Eastern RegionSTANDARD AIR CONTAMINANT DISCHARGE PERMIT

REVIEW REPORT

Department of Environmental Quality

Source Information:

Compliance and Emissions Monitoring Requirements:

Reporting Requirements

Air Programs

TABLE OF CONTENTS

PERMITTING  3

SOURCE DESCRIPTION  3

COMPLIANCE  4

EMISSIONS  5

TITLE V MAJOR SOURCE APPLICABILITY  6

ADDITIONAL REQUIREMENTS  6

SOURCE TESTING  7

PUBLIC NOTICE  8

EMISSION DETAIL SHEETS  9

PERMITTING

PERMITTEE IDENTIFICATION

1.  Ochoco Lumber Company is located at Malheur Lumber Company, 60339 West Highway 26, John Day, Oregon 97845.

PERMITTING ACTION

2.  The proposed permit is a renewal of an existing Air Contaminant Discharge Permit (ACDP) that was issued on September 21, 2007, and was originally scheduled to expire on February 1, 2012. The existing ACDP remains in effect until the proposed permit is issued because the permittee submitted a timely and complete application for renewal.

OTHER PERMITS

3.  No other permits have been issued or are required by the DEQ for this source.

ATTAINMENT STATUS

4.  The source is located within 10 kilometers of the Strawberry Mountain Wilderness Class I Air Quality Protection Area, but this is neither a new or modified source.

SOURCE DESCRIPTION

OVERVIEW

5.  The permittee operates a sawmill and planing facility in John Day, Oregon. The plant consists of two existing 16,500 lb/hr steam Wellons hogged fuel boilers with multiclones and drying kilns. The annual pounds of steam produced from the combined boilers is approximately 160 MM lb/year – steam. The facility commenced operation in 1984.

6.  On October 29, 2010, the facility was issued a permit modification for the construction and operation of a compressed wood process that manufactures wood bricks and pellets. Chips, sawdust, shavings or waste wood are placed on an asphalt storage pad with an automated chain reclaimer. The wood is conveyed and milled in a primary hammermill; dried in a horizontal, steam heated, moving belt dryer; ground in a secondary hammermill; and, compressed in brick and pellet machines. The dryer is heated from the two existing Wellons hogged fuel boilers. Pellets are cooled and stored in a silo. Pellets and bricks are shipped in bulk or bagged. Production capacity is 4 – 6 oven dried (OD) tons per hour or approximately 25,000 OD tons per year. The new pellet and brick process added five emission points to the facility: two dyer cyclones, a pellet cooler cyclone, a wood silo vent filter, and a pellet bin vent filter. The facility does not have the steam capacity to operate the wood chip process dryer concurrently with the drying kilns. The cooler cyclone and vent filters contribute negligible emissions. For these reasons the addition of the wood pellet and brick process did not increase the Plant Site Emission Limits.

PROCESS AND CONTROL DEVICES

7.  Existing air contaminant sources at the facility consist of the following:

a.  Two 16,500 lb/hr Wellons hogged fuel boilers, with model #W-24 multiclone emission controls, installed in 1983.

b.  One cyclone which exhausts directly to the atmosphere, handling planer shavings, installed in 1983.

c.  Seven tracks of lumber drying kilns, with no emission controls, installed in 1983.

d.  Two dyer cyclones, a pellet cooler cyclone, a wood silo vent filter, and a pellet bin vent filter installed in 2010.

e.  Fugitive emissions from vehicular traffic and miscellaneous operations.

COMPLIANCE

8.  The facility will be inspected by DEQ personnel to ensure compliance with the permit conditions.

9.  The facility was not inspected during the prior permit period.

10.  During the prior permit period there were no complaints recorded for this facility.

11.  During the prior permit period there were no enforcement actions taken against the source.

EMISSIONS

12.  Proposed Plant Site Emission Limits:

a.  The proposed PSELs for all pollutants, except VOC, PM₁₀ and PM_2.5, are equal to the Generic PSEL in accordance with OAR 340-222-0041. Although the Generic PSEL for PM_2.5 is 9.0 tons/year, a Netting Basis of up to 5.0 tons/year may be added to the PM_2.5 Generic PSEL in order to prevent PM_2.5 emissions from initially exceeding SER (OAR 340-200-0020).

b.  The PSEL for VOC is based on the netting basis plus 39 tons requested by the source. The netting basis was established based on the interpretation of the rules in effect during previous permitting action.

c.  During the previous permit term, approximately 98% of the lumber produced was derived from pine species. Therefore, the VOC levels from kiln drying are based exclusively on the pine emission factor.

d.  As the CH₄ and N₂O emissions (Anthropogenic CO₂e short tons) are emitted at diminimis levels (< 2,750 tons/year) for baseline and current emissions, neither a baseline nor a PSEL for GHGs are established in this 2012 permit action. The basis for this may be found in the Emission Detail Sheets provided at the end of this review report.

e.  The basis for the PSELs may be found in the Emission Detail Sheets provided at the end of this review report.

f.  The PSEL is a federally enforceable limit on the potential to emit.

SIGNIFICANT EMISSION RATE ANALYSIS

13.  For each pollutant, the proposed Plant Site Emission Limit is less than the Netting Basis plus the significant emission rate, thus no further air quality analysis is required.

TITLE V MAJOR SOURCE APPLICABILITY

CRITERIA POLLUTANTS

14.  A major source is a facility that has the potential to emit 100 tons/yr or more of any criteria pollutant. For greenhouse gases, the source must also have the potential to emit 100,000 tons/year or more CO₂e to be a major source. This facility is not a major source of criteria pollutant emissions.

15.  The capacity of the facility is based on the following maximum operating rates for each device/activity and 8,424 hours per year, assuming that the plant is shut down for two weeks per year for routine maintenance. It should be noted that the theoretical capacity of the facility is probably much higher than the practical capacity due to production limiting steps in the process, such as the planer, saws, and actual kiln and pellet chip drying times.

HAZARDOUS AIR POLLUTANTS

16.  A major source is a facility that has the potential to emit 10 tons/yr or more of any single HAP or 25 tons/yr or more of combined HAPs. This source is not a major source of hazardous air pollutants. The HAP emissions detail is provided at the end of this report.

ADDITIONAL REQUIREMENTS

NSPS APPLICABILITY

17.  There are no sources at this facility for which NSPS standards have been promulgated. The boilers were installed in 1983, before the applicability date of 40 CFR Part 60, Subpart Dc.

NESHAPS/MACT APPLICABILITY

The NESHAPS/MACT Standard for Industrial, Commercial and Institutional Boilers and - Boiler Area Source MACT (40 CFR Part 63 Subpart JJJJJJ) applies to this source because the boiler combusts biomass. The permittee is required to perform biennial tune-ups beginning in March 2013 and a one-time energy assessment by March 2014.

RACT APPLICABILITY

18.  The RACT rules are not applicable to this source because it is not in the Portland AQMA, Medford AQMA, or Salem SKATS.

SOURCE TESTING

PRIOR TESTING RESULTS

19.  The results of the most recent source tests are listed below:

Grain Loading Measurements:

PROPOSED TESTING

20.  The Wellons hogged fuel boilers will be tested at least once during the permit term for Particulate Matter (PM) emissions. The following production and control device parameters will be recorded during the boiler tests: steam production rate, steam temperature, the pressure drop across the multiclones, NO_x emissions rate, CO emissions rate, and opacity. The pellet chip dryer cyclones (DMM2A & B) will also be tested at least once during this permit term for Particulate Matter Emissions (PM) and Volatile Organic Compounds (VOCs). The following production and control device parameters will be recorded during the pellet dryer tests: The species and amount of wood processed through each dryer cyclone, pressure drop across dryer cyclones, operating and exhaust temperatures (^oF) of each dryer cyclone, and opacity.

PUBLIC NOTICE

21.  Pursuant to OAR 340-216-0066(4)(a)(A), issuance of Standard Air Contaminant Discharge Permits require public notice in accordance with OAR 340-209-0030(3)(b), which requires DEQ to provide notice of the proposed permit action and a minimum of 30 days for interested persons to submit written comments. The public notice was issued on May 31, 2012 and the comment period ended on July 2, 2012. No comments were received in response to the public notice and no changes have been made to the permit.

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EMISSION DETAIL SHEETS

Current Emissions

Note: Total emissions are calculated based on the highest emission rate with either the kiln and cyclones or the pellet chip dryer. The combined boilers have a limited steam capacity to operate the kiln or pellet chip dryer. Simultaneous operation of these processes is not possible.

GHG Emissions

Regulation of biogenic carbon dioxide (CO₂) emissions derived from hogged fuel boilers have been deferred by EPA until the global warming effects of biogenic carbon dioxide can be further evaluated. For the purpose of this permit renewal action only the anthropogenic CO₂ emissions generated from CH₄ and N₂O are to be addressed. The anthropogenic CO₂ emissions are emitted below deminimis levels (< 2,750 short tons/year). Due to the deminimis emissions, a GHG PSEL is not proposed for this permit renewal. If the biogenic CO₂ deferral is removed, the PSEL will be adjusted to include biogas CO₂ emissions and the permit will be revised.

HAPs

Hogged Fuel Boilers:

⁽¹⁾  Assumes 1100 Btu per pound of steam

Drying Kilns: (*White Fir > 200^oF Drying Temp)

*  The permittee processes only fir and pine species. White fir at >200^oF was chosen since the most conservative emission factors were derived from this species and temperature range.

Pellet Chip Drying:

Total HAPs: 8.3 tons/year