Department of Environmental Quality

Eastern Region

Air Quality Program

STANDARD

AIR CONTAMINANT DISCHARGE PERMIT

REVIEW REPORT

Hampton Lumber Mills, Inc.

Dba Willamina Lumber Company

P.O. Box 8

Willamina, OR 97396

(503) 876-3152

TABLE OF CONTENTS

PERMITTING  2

SOURCE DESCRIPTION  2

COMPLIANCE  4

EMISSIONS  4

MAJOR SOURCE APPLICABILITY  6

ADDITIONAL REQUIREMENTS  6

PUBLIC NOTICE  7

PERMITTING

PERMITTING ACTION

1.  The permit is a for an existing Air Contaminant Discharge Permit (ACDP) which was issued on June 25, 2002, and was originally scheduled to expire on March 1, 2006. The renewal application was submitted in a timely manner and was put on hold pending internal policy decisions related to fugitive dust and emission calculation verifications. No changes have been made to the permit since the last renewal.

OTHER PERMITS

2.  Other permits issued by the Department of Environmental Quality for this source include a 1200Z Storm Water Permit and a 500J Boiler Blow down permit.

ATTAINMENT STATUS

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

4.  The source located within 10 kilometers of the Class I Air Quality Protection Area.

SOURCE DESCRIPTION

OVERVIEW

The permittee operates a sawmill, two planer mills, a finger jointer, as well as four double-track and two single-track lumber kilns. The facility uses a 66.7 MMBtu/hr natural gas-fired boiler with oil backup capability. The date the facility was built is unknown but Department records go back to 1973.

5.  The following changes have been made to the facility since the last permit renewal:

a.  Notice of Intent to Construct (NC# 020502) - Installation of a baghouse at the Twin Mill. The baghouse collects emissions from cyclones FJ and MD1.

b.  Notice of Intent to Construct (NC# 021592) - Installation of a new high speed planer and associated cyclone (NPC-1) and baghouse (BH-2). The facility plans to cease operation of the existing #2 Planer and remove the Moulder operation.

PROCESS AND CONTROL DEVICES

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

a.  BLR1: Cleaver Brooks (Model DL-68), 66.7 MMBtu/hr heat input natural gas-fired boiler with 476 gal/hr distillate fuel oil backup capability; installed in 1996. BLR1 is subject to federal regulation for New Source Performance Standards 40CFR, Part 60, Subpart Dc.

b.  DK1, DK2, DK5, DK6: four double-track dry kilns, 14,840 bf/hr capacity. DK1 and DK2 were installed in 1996. DK5 and DK6 were installed in 2002.

c.  DK3, DK4: two single track dry kilns, 14,840 bf/hr capacity installed in 1998.

d.  QM2 (Quad Mill): medium efficiency cyclone pneumatically moves chips from the re-saw chipper to the drag chain which feeds the surge line.

e.  PM1 (#1 Quad Planer): medium efficiency cyclone pneumatically conveying shavings from the Stetson Ross planer to shavings bunker.

 f.  PM2 (#2 Quad Planer): medium efficiency cyclone pneumatically conveying      shavings from Woods Planer to shaving bunker.

 g.  PM3 (Quad Planer): medium efficiency cyclone pneumatically conveying        materials from chip screen to shavings bin.

 h.  PM5 (Quad Planer): medium efficiency cyclone pneumatically conveying chips      from trim end chipper to planer chip screen.

 i.  PM7 (Quad Mill): medium efficiency cyclone pneumatically conveying chips      from the planer chip screen to quad mill chip bunker.

 j.  PMC (Twin Mill): medium efficiency cyclone pneumatically moving chips from      planer to chip screen.

 k.  FJ1 (Twin Mill): high efficiency cyclone pneumatically conveying shavings from    the Finger Jointer to Twin Mill Bunker #4.

 l.  FJ (Twin Mill): high efficiency cyclone with baghouse control (BH1)        pneumatically conveying shavings from Finger Jointer to Twin Mill Bunker #4 .

 m.  NPC-1 (New Planer): medium efficiency cyclone with baghouse control (BH2)      pneumatically moves chips from new planer to chip screen.

 n.  ASB-1: (Planer #1): Anti Stain Spray booth with mist eliminator.

 o.  ASB-2: (Planer #2): Anti Stain Spray booth with mist eliminator. This was      eliminated when the new high speed planer was in full operation.

 p.  ASB-3: (New Planer): Anti Stain Spray booth with mist eliminator. This        replaces ASB-2.

q.  Finger Joint Glue: resin, hardener, and catalyst used in the finger jointer processes.

 r.  Truck bin unloading - PM and PM₁₀ emissions from material being transferred      from the truck bins to the trucks.

COMPLIANCE

7.  The facility was inspected on August 13, 2001, and June 16, 2004, and found to be in compliance with permit conditions.

8.  During the prior permit period there was one complaint recorded on May 4, 2004, for this facility. The complaint was regarding shavings and sawdust blowing onto homes near the mill. The complaint was resolved by reconfiguring a cyclone that was producing visible emissions.

9.  No enforcement actions have been taken against this source since the last permit renewal.

EMISSIONS

10.  Proposed PSEL information:

a.  The baseline emission rate equals the actual pollutant emissions during the baseline period of 1978 and is now “frozen” in accordance with OAR 340-200-0020(71).

b.  The netting basis is equal to the baseline in accordance with OAR 340-222-0040(2).

c.  The proposed PSELs for SO₂, NOx, and CO are equal to the Generic PSEL in accordance with OAR 340-222-004(1).

d.  The proposed PSEL for PM and PM₁₀ is equal to one ton less than the Generic PSEL above the baseline emission rate in accordance with OAR-340-222-0041(3)(a).

e.  The VOC PSEL is equal to the operation rate and meets the requirements of OAR-340-222-0041(b) which describes the requirements for assigning a source specific PSEL.

f.  The increases to the baseline and PM and PM₁₀ PSEL are due to rounding corrections and including fugitive emissions.

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

SIGNIFICANT EMISSION RATE ANALYSIS

11.  The proposed PSEL increase over the netting baseline is less than the Significant Emission Rate (SER) for all pollutants except VOCs. Therefore, no further air quality analysis is required for those pollutants. For VOCs, the Proposed PSEL is greater than the SER. However, since the PSEL is less than 250 tons/year and the source is not a listed source in OAR 340-200-0020(53), the source is not considered a federal major source, therefore, the PSEL increase must be evaluated under the Department’s PSEL rules in OAR 340-222-0041(3)(b)(C) rather than the New Source Review/Prevention of Significant Deterioration rules in Division 224.

12.  While the VOC PSEL levels above the baseline exceed the SER, there is no ambient standard for VOCs. Although VOCs are a precursor to ozone (for which there is an ambient standard) formation, the formation of ozone typically occurs far downwind from  a source when the precursors (VOC and NOx) react in the presence of sunlight. The formation rates of ozone are strongly influenced by atmospheric conditions as well as the proximity to and magnitude of other sources (industrial, mobile, and area sources) of the precursor pollutants. As such, the reactions are extremely complex and not easily estimated. As a result, the Department is not requiring ozone dispersion modeling for this PSEL increase.

MAJOR SOURCE APPLICABILITY

CRITERIA POLLUTANTS

13.  A major source is a facility that has the potential to emit more than 100 tons per year of any criteria pollutant. This facility a major source of criteria pollutant emissions.

HAZARDOUS AIR POLLUTANTS

14.  A major source is a facility that has the potential to emit more than 10 tons/year of any single HAP or 25 tons/year of combined HAPs. This source a major source of hazardous air pollutants.

ADDITIONAL REQUIREMENTS

NSPS APPLICABILITY

15.  40 CFR Part 60, Subpart Dc applicable to the BLR1 because as it was installed after June 9, 1989, and has a heat input rating of greater than 10 MMBtu/hr.

NESHAPS/MACT APPLICABILITY

16.  40 CFR Part 63, Subpart DDDD does not apply to the dry kilns at this facility because it is not a major HAP source.

RACT APPLICABILITY

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

PUBLIC NOTICE

18.  Pursuant to OAR 340-216-0066(4)(a)(A), issuance of renewed 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 mailed on December 13, 2007, but an error was made in the notice pertaining to the public notice category. Consequently, the notice was re-mailed on December 20, 2007, and the comment due date was extended to January 25, 2008. One comment was received on December 27, 2007, regarding changes to the permitting limits for VOCs. The comment was responded to on January 3, 2007, explaining the changes.

Detail Sheets

Production Parameters

Emissions Summary

Facility

Proposed Baseline Increase

Hazardous Air Pollutants

Emission Factors