INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
August 4, 2016

FOR:
Weyerhaeuser NR Company, Columbus Modified Fiber Facility
371 Manufacturers Drive
Columbus, MS 39701    

FACILITY DESCRIPTION
Weyerhaeuser NR Company, Columbus Modified Fiber Facility operates an existing Condition Pulp Fiber Manufacturing Mill at their site.  The facility has applied for re-issuance of a Title V Operating Permit for the air emissions from the following sources:

Emission Point	Description	
AA-001	The first stage dryer consisting of four natural gas fired burners with a total rated capacity of 128 MMBTU/hr equipped with a scrubber and cyclones (Facility Ref. No. EP1-1)	
AA-002	The manufacturing process equipped with a cooling cyclone (Facility Ref. No. EP1-2)	
AA-004	The continuous house vacuum system #1 with a rotary drum filter (Facility Ref. No. EP1-4)	
AA-005	208 Hp Fire Pump which is used as part of the mill fire protection system (Reconstructed Emergency Stationary Reciprocating Internal Combustion Engine) 	
The facility is not classified as a major source of air emissions with regards to PSD for any pollutant.

TITLE V PROGRAM APPLICABILITY BASIS
The facility’s potential-to-emit exceeds the Title V threshold limit of 100 tons/year for PM/PM10  and Volatile Organic Compounds (VOC’s).

LEGAL AND FACTUAL BASIS FOR DRAFT PERMIT CONDITIONS
The State and Federally-enforceable conditions of Title V Operating Permits are based upon the requirements of the State of Mississippi Air Emissions Operating Permit Regulations for the Purposes of Title V of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 6.), and applicable requirements effective upon the date of permit issuance.  Applicable requirement means all of the following as they apply to emissions units in a Title V source:

1.	any standard or other requirement set forth in the State Implementation Plan (SIP) approved or promulgated by EPA through rulemaking under Title I of the Federal Clean Air Act (Federal Act) including the following:

a.	most of the State of Mississippi Air Emission Regulations for the Prevention, Abatement, and Control of Air Contaminants (11 Miss. Admin. Code Pt. 2, Ch. 1.) 
b.	the State of Mississippi Regulations for the Prevention of Air Pollution Emergency Episodes (11 Miss. Admin. Code Pt. 2, Ch. 3.),
c.	the State of Mississippi Regulations for the Prevention of Significant Deterioration of Air Quality (11 Miss. Admin. Code Pt. 2, Ch. 5.), and 40 CFR Part 52.21 by reference, and
d.	the provisions of the State of Mississippi Permit Regulations for the Construction and/or Operation of Air Emissions Equipment (11 Miss. Admin. Code Pt. 2, Ch. 2.), relating to construction permits and synthetic minor operating permits;

2.	any term or condition of any construction permits issued pursuant to Mississippi regulations approved or promulgated through rulemaking under Title I;

3.	any standard or other requirement under Section 111 of the Federal Act, including Section 111(d) which includes Title 40, Part 60 of the Code of Federal Regulations (40 CFR Part 60) and relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1.;

4.	any standard or other requirement under Section 112 of the Federal Act, including relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1.and 40 CFR Parts 61, 63, and 68;

5.	any standard or other requirement of the acid rain program under Title IV of the Federal Act or the regulations promulgated thereunder, including the State of Mississippi Acid Rain Program Permit Regulations for Purposes of Title IV of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 7.)  adopted November 17, 1994, and 40 CFR Parts 72, 73, 75, 77, and 78;

6.	any requirements established pursuant to Section 504(b) or Section 114(a)(3) of the Federal Act;

7.	any standard or other requirement governing solid waste incineration under Section 129 of the Federal Act;

8.	any standard or other requirement for consumer and commercial products under Section 183(e) of the Federal Act;

9.	any standard or other requirement for tank vessels under Section 183(f) of the Federal Act;

10.	any standard or other requirement of the program to control air pollution from outer continental shelf sources under Section 328 of the Federal Act;

11.	any standard or other requirement of the regulations promulgated to protect stratospheric ozone under Title VI of the Federal Act;

12.	any national ambient air quality standard or increment or visibility requirement under part C of Title I of the Federal Act.

Each State and Federally-enforceable condition of the draft Title V Operating Permit references the specific relevant requirements of 11 Miss. Admin. Code Pt. 2, Ch. 6.or the applicable requirement upon which it is based. Any condition of the draft Title V permit that is enforceable by the State but is not Federally-enforceable is identified in the draft Title V permit as such.

SPECIFIC APPLICABLE REQUIREMENTS

Emission Points AA-001, AA-002, and AA-004

These emission points are subject to the State of Mississippi air regulation limit, 11 Miss. Admin. Code Pt. 2, R. 1.3.F, the process weight equation limit for particulate matter (filterable only).  As a result of a Permit to Construct issued on April 25, 1992, and modified on September 22, 1997 and November 30, 1998, the permittee is limited to a process weight equation limit of 52.36 lbs/hr and 229.33 tons per year.  As found in the existing permit, to verify compliance with these limitations, the facility will be required to perform a biennial stack test of each emission point.  

Emission Point AA-001

Emission Point AA-001 is subject to 11 Miss. Admin. Code Pt. 2, R. 1.3.A and 11 Miss. Admin. Code Pt. 2, R. 1.3.B, the opacity limits for emission sources. The permittee shall assure compliance with the opacity limitation by having an observer perform weekly opacity observations for a minimum of six (6) consecutive minutes and maintain a log of the results.  If any visible emissions are detected, then a Visible Emission Evaluation (VEE) shall be performed using EPA Reference Method 9 by a certified observer.  

As a result of a Permit to Construct issued November 30, 1998, May 27, 2008, and February 6, 2007, the permitee is limited to a VOC emission limit of 434.6 lbs/hr not to exceed 234 tons per year and a yearly production limit for both Group B and Group C products.  As found in the existing permit, to verify compliance with these limitations, the facility will be required to perform monthly recordkeeping.

As is found in the existing permit, the permittee shall maintain daily records for scrubber water flow and shall measure scrubber water flow at the time of stack testing.  In addition, the permittee shall maintain records of the type and fuel combusted in the burners.
 
As identified in the existing permit, Emission Point AA-001 is also subject to 11 Miss. Admin. Code Pt. 2, R.1.4.B(1), the sulfur dioxide limit for any process equipment constructed after January 25, 1972.  No compliance demonstration is being proposed as the margin of compliance is expected to be high.

Emission Point AA-002

Emission Point AA-002 is subject to 11 Miss. Admin. Code Pt. 2, R. 1.3.B, the opacity limit for emission sources. The permittee shall assure compliance with the opacity limitation by having an observer perform weekly opacity observations for a minimum of six (6) consecutive minutes and maintain a log of the results.  If any visible emissions are detected, then a Visible Emission Evaluation (VEE) shall be performed using EPA Reference Method 9 by a certified observer.   

Emission Point AA-004

Emission Point AA-004 is subject to 11 Miss. Admin. Code Pt. 2, R. 1.3.B, the opacity limit for emission sources. The permittee shall assure compliance with the opacity limitation by having an observer perform weekly opacity observations for a minimum of six (6) consecutive minutes and maintain a log of the results.  If any visible emissions are detected, then a Visible Emission Evaluation (VEE) shall be performed using EPA Reference Method 9 by a certified observer.   

As is found in the existing permit, monthly maintenance inspections are being required to be performed on the drum filter and a spare drum filter cloth shall be kept on site.  

Emission Point AA-005

This facility is subject to the National Emission Standard for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (40 CFR 63, Subpart ZZZZ) and the New Source Performance Standards for Stationary Compression Ignition Internal Combustion Engines (40 CFR 60, Subpart IIII) for Emission Point AA-005.  As a result, permit limitations and conditions have been incorporated into the permit for Emission Point AA-005 for these two federal regulations.

This emission point is also subject to 11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(b), the PM (filterable only) emission limit from fossil fuel burning.  As the margin of compliance is expected to be high, periodic monitoring is not being proposed to ensure compliance with this limitation.

COMPLIANCE ASSURANCE MONITORING (CAM)

As is found in the existing permit, a CAM plan has been incorporated into the proposed permit.  The facility will be required to measure the scrubber flow rate at the time of the PM stack emissions test.  The facility will be required to monitor scrubber flow rate continuously and report within five working days any excursion.  An excursion is defined as a 15-minute average scrubbing liquid flow rate less than 90% of the average flow rate recorded during the most recent PM stack test. QA/QC practices for the scrubber will consist of annual replacement of the flow meter and annual testing of the low flow alarm.  The facility will also be required to perform weekly opacity observations for a minimum of six (6) consecutive minutes and maintain a log of the results.  If any visible emissions are detected, then a Visible Emission Evaluation (VEE) shall be performed using EPA Reference Method 9 by a certified observer.   An excursion is defined as opacity >40%.  All excursions will trigger an inspection and corrective action as well as the reporting requirement.