AIR EMISSION PERMIT NO IS ISSUED TO. Potlatch Corporation. Potlatch Corporation - Cloquet PO Box 503 Cloquet, Carlton County, MN 55720

Transcription

1 AIR EMISSION PERMIT NO IS ISSUED TO Potlatch Corporation PO Box 503 Cloquet, Carlton County, MN The emission units, control equipment and emission stacks at the stationary source authorized in this permit are as described in the following permit application(s): Permit Type Application Date Total Facility Operating Permit April 1995 Issued September 25, 1998 Major Amendment February 1999 Administrative Amendments March 27, 2000 and April 13, 2000 This permit authorizes the permittee to the stationary source at the address listed above unless otherwise noted in Table A. The permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Permit Type: Federal; PSD/NSR Issue Date For This Amendment: April 28, 2000 Expiration: The Part 70 permit expires on September 25, 2003 All Title I Conditions do not expire. Rodney E. Massey, P.E. Director North/South District for Karen A. Studders Commissioner Minnesota Pollution Control Agency

2 TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Table C: Submittals Compliance Schedule (not used in this permit) Appendices: Attached and Referenced in Table A

3 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area (651) Outside Metro Area TTY (651) The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Certain requirements which have been determined not to apply are listed in Table A of this permit.

4 FACILITY DESCRIPTION: The facility is an existing pulp and paper mill; the facility uses the Kraft process to make pulp from wood chips. The pulp is bleached and made into coated paper. Currently the mill operates four boilers, including a chemical recovery. An expansion has been underway at the facility for several years. Other sources of air emissions, besides the boilers, include sources in the chemical recovery system. This includes a smelt dissolving tank and the lime calciner; the lime calciner will be replaced by a lime kiln as part of the expansion. The bleach plant also has emission sources; these include the chlorine dioxide plant and two existing bleach lines. A new bleach plant will be installed as part of the expansion project. The existing bleach plant will be shutdown. These sources are primarily sources of chlorine dioxide and chloroform emissions; the bleaching system is also a source of Carbon Monoxide (CO) and Volatile Organic Compound (VOC) emissions. The paper machines are also not significant sources of criteria pollutants, except for VOCs, and do emit Hazardous Air Pollutants (HAPs). Sources of particulate emissions, besides the boilers and chemical recovery sources, include the fuel house and fuel reclaim buildings as well as fugitive sources such as woodpiles and roadways. This permit action addresses two administrative amendment applications which request extensions to the performance testing deadlines for a number of pollutants from four different emission units at the facility. For more detail, see the Technical Support Document for this permit.

5 Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do Why to do it Plans and Specifications: This is the Ambient TRS Plan. This is a state only Minn. R , subp. 2 requirement and is not federally enforceable or enforceable by citizens under the Act. This was submitted after Permit Issuance. Ambient TRS Plan: The Ambient TRS Plan shall describe the steps to be taken to Minn. R , subp. 2 maintain the ambient air TRS target. The Ambient TRS Plan is due 90 days after permit issuance. The ambient air TRS target is described in the Technical Support Document for Air Emission Permit The Plan shall include a description of the location of the TRS monitors and the quality assurance requirements for the monitors and their data. Also to be included are steps that the Permittee will follow if the ambient air TRS target is exceeded, if the exceedance is attributable to Potlatch. This will include the investigative steps and the timelines for reporting the corrective actions that the Permittee will take to meet the ambient air TRS target. Upon approval by the Division Manager, the Ambient TRS Plan shall be an enforceable part of the permit. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. Cease Operation: due 730 days after Initial Startup of EU 080 (Pulp machine), the Minn. R , subp. 2 Permittee shall cease operation of the ambient TRS monitors. MPCA reserves the right to extend the time for operation of the TRS monitors if the Permittee has not achieved the TRS target levels for a minimum of two years. The MPCA may also require the startup of the monitors after they have been shut down if there is reason to believe that the ambient TRS targets are no longer being achieved. The Permittee shall continue to abide by the Ambient TRS Plan, except for those provisions related to operation and maintenance of the TRS monitors, after the monitors have been shut off. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. Operation and Maintenance Plan: This Plan was submitted after Permit Issuance. Minn. R , subp. 2 Operation and Maintenance Plan: The O&M Plan shall include information for the following control equipment: CE003, CE006, CE007, CE010, CE011, CE017-CE019, and the IQS (EU081). The Plan is due 90 days after permit issuance; a description of what the Plan should include is given below. The Division Manager may require additions or changes to the O&M Plan when granting approval. The Permittee will be given an opportunity to comment on any required changes to the Plan before granted approval of the Plan. The Plan may be amended with the Division Manager's written approval. Upon approval, the Plan shall be an enforceable part of the permit and the Permittee shall comply with all parts of the Plan. Operation and Maintenance Plan: The O&M Plan shall include, for each pollution control equipment listed above: the parameters to be monitored and the parameter ranges to be used; corrective action procedures to be followed to return the control equipment to within specified range(s); corrective action procedures to be followed in the event of a malfunction or breakdown; a description of inspection procedures to be followed; and records kept to demonstrate plan implementation. Notification of Initial Startup of Control Equipment: Notification of initial startup of the control equipment shall be due within 180 days after startup of that control equipment. The notifications shall be made after startup of CE019 and the scrubber for the IQS (EU 081). The notification shall include information which will be used to amend the O&M Plan and shall include the monitored parameter ranges to be used for the control equipment. The Division Manager may require additions or changes to the O&M Plan when granting approval. The Permittee will be given an opportunity to comment on any required additions or changes to the Plan before the Division Manager grants approval of the Plan. Upon approval of the Plan, it shall become an enforceable part of the permit. Initial Startup of the Monitor: due 60 days after Initial Startup of EU 080 (pulp machine). Ambient monitors for PM10 and SO2 shall be placed at locations approved by the Division Manager. Operation of the monitors shall continue for a minimum period of two years after the expansion is completed. (Completion of expansion is defined as initial startup of the pulp machine, EU 080.) Inspection and Maintenance: Inspect the fencing and gates established for access control once per year. All repairs and maintenance to the fence and gates shall be completed as soon as possible but no later than 30 days after the Permittee observes the need for repair or maintenance or after the MPCA notifies the Permittee of the need for repair or maintenance. Minn. R , subp. 2 Minn. R , subp. 2 Minn. R , subp. 2 Title I Condition: 40 CFR Section 52.21(m)(2) (post-construction monitoring); Title I Condition: Inspection to maintain fence established to set property boundaries established in modeling (40 CFR 52.21(k)); A-1

6 Access Control: All gates installed at access points shall be kept closed unless: 1) A guard is present controlling access at a gate; or 2) Authorized persons are entering or leaving the property through a gate. Noise: The Permittee shall comply with the noise standards. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. Post-Construction Noise Monitoring Plan: The Post-Construction Noise Monitoring Plan shall be submitted within 90 days after initial startup of EU 080 (pulp machine). The Permittee shall perform noise monitoring to demonstrate compliance with the MPCA noise standards. The Plan shall specify how, when and at what locations the monitoring will be conducted. The Plan shall be submitted to the MPCA for approval and once approved, the Plan shall be considered an enforceable part of the permit. Further monitoring shall not be required if the monitoring shows the facility to be in compliance with the noise standards or as approved by the Division Manager. This is a state only requirement and is not federally enforceable or enforceable by citizens under the Act. Title I Condition: Establish property boundaries as used in modeling (40 CFR 52.21(k)); Minn. R Minn. R , subp. 2; Minn. R Fugitive Control Plan: This Plan was submitted after Permit Issuance. Title I Condition: 40 CFR Section 52.21; ; Minn. R ; Minn. R , subp. 2 Fugitive Control Plan: The Permittee shall implement the Fugitive Control Plan, which is due 90 days after permit issuance. The Plan shall describe methods that the Permittee will use to control fugitive emissions from the property, including from paved and unpaved roads and from the Potlatch Industrial Solid Waste landfill. Upon approval by the MPCA, the Plan shall be an enforceable part of the permit. Visual Inspection Training: The Permittee shall provide annual training to its employees that are directly involved in the loading operations for the coating department and pulp mill lime silos and ash silo. The training shall include instructions on procedures for making visual inspections of the silos, including transport lines. The person making the inspection shall be trained to look for accumulation of dust or particulate matter, as well as excess emissions or high opacity from the loading operations. The employees shall be trained on procedures to be followed if there are any problems observed from such things as line ruptures or spills which may result in dust accumulations or high opacity. The Permittee shall retain records of the training given. Stack Parameters Relied Upon in Modeling: The stack heights and other parameters relied upon in the modeling performed for the PSD permit amendment #5 issued in 1995 are listed in a Table in Appendix B of this permit. The Permittee must submit to the Division Manager for approval any revisions of these parameters. The stack information submitted must include, at a minimum, the location and height of the stacks, nearby building dimensions, and the velocity and temperature of the gases emitted. The plume dispersion characteristics due to the revisions of the stack information must be equivalent to or better than the dispersion characteristics modeled by ENSR as submitted by letter from ENSR to Potlatch on September 25, The Permittee shall demonstrate this equivalency in the proposal. This proposal must be submitted no later than 90 days before beginning actual construction of the stack or associated emission unit. Title I Condition: 40 CFR Section 52.21; ; Minn. R ; Minn. R , subp. 2 Minn. R , subp. 2 Title I Condition: 40 CFR Section 52.21(k); : This Plan was submitted after Permit Issuance. Minn. R , subp. 2 Performance Test Methods Plan: The Performance Test Methods Plan is due 90 days after Permit Issuance. The Permittee requested that this requirement be added to the permit. The Plan shall specify the emission unit, pollutant, and test method for each pollutant limit for which a performance test or COMS or CEMS certification test is required. Upon approval by the Division Manager, the Performance Test Methods Plan shall be an enforceable part of the permit. The Plan may be amended by the Permittee with the Division Manager's written approval. The Division Manager may also amend the Plan following notification to the Permittee of the intent to change the Plan and allowing 120 days from the date of notification to the Permittee to allow time for the Permittee to evaluate the changes in test methods and to respond in writing to the Division Manager, if necessary. List of Insignificant Activities Required to be Listed: Appendix C includes activities and sources at the facility that have been determined to be insignificant activities under Minn. R This list does not include every insignificant activity and is subject to change. Recordkeeping: For each storage vessel as specified in 40 CFR section b(b) or (c), the Permittee shall keep readily accessible records showing the dimension of the storage vessel and an analysis showing the capacity of the storage vessel. These records will be kept for the life of the source. MACT REQUIREMENTS - SUBPART S Minn. R , subp. 2 Minn. R , subp. 2; Minn. R CFR Section b(a) and (b) hdr A-2

7 MACT Requirements: This facility is subject to all pertinent requirements of the MACT, 40 CFR pt. 63, subp. S (National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry). This permit contains many of the applicable requirements from 40 CFR part 63, Subparts A and S. Some of the requirements may be paraphrased in this permit. If there is a conflict between a permit term and the regulation, then the regulation takes precedence. Initial Compliance Status Report: This report has been submitted on-time; it was due by 4/15/99. This report shall serve as the initial notification report specified under 40 CFR Section 63.9(b)(2). A non-binding control strategy report shall be submitted with the initial notification report and shall be prepared in accordance with 40 CFR Section (b). Condensate MACT Schedule: The Condensate MACT Schedule shall be due by April 1, The Schedule shall describe the Permittee's proposed schedule for controlling, collecting and/or treating emissions from the Kraft pulping process condensate emission units. The schedule shall include the schedule for implementing the monitoring, recordkeeping and reporting requirements which are to be followed as well as a schedule for obtaining a permit amendment to incorporate the proposed changes. Compliance Dates for Enclosures and Closed-Vent Systems: Compliance for the requirements in 40 CFR Section and described below (i.e. the standards for enclosures and closed-vent systems) shall be achieved by the date for the applicable system. The compliance date for the LVHC system, pulping condensates and bleach plant is April 16, 2001; the compliance date for the HVLC system is April 17, Standards for Enclosures and Closed-vent Systems: Each enclosure shall maintain negative pressure at each enclosure or hood opening as demonstrated by procedures specified in 40 CFR Section (e). Each enclosure or hood opening closed during the initial performance test specified in 40 CFR Section (a) shall be maintained in the same closed and sealed position as during the performance test at all times except when necessary to use the opening for sampling, inspection, maintenance, or repairs. Each component of the closed-vent system used to comply with 40 CFR Section (c) and (b) that is operated at positive pressure and located prior to a control device shall be designed for and operated with no detectable leaks as indicated by an instrument reading of less than 500 ppm by volume above background, as measured by the procedures in 40 CFR Section (d). Each bypass line in the closed-vent system that could divert vent streams containing HAP to the atmosphere without meeting the emission limitations in 40 CFR Section or shall comply with either of the following requirements: 1) On each bypass line, the owner or operator shall install, calibrate, maintain and operate according to manufacturer's specifications, a flow indicator that provides a record of the presence of gas stream flow in the bypass line at least once every 15 minutes. The flow indicator shall be installed in the bypass line in such a way as to indicate flow in the bypass line; or 2) For bypass line valves that are not computer controlled, the owner or operator shall maintain the bypass line valve in the closed position with a car seal or a seal placed on the valve or closure mechanism in such a way that the valve or closure mechanism cannot be opened without breaking the seal. Monitoring Requirements for Enclosure and Closed-vent Systems: 1) For each enclosure opening, a visual inspection of the closure mechanism specified in 40 CFR Section (b) shall be performed at least once every 30 days to ensure the opening is maintained in the closed position and sealed. 2) Each closed-vent system required by 40 CFR Section (a) shall be visually inspected every 30 days and at other times as required by the Administrator. The visual inspection shall include inspection of ductwork, piping, enclosures and connections to covers for visible evidence of defects. 3) For positive pressure closed-vent systems or portions of closed-vent systems, demonstrate no detectable leaks as specified in 40 CFR Section (c) measured initially and annually by the procedures in 40 CFR Section (d). 4) Demonstrate initially and annually that each enclosure opening is maintained at negative pressure as specified in 40 CFR Section (e). 40 CFR pt. 63, subp. S 40 CFR Section (a) Minn. R , subp CFR Section CFR Section (b) 40 CFR Section (b) CONTINUED 40 CFR Section (k) A-3

8 5) The valve or closure mechanism specified in 40 CFR Section (d)(2) shall be inspected at least once every 30 days to ensure that the valve is maintained in the closed position and the emission point gas stream is not diverted through the bypass line. 6) If an inspection required by paragraphs 1 through 5 of this section identified visible defects in ductwork, piping or enclosure or connections to covers required by 40 CFR Section , or if an instrument reading of 500 ppm by volume or greater above background is measured, or if enclosure openings are not maintained at negative pressure, then the following corrective actions shall be taken as soon as practicable: (i) A first effort to repair or correct the closed-vent system shall be made as soon as practicable but no later than 5 calendar days after the problem is identified. (ii) The repair or corrective action shall be completed no later than 15 calendar days after the problem is identified. Site-Specific Inspection Plan: The Permittee shall prepare and maintain a site-specific inspection plan for each applicable enclosure opening, closed-vent system, and closed collection system. The Plan shall include a drawing or schematic of the components of applicable affected equipment. The Permittee shall record the information described in 40 CFR Section (b) for each inspection. MACT REQUIREMENTS - GENERAL PROVISIONS At all times the Permittee shall operate and maintain the emission unit subject to the MACT standard and its associated air pollution control equipment in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards. Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the startup, shutdown, and malfunction plan. The Permittee shall prepare and implement a Startup, Shutdown, and Malfunction Plan (SSMP) for each of the emission units subject to Maximum Control Technology Standards by the applicable MACT standard compliance date. The SSMP must be located at the plant site and must be kept updated. When the SSMP is updated, the Permittee must keep all previous versions of the SSMP for a period of 5 years. The Permittee must submit the SSMP when required. During periods of startup, shutdown, and malfunction, the Permittee shall operate and maintain the source in accordance with the procedures specified in the startup, shutdown, and malfunction plan. A written SSMP must contain the minimum of the following information: 1. A procedure that documents how any startup, shutdown, or malfunction event that has occurred will be addressed and documented; 2. Information regarding the operation of the source and its associated pollution control devices during a startup, shutdown, or malfunction event in a manner consistent with good air pollution control practices for minimizing emissions at least to the levels required by all relevant standards; and 3. Adequate procedures for correcting malfunctioning process and/or air pollution control equipment as quickly as practicable. The Permittee shall maintain files of all information required by this part in a form suitable and readily available for expeditious inspection and review. The files should be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. Only the most recent two years of information must be kept on site. The Permittee shall maintain, at a minimum, the following information in the files: 1) the occurrence and duration of each startup, shutdown, or malfunction of operation; 2) the occurrence and duration of each malfunction of the air pollution control equipment; 3) all maintenance performed on the pollution control equipment; 4) actions taken during periods of startup, shutdown, and malfunction when such actions are different from the procedures specified in the affected source's startup, shutdown, and malfunction plan (SSMP). In this case, the Permittee shall report this action within 2 days of occurrence and follow by a written notification within 7 days of occurrence. 5) all information necessary to demonstrate conformance with the affected source's SSMP and actions taken in accordance with SSMP; 40 CFR Section (k) CONTINUED 40 CFR Section (b) hdr 40 CFR Section 60.6(e)(1)(i) 40 CFR Section 60.6(e)(1)(ii) 40 CFR Section 63.6(e)(3)(i); 40 CFR Section 63.6(e)(3)(v) 40 CFR Section 60.6(e)(3)(ii); 40 CFR Section 63.6(e)(3)(iii) 40 CFR Section 63.6(e)(3)(vii) 40 CFR Section 63.10(b)(1) 40 CFR Section 63.10(b)(2) A-4

9 6) each period during which a continuous monitoring system (CMS) is malfunctioning or inoperative; 7) all required measurements needed to demonstrate compliance with a relevant standard; 8) all results of performance test, CMS performance evaluations, and opacity and visible emission observations; 9) all measurements as may be necessary to determine the conditions of performance tests and performance evaluations; 10) all CMS calibration checks; 11) all adjustments and maintenance performed on CMS; 12) any information demonstrating whether a source is meeting the requirements for a waiver of record keeping or reporting requirements under this part; 13) all documents supporting initial notifications and notifications of compliance status. Startup, shutdown, and malfunction reports shall be submitted only if there is an occurrence of startup, shutdown, or malfunction during the reporting period and shall be delivered or postmarked by the 30th day following the end of each calendar half year. If the Permittee deviates from the startup, shutdown, and malfunction plan (SSMP) the Permittee shall record the actions taken for that event and report such actions within 2 working days after commencing actions inconsistent with the plan, followed by a letter within 7 working days after the end of the event. The report must contain name, title, and signature of a responsible official who is certifying its accuracy, explaining the circumstances of the event, the reasons for not following the SSMP, and whether any excess emissions and/or parameter monitoring exceedances are believed to have occurred. Prior to construction or reconstruction of an "affected source" under the promulgated MACT standards, the Permittee must apply for and obtain an air emission permit. GENERAL TOTAL FACILITY REQUIREMENTS COMS and CEMS Continuous Operation: Except for system breakdowns, repairs, calibration checks, zero and span adjustments, and periods when the monitored source is not in operation, all COMS and CEMS shall be in continuous operation. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Breakdowns: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Shutdowns: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner again when the shutdown is over. Monitoring Equipment: Install or make needed repairs to monitoring equipment for existing control equipment within 90 days of issuance of the permit if monitoring equipment is not installed and operational on the date the permit is issued. After installation of new control equipment, the associated monitoring equipment must be installed upon achieving maximum production rate for the subject emission unit but no later than 60 days after initial startup of the emission unit. Operation of Monitoring Equipment: Unless otherwise noted in Tables A, B, and/or C, monitoring a process or control equipment connected to that process is not necessary during periods when the process is not in operation, shutdown, such as for system breakdowns, repairs, calibration checks, and zero and span adjustments (as applicable). Monitoring records should reflect any such periods of process shutdown. 40 CFR Section 63.10(b)(2) 40 CFR Section 63.10(d)(5)(i) 40 CFR Section 63.6(e)(3)(iv); 40 CFR Section 63.10(d)(5)(ii) 40 CFR Section 63.5(b)(3) hdr Minn. R , subp. 4; Minn. R , subp. 2 Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R , subp. 2 Minn. R , subp. 3 Minn. R , subp. 4(D) Minn. R , subp. 4(D) A-5

10 Operating and/or production limits may be placed on emission units based on Minn. R operating conditions during compliance testing in accordance with Minn. R Limits set as a result of a compliance test (conducted before or after permit issuance) apply until new operating/production limits are set following formal review of a performance test as specified by Minn. R Circumvention: Do not install or use a device or means that conceals or dilutes Minn. R emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Notification of Deviations Endangering Human Health or the Environment: In the Minn. R , subp.1 event of any deviation, as defined in Minn. R , subp. 8a, which could endanger human health or the environment, the owner or operator shall notify, orally or in writing, the Commissioner as soon as possible after discovery of the deviation. Written Notification of Deviations Endangering Human Health or the Environment Minn. R , subp. 1 Report: Within 2 working days of discovery, the owner or operator shall submit to the Commissioner a written description of the deviation stating: A. the cause of the deviation; B. the exact dates of the period of the devation, if the deviation has been corrected; C. whether or not the deviation has been corrected; D. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and E. steps taken or planned to reduce, eliminate and prevent reoccurrence of the deviation. Application for Permit Amendment: If a permit amendment is needed, submit an Minn. R through Minn. R application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Emission Fees: due 60 days after receipt of an MPCA bill Minn. R through Minn. R Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. No person shall cause or permit a building or its appurtenances or a road, or a driveway, or an open area to be constructed, used, repaired, or demolished without applying all such reasonable measures as may be required to prevent particulate matter from becoming airborne. All persons shall take reasonable precautions to prevent the discharge of visible fugitive dust emissions beyond the lot line of the property on which the emissions originate. The commissioner may require such reasonable measures as may be necessary to prevent particulate matter from becoming airborne including, but not limited to, paving or frequent clearing of roads, driveways, and parking lots; application of dust-free surfaces; application of water; and the planting and maintenance of vegetative ground cover. Inspections: Upon presentation of credentials and other documents as may be required by law, allow the Agency, or its representative, to enter the Permittee's premises, to have access to and copy any records required by this permit, to inspect at reasonable times (which include any time the source is operating) any facilities, equipment, practices or operations, and to sample or monitor any substances or parameters at any location. Record keeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R , subp. 2), including records of the emissions resulting from those changes. The records are to be maintained for a period of at least five (5) years. Record keeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original strip-chart recordings for continuous monitoring instrumentation, records of all COMS and CEMS monitoring data and support information, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). For those units subject to NSPS, records and record keeping must conform to the requirements listed in 40 CFR Section 60.7(b) and (f). Extension Requests: The permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). The Permittee shall comply with the General Condtions listed in Minn. R , subp. 16. Minn. R Minn. R , subp. 9(A) Minn. R , subp. 5(B) Minn. R , subp. 5(C) Minn. R , subp. 1(H) Minn. R , subp. 16 A-6

11 Risk Management Plan: The Permittee is not required to submit a Risk Management Plan under regulations which are to be promulgated by the Administrator at 40 CFR Section 68, subp. B; no regulated substances are present above the threshold quantity. These regulations will require each owner or operator of a stationary source, at which a regulated substance is present above a threshold quantity in a process, to design and implement an accidental release prevention program. Program elements are to be summarized in a publicly available Risk Management Plan which will be registered with the Administrator and submitted to state and local authorities. These requirements must be complied with no later than the latest of the following dates: (1) June 21, 1999; (2) Three years after the date on which a regulated substance is first listed under 40 CFR Section ; or (3) The date on which a regulated substance is first present above a threshold quantity in a process. 40 CFR Section 68 A-7

12 Subject Item: GP 003 LVHC NCG sources Associated Items: CE 020 Boiler #7 CE 021 Boiler #9 EU 034 Digester Relief EU 035 Turpentine System EU 041 Existing Evaporator Vacuum SV 002 SV 003 SV 005 MACT REQUIREMENTS What to do hdr Why to do it Compliance Date for MACT Requirements: Compliance with the requirements from the MACT standard for the LVHC system shall be achieved by April 16, HAP Control: Gases from the LVHC system shall be combusted in the IQS (EU 081), or boiler #7 or #9 as backup. The IQS shall be designed and operated at a minimum temperature of 1600 degrees Fahrenheit and a minimum residence time of 0.75 seconds. When the gases are burned in the backup (boilers #7 or #9), the HAP emission stream shall be introduced with the primary fuel or into the flame zone. The temperature will be monitored as described under Subject Item EU 081 (IQS). Enclosures and Venting: All equipment listed in this group shall be enclosed and vented into a closed-vent system meeting the requirements specified in 40 CFR Section and as described in the Total Facility subject item. OTHER REQUIREMENTS TRS Control: Gases from the NCG sources shall be combusted in the IQS (EU 081), or power boilers #7 and #9 as backup, and shall be subjected to a minimum temperature of 1200 degrees Fahrenheit for at least 0.5 second. The Permittee is not subject to 40 CFR Section (b)(1) or 40 CFR Section (d)(3)(ii) and is protected by the permit shield provision of Minn. R from any expectation to comply with these requirements. 40 CFR (d) 40 CFR Section (a)(i); 40 CFR Section d(3)&(4) 40 CFR SEction (c) hdr 40 CFR Section (a)(1)(iii); Minn. R ; Minn. R , subp. 2 Minn. R , subp. (A)(2); 40 CFR Section (b)(1); Minn. R The requirement to continuously monitor and record the combustion temperature in the power boilers does not apply since #7 and #9 power boilers (EU002 and EU004) used to combust the NCG gases are not incinerators, because according to the fourth revision to NSPS Subpart BB, "[EPA] deletes the requirement to monitor the combustion (51 FR 18538) temperature in lime kilns, power boilers, or recovery furnaces." In addition, since continuous monitoring is not required, the facility is not required to submit semi-annual excess emissions reports to EPA for periods in excess of 5 minutes and their duration which the combustion temperature at the point of incineration is less than 1200 degrees Fahrenheit. A-8

13 Subject Item: GP 004 HVLC NCG Sources Associated Items: CE 020 Boiler #7 CE 021 Boiler #9 EU 018 Oxygen Delignification Blow Tank EU 043 Brownstock Washers EU 044 Brownstock Tanks EU 045 Black Liquor Tanks (Digesters) EU 046 Black Liquor Tanks (Washers) EU 047 Heavy Black Liquor Tanks EU 048 Digester Air Evacuation EU 052 #10 Recovery Boiler Salt-Cake Mix Tank SV 002 SV 003 SV 005 MACT REQUIREMENTS What to do hdr Why to do it Compliance Date for MACT Requirements: Compliance with the requirements from the MACT standard for the HCLC system shall be achieved as expeditiously as possible but in no event later than April 17, HAP Control: Gases from the HVLC system shall be combusted in the IQS (EU 081), or boiler #7 or #9 as backup. The IQS shall be designed and operated at a minimum temperature of 1600 degrees Fahrenheit and a minimum residence time of 0.75 seconds. When the gases are burned in the backup (boilers #7 or #9), the HAP emission stream shall be introduced with the primary fuel or into the flame zone. Enclosures and Venting: All equipment listed in this group shall be enclosed and vented into a closed-vent system meeting the requirements specified in 40 CFR Section and as described in the Total Facility subject item. OTHER REQUIREMENTS TRS Control: Gases from the NCG sources shall be combusted in the IQS (EU 081), or power boilers #7 and #9 as backup, and shall be subjected to a minimum temperature of 1200 degrees Fahrenheit for at least 0.5 second. (Note: EU047 is not subject to the NSPS standard.) The Permittee is not subject to 40 CFR Section (b)(1) or 40 CFR Section (d)(3)(ii) and is protected by the permit shield provision of Minn. R from any expectation to comply with these requirements. 40 CFR (d) 40 CFR Section (a)(i); 40 CFR Section d(3)&(4) 40 CFR SEction (c) hdr 40 CFR Section (a)(1)(iii); Minn. R ; Minn. R , subp. 2 Minn. R , subp. (A)(2); 40 CFR Section (b)(1); Minn. R The requirement to continuously monitor and record the combustion temperature in the power boilers does not apply since #7 and #9 power boilers (EU002 and EU004) used to combust the NCG gases are not incinerators, because according to the fourth revision to NSPS Subpart BB, "[EPA] deletes the requirement to monitor the combustion (51 FR 18538) temperature in lime kilns, power boilers, or recovery furnaces." In addition, since continuous monitoring is not required, the facility is not required to submit semi-annual excess emissions reports to EPA for periods in excess of 5 minutes and their duration which the combustion temperature at the point of incineration is less than 1200 degrees Fahrenheit. A-9

14 Subject Item: Associated Items: GP 005 Stripper Off Gas NCG System EU 036 Condensate Stripper MACT REQUIREMENTS What to do hdr Why to do it Compliance Date for MACT Requirements: Compliance with the requirements from the MACT standard for the stripper off gas NCG system shall be achieved by April 16, HAP Control: Gases from the stripper off gas NCG system shall be combusted in the IQS (EU 081), or boiler #7 or #9 as backup. The IQS shall be designed and operated at a minimum temperature of 1600 degrees Fahrenheit and a minimum residence time of 0.75 seconds. When the gases are burned in the backup (boilers #7 or #9), the HAP emission stream shall be introduced with the primary fuel or into the flame zone. Enclosures and Venting: All equipment listed in this group shall be enclosed and vented into a closed-vent system meeting the requirements specified in 40 CFR Section and as described in the Total Facility subject item. OTHER REQUIREMENTS TRS Control: Gases from the NCG sources shall be combusted in the IQS (EU 081), or power boilers #7 and #9 as backup, and shall be subjected to a minimum temperature of 1200 degrees Fahrenheit for at least 0.5 second. The Permittee is not subject to 40 CFR Section (b)(1) or 40 CFR Section (d)(3)(ii) and is protected by the permit shield provision of Minn. R from any expectation to comply with these requirements. 40 CFR (d) 40 CFR Section (a)(i); 40 CFR Section d(3)&(4) 40 CFR SEction (c) hdr 40 CFR Section (a)(1)(iii); Minn. R Minn. R , subp. (A)(2); 40 CFR Section (b)(1); Minn. R The requirement to continuously monitor and record the combustion temperature in the power boilers does not apply since #7 and #9 power boilers (EU002 and EU004) used to combust the NCG gases are not incinerators, because according to the fourth revision to NSPS Subpart BB, "[EPA] deletes the requirement to monitor the combustion (51 FR 18538) temperature in lime kilns, power boilers, or recovery furnaces." In addition, since continuous monitoring is not required, the facility is not required to submit semi-annual excess emissions reports to EPA for periods in excess of 5 minutes and their duration which the combustion temperature at the point of incineration is less than 1200 degrees Fahrenheit. A-10

15 Subject Item: Associated Items: GP 008 Fuel limits: #7, #8 and #9 boilers EU 002 Power Boiler #7 (Spreader Stoker - Coal/Bark) EU 004 Power Boiler #9 (Tang. Fired Pulverized Coal) EU 037 Power Boiler #8 What to do NOTE: All requirements under this subject item apply to EU 002 and EU 004 (Power Boilers #7 and #9) only, unless otherwise noted in the requirement. Fuel burned: limited to following fuel types: coal; wood (including chipped railroad ties); mill waste (including knots and screen rejects, CDF (combustible derived fuel, which consists of nonrecyclable office paper, cardboard, scrap pallets, scrap lumber, press trials prints, waste wet lap pulp or other non-food product wood-based wastes generated at the Potlatch Cloquet and Brainerd mills), and bark, peat and/or sawdust used to clean up oil and chemical spills); fuel oil; natural gas; and wastewater treatment plant sludge. Non-condensible gas (NCG) is also burned in power boilers #7 and #9. Cease Operation: due 180 days after Initial Startup of IQS (EU 081). Burning of coal and #6 fuel oil shall cease within 180 days of startup of the IQS. Fuel Usage: less than or equal to 500,000 tons/year using 12-month Rolling Sum, on a wet basis (WOOD AND MILL WASTE USAGE LIMIT). This limit applies after startup of pulp machine (EU080). The wood and mill waste usage limit includes railroad ties, knots and screen rejects and bark, peat and/or sawdust used to soak up oil and chemical spills. Fuel Usage: less than or equal to 502 tons/day for #7 power boiler (EU002) and 1030 tons/day for #9 power boiler (EU004) as a 24-hr block average (RAILROAD TIE USAGE LIMIT). Fuel Usage: less than or equal to 410,000 gallons/year using 12-month Rolling Sum (#2 and #6 COMBINED FUEL OIL USAGE LIMIT). This limit applies after startup of pulp machine (EU 080). After #6 fuel oil is eliminated, the limit for #2 fuel oil is 4,000,000 gallons/year for a combined basis for #7, #8, and #9 boilers (EU 002, EU 037, EU004) on a 12-month rolling sum basis. Sulfur Content of Fuel: less than or equal to 0.7 percent by weight for the mixture of #2 and #6 fuel oil. This limit applies after startup of pulp machine (EU080) until superseded by limit below. Sulfur Content of Fuel: less than or equal to 0.05 percent by weight for #2 fuel oil. This limit applies within 180 days of startup of IQS (EU 081). Fuel Usage: less than or equal to 1667 tons/month using 12-month Rolling Average (COAL USAGE LIMIT). This limit applies after startup of pulp machine (EU 080). Use of this fuel will be discontinued within 180 days of startup of the IQS. Sulfur Content of Fuel: less than or equal to 0.8 percent by weight for coal. This limit applies after startup of Pulp Machine (EU 080). Fuel Usage: less than or equal to 38,220 tons/year using 12-month Rolling Sum on a wet basis (WASTEWATER TREATMENT PLANT SLUDGE USAGE LIMIT). This limit applies after startup of pulp machine (EU 080). Vendor Certifications: For all fuel oil and coal burned in EU002 (power boiler #7) and EU004 (power boiler #9), maintain oil and coal vendor information on site that documents oil and coal sulfur content in percent by weight, to verify that the fuel oil sulfur content limit of 0.7% by weight (0.05% by weight after #6 fuel oil is eliminated) and coal sulfur content limit of 0.8% by weight are being met. Copies of the sulfur content certification or analysis shall be obtained from the vendor for each delivery of fuel oil and coal and must give the sulfur content of the fuel oil or coal. This information shall be maintained on site. This requirement applies after startup of pulp machine (EU 080). hdr Why to do it Title I Condition: 40 CFR 52.21(netting, modeling); Limit to reflect conditions set in netting calculations, and in modeling; Title I Condition: Limit as part of Pollution Control Project, to avoid classification as modification under 40 CFR Title I Condition: 40 CFR Section 52.21(k); Limit to reflect conditions set in netting calculations, and in modeling; Title I Condition: 40 CFR Section 52.21; Limit set to reflect usage limit in performance test. Title I Condition: 40 CFR Section 52.21(k); Limit to reflect conditions set in netting calculations, and in modeling; Title I Condition: 40 CFR Section 52.21(k); Limit to reflect conditions set in netting calculations, and in modeling; Title I Condition: Limit as part of Pollution Control Project, to avoid classification as modification under 40 CFR Title I Condition: 40 CFR Section 52.21(k); Limit to reflect conditions set in netting calculations, and in modeling; Title I Condition: 40 CFR Section 52.21(k); Limit to reflect conditions set in netting calculations, and in modeling; Title I Condition: 40 CFR Section 52.21(k); Title I Condition: Certification associated with fuel oil and coal sulfur limits taken for modeling purposes (40 CFR Section 52.21); A-11

16 Recordkeeping: Monthly wood and mill waste (including railroad ties, knots and screen rejects, bark, peat, and/or sawdust used to soak up oil and chemical spills) usage and monthly calculation of 12-month rolling sum, by the 15th of the following month. This requirement applies after startup of pulp machine (EU080). For the first 12 months of operation after startup of pulp machine (EU080), monthly determination of the 12-month rolling sum limit for wood and mill waste usage shall be determined based on the following: Month 1: WU < 500,000; Month 2-12: WU(month n) < 500,000 - sum[wu(actual)]; where: WU is the wood and mill waste usage limit, in tons/year; sum[wu(actual)] is the sum of WU for all months previous to month n; month n is the month for which the limit is being calculated. The limit is being met when the formula is true for month n. Recordkeeping: Monthly fuel oil usage and monthly calculation of 12-month rolling sum, by the 15th of the following month. This requirement applies after startup of pulp machine (EU080). For the first 12 months of operation after startup of pulp machine (EU080), monthly determination of the 12-month rolling sum limit for fuel oil usage shall be determined based on the following: Month 1: FOU < 410,000; Month 2-12: FOU(month n) < 410,000 - sum[fou(actual)]; where: FOU is the fuel oil usage limit, in gallons/year; sum[fou(actual)] is the sum of FOU for all months previous to month n; month n is the month for which the limit is being calculated. Title I Condition: Recordkeeping associated with fuel usage limits; Minn. R , subp. 5 Title I Condition: Recordkeeping associated with fuel usage limits; Minn. R , subp. 5 The limit is being met when the formula is true for month n. Recordkeeping: Monthly coal usage and monthly calculation of 12-month rolling sum, by the 15th of the following month. This requirement applies after startup of pulp machine (EU080). Coal usage will be discontinued within 180 days of startup of the IQS (EU 081); recordkeeping will no longer be required at that point. Recordkeeping: Monthly sludge usage and monthly calculation of 12-month rolling sum, by the 15th of the following month. This requirement applies after startup of pulp machine (EU080). For the first 12 months of operation after startup of pulp machine (EU080), monthly determination of the 12-month rolling sum limit for sludge usage shall be determined based on the following: Month 1: SU < 38,220; Month 2-12: SU(month n) < 38,220 - sum[su(actual)]; where: SU is the sludge usage limit, in tons/year; sum[su(actual)] is the sum of SU for all months previous to month n; month n is the month for which the limit is being calculated. Title I Condition: Recordkeeping associated with fuel usage limits; Minn. R , subp. 5 Title I Condition: Recordkeeping associated with fuel usage limits; Minn. R , subp. 5 The limit is being met when the formula is true for month n Recordkeeping: After burning of RR ties has commenced, the Permittee shall Title I Condition: Recordkeeping associated with fuel record daily the total wood refuse usage for each boiler for the purpose of usage limits; determining whether railroad tie usage limit is being met. If the total wood Minn. R , subp. 5 refuse/railroad tie usage is more than the railroad tie usage limit, then the Permittee shall use fuel yard inventories and operator logsheets to determine the daily railroad tie usage. The semi-annual deviations report shall include all instances where the daily wood refuse/railroad tie usage exceeded the railroad tie daily limit and shall include the determined railroad tie usage for that day. Notification of initial burning of railroad ties: due 15 days after initial burning of Minn. R , subp. 2 railroad ties in #7 and/or #9 power boilers (EU002 and EU004). A-12