From: Holmes, Jill R. [mailto:JILL.HOLMES@GAPAC.com] 

Sent: Thursday, March 29, 2012 12:51 PM

To: Holloway, Thomas C. (Tom)

Cc: Bill Schrock; John Bradfield; Hanks, Katie P.

Subject: RE: Attention Docket ID No. EPA-HQ-OAR-2007-0544

Mr. Holloway,

Looking at the data changes, the stack parameters for emission units
LG09 were revised to represent proper conversion from metric to English
units.  The temperature and velocity numbers appear to be accurate.  I
did notice that I made a mistake on the stack diameter when I changed
it.  The original value of 0.984 ft would be the correct value.  You
may change it back to this original number.

For LG11, the Lime Mud Filters, these sources release at the top of the
filter building which is very near the 5LK stack location.  They are
different stacks.  I have no specific data on the LG11 sources other
than the height and the diameter of the angled fan exit.  There is very
little visible plume coming from those sources.  Since they also
errantly show the same stack IDs, you could also change the LG11 stack
IDs to 542V and 543V for the North (TV#L542) and South (TV#L543) Lime
Mud Filters, respectively.

Please let me know if this answers your questions or if you need any
further information for the BCI facility.

Thank you.

Jill R. Holmes

(912) 717-1768 (office)

(912) 399-6284 (cell)

From: Holloway, Thomas C. (Tom)   HYPERLINK
"mailto:[mailto:tcholloway@rti.org]"  [mailto:tcholloway@rti.org]  

Sent: Monday, March 19, 2012 3:46 PM

To: Holmes, Jill R.

Cc: Bill Schrock; John Bradfield; Hanks, Katie P.

Subject: RE: Attention Docket ID No. EPA-HQ-OAR-2007-0544

Ms. Holmes,

We are EPA’s contractor for reviewing the revisions to the NEI file
for the pulp and paper industry.  We have reviewed your corrections to
the model risk inputs for your facility (Brunswick Cellulose,
NEI8196).  Thank you for taking the time to prepare the corrections.  

We have some questions about the stack parameters for emission units
LG09 (Slaker Vents L511 and L514 & Scrubbers) and LG11 (Lime Mud Filters
(North & South) (L542 & L543).  Specifically, we noted that you revised
the stack height and stack diameter for these emission units and wanted
to know whether there are any changes to be made to the stack
temperature and/or exit gas velocity for these emission units.  (We can
calculate the exit gas flow rate from the stack diameter and exit gas
velocity values that are ultimately used.)  For example, we noted that
you changed the emission release point type for emission unit LG11 from
fugitive to stack at the same time you revised the stack height and
diameter and wanted to know whether you would like to change the stack
temperature and exit gas velocity from the national default values of 72
degrees F and 0.0003 ft (which are assigned to fugitive sources) to
something else.  (If you do not have actual temperature and velocity
values available, we can assign SCC default values for these
parameters.)  

We also noted that the latitude and longitude values for the lime mud
filters (as revised) are similar to the latitude and longitude values
for the lime kiln, a conclusion that appears to be supported by the two
emission units having identical scrubber stack IDs in your mill’s ICR
response.  If the lime mud filters and lime kiln do exhaust through the
same stack, we may want to revise the stack parameter and
latitude/longitude data for the lime mud filters and lime kiln to make
them identical.  How would you like to proceed?

Thanks for looking into this for us.  We really appreciate it.  Let us
know if you have any questions.

Thomas Holloway

RTI International

  HYPERLINK "mailto:ppsurvey@rti.org"  ppsurvey@rti.org 

1-877-834-7065

