DES RESPONSE TO COMMENTS FROM FRASER N.H. LLC & USEPA REGION

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1 ATTACHMENT A DES RESPONSE TO COMMENTS FROM FRASER N.H. LLC & USEPA REGION 1 Fraser N.H. LLC Berlin/Gorham, NH Temporary Permit TP-B-0489 Facility ID# , Application# FY Fraser N.H. LLC (Fraser) submitted the following comments related to the draft Temporary Permit for construction, installation, and initial operation of a new Package Boiler, steam stripper, foul condensate tank, and steam driven turbine. 1. Page 4, Section IV.J. 40 CFR 63 Subpart S Section (d) provides three compliance options for treating stripper off gases. DES has only listed using the Thermal Oxidizer at 1600 degrees F and residence time of 0.75 seconds, yet on page 12 in Item XI.D.3. includes all three options. Please revise Item IV.J. to include all three options. The New Hampshire Department of Environmental Services, Air Resources Division (DES) has revised Item IV. J. to read as follows: In accordance with 40 CFR 63 Subpart S Section (d), the Thermal Oxidizer shall reduce total HAP emissions by 98 percent or more by weight; or reduce the total HAP outlet concentration to 20 parts per million or less by volume, corrected to 10 percent oxygen on a dry basis; or be operated at a minimum temperature of 1600 Fahrenheit and a minimum residence time of 0.75 seconds when treating SOGs. 2. Page 6, Item VI.B. Pursuant to Subpart S, Fraser will be required to convey the SOGs and LVHCs to Package Boiler No. 15 or Thermal Oxidizer as a possible backup in a closed vent collection system. To meet the requirements of Subpart S, Fraser will need to monitor bypass vents, inspect for leaks and maintain records of when SOGs and LVHCs are being collected or vented. In light of these requirements, measuring flow of SOGs and LVHC gases in the feed lines to Package Boiler No. 15 will not provide additional information that is meaningful to determining compliance with Subpart S or other requirements. DES has modified Item VI.B. by removing the to requirement to monitor flow of SOGs and LVHCs to Package Boiler No. 15. In its place, DES has added the applicable requirements from 40 CFR 63 Subpart S Section (d)(1) and (2) for monitoring of each bypass line in the closed vent collection systen for SOGs and LVHCs that could divert vent streams containing HAP to the atmosphere without meeting the emissions limitations of Sections , , or In addition, it should be noted that DES has added performance testing of the thermal oxidizer, required within 60 days of initial operation to treat SOGs. Performance test requirements are Items VII.D., E., & F. which require Fraser to test for emissions of criteria pollutants, HCl, determining minimum liquor flow to the packed bed scrubber serving the Thermal Oxidizer, and quantifying SOG volumetric flows during the performance testing only of the Thermal Oxidizer. 3. Page 11, Item XI.A. The consent agreement between Fraser, DES, and the United States Environmental Protection Agency Region 1 (EPA) provides an extension until December 15, 2003 for compliance with all of 40 CFR 63 Subpart S. Fraser suggested new wording for this item.

2 Response to Fraser and EPA Comments Page 2 of 6 DES has modified the text of Item XI.A. to read exactly as in Condition V. Compliance Order, Section B. Cluster Rule of the consent agreement. At the end of that text DES has added, Fraser has included equipment installations in its permit application for this Temporary Permit which address applicable requirements of 40 CFR 63 Subpart S. 4. Page 14, Item XI.D.4. Section (f) Standards for kraft pulping process condensates Fraser has requested to add the word possible to language suggesting the Thermal Oxidizer as a backup for when Package Boiler No. 15 is unavailable for SOG combustion. Fraser has clearly indicated that they are looking at the Thermal Oxidizer as a potential backup for when the Package Boiler No. 15 is unavailable for service. The mill is also considering other options in case Power Boiler No. 15 is out of service. DES has modified the text in renumbered Item XI.E.4. to read as follows: Fraser will combust steam stripper off-gases in Package Boiler No. 15, with the Thermal Oxidizer as a possible backup for when the Package Boiler No. 15 is unavailable for SOG combustion. 5. Page 18, Item XIII. Please remove the term federally enforceable from the introductory text of Item XIII. as the new Env-A 900 rules cited are not yet part of the EPA approved New Hampshire State Implementation Plan (SIP). DES has removed the expression federally enforceable from the introductory text of Item XIII. It should be noted that after issuance of this Temporary Permit that these regulatory citations in Item XIII. will be federally enforceable by way of Temporary Permits being federally enforceable. Hence, those regulatory citations will be federally enforceable in the upcoming Title V Operating Permit for Fraser. 6. Page 26, Attachment A Please remove the sentence with reference to deletion of CO emissions limitations in the Changes to Emissions Limitations in Previously Issued Permits Section of Attachment A as the Bark Boiler is not being removed as part of this project as in the original project scope in DES has removed the sentence Please note the deletion of CO emissions limitations, which were previously discussed in an earlier section of this permit., which appears in the first paragraph under Changes to Emissions Limitations in Previously Issued Permits on page Pages 26 through 31, Attachment A Changes to Emissions Limitations in Previously Issued Permits Section Fraser is suggesting simplification of showing each of the individual permit emissions limitations table for pollutants with one table showing the old facility wide caps for each device along with the new reduced facility wide cap for the units not including the new Package Boiler 15 and Thermal Oxidizer. DES has simplified this section of Attachment A with one table showing the old facility wide emissions caps for all of the units without Package Boiler No. 15 and the Thermal Oxidizer, i.e., Power Boilers 1, 2, 3, 4, 9, 12, Temporary Package Boiler, Bark Boiler, No. 2 Lime Kiln, Recovery Boiler, and Recovery Boiler Smelt Tank, and the new facility wide cap for the same group of units.

3 Response to Fraser and EPA Comments Page 3 of 6 8. Page 31, Alternate Opacity Monitoring for Package Boiler No. 15 Please remove monitoring the pressure drop for the spray tower as there is virtually no differential pressure drop across the proposed spray tower in the gaseous emissions. DES has deleted reference to monitoring pressure drop across the spray tower in the alternative opacity monitoring for Package Boiler No. 15 description on page 31. However, it should be noted that in the EPA approved alternative opacity monitoring for Package Boiler No. 15, Fraser is required to monitor liquor flow to the spray tower and voltage drop across the electrostatic precipitator for Package Boiler No. 15. These changes are incorporated into permit Items VI.F. and G. 9. Page 2, Item II. Facility Description of Operations Please replace Great North Woods Mills Energy LLC with White Mountain Energy LLC. DES has replaced both references to Great North Woods Mills Energy LLC with White Mountain Energy LLC in the fifth paragraph on page 2 under Item II. Facility Description of Operations. The United States Environmental Protection Agency Region 1 (EPA) submitted the following comments related to the draft Temporary Permit. 1. Section V.B. Emissions Limitations The permit requires Fraser to install and operate an SCR system for Package Boiler No. 15 yet does not specify a minimum control efficiency for the system. In addition, the permit only expects Fraser to meet the 0.2 lb/mmbtu emission limit as required by 40 CFR 60 Subpart Db. This limit is based on conventional combustion controls and not SCR systems. Considering that the SCR system must be operated at all times, DES should include a NOx emission limit that represents the emission limit that can be achieved by any well-run effective SCR system. DES has left the short term NOx emission limitation of 0.2 lb/mmbtu unchanged in the Emissions Limitations Table contained in permit Item V.C. (V.B. was renumbered as V.C.). DES recognizes that this new Boiler has add-on pollution control equipment which has the potential to remove more NOx emissions than conventional combustion controls. As such, DES has added the requirement for Fraser to determine a minimum urea flow during the performance test of the Boiler indicative of good pollution control equipment operation and to maintain this minimum flow thereafter. DES has added Item IV.P. requiring Fraser to operate the SCR at all times during normal operation of the Boiler (once the minimum catalyst bed temperature is achieved) and the urea to be injected at the minimum urea to air ratio established during the performance test to demonstrate good air pollution control equipment operation. DES would like to point out that there are no applicable regulations other than Subpart Db s short term emission limitation of 0.2 lb/mmbtu and the annual NOx emissions cap on Package Boiler No. 15 plus the Thermal Oxidizer of tons, as there are no BACT or LAER requirements applicable in that this project netted out. 2. Attachment A DES should include a line in the netting analysis table in Attachment A reflecting that there were no actual emissions increases of the four pollutants occurred during the 5 year contemporaneous period prior to this project.

4 Response to Fraser and EPA Comments Page 4 of 6 DES has added a line in the Netting Analysis table in Attachment A of the Temporary Permit which reads, Any contemporaneous emissions increases in past 5 years? with a NO as a response for all four pollutants, SO2, NOx, PM10, and H2SO4. 3. Item IV. Operating Limitations for the Thermal Oxidizer The permit requires Fraser to control SO2 emissions from the Thermal Oxidizer using a packed bed scrubber. However, the permit does not specify a control efficiency for the scrubber nor a maximum SO2 emission rate from the scrubber. In addition, the permit should include some means to monitor the efficiency of the packed bed scrubber. EPA recommends to determine the minimum scrubber liquor flow to the packed bed scrubber to maintain the SO2 removal efficiency and a flow meter to ensure the minimum liquor flow is maintained. In Item IV.I., DES has added to operate the packed bed scrubber with the minimum scrubber liquor flow rate to maintain greater than 50% SO2 removal efficiency for the packed bed scrubber serving the Thermal Oxidizer. DES has added the requirement for monitoring the scrubber liquid flow to the packed bed scrubber in Item VI.C. Finally, DES is requiring a performance test of the Thermal Oxidizer within 60 days of operation to treat stripper off gases, stipulated in Items VII.D., E., and F., which includes determining a minimum scrubber liquor flow. Considering the Thermal Oxidizer SO2 emissions are 8.1 times 10 to the minus 4 pounds per hour, DES is not stipulating a minimum removal efficiency for SO2 or short term emission limit for SO2 in this Permit. 4. Item IV.K. 1. EPA understands that Fraser is allowed to bypass the thermal oxidizer during startup/shutdown and malfunction conditions provided total bypass time does not exceed 10% of the total processing time. However, this operational condition is not clearly outlined in the permit. 2. The ARD should include a provision that clearly explains when Fraser can bypass the thermal oxidizer and for how long. 3. In addition, to show compliance to this condition, the ARD should require Fraser to monitor the amount of time the thermal oxidizer is bypassed and to keep records that indicate the percent bypassed operations versus total operations. 4. The ARD should also quantify the emissions during the bypass operations and include these emissions in the permits facility wide caps. 5. EPA recommends the Section IX to include provisions to develop and maintain a QA/QC plan for the oxidizer and a provision requiring Fraser to keep record of all excess emissions. 1. Permit condition IV.K. made an incorrect reference to 40 CFR 63 Subpart S Section (g) in the first line, which has been corrected to read Section (g), which correctly pertains to requirements for kraft pulping process condensates. The reference to SOGs in condition IV.K. needs to be removed from this permit condition, as SOGs are classified as a LVHC source and subject to Section (c) and (d). In this case the thermal oxidizer is the backup destruction device and via Section (e)(1), periods of excess emissions (excluding periods of startup, shutdown, or malfunction) for the thermal oxidizer or Package Boiler No. 15 or Lime Kiln is limited to 1 percent. If you go down to Section XI., 40 CFR 63 Subpart S Requirements, Item E.5., this adequately addresses the 10% downtime applicable to the steam stripper. Likewise, if you go to Section XI., Items D.3. and 4.(1), it defines that periods of excess emissions reported semi-annually are not a violation provided they are less than 1% for control devices used to reduce total HAPs from the LVHC system (i.e., SOGs from the steam stripper to the thermal

5 Response to Fraser and EPA Comments Page 5 of 6 oxidizer or Package Boiler No. 15 or LVHCs collected going to the Package Boiler No. 15 or Lime Kiln as backup). To clarify excess emissions, DES has added an item IV.L. after IV.K. which defines excess emissions for the thermal oxidizer and has removed reference to SOGs in Item IV.K. 2. Permit conditions IV.M. and N. have been added to the Temporary Permit to better clarify how long the facility can bypass the thermal oxidizer or Package Boiler No. 15 and what constitutes an excess emission in accordance with Env-A 2600, Pulp and Paper Industry Total Reduced Sulfur Emissions From Kraft Mills regulations. Condition M. defines excess emissions as any time greater than 5 minutes when the combustion temperature is below 1200 degrees Fahrenheit in the Thermal Oxidizer or Package Boiler No. 15 and condition N. allows a maximum of 15 minutes per day to bypass the Thermal Oxidizer or Package Boiler No. 15 with LVHC sources. 3. DES has added condition VI.B. to the Temporary Permit requiring the facility to monitor the amount of time either the Thermal Oxidizer or Package Boiler No. 15 are bypassed. In addition, DES has added condition IX.C. which specifies recordkeeping requirements for the Thermal Oxidizer and has already in place excess emission reporting requirements for the Thermal Oxidizer in condition IX.A. 4. DES has added the requirement to quantify and report excess emissions from the Thermal Oxidizer in permit condition IX.A Permit condition IX.B. sets out QA/QC plan requirements and condition IX.C. specifies recordkeeping of excess emissions from the thermal oxidizer. 5. Section IX.A.1. This requires Fraser to record readings from the data acquisition system below the minimum destruction limit. Section IV. requires the thermal oxidizer to be operated at a minimum temperature of 1600 degrees Fahrenheit. Since the thermal oxidizer must operate at or above 1600 degrees Fahrenheit, the ARD should replace minimum destruction deficiency with 1600 degrees Fahrenheit. DES has left this permit condition as stated in that the facility has three ways of being in compliance with Section (d): a minimum temperature determined during the performance test which yields 98% destruction of methanol, a minimum temperature determined during the performance test which yields less than 20 ppmvd methanol at 10% oxygen, or be operated at a minimum of 1600 degrees Fahrenheit and a minimum residence time of 0.75 seconds when treating the SOGs. Please note that permit item IV.J. has been restated including these three options for the thermal oxidizer for compliance with Section (d) and DES has added these three minimum temperature options to the details in Item IX.A.1. In addition, DES has added Item IX.A.3. Quantity of excess emissions by pollutant. These emissions are also to be included in the annual facility wide annual emissions report to DES. 6. Section VI.D. Since Fraser is required to install a Continuous Emission Monitor (CEMs) for NOx emissions, section VI.D.1. should reference the NSPS monitoring requirements for CEMs, 60.48b(b)(2), instead of 60.48b(b)(1). DES has corrected condition VI.D.1., renumbered as VI.E.1., to read as: In accordance with Section 60.48b(b)(2), except..

6 Response to Fraser and EPA Comments Page 6 of 6 7. Section VI.D. Section VI.D. contains an alternative opacity monitoring procedure in place of the NSPS monitoring requirement for Package Boiler No. 15. The ARD must first receive approval from EPA before it allows the use of any alternative method for any federal standard. Section VI.D., renumbered as VI.F. and VI.G. contains an alternative monitoring requirement for Package Boiler No. 15 for opacity measurement, which received EPA approval in a letter dated November 22, Attachment A of the Temporary Permit describes why there is an alternative opacity monitoring requirement and the conditions stipulated by EPA in its approval. Items 1. and 2. from EPA s approval letter are included in Temporary Permit conditions VI.F. and VI.G., while Item 3. is included in condition VIII.D. of this Temporary Permit. All of the alternative opacity monitoring requirements and parametric operating parameter ranges established in this Temporary Permit will be included in the facility s upcoming Title V Operating Permit.