Liquor
Tank Weak </=20% Soilds
24
hr/day
9.29E-02
4.88E-04
1.15E-01
6.06E-04
09-05-0100
etc.
R24-26, R32,
R36, R39-R43
18% Liquor Mix Tanks
3.87E-03
lb/hr/tank
NCASI 973 Database 2013 - Recovery Black Liquor
Tank Weak </=20% Soilds, 6.5 multiplier for tank
movements
156.0
tank*hr/day
6.04E-01
3.17E-03
7.50E-01
3.94E-03
09-30-0010,
09-30-0020
R27-R28, R31,
R33, R34, R37,
R38, R44, R72
48% Liquor Storage Tanks, Soap Tanks
4.89E-02
lb/hr/tank
NCASI Technical Bulletin No. 973, February 2010,
Table 4.19 - Strong or Heavy Black Liquor Storage
Tanks p. 81.; 3.35 multiplier for tank movements
80.4
tank*hr/day
3.93
2.06E-02
4.88
2.56E-02
09-40-0010,
09-40-0020
R29, R30
65% Liquor Storage Tanks
4.89E-02
lb/hr/tank
NCASI Technical Bulletin No. 973, February 2010,
Table 4.19 - Strong or Heavy Black Liquor Storage
Tanks p. 81., 2 multiplier for tank movements
48.0
tank*hr/day
2.35
1.23E-02
2.92
1.53E-02
09-27-1000
LRP 40%
LRP 40% Black Liquor Tank
4.89E-02
lb/hr/tank
NCASI Technical Bulletin No. 973, February 2010,
Table 4.19 - Strong or Heavy Black Liquor Storage
Tanks p. 81.
24
hr/day
1.17E+00
6.16E-03
1.46E+00
7.65E-03
09-27-3100
LRP SCWT
LRP Secondary Cloth Wash Tank
1.16E-01
lb/hr
Testing Conducted in May 2016. Emissions increased
50% for compliance margin. (consistent with 2016
LSRP PSD Calcs)
24
hr/day
2.77
1.46E-02
3.44
1.81E-02
09-27-2100
LRPPRS1A,
LRPPRS1B
LRP Press Building (Primary and Secondary)
3.73E+00
lb/hr
Testing Conducted in May 2016. 85% through
stacks, 15% as fugitives. Emissions increased 50% for
compliance margin. (consistent with 2016 LSRP PSD
Calcs)
24
hr/day
89.54
4.70E-01
111.20
5.84E-01
09-27-3000
LRPPRS2
LRP Press Building Fugitives
6.76E-01
lb/hr
Testing Conducted in May 2016. 85% through
stacks, 20% as fugitives. Emissions increased 15% for
compliance margin. (consistent with 2016 LSRP PSD
Calcs)
24
hr/day
16.22
8.51E-02
20.14
1.06E-01
WWTP
FIBLIFT,
PUCHANN
Open Sewer
7.26E+00
lb/day
NCASI 2006 H2S Study - Converted to lb/day
1
unity
7.26
3.81E-02
9.01
4.73E-02
WWTP
SETPOND1
No. 1 Settling Pond
1.32E+04
lb/yr
2012 NCASI Emission Estimation Model and NCASI
2006 H2S study. Total Settling Pond emissions
ratioed by the total flow to each pond.
365
days/yr
36.05
1.89E-01
44.77
2.35E-01
TABLE F-4
HYDROGEN SULFIDE EMISSION RATES
DOMTAR PAPER COMPANY,
PLYMOUTH, NC
Revised 8/1/2017
Attachment 2, Page 4
October 31, 2017 Air Permit Review T44
Emission
Source ID
Model ID
Source Description
Emission
Factor
Units
Reference
Activity
Factor
Units
Potential Emission Rate Optimized Emission
Rate
(lb/day) (g/s) (lb/day) (g/s)
WWTP
SETPOND2
No. 2 Settling Pond
3.90E+03
lb/yr
2012 NCASI Emission Estimation Model and NCASI
2006 H2S study. Total Settling Pond emissions
ratioed by the total flow to each pond.
365
days/yr
10.68
5.61E-02
13.27
6.96E-02
WWTP
AIRBASIN
Aerated Stabilization Basin
1.82E+04
lb/yr
2012 NCASI Emission Estimation Model and NCASI
2006 H2S study.
365
days/yr
49.75
2.61E-01
61.79
3.24E-01
09-20-0250
R71
Combined Condensate Tank
2.05E-03
lb/hr
1998 Stack Testing; 3.76% increase due to sewering
of condensates from C3 and No. 6 Evaps 5th effect
(2013 Project)
24
hr/day
4.93E-02
2.59E-04
6.12E-02
3.21E-04
LRPSSUMP
LSRP Fugitives (LVHC Drain Loop and No. 1
Filtrate Sump)
1.22E-01
lb/hr
Testing Conducted in May 2016. Emissions
increased 50% for compliance margin. (consistent
with 2016 LSRP PSD Calcs)
24
hr/day
2.93E+00
1.54E-02
3.64E+00
1.91E-02
TABLE F-5
METHYL MERCAPTAN EMISSION RATES
DOMTAR PAPER COMPANY, PLYMOUTH, NC
Revised 8/1/2017
Attachment 2, Page 5
October 31, 2017 Air Permit Review T44
Emission Source
ID
Model ID
Source Description
Emission
Factor
Units
Reference
Activity
Factor
Units
Potential Emission Rate Optimized Emission
Rate
(lb/hr) (g/s) (lb/hr) (g/s)
06-31-0180
F09, F12, F13,
F14, F17, F18,
F19, F41
No. 6 O2 Delig
8.10E-07
lb/ODTP
July 1995 Stack Testing
35.5
ODTP/hr
2.88E-05
3.62E-06
3.84E-05
4.84E-06
06-40-8000
F15, F16
No. 6 Bleach Plant
Scrubber
1.82E-03
lb/ODTP
NCASI 2013 Pulp & Paper Database (Median Values for ECF
Bleach Plant Scrubber) (Emission Factor given in lb/ADTUBP
