Proposed Rules 234 240 gfd

340-234-0510

Veneer and Plywood Manufacturing Operations

(1) Veneer Dryers:

(a) Consistent with OAR 340-234-0500(1) through (3), it is the object of this section to control air contaminant emissions, including, but not limited to, condensable hydrocarbons such that visible emissions from each veneer dryer are limited to a level which does not cause a characteristic "blue haze" to be observable;

(b) No person may operate any veneer dryer such that visible air contaminants emitted from any dryer stack or emission point exceed:

(A) A daily average operating opacity of 10 percent on more than two days within any 12-month period, with the days separated from each other by at least 30 days, and with opacity determined by EPA Method 9; or

Original language:

(b) No person shall operate any veneer dryer such that visible air contaminants emitted from any dryer stack or emission point exceed:

(A) An average operating opacity of ten percent; and

"Average Operating Opacity" means the opacity of emissions determined using EPA Method 9 on any three days within a 12-month period which are separated from each other by at least 30 days; a violation of the average operating opacity limitation is judged to have occurred if the opacity of emissions on each of the three days is greater than the specified average operating opacity limitation.

(B) A maximum opacity of 20 percent as measured by EPA Method 9 at any time.

340-240-0120

Veneer Dryer Emission Limitations

(1) No person may operate any veneer dryer such that visible air contaminants emitted from any dryer stack or emission point exceed the opacity limits specified in subsection (a) or such that emissions of particulate matter exceed the mass emission limits of subsections (b) through (f):

(a)(i) A daily average operating opacity of five percent on more than two days within any 12-month period, with the days separated from each other by at least 30 days, and with opacity determined by EPA Method 9; or

Original language:

(ii) A maximum opacity of ten percent as a six minute average as measured by EPA Method 9 at any time, unless the permittee demonstrates by source test that it can achieve the emission limits in subsections (b) through (f) at higher visible emissions than specified in subsection (a) , but in no case may emissions exceed the visible air contaminant limitations of OAR 340-234-0510(1)(b). Specific opacity limits will be included in the permit for each affected source;

(b) 0.30 pounds per 1,000 square feet of veneer dried (3/8" basis) for direct natural gas or propane fired veneer dryers;

(d) 0.40 pounds per 1,000 square feet of veneer dried (3/8" basis) for direct wood fired veneer dryers using fuel which has a moisture content equal to or less than 20 percent by weight on a wet basis as measured by ASTM D4442-84;

(e) 0.45 pounds per 1,000 square feet of veneer dried (3/8" basis) for direct wood fired veneer dryers using fuel which has a moisture content greater than 20 percent by weight on a wet basis as measured by ASTM D4442-84; or

(f) In addition to subsections (e) and (f), 0.20 pounds per 1,000 pounds of steam generated in any boiler that exhausts its combustion gases to the veneer dryer.

(2) Exhaust gases from fuel burning equipment vented to the veneer dryer are exempt from OAR 340-228-0210.

(3) No person may operate a veneer dryer unless:

(a) The owner or operator has submitted a program and time schedule for installing an emission-control system which has been approved in writing by DEQ as being capable of complying with subsections (1)(a) through (g);

(b) The veneer dryer is equipped with an emission-control system which has been approved in writing by DEQ and is capable of complying with subsections (1)(a) through (g); or

(c) The owner or operator has demonstrated and DEQ has agreed in writing that the dryer is capable of being operated and is operated in continuous compliance with subsections (1)(a) through (g).

(4) Each veneer dryer must be maintained and operated at all times such that air contaminant generating processes and all contaminant control devices are at full efficiency and effectiveness so that the emission of air contaminants is kept at the lowest practicable levels.

(5) No person may willfully cause or permit the installation or use of any means, such as dilution, which, without resulting in a reduction in the total amount of air contaminants emitted, conceals an emission which would otherwise violate this rule.

(6) Where effective measures are not taken to minimize fugitive emissions, DEQ may require that the equipment or structures in which processing, handling and storage are done, be tightly closed, modified, or operated in such a way that air contaminants are minimized, controlled, or removed before discharge to the open air.

[NOTE: These rules are included in the State of Oregon Clean Air Act Implementation Plan as adopted by the EQC under OAR 340-200-0040.]

Stat. Auth.: ORS 468 & 468A

Stats. Implemented: ORS 468A.025

Hist.: DEQ 22-1989, f. & cert. ef. 9-26-89; DEQ 23-1991, f. & cert. ef. 11-13-91; DEQ 4-1993, f. & cert. ef. 3-10-93; DEQ 14-1999, f. & cert. ef. 10-14-99, Renumbered from 340-030-0021; DEQ 6-2001, f. 6-18-01, cert. ef. 7-1-01; DEQ 1-2005, f. & cert. ef. 1-4-05

George, 2014-04-16T07:55:00Z
This is my proposed rewrite of this rule. Basically, the rule says “no one may exceed…average opacity of 10 percent…with a violation if average opacity exceeds 10 percent on 3 days”. So first, this is a “daily average opacity” limit; second, this limit can be exceeded for up to 2 days in any 12 month period (it’s a violation if the average is exceeded for 3 days or more).

What do you mean by a daily average opacity? Does that mean more than one method 9? Do they have to read all day?

Mark, 2014-04-15T05:54:00Z
George?

George, 2014-04-15T15:55:00Z

Note corrections here to match the renumbering below.

Mark, 2014-04-15T06:59:00Z
An average operating opacity of five percent on each of three separate days; or

I wasn’t sure if this was to be tested in the same way as in division 234, above—i.e., with the days separated by at least 30 days, and within a 12-month period. If so, then I recommend copying that language here.

Gfd- yes, same language so I copied from 234