Oklahoma department of environmental quality
EUG 7 – Non-Combustion PM Sources Not Subject to NSPS or NESHAP
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- Machine Paper Throughput (TPY) PM Emissions (TPY)
- Film Production (MMlbs/yr) Factor PM Emissions (TPY) 2002-2003
- Hazardous Air Pollutants (HAPs)
- SECTION V. AIR DISPERSION MODELING Overview
- Boiler -Unit B-2 Babcock Wilcox
- FXRT 1 - Unleaded Gasoline
- Emergency Diesel Generators
- Chlor Alkali Absorption Towers
- Pulp Bleaching with Hypochlorite
- Polyethylene Extruding and Printing**
- Non-hypochlorite Pulp Bleaching
- Coal Pile Fugitive Emissions
- Waste Water Treatment Plant
EUG 7 – Non-Combustion PM Sources Not Subject to NSPS or NESHAPPaper Machines Paper fibers are released into the atmosphere via the drying, trimming, handling and slitting of the paper sheet. Emissions were calculated using stack test data from a sister mill in Rincon, Georgia. Results from the 2002 stack testing of Rincon’s #19 Paper Machine drying hood indicated 0.415 lbs/hr of non-combustion particulate matter generated. Dividing this number by the paper production rate yielded an emission factor of 0.048 lbs PM/ton paper. The derived emission factor was doubled to account for particulate matter emissions generated by the wet end of the paper machine, which is a conservatively high assumption. Similarly, stack test data (November 2001) from the roof vents in the building above Rincon’s #19 paper machine showed 0.875 lbs/hr of particulate matter, which was converted to an emission factor of 0.108 lb PM/ton paper produced. The memorandum associated with the pending Part 70 permit treats these factors separately, but they are combined here for ease of presentation. Details may be found in the referenced memorandum. The following table shows 2002-2003 average actual emissions for each machine, potential emissions after the current project, and the actual-to-potential increase.
Coal Pile Emissions Although additional coal may be handled, none of the considerations involved in calculating emissions for the coal pile will change. Thus, there is no change in emissions to be expected.
The Part 70 permit calculated PM emissions from resin storage and handling using an emission factor from Table 6.6.2-1 of AP-42 (1/95) for dimethyl terephthalate resin production processes, assuming a resin usage rate of 6.0 MM lbs/yr. Addition of three more extruders will increase throughput to 35 MM lbs/yr. The following table presents the results, using 2002-2003 average production instead of the Part 70 Memorandum estimate.
Hazardous Air Pollutants (HAPs) Individual HAP emissions were discussed in the memorandum associated with the pending Part 70 permit and are not repeated here, both because the PTE for these materials will not increase and because any actual-to-potential increases require discussion in the context of PSD. PSD issues will be discussed later in this memorandum. The following table summarizes actual-to-potential emission changes for all EUGs discussed in this section.
SECTION V. AIR DISPERSION MODELING Overview Air dispersion modeling has been performed at various times in the permitting life of the facility. Some modeling has been performed to demonstrate compliance with Part 5 of OAC 252:100-41 and some has been performed to demonstrate compliance with other ambient standards. Two PSD permits and evaluations have been issued during the life of this plant and further analyses were submitted with the application for the pending Part 70 permit. These analyses have been reviewed in previous permit memoranda or will have been reviewed in the memorandum associated with the Part 70 operating permit. These reviews are not reproduced or summarized here. Note that previous analyses dealing with toxic air contaminants (TACs) are no longer pertinent, due to the replacement of Part 5 of Subchapter 41 by Subchapter 42. Modeling information for those TAC constituents that are also HAP remain valid unless updated by this construction permit. Ozone Modeling The modeling analysis for ozone was performed by DEQ. OAC 252:100-8-35 requires an air quality impact evaluation for each regulated pollutant for which a major modification would result in a significant net emissions increase. No de minimis air quality level is provided for ozone. However, any net increase of 100 tons per year or more of volatile organic compounds subject to PSD is required to perform an ambient impact analysis. Methods for evaluating single source impacts on ozone concentrations are not consistent, due to the lack of availability of data at a refined level, readily available tools and EPA guidance. DEQ has evaluated the impact of the proposed modification to the Fort James facility using an existing air quality database generated for a SIP evaluation and the CAMx photochemical modeling system. Oklahoma entered into Early Action Compact (EAC) agreements with EPA for the Tulsa and Oklahoma City metropolitan areas. Photochemical modeling evaluations were prepared in support of the agreements. These evaluations were conducted in accordance with EPA guidance and underwent an extensive public comment process and EPA review. The modeling was based on a two week episode beginning in Mid-August of 1999 and extending through the first week of September 1999. This episode was chosen both by virtue of being a prolonged period of high ozone concentrations and a reflection of the most common meteorological conditions that spawn high concentrations for Tulsa and Oklahoma City. Modeling for Fort James was conducted using the EAC base case. Emissions to be modeled were calculated by subtracting the 1999 inventoried emissions from the future potential emissions identified in the application. VOC emissions were further speciated by Source Classification Code, SCC, using speciation tables generated by EPA and SCCs for Fort James processes as identified in annual inventories.
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