STANDARD

AIR CONTAMINANT DISCHARGE PERMIT

 

Department of Environmental Quality

Eastern Region

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:

 

Application No.:  021630

Date Received:  12/09/2005

 

 

PLANT SITE LOCATION:

 

5900 Moffett Road

Tillamook, OR 97141

 

LAND USE COMPATIBILITY FINDING:

 

Approving Authority:  Tillamook County

Approval Date:  6/02/1990

 

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

Part B, #62

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.

1.4.  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.

1.5.  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.

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.

 

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.

 

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

 

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.

 

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)

7.2.  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.

 

 

8.0  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.

 

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

 

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, 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

 

9.1.  Permit Renewal Application

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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