ISSUED TO:

Amerities West, LLC

PO Box 1608

The Dalles, OR 97058

INFORMATION RELIED UPON:

Application No.:  22062

Date Received:  12/11/2006

PLANT SITE LOCATION:

100 Tie Plant Road

The Dalles, OR 97058

LAND USE COMPATIBILITY FINDING:

Approving Authority:  The City of The Dalles

Approval Date:  09/20/1989

Table 1 Code

Source Description

SIC

Part B, 73

Wood Preserving

2491

Part B, 12

Boilers and other fuel burning equipment over 10 million Btu/hr heat input

4961

Part B, 74

All Other Sources not listed herein that the Department determines an air quality concern exists or one which would emit significant malodorous emissions.

1.1  Visible Emissions

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

Particulate Matter Emissions

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

a.  Particulate matter emissions from the boilers (Erie City and Cleaver Brooks) must not exceed 0.1 grains per standard cubic foot, corrected to 50% excess air.

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

1.2  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.

1.3  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. The Department will verify that the deposition exists and will notify the permittee that the deposition must be controlled.

1.4  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 Department personnel.

1.5  Fuels and Fuel Sulfur Content

The permittee must not use any fuel other than natural gas, propane, butane, ASTM grade fuel oils, or on-specification used oil.

a.  Fuel oils must not contain more than:

i.  0.3% sulfur by weight for ASTM Grade 1 distillate oil;

ii.  0.5% sulfur by weight for ASTM Grade 2 distillate oil;

iii.  1.75% sulfur by weight for residual oil;

b.  The permittee is allowed to use on-specification used oil as fuel which contains no more than 0.5% sulfur by weight. The permittee must obtain analyses from the marketer or, if generated on site, have the used oil analyzed, so that it can be demonstrated that each shipment of oil does not exceed the used oil specifications contained in 40 CFR Part 279.11, Table 1.

2.1  Cleaver Brooks Boiler

The following New Source Performance Standards (NSPS) apply to the Cleaver Brooks boiler:

Fuels: The permittee may only burn natural gas, propane, butane, or #2 distillate oil.

a.  Sulfur dioxide:

i.  The permittee must not combust fuel oil that contains greater than 0.5 weight percent sulfur.

ii.  Compliance with the fuel oil sulfur limits may be determined based on a certification from the fuel supplier.

iii.  The fuel oil sulfur limits apply at all times, including periods of startup, shutdown, and malfunction.

b.  Particulate matter:

i.  While burning oil, the permittee must not cause to be discharged into the atmosphere from the Cleaver Brooks boiler, any gases that exhibit greater than 20 percent opacity (6-minute average), except one 6-minute period per hour of not more than 27 percent opacity.

ii.  The opacity standard applies at all times, except during periods of startup, shutdown, or malfunction.

3.1  Boiler Maintenance

The permittee must perform a maintenance service on each boiler at least once in every 2-year period. As a minimum, the service must include an inspection of the burners and refractory chamber; cleaning, adjustment, and repair as necessary. For water tube boilers, the service must include flushing the tubes.

Pollution Control Devices

The following pollution control devices must be operated at all times. At least once a month, the permittee must perform an inspection of the pollution control devices and make repairs, if necessary, to ensure good pollution control practices. The permittee must maintain records of the inspections and any necessary repairs.

Process/Activity

Pollution Control Devices

Conditioning (retort vacuum system), Working and Storage Tanks

Ventilation air tank/knock-out

Oil spray

Covers

Vapor balancing line

Wastewater Treatment (WWT)

Water spray

Covers

Vapor balancing line

Sump Tanks

Covers

Retort Doors

Organic vapor mist reduction system

Management practice plan

The permittee must prepare and operate according to a management practice plan to minimize air emissions from the preservative treatment of wood. The management practice plan must include, but is not limited to, the following activities:

3.2  

Minimize preservative usage;

a.  Maintain records on the type of treatment process and types and amounts of wood preservatives used at the facility;

b.  Maintain charge records identifying pressure reading(s) inside the retorts;

c.  Store treated wood product on drip pads or in a primary containment area to convey preservative drippage to a collection system until drippage has ceased;

d.  Fully drain the retort to the extent practicable, prior to opening the retort door;

e.  Promptly collect any spills; and

f.  Perform relevant corrective actions or preventative measures in the event of a malfunction before resuming operations.

4.1  Plant Site Emission Limits (PSEL)

Plant site emissions must not exceed the following:

Pollutant

Limit

Units

PM

24

tons per year

PM₁₀

14

tons per year

SO₂

39

tons per year

NO_X

39

tons per year

CO

99

tons per year

VOC

39

tons per year

Annual Period

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

5.1  Monitoring Requirements

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

All operating and production parameters to be reported to the Department annually as required in Conditions 8.2 and 8.3.

a.  Amounts of each type of fuel combusted in the Cleaver Brooks boiler during each day. [40 CFR 60.48c(g)] If approved by EPA, the amount of natural gas combusted may be recorded monthly instead of daily.

b.  Amounts of each type of fuel combusted in the Erie City boiler during each month.

c.  Fuel supplier certification for the #2 distillate oil shipments. [40 CFR 60.48c(f)((1)]

d.  Plant production of treated wood on a monthly basis (charges/month).

e.  Storage yard inventory of treated wood products on a monthly basis (average units/month).

f.  Excess emissions records as defined in OAR 340-214-0340 (recorded on occurrence). Excess emissions are emissions in excess of the applicable standards identified in Section 1.0, 2.0, and 4.0 of this permit.

g.  An explanation of any permanent changes made in the plant process or production, which would affect air contaminant emissions (indicating when changes were made).

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

5.2  PSEL Compliance Monitoring

Compliance with the PSEL is determined for each 12-consecutive calendar month period summing the results of the following calculations for each pollutant:

a.  Boilers:

E  =  EF x F/2,000 lbs/ton

where,

E  =  Pollutant emissions (ton/yr);

EF  =  Pollutant emission factor (see Condition 12.0);

F  =  Fuel combusted for the 12-month period (million cubic feet of natural gas or 1,000 gallons of oil)

b.  Cyclones:

E  =  EF x P/2,000 lbs/ton

where,

E  =  Pollutant emissions (ton/yr);

EF  =  Pollutant emission factor (0.5 lb/BDT for PM and 0.25 lb/BDT for PM₁₀)

P  =  Process production for the 12-month period (bone dry tons - BDT)

c.  VOC from wood treating:

i.  The number of relief valves x 0.023 lb/hr x 8,760 hours/year x 1 ton/2,000 lbs;

ii.  The number of flanges x 0.00018 lb/hr x 8,760 hour/year x 1 ton/2,000 lbs;

iii.  The number of pump seals x 0.0047 lb/hr x 8,760 hours/year x 1 ton/2,000 lbs;

iv.  Storage yard emissions as determined by the Kerr-McGee Chemical LLC (KMCLLC) spread sheet as a function of inventory and period of time;

v.  The number of charges during the 12-month period x 0.4 lb/charge (retort door emissions)

vi.  The number of charges during the 12-month period x 0.1 lb/charge (vacuum system emissions);

vii.  One ton per year for all insignificant sources and activities, which include valves (other than those identified above), drip pad, tank farm containment, process drains, hot sump, working tanks, storage tanks, and waste water treatment system.

5.3  Emission Factors

The permittee must use the default emission factors provided in Conditions 5.2 and 12.0 for calculating pollutant emissions, unless alternative emission factors are approved by the Department. The permittee may request or the Department 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 the Department.

6.1  Complaints

The permittee must provide written notification within five working days of all nuisance or odor complaints received by the permittee during the operation of the facility. Documentation must include the date of contact, time of claimed nuisance condition, description of claimed nuisance condition, location of receptor, and status of plant operation during the observed period. The notification must be submitted to the DEQ office listed on the first page of the permit.

The permittee may notify the Department immediately of any complaints and, if possible, the Department may perform an investigation of the complaint either independently or in conjunction with the investigation performed by the permittee. If the Department performs an independent investigation, results of the investigation will be provided to the permittee.

6.2  Odor reduction measures

The permittee must evaluate potential sources of odors and take measures to reduce odors as follows:

a.  The pemittee must develop an interim work practices plan (in addition to, but not in place of the management practices plan required by condition 3.3) for minimizing odors. The plan must be submitted by June 30, 2008 to the Department for review and approval. The plan must be implemented immediately upon approval. At a minimum, the following work practices should be evaluated in developing the plan:

i.  If possible, cool charges within the retort without causing adverse consequences;

ii.  To the extent possible, cool charges while stored on the drip pad;

iii.  Evaluate the effectiveness of staggered cylinder load/unload cycles; and

iv.  Evaluate the effectiveness of off-shift load/unload time frames.

b.  The permittee must develop a long term strategy for reducing odors. The permittee must consider at a minimum the following when developing the long term strategy.

i.  Alternative wood treatment materials;

ii.  To the extent feasible, (e.g., cost effective), capture and control of emissions from the retort doors;

iii.  To the extent feasible, (e.g., cost effective), capture and control of emissions from the drip pad;

iv.  Further VOC reduction from leak detection and repair program; and

v.  Prompt shipment of treated product, when possible.

c.  The long term plan for reducing odors must be submitted to the Department by March 31, 2009. The plan must include an implementation schedule not to exceed 3 years from the date of approval by the Department.

6.3  Ambient monitoring

The permittee, in coordination with the Department, must conduct ambient monitoring during a period when odor events are most likely to occur, but not later than March 31, 2009. A sampling protocol must be developed and approved by June 30, 2008. The sampling protocol must include the following provisions:

a.  Two separate sampling periods when odor events are expected to occur;

b.  Each sampling period at least 24-hours;

c.  Three sampling locations (background, downstream near the plant, and downstream up on the bluff) during each sampling period; and

d.  Samples to be analyzed primarily for naphthalene.

7.1  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:

Boiler inspection logs (on occurrence);

a.  Pollution control device inspection logs (on occurrence)

b.  Amount of natural gas, propane, and butane burned in the boilers (monthly);

c.  Amount of #2 distillate oil burned in the boilers (daily and monthly);

d.  Average sulfur content (weight percent) and density (lb/gallon) of the distillate oil combusted (monthly)

e.  Fuel supplier certifications for the #2 distillate oil shipments [40 CFR 60.48c(f)(1)];

f.  If used oil is burned, the permittee must obtain analyses from the marketer or, if generated on site, have the used oil analyzed, so that it can be demonstrated that the used oil does not exceed the used oil specifications contained in 40 CFR Part 279.11, Table 1.

g.  Amount of material throughput for the cyclones (monthly)

h.  The number of relief valves, flanges, and pump seals in the system (recorded initially and then updated if there are any changes);

i.  Storage yard inventory (average units) of treated wood products (monthly);

j.  Number of charges treated (monthly);

k.  Best management plan records; and

l.  Pollutant emissions for the previous 12-month period (calculated monthly)

7.2  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.

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.

7.3  Retention of Records

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

8.1  Excess Emissions

The permittee must notify the Department by telephone or in person of any excess emissions which are 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 9.4.

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

b.  c. The permittee must also submit follow-up reports when required by the Department.c.  

Semi-annual NSPS Report

The permittee must submit semi-annual reports to the Department and EPA. The semi-annual reports must be postmarked by the 30^th day following the end of each semi-annual period (January 1 to June 30 and July 1 to December 31). The semi-annual reports must include the following information:

d.  Calendar dates covered in the reporting period;

e.  Each 30-day average sulfur content (weight percent) of fuel oil calculated during the reporting period, ending with the last 30-day period in the semi-annual period; reasons for any noncompliance with the emission standards; and a description of corrective actions taken;

f.  If fuel supplier certification is used to demonstrate compliance, records of fuel supplier certification as described under 40 CFR 60.48c(f)(1). In addition to records of fuel supplier certifications, the semi-annual report must include a certified statement signed by the permittee that the records of fuel supplier certifications submitted represent all of the fuel combusted during the semi-annual period.

g.  Fuel supplier certifications for distillate oil must include the following information:

i.  The name of the oil supplier; and

ii.  A statement from the oil supplier that the oil complies with the specifications under the definition of distillate oil in 40 CFR 60.41c.

h.  The EPA address is:

Director

Air and Waste Management Division

EPA Region X

1200 Sixth Avenue, Suite 900

Seattle, WA 98101

8.2  Annual Report

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

a.  Operating parameters:

i.  Amount of natural gas, propane, and butane burned in the boilers (cubic feet);

ii.  Amount of distillate oil burned in the boilers (gallons);

iii.  Average sulfur content (weight percent) and density (lb/gallon) of the distillate oil combusted during the year;

iv.  

v.  Amount of material through the cyclones (bone dry tons);

vi.  The average number of relief valves, flanges, and pump seals;

vii.  The number of charges treated;

viii.  The pollutant emissions for each 12-month period during the year (tons).

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.

8.3  Notice of Change of Ownership or Company Name

The permittee must notify the Department in writing using a Departmental “Permit Application Form” 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.

8.4  Construction or Modification Notices

The permittee must notify the Department in writing using a Departmental “Notice of Construction Form,” or “Permit Application Form,” 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.

8.5  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 9.3.

9.1  Permit Renewal Application

The completed application package for renewal of this permit is due on February 1, 2013. Two (2) copies of the application must be submitted to the DEQ Permit Coordinator listed in Condition 9.3

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 Business Office of the Department.

9.2  Permit Coordinator Addresses

All reports, notices, and applications should be directed to the Permit Coordinator at the DEQ address provided on the cover page of this permit.

9.3  Department Contacts

Information about air quality permits and the Department’s regulations may be obtained from the DEQ web page at www.oregon.gov/DEQ. All inquiries about this permit should be directed to the DEQ office identified on the first page of this permit.

10.1  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 Department regulations, will be mailed prior to the above date.

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.

10.2  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.

10.3  Where to Submit Fees

Fees must be submitted to:

Department of Environmental Quality

Business Office

811 SW Sixth Avenue

Portland, OR 97204-1390

11.1  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 the Department with respect to air contaminant discharges.

11.2  Conflicting Conditions

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

11.3  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.

11.4  Department Access

The permittee must allow the Department’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.

11.5  Permit Availability

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

11.6  Open Burning

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

11.7  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 limit to, demolition, renovation, repair, construction, and maintenance.

11.8  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.

11.9  Termination, Revocation, or Modification

The Department 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 – natural gas (propane, butane)

PM/PM₁₀

2.5

lb/10⁶ ft³

DEQ

SO₂

2.6

lb/10⁶ ft³

DEQ

NO_x

100

lb/10⁶ ft³

AP-42

CO

84

lb/10⁶ ft³

AP-42

VOC

5.5

lb/10⁶ ft³

AP-42

Boilers – #2 distillate oil

PM

3.3

lb/10³ gallons

AP-42

PM₁₀

2.3

lb/10³ gallons

AP-42

SO₂

a.

lb/10³ gallons

Calculation

NO_x

20

lb/10³ gallons

AP-42

CO

5

lb/10³ gallons

AP-42

VOC

0.2

lb/10³ gallons

AP-42