ISSUED TO:

Ochoco Lumber Company

PO Box 160

John Day, OR 97845

INFORMATION RELIED UPON:

Application No.:  26565

Date Received:  11/21/2011

PLANT SITE LOCATION:

Malheur Lumber Company

60339 West Highway 26

John Day, OR 97845

LAND USE COMPATIBILITY FINDING:

Approving Authority:  Grant County &

City of John Day

Approval Date:  11/1983

Table 1 Code

Source Description

SIC

Part B, 13

Boilers and other Fuel Burning Equipment over 10 MMBtu/hr. heat input, except exclusively Natural Gas and Propane fired units (with or without #2 diesel backup) under 30 MMBtu/hr. heat input.

2421

Part B, 71

Sawmills and/or Planing Mills 25,000 or more bd.ft./maximum 8 hr. finished product.

4961

1.1.  Visible Emissions

Emissions from any air contaminant source must not equal or exceed 20% opacity for a period aggregating more than 3 minutes in any one hour.

1.2.  Particulate Matter Emissions

The permittee must comply with the following particulate matter emission limits, as applicable:

a.  Particulate matter emissions from the Wellons Boilers must not exceed 0.1 grains per standard cubic foot, corrected to 12% CO₂ or 50% excess air.

b.  Particulate matter emissions from any air contaminant source other than the Wellons Boilers and fugitive emission sources must not exceed 0.1 grains per standard cubic foot.

1.3.  Fugitive Emissions

The permittee must take reasonable precautions to prevent fugitive dust emissions by:

a.  Treating vehicular traffic areas of the plant site under the control of the permittee.

b.  Operating all air contaminant-generating processes so that fugitive type dust associated with the operation will be adequately controlled at all times.

c.  Storing collected materials from air pollution control equipment in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer.

1.4.  Particulate Matter Fallout

The permittee must not cause or permit the emission of any particulate matter larger than 250 microns in size at sufficient duration or quantity, as to create an observable deposition upon the real property of another person. DEQ will verify that the deposition exists and will notify the permittee that the deposition must be controlled.

1.5.  Nuisance and Odors

The permittee must not cause or allow air contaminants from any source to cause a nuisance. Nuisance conditions will be verified by DEQ personnel.

2.1.  Wellons Boilers – 40 CFR Part 63, Subpart JJJJJJ NESHAP Requirements

The NESHAP/MACT Standard for Industrial, Commercial and Institutional Boilers - Boiler Area Source MACT (40 CFR Part 63 Subpart JJJJJJ) applies to the Wellons Boilers because these boilers combust biomass. The permittee may only burn biomass. Biomass means any biomass-based solid fuel that is not a solid waste as defined in 40 CFR 241.3. This includes, but is not limited to:

•  Wood residue and wood products, including trees, tree stumps, tree limbs, bark, lumber, sawdust, sander dust, chips, scraps, slabs, millings and shavings;

•  Animal manure, including litter and other bedding materials;

•  Vegetative agricultural and silvicultural materials, including logging residues (slash), nut and grain hulls and chaff , bagasse, orchard prunings, corn stalks, coffee bean hulls and grounds.

Boiler Tune-Up Requirements

No later than March 21, 2012, the permittee must conduct a performance tune-up and every two years thereafter as follows: [40 CFR 63.11196(a)(1), 63.11201(b), 63.11214(b) and 63.11223]

a.  Inspect the burner, and clean or replace any components of the burner as necessary. The burner inspection may be delayed until the next scheduled boiler shutdown, but each burner must be inspected at least once every 36 months;

b.  Inspect the flame pattern, and adjust the burner as necessary to optimize the flame pattern. Any adjustment must be consistent with the manufacturer’s specifications for the burner, if available;

c.  Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure it is correctly calibrated and functioning properly;

d.  Measure the exhaust concentration of carbon monoxide (ppmv) and oxygen (%), before and after the adjustments are made. Measurements may be made either on a dry or wet basis, as long as it is the same basis before and after any adjustments are made;

e.  Optimize the total emissions of carbon monoxide. This optimization must be consistent with the manufacturer’s specifications, if available;

f.  If the boiler is not operating on the required date for the tune-up, the tune-up must be conducted within one week of startup; and

g.  Each biennial tune-up must be conducted no more than 25 months after the previous tune-up.

2.2.  Tune-Up Reports

The permittee must maintain biennial reports containing the tune-up information as required in Condition 2.2, specifically: [40 CFR 63. 11223(b)(6) (i) through (iii) and 63.11225(c)(2) (i) and (ii)]

a.  Identification of the boiler, date of tune up, the procedures followed for the tune-up, and the manufacturer’s specifications to which the boiler was tuned;

b.  The CO concentrations in the exhaust in ppmv, and oxygen %, measured before and after the tune-up, as detailed in Condition 2.2.d;

c.  A description of any corrective actions taken as part of the tune-up;

d.  The type and amount of fuel used each month over the 12 months prior to the biennial tune-up; and

e.  These records must be maintained onsite, in a form suitable for inspection and/or submittal upon request.

2.3.  Notification of Compliance Status for the Initial Tune-Up

No later than July 19, 2012, the permittee must submit the Notification of Compliance Status including the statement, signed by the responsible official, that states: “This facility complies with the requirements in 40 CFR 63.11214 to conduct an initial tune-up of the boiler.” [40 CFR 63.11225(a)(4)(i)]

2.4.  Energy Assessment

No later than March 21, 2014, the permittee must conduct an energy assessment of the boilers and their energy use systems. [40 CFR 63.11214(c), 63.11237 and Table 2 to Subpart JJJJJJ of Part 63]

a.  The energy assessment must be conducted as follows dependent on the annual heat input to the facility:

i.  For facilities with affected boilers using less than 300,000 MMBtu (0.3 trillion Btu) per year total heat input, the energy assessment must be no less than one day in length. The boiler system and energy use system accounting for at least 50 percent of the affected boiler(s) energy output must be evaluated to identify energy saving opportunities.

ii.  For facilities with affected boilers and process heaters using greater than 300,000 MMBtu (0.3 trillion Btu), but less than 1,000,000 MMBtu (1 trillion Btu) per year total heat input, the energy assessment must be no less than three days in length. The boiler system and energy use system accounting for at least 33 percent of the affected boiler(s) energy output must be evaluated to identify energy saving opportunities.

iii.  For facilities with affected boilers and process heaters using more than 1,000,000 MMBtu (1 trillion Btu) per year total heat input. The boiler system and energy use system accounting for at least 20 percent of the affected boiler(s) energy output must be evaluated to identify energy saving opportunities

The energy assessment must include:

iv.  A visual inspection of the boiler system;

v.  An evaluation of operating characteristics of the facility, specifications of energy use systems, operating and maintenance procedures, and unusual operating constraints;

vi.  Energy use systems include, but are not limited to process heating, compressed air systems, machine drive (pumps, motors, fans), process cooling, facility heating, ventilation and air conditioning (HVAC) systems, hot heater systems, building envelope, and lighting;

vii.  An inventory of major systems consuming energy from each affected boiler(s);

viii.  A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage;

ix.  A list of major energy conservation measures; and

x.  A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments.

Notification of Compliance Status for the Energy Assessment

No later than July 19, 2014, the permittee must submit the Notification of Compliance Status including the statement, signed by the responsible official, that states: “This facility has had an energy assessment performed according to 40 CFR 63.11214(c).” This energy assessment report must be submitted upon request. [40 CFR 63.11225(a)(4)(ii)]

2.5.  Ongoing Reporting, Notification, and General Provision Requirements

a.  The permittee must prepare a biennial compliance report and include it with the annual report specified in Condition 6.2. The report must include the following: [40 CFR 63.11225(b)]

i.  Company name and address;

ii.  Statement by a responsible office, with the official’s name, title, phone number, e-mail address and signature, certifying the truth, accuracy and completeness of the notification and a statement of whether the source has complied with all of the relevant standards and other requirements of 40 CFR Part 63, Subpart JJJJJJ; and

iii.  If the source experiences any deviations from the applicable requirements during the reporting period, include a description of the deviations, the time periods during which the deviations occurred, and the corrective action taken.

Notification 30 days prior to commencing combustion of solid waste including the following information: [40 CFR 63.11225(f)]

iv.  The name of the owner or operator of the affected source, the location of the source, the boilers(s) that will commence burning solid waste, and the date of the notice;

v.  The currently applicable subcategory under 40 CFR Part 63, Subpart JJJJJJ;

vi.  The date on which the boilers became subject to the currently applicable emission limits; and

vii.  The date upon which combusting solid waste will commence.

Notification 30 days prior to switching to a fuel(s) that may result in the applicability of a different subcategory or a switch out of 40 CFR Part 63, Subpart JJJJJJ due to a switch to 100 percent natural gas, including the following information: [40 CFR 63.11225(g)]

viii.  The name of the owner or operator of the affected source, the location of the source, the boiler(s) that will switch fuels, and the date of the notice;

ix.  The currently applicable subcategory under 40 CFR Part 63, Subpart JJJJJJ;

x.  The date on which the boilers became subject to the currently applicable emission limits; and

xi.  The date upon which the fuel switch will commence.

The General Provisions of 40 CFR Part 63 are incorporated by reference in accordance with Table 8 of Subpart JJJJJJ. [40 CFR 63.11235]

3.1.  Plant Site Emission Limits (PSEL)

Plant site emissions must not exceed the following:

Pollutant

Limit

Units

PM

24

tons per year

PM₁₀

17

tons per year

PM_2.5

12

tons per year

SO₂

39

tons per year

NO_x

39

tons per year

CO

99

tons per year

VOC

86

tons per year

Annual Period

The annual plant site emissions limits apply to any 12-consecutive calendar month period.

4.1.  Testing Requirements

By no later than January 1, 2015, the permittee must demonstrate the Wellons hogged fuel boilers and the pellet chip dryer cyclones (DMM2a & b) are capable of operating at their maximum operating capacity in compliance with Condition 1.2 by conducting a source test for Particulate Matter (PM). During the test, CO and NO_x emissions must also be measured at the hogged fuel boilers multiclones and Volatile Organic Compounds (VOCs) are to be measured at the pellet chip dryer cyclones. The test must be performed using the following test methods and procedures:

The following test methods must be used for the following parameters:

i.  ODEQ Method 7 must be used for PM Emissions;

ii.  EPA Method 10 for CO emissions;

iii.  EPA Method 7E for NO_x emissions; and,

iv.  EPA Method 25A for VOC emissions.

b.  Each Method 7 test run must represent a minimum of 31.8 dry standard cubic feet sample volume for PM.

c.  Each run must be conducted at a minimum of 90% of maximum operating capacity.

d.  The following parameters must be monitored and recorded during the source test:

i.  

ii.  Visible emissions as measured by EPA Method 9 for a period of at least six minutes during or within 30 minutes before or after each test run;

iii.  

iv.  Steam production rate, steam temperature, fuel species and moisture content of hogged fuel, NO_x emission factor (lb/Mlb steam) and CO emission factor (lb/Mlb steam);

v.  

vi.  Pressure drops across the multiclones (inches of water column); and,

vii.  

viii.  Species and amount of wood processed through each dryer cyclone DMM2a & b; operating and exhaust temperatures (^oF) of each dryer cyclone. PM (lb/ODT) emission factors. VOC emission factors for Douglas Fir/Larch (lb/ODT), Ponderosa Pine (lb/ODT), and Hemlock/White Fir (lb/ODT).

e.  All tests must be conducted in accordance with DEQ’s Source Sampling Manual and the approved pretest plan. The pretest plan must be submitted at least 15 days in advance and approved by the Regional Source Test Coordinator. Test data and results must be submitted for review to the Regional Source Test Coordinator within 30 days unless otherwise approved in the pretest plan.

f.  Only regular operating staff may adjust the combustion system or production processes and emission control parameters during the source test and within two hours prior to the source test. Any operating adjustments made during the source test, which are a result of consultation with source testing personnel, equipment vendors or consultants, may render the source test invalid.

4.2.  Monitoring Requirements

The permittee must monitor the operation and maintenance of the plant and associated air contaminant control devices as follows:

a.  All operating and production parameters to be reported to the Department annually as required in Condition 5.1.b.

b.  Records of excess emissions (recorded on occurrence).

c.  A description of any maintenance to the air pollution control system (recorded on occurrence).

4.3.  PSEL Compliance Monitoring

Compliance with the PSEL is determined for each 12-consecutive calendar month period based on the following calculation for each pollutant:

E  =  S(EF x P)/2000 lbs

Where,

E  =  pollutant emissions (ton/yr);

EF  =  pollutant emission factor (see Condition 10.0);

P  =  process production (see Condition 6.2.a)

4.4.  Emission Factors

The permittee must use the default emission factors provided in Condition 10.0 for calculating pollutant emissions, unless alternative emission factors are approved by DEQ. The permittee may request or DEQ may require using alternative emission factors provided they are based on actual test data or other documentation (e.g., AP-42 compilation of emission factors) that has been reviewed and approved by DEQ.

5.1.  Operation and Maintenance

The permittee must maintain the following records related to the operation and maintenance of the plant and associated air contaminant control devices:

Logs of any repairs or maintenance to the multiclones, recorded on occurrence.

a.  PSEL Compliance Monitoring:

i.  Steam Production (lbs/month).

ii.  Amount of lumber, by species, kiln dried (bd.ft/month).

iii.  Throughput of wood chips, by species, dryer cyclone: Douglas Fir/Larch (ODT /month); Ponderosa Pine (ODT/month); Hemlock/White Fir (ODT/month).

iv.  Total wood chip throughput in dryer cyclones (ODT/month)

v.  Cyclone throughput (BDT/month).

vi.  Monthly emissions calculated in accordance with Condition 4.3.

5.2.  Excess Emissions

The permittee must maintain records of excess emissions as defined in OAR 340-214-0300 through 340-214-0340 (recorded on occurrence). Typically, excess emissions are caused by process upsets, startups, shutdowns, or scheduled maintenance. In many cases, excess emissions are evident when visible emissions are greater than 20% opacity for 3 minutes or more in any 60-minute period. If there is an ongoing excess emission caused by an upset or breakdown, the permittee must cease operation of the equipment or facility no later than 48 hours after the beginning of the excess emissions, unless continued operation is approved by DEQ in accordance with OAR 340-214-0330(4).

5.3.  Complaint Log

The permittee must maintain a log of all written complaints and complaints received via telephone that specifically refer to air pollution concerns associated to the permitted facility. The log must include a record of the permittee’s actions to investigate the validity of each complaint and a record of actions taken for complaint resolution.

5.4.  Retention of Records

Unless otherwise specified, all records must be maintained on site for a period of two (2) years and made available to DEQ upon request.

6.1.  Excess Emissions

The permittee must notify DEQ of excess emissions events if the excess emission is of a nature that could endanger public health.

Such notice must be provided as soon as possible, but never more than one hour after becoming aware of the problem. Notice must be made to the regional office identified in Condition 7.4 by email, telephone, facsimile, or in person.

a.  If the excess emissions occur during non-business hours, the permittee must notify DEQ by calling the Oregon Emergency Response System (OERS). The current number is 1-800-452-0311.

b.  The permittee must also submit follow-up reports when required by DEQ.

6.2.  Annual Report

For each year this permit is in effect, the permittee must submit to DEQ by February 15 two (2) copies of the following information for the previous calendar year:

a.  Operating parameters:

i.  Sawmill production (bd.ft/yr).

ii.  Lumber dried in kilns by species (bd.ft/yr)

iii.  Type and amount of wood waste processed through each cyclone (BDT/yr).

iv.  Annual steam production of the boilers (lb/yr steam).

v.  Throughput of wood chips, by species, dryer cyclone: Douglas Fir/Larch (ODT /month); Ponderosa Pine (ODT/month); Hemlock/White Fir (ODT/month).

vi.  Total wood chip throughput in dryer cyclones (BDT /month)

vii.  Wood pellet and brick production (tons/yr).

viii.  Annual emissions calculated according to Condition 4.3.

b.  Records of all planned and unplanned excess emissions events.

c.  Summary of complaints relating to air quality received by permittee during the year.

d.  List permanent changes made in plant process, production levels, and pollution control equipment which affected air contaminant emissions.

e.  List major maintenance performed on pollution control equipment.

6.3.  Notice of Change of Ownership or Company Name

The permittee must notify DEQ in writing using a Departmental “Transfer Application” form (AQ103) within 60 days after the following:

a.  Legal change of the name of the company as registered with the Corporations Division of the State of Oregon; or

b.  Sale or exchange of the activity or facility.

6.4.  Construction or Modification Notices

The permittee must notify DEQ in writing using a Departmental “Notice of Intent to Construct” form (AQ104) or other permit application forms, and obtain approval in accordance with OAR 340-210-0205 through 340-210-0250 before:

a.  Constructing, installing, or establishing a new stationary source that will cause an increase in any regulated pollutant emissions;

b.  Making any physical change or change in operation of an existing stationary source that will cause an increase, on an hourly basis at full production, in any regulated pollutant emissions; or

c.  Constructing or modifying any air pollution control equipment.

6.5.  Where to Send Reports and Notices

The reports, with the permit number prominently displayed, must be sent to the Permit Coordinator for the region where the source is located as identified in Condition 7.3.

7.1.  Permit Renewal Application

The completed application package for renewal of this permit is due on May 1, 2017. Two (2) copies of the application must be submitted to the DEQ Permit Coordinator listed in Condition 7.3

Permit Modifications

Application for a modification of this permit must be submitted not less than 60 days prior to the source modification. A special activity fee must be submitted with an application for the permit modification. The fees and two (2) copies of the application must be submitted to the DEQ Business Office.

7.2.  Permit Coordinator’s Address

All reports, notices and applications should be directed to the Permit Coordinator for the area where the source is located. The Permit Coordinator’s address is as follows:

Department of Environmental Quality

Eastern Region - Bend Office

475 NE Bellevue Drive, Suite 110

Bend, OR 97701-7415

Telephone: (541) 633-2021

7.3.  Department Contacts

Information about air quality permits and DEQ’s regulations may be obtained online at www.oregon.gov/DEQ/. All inquiries about this permit should be directed to the regional office for the area where the source is located. DEQ’s regional office is as follows:

8.1.  Annual Compliance Fee

The Annual Fee specified in OAR 340-216-0020, Table 2, Part 2 for a Standard ACDP is due on December 1 of each year this permit is in effect. An invoice indicating the amount, as determined by DEQ regulations will be mailed prior to the above date. Late fees in accordance with Part 4 of the table will be assessed as appropriate.

8.2.  Change of Ownership or Company Name Fee

The non-technical permit modification fee specified in OAR 340-216-0020, Table 2, Part 3(a) is due with an application for changing the ownership or the name of the company.

Special Activity Fees

The special activity fees specified in OAR 340-216-0020, Table 2, Part 3 (b through i) are due with an application to modify the permit.

8.3.  Where to Submit Fees

Fees must be submitted to:

Department of Environmental Quality

Business Office

811 SW Sixth Avenue

Portland, OR 97204-1390

9.1.  Permitted Activities

This permit allows the permittee to discharge air contaminants from processes and activities related to the air contaminant source(s) listed on the first page of this permit until this permit expires, is modified, or is revoked.

Other Regulations

In addition to the specific requirements listed in this permit, the permittee must comply with all other legal requirements enforceable by DEQ.

9.2.  Conflicting Conditions

In any instance in which there is an apparent conflict relative to conditions in this permit, the most stringent conditions apply.

9.3.  Masking of Emissions

The permittee must not cause or permit the installation of any device or use any means designed to mask the emissions of an air contaminant that causes or is likely to cause detriment to health, safety or welfare of any person or otherwise violate any other regulation or requirement.

9.4.  Department Access

The permittee must allow DEQ’s representatives access to the plant site and pertinent records at all reasonable times for the purposes of performing inspections, surveys, collecting samples, obtaining data, reviewing and copying air contaminant emissions discharge records and conducting all necessary functions related to this permit in accordance with ORS 468-095.

9.5.  Permit Availability

The permittee must have a copy of the permit available at the facility at all times.

9.6.  Open Burning

The permittee may not conduct any open burning except as allowed by OAR 340 Division 264.

Asbestos

The permittee must comply with the asbestos abatement requirements in OAR 340, Division 248 for all activities involving asbestos-containing materials, including, but not limited to, demolition, renovation, repair, construction and maintenance.

9.7.  Property Rights

The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of federal, state, or local laws or regulations.

9.8.  Permit Expiration

a.  A source may not be operated after the expiration date of the permit, unless any of the following occur prior to the expiration date of the permit:

i.  a timely and complete application for renewal or for an Oregon Title V Operating Permit has been submitted, or

ii.  another type of permit (ACDP or Oregon Title V Operating Permit) has been issued authorizing operation of the source.

b.  For a source operating under an ACDP or Oregon Title V Operating Permit, a requirement established in an earlier ACDP remains in effect notwithstanding expiration of the ACDP, unless the provision expires by its terms or unless the provision is modified or terminated according to the procedures used to establish the requirement initially.

Permit Termination, Revocation, or Modification

DEQ may modify or revoke this permit pursuant to OAR 340-216-0082 and 340-216-0084.

Emissions Device or Activity

Pollutant

Emission Factor (EF)

EF Units

EF Reference

Boilers

PM

0.17

lb/M lb steam

1985, 1999, 2009 ST

PM₁₀

0.15

DEQ Est.

PM_2.5

0.09

DEQ (AQ-EF08)

SO₂

0.014

DEQ

NO_X

0.37

1999& 2009 ST

CO

0.38

VOC

0.13

DEQ

Cyclones

PM

0.5

lb/BDT

DEQ (AQ-EF02)

PM₁₀

0.25

DEQ Est. &

(AQ-EF03)

PM_2.5

0.25

Dry Kiln

PM

0.02

lb/M bd ft

1996 NCASI Study

PM₁₀

0.02

PM_2.5

0.02

VOC (pine)

2.7

VOC (fir)

0.7

Pellet Chip Dryer Cyclones

PM

0.26

lb/ODT

2011 ST

PM₁₀

0.21

DEQ (AQ-EF03)

PM_2.5

0.13

VOC (Douglas Fir/Larch)

0.6

lb/ODT

DEQ (AQGP-110) Steam Kiln

VOC (Ponderosa Pine)

2.85

lb/ODT

2011 ST

VOC (Hemlock/White Fir)

0.33

lb/ODT

DEQ (AQGP-110) Steam Kiln

Pellet Cooler Cyclone

PM

0.03

lb/ODT

Estimate

PM₁₀

0.015

lb/ODT

PM_2.5

0.015

lb/ODT