STANDARD
AIR CONTAMINANT DISCHARGE PERMIT
Department of Environmental Quality
1550 NW Eastman Parkway, Suite 290
Gresham, Oregon 97030
(503) 667-8414
This permit is being issued in accordance with the provisions of ORS 468A.040 and
based on the land use compatibility findings included in the permit record.
ISSUED TO:
Stimson Lumber Company 5900 Moffett Road Tillamook, OR 97141 | INFORMATION RELIED UPON:
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PLANT SITE LOCATION:
5900 Moffett Road Tillamook, OR 97141 |
LAND USE COMPATIBILITY FINDING:
Approving Authority: Tillamook County |
ISSUED BY THE DEPARTMENT OF ENVIRONMENTAL QUALITY
____________________________________________ _______________________
Ed Druback, Northwest Region Air Quality Manager Dated
Source(s) Permitted to Discharge Air Contaminants (OAR 340-216-0020):
Table 1 Code | Source Description | SIC/ NAICS |
Sawmills and/or Planing Mills, 25,000 or more Bd. Ft./ Maximum 8 hr. finished product | 2421/ 321113 |
Modification and Re-issuance
In accordance with OAR 340-216-0084, the permit has been re-issued in it’s entirety to reflect the addition to increase dry-lumber production by installing a new 68-foot, single-track lumber kiln and by replacing the existing stacker with a more efficient stacker unit. The modification will result in an increase in the hogged fuel boilers annual steaming rate.
TABLE OF CONTENTS
1.0 GENERAL EMISSION STANDARDS AND LIMITS 3
2.0 NEW SOURCE PERFORMANCE STANDARDS 4
3.0 OPERATION AND MAINTENANCE REQUIREMENTS 5
4.0 PLANT SITE EMISSION LIMITS 5
5.0 COMPLIANCE DEMONSTRATION 6
6.0 SPECIAL CONDITIONS 10
7.0 RECORDKEEPING REQUIREMENTS 10
8.0 REPORTING REQUIREMENTS 11
9.0 ADMINISTRATIVE REQUIREMENTS 12
10.0 DEQ CONTACTS / ADDRESSES 13
11.0 FEES 13
12.0 GENERAL CONDITIONS AND DISCLAIMERS 14
13.0 EMISSION FACTORS 15
14.0 PROCESS/PRODUCTION RECORDS 16
15.0 ABBREVIATIONS, ACRONYMS, AND DEFINITIONS 17
1.0 GENERAL EMISSION STANDARDS AND LIMITS
1.1. Visible Emissions
1.2. Particulate Matter Emissions | The permittee must comply with the following visible emission limits, as applicable: |
a. 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. | |
1.3. | The permittee must comply with the following particulate matter emission limits, as applicable: |
a. Particulate matter emissions from any fuel burning equipment 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 fuel burning equipment and fugitive emission sources must not exceed 0.1 grains per standard cubic foot. | |
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. | |
1.5. 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. |
1.6. 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. |
2.0 NEW SOURCE PERFORMANCE STANDARDS
2.1. Compliance Requirements | At all times, including periods of startup, shutdown, and malfunctions, owners and operators shall, to the extent practicable, maintain and operate any affected facility ( the new boiler) including associated air pollution control equipment in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Administrator which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection of the source.
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2.2 Record Keeping | The permittee must maintain on-site, records of the amount and type of fuels burned each day for a period of at least (3) years.
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2.3 Construction or Modification | In addition to the Notice of Construction (NC) requirement in Condition 8.4, the permittee must notify the Department and the EPA when equipment becomes subject to NSPS as summarized below: a. The date construction commences on the subject facility, postmarked no later than 30 days after such date; b. The anticipated date of initial startup, postmarked not more than 60 days nor less than 30 days prior to such date; c. The actual date of initial startup, postmarked within 15 days after such date; d. The date of completion of the construction or installation of the boilers, postmarked not more than 60 days prior to expected completion date.
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2.4 EPA Submittal Address | All submittals to the EPA must be sent to the following address: Director Air and Waste Management Division EPA Region X Mail Stop ATW-107 1200 Sixth Avenue, Ste 900 Seattle, WA 98101-3132 |
3.0 OPERATION AND MAINTENANCE REQUIREMENTS
3.1. ESP Monitoring Plan | The permittee must monitor the ESP in accordance with the approved operation and maintenance plan required by Condition 5.2. |
Control System | The permittee must prepare, implement, and maintain a routine plan to check on the ESP and the baghouse systems, and repair any control system within 24 hours after notice of malfunction or damage. |
3.2. Oxygen Monitoring Plan | The permittee must monitor the Boiler Excess Oxygen for the wood fired hogged fuel boilers in accordance with the approved operation and maintenance plan submitted by the permittee to the Department. |
4.0 PLANT SITE EMISSION LIMITS
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 | |
NOX | 45 | tons per year | |
CO | 99 | tons per year | |
VOC | 69 | tons per year | |
Single HAP | 9 | tons per year | |
Combined HAPs | 24 | tons per year |
Annual Period | The annual plant site emissions limits apply to any 12-consecutive calendar month period. |
5.0 COMPLIANCE DEMONSTRATION
5.1. Testing Requirements
| Source tests are not a requirement of this permit. However, if the permittee chooses to conduct source testing for validation of emission factors or for compliance demonstration, or if testing should become otherwise necessary during the permit period, the following source test conditions must be observed: |
a. During the source test, stack exhaust gas must be sampled while the facility is operating at approximately its maximum normal operating capacity. | |
b. During the source test the following parameters should be monitored and recorded: | |
i. Opacity reading on the exhaust stack following the procedures of EPA Method 9; | |
Steam flow rate; | |
ii. Type of fuel or physical characteristics of the fuel, including species of wood/bark, size distribution, and moisture content (wet basis) | |
iii. Process operating parameters during the emissions source test. | |
c. A pretest plan for the source test must be submitted to the Department for approval, at least 15 days prior to testing. Testing must be preformed using the reference test methods identified in the table below (as applicable) with no deviations unless test method modification/variance or substitution of an alternative test method has been pre-approved by the Department in its pretest plan review. All tests must be conducted in accordance with the Department’s Source Sample Manual and with pretest plan. A report of test data and results must be submitted to the Department for review within 45 days after testing unless an alternate submission date or extension is approved by the Department. The pretest plan and test report are to be submitted to the Department’s regional office identified in Condition 10.3. | |
d. Only regular operating staff may adjust the abatement device, production processes, and/or 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 result of the consultation with source test personnel, equipment vendors or consultants may render the source test invalid. |
Tested Pollutant | Reference Test Method(1) |
NOX | EPA Method 7E |
CO | EPA Method 10 Note: Method 10 must be modified to include improved quality assurance procedures of Method 6C – Contact the Departments Regional Field office for details. |
PM/PM10 | Oregon Method 5 or 8 as applicable |
VOC | EPA Method 18, 25 or 25A |
Opacity | EPA Method 9 |
5.2. ESP Monitoring Plan
| The permitte must maintain a monitoring plan for the ESP and must monitor the operation of the ESP in accordance with the plan. |
5.3. Boilers Oxygen Monitoring
| The permittee must monitor the performance of Boilers 1 and 2 and associated pollution control devices in accordance with the following conditions: i. For each boiler, the permittee must calibrate, operate, maintain, and record the output of a continuous excess oxygen monitor in accordance with the manufacturer’s written instructions. Real time data must be displayed/recorded at least once every minute that the boiler is in operation. Hourly averages of the data must be recorded once each clock hour that the boiler is in operation. The minimum data availability shall be 75% of the operating hours per day for 90% of the operating days per calendar quarter. . Monitor availability must be determined excluding periods of calibrations and routine maintenance. ii. The permittee must maintain excess oxygen levels within the range of 4% to 14% except during periods of boiler startup and shut down. The permittee must record any instance in which the excess oxygen level is found outside this range and take immediate corrective action to return the boiler(s) to efficient operation. Operation outside the identified range is not considered a violation in itself if corrective action is immediately taken to restore the boiler(s) to efficient operation. The corrective action taken must be identified and recorded in a boiler operating log. iii. The permittee may establish a revised excess oxygen action level with written approval by the Department. iv. The permittee must maintain a log of the types and amounts of wood based fuel burned. |
Monitoring Requirements | The permittee must inspect, monitor, and maintain records of the operation and maintenance of the plant and associated air contaminant control devices to report to the Department for the following parameters and information: |
b. All operating and production parameters used to calculate the plant site emissions as required by Condition 0 and 5.6 to determine compliance with Condition 4.1. Operating Parameters:
i. MBF/month of Douglas fir processed through the dry kilns. ii. MBF/month of Hemlock and Spruce processed through the dry kilns. iii. Steam production of the boilers (lbs/month) iv. VOC content of antisapstain applied (lbs/gal) v. Parameters identified for the ESP monitoring in Condition 5.2. c. Excess emission records as defined in OAR 340-214-0300 through 340-214-0340 (recorded on occurrence) d. Records of major maintenance to the air contaminant control systems or any changes to the process that took place (record on occurrence). |
5.4. PSEL Compliance Monitoring | Compliance with the PSEL must be calculated monthly and 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 13.0); P = process production (see Condition 14.0) |
5.5. VOC PSEL Compliance Monitoring | Annual VOC emissions for each 12 consecutive calendar month period must be calculated monthly by the following formula:
EVOC-A = å[EVOC-MB + EVOC-B/K] x 1 ton/2000 lb EVOC-MB = [å(CX * DX * KX) – W] EVOC-B/K = Boiler/Kiln VOC emissions determined in Condition 5.5. Where,
EVOC-A = Annual VOC emissions in tons EVOC-MB = Mass balance EVOC-B/K = Boiler/kiln C = Material usage for the period in gallons D = Material density in pounds per gallon K = VOC concentration expressed as a decimal X = Subscript x represents a specific material W = Weight of VOC shipped offsite
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5.6. Emission Factors | The permittee must use the emission factors provided in Condition 13.0 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. |
6.0 SPECIAL CONDITIONS
6.1. Small Quantities Sawdust | Small quantities (less than 200lbs/month) of sawdust used to soak up oil spills may be burned in the fuel boiler. Emissions from the estimated 10 gallons of oil burned per year would be less than emissions from burning wood and therefore are conservatively addressed by treating them as if they were from burning wood.
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6.2. Dry Kilns | The Permittee is prohibited from operating the dry kilns for production drying at a temperature > 200º Fahrenheit unless a higher temperature is approved by the Department. |
7.0 RECORDKEEPING REQUIREMENTS
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: |
a. All parameters required to be monitored in Condition 5.2 and those parameters to be reported in Condition 8.0 must be recorded. | |
i. MBF/month of Douglas fir processed through the dry kiln | |
ii. MBF/month of Hemlock and Spruce processed through the dry kiln | |
iii. Steam production of the boilers (lbs/month) | |
iv. VOC content of sapstain applied (lbs/gal) | |
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. |
8.0 REPORTING REQUIREMENTS
8.1. Excess Emissions | The permittee must notify the Department 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 10.3 by e-mail, telephone, facsimile, or in person. | |
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. The permittee must also submit follow-up reports when required by the Department. | |
8.2. Annual Report | For each year this permit is in effect, the permittee must submit to the Department by February 15 two (2) copies of the following information for the previous calendar year: |
a. Operating parameters required by Condition 5.2. | |
b. All PSEL calculations required in Condition 5.4 and 5.5. | |
MBF/month of Douglas fir processed through the dry kilns.
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d. MBF/month of Hemlock and Spruce processed through the dry kilns. | |
e. Monthly and annual steam production of theWellon Boilers (lbs/month). | |
f. VOC content of antisapstain applied (lbs/gal). | |
g. Records of all planned and unplanned excess emissions events. | |
h. Summary of complaints relating to air quality received by permittee during the year. | |
i. List permanent changes made in plant process, production levels, and pollution control equipment which affected air contaminant emissions. | |
j. 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 | |
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, of 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 field office for the region where the source is located as identified in Condition 10.3. |
9.0 ADMINISTRATIVE REQUIREMENTS
The completed application package for renewal of this permit is due on 3/01/2013. Two (2) copies of the application must be submitted to the DEQ Permit Coordinator listed in Condition 10.2. | |
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 listed in Condition 10.1. |
10.0 DEQ CONTACTS / ADDRESSES
10.1. Business Office | The permittee must submit payments for invoices, applications to modify the permit, and any other payments to DEQ’s Business Office: |
Department of Environmental Quality
Business Office
811 SW Sixth Avenue
Portland, Oregon 97204-1390
10.2. Permit Coordinator | The permittee must submit all Notices and applications that do not include payment to the Northwest Region’s Permit Coordinator: |
Department of Environmental Quality
Northwest Region
2020 SW 4th Avenue, Suite 400
Portland, OR 97201-4987
Telephone: (503) 229-5582
10.3. Field Office | Unless otherwise notified, the permittee must submit all reports (annual reports, source test plans and reports, etc.) to field office noted below. |
Department of Environmental Quality
NWR-ESO/AQ
1550 NW Eastman Pkwy, Suite 290
Gresham, OR 97030
Telephone: (503) 667-8414
10.4. Web Site | Information about air quality permits and the Department’s regulations may be obtained from the DEQ web page at www.deq.state.or.us |
11.0 FEES
11.1. 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. |
11.2. 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. |
11.3. Where to Submit Fees | Fees must be submitted to: Department of Environmental Quality Business Office 811 SW Sixth Avenue Portland, Oregon 97204-1390 |
12.0 GENERAL CONDITIONS AND DISCLAIMERS
12.1. 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. |
12.2. Conflicting Conditions | In any instance in which there is an apparent conflict relative to conditions in this permit, the most stringent conditions apply. |
12.3. 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. |
12.4. 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. |
12.5. Permit Availability | The permittee must have a copy of the permit available at the facility at all times. |
12.6. Open Burning | The permittee may not conduct any open burning except as allowed by OAR 340 Division 264. |
12.7. 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. |
12.8. 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. |
Termination, Revocation, or Modification | The Department may modify or revoke this permit pursuant to OAR 340-216-0082 and 340-216-0084. |
13.0 EMISSION FACTORS
Criteria Pollutant | Source | Emission Factor (EF) | EF Reference |
VOC | Sapstain application | VOC content of sapstain applied (lbs/gal) | Manufacturer’s data |
PM/PM10 | Boilers 1&2 | 0.04 lb/Mlb-steam | 3/1/2000 source test** see note. DEQ approved factor PM10 *** see note |
SO2 | Boilers 1&2 | 0.008 lb/Mlb-steam | AP-42 Table 1.6-2 |
CO | Boilers 1&2 | 0.66 lb/Mlb-steam | 3/27/2008 source test |
NOx | Boilers 1&2 | 0.30 lb/Mlb-steam | 3/27/2008 source tests |
VOC | Boilers 1&2 | 0.049 lb/Mlb-steam | AP-42 Table 1.6-2 |
Total HAPs | Boilers 1&2 | 0.029 lb/Mlb-steam | DEQ Emission Factor |
PM/PM10 | Shavings Bag house | 0.001 gr/SCF at 10,000 SCFM | Manufacturer’s specification |
PM/PM10 | Sawdust Baghouse | 0.01 gr/SCF at 3,600 SCFM | Engineering estimate |
PM/PM10 | Dry Kiln | Douglas fir 0.02/MBF | DEQ Emission Factor |
Hemlock 0.05/MBF | |||
VOC * see note | Dry Kiln | Douglas fir 0.5/MBF | DEQ Emission Factor |
Hemlock 0..25/MBF | |||
Total HAPs | Dry Kiln | Douglas fir 0.13/MBF | DEQ Emission Factor |
Hemlock 0.19/MBF | |||
Acetaldehyde | Dry Kiln | Douglas fir 0.06/MBF Hemlock 0.113/MBF | DEQ Emission Factor |
Methanol | Dry Kiln | Douglas fir 0.04/MBF | DEQ Emission Factor |
Hemlock 0.07/MBF |
Notes:
*VOC reported as propane, lb propane/MBF
**PM/PM10 ESP control efficiency 75% provided by Wellons.
***PM equals 100% of PM10
14.0 PROCESS/PRODUCTION RECORDS
Emissions device or activity | Process or production parameter | Frequency |
Antisapstain Application | Gallons of concentrate used | Monthly/Annually |
End Seal Application | Gallons used | Monthly/Annually |
Solvent Use | Gallons used | Monthly/Annually |
Steam Production | Mlb-steam | Monthly |
Kiln Production | lb/MBF | Monthly |
Bag house | Hours of operation | Monthly |
15.0 ABBREVIATIONS, ACRONYMS, AND DEFINITIONS
ACDP | Air Contaminant Discharge Permit |
ASTM | American Society for Testing and Materials |
AQMA | Air Quality Maintenance Area |
calendar year | The 12-month period beginning January 1st and ending December 31st |
CFR | Code of Federal Regulations |
CO | carbon monoxide |
DEQ | Oregon Department of Environmental Quality |
dscf | dry standard cubic foot |
EPA | US Environmental Protection Agency |
FCAA | Federal Clean Air Act |
gal | gallon(s) |
gr/dscf | grains per dry standard cubic foot |
HAP | Hazardous Air Pollutant as defined by OAR 340-244-0040 |
I&M | inspection and maintenance |
lb | pound(s) |
MMBtu | million British thermal units |
NA | not applicable |
NESHAP | National Emissions Standards for Hazardous Air Pollutants |
NOX | nitrogen oxides |
NSPS | New Source Performance Standard |
NSR | New Source Review |
O2 | oxygen |
OAR | Oregon Administrative Rules |
ORS | Oregon Revised Statutes |
O&M | operation and maintenance |
Pb | lead |
PCD | pollution control device |
PM | particulate matter |
PM10 | particulate matter less than 10 microns in size |
ppm | part per million |
PSD | Prevention of Significant Deterioration |
PSEL | Plant Site Emission Limit |
PTE | Potential to Emit |
RACT | Reasonably Available Control Technology |
scf | standard cubic foot |
SER | Significant Emission Rate |
SIC | Standard Industrial Code |
SIP | State Implementation Plan |
SO2 | sulfur dioxide |
Special Control Area | as defined in OAR 340-204-0070 |
VE | visible emissions |
VOC | volatile organic compound |
year | A period consisting of any 12- consecutive calendar months |
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