Department of Environmental Quality

Eastern Region

Air Quality Program

Standard

AIR CONTAMINANT DISCHARGE PERMIT

REVIEW REPORT

Stimson Lumber Company

5900 Moffett Road

Tillamook, OR 97141

503-842-3164

TABLE OF CONTENTS

PERMITTING  2

SOURCE DESCRIPTION  3

COMPLIANCE  4

SPECIAL CONDITIONS  4

OPERATION & MAINTENANCE REQUIREMENTS  5

EMISSIONS  5

MAJOR SOURCE APPLICABILITY  12

ADDITIONAL REQUIREMENTS  13

SOURCE TESTING  14

PUBLIC NOTICE  14

PERMITTING

PERMITTING ACTION

1.  The proposed modification is for an existing Standard Air Contaminant Discharge Permits (ACDP) that was issued on March 2, 2004, and is originally scheduled to expire on May 1, 2009. The expiration date of the existing permit is being extended to May 1, 2013 with this permit action.

2.  Stimson-Tillamook sawmill is proposing to increase production from their 2 wood fueled boilers. The production increase is necessary to fully utilize new productive capacity of Stimson’s wood drying kilns. In December 2007 Stimson added a 5^th drying kiln bringing the total number of kilns to 5. The proposed change will increase the annual steaming rate (pounds of steam per year) generated by the existing hogged fuel boilers. Modifications to the hogged fueled boilers will not be required. Since the requested NO_x emission increase is over the Significant Emission Rate of 40 tons/year, an ambient air quality analysis was performed as required by OAR 340-222-0041. Stimson-Tillamook sawmill also requested an increase in the allowable VOC emissions from 39 tons per year to 69 tons/yr VOC. Since the netting basis for VOC for this facility is 0, this is a 69 ton/year increase over the Netting basis. This is greater than the Significant Emission Rate for VOC, which is 40 tons/yr. Stimson-Tillamook demonstrated that following the modification would not contribute a significant ozone impact.

3.  The proposed changes represent a “Major Modification” of the existing facility. A major modification is defined as:

 Any physical change or change of operation of a source that results in an increase      in the emissions by an  amount equal to or more than the significant emission rate      over the netting basis  for any regulated pollutant.

4.  The facility is now recognized as a “Major Source” for VOC & NOx. A “Major Source” means a source that emits, any regulated air pollutant at or above a Significant Emission Rate. This includes emissions from insignificant activities.

5.  The facility is located in an area that is in attainment for all pollutants. Since the proposed emission levels were not at “Federal Major Source” thresholds the emission increases did not require a “New Source Review” permitting action.

6.  Air Quality Impact analyses were performed in accordance with 340-222-0041 (3) (b).

OTHER PERMITS

7.  The Department of Environmental Quality has also issued an NPDES General Permit (500-J) for discharge of Boiler Blowdown water for this facility (WQ File # 105191). Stormwater from this facility is covered by an NPDES General Permit (1200-Z) issued to The Port of Tillamook Bay (WQ File # 70615).

ATTAINMENT STATUS

8.  The source is located in an attainment area for all pollutants.

SOURCE DESCRIPTION

OVERVIEW

9.  Stimson Lumber Company processes wood logs to manufacture industrial and dimension grade lumber. Site activities include: debarking, saw cutting, chipping, planing, drying and fuel burning. Drying is accomplished utilizing four (5) kilns, which utilize steam supplied by two (2) hogged fuel boilers.

The two boilers are both dutch-oven type units manufactured by Wellon’s equipped with two independent multiclones. Particulate emissions are controlled by one electrostatic precipitator that serves both combustion units and exhausts through a common stack. Fuel is primarily comprised of Douglas Fir and Hemlock bark, sawdust and planer shavings.

Stimson-Tillamook is proposing to increase dry-lumber production. Stimson recently installed a new 68-foot, single-track lumber kiln and replaced the existing stacker with a more efficient stacker unit. These modifications result in an increase in the hogged fuel boilers annual steaming rate. It is proposed to utilize the current maximum steaming capacity therefore modifications to the hogged fueled boilers will not be required.

The plant is in Tillamook, Oregon; Universal Transverse Mercator (UTM) coordinates 5,029,790 Northing and 436,891 Easting (UTM zone 10, NAD 27).

Raw logs are transported to the site by truck and unloaded into log storage piles until needed. The logs are then loaded onto the in-feed deck of the debarker, the bark is removed, and the logs are cut down to length. The logs proceed to the primary breakdown line, where parallel faces are sawn into the log to produce a cant. The cants then go through a process of trimming, edging, resawing and planing to produce green stud lumber. Wood residuals that are produced from this process are transferred to storage bins by mechanical conveyors. Wood treatment for sap stain is applied to the green stud lumber that is not kiln dried.

Lumber to be dried is processed in the steam heated kilns. Rough sawn lumber is stacked on cribs with stickers between each course and level to promote air circulation. The cribs are placed into the kiln on railed tracks. Steam from the boiler is introduced into the kiln heat exchangers. Kiln vents open and close as required to allow the wood moister to escape the kiln. The recirculation fans also can change direction to improve heat exchanger efficiency. After drying, lumber is removed from the kilns and sent to the sawmill planer. The planing operation dresses the rough lumber using high speed rotating knives. The planing shavings are conveyed pneumatically to the shaving bin cyclone which separates the shavings from the conveying air stream and drops them into the load-out bin. A bag house system installed in 2001 controls emissions from the cyclone. The facility burns bark, shavings, and sawdust in the boilers. Depending upon the time of year, the exact ratio varies. The new boiler may require the purchase of hog fuel from off-site.

PROCESS AND CONTROL DEVICES

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

a.  One Wellon’s hogged fuel boiler manufactured in 1970 and installed in 1995 with a multiclone control. Fuel is primarily Douglas-fir and Hemlock bark, sawdust and planer shavings.

b.  One Wellon’s 29.4 MMBTU/hr wood fired boiler manufactured in 2004 and installed in 2005 with a multiclone. Fuel is primarily Douglas-fir and Hemlock bark, sawdust and planer shavings.

c.  A dry electrostatic precipitator (DESP) to control both the hogged fuel boiler and the wood fired boiler.

d.  Five existing kilns.

e.  An Antisapstain application system.

f.  Baghouse to control emission from the Shavings Cyclone.

g.  Baghouse to control emissions from several saws.

COMPLIANCE

11.  The facility was inspected on September 12, 2007 and found to be in compliance with permit conditions.

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

13.  The permittee source tested the existing Wellons hogged fuel boilers on March 27, 2008, and demonstrated compliance with the PSELs.

14.  The ash waste (generated from hogged fuel boilers) is used offsite as a soil amendment for trace elements and lime equivalent.

SPECIAL CONDITIONS

15.  Small quantities (less than 200 lbs/month) of sawdust used to soak up oil spills may be burned in the hogged fuel boiler. Emission from the estimated 10 gallons of oil burned per year would be less than the emissions from burning wood and therefore are conservatively addressed by treating them as if they were from burning wood.

16.  An action level regulating excess air for the boilers and optimal reduction of CO air emissions has been included in the permit under Condition 5.3.

17.  A production drying temperature for the dry kilns has been included in the permit under Condition 6.2.

OPERATION & MAINTENANCE REQUIREMENTS

18.  The permittee is required to monitor the electrostatic precipitator (ESP) in accordance with the approved operation and maintenance plan submitted by the permittee to the Department.

EMISSIONS

19.  Proposed PSEL information:

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

b.  The Department’s approval is required for any request for increase in the PSEL.

c.  The requested increase for NO_X emissions meets all applicable requirements for acceptable ambient impacts in accordance with 340-222-0041(c).

d.  The requested increase for VOC does not have a significant impact and is outside the Ozone Precursor Distance.

SIGNIFICANT EMISSION RATE ANALYSIS

20.  An analysis of the proposed PSEL increases over the Netting Basis is shown in the following table.

*SER for Medford-Ashland AQMA

21.  A refined steady-state dispersion model (ISCPRIME) was utilized to perform the Class II and Class I air quality analysis. Class II area assessment included a Significant Impact Level analysis, an Ambient Air Quality Standard evaluation, and PSD Increment analysis. The submitted air quality analysis successfully demonstrated that the requested NO_X emission limit would not adversely affect the ambient air quality within the Class II or Class I Scenic areas potentially influenced by the Stimson-Tillamook sawmill. Since this permit action did not completely address all requirements of a “New Source Review” permit action the emission increases permitted through this action will not be included in the permittee’s “Netting Basis” if/when future emission increases are requested.

NO_x Impact Analysis Summary:

OZONE PRECURSOR SIGNIFICANT DEMONSTRATION

The air quality analysis was consistent with the DEQ guidance document titled, “Guidance to DEQ Air Quality Staff for Portland and Medford AQMAs: Evaluating Demonstrations of Ozone Precursor Significant & Offset Amounts.” The guidance outlines steps that DEQ staff take in evaluating the significance of a source as an ozone precursor, and determining the level of offsets, if required.

Initial Screening:

Stimson-Tillamook requested a 48 tons/yr VOC increase over the Netting basis. This is greater than the Significant Emission Rate of 40 tons/yr. The facility is approximately 48.6 km from the nearest boundary of the Portland AQMA, which is less than the screening threshold distance of 100 km. Therefore, the initial screening approach failed to prove that this was a non-significant source.

A NAAQs and PSD Increment standard has not been defined for VOC’s and the use of controversial models that account for the complicated atmospheric chemistry involved in forming Secondary VOC pollutants are beyond the scope of this project. Therefore, VOC modeling was not performed during this ambient air quality analysis.

 Demonstration Stage (Significance Area Maps)

The most recent Significance Area Maps available were used to demonstrate the Stimson-Tillamook facility is not considered a potentially significant source of ozone.

22.  Production and Process Rates:

*MBF is thousand Board feet.

NOTES:

(a)  Estimated PTE annual boiler steam production (Mlb-steam/yr) = (hourly maximum boiler steam rating {Mlbs-steam/hr}) x (PTE hours of operation hrs/yr)

Existing boiler hourly maximum steam rating (Mlbs-steam) = 17.0 (5)

Installed 2004 boiler hourly maximum steam rating (Mlbs-steam) = 22.4 (8)

REFERENCES:

(1)  Maximum projected production estimated by Stimson. This is unchanged

(2)  Maximum throughput allowed, limited by HAP PSEL. This is a reduction.

(3)  Maximum throughput allowed, limited by CO PSEL. This is a reduction.

(4)  Production for the proposed kiln was estimated by Stimson Lumber Company. .

(5)  Boiler steam capacity from manufacturer’s estimate.

(6)  Assumes operation 24 hours a day, 365 days a year.

(7)  Species dried 80% Hemlock and 20% Douglas fir/Spruce estimated by Stimson Lumber Company.

(8)  Boiler Steam rating from Horizon Environmental Engineering source test report dated March 27, 2008.

23.  The Boiler Emissions from Wood Combustion:

NOTES:

 Annual emissions (tons/yr) = (emission factor {lbs/Mlbs-steam}) x (annual steam production {Mlbs-steam/yr}) / (2000 lbs/ton) x (1-ESP control efficiency {%})

Project annual steam production (Mlbs-steam/yr) = 300,000 (2)

Estimated PTE annual steam production (Mlbs-steam/yr) = 330,252 (2)

Control efficiency = 75% (3)

REFERENCES:

(1)  Boiler emission factors – see Condition 12.0 of the Standard ACDP dated 7/18/02. As previously agreed with the Department, the facility has assumed that PM₁₀ emissions from the boiler will constitute 50% of the PM.

(2)  See item # 22 Production and Process Rates of this review report.

(3)  The ESP is assumed to provide 75% control of particulate emissions from the boilers. This is a 75% reduction of the emission factor from the Pre ESP Source test. The 75% control efficiency was provided by Wellons.

24.  KILN DRYING EMISSIONS:

NOTES:

a.  Annual emissions (tons/yr) = (annual kiln production {MBF/yr}) x (emission factor {lbs/MBF}) / (2000 lbs/ton).

b.  Emission Factors from DEQ.

REFERENCES:

(1)  According to the existing Standard ACDP dated 7/18/02, the facility is permitted to dry Douglas fir and Hemlock in the kilns. Small amounts of other coastal species are also dried. The facility mostly dries hemlock. Douglas fir emissions are used for the PTE scenario for criteria pollutants, but only Hemlock is considered in the projected normal operations scenario. When the facility does dry Douglas fir in the future, they would control operations to maintain emissions below the applicable PSELs.

(2)  PM₁₀ conservatively assumed to be 100% of PM.

(3)  HAP emission factor for White Fir and Spruce is assumed to be the same as that for Hemlock.

(4)  Particulate and VOC kiln emission factors for Hemlock and Douglas fir are taken from DEQ Emission Factors. Inorganic condensable PM (0.049 lb/MBF) obtained from draft AP-42 Table 10-1-2, 11/93, for Ponderosa Pine. Organic condensable PM was assumed to be proportionate to total VOC based on Ponderosa Pine VOC emission factor (1.86 lb/MBF) obtained from NCASI July 1996 technical bulletin (No. 7180 and the Ponderosa Pine organic condensable PM emission (0.11 lb/MBF) from the draft AP-42 table. NCASI July 1996 Technical Bulletin, No. 7180.

(5)  HAP Emission Factors from the General ACDP for sawmill, planing mills or millworks, per condition 12.0, Emission Factors for steam and electric heated kilns (lbs/1000 board feet). This is based on limited information and is a rough estimate of the HAP emissions.

(6)  The HAP total projected for normal operation scenario is equal to the sum of all Hemlock methanol, formaldehyde and acetaldehyde emissions.

(7)  The HAP total PTE is equal to the sum of all Hemlock methanol, formaldehyde and acetaldehyde emissions.

(8)  Using the Kiln HAP emission factor listed above up to 158,000 MBF of Hemlock can be dried without exceeding the single and combined HAPs PSEL.

 (10)Compliance with the PSEL will be based on actual production by wood species,   actual boiler steam production and miscellaneous coatings based on material balance.

25.  Maximum annual and uncontrolled PTE emissions estimate for Facility-Wide Use of VOC/HAP – Containing Material:

NOTES:  

(a) Projected annual material usage (gals/yr)

Anti Sapstain = 6000 gallons (estimate of maximum use by Stimson)

End Seal = 3000 gallons (estimate of maximum use by Stimson)

Solvent = 650 gallons (estimate of maximum use by Stimson)

(b) VOC content of typical Antisapstain, End Seal, and Solvent products. VOC content, usage and application rates may vary with different products used.

(c) Based on the information provided by Stimson, none of the process VOC products currently used have HAPs in them. However, future products may contain HAPs.

26.  Bag house Particulate Emissions:

NOTES:

 (a) Annual emissions (tons/yr) = (bag house airflow {dscf/min}) x (50 mins/hr) x

(emission factor {gr/dscf}) / (7000 gr/lb) x (annual hours of operation {Hrs/yr}) /

(2000lbs/ton).

  Annual hours of operation (hrs/yr) = 8760 (5)

REFERENCES:

(1)  The Shavings bag house controls emissions from the shaving cyclone and the shavings bin vent. The Sawdust baghouse controls emissions from several saws.

(2)  The bag house emission factor and airflow were taken from ACDP dated 7/18/02, for the shavings baghouse, and engineering estimates for the Sawdust baghouse.

(3)  PM10 conservatively assumed to be 100% of PM.

(4)  Assumes the projected annual emissions are equal to the estimated (unregulated) PTE emissions for the bag house.

(5)  Assumes operation 24 hours a day 365 days a year.

27.  PROJECTED ANNUAL EMISSIONS SUMMARY:

NOTES:

 (1) The kiln drying emissions include all existing kilns.

(2) Drying Hemlock at a production rate of 158,000 MBF.

 (3) Drying Douglas fir at a production rate of 200,000 MBF.

MAJOR SOURCE APPLICABILITY

TITLE V CRITERIA POLLUTANTS

28.  A major source for Title V applicability is a facility that has the potential to emit 100 tons or more per year of any criteria pollutant. This facility is not a major source of criteria pollutant emissions. The PSEL is a federally enforceable limit on the potential to emit. If the permit limits were not in place, the facility Potential To Emit would be:

NOTE: The kiln drying emissions include the existing kilns and the kiln emissions installed     in 2005.

 (a) Only Acetaldehyde is presented as it is the highest plantwide.

 (b) These materials are not expected to contain the HAP Acetaldehyde.

HAZARDOUS AIR POLLUTANTS

29.  A major source is a facility that has the potential to emit 10 tons or more a year of any single HAP or 25 tons or more a year of combined HAPs. This source has chosen to accept enforceable HAP emission limitations in the permit that prohibit it from operating at or above Major Source thresholds. It is therefore a minor source of HAPs.

30.  The source’s unregulated PTE for an individual HAP (acetaldehyde) is greater than 80% of the threshold values for Title V applicability therefore; full compliance evaluation (FCE) is required.

ADDITIONAL REQUIREMENTS

NSPS APPLICABILITY

31.  40 CFR Part 60, Subpart Dc is applicable to the source because of the facility’s 29.4 million BTU/hr Wellons hogged fuel boiler.

NESHAPS/MACT APPLICABILITY

32.  At the time of permitting there was no source at this facility for which NESHAP/MACT standards were promulgated.

RACT APPLICABILITY

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

TACT APPLICABILITY

34.  The source is meeting the State’s TACT/Highest and Best Rules by conducting the following activities:

 a. Multiclones and an electrostatic precipitator (ESP) control the boiler’s particulate     emissions.

c. A bag house system is used to control particulate emissions from the planer shavings

cyclone.

SOURCE TESTING

PRIOR TESTING RESULTS

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

PUBLIC NOTICE

36.  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)(c), which requires that the Department provide notice of the proposed permit action and a minimum of 35 days for interested persons to submit written comments. In addition, a hearing will be scheduled to allow interested persons to submit oral or written comments if the Department receives written request for a hearing from ten persons, or from an organization representing at least ten persons, within 35 days of the mailing of the public notice. If a hearing is scheduled, the Department will provide a minimum of 30 days notice for the hearing. The public notice was made available for public comment from September 5, 2008 and will end October 14, 2008, 5pm. No comments were received, no requests for a public hearing were received.

tll:ggg

Document2

10/05/25