EUG 3 –Coal Preparation Plant

EUG 6 – VOC Sources Not Subject to an NSPS or NESHAP

Emission factors for these units were developed in a comprehensive emissions testing program by The National Council for Air and Stream Improvement (NCASI). Lengthy discussion of this program, with details concerning applicant’s participation may be found in the memorandum associated with the pending Part 70 permit. The Pulp Processing emission factors developed in this program are used to estimate total VOC and HAP emissions for all pulping systems. This action was taken in the discussion for the Part 70 permit, which concluded that such an approach is reasonable since all systems use similar processes and raw materials to produce similar products. The primary difference in the Systems lies in the bleaching agent and/or sequence. Emission factors for the systems were developed by applying the production rate-normalized emission factors from the two areas tested. In every case where the choice of bleaching agent created a difference in emissions, the higher factors were selected and applied to the maximum expected production rates for the pulping system, producing conservatively high results. An overall factor of 0.45 lbs of VOC per ton of pulp processed is the highest value shown in the NCASI study. Paper production requires approximately 100 tons of pulp for every 95 tons of finished product. The following table uses this factor in a comparison of 2002-2003 average actual emissions with current project PTE.

Various methods have been used in the past to calculate emissions of VOC from chemicals used at the paper machines. One method used a site-specific evaluation by NCASI. Emissions from building vents and equipment vents were measured, certain worst-case assumptions were made, and uniform values applied to all machines. Mass balance methods have also been used, sometimes with restrictions as to the amount of VOC released, as opposed to VOC reacted or bound in some other fashion. The method used for this permit analysis is reflected in the section following this.

The additives to which the heading refers are chemicals used with paper machines, but that were not in use when the NCASI testing was performed in 1995. They include chemicals that enhance the product, such as softness aids, dyes, biocides, etc. Considerations similar to those in the preceding section were made in calculations of VOC emissions for the memorandum associated with the pending Part 70 permit.