"...prior to facility operations the following Authority to Construct (ATC) permits would need to be converted to Permits to Operate (PTO) through the significant modification process:
ATC #348-1 Electrostatic Precipitator (ESP) - Lime Kiln
ATC #413-1 Emergency Generator - Lime Kiln
ATC #540=1 D-GLU Project
ATC #593-1 Smelt Dissolver with Venturi Scrubber
To incorporate these permits into the existing Title V Permit, Freshwater will need to submit Significant Modification applications to the District to accomplish these permit actions. While the District will certainly process such applications as soon as possible, there are some time constraints that would affect any potential mill startup. Within the District Rules and Regulations, Rule 503(3.0) affords up to 18 months for the District to review and issue a significant permit modification, which must occur prior to any startup.
The District is also aware of recent activities of the Regional Water Quality Control Board to consider changes contained in a proposed revision to the mill's discharge permit. Proposed changes, specifically as they relate to air quality impacts will also require the submittal of an air quality permit application(s). The potential air quality impacts would need to be quantified and changes in emissions and/or equipment affecting air quality may also need to gain permit approval prior to startup."