All industrial permits sources were reviewed to insure that appropriate
requirements had been applied and that these requirements constituted
RACT. The following are thirteen sources that had the highest sum of
emissions of combined NOx, SO2, and Particulate. Particulate was used
because PM2.5 emission factors are limited. These sources were reviewed
to verify that the sources were subject to RACT levels of controls.

Industrial emissions were reviewed to see if there was a possibility of
any additional controls that could change the attainment date from the
end of 2009 to the end of 2008. No additional controls were found. Table
15 shows that no possible reductions will result in a 2008 attainment. 

Brach’s Confections

Company Number	0300

Full Compliance Evaluation:	April 24 2007.  The source was in
compliance.

Allowable Emissions:	Particulate	46.31 tons per year

			NOx		41 tons per year

			SO2		0.18 tons per year  Natural Gas Combustion only 

This source is subject to the following rules.

	1. 40 CFR Part 60 Subpart DC – Standards of Performance for Small
Industrial –

		Commercial-Institutional Steam Generating Units

	2. Particulate	Rule 10 

	3. Opacity	Rule 3

	4. Particulate BACT  4-8(e)(2)b

Three boilers on site are fired by natural gas only.

One 21.32 million BTU/hr boiler

One 15.7 million BTU/hr boiler  

One 30.1 million BTU per hour boiler 

	

The 15.7 million BTU/hr Boiler is subject to 40CFR Part 60 Subpart
Dc-Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Unit.

Process equipment emits 2.5 TPY of particulate at maximum operating
rate. Process emissions are controlled by baghouses. 

East Tennessee Natural Gas

Company Number	5340

Full Compliance Evaluation March 29, 2007. The source was in compliance

Emissions	Particulate is 2.24 tons per year.  All particulate is PM2.5.

		Allowable NOx 48.20 Tons per year. 		

	

Subject to the following as adopted into the Chattanooga Air Pollution
Control Ordinance

	

1. 40 CFR Part 60 Subpart GG Standards of Performance for Stationary Gas
Turbines.

2. Chattanooga Air Pollution Control Ordinance Rule 15 Adoption of NSPS 


 

Both turbines burn pipeline natural gas and have been stack tested. The
allowable NOx limit in the NSPS is 150 ppm. The older turbine which was
tested in 1991 demonstrated NOx emissions of 63 ppm or 3.7 lb/hour. The
newer turbine which was tested in 2002 demonstrated NOx emissions of
14.2 ppm or 2.72 lb/hr. If both turbines ran 8760 hours, the potential
emissions would be 28.12 tons per year. 

Fuel sulfur has also been demonstrates as 0.02 % which is well below the
NSPS allowable of 0.08%. 

Particulate is likely to be overestimated as discussed in the emission
inventory document that said that particulate emissions from combustion
of natural gas are significantly overestimated. 



Erlanger Medical Center

Company Number 0150

Full Compliance Evaluation completed on October 23, 2007. The source was
in compliance 

Allowable/ Actual Emissions	Particulate 	11.87	 TPY

				NOx		71.92	TPY

				SO2		18.00	 TPY

SO2 is limited by the permit to 500,000 gallons on Number 2 fuel oil
with 0.5% sulfur. 

There are 4 permitted boilers that provide steam for a large medical
center. The boilers are fired on natural gas but use Number 2 fuel as a
backup fuel. Depending on steam demand one or two boilers will be
operated at a time.  Though the facility is permitted for Number 2 oil
with 0.5% sulfur oil, the facility used 3600 gallons and the number 2
oil was 0.1865 % Sulfur in the last year. 	

		

This source is subject to the following rules.

1.40CFR Part 60 Subpart Dc Small Industrial-Commercial-Institutional
Steam Generating Units

		2. Particulate		Rule 27.3

		3. Opacity		Rule   3  10% Opacity limits

		6. SO2			Rule 13.2  Quarterly Sulfur Reports Required 

Erlanger Medical Center

Company Number 0150

Full Compliance Evaluation completed on October 23, 2007. The source was
in compliance 

Allowable/ Actual Emissions	Particulate 	11.87	 TPY

				NOx		71.92	TPY

				SO2		18.00	 TPY

SO2 is limited by the permit to 500,000 gallons on Number 2 fuel oil
with 0.5% sulfur. 

There are 4 permitted boilers that provide steam for a large medical
center. The boilers are fired on natural gas but use Number 2 fuel as a
backup fuel. Depending on steam demand one or two boilers will be
operated at a time.  Though the facility is permitted for Number 2 oil
with 0.5% sulfur oil, the facility used 3600 gallons and the number 2
oil was 0.1865 % Sulfur in the last year. 	

This source is subject to the following rules.

1.40CFR Part 60 Subpart Dc Small Industrial-Commercial-Institutional
Steam Generating Units

		2. Particulate		Rule 27.3

		3. Opacity		Rule   3  10% Opacity limits

		6. SO2			Rule 13.2  Quarterly Sulfur Reports Required 



Memorial Hospital RACT

Company Number 2010

Full Compliance Evaluation was completed on December 21, 2006. The
source was in compliance. 

This permit applies to the three 500 hp Johnson boilers that provide
steam for Memorial hospital. Natural gas is used to fire the boilers
with number 2 fuel oil as a backup fuel in case of natural gas
curtailment. By permit condition, only 2 boilers can be in operation at
a time. 

Allowable Emissions	Particulate 	8.20 lb/hr	 

			NOx		N/A

			SO2		10.15 lb/hr	

Actual Emissions	Particulate 	1.235 TPY

			NOx	       	12.57 TPY

			SO2	     	 44.46   TPY

Available Emission Factors show direct PM2.5 as 0.8820 TPY

 		

This source is subject to the following:

40CFR Part 60 Subpart Dc- Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units.

The NSPS limits the sulfur in the fuel oil to 0.5% 

		Rule 8.2 limits particulate to 8.2 lb/hr

Rule 13 limits SO2 to 300 ppm. 

Rock Tenn Converting Company

Company Number 47-065-3455

Full Compliance Evaluation completed on December 12, 2006. Source was in
compliance 

Allowable Emissions	Particulate 	23.074 TPY

			NOx		96.76	TPY

			SO2		349.19 TPY

Allowable emissions are based on 2% sulfur content and 3,500,000 gallons
per year. Actual oil sulfur content is normally considerably less than
2%. Natural gas is the primary fuel and is used when it is available and
is cost competitive. 

This source is subject to the following;

40 CFR Part 70 Operating Permit Program

The following local rules;

		1. Particulate	Rule 26.6

		2. Opacity	Rule 3

		3. VOC	Rule 25.3

		4. SO2		4-60(d)(9)

 Actual emissions from the boilers in the last year are as follows

			Particulate 	15.25 TPY

			NOx		73.92 TPY

			SO2	          174.97  TPY

The lower actual emissions occurred because the facility used Number 6
fuel with a sulfur content of 1.61 % for the first 6 months and 0.99%
for the second six months of the year. 

This source is a candidate for contingency measures. Specifically, the
oil sulfur limit may be further restricted. 

Signal Mountain Cement

Company Number	47-065-3070

Reconstructed  	2001

Full Compliance Evaluation by Chattanooga-Hamilton County APCB November
26, 2006. The source was found to be In Compliance.

Full Compliance Evaluation by Region 4 March 13, 2007 the source was
found to be In Compliance.

Stack Tests 

NOx Sept 2001 and Jan 2007

	Particulate Sept 2001

	SO2 Sept 2001

	CO Sept 2001

	Opacity Sept 2001 

Emissions	Particulate 	64.18 tons per year

		NOx		1651 tons per year 		

		SO2		0

Subject to the following as adopted into the Chattanooga Air Pollution
Control Ordinance

 	1.   NOx  SIP Call

2. 40 CFR Part 63 Subpart LLL National Emissions Standards for  
Hazardous Air  Pollutants from the Portland Cement Industry 

3.  40 CFR Part 60 Subpart F Standards of Performance for Portland
Cement Plants

 4. 40 CFR Part 60 Subpart Y Standards of Performance for Coal
Preparation     Plants		

	5.   40 CFR Part 64 Compliance Assurance Monitoring  

	6.   40 CFR Part 70 Operating Permit Program

7.   Chattanooga Air Pollution Control Ordinance Rules 2.6, Rule 27,
Rule 26, and Rule 18 . 

COMS on Kiln Baghouse. Observed Opacity  between 0 and 5%.

Pressure differential recorded as required by the permit. All pressures
differentials in compliance

Periodic opacity readings recorded as required by the permit. No reading
in violation. 

NOx monitored using back end oxygen correlation in compliance. Recorded
at at least 1 minute intervals.

 

Nine Baghouses subject to CAM. One equipped with COMs. Eight require
pressure drop readings.

Daily qualitive visible observations for all emissions units except for
those equipped with COMs are required. If opacity is greater than 10 %
then a daily Method 9 reading is required. If the limit for a particular
unit is exceeded, then  a Method 9 reading is required daily until the
unit is in compliance.  

Archer Daniels Midland Company  d/b/a Southern Cellulose Products 

Company Number 3110

Full Compliance Evaluation was completed on November 1, 2006. 

Allowable Emissions	Particulate 	14.51	 lb/hr

NOx	No NOx limit for small boilers. Heaters NOx allowable 0.56 lb/hr
(Process Equipment)

			SO2		57.71	 lb/hr

Actual Emissions	Particulate 3.28 TPY

			NOx	      40.67 TPY

			SO2	      0.410    TPY		

This source is subject to the following rules.

		1. Particulate			Rule 26.6, 4-8(e)(2)(b), Rule 10  

		2. Process NOx		Rule   2.4

		2. Opacity			Rule   3, Rule 26.20

		3. SO2				Rule 13

Caraustar Mill Group, Inc. d/b/a Chattanooga   Paperboard

Company Number 47-065-0700

Full Compliance Evaluation completed on May 3, 2007.  The source was in
compliance.

Allowable Emissions	Particulate 	11.42 TPY

			NOx		30.078	TPY

			SO2		245 TPY

Allowable emissions are based on 2% sulfur content of fuel oil.  

Boiler #2 is subject to 40CFR Part 60 Subpart Dc Standard of Performance
for Small Industrial-Commercial-Institutional Steam Generating Units

The source is subject to;

40 CFR Part 70 Operating Permit Program

This source is subject to the following  local rules.

		1. Particulate	Rule 26.6

		2. Opacity	Rule 3

		3. VOC	Rule 25.3

		4. SO2		4-57(a)(1)

		5. Particulate	Rule 27

Ergon Terminaling RACT

Company Number 4040 

 Full Compliance Evaluation was completed on July 3, 2007. 

This permit applies to a terminal storage facility for asphalt cement,
caustic soda, and styrene monomer. On average, 32 barges per year are
unloaded per year. There are emissions of VOC from the products but the
heaters are the sources of PM2.5 precursors and direct PM2.5. The
facility operates 4 heaters and boilers. These are the following:

				Hopkins Thermal Liquid Heater	8.6 million BTU/hr

				VA Power Boiler			5    million BTU/hr					VA Power Thermal Liquid
heater          6.6 million BTU/hr

				Boiler B1  				13 million   BTU/hr

Allowable Emissions	Particulate 	8.20 lb/hr	 

			NOx		N/A

			SO2		10.15 lb/hr	

Actual Emissions	Particulate 	1.41 TPY

			NOx	       	14.12 TPY

			SO2	     	 50.13   TPY

Available Emission Factors show direct PM2.5 as 0.8820 TPY

 		

Boiler B1 is subject to 

40CFR Part 60 Subpart Dc- Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units.

The NSPS limits the sulfur in the fuel oil to 0.5% 

		Rule 8.2 limits particulate to 8.2 lb/hr

INVISTA S.à.r.l., LLC

Company Number	47-065-3889

INVISTA, at this time consists of three sources. The sources are
INVISTA, Kordsa, and DuPont. 98.9% of the emissions are from INVISTA.
Changes in ownership are such that this permit will soon be broken into
three. INVISTA will be the only one of the three that will be a major
source. 

Full Compliance Evaluation completed on May 18, 2006. The source was in
compliance.   

 

Emissions	Particulate	40.60 tons per year

		NOx		273.27 tons per year

		SO2		828.44 tons per year

Subject to the following as adopted into the Chattanooga Air Pollution
Control Ordinance

		

	1.   40 CFR Part 64 Compliance Assurance Monitoring  

	2.   40 CFR Part 70 Operating Permit Program

3.  40 CFR Part 60 Subpart Dc Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units.

4. Chattanooga Air Pollution Control Ordinance 4-8(e)(2), Rule 2, Rule
3, Rule 10, Rule 13,  Rule 26, and Rule 27. 

This source is a major source because of combustion emissions. 

Boilers 1 and 2

	Natural Gas Primary Fuel 

Fuel oil limited to 1.830,000 gallons per year in boilers with 0.3 %
sulfur.

Monitored by recordkeeping

Opacity limit 10%

Boilers 3, 4, and 5

	Bituminous Coal Fuel limited to 112,000 tons per year.

	Sulfur limited to 1.25 % by weight.

	Particulate limited by Rule 26

	Baghouse control.

	Sulfur monitored by fuel testing.

Coal-fired boilers demonstrated the same emissions as original tests
when Method 5 was performed as part of the Site Specific Health Based
Compliance Demonstration

	

Vaporizers 1, 2, 3, 4, 5, and 6.  

	Limited to natural gas and Number 2 fuel oil.

10% opacity limit

Limited to 2,000,000 gallons per year.

Fuel oil limited to 0.3% sulfur.

Dowtherm Transport System

	Condensers followed by demisters

Continuous Polymerization Line II

	Scrubber control 

.

Particulate from polyester flake handling 

	Controlled by 9 bag houses and 2 HEPA filters

Particulate from hot chest exhausts of Spinning Machines
201,202,203,211,221,231,241, and 251

 Controlled by ESPs.

All control systems have required monitoring in the permit to insure
that the controls are working as designed. 

Mueller Company

Company Number	47-065-2150

Reconstructed  	1999

Full Compliance Evaluation by Chattanooga-Hamilton County APCB, November
26 2006. The source was found to be In Compliance.

Full Compliance Evaluation by Region 4, March 13, 2007.  The source was
found to be In Compliance.

Emissions	Particulate  47.8  tons per year

		NOx	17.14 tons per year 		

		SO2	3.6 	tons per year	

Subject to the following as adopted into the Chattanooga Air Pollution
Control Ordinance

 	

1. 40 CFR Part 63 Subpart EEEEE National Emissions Standards for
Hazardous Air  Pollutants from the Iron and Steel Foundrys

	5.   40 CFR Part 64 Compliance Assurance Monitoring  

	6.   40 CFR Part 70 Operating Permit Program

7 40 CFR Part 60 Subpart Cc Standards of Performance for Small
Industrial-Commercial-Institutional Steam Generating Units.

8 Chattanooga Air Pollution Control Ordinance Rules, Rule 27, Rule 26,
Rule 3, Rule 2, Rule 10, Rule 13, Rule 2, Rule 18. 

 

Pressure differential recorded as required by the permit. All pressures
differentials in compliance

Bag leak detectors as required by the MACT are in place

Periodic opacity readings recorded as required by the permit. No reading
in violation. 

Eight baghouses are subject to CAM. These require daily pressure drop
readings.

Four emission points are controlled by a HEPA filter in series with a
baghouse. 

Foundry visible emissions 10 % except for emissions from buildings and
then iyt is 5%. 

Foundry landfill visible emissions limit is 10%. 

Saint-Gobian  Norpro RACT

Company Number 2220

Full Compliance Evaluation completed on December 8, 2006. The source was
in compliance 

Allowable Emissions	Particulate 	83.5	 TPY

			NOx		10	TPY

			SO2		72	 TPY

Actual Emissions	Particulate 10.2 TPY

			NOx	       3.5 TPY

			SO2	      20    TPY		

This source is subject to the following rules.

		1. Particulate			Rule 10.3 , Rule 26.3, and 4-8(e)(2)(b)

		2. Process NOx		Rule   2.4

		2. Opacity			Rule   3  10% Opacity limits

		3. Process gaseous emissions	Rule 23

		4. SO2				Rule 13.2

Southeastern Materials (Shallowford Plant) 

Company Number 6008

Full Compliance Evaluation was completed on June 23, 2006. The source
was in compliance.

Allowable Emissions	Particulate 	71.83	 TPY

			NOx		24.3	TPY

			SO2		6.69	 TPY

Actual Emissions	Particulate 	22.1 TPY

			NOx	      	 20.5 TPY

			SO2	      	2.25    TPY

Available Emission Factors show direct PM2.5 as 2.25 TPY

 		

This source is subject to the following :

40CFR Part 60 Subpart I Standards of Performance for Hot Mix Asphalt
Facilities

The NSPS sets a PM emissions limit of 0.04 gr/dscf and a visible
emission limit of less than 20%.

		The facility is subject to the following local Rules;

Rule 27.1 which requires particulate BACT applies. The NSPS particulate
limit is considered as BACT but a 10% opacity limit is required under
Rule 27.1

Rule 2.4  limits NOx emissions to 300 ppm

Rule 13 limits SO2 to 300 ppm. 

The stack test required by the NSPS was conducted in August 1999. 



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