DAQ-2024-008536

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DAQC-585-24
Site ID 14107 (B1)

MEMORANDUM

TO: FILE – THE PROCTER & GAMBLE PAPER PRODUCTS COMPANY (P&G) –
Box Elder Facility

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joe Rockwell, Environmental Scientist

DATE: June 10, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Box Elder County,
FRS #UT0000004900300053

INSPECTION DATE: May 10, 2024

SOURCE LOCATION: 5000 North (Wakegan Road) Iowa String Road (6800 West)
Bear River City, Utah 84301

Take exit 365 off I-15 and go west on Promontory Road. Keep going
through Corrine to Iowa String Road (6800 West). Head north to the
plant at 6400 North.

MAILING ADDRESS: 5000 North (Wakegan Road) Iowa String Road (6800 West)
Bear River City, Utah 84301

SOURCE CONTACTS: Cleon Murray, HS&E Manager: Cell: 302-264-1005
[e-mail]

Dean Shepherd, Environment Manager:
Office: 435-279-1337, Cell: 801-710-7716
[e-mail]

OPERATING STATUS: Operating

PROCESS DESCRIPTION: The facility has three business groups:

1) Paper making (Family Care)
2) Assembled Paper Products A (Baby Care)
3) Assembled Paper Products B (Fem Care)

Family Care:
The Box Elder Plant uses pulp, which is manufactured at separate
facilities, mixed with water and additives as raw materials. The additives
enhance the paper’s softness, strength, and appearance. The raw
materials are formed into a web and dried with hot air from a
combination of process heaters and steam dryers.
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Finally, when the wet paper undergoes drying a wet paper web is passed
through drying zones. Air and heat distribution are critical in order
to uniformly dry the paper sheet and ensure a quality product. Hot air is
transferred across the wet paper web; therefore, passing directly through
and/or impinging upon the product in the forming system and dry end.
The air is heated by two (2) duct burners referred to as Burner
#1 and Burner #2.

The paper product finishes in the paper machine as a large roll (pressure)
for further processing. The dry-end of the process is controlled by a
Venturi scrubber and the wet end of the process and under dryer are
controlled by cyclonic separators that function as mist eliminators and
remove particulate.

Material is fed into one (1) of three (3) converting process lines and
combined with other raw materials to form a specific paper product. The
materials are bound together with adhesives and cut into the appropriate
shape prior to packaging and shipping.

Baby Care:
Each Assembled Paper Product A line functions to assemble various raw
materials into the finished product. Several raw materials are unwound at
points along the assembly process. In addition, some raw materials are
de-bulked in an offline process and delivered via air to the lines. Various
raw and scented materials are also used in the assembly and packaging of
Assembled Paper Products. Particulate is captured during the de-bulking
of raw materials, the delivery of raw materials, and from the cutting
operations on the line. VOCs occur as a result of raw and scented
material application as well as from finished product packaging.

Fem Care:
Assembled Paper Products B consists of two primary process steps
including Functional Absorbent Material (FAM) manufacturing and
converting. The goal of the FAM manufacturing process is to make a raw
material web that is fed into the converting process lines. The raw
materials for the FAM process primarily consist of, but are not limited to,
monomers, salt brines, and activators. The monomers, brines, and
activators are mixed together using an in-line mixer. This mixture is
an emulsion due to the low solubility of monomers in water. The mixture
undergoes a polymeric reaction and is then extruded onto a conveyor
(“sheet making”) and cured into a solid web in a steam-heated curing
oven. The curing oven has steam coils which heat a water bath at the
base of the curing oven. The web is sprayed with brine, mechanically
dewatered, and dried in a natural gas fired dryer. The product is cut and
wound onto rolls for transport to the converting area.

Once the FAM process is complete this raw material is fed into three (3)
of six (6) converting process lines and combined with other raw
materials to form the complete Assembled Paper Product B. These raw
materials are bound together with adhesives and cut into the appropriate
shape prior to packaging.
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APPLICABLE
REGULATIONS: Title V Operating Permit 300053003, Dated April 11, 2023, Revised
January 19, 2024

NSPS (Part 60), A: General Provisions
NSPS (Part 60), Dc: Standards of Performance for Small Industrial-
Commercial-Institutional Steam Generating Units
MACT (Part 63), A: General Provisions
NSPS (Part 60), IIII: Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines
NSPS (Part 60), JJJJ: Standards of Performance for Stationary Spark
Ignition Internal Combustion Engines
MACT (Part 63), ZZZZ: NESHAP for Stationary Reciprocating Internal
Combustion Engines
MACT (Part 63), CCCCCC: Gasoline Distribution and Storage.

SOURCE EVALUATION:

SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

Status: This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: This is a statement of fact and not an inspection item.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that
the Director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the Director copies of records
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required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause. The
filing of a request by the permittee for a permit modification, revocation and reissuance, or
termination, or of a notification of planned changes or anticipated noncompliance shall not
stay any permit condition, except as provided under R307-415-7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

Status: This is a statement of fact and not an inspection item.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: The permit expires April 11, 2028. Application for renewal is due October 11, 2027.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit renewal application. In such case, the terms and conditions
of this permit shall remain in force until permit renewal or denial. This protection shall
cease to apply if, subsequent to the completeness determination required pursuant to R307-
415-7a(3), and as required by R307-415-5a(2), the applicant fails to submit by the deadline
specified in writing by the Director any additional information identified as being needed to
process the application. (R307-415-7b(2))

Status: Application for renewal is due October 11, 2027.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: This is a statement of fact and not an inspection item.
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I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In compliance – The annual emission fee invoice payment was made on August 31, 2023,
before the due date of October 2, 2023.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: This is a statement of fact and not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under
the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements. (R307-415-
6c(2)(d))

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I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall
be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In compliance – Required records were made available and no claims of confidentially were
made at time of the inspection.

I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible
official as defined in R307-415-3. This certification shall state that, based on information
and belief formed after reasonable inquiry, the statements and information in the document
are true, accurate, and complete. (R307-415-5d)

Status: In compliance – All reports and certifications submitted, by P&G, appeared to have
certification statements and were signed by responsible officials.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than
the date shown under "Enforceable Dates and Timelines" at the front of this permit, and that
date each year following until this permit expires. The certification shall include all the
following (permittee may cross-reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this permit. If
necessary, the permittee also shall identify any other material information that must
be included in the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and
take it into account in the compliance certification. The certification shall also
identify as possible exceptions to compliance any periods during which compliance
is required and in which an excursion or exceedance as defined under 40 CFR Part
64 occurred; and

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I.L.1.d Such other facts as the Director may require to determine the compliance status.

I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director:
(R307-415-6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In compliance – The 2022 annual compliance certification, dated July 27, 2023, was received
on August 2, 2023, and deemed acceptable. The report with a due date of August 1, 2023, was
received only one day late. The 2023 annual compliance certification is due by August 1, 2024.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed
in this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-
112, and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(g) and Section 19-2-110
prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: N/A – See section III of this permit.

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I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a technology-
based emission limitation under this permit, due to unavoidable increases in emissions
attributable to the emergency. An emergency shall not include noncompliance to the extent
caused by improperly designed equipment, lack of preventive maintenance, careless or improper
operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance with
such technology-based emission limitations if the affirmative defense is demonstrated through
properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emission standards, or other requirements in this
permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two working
days of the time when emission limitations were exceeded due to the emergency. This
notice must contain a description of the emergency, any steps taken to mitigate
emissions, and corrective actions taken. This notice fulfills the requirement of Provision
I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in any
other section of this permit. (R307-415-6g(5))

Status: An emergency event, occurred on May 25, 2023. It concerned release of emissions due to a B Inks
RTO malfunction, because of an alarm malfunction. This deviation should be noted in the 2023
annual compliance certification. See condition I.L and attached Breakdown report email dated
May 26, 2023.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.
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I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: These are statements of fact and not inspection items (I.O through I.R).

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be retained by
the permittee for a period of at least five years from the date of the monitoring sample,
measurement, report, or application. Support information includes all calibration and
maintenance records, all original strip-charts or appropriate recordings for continuous
monitoring instrumentation, and copies of all reports required by this permit. (R307-
415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the source
shall record the following information, where applicable:
(R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or measurement.

I.S.1.c

Additional record keeping requirements, if any, are described in Section II, Special
Provisions.
Status: In compliance – Required records were provided at time of the inspection.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from permit requirements
shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a responsible
official in accordance with Provision I.K of this permit.
(R307-415-6a(3)(c)(i)

I.S.2.c The Director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, the probable
cause of such deviations, and any corrective actions or preventative measures taken.
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Prompt, as used in this condition, shall be defined as written notification within the
number of days shown under "Enforceable Dates and Timelines" at the front of this
permit. Deviations from permit requirements due to breakdowns shall be reported in
accordance with the provisions of R307-107. (R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be submitted to
the Director are to be sent to the following address or to such other address as may be
required by the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b All reports, notifications or other submissions required by this permit to be submitted to
the EPA should be sent to one of the following addresses or to such other address as
may be required by the Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Office of Partnerships and Regulatory Assistance Air and Radiation Program (mail code
8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance – The 2022, six-month monitoring reports were received on August 5, 2022, and
February 9, 2023, they were deemed acceptable. The most recent 2023, six-month monitoring
reports were received on August 2, 2023 and January 23, 2024. Two of the three 2023, monitoring
reports have been revised. Also, the deviation reports for 2023 were received on June 9, 2023 and
July 6, 2023, and deemed acceptable.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due to
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expire, unless the terms and conditions of this permit have been extended pursuant to
R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other terms
or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to assure
compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date of
this permit and are in conflict with existing permit conditions.
(R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a Title
IV affected source under the Acid Rain Program. Upon approval by EPA, excess emissions
offset plans shall be deemed to be incorporated into this permit.
(R307-415-7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen exists.
(R307-415-7g(2))

Status: This is a statement of fact and not an inspection item.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In compliance – According to P&G and the SLEIS database the emission inventories are required
to be submitted tri-annually. P&G submitted their 2023 emission inventory on April 3, 2024. The
emission inventory was re-submitted after additional comments were made. See the SLEIS
database and Emission Inventory below.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of regulations
promulgated under Title IV of the Act, Acid Deposition Control, both provisions shall be
incorporated into this permit. (R307-415-6a(1)(b))

Status: This is a statement of fact and not an inspection item.
SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

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II.A.2 Paper Machine 15B Process Stack
Includes one 150 MMBTU/hr natural gas fired dryer with low NOx burner. A venturi scrubber is on the
dry-end of the process and two cyclonic separators (one is at the wet-end of the process and one under
machine exhaust).

II.A.3 Paper Machine 16B Process Stack
Includes one 130 MMBTU/hr natural gas fired dryer with ultra-low NOx burner and make-up air units
with low NOx burners. A venturi scrubber is on the dry-end of the process and two cyclonic separators
(one is at the wet-end of the process and one under machine exhaust).

II.A.4 Paper Product and Utility Boilers
Two natural gas fired paper product boilers 60.24 MMBTU/hr (each) with low NOx burners.
Two natural gas fired utility boilers 50 MMBTU/hr (each) with ultralow NOx burners.
One natural gas back-up boiler (if a boiler is out of service). Propane is the secondary fuel in case of
emergency or curtailment.

II.A.5 Paper Product Converting Operation
One paper product converting operation consists of 5 converting lines (2 New): 3 converting lines
controlled by 3 dedicated drum filters that vent to atmosphere and 2 converting lines controlled by 2
dedicated baghouses that vent indoors.

II.A.6 Multiple Space Heaters
No unit specific applicable requirements.

II.A.7 NSPS CI RICE
Two 375 hp (each) and two 399 hp (each) CI RICE to power fire pumps. One 1,214 hp CI RICE
emergency power generator. All engines are diesel fired.

II.A.8 NSPS CI RICE Non-Fire Pump Engines
One 1,214 hp CI RICE emergency power generators.

II.A.9 NSPS CI RICE Emergency Fire Pump Engines
Two 375 (each) hp and two 399 (each) hp CI RICE.

II.A.10 Tanks
Multiple tanks including diesel and gasoline fuel storage and various raw material storage tanks.

II.A.11 Cooling Towers
Multiple cooling towers with drift eliminators (0.001%) to support the facility. No unit specific
applicable requirements.

II.A.12 NSPS SI Natural Gas-fired Emergency Engine
Two natural gas-fired emergency generators, rated at 54 hp (40 kW) and 1006 hp (750 kw), respectively.

II.A.13 Assembled Paper Product A Equipment
Pneumatic pumps. No unit specific applicable requirements.

II.A.14 Assembled Paper Product A Portable Dry Vacuum Units
No unit specific applicable requirements.

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II.A.15 Assembled Paper Products A Drum Filters/Baghouses
Four assembled paper product A drum filters (one per line). One assembled paper product A baghouse
(one per four lines). Emission from the assembled paper products A converting operation shall be routed
to the assembled paper products A drum filters and the assembled paper product A baghouse.

II.A.16 Assembled Paper Product B RTO (FAM RTO)
Functional Absorbent Material (FAM) manufacturing operation, use of a natural gas fired (with 2
MMBTU/hr, low NOx burner) Regenerative Thermal Oxidizer (RTO) to control emissions.

II.A.17 Assembled Paper Product B FAM Dryer
Four natural gas fired burners each rated at 2.5 MMBtu/hr. No unit specific applicable requirements.

II.A.18 Assembled Paper Product B Converting Baghouse/Fabric Filter
Includes one drum filter system and three baghouses: Briquetter Baghouse, Active Ingredient Baghouse
and Central Vacuum System Baghouse. Emissions from the assembled paper products B converting
operation shall be routed to the assembled paper products B Converting drum filter and the assembled
paper product B Converting baghouses.

II.A.19 Assembled Paper Product B FAM Silo
Storing the raw material (salts) for FAM operation. No unit specific applicable requirements.

II.A.20 Assembled Paper Product B Inks RTO
The RTO with the burner size 1 MMBtu/hr to control the VOC emissions from the ink’s application and
maintenance processes

II.A.21 Assembled Paper Product B Equipment
Pneumatic pump. No unit specific applicable requirements.

II.A.22 FAM Making Operations Tanks
Includes one 500-gallons and one 6,000-gallons tanks for storing sodium bisulfite, one 60-gallons tank
for storing 25% HCl. No unit specific applicable requirements.

Status: In compliance – No unapproved equipment was noted at time of the inspection. The Paper
Machine 16B Process Stack (item II.A.3) is currently under construction. The Paper Product
Boilers and Utility Boilers (item II.A.4) are currently under construction. Three of the four boilers
have been installed. The forth boiler is currently under construction. The Paper Product
Converting Operation (item II.A.5) are currently under construction. Three of the five lines are
operating. There are two lines currently under construction. Finally, NSPS SI Natural Gas - Fired
Emergency Engines (item II.A.12) are currently under construction. The 54 hp engine was
installed in 2019, and the 1006 hp engine is currently under construction.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted facility
as indicated:

II.B.1 Conditions on Permitted Source (Source-wide).

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II.B.1.a Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate the affected emission units, including associated air pollution control
equipment, in a manner consistent with good air pollution control practice for minimizing emissions.
Determination of whether acceptable operating and maintenance procedures are being used will be
based on information available to the Director which may include, but is not limited to, monitoring
results, opacity observations, review of operating and maintenance procedures, and inspection of the
source. All maintenance performed on authorized equipment shall be recorded.
[Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.1.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – An in-house database (SAP) is used to track maintenance (preventative and
routine) and work orders.

II.B.1.b Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for
class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction.
[Origin: 40 CFR 82 Subpart F]. [40 CFR 82.150(b)]

II.B.1.b.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart F. [40 CFR 82]

II.B.1.b.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision I.S.1 in of this permit. [40 CFR 82]

II.B.1.b.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit. [40 CFR 82]

15
Status: In compliance – MSS, CCI and/or Trane are contracted to work with the refrigerants on an
annual and on an as needed basis. P&G certified compliance with this condition in their 2022
annual compliance certification received August 2, 2023

II.B.1.c Condition:

The plant-wide emissions of VOCs and HAPs from the operations shall not exceed:

(1) 130.07 tons of VOC emissions per rolling 12-month period;
(2) 3.14 tons of Hexane per rolling 12-month period;9.07 tons of Methanol per rolling 12-month period.

[Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.1.c.1 Monitoring:

Compliance with each limitation shall be determined on a rolling 12-month total. Based on the
last day of each month, a new 12-month total shall be calculated using data from the previous 12
months. Monthly calculations shall be made no later than 30 days after the end of each calendar
month.

II.B.1.c.2 Recordkeeping:

VOC and HAP emissions shall be determined by maintaining a record of VOC and HAP
emitting materials used each month if applicable to the product in sections 1, 2, and 3 below
and/or to emission calculations in section 4. The record shall include the following data for each
material used for calculating the rolling 12-month total:

(a) Name of the VOC and volatile HAP emitting process material.

(b) Percent by weight of all VOC and volatile HAP in each process material used.

(c) Quantity of each VOC and volatile HAP emitting process material used in pounds.

(d) The amount of VOC and volatile HAP emitted monthly by each process material used,
calculated by the following procedure:

VOC = (% VOC by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000 lb)
Or an Alternative VOC calculation consistent with US EPA emission calculation
methodologies.

HAP = (% HAP by Weight) x (Quantity of Chemical Used in lbs./100) x (1 ton/2000lb)
Or an Alternative HAP calculation consistent with US EPA emission calculation methodologies.

(e) The amount of VOC or volatile HAP emitted monthly from all materials used.

(f) The amount of VOC or volatile HAP reclaimed for the month shall be similarly quantified
and subtracted from the quantities calculated above, to provide the monthly total VOC and
volatile HAP emissions.

Records shall be maintained in accordance with Provision I.S.1 of this permit.

16
II.B.1.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Plant wide VOC and HAP emissions as of April 2024. Emissions started to be
recorded on January 19, 2024 to present (Four Month Rolling Total):

Summary

Pollutant Limit (Tons) Actual Emissions (Tons)
VOC 130.07 29.07
Hexane 3.14 0.31
Methanol 9.07 2.04

II.B.1.d

Condition:

The permittee shall submit documentation of the status of construction of the 16B paper machine to the
Director within 18 months from the date of AO DAQE-AN141070018-23. This AO DAQE-141070018-
23 may become invalid if construction is not commenced within 18 months from November 16, 2023 or
if construction is discontinued for 18 months or more.

[Origin: DAQE-AN141070018-23]. [R307-401-18]

II.B.1.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.d.2 Recordkeeping:

The permittee shall maintain a copy of each notification required by this permit condition in
accordance with Provision I.S.1 of this permit.

II.B.1.d.3 Reporting:

The permittee should submit the notification to the Director in writing on the status of the
construction and/or installation within 18 months from the date of AO DAQE-AN141070018-
23. To insure proper credit when notifying the Director, send your correspondence to the
Director, attn: NSR Section.

There are no other reporting requirements for this provision except those specified in Section I
of this permit.

Status: In compliance – P&G has until May of 2025, (18 months from November 16, 2023), to submit the
16 B paper machine construction status notice. P&G is aware that installation notices are required
to be submitted.

II.B.1.e Condition:

Visible emissions shall be no greater than 20 percent opacity, unless otherwise specified in this permit.
[DAQE-AN141070018-23]. [R307-401-8]
17
II.B.1.e.1 Monitoring:

The permittee shall conduct a monthly 1-minute visible emissions test of each affected source in
accordance with 40 CFR 60, Appendix A, Method 22.

If no visible emissions are observed in six consecutive monthly tests for any affected source, the
permittee may decrease the frequency of testing from monthly to semi-annually for the affected
source. If visible emissions are observed during any semi-annual test, the permittee shall resume
testing of that affected source on a monthly basis and maintain that schedule until no visible
emissions are observed for six consecutive monthly tests.

If no visible emissions are observed during two consecutive semi-annual tests for any affected
source, the permittee may decrease the frequency of testing from semi-annually to annually for
the affected source. If visible emissions are observed during any annual test, the permittee shall
resume testing of that affected source on a monthly basis and maintain that schedule until no
visible emissions are observed for six consecutive monthly tests.

If visible emissions are observed during any Method 22 test, a current Method 9 certified
observer shall conduct a:
(a) six minute test of opacity in accordance with 40 CFR 60, Appendix A Method 9 for point
sources, or
(b) one minute test of opacity with five second observation intervals in accordance with 40 CFR
51, Method 203C for fugitive emission sources
(c) the Method 9 or 203C test shall begin within 24 hours of any observation of visible emission.

II.B.1.e.2 Recordkeeping:

Records of visible emission tests performed and data required by 40 CFR 60, Appendix A,
Method 22, Method 9, or 40 CFR 51, Method 203C shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.1.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Six-month Visible Emission Observations (VEOs) of the affected sources are now
being conducted. The method 22 and method 9 VEO forms are filed with Method 9 certifications.
VEO records indicated that only Method 22s have been conducted since the last inspection.
Records are kept for five years.

II.B.1.f Condition:

Visible emissions shall be no greater than 10 percent opacity for all natural gas combustion equipment
and cooling towers. [Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.1.f.1 Monitoring:

Records required for this permit condition will serve as monitoring for natural gas combustion
equipment.

18
For each cooling tower the following shall serve as monitoring:
The permittee shall conduct a monthly 1-minute visible emissions test of each affected source
in accordance with 40 CFR 60, Appendix A, Method 22.

If no visible emissions are observed in six consecutive monthly tests for any affected source,
the permittee may decrease the frequency of testing from monthly to semi-annually for the
affected source. If visible emissions are observed during any semi-annual test, the permittee
shall resume testing of that affected source on a monthly basis and maintain that schedule until
no visible emissions are observed for six consecutive monthly tests.

If no visible emissions are observed during two consecutive semi-annual tests for any affected
source, the permittee may decrease the frequency of testing from semi-annually to annually for
the affected source. If visible emissions are observed during any annual test, the permittee shall
resume testing of that affected source on a monthly basis and maintain that schedule until no
visible emissions are observed for six consecutive monthly tests.

If visible emissions are observed during any Method 22 test, a current Method 9 certified
observer shall conduct a:
(a) six minute test of opacity in accordance with 40 CFR 60, Appendix A Method 9 for point
sources, or
(b) one minute test of opacity with five second observation intervals in accordance with 40
CFR 51, Method 203C for fugitive emission sources
(c) the Method 9 or 203C test shall begin within 24 hours of any observation of visible
emission.

II.B.1.f.2 Recordkeeping:

In lieu of monitoring via visible emission observations for natural gas combustion equipment,
the permittee shall keep one of the following sets of records for each affected emission unit, as
applicable:

(a) Documentation that the emission unit can only burn natural gas;
(b) Documentation that the fuels other than natural gas cannot be supplied to the emission unit
without modification of the fuel supply system; or
(c) Fuel bills or fuel meter reading that demonstrate only natural gas is combusted in the
emission unit.

The permittee shall keep a log which includes the location and description of each affected
emission unit. For each affected emission unit, the log shall include the type of records that will
be used in lieu of monitoring via visible emission observations, the permittee shall review fuel
bills or fuel meter reading once per quarter and record in the log the types of fuel combusted.

The records and log required by this condition and the results of cooling tower monitoring shall
be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

19
Status: In compliance – Six-month VEOs of the cooling towers are now being conducted. The method 22
and method 9 VEO forms are filed with Method 9 certifications. VEO records indicated that only
method 22s were conducted since that last inspection. Records are kept for five years. Natural gas
usage records are also maintained for natural gas equipment

II.B.1.g Condition:

Salt applied to roads shall be at least 92% NaCl, MgCl2, CaCl2, or KCl. Any person who applies an
abrasive such as crushed slag or sand, or who applies salt that is less than 92% by weight NaCl, MgCl2,
and/or CaCl2 to roads shall comply with the requirements of either R307-307-5(1)(a) or (b). [Origin:
R307-307]. [R307-307-4(1), R307-307-5(2)]

II.B.1.g.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.g.2 Recordkeeping:

The following records shall be maintained as outlined in Provision I.S.1 of this permit:

For Salt - the quantity applied annually, the percent by weight of insoluble solids in the salt, and
the percentage of the material that is sodium chloride (NaCl), magnesium chloride (MgCl2),
calcium chloride (CaCl2), or potassium chloride (KCl).

For Abrasives (such as sand or crushed slag) - the quantity applied annually and the percent by
weight of fine material which passes the number 200 sieve in a standard gradation analysis.

II.B.1.g.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Records of road treatments are kept. The material used, 100% of the time, is 93%
- 96% NaCl. Saltworx provides the material and Safety data Sheets (SDS) to the facility

II.B.1.h Condition:

The permittee shall ensure that the following conditions are met for all cold VOC containing solvent
parts washers:
(1) A cover shall be installed which shall remain closed except during actual loading, unloading or
handling of parts in cleaner. The cover shall be designed so that it can be easily operated with one hand
if (a) the volatility of the solvent is greater than 2 kPa (15 mm Hg or 0.3 psi) measured at 38 degrees C
(100 degrees F),
(b) the solvent is agitated, or (c) the solvent is heated.

(2) An internal draining rack for cleaned parts shall be installed on which parts shall be drained until all
dripping ceases. If the volatility of the solvent is greater than 4.3 kPa (32 mm Hg at 38 degrees C (100
degrees F)), the drainage facility must be internal, so that parts are enclosed under the cover while
draining. The drainage facility may be external for applications where an internal type cannot fit into the
cleaning system.

20
(3) Waste or used solvent shall be stored in covered containers.

(4) Tanks, containers and all associated equipment shall be maintained in good operating condition and
leaks shall be repaired immediately or the degreaser shall be shutdown.

(5) Written procedures for the operation and maintenance of the degreasing or solvent cleaning
equipment shall be permanently posted in an accessible and conspicuous location near the equipment.

(6) If the solvent volatility is greater than 4.3 kPa (33 mm Hg or 0.6 psi) measured at 38 degrees C (100
degrees F), or if solvent is heated above 50 degrees C (120 degrees F), then one of the following control
devices shall be used: (a) freeboard that gives a freeboard ratio greater than 0.7; (b) water cover if the
solvent is insoluble in and heavier than water; (c) other systems of equivalent control, such as a
refrigerated chiller or carbon absorption.

(7) If used, the solvent spray shall be a solid fluid stream at a pressure which does not cause excessive
splashing and may not be a fine, atomized or shower type spray. [Origin: R307-335-4]. [R307-335-4]

II.B.1.h.1 Monitoring:

A visual observation shall be conducted monthly for all equipment and applicable work
practices.

II.B.1.h.2 Recordkeeping:

Results of monthly inspections and the volatility of the solvent(s) being used shall be recorded
and maintained as described in Provision I.S.1 of this permit.

II.B.1.h.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The two on-site solvent washers are maintained according to this condition. The
company keeps monthly inspection logs. All monthly inspections have been conducted since the
last inspection. Safety Kleen handles the solvent and disposes of the solvent on a quarterly basis.

II.B.1.i Condition:

Unless otherwise specified in this permit, visible emissions caused by fugitive dust shall not exceed 10%
at the property boundary, and 20% onsite. Opacity shall not apply when the wind speed exceeds 25
miles per hour if the permittee has implemented, and continues to implement, the accepted fugitive dust
control plan and administer at least one of the following contingency measures:

(1) Pre-event watering
(2) Hourly watering
(3) Additional chemical stabilization
(4) Cease or reduce fugitive dust producing operations
(5) Other contingency measure approved by the Director

[Origin: R307-309]. [R307-309-5, R307-309-6]

21
II.B.1.i.1 Monitoring:

In lieu of monitoring via visible emissions observations, adherence to the current fugitive dust
control plan approved by the Director shall be monitored to demonstrate that appropriate
measures are being taken to control fugitive dust. Wind speed may be measured by a hand-held
anemometer or equivalent device.

II.B.1.i.2 Recordkeeping:

If wind speeds are measured to establish an exception from the above visible emissions limits,
records of the administered contingency measures and the wind speed measurements shall be
maintained. Records required by the most recently approved fugitive dust control plan shall be
maintained in accordance with the plan.

Records that demonstrate compliance with this condition shall be available to the Director upon
request. [R307-309-12]
Records shall be maintained as described in provision I.S.1 of this permit.

II.B.1.i.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – A dedicated water truck waters the loop road and construction site on an as
needed basis. Water records were reviewed for fall of 2023. The operational area around the
facility is paved. The current Fugitive Dust Control Plan (FDCP), dated May 15, 2022, has been
submitted electronically. When construction becomes active during the summer months a
dedicated water truck is on-site. Construction was not active at time of the inspection

II.B.1.j Condition:

The permittee shall not sell, supply or offer for sale any adhesive, sealant, adhesive primer or sealant
primer with a VOC content in excess of the limits in Table 1 of R307-342-5 and that was manufactured
on or after September 1, 2014. The permittee shall not apply any adhesive, sealants, adhesive primer or
sealant primer with a VOC content in excess of the limits specified in Table 1 of R307-342-5 unless an
add-on control device as specified in R307-342-8 is used or unless the adhesive, sealant, adhesive
primer or sealant primer was manufactured before September 1, 2014.

The VOC content limits in Table 1 of R307-342-5 for adhesives applied to particular substrates shall
apply as specified in R307-342-5(4). The permittee shall comply with the additional standards and work
practices contained in R307-342-6 and R307-342-7, as applicable. These requirements do not apply if
exempted in accordance with R307-342-3.
[Origin: R307-342]. [R307-342].

II.B.1.j.1 Monitoring:

Records required for this permit condition will serve as monitoring.

22
II.B.1.j.2 Recordkeeping:

(a) For operations that are not exempt under R307-342-3, the permittee shall maintain records
demonstrating compliance as specified in R307-342-7(2);

(b) If an exemption is claimed pursuant to R307-342-3 the permittee shall record and maintain
operational records sufficient to demonstrate compliance. (R307-342-3(7))

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.j.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – An Adhesive and Sealant Compliance Tool spreadsheet is maintained. The
spreadsheet is 89 pages and was implemented in 2017.

II.B.1.k Condition:

The permittee shall use natural gas as fuel in all equipment listed in this permit as a primary fuel and
propane as a backup fuel in all boilers (except for listed emergency equipment which is diesel operated).
[Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.1.k.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.k.2 Recordkeeping:

The type of fuel used shall be recorded and maintained in accordance with Provision I.S.1 of
this permit.

II.B.1.k.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Natural gas is the only fuel burned in all of the permitted equipment. Propane is
only used to fuel rental boilers. Natural gas records are maintained.

II.B.2 Conditions on Paper Machine 15B Process Stack

II.B.2.a Condition:

Emissions of CO shall be no greater than 15.75 lb/hr and 0.105 lb/MMBTU for the paper machine 15B
process stack. [Origin: DAQE-AN141070018-23]. [R307-401-8]

23
II.B.2.a.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. Emissions shall be tested every three years base on the date of the previous test.
The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Testing
protocol shall be approved by the Director.

(c) Sample Point: The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director. In
addition, Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.

(d) Methods.
(1) 40 CFR 60, Appendix A, Method 10 or other EPA approved testing methods, as acceptable
to the Director shall be used to determine CO emissions;
(2) 40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods as acceptable to
the Director shall be used to determine stack gas velocity and volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.

(f) Production Rate during Testing.
(1) The operational rate during all compliance testing shall be no less than 90% of the maximum
rate achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum production rate achieved during operation. If the test is passed, the new
maximum allowable production rate shall be 110% of the tested achieved rate. This new
allowable maximum production rate shall remain in effect until successfully tested at the higher
rate.

II.B.2.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

II.B.2.a.3 Reporting:

Results of required stack testing shall be submitted to the Director within 60 days of completion
of the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation.

24
Status: In compliance – The latest stack test was conducted on April 10 through April 15, 2023. The test
was completed on June 5 through June 10, 2023. Results of the stack test are as follows:

Stack Test Summary

Stack CO Limit CO Results
Paper Machine Process Stack 15.75 (lb/hr) 7.2 (lbs/hr)
0.105 (lb/MMBTU) 0.075 (lb/MMBTU)

II.B.2.b Condition:

Emissions of NOx shall be no greater than 13.50 lbs/hour and 0.09 lb/MMBTU for the paper machine
15B process stack. [Origin: DAQE-AN141070018-23and SIP Section IX, Part H.12.n.i]. [R307-110-17,
R307-401-8]

II.B.2.b.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested every three years based on the date of the previous test.
The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Test protocol
shall be approved by the Director.

(c) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director.
An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.

(d)Methods
(1) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, or 7E, or other EPA approved testing
methods as acceptable to the Director shall be used to determine the NOx emission rate.
(2) 40 CFR 60, Appendix A, Method 2, or other EPA approved testing method as acceptable to
the Director shall be used to determine the volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.

(f) Production Rate During Testing.
(1) The production rate during all compliance testing shall be no less than 90% of the maximum
production achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum production rate achieved during operation. If the test is passed, the new
maximum allowable production rate shall be 110% of the tested achieved rate. This new
25
allowable maximum production rate shall remain in effect until successfully tested at the higher
rate.

II.B.2.b.2 Recordkeeping:

Results of all stack testing shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation.

Status: In compliance – The latest stack test was conducted on April 10 through April 15, 2023. The test
was completed on June 5 through June 10, 2023. Results of the stack test are as follows:

Stack Test Summary

Stack NOx Limit NOx Results
Paper Machine Process Stack 13.50 (lbs/hr) 6.2(lbs/hr)
0.09 (lb/MM/BTU) 0.064 (lb/MMBTU)

II.B.2.c Condition:

Emissions of PM2.5 shall be no greater than 6.65 lb/hr and 0.044 lb/MMBTU for the paper machine 15B
process stack. [Origin: DAQE-AN141070018-23and SIP Section IX, Part H.12.n.i]. [R307-401-8 and
R307-110-17]

II.B.2.c.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested every three years based on the date of the previous test.
The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Test protocol
shall be approved by the Director.

(c) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director.
An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.

(d) Methods: Total PM2.5 shall be the sum of filterable PM2.5 and condensable PM2.5
(1) The following methods shall be used to measure filterable particulate emissions: 40 CFR 51,
Appendix M, Methods 201A, or other EPA approved testing methods as acceptable to the
26
Director. If other approved testing methods are used which cannot measure the PM2.5 fraction of
the filterable particulate emissions, all of the filterable particulate emissions considered PM2.5.
(2) The following methods shall be used to measure condensable particulate emissions: 40 CFR
51, Appendix M, Method 202 or other EPA approved testing method as acceptable to the
Director.
(3) The following methods shall be used to measure total particulate emissions: 40 CFR
60.8(b)(2), Appendix A, including EPA-approved testing method OTM 37.
(4) 40 CFR 60, Appendix A, Method 2, or other EPA approved testing methods as acceptable to
the Director shall be used to determine the volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb./hr., etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors to give the results in the specified units of the emission
limitation. The filterable particulate emissions shall be added to the condensable particulate
emissions for compliance demonstration.

(f) Production Rate During Testing.
(1) The production rate during all compliance testing shall be no less than 90% of the maximum
production achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum production rate achieved during operation. If the test is passed, the new
maximum allowable production rate shall be 110% of the tested achieved rate. This new
allowable maximum production rate shall remain in effect until successfully tested at the higher
rate.

II.B.2.c.2 Recordkeeping:

Results of all stack testing shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.c.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation.

Status: In compliance – The latest stack test was conducted on April 10 through April 15, 2023. The test
was completed on June 5 through June 10, 2023. The results of the stack are as follows:

Stack Test Summary

Stack PM2.5 Limit PM2.5 Results
Paper Machine Process Stack 6.65 (lb/hr) 3.1 (lb/hr)
0.044 lb/MMBTU 0.033 (lb/MM/BTU)

II.B.2.d Condition:

The permittee shall maintain the pressure drop across the 15B venturi scrubber at no less than 4 inches
of water when the unit is operating and venting to the atmosphere. [Origin: DAQE-AN141070018-23].
[R307-401-8]

27
II.B.2.d.1 Monitoring:

The permittee shall monitor the scrubber differential pressure once per operating day.

II.B.2.d.2 Recordkeeping:

Results of daily pressure drop readings shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.2.d.3 Reporting:

There are no other reporting requirements for this provision except those specified in Section I
of this permit.

Status In compliance – The pressure drop reading was within the permitted range at time of the
inspection. The pressure drop records are kept electronically and are also maintained in a
logbook. The system has an automated shutdown if pressure drops below the allowed limit.

II.B.2.e Condition:

The permittee shall implement an Emissions Minimization Plan (Paper Machine Plan) that describes
procedures for operating and maintaining the Paper Machine 15B, including associated air pollution
control and monitoring equipment, during events of startup and shutdown. The Paper Machine Plan shall
define the startup and shutdown events and shall contain the minimum requirements as follows:

(1) Startup begins when natural gas in supplied to the dryer combustion equipment with the intent of
combusting the fuel to heat the air to a desired temperature for the paper machine. Startup conditions
end within thirty minutes of natural gas being supplied to the dryer combustion equipment.

(2) Shutdown begins with the diversion of the hot air to the dryer startup stack and then the cessation of
natural gas flow to the dryer combustion equipment. Shutdown conditions end with thirty minutes of hot
air being diverted to the dryer startup stack. [Origin: SIP Section IX, Part H.12.n.iii]. [R307-110-17]

II.B.2.e.1 Monitoring:

Recordkeeping requirements required in this permit condition shall serve as monitoring
requirement.

II.B.2.e.2 Recordkeeping:

The permittee shall maintain records demonstrating that the procedures in the Paper Machine
Plan were followed

II.B.2.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status In compliance – The Emission Minimization Plan (EMP), regarding the 15B Paper Machine, was
implemented on February of 2024.

28
II.B.3 Conditions on Paper Machine 16B Process Stack

II.B.3.a Condition:

Emissions of CO shall be no greater than 4.82 lb/hr and 0.037 lb/MMBTU for the paper machine 16B
process stack. [Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.3.a.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. The initial test should be conducted within 180 days after startup and subsequent
test shall be conducted every three years base on the date of the previous test. Director may
require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Testing
protocol shall be approved by the Director.

(c) Sample Point: The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director. In
addition, Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.

(d) Methods.
(1) 40 CFR 60, Appendix A, Method 10 or other EPA approved testing methods, as acceptable
to the Director shall be used to determine CO emissions;
(2) 40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods as acceptable to
the Director shall be used to determine stack gas velocity and volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.

(f) Production Rate during Testing.
(1) The operational rate during all compliance testing shall be no less than 90% of the maximum
rate achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum production rate achieved during operation. If the test is passed, the new
maximum allowable production rate shall be 110% of the tested achieved rate. This new
allowable maximum production rate shall remain in effect until successfully tested at the higher
rate.

II.B.3.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision S.1 in Section I of this permit.

29
II.B.3.a.3 Reporting:

Results of required stack testing shall be submitted to the Director within 60 days of completion
of the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation.

Status N/A – Paper machine 16B is currently under construction. This is considered to be a new
condition. See status of condition II.A.

II.B.3.b Condition:

Emissions of NOx shall be no greater than 3.95 lbs/hour and 0.03 lb/MMBTU for the paper machine
16B process stack. [Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.3.b.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. The initial test should be conducted within 180 days after startup and subsequent
test shall be conducted every three years base on the date of the previous test. The Director may
require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Test protocol
shall be approved by the Director.

(c) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director.
An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.

(d)Methods
(1) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, or 7E, or other EPA approved testing
methods as acceptable to the Director shall be used to determine the NOx emission rate.
(2) 40 CFR 60, Appendix A, Method 2, or other EPA approved testing method as acceptable to
the Director shall be used to determine the volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.

(f) Production Rate During Testing.
(1) The production rate during all compliance testing shall be no less than 90% of the maximum
production achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum production rate achieved during operation. If the test is passed, the new
maximum allowable production rate shall be 110% of the tested achieved rate. This new
30
allowable maximum production rate shall remain in effect until successfully tested at the higher
rate.

II.B.3.b.2 Recordkeeping:

Results of all stack testing shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.3.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation.

Status N/A – Paper machine 16B is currently under construction. This is considered to be a new
condition. See status of condition II.A.

II.B.3.c Condition:

Emissions of PM2.5 shall be no greater than 6.65 lb/hr and 0.05115 lb/MMBTU for the paper machine
16B process stack. [Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.3.c.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. The initial test should be conducted within 180 days after startup and subsequent
test shall be conducted every three years base on the date of the previous test. The Director may
require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Test protocol
shall be approved by the Director.

(c) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director.
An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.

(d) Methods: Total PM2.5 shall be the sum of filterable PM2.5 and condensable PM2.5
(1) The following methods shall be used to measure filterable particulate emissions: 40 CFR 51,
Appendix M, Methods 201A, or other EPA approved testing methods as acceptable to the
Director. If other approved testing methods are used which cannot measure the PM2.5 fraction of
the filterable particulate emissions, all of the filterable particulate emissions considered PM2.5.
(2) The following methods shall be used to measure condensable particulate emissions: 40 CFR
51, Appendix M, Method 202 or other EPA approved testing method as acceptable to the
Director.
(3) The following methods shall be used to measure total particulate emissions: 40 CFR
60.8(b)(2), Appendix A, including EPA-approved testing method OTM 37.
31
(4) 40 CFR 60, Appendix A, Method 2, or other EPA approved testing methods as acceptable to
the Director shall be used to determine the volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb./hr., etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors to give the results in the specified units of the emission
limitation. The filterable particulate emissions shall be added to the condensable particulate
emissions for compliance demonstration.

(f) Production Rate During Testing.
(1) The production rate during all compliance testing shall be no less than 90% of the maximum
production achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum production rate achieved during operation. If the test is passed, the new
maximum allowable production rate shall be 110% of the tested achieved rate. This new
allowable maximum production rate shall remain in effect until successfully tested at the higher
rate.

II.B.3.c.2 Recordkeeping:

Results of all stack testing shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.3.c.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. The submittal shall clearly identify results and indicate compliance status. The
annual compliance certification required by Provision L in Section I of this permit shall use the
most recent test results as a basis for stating compliance status for this limitation.

Status N/A – Paper machine 16B is currently under construction. This is considered to be a new
condition. See status of condition II.A.

II.B.3.d Condition:

The permittee shall maintain the pressure drop across the 16B venturi scrubber at no less than 4 inches
of water when the unit is operating and venting to the atmosphere. [Origin: DAQE-AN141070018-23].
[R307-401-8]

II.B.3.d.1 Monitoring:

The permittee shall monitor the scrubber differential pressure once per operating day.

II.B.3.d.2 Recordkeeping:

Results of daily pressure drop readings shall be maintained in accordance with Provision I.S.1 of
this permit.

II.B.3.d.3 Reporting:

There are no other reporting requirements for this provision except those specified in Section I
of this permit.
32
Status N/A – Paper machine 16B is currently under construction. This is considered to be a new
condition. See status of condition II.A.

II.B.3.e Condition:

The consumption of natural gas in the 16B make-up air units shall not exceed 96,360 MMBtu per rolling
12-month total. [Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.3.e.1 Monitoring:

Compliance with the operational limitation shall be determined by the permittee maintaining a
monthly log tracking the MMBtu on a rolling 12-month total. Based on the last day of each
month, a new 12-month total shall be calculated using data from the previous 12 months.
Monthly calculations shall be made no later than 30 days after the end of each calendar month.

II.B.3.e.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.3.e.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status N/A – Paper machine 16B is currently under construction. This is considered to be a new
condition. See status of condition II.A.

II.B.4 Conditions on Paper Product and Utility Boilers.

II.B.4.a Condition:

Emissions of CO shall be no greater than 3.0 lb/hr and 70 ppm for each paper product boiler. [Origin:
DAQE-AN141070018-23]. [R307-401-8]

II.B.4.a.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. Emissions shall be tested every three years based on the date of the previous test.
The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Testing
protocol shall be approved by the Director.

(c) Sample Point: The emission sample point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director. In
addition, Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
33
Administration (MSHA) approved access shall be provided to the test location.

(d) Methods.
(1) 40 CFR 60, Appendix A, Method 10, or other EPA approved testing methods as acceptable
to the Director shall be used to determine CO emissions;
(2) 40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods as acceptable to
the Director shall be used to determine stack gas velocity and volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.

(f) Production Rate during Testing.
(1) The operational rate during all compliance testing shall be no less than 90% of the maximum
rate achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum achieved production rate. If the test is passed, the new maximum
allowable production rate shall be 110% of the tested achieved rate. This new allowable
maximum production rate shall remain in effect until successfully tested at the higher rate.

II.B.4.a.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associ ated
test method and Provision S.1 in Section I of this permit.

II.B.4.a.3 Reporting:

Results of required stack testing shall be submitted to the Director within 60 days of
completion of the testing. The submittal shall clearly identify results and indicate compliance
status. The annual compliance certification required by Provision L in Section I of this permit
shall use the most recent test results as a basis for stating compliance status for this limitation.

Status In compliance – The latest stack test was conducted on June 5-10, 2023. The results of the stack
test are as follows:
Stack Test Summary
Paper Product Boilers CO Limit (lb/hr) CO Results (lb/hr)
Boiler #1 (60.243 MMBTU/hr) 3.0 0.025
Boiler #2 (60.243 MMBTU/hr) 3.0 0.00 (ND)
ppmvd @ 3% O2 ppmvd @ 3% O2
Boiler #1 (60.243 MMBTU/hr) 70 0.60
Boiler #2 (60.243 MMBTU/hr) 70 0.00 (ND)

II.B.4.b Condition:

Emissions of NOx shall be no greater than 3.3 lbs/hour and 45 ppm for each paper product boiler.
[Origin: DAQE-AN141070018-23 and SIP Section IX, Part H.12.n.i]. [R307-110-17, R307-401-8]

34
II.B.4.b.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested every three years based on the date of the previous test.
The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Test protocol
shall be approved by the Director.

(c) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director.
An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.

(d)Methods
(1) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, or 7E, or other EPA approved testing
methods as acceptable to the Director shall be used to determine the NOx emission rate.
(2) 40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods as acceptable to
the Director shall be used to determine the volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.

(f) Production Rate During Testing.
(1) The production rate during all compliance testing shall be no less than 90% of the maximum
production achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum production rate achieved during operation. If the test is passed, the new
maximum production rate shall be 110% of the tested achieved rate. This new allowable
maximum production rate shall remain in effect until successfully tested at the higher rate.

II.B.4.b.2 Recordkeeping:

Results of all stack testing shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.b.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. The submittal shall clearly identify results and indicate compliance status.
The annual compliance certification required by Provision L in Section I of this permit shall use
the most recent test results as a basis for stating compliance status for this limitation.

Status In compliance – The latest stack test was conducted on June 5-10, 2023. The results of the stack
test are as follows:

35
Stack Test Summary

Paper Product Boilers NOx Limit (lb/hr) NOx Results (lb/hr)
Boiler #1 (60.243 MMBTU/hr) 3.3 3.0
Boiler #2 (60.243 MMBTU/hr) 3.3 2.4
ppmvd @ 3% O2 ppmvd @ 3% O2
Boiler #1 (60.243 MMBTU/hr) 45 43.3
Boiler #2 (60.243 MMBTU/hr) 45 43.16

II.B.4.c
Condition:

The Back-up Boiler may only be used during periods when a permitted boiler is taken out of service.
The Back-up Boiler and the permitted boiler shall not be operated at the same time, except for periods of
post-repair readiness checks and initial start-up of the permitted boiler. The Back-up Boiler shall only
burn natural gas or propane. The Back-up Boiler capacity shall not exceed the boiler capacity and the
boiler emission limits of a paper product boiler. [Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.4.c.1 Monitoring:

Emission testing for the Back-up Boiler shall not be required and emission rates shall be
guaranteed by vendor documentation. Records required for this permit condition will serve as
monitoring.

II.B.4.c.2 Recordkeeping:

Records of the vendor guaranteed emissions rates and documentation of time and date a
permitted boiler as well as the Back-up Boiler are put into service or taken out of service.
Records shall be maintained in accordance with Section I.S.1 of this permit.

II.B.4.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: N/A – The back-up boiler has not been installed to date. There are no plans to install the back-up
boiler. A rental boiler will be used if a back-boiler is required.

II.B.4.d Condition:

The permittee shall record the total amount of each steam generating unit fuel delivered to the plant
property during each calendar month. [Origin: 40 CFR 60.48c(g)(3)]. [40 CFR 60 Subpart Dc]

II.B.4.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

36
II.B.4.d.2 Recordkeeping:

Records of the amount of natural gas or propane to each steam generating unit during each
calendar month shall be maintained as described in Provision I.S.1 of this permit.

II.B.4.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Natural gas records are kept in the compliance logbook and spreadsheet.

II.B.4.e Condition:

The permittee shall comply with all applicable requirements of 40 CFR 60 Subpart A. [Origin: 40 CFR
60 Subpart A]. [40 CFR 60 Subpart A]

II.B.4.e.1 Monitoring:

Records required for this permit condition will serve as monitoring. [40 CFR 60 Subpart A]

II.B.4.e.2 Recordkeeping:

All applicable records and notifications required by 40 CFR 60 Subpart A shall be maintained in
accordance with provision I.S.1 of this permit. [40 CFR 60 Subpart A]

II.B.4.e.3 Reporting:

The permittee shall comply with the reporting requirements in Section I of this permit and any
additional reporting and notification requirements of 40 CFR 60 Subpart A.
[40 CFR 60 Subpart A]

Status: In compliance – All applicable requirements of 40 CFR 60 Subpart A have been included in this
permit.

II.B.4.f Condition:

Emission of PM2.5 shall not exceed 0.9 lb/hr for each paper product boiler. [Origin: DAQE-
AN141070018-23 and SIP Section IX, Part H.12.n.i]. [R307-401-8, R307-110-17]

II.B.4.f.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested every three years based on the date of the previous test.
The initial compliance test shall be performed as soon as possible but no later than 180 days
after the startup of a boiler. Initial PM2.5 compliance test for the existing boilers will be
completed in conjunction with the next paper line stack test to be performed for CO and NOx.
The Director may require testing at any time.
37
(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Test protocol
shall be approved by the Director.

(c) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director.
An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.

(d)Methods: Total PM2.5 shall be the sum of filterable PM2.5 and condensable PM2.5
(1) The following methods shall be used to measure filterable particulate emissions: 40 CFR 51,
Appendix M, Methods 201A, or other EPA approved testing methods as acceptable to the
Director. If other approved testing methods are used which cannot measure the PM2.5 fraction of
the filterable particulate emissions, all of the filterable particulate emissions shall be considered
PM2.5
(2) The following methods shall be used to measure condensable particulate emissions: 40 CFR
51, Appendix M, Method 202 or other EPA approved testing method as acceptable to the
Director.
(3) The following methods shall be used to measure total particulate emissions: 40 CFR
60.8(b)(2), Appendix A, including EPA-approved testing method OTM37.
(4) 40 CFR 60, Appendix A, Method 2, or other EPA approved testing methods as acceptable to
the Director shall be used to determine the volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation. The filterable particulate emissions shall be added to
the condensable particulate emissions for compliance demonstration.

(f) Production Rate During Testing.
(1) The production rate during all compliance testing shall be no less than 90% of the maximum
production achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum production rate achieved during operation. If the test is passed, the new
maximum production rate shall be 110% of the tested achieved rate. This new allowable
maximum production rate shall remain in effect until successfully tested at the higher rate.

II.B.4.f.2 Recordkeeping:

Results of all stack testing shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.f.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. The submittal shall clearly identify results and indicate compliance status.
The annual compliance certification required by Provision L in Section I of this permit shall use
the most recent test results as a basis for stating compliance status for this limitation.

38
Status: In compliance – The latest stack test was conducted on April 10-15, 2023. The results of the stack
test are as follows:

Stack Test Summary

Paper Products Boilers PM 2.5 Emissions Limit
(lb/hr)
PM 2.5 Emissions Limit (lb/hr)
Boiler #1 (60.243 MMBTU/hr) 0.9 0.060
Boiler #2 (60.243 MMBTU/hr) 0.9 0.078

II.B.4.g Condition:

Filterable and condensable PM2.5 shall not exceed 0.74 lb/hr for each utility boiler. [Origin:
DAQE-AN141070018-23 and SIP Section IX, Part H.12.n.i]. [R307-401-8, R307-110-17]

II.B.4.g.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested every three years based on the date of the previous test.
The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Test protocol
shall be approved by the Director.

(c) Sample Location - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director.
An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.

(d)Methods: Total PM2.5 shall be the sum of filterable PM2.5 and condensable PM2.5
(1) The following methods shall be used to measure filterable particulate emissions: 40 CFR 51,
Appendix M, Methods 201A, or other EPA approved testing methods as acceptable to the
Director. If other approved testing methods are used which cannot measure the PM2.5 fraction of
the filterable particulate emissions, all of the filterable particulate emissions shall be considered
PM2.5.
(2) The following methods shall be used to measure condensable particulate emissions: 40 CFR
51, Appendix M, Method 202 or other EPA approved testing method as acceptable to the
Director.
(3) The following methods shall be used to measure total particulate emissions: 40 CFR
60.8(b)(2), Appendix A, including EPA-approved testing method OTM 37.
(4) 40 CFR 60, Appendix A, Method 2, or other EPA approved testing methods as acceptable to
the Director shall be used to determine the volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
39
specified units of the emission limitation. The filterable particulate emissions shall be added to
the condensable particulate emissions for compliance demonstration.

(f) Production Rate During Testing.
(1) The production rate during all compliance testing shall be no less than 90% of the
maximum production achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum production rate achieved during operation. If the test is passed, the new
maximum production rate shall be 110% of the tested achieved rate. This new allowable
maximum production rate shall remain in effect until successfully tested at the higher rate.

II.B.4.g.2 Recordkeeping:

Results of all stack testing shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.g.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. The submittal shall clearly identify results and indicate compliance status.
The annual compliance certification required by Provision L in Section I of this permit shall use
the most recent test results as a basis for stating compliance status for this limitation.

Status: In compliance – The latest stack test was conducted on June 5-10, 2023. The results of the stack
test are as follows:
Stack Test Summary

Paper Products Boilers Filterable and Condensable
PM2.5 Limit (lb/hr)
Filterable and Condensable
PM2.5 Results (lb/hr)
Boiler #1 (60.243 MMBTU/hr) 0.74 0.37
Boiler #2 (60.243 MMBTU/hr) 0.74 0.12

II.B.4.h Condition:

Emissions of CO shall be no greater than 4.06 lb/hr and 156 ppm for each utility boiler. [Origin: DAQE-
AN141070018-23]. [R307-401-8]

II.B.4.h.1 Monitoring:

Stack testing shall be performed as specified below:

(a) Frequency. Emissions shall be tested every three years based on the date of the previous test.
The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Test protocol
shall be approved by the Director.

40
(c) Sample Point - the emission point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the Director.
An Occupational Safety and Health Administration (OSHA) or Mine Safety and Health
Administration (MSHA) approved access shall be provided to the test location.

(d) Methods
(1) 40 CFR 60, Appendix A, Method 10, or other EPA approved testing methods as acceptable
to the Director shall be used to determine CO emissions;
(2) 40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods as acceptable to
the Director shall be used to determine stack gas velocity and volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.

(f) Production Rate During Testing.
(1) The production rate during all compliance testing shall be no less than 90% of the maximum
production achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum production rate achieved during operation. If the test is passed, the new
maximum production rate shall be 110% of the tested achieved rate. This new allowable
maximum production rate shall remain in effect until successfully tested at the higher rate.

II.B.4.h.2 Recordkeeping:

Results of all stack testing shall be recorded and maintained in accordance with the associated
test method and Provision I.S.1 of this permit.

II.B.4.h.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. The submittal shall clearly identify results and indicate compliance status.
The annual compliance certification required by Provision L in Section I of this permit shall use
the most recent test results as a basis for stating compliance status for this limitation.

Status: In compliance – The FEM Care boiler came on-line on April 20, 2023. The Family Care boiler is
currently under construction. The stack test, for the FEM Care boiler, was conducted on June 5-
10, 2023. The stack test results for the FEM Care are as follows:

Stack Test Summary

FEM Care Boiler CO Limit CO Results
4.06 (lb/hr) 0.00 (lb/hr), (ND)
156 (ppm) 0.00 (ppm), (ND)

II.B.4.i Condition:

Emissions of NOx shall be no greater than 1.80 lbs/hour and 10 ppm corrected to for each utility boiler.
[Origin: DAQE-AN141070018-23 and SIP Section IX, Part H.12.n.i]. [R307-110-17, R307-401-8]

41
II.B.4.i.1 Monitoring:

Stack testing shall be performed as specified here:

(a) Frequency. Emissions shall be tested every three years based on the date of the previous test.
The Director may require testing at any time.

(b) Notification. At least 30 days before the test, the source shall notify the Director of the date,
time, and place of testing and provide a copy of the test protocol. The source test protocol shall
outline the proposed test methodologies, stack to be tested, and procedures to be used. The
source shall attend a pretest conference if determined necessary by the Director. Testing
protocol shall be approved by the Director.

(c) Sample location: The emission sample point shall conform to the requirements of 40 CFR
60, Appendix A, Method 1, or other EPA-approved testing method, as acceptable to the
Director. In addition, Occupational Safety and Health Administration (OSHA) or Mine Safety
and Health Administration (MSHA) approved access shall be provided to the test location.

(d) Methods.
(1) 40 CFR 60, Appendix A, Method 7, 7A, 7B, 7C, 7D, or 7E, or other EPA approved testing
methods as acceptable to the Director shall be used to determine the NOx emission rate.
(2) 40 CFR 60, Appendix A, Method 2 or other EPA approved testing methods as acceptable to
the Director shall be used to determine the volumetric flow rate.

(e) Calculations. To determine mass emission rates (lb/hr, etc.) the pollutant concentration as
determined by the appropriate methods above shall be multiplied by the volumetric flow rate
and any necessary conversion factors determined by the Director to give the results in the
specified units of the emission limitation.

(f) Production Rate during Testing.
1) The production rate during all compliance testing shall be no less than 90% of the maximum
production achieved in the previous three (3) years.
(2) Until three years of data is available, compliance testing shall be conducted at no less than
90% of the maximum achieved production rate. If the test is passed, the new maximum
allowable production rate shall be 110% of the tested achieved rate. This new allowable
maximum production rate shall remain in effect until successfully tested at the higher rate.

II.B.4.i.2 Recordkeeping:

Results of all stack testing shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.4.i.3 Reporting:

The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. The submittal shall clearly identify results and indicate compliance status.
The annual compliance certification required by Provision L in Section I of this permit shall use
the most recent test results as a basis for stating compliance status for this limitation.

42
Status: In compliance – The FEM Care boiler came on-line on April 20, 2023. The Family Care boiler is
currently under construction. The stack test, for the FEM Care boiler, was conducted on June 5-
10, 2023. The stack test results for FEM Care are as follows:

Stack Test Summary

FEM Care Boiler NOx Limit NOx Results
1.80 (lbs/hr) 0.39 (lbs/hr)
10 (ppm) 8.37 (ppm)

II.B.4.j Condition:

The permittee shall implement an Emissions Minimization Plan (Boiler Plan) that describes
procedures for operating and maintaining the boilers, including associated air pollution control and
monitoring equipment, during events of startup and shutdown. The Boiler Plan shall define the startup
and shutdown events and shall contain the minimum requirements as follows:
(1) Startup begins when natural gas in supplied to the boiler(s) with the intent of combusting the fuel
to generate steam. Startup conditions end within thirty minutes of natural gas being supplied to the
boiler(s).

(2) Shutdown begins with the initiation of the stop sequence of the boiler until the cessation of natural
gas flow to the boiler(s). [Origin: SIP Section IX, Part H.13.n.ii]. [R307-110-17]

II.B.4.j.1 Monitoring:

Recordkeeping requirements required in this permit condition shall serve as monitoring
requirement.

II.B.4.j.2 Recordkeeping:

The permittee shall maintain records demonstrating that the procedures in the Boiler Plan were
followed.

II.B.4.j.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.
Status: In compliance – The Emission Minimization Plan (EMP), regarding the boilers, was implemented
on February of 2024.

II.B.5 Conditions on Paper Product Converting Operation

43
II.B.5.a Condition:

The permittee shall install, calibrate, maintain, and operate a monitoring device for the continuous
measurement of the change in pressure of the gas stream through the paper making converting operation
drum filters. The monitoring device shall be certified by the manufacturer to be accurate within plus or
minus one inch of water gauge and shall be calibrated on an annual basis in accordance with the
manufacturer's instructions. Continuous recording for the monitoring device is not required. When the
paper making converting operation drum filters are in operation and venting to the atmosphere the
pressure drop shall be no less than 1.0 inch’s water gauge (w.g.) for more than five minutes in any 60-
minute period except during start-up and shut-down of the converting dust control fans.

After a media change the pressure drop shall be less than 1.0 inches of water gauge. The permittee is not
restricted to a minimum pressure drop across the control device for the first 96 consecutive hours after
replacement of a filter. This seasoning-in period shall last no more than 96 hours. [Origin: DAQE-
AN141070018-23]. [R307-401-8]

II.B.5.a.1 Monitoring:

The permittee shall monitor the drum filter pressure drop once per operating day.

II.B.5.a.2 Recordkeeping:

Records of the pressure drop shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.5.a.3 Reporting:

There are no other reporting requirements for this provision except those specified in Section I
of this permit.

Status In compliance – The company has installed continuous pressure drop monitors on both sides of
the three drum filters for the paper making converting operation. The line will automatically shut
down if the pressure drop becomes too low. The company maintains records which show pressure
drop readings, and fan on/off. The pressure drops were greater than 1 inch of water gauge at time
of this inspection.

44
II.B.5.b Condition:

(1) The permittee shall not apply graphic art materials with a VOC content greater than the amounts
specified in Table 1 unless the permittee uses an add-on control device as specified in
R307-351-6

TABLE 1

VOC Limits (values in grams of VOC per liter, minus water and exempt compounds (compounds
that are not defined as VOC in R307-101-2)

Graphic Art Material VOC Limits (g/L)

Adhesive 150
Coating 300
Flexographic Fluorescent Ink 300
Flexographic Ink-Non-Porous Substrate 300
Flexographic Ink-Porous Substrate 225
Gravure Ink 300
Letterpress Ink 300
Offset Lithographic Ink 300
Heatset Web Offset Lithographic ink 300

Heatset Web Offset Lithographic Ink:
Used on Book Presses and Presses
Less Than 22 Inches in Diameter 400
Used on Presses with Potential to Emit Less Than 10 Tons/yr 400
Nonmembrane roof installation/repair 300

(2) The permittee shall use cleaning materials with a VOC composite vapor pressure of less than 10
mm Hg at 68 degrees Fahrenheit or cleaning materials containing less than 50 percent VOC by
weight.

(3) The permittee shall implement control techniques and work practices at all times to reduce VOC
emissions. Control techniques and work practices include:

(a) Keeping cleaning materials, used shop towels, and solvent wiping cloths in closed containers; and

(b) Minimizing spills of VOC-containing cleaning materials.
[Origin: R307-351]. [R307-351]

II.B.5.b.1 Monitoring:

The recordkeeping requirement in this permit condition will serve as monitoring.
45
II.B.5.b.2 Recordkeeping:

The permittee shall maintain records that demonstrate compliance with R307-351. Records shall
include, but are not limited to, inventory and product data sheets of all graphic arts materials and cleaning
solutions subject to R307-351.

II.B.5.b.3 Reporting:

There are no other reporting requirements for this provision except those specified in Section I of this
permit.

Status: N/A – Graphic art material, with VOCs, is currently not being used.

II.B.6 Conditions on NSPS CI RICE.

II.B.6.a Condition:

CI RICE shall be operated and maintained to achieve the emission standards as required in 40 CFR
60.4205(b). Further, the engine shall be operated and maintained according to the manufacturer's
emissions-related written instructions, over the entire life of the engine. The permittee may only change
those settings that are permitted by the manufacturer. The permittee shall also meet the requirements of
40 CFR 89, as they apply. [Origin: 40 CFR 60.4206, 40 CFR 60.4211(a)(1-3)]. [40 CFR 60 Subpart IIII]

II.B.6.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.6.a.2 Recordkeeping:

Records demonstrating proper operation and maintenance shall be maintained. Records shall be
maintained in accordance with Provision I.S.1 of this permit.

II.B.6.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – According to the P&G records, all of the on-site diesel engines have Certificates
of Conformity (certified). The engines are maintained and operated as certified engines. Diesel
engine maintenance is performed annually. Maintenance was performed, by Wheeler Power
Systems, on all of the diesel generators in November and December of 2023.

II.B.6.b Condition:

(1) There is no time limit on the use of emergency stationary ICE in emergency situations.

(2) Each emergency CI RICE may be operated for the purpose of maintenance checks and readiness
testing, provided that the tests are recommended by Federal, State, or local government, the
manufacturer, the vendor, or the insurance company associated with the engine. Maintenance checks
and readiness testing is limited to 100 hours per year. There is no time limit on use for emergency
46
situations. The permittee may petition the Administrator for approval of additional hours to be used for
maintenance checks and readiness testing, but a petition is not required if records are maintained
indicating that Federal, State, or local standards require maintenance and testing beyond 100 hours per
year.

(3)The generator may operate up to 50 hours per year in non-emergency situations, but those 50 hours
are counted towards the 100 hours per year provided for maintenance and testing. The 50 hours per year
for non-emergency situations cannot be used for peak shaving or to generate income for a facility to
supply power to an electric grid or otherwise supply non-emergency power as part of a financial
arrangement with another entity. Any operation other than emergency operation, maintenance and
testing, and operation in non-emergency situations for 50 hours per year is prohibited. [Origin: 40 CFR
60.4211(f) and DAQE-AN141070010A-18]. [40 CFR 60 Subpart IIII]

II.B.6.b.1 Monitoring:

The permittee shall install a non-resettable hour meter for each diesel-fired backup engine.

II.B.6.b.2 Recordkeeping:

Records of the time of operation shall be kept on a monthly basis. Records shall indicate the
reason for each operation, such as maintenance or emergency related. If emergency related, the
nature of the emergency shall be recorded. If maintenance and testing beyond 100 hours per
year are required by Federal, State, or local standards, records of these standards shall also be
kept. [40 CFR 60.4211(f) and 40 CFR 60.4214(b)].

II.B.6.b.3 Reporting:

The permittee shall submit an annual report as specified in 40 CFR 60.4211(d) if the CI ICE
with a maximum engine power more than 100 hp that operates for the purpose specified in 3(a)
of this permit conditions.

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – According to P&G maintenance records, the emergency diesel engines are
maintenance checked at least every month for approximately 30 minutes. The four fire pump
engines are exercised weekly for about 30 minutes. All emergency engines have non-resettable
hour meters.

Generator hours of operation for 2023:

Equipment Emergency
Hours
Maintenance
Hours
Total Hours
Emergency Generator 1,214 hp <1.0 3.25 4.25
Fire Pumps
West 375 hp (Building 106) 1.0 22.75 23.75
East 375 hp 0.0 23 23
West 399 hp (Building 107) 0.0 21.08 21.08
East 399 hp 1.0 20.67 21.67

47
II.B.6.c Condition:

The permittee shall purchase and use diesel fuel for CI RICE that meets the requirements of 40 CFR
1090.305 for nonroad diesel fuel:
(1) Sulfur content no greater than 15 ppm (0.0015 percent) by weight
(2) A minimum cetane index of 40 or a maximum aromatic content of 35 volume percent [Origin: 40
CFR 60.4207(b) and AO DAQE-AN141070018-23]. [40 CFR 60 Subpart IIII and R307-401-8]

II.B.6.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.6.c.2 Recordkeeping:

For each fuel load received, the permittee shall maintain either fuel receipt records or other
documentation showing fuel meets the specifications of 40 CFR 80.510(b). The permittee shall
maintain documentation demonstrating compliance with the condition.

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.6.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – According to the HF Sinclair Certificate of Analysis, dated February 23, 2024,
only Ultra Low Sulfur Diesel (ULSD) fuel with a Cetane Index > 40 is deliver to the facility.

II.B.7 Conditions on NSPS CI RICE Non-Fire Pump Engines.

II.B.7.a Condition:

For all affected emission units, except those that are modified, reconstructed, or removed from one
existing location and reinstalled at a new location, the permittee shall comply with paragraphs (1)
through (3).

(1) The permittee shall not install affected emission units (excluding fire pump engines) that do not meet
the applicable requirements for 2007 model year engines.

(2) The permittee shall not install affected emission units (excluding fire pump engines) with a
maximum engine power of less than 19 KW (25 HP) that do not meet the applicable requirements for
2008 model year engines.

(3) The permittee shall not import affected emission units with a displacement of less than 30 liters per
cylinder that do not meet the applicable requirements specified in paragraphs (a) and (b) of this
condition.
[Origin: 40 CFR 60.4208]. [40 CFR 60 Subpart IIII, 40 CFR 63 Subpart ZZZZ]

48
II.B.7.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.7.a.2 Recordkeeping:

The permittee shall keep records of the install date of each affected emission unit and the
applicable requirements under 40 CFR 60 Subpart IIII. Records shall be maintained as described
in Provision I.S.1 of this permit.

II.B.7.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status:

In compliance – The 1,214 hp emergency generator purchased in 2008, is considered to be new
install. The manufacturers certification is on the frame.

II.B.7.b Condition:

2007 model year and later emergency affected emission units with a displacement of less than 30 liters
per cylinder that are not fire pump engines shall comply with the emission standards for new nonroad CI
RICE in 40 CFR 60.4202, for all pollutants, for the same model year and maximum engine power for
their 2007 model year and later emergency stationary CI RICE. If the permittee conducts performance
tests in-use on emergency stationary CI RICE with a displacement of less than 30 liters per cylinder they
shall meet the not-to-exceed (NTE) standards as indicated in 40 CFR 60.4212. [Origin: 40 CFR 60
Subpart IIII]. [40 CFR 60.4205(b), 40 CFR 60.4205(e), 40 CFR 60.4205(f), 40 CFR 63 Subpart ZZZZ]

II.B.7.b.1 Monitoring:

The permittee shall comply by purchasing an engine certified to the emission standards in 40
CFR 60.4205(b) for the same model year and maximum engine power. The engine must be
installed and configured according to the manufacturer's emission-related specifications.
(Origin: 40 CFR 60.4211(c)).

II.B.7.b.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.7.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The 1,214 hp engine is a Tier 2 engine that is newer than 2007 and that complies
with the Subpart IIII standards.

49
II.B.8 Condition on NSPS CI RICE Emergency Fire Pump Engines.

II.B.8.a Condition:

Affected emission units with a displacement of less than 30 liters per cylinder shall comply with the
emission standards in Table 4 of 40 CFR 60 Subpart IIII, for all pollutants. Modified or reconstructed
affected emission units shall meet the emission standards in Table 4 of 40 CFR 60 Subpart IIII
applicable to the model year, maximum engine power, and displacement of the modified or
reconstructed engine. If the permittee conducts performance tests in-use on emergency stationary CI
RICE with a displacement of less than 30 liters per cylinder they shall meet the not-to-exceed (NTE)
standards as indicated in 40 CFR 60.4212. [Origin: 40 CFR 60 Subpart IIII]. [40 CFR 60.4205(c), 40
CFR 60.4205(e), 40 CFR 60.4205(f), 40 CFR 63 Subpart ZZZZ]

II.B.8.a.1 Monitoring:

For affected emission units that are manufactured prior to the model years in Table 3 of 40 CFR
60 Subpart IIII, the permittee shall demonstrate compliance according to one of the methods
specified in paragraphs (a) through (e) of this paragraph.
(a) Purchasing an engine certified according to the emission standards for the same model
year and maximum engine power as described in 40 CFR parts 1039 and 1042, as
applicable. The engine must be installed and configured according to the manufacturer's
specifications.
(b) Keeping records of performance test results for each pollutant for a test conducted on a
similar engine. The test must have been conducted using the same methods specified in 40 CFR
60 Subpart IIII and these methods must have been followed correctly.
(c) Keeping records of engine manufacturer data indicating compliance with the standards.
(d) Keeping records of control device vendor data indicating compliance with the standards.
(e) Conducting an initial performance test to demonstrate compliance with the emission
standards according to the requirements specified in 40 CFR 60.4212, as applicable. (Origin: 40
CFR 60.4211(b))

For affected emission units that are manufactured during or after the applicable model years for
fire pump engine power rating in Table 3 of 40 CFR 60 Subpart IIII, the permittee shall comply
by purchasing an engine certified to the emission standards in 40 CFR 60.4205(c) for the same
model year and maximum (or in the case of fire pumps, NFPA nameplate) engine power. The
engine must be installed and configured according to the manufacturer's emission-related
specifications. (Origin: 40 CFR 60.4211(c)).

II.B.8.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.8.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: N/A – All installed fire pump engines are new installs and have the manufacturers certification on
the frame. See status of condition II.B.6.a.

50
II.B.9 Condition on Gasoline Storage Tank.

II.B.9.a Condition:

For each gasoline storage tank with a throughput less than 10,000 gallons per month the permittee shall
allow gasoline to be handled in a manner that would not result in vapor releases to the atmosphere for
extended periods of time. Measures to be taken include, but are not limited to, the following:
(1) Minimize gasoline spills;
(2) Clean up spills as expeditiously as practicable;
(3) Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal
when not in use;
(4) Minimize gasoline sent to open waste collection systems that collect and transport gasoline to
reclamation and recycling devices, such as oil/water separators.

The permittee shall also, at all times, operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. Determination of whether such operation and
maintenance procedures are being used will be based on information available to the Administrator
which may include, but is not limited to, monitoring results, review of operation and maintenance
procedures, review of operation and maintenance records, and inspection of the source. [Origin:40 CFR
63 Subpart CCCCCC]. [40 CFR 63.11116 and .11115]

II.B.9.a.1 Monitoring:

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130]

Records required for this permit condition will serve as monitoring.

II.B.9.a.2 Recordkeeping:

The permittee shall, upon request of the Director, demonstrate their monthly throughput is less
than 10,000 gallons within 24 hours of the request. Records shall be maintained in accordance
with Provision I.S.1 of this permit. A log shall be maintained to document records in accordance
with 40 CFR 63.11125. [40 CFR 63.11111(e) and 63.11116(b)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 3 of 40 CFR 63 Subpart CCCCCC. [40 CFR 63.11130].

II.B.9.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – P&G operates one 500-gallon gasoline tank. According to the monthly Fuel
Delivery Usage records there was 247 gallons (gals) of gasoline throughput in 2023, and 411 gals
of throughput in 2024. Procedures are in place to minimize and to clean up fuel spills. All seals
and coverings were in place at time of the inspection.

51
II.B.10 Conditions on NSPS SI Emergency Engine

II.B.10.a Condition:

(1) The permittee shall comply with the emission standards in Table 1 of 40 CFR 60 Subpart JJJJ.

(2) The permittee shall operate and maintain affected emission units that achieve the emission standards
as required in this condition over the entire life of the engine.

(3) The air-to-fuel ratio (AFR) controller shall be maintained and operated appropriately in order to
ensure proper operation of affected emission units and control device to minimize emissions at all times.
[40 CFR 63 Subpart ZZZZ, 40 CFR 60.4233(d) and (e), 40 CFR 60.4234, 40 CFR 60.4243(g)]. [40 CFR
60 Subpart JJJJ]

II.B.10.a.1 Monitoring:

The permittee shall purchase an engine certified according to procedures specified in 40 CFR
Subpart JJJJ, for the same model year and demonstrating compliance according to one of the
methods specified in paragraph (a) and (b).

(a) If the permittee operates and maintains the certified stationary SI internal combustion engine
and control device according to the manufacturer's emission-related written instructions, the
permittee shall keep records of conducted maintenance to demonstrate compliance, but no
performance testing is required. The permittee shall also meet the requirements as specified in
40 CFR part 1068, subparts A through D, as they apply. If the permittee adjusts engine settings
according to and consistent with the manufacturer's instructions, the affected emission unit will
not be considered out of compliance.

(b) If the permittee does not operate and maintain the certified stationary SI internal combustion
engine and control device according to the manufacturer's emission-related written instructions,
the engine will be considered a non-certified engine, and the permittee shall demonstrate
compliance according to (b)(1) or (b)(2) below.

(1) If the affected emission unit is less than 100 HP, the permittee shall keep a maintenance plan
and records of conducted maintenance to demonstrate compliance and shall, to the extent
practicable, maintain and operate the engine in a manner consistent with good air pollution
control practice for minimizing emissions, but no performance testing is required.

(2) If the affected emission unit is greater than 500 HP, the permittee shall keep a maintenance
plan and records of conducted maintenance to demonstrate compliance and shall, to the extent
practicable, maintain and operate the engine in a manner consistent with good air pollution
control practice for minimizing emissions. In addition, the permittee shall conduct an initial
performance test within 1 year of engine startup and conduct subsequent performance testing
every 8,760 hours or 3 years, whichever comes first, thereafter to demonstrate compliance.
(40 CFR 60.4243(b)(1))

II.B.10.a.2 Recordkeeping:

For each affected emission unit, the permittee shall keep records of the information in
paragraphs
52
(b) through (d).

(a) All notifications submitted to comply with this condition and all documentation
supporting any notification.

(b) Maintenance conducted on the engine.

(c) If the stationary SI ICE is a certified engine, documentation from the manufacturer that
the engine is certified to meet the emission standards and information as required in 40
CFR parts 1048, 1054, and 1060, as applicable.

(d) If the stationary SI ICE is not a certified engine or is a certified engine operating in a
non- certified manner and subject to (a)(2) of monitoring, documentation that the
engine meets the emission standards. (Origin: 40 CFR 60.4245(a))

Records and results of monitoring shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.10.a.3 Reporting:

For stationary SI ICE that are subject to performance testing, the permittee shall submit a copy
of each performance test as conducted in 40 CFR 60.4244 within 60 days after the test has been
completed. (40 CFR 60.4245(d))
There are no additional reporting requirements for this provision except those specified in
Section I of this permit.
Status: In compliance – The 54 hp natural gas fired emergency generator was last serviced, by Wheeler,
on November 20, 2023. The engine is considered to be non-certified. The 1006 hp natural gas fired
emergency generator is still under construction. See status of condition II.A.

II.B.10.b Condition:

The permittee shall operate the emergency affected emission unit according to the requirements in
paragraphs (1) through (3). In order for the engine to be considered an emergency stationary ICE under
40 CFR 60 Subpart JJJJ, any operation other than emergency operation, maintenance and testing, and
operation in non-emergency situations for 50 hours per year, as described in (1) through (3), is
prohibited. If the engine is not operated in accordance with paragraphs (1) through (3), it will not be
considered an emergency engine and shall meet all requirements for non-emergency engines.

(1) There is no time limit on the use of emergency stationary ICE in emergency situations.

(2) Emergency stationary ICE may be operated for the purposes specified in paragraph (a) for a
maximum of 100 hours per calendar year. Any operation for non-emergency situations as allowed by
paragraph (3) counts as part of the 100 hours per calendar year allowed by this paragraph (2).

(a) Emergency stationary ICE may be operated for maintenance checks and readiness testing, provided
that the tests are recommended by Federal, State or local government, the manufacturer, the vendor, the
regional transmission organization or equivalent balancing authority and transmission operator, or the
insurance company associated with the engine. A petition for approval of additional hours to be used for
maintenance checks and readiness testing is not required if the permittee maintains records indicating
53
that Federal, State, or local standards require maintenance and testing of emergency ICE beyond 100
hours per calendar year.

(3) Emergency engines may operate up to 50 hours per calendar year in non-emergency situations. The
50 hours of operation in non-emergency situations are counted as part of the 100 hours per calendar year
for maintenance and testing provided in paragraph (2). Except as provided in paragraph (3)(a), the 50
hours per calendar year for non-emergency situations cannot be used for peak shaving or non-
emergency demand response, or to generate income for the permittee to an electric grid or otherwise
supply power as part of a financial arrangement with another entity.

(a) The 50 hours per year for non-emergency situations can be used to supply power as part of a
financial arrangement with another entity if all of the following conditions are met:

(i) The engine is dispatched by the local balancing authority or local transmission and distribution
system operator;

(ii) The dispatch is intended to mitigate local transmission and/or distribution limitations so as to avert
potential voltage collapse or line overloads that could lead to the interruption of power supply in a local
area or region.

(iii) The dispatch follows reliability, emergency operation or similar protocols that follow specific
NERC, regional, state, public utility commission or local standards or guidelines.

(iv) The power is provided only to the permittee itself or to support the local transmission and
distribution system.

(v) The permittee identifies and records the entity that dispatches the engine and the specific NERC,
regional, state, public utility commission or local standards or guidelines that are being followed for
dispatching the engine. The local balancing authority or local transmission and distribution system
operator may keep these records on behalf of the permittee.
[40 CFR 63 Subpart ZZZZ, 40 CFR 60.4243(d), 40 CFR 60.4243(e)]. [40 CFR 60 Subpart JJJJ]

II.B.10.b.1 Monitoring:

The permittee shall install a non-resettable hour meter upon startup of the emergency engine.

II.B.10.b.2 Recordkeeping:

The permittee shall keep records of the hours of operation of the affected emission unit that is
recorded through the non-resettable hour meter.

The permittee shall document how many hours are spent for emergency operation, including
what classified the operation as emergency and how many hours are spent for non-emergency
operation. (40 CFR 60.4245(b))

Records shall be maintained as described in Provision I.S.1 of this permit.

54
II.B.10.b.3 Reporting:

The permittee shall submit an annual report as specified in 40 CFR 60.4245(e) if the SI ICE
with a maximum engine power more than 100 hp that operates for the purpose specified in 3(a)
of this permit conditions.

There are no other reporting requirements for this provision except those specified in Section I
of this permit.

Status: In compliance – According to P&G maintenance records, the 54 hp emergency natural gas
generator is maintenance checked every week for about 35 minutes. This engine conducts its own
maintenance check (Auto-Check). All on-site emergency engines have non-resettable hour meters.

Generator hours of operation for 2023:

Equipment Emergency
Hours
Maintenance
Hours
Total hours of
Operation
Emergency NG Generator
(54 hp)
0.0 30.08 30.08

II.B.10.c Condition:

Visible emissions shall be no greater than 10 percent opacity. [DAQE-AN141070018-23]. [R307-401-8]

II.B.10.c.1 Monitoring:

During any period that an emergency engine is operated for longer than 12 hours consecutively,
a visual observation of that generator's exhaust shall be made by an individual trained on the
observation procedures of 40 CFR 60, Appendix A, Method 22. If any visible emissions other
than steam are observed, then an opacity determination shall be performed in accordance with
40 CFR 60, Appendix A, Method 9, or other EPA-approved testing method, as acceptable to the
Director, by a certified visible emissions observer. If the engine continues to operate on
consecutive days following the initial observation, an opacity determination shall be performed
on a daily basis.

II.B.10.c.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A,
Method 9, 22, or other EPA-approved testing method, as acceptable to the Director, for each
determination shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.10.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – None of the on-site generators have ever operated for 12 consecutive hours.

55
II.B.11 Conditions on Assembled Paper Product A Drum Filters and Baghouse

II.B.11.a Condition:

The emissions from the assembled paper product A converting operation shall be routed to the
assembled paper product A drum filters and the baghouse. The assembled paper product A drum filters
and the assembled paper product A baghouses shall be operated and maintained in accordance with the
manufacturer's specifications. The drum filters and baghouses shall be equipped with gauges or meters,
which indicates the pressure drop across the control device. The pressure gauges or meters shall be
located such that an inspector/operator can safely read the indicators at any time.

The drum filters and baghouses while in operation and venting to the atmosphere shall be operated such
that the minimum pressure drop across each control device is greater than or equal to 0.5 inches of water
column except during start-up and shutdown of the fans. The permittee is not restricted to a minimum
pressure drop across the control device for the first 96 hours of operation after replacement of the filter
media on the drum filter or a bag(s) in the baghouse.

The operating pressure drop shall be maintained within the design conditions specified by the
manufacturer's performance warranty. [Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.11.a.1 Monitoring:

The permittee shall monitor the operating pressure drop across each drum filter and each
baghouse once per operating day. Continuous recording for the monitoring device is not
required.

II.B.11.a.2 Recordkeeping:

The permittee shall maintain an operating and maintenance log for each drum filter and each
baghouse along with the manufacturer's warranty. Records shall be maintained in accordance
with Provision I.S.1 of this permit.

II.B.11.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section 1 of this
permit.

Status: In compliance – The Assembled Paper Products A drum filters and baghouse are monitored for
pressure drops (pd). Records indicated that the pd across the drum filters and baghouse are
maintained equal to or above 0.5 inches of water column.

II.B.11.b Condition:

Visible emissions shall be no greater than 10 percent opacity. [DAQE-AN141070018-23]. [R307-401-8]

II.B.11.b.1 Monitoring:

The permittee shall conduct a monthly 1-minute visible emissions test of each affected source in
accordance with 40 CFR 60, Appendix A, Method 22.

56
If no visible emissions are observed in six consecutive monthly tests for any affected source, the
permittee may decrease the frequency of testing from monthly to semi-annually for the affected
source. If visible emissions are observed during any semi-annual test, the permittee shall resume
testing of that affected source on a monthly basis and maintain that schedule until no visible
emissions are observed for six consecutive monthly tests.

If no visible emissions are observed during two consecutive semi-annual tests for any affected
source, the permittee may decrease the frequency of testing from semi-annually to annually for
the affected source. If visible emissions are observed during any annual test, the permittee shall
resume testing of that affected source on a monthly basis and maintain that schedule until no
visible emissions are observed for six consecutive monthly tests.

If visible emissions are observed during any Method 22 test, a current Method 9 certified
observer shall conduct a:
(a) six minute test of opacity in accordance with 40 CFR 60, Appendix A Method 9 for point
sources, or
(b) one minute test of opacity with five second observation intervals in accordance with 40 CFR
51, Method 203C for fugitive emission sources
(c) the Method 9 or 203C test shall begin within 24 hours of any observation of visible
emission.

II.B.11.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A,
Method 9 and/or 22 for each determination shall be maintained in accordance with Provision
I.S.1 of this permit.

II.B.11.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Monthly visible emissions records (Fugitive or Smoke Emissions Inspection
Sheets) were reviewed at time of the inspection. These emission records were implemented in
April of 2023.

II.B.12 Conditions on Assembled Paper Product B RTO (FAM RTO)

II.B.12.a Condition:

The emissions from the FAM raw material tanks, curing oven, treatment from skid waste vent shall be
routed to the assembled paper product B RTO

The RTO shall be preheated and maintain the manufacturer recommended temperature for ideal
operation. The RTO's temperatures shall be maintained within the design condition specified by the
manufacturer's performance warranty. [Origin: DAQE-AN141070018-23]. [R307-401-8]

57
II.B.12.a.1 Monitoring:

The permittee shall monitor and record the RTO's temperatures once per operating
day. Continuous recording for the monitoring device is not required.
II.B.12.a.2 Recordkeeping:

The permittee shall maintain an operating and maintenance log for the RTO along with the
manufacturer's warranty. Records shall be maintained in accordance with Provision I.S.1 of this
permit.
II.B.12.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section 1 of this
permit.
Status: In compliance – The RTO’s temperature records have been maintained since November 2022,
when the Assembled Paper Products B RTO came on-line.

II.B.13 Conditions on Assembled Paper Product B Converting Baghouses/Fabric Filter

II.B.13.a Condition:

The emissions from the assembled paper products B converting operation shall be routed to the
assembled paper product B drum filters and baghouses. The assembled paper product B converting
drum filter and the assembled paper product B converting baghouses shall be operated and maintained
in accordance with the manufacturer's specifications. The drum filter and baghouses shall be equipped
with gauges or meters, which indicates the pressure drop across the control device. The pressure gauges
or meters shall be located such that an inspector/operator can safely read the indicators at any time.

The converting drum filter and baghouses while in operation and venting to the atmosphere shall be
operated such that the minimum pressure drop across each control device is greater than or equal to 0.5
inches of water column except during start-up and shutdown of the fans. The permittee is not restricted
to a minimum pressure drop across the control device for the first 96 hours of operation after
replacement of the filter media on the drum filter or a bag(s) in the baghouse.

The operating pressure drop shall be maintained within the design conditions specified by the
manufacturer's performance warranty. [Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.13.a.1 Monitoring:

The permittee shall monitor the operating pressure drop across the converting drum filter and
converting baghouse once per operating day. Continuous recording for the monitoring device
is not required.
II.B.13.a.2 Recordkeeping:

The permittee shall maintain an operating and maintenance log for the converting drum filter
and converting baghouse along with the manufacturer's warranty. Records shall be maintained
in accordance with Provision I.S.1 of this permit.

58
II.B.13.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section 1 of this
permit.

Status: In compliance – The Assembled Paper Products B converting drum filter and baghouse are
monitored for pressure drop (pd). Records were implemented in January 2022, when the
Assembled Paper Products B converting drum filter and baghouse came on-line. The pd readings
of the drum filter and baghouses were above 0.5 inches of water column at time of the inspection.

II.B.13.b Condition:

Visible emissions shall be no greater than 10 percent opacity. [DAQE-AN141070018-23]. [R307-401-8]

II.B.13.b.1 Monitoring:

The permittee shall conduct a monthly 1-minute visible emissions test of each affected source in
accordance with 40 CFR 60, Appendix A, Method 22.

If no visible emissions are observed in six consecutive monthly tests for any affected source, the
permittee may decrease the frequency of testing from monthly to semi-annually for the affected
source. If visible emissions are observed during any semi-annual test, the permittee shall resume
testing of that affected source on a monthly basis and maintain that schedule until no visible
emissions are observed for six consecutive monthly tests.

If no visible emissions are observed during two consecutive semi-annual tests for any affected
source, the permittee may decrease the frequency of testing from semi-annually to annually for
the affected source. If visible emissions are observed during any annual test, the permittee shall
resume testing of that affected source on a monthly basis and maintain that schedule until no
visible emissions are observed for six consecutive monthly tests.

If visible emissions are observed during any Method 22 test, a current Method 9 certified
observer shall conduct a:
(a) six minute test of opacity in accordance with 40 CFR 60, Appendix A Method 9 for point
sources, or
(b) one minute test of opacity with five second observation intervals in accordance with 40 CFR
51, Method 203C for fugitive emission sources
(c) the Method 9 or 203C test shall begin within 24 hours of any observation of visible
emission.

II.B.13.b.2 Recordkeeping:

Records of visual observations performed and data required by 40 CFR 60, Appendix A,
Method 9 and/or 22 each determination shall be maintained in accordance with Provision I.S.1
of this permit.

59
II.B.13.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Monthly visible emissions records (Fugitive or Smoke Emissions Inspection
Sheets) were reviewed at time of the inspection. These emission records, regarding the baghouses,
were implemented in January 2022. The emission records, regarding the drum filters, were
implemented in April 2023.

II.B.14 Conditions on Assembled Paper Product B Inks RTO

II.B.14.a Condition:

The VOC emissions from the Assembled Paper Products B solvent based product inks shall be routed to
the Assembled Paper Products B Inks RTO.

The Inks RTO shall be preheated and maintain the manufacturer recommended temperature for ideal
operation. The Inks RTO's temperatures shall be maintained within the design condition specified by the
manufacturer's performance warranty. [Origin: DAQE-AN141070018-23]. [R307-401-8]

II.B.14.a.1 Monitoring:

The permittee shall monitor and record the Assembled Paper Products B Inks RTO's
temperatures once per operating day. Continuous recording for the monitoring device is not
required.

II.B.14.a.2 Recordkeeping:

The permittee shall maintain an operating and maintenance log for the Assembled Paper
Products B Inks RTO along with the manufacturer's warranty. Records shall be maintained in
accordance with Provision I.S.1 of this permit.

II.B.14.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section 1 of this
permit.

Status: In compliance – The RTO’s temperature records have been maintained since February 2023,
when the Assembled Paper Products B Inks RTO came on-line.

II.C Emissions Trading.

Not applicable to this source.

II.D Alternative Operating Scenarios.

Not applicable to this source.

60
SECTION III: PERMIT SHIELD

The following requirements have been determined to be not applicable to this source in accordance with
Provision I.M, Permit Shield:

III.A 40 CFR 60, Subpart Dc (Emergency/standby package boiler exempt form 40 CFR 60, Subpart Dc)

This regulation is not applicable to the Permitted Source for the following reason(s): Each
emergency/standby package boiler shall be exempt for 40 CFR 60, Subpart Dc if it meets the definition
of a temporary boiler as defined in 60.41c.

III.B 40 CFR 60, Subpart Kb (Tanks exempt form 40 CFR 60, Subpart Dc)

This regulation is not applicable to the Tanks for the following reason(s): Each storage tank shall be
exempt for 40 CFR 60, Subpart Kb based on exemptions listed in 40 CFR 60.110b(b).

SECTION IV: ACID RAIN PROVISIONS

IV.A This source is not subject to Title IV.

This section is not applicable.

EMISSIONS INVENTORY: The 2023 Tri-Annual emission inventory was submitted on April 3, 2024.

Proctor & Gamble’s 2023 Tri-Annual Emission Inventory Summary:

Pollutants Total Tons /Year
PM10 40.84
PM2.5 40.83
SO2 1.79
NOx 51.35
VOC 19.37
CO 33.00

PREVIOUS ENFORCEMENT
ACTIONS Warning letter issued on April 12, 2022, (DAQC-373-22) for
submitting annual emission fee payment late (condition I.G.2) and
failure to conduct February 2022, solvent washer inspections
(condition II.B.1.h.2).

COMPLIANCE STATUS &
RECOMMENDATIONS

In compliance with the conditions of the Title V Operating Permit
300053003, dated April 11, 2023, and revised January 19, 2024.

HPV STATUS: N/A

COMPLIANCE ASSISTANCE: None

61
RECOMMENDATION FOR NEXT
INSPECTION:

Inspect as usual.

ATTACHMENT: VEO Form
Correspondence
Emergency Breakdown Report – Dated May 26, 2023

Joe Rockwell <[e-mail]>
Air Quality Inspection
4 messages
Shepherd, Dean <[e-mail]>Tue, May 7, 2024 at 5:48 AM
To: Joe Rockwell <[e-mail]>
Joe,

When we talked last week, I was not in the office and I failed to write down the day you were planning on completing our
annual inspection. I know we decided on 9:30 – 10:00am for a start time but was it Thursday the 9th or Friday the 10th?
Let me know.

Thanks,

DEAN SHEPHERD
Site Environmental Leader
P&G Box Elder Plant
5000 Iowa String Road | Bear River City, UT 84301
W(435) 279-1377 | M(801) 710-7716

Joe Rockwell <[e-mail]>Tue, May 7, 2024 at 10:12 AM
To: "Shepherd, Dean" <[e-mail]>
Hi Dean -
We decided on Friday May 10th to conduct the Inspection. And yes I will be there between 9:30 and 10:00.
Thanks,
Joe Rockwell | Environmental Scientist
Phone: [phone]

6/15/24, 3:41 PM State of Utah Mail - Air Quality Inspection
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1798394349089173375&simpl=msg-f:17983943490891733…1/3
195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Shepherd, Dean <[e-mail]>Tue, May 7, 2024 at 10:19 AM
To: Joe Rockwell <[e-mail]>
Joe,

Thank you for confirming. See you on Friday.

DEAN SHEPHERD
Site Environmental Leader
P&G Box Elder Plant
5000 Iowa String Road | Bear River City, UT 84301
W(435) 279-1377 | M(801) 710-7716

From: Joe Rockwell <[e-mail]>
Sent: Tuesday, May 7, 2024 10:13 AM
To: Shepherd, Dean <[e-mail]>
Subject: Re: Air Quality Inspection

[EXTERNAL]
[Quoted text hidden]
Joe Rockwell <[e-mail]>Tue, May 7, 2024 at 5:45 PM
To: "Shepherd, Dean" <[e-mail]>
👍
Joe Rockwell | Environmental Scientist
Phone: [phone]
6/15/24, 3:41 PM State of Utah Mail - Air Quality Inspection
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1798394349089173375&simpl=msg-f:17983943490891733…2/3

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
6/15/24, 3:41 PM State of Utah Mail - Air Quality Inspection
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1798394349089173375&simpl=msg-f:17983943490891733…3/3
Joe Rockwell <[e-mail]>
Revised Semi Annual Monitoring Reports
6 messages
Shepherd, Dean <[e-mail]>Wed, May 15, 2024 at 11:55 AM
To: Joe Rockwell <[e-mail]>
Cc: "Murray, Cleon" <[e-mail]>
Joe,

Per your request, please find attached revisions to our 2023 semi-annual monitoring reports as follows:
1st half 2023 April 11th - June 30th Title V Semi-Annual Monitoring Report
2nd half 2023 July 1st - December 31st Title V Semi-Annual Monitoring Report

I’m also sending these revised reports via certified mail.

Please let me know if you have any questions.

Thanks,

DEAN SHEPHERD
Site Environmental Leader
P&G Box Elder Plant
5000 Iowa String Road | Bear River City, UT 84301
W(435) 279-1377 | M(801) 710-7716

2 attachments
First Half 2023 Semi-Annual Monitoring Report 300053003 Apr-June 2023 0726 v2.0 REVISED 5-13-24
signed.pdf
353K
Second Half 2023 Semi-Annual Monitoring Report REVISED 5-13-2024 signed.pdf
164K
Joe Rockwell <[e-mail]>Wed, May 15, 2024 at 4:30 PM
To: "Shepherd, Dean" <[e-mail]>
6/15/24, 3:43 PM State of Utah Mail - Revised Semi Annual Monitoring Reports
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1799142237315689941&simpl=msg-f:17991422373156899…1/4
Hi Dean -
Everything looks good.
Just wondering why Conditions II.B.2.e and II.B.3.j in the first half of 2023 report (April 11 - June 30, 2023) were just red
lined and not deleted? You deleted the Conditions II.B.2.e and II.B.3.j in the second half 2023 report.
Thank you for your cooperation.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Joe Rockwell <[e-mail]>Thu, May 16, 2024 at 5:29 PM
To: "Shepherd, Dean" <[e-mail]>
Hi, Dean -
Can you send me the date and DAQ receive date of the construction notice regarding the 16B Paper Machine (condition
II.B.1.d of the current TV). I cannot locate that notice.
Thank You,
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Joe Rockwell <[e-mail]>Thu, May 16, 2024 at 5:35 PM
To: "Shepherd, Dean" <[e-mail]>
It is ok if the notice wasn't sent. The notice is not due until May of 2025. Just thought you that the notice was sent under
the 2022 AO.
Joe Rockwell | Environmental Scientist
Phone: [phone]
6/15/24, 3:43 PM State of Utah Mail - Revised Semi Annual Monitoring Reports
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1799142237315689941&simpl=msg-f:17991422373156899…2/4

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
Shepherd, Dean <[e-mail]>Fri, May 17, 2024 at 6:21 AM
To: Joe Rockwell <[e-mail]>
Joe,

Please find attached the status of construction notification associated with DAQE-AN141070017-22 Section I.8 which was
sent on 3/22/24 and received by UDAQ on 3/27/24.

Please let me know if you have any questions.

Thanks,

DEAN SHEPHERD
Site Environmental Leader
P&G Box Elder Plant
5000 Iowa String Road | Bear River City, UT 84301
W(435) 279-1377 | M(801) 710-7716

From: Joe Rockwell <[e-mail]>
Sent: Thursday, May 16, 2024 5:36 PM
To: Shepherd, Dean <[e-mail]>
Subject: Re: Revised Semi Annual Monitoring Reports

[EXTERNAL]
6/15/24, 3:43 PM State of Utah Mail - Revised Semi Annual Monitoring Reports
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1799142237315689941&simpl=msg-f:17991422373156899…3/4
[Quoted text hidden]
2 attachments
Box Elder Continuous Construction Update_3-22-2024 _ signed.pdf
35K
Certified mail documentation of delivery.pdf
122K
Joe Rockwell <[e-mail]>Fri, May 17, 2024 at 11:07 AM
To: "Shepherd, Dean" <[e-mail]>
Thank you Dean.
Have a great weekend.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
6/15/24, 3:43 PM State of Utah Mail - Revised Semi Annual Monitoring Reports
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1799142237315689941&simpl=msg-f:17991422373156899…4/4
Joe Rockwell <[e-mail]>
Fwd: Breakdown report from Procter and Gamble Paper
2 messages
Harold Burge <[e-mail]>Fri, May 26, 2023 at 11:18 AM
To: Joe Rockwell <[e-mail]>
FYI.
---------- Forwarded message ---------
From: Susan Weisenberg <[e-mail]>
Date: Fri, May 26, 2023 at 11:09 AM
Subject: Breakdown report from Procter and Gamble Paper
To: Harold Burge <[e-mail]>
Hello Harold, I just received an Emergency Breakdown report from Cleon Murray, 302-264-1005, [e-mail]
An emergency situation occurred yesterday, May 25, 2023, during the hours of 8:00 am through 2:40 pm, where they
operated for 59 minutes without a RTO function. They performed a count validation and estimated that approximately 5
kilograms of VOC were released. The cause of the event appears to have been an alarm malfunction. They are now
performing a full investigation. Mr. Murray has also submitted a written notification using the DAQ's online breakdown
form.
Susan Weisenberg,
Environmental Scientist
Office: 385-306-6512
Joe Rockwell <[e-mail]>Mon, May 29, 2023 at 1:08 PM
To: Harold Burge <[e-mail]>
Thanks Harold,
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
[Quoted text hidden]
5/16/24, 12:55 PM State of Utah Mail - Fwd: Breakdown report from Procter and Gamble Paper
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1766978003087681911&simpl=msg-f:17669780030876819…1/1