ADEQ OPERATING AIR PERMIT

Transcription

1 ADEQ OPERATING AIR PERMIT Pursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation 26: Permit No. : 1533-AOP-R6 Renewal #1 IS ISSUED TO: TIN Inc., dba Temple-Inland Route 4, 100 Temple Drive Hope, AR Hempstead County AFIN: THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITTEE TO INSTALL, OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION UNITS DESCRIBED IN THE PERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT IS VALID BETWEEN: July 11, 2003 AND July 10, 2008 THE PERMITTEE IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Mike Bates Chief, Air Division Date Modified

2 Table of Contents SECTION I: FACILITY INFORMATION... 4 SECTION II: INTRODUCTION... 5 Summary of Permit Activity... 5 Process Description... 5 Regulations... 9 Emission Summary... 9 SECTION III: PERMIT HISTORY SECTION IV: SPECIFIC CONDITIONS SN-03 and SN-05, 06 and SN-07 & SN-08A and SN-08B SN-10 and SN SN SN SN-17A SN-20, 21, and SN-09, SN-27 through SN SECTION V: COMPLIANCE PLAN AND SCHEDULE SECTION VI: PLANTWIDE CONDITIONS Acid Rain (Title IV) Title VI Provisions SECTION VII: INSIGNIFICANT ACTIVITIES SECTION VIII: GENERAL PROVISIONS Appendix A 40 CFR 63, Subpart DDDD Appendix B PSD permit history 2

3 List of Acronyms and Abbreviations A.C.A. AFIN CFR CO HAP lb/hr MVAC No. NO x PM PM 10 SNAP SO 2 SSM Tpy UTM VOC Arkansas Code Annotated ADEQ Facility Identification Number Code of Federal Regulations Carbon Monoxide Hazardous Air Pollutant Pound Per Hour Motor Vehicle Air Conditioner Number Nitrogen Oxide Particulate Matter Particulate Matter Smaller Than Ten Microns Significant New Alternatives Program (SNAP) Sulfur Dioxide Startup, Shutdown, and Malfunction Plan Tons Per Year Universal Transverse Mercator Volatile Organic Compound 3

4 SECTION I: FACILITY INFORMATION PERMITTEE: TIN Inc., dba Temple-Inland AFIN: PERMIT NUMBER: 1533-AOP-R6 FACILITY ADDRESS: MAILING ADDRESS: Route 4, 100 Temple Drive Hope, AR Temple Drive Hope, Arkansas COUNTY: CONTACT POSITION: Hempstead Wayne Hargraves, Plant Manager TELEPHONE NUMBER: (870) REVIEWING ENGINEER: Wesley Crouch UTM North South (Y): Zone 15: UTM East West (X): Zone 15:

5 SECTION II: INTRODUCTION Summary of Permit Activity TIN Inc., dba Temple-Inland (AFIN: ) located at Route 4, 100 Temple Drive, Hope, AR 71801, has proposed to add two platens to the press (SN-17), replace ten hot plates, add a new crown and cooling plate, replace the simultaneous arms on the press, replace the loader cage and add two openings to the unloader cage. This modification also includes an annual production increase from 220 MMSF/yr (3/4 basis) to 240 MMSF/yr (3/4 basis). Hourly production throughput will remain unchanged. Permitted emissions increases will be 1.0 tpy PM, 1.0 tpy PM 10, 4.7 tpy VOC, 1.6 tpy methanol and 0.43 tpy formaldehyde. Process Description Temple Inland Forest Products Company=s (TIFPC's) particleboard plant in Hope, Arkansas, was designed to utilize wood residue from other wood processing plants in the southwest Arkansas area. The plant will utilize a maximum 347,600 oven-dried tons (ODT, 0% moisture content) of wood residue annually for a 7 days/week operation with a maximum annual production rate of 240,000 thousand square feet (MSF) of board per year on a 3/4 inch basis. The maximum hourly short term level of production for the press is 32,000 square feet (SF) of board on a 3/4 inch basis and 51.3 ODT for the primary dryers. Raw Material Processing All raw materials are delivered to the plant by truck then off-loaded and stored in an enclosed storage building. TIFPC utilizes a hydraulic truck dumper with a receiving screw conveyor discharge hopper for the unloading process. All mechanical conveying is performed in an enclosed system which minimizes fugitive emissions. The truck is backed into the unloader facility where it is lifted and tilted backward. The raw material falls into an unloading bin that is hooded and enclosed as much as possible. This style of truck dumper reduces these fugitive emissions. The raw materials are metered directly to the Raw Material Storage (RMS) building utilizing a totally enclosed conveyor. The wood residuals are stored in piles in the enclosed raw material storage building. This stored material is reclaimed as needed, then conveyed to the process storage metering bins. Two types of residue are used as raw material, Agreen@ ($18% Oven Dried (OD) moisture content) material and Adry@ (<18% moisture content OD) material. The "green@ material is primarily sawdust generated from sawmills cutting untreated lumber, whereas the "dry" material is primarily shavings and sawdust produced when planing or cutting kiln dried lumber. Acceptable material from the RMS building is fed to one of three storage silos; dried material, green material and dried green material which are equipped with bin vent filters (SN-27, 28 & 29 5

6 respectively). Once the material is in the silos, it is conveyed to the reciprocating shaker screens, which classifies the material. Overs from the screens are conveyed to a hammermill which recycles material back to the screens. Dust generated at the hammermill is controlled by a small baghouse (SN-35). Reject material from the forming line and hogged trim material from the finished boards are collected in a separate silo and re-enters the system to optimize material usage. Milling and Drying The two screen systems produce two separate process stream flows; both core and face. Both screen systems deliver material via a covered conveying system to the Milling and Drying (M&D) area. The finer portion of the wood fiber is used in the surface layers of the board ("face"), while the coarser material is used in the middle board layers ("core"). Face and core materials are processed through hammermills and refiners, respectively. Refining is accomplished as the material is plug-fed by screw conveyors into the center of each of the four refiners and is sheared by the attrition plates. The gap spacing is determined by the type of furnish being produced. The face material leaves the screens and is sent to one of six hammermills. The hammermills pulverize the material into smaller particle sizes which can then be accepted by the process. The refining process controls the geometry of the finished particle and influences both the density and weight of the board. Centrifugal force causes the material to exit the refiners. The refined material is then air conveyed through large cyclones to metering bins that feed one of three rotary drum dryers. Exhaust from these cyclones is conveyed to four (4) large, designated baghouses (SN-03, 04, 05 & 06) for particulate control. The green material is initially sent to a MEC Model 1360-T Predryer (SN-16) which reduces the moisture content of the material to <18%. Sander dust is burned on the No. 2 Dust Suspension burner to provide heat for the predryer. The exhaust from the predryer is first conveyed to a primary cyclone to remove the product. The remaining exhaust gas is then sent to a Wet Electrostatic Precipitator (WESP), which is followed by an incinerator called a Regenerative Thermal Oxidizer (RTO). This system effectively reduces VOC and particulate emissions from this source with a control efficiency of 95% for VOC and 90% for particulates. After the green material is dried in the predryer to approximately 15-18% moisture content, it is conveyed to the Dried Green Material Silo by way of the Predryer Return System Baghouse (SN-07). Material from the predryer is combined with purchased dried material and is further dried in one of the three primary dryers. All three dryers are MEC Model 1248-T traditional triple pass dryers. The three rotary dryers are directly heated through a common plenum by exhaust heat generated from the combustion of sander dust and/or natural gas. The flame temperatures of these burners are usually in the F to F range. However, this exhaust gas is diluted and cooled 6

7 immediately upon exiting the combustion chamber with diluent air. This exhaust gas is combined with the exhaust from the hot oil heater system (recirculating oil system for supplying heat to the press) which also utilizes sander dust for fuel. The rotary dryer furnace or blending box also brings in additional diluent air to further lower the air temperature at the entrance of the rotary dryers. Dryer inlet air averages from F to F, and the raw material moisture content is 15-18% on average. The dryer exhaust air ranges in temperatures from F to F. The determining factor for the exhaust gas temperature is the inlet air temperature and the moisture contained in the wood particles. The average moisture content of the wood particles after drying is 3 to 5%. The exhaust gases from each primary dryer enter a dedicated multicyclone separator. Drying and Former Preparation The multicyclones are designed to remove wood particles from the exhaust gas of the dryers at a relatively high efficiency. The exhaust gas from each dryer multicyclone is sent to a common stack (SN-15). The dried material exits the bottom of the multicyclones, and is conveyed into the dry storage bins, one bin for each type of furnish, face and core. Each bin has a bin filter (SN-32 and SN-33 respectively). Material from the dry storage bins is conveyed to the blending area where a urea-formaldehyde (UF) resin (used as a thermosetting binder) is applied in a rotary mixing device. A small amount of wax emulsion is also applied at this point as a moisture inhibitor during the pressing operation. Some excess formaldehyde, which is required as part of the thermosetting chemical reaction, could potentially be released from the resin in the hot pressing operation, but is controlled with an RTO (SN-17A). Usually, a formaldehyde scavenger is used to reduce free formaldehyde. The UF resin is stored in two storage tanks along with urea and wax storage tanks inside the building. The emissions from all these tanks are vented inside the process building and are considered insignificant. Blending of the resin laden furnish is accomplished in water cooled blenders. The blenders are cooled to prevent pre-curing as the material is discharged to mechanical conveyors which carry it over to the forming line. Former and Press System The Hope facility has a moving flexible screen forming line. This forming process is an air classification process in which bottom face material is first placed on the moving flexible screens by a combination of gravity and induced air to form the bottom quarter of the mat. As the screen enters the former, the face furnish is blown countercurrent onto the screen. This ensures that the finest, lightest material will blow onto the flexible screen first for a smoother finished board surface. As the screen reaches the end of the bottom face chamber, the larger particles fall onto 7

8 the mat to form the intermediate levels. The core chambers use gravitational discharge to spread the core material through the middle half of the mat. The thickness consistency is controlled by varying the speed of the belt feeding the chamber. Finally, the top face is put on the mat in the same manner as the bottom face, except that the air is blown in the same direction as the traveling screens to ensure that the lightest and finest material will be the top surface of the mat. Once formed, the mat exits the former and travels the length of the line to the press. Along the way, the mat is weighed, the ends are trimmed and tramp metals are removed. The trim material is pneumatically removed from the former and captured in a cyclone/baghouse combination (SN- 8B). The captured material is recycled back to the process. Dust generated at the former is controlled by a separate baghouse (SN-8A). The flexible screen system delivers the formed mats to the press loader where they are accumulated for simultaneous loading into the hot press. The mats are pressed batchwise on the flexible screens at an average temperature of F and a specific pressure of 800 psi. The heat for the press operation is provided by the hot oil system. The controls of the press are accomplished using computers and timing algorithms to achieve precision and consistency. After the press has opened and the screens with the pressed board are removed, the boards are separated from the screens. Upon release of the pressure, steam and organic vapor is liberated. The emissions are collected within an enclosure surrounding the press. The collected vapors are sent to an RTO for reduction of VOC emissions before exiting to the atmosphere through a stack (SN-17A). Board Finishing Operation The flexible screens are removed from the press and the particleboard is separated from the screens. The screens are returned to the beginning of the forming line by the underground return line. The boards are trimmed by a series of saws that cut approximately two inches off the length and the width edges of the board. Dust created by the sawing operation and materials from the reject bin are conveyed to a cyclone exhaust which is controlled by a baghouse (SN-09). The boards go to a wicket cooling station with a specified retention time to allow the board to cool and give time for the completion of the curing process. As each board cools, emissions from the board are ultimately vented to the atmosphere by way of three roof vents (SN-20, 21, and 22). The cut boards are sent directly to the sanders. The sanders are a multi-head type with the primary function of removing the excess board thickness and to provide a smooth finished face for the board. The first set of heads takes the majority of the material off the board, top and bottom, while the remaining heads remove considerably less material each time. The last head acts as a buffer to ensure high quality of the face of the finished board. 8

9 The sander dust generated in the sanding operation is collected by high suction pneumatic pickup systems and sent through either of two baghouses. The sander dust is then pneumatically conveyed to the storage silos through the transfer system baghouse (SN-12). Emissions from this silo are controlled by a bin vent filter (SN-31). The collected material is used to fuel the sander dust burners of the predryer, the hot oil system, and primary dryers. Following sanding, the board is cut into the desired lengths, graded for quality, sorted, stacked, and packaged for shipment. Regulations The following table contains the regulations applicable to this permit. Regulations Arkansas Air Pollution Control Code, Regulation 18, effective February 15, 1999 Regulations of the Arkansas Plan of Implementation for Air Pollution Control, Regulation 19, effective May 28, 2006 Regulations of the Arkansas Operating Air Permit Program, Regulation 26, effective September 26, CFR Part 52.21, PSD 40 CFR Part 63, Subpart DDDD, Plywood and Composite Wood Products The following table is a summary of emissions from the facility. This table, in itself, is not an enforceable condition of the permit. Emission Summary EMISSION SUMMARY Source Number Description Pollutant lb/hr Emission Rates tpy Total Allowable Emissions PM PM SO VOC

10 HAPs 10 CO NO X Formaldehyde Methanol SN Description Pollutant lb/hr tpy 03 Refiners (2) 04 Refiners (2) 05 Hammermills (3) 06 Hammermills (3) 07 Pre-dryer Return System 08A 08B Forming Line Dust Collection Formers Dust Collector Rough Trim Material Baghouse #1 Sander Dust Collection System PM PM 10 VOC Formaldehyde Methanol PM PM 10 VOC Formaldehyde Methanol PM PM 10 VOC Formaldehyde Methanol PM PM 10 VOC Formaldehyde Methanol PM PM 10 PM PM 10 PM PM 10 PM PM 10 PM PM 10 VOC Formaldehyde Methanol #2 Sander Dust Collection PM

11 System PM 10 VOC Formaldehyde Methanol 12 Sander Dust Transfer PM 10 PM System 13 Finish Saw Dust PM Collection PM Trim Return System PM 15 Primary Dryers (3 Units) 16 Pre-dryer 17A Press Vent RTO Stack Cooler Vent Dry Material Silo Bin Vent Filter PM 10 PM PM 10 SO 2 VOC CO NO x Formaldehyde Methanol PM PM 10 SO 2 VOC CO NO x Formaldehyde Methanol PM PM 10 VOC CO NO x Formaldehyde Methanol PM PM 10 VOC Formaldehyde Methanol PM PM Green Material Silo Bin PM

12 Vent Filter PM Dried Green Material Silo Bin Vent Filter PM PM Bin Vent Filter PM Dried Trim Material Silo PM Filter PM Sander Dust Silo Bin Vent PM Filter PM Dry Face Silo Bin Vent PM PM Dry Core Silo Bin Vent PM Filter 35 Overs Hammermill PM PM *HAPs included in the VOC totals. Other HAPs are not included in any other totals unless specifically stated. 12

13 SECTION III: PERMIT HISTORY 1533-A was issued on May 19, This was the initial air permit for the facility and contained all of the currently permitted sources, with the exception of the press vent RTO (SN- 17) AR-1 was issued on December 28, This modification was issued to address modifications in the process which caused minor increases in emissions and also clarified the record keeping and stack testing requirements of the facility to ensure compliance with emission limits. The facility took a limit of 208,000 MSF/yr of particleboard AR-2 was issued on November 7, This permit modification addressed the installation of a regenerative thermal oxidizer (RTO) to control VOC emissions from the hot press (SN-17 in the previous permit). Also the facility was allowed to burn natural gas only, which prevented the facility from being subject to PSD AOP-R0 was issued on March 9, This permit represented the issuance of the initial Regulation #26 (Title V) permit for the facility. Also the facility was allowed to burn natural gas only, which prevented the facility from being subject to PSD AOP-R1 was issued on November 19, Temple-Inland modified the permit to increase annual production to 220,000 MSF/yr, also the facility requested to burn sander dust fuel in its burners that supply heat to the primary dryers. The following tables are the BACT Analysis and PSD Review. Predryer (SN-16) BACT Analysis PM/PM 10 Cyclone, WESP, and RTO A facility using EFB and RTO is currently undergoing re-permitting due to the fact that it cannot meet their permit limits, therefore this control technology should not be considered BACT. Temple=s proposal has a removal efficiency of 90% which is equal to or higher than all other listed control technologies. VOC RTO The RTO has a VOC removal efficiency of 95% compared to the 90% removal for the RCO. CO Good Combustion There are no instances of add-on controls required for CO emissions. NOx Low NOx Burner These burners minimize thermal NOx formation by the use of low NOx technology and temperature/combustion controls to minimize excess air and excess temperatures. 13

14 Primary Dryers (SN-15) PM/PM 10 Multicyclone Since the moisture content of the wood to be dried is less than 18% there is nothing in the RBLC to compare it to. As part of the BACT research conducted for the particleboard industry, an RTO went through the top-down analysis and was eliminated due to unacceptable economic impacts ($11,429/ton removed). VOC No Control An RTO went through the top-down analysis and was eliminated due to an unacceptable economic impact of $11,429/ton VOC removed. RCO to reduce VOC emissions has yet to be installed and its efficiency has not yet been demonstrated. Scrubbers in the wood products industry are virtually nonexistent. One reason is the process off gas streams is generally associated with high molecular weight organics and therefore would have minimal impact on these type of organics, effecting the unit=s overall efficiency. Activated carbon absorption is likely to plug up due to high flowrates, particulate loading, and condensable organics. Also, the use of this technology for certain organics could result in the generation of hazardous waste. CO Good Combustion There are no listings in the RBLC for CO emissions associated with particleboard facilities. NOx Good Combustion The only listings in the RBLC are for Low NOx Burners on a gas fired dryer. Since the facility is going to burn sander dust as the primary fuel there is no technology for the control of NOx emissions using Low NOx Burners. Press (SN-17) PM/PM 10 RTO All entries in the RBLC have an RTO installed on the press. VOC RTO All entries in the RBLC have an RTO installed on the press. CO Good Combustion There are no listings in the RBLC for CO emissions associated with particleboard facilities. NOx Low NOx Burners These burners minimize thermal NOx formation by the use of low NOx technology and temperature/combustion controls to minimize excess air and excess temperatures. Cooling Wheel (SN-20, 21, and 22) PM/PM 10 No Control There are no listings in the RBLC for PM/PM 10 emissions associated with Cooling Wheels. VOC No Control There are no listings in the RBLC for VOC emissions associated with Cooling Wheels. 14

15 Material Handling and Transferring Operations PM/PM 10 Baghouses Baghouses have 99.9% removal efficiency. Permit 1533-AOP-R2 was issued to Temple-Inland on April 17, This modification was to relocate the primary dryers stack to a position approximately 8 meters to the east of its existing location. The height of the stack will be increased to 150 feet. There were two administrative amendments to permit 1533-AOP-R2. The first was issued on August 2, 2000 corrected the stack height listed in Specific Condition 26 and corrected the Specific Condition numbering. The second was issued on February 19, 2001 corrected Specific Condition 13 to reference the correct sources. Permit 1533-AOP-R3 was issued on August 2, 2001, this modification allowed TIFPC to divert approximately 20% of the exhaust from the hot oil heater to the pre-dryer (SN-16). The exhaust is to be diverted when the pre-dryer is idle to prevent condensation buildup which causes corrosion. This modification also allowed TIFPC to use an additive in their resin water mix known as Additive A. This additive allowed for greater penetration and absorption of the resin into the wood particles during the blending operation. Neither of these modifications affected the facility=s permitted emission rates. Permit 1533-AOP-R4 was issued on July 11, This was the first title V renewal permit for this facility. This was also a modification to the permit allowing the amount of green wood received to be reduced from 128,741 ODT/year to 70,000 ODT/year. Also, the factor used to determine the particulate matter emission rate from SN-16 was lowered from 6.15 lb/odt to 5.27 lb/odt due to improved control from the cyclone prior to the WESP and RTO. Emission rates at some sources were changed to take advantage of new NCASI factors. Finally, the Department clarified the BACT limit for SN-16. Previous calculations for this facility were based on a 98% control. The required combined control efficiency of the WESP and RTO is actually 90% and the emission rates were adjusted to reflect this. Permit 1533-AOP-R5 was issued on December 19, This permit proposed the following changes. A modification will be made to the press by adding two openings. The simultaneous arms on the press will be replaced with new ones to accommodate the additional openings in the press. The thermal oil heaters will be modified to provide oil to the new hot plates. The loader cage will be replaced with a twelve opening loader cage. The unloader cage will be modified to add two openings. These changes will not result in an increase in permitted emissions. An administrative amendment to this permit was issued on January 30, This amendment was performed because Temple decided not to make the proposed modifications. It allowed the facility to redesign the crown of the press and replace the 10 hot plates and jack cylinder jugs in the press and (SN-17). It also corrected several typographical errors in the permit. 15

16 SECTION IV: SPECIFIC CONDITIONS SN-03 and 04 Refiners (4) Source Description Raw material from the silos is classified by reciprocating shaker screens for use in the manufacturing process. Two size streams of material are created by the screening process. The larger material is sent to the hammermills for further size reduction, while other material is sent to the Mill & Drying area to be used in the creation of the particleboard. Emissions generated by the refining of the wood residue by size are controlled by two cyclones. The exhaust from these cyclones is further controlled by a pair of baghouses (SN-03 and SN-04). Specific Conditions 1. The permittee shall not exceed the emission rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. Compliance with the tpy emission rates shall be demonstrated by complying with Plantwide Conditions 5 and 7. [Regulation 19, et seq., effective May 28, 2006 and 40 CFR Part 52, Subpart E] SN Pollutant lb/hr tpy PM VOC PM VOC The permittee shall not exceed the emission rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. Compliance with the tpy emission rates shall be demonstrated by complying with Plantwide Conditions 5 and 7. [Regulation 18, , effective February 15, 1999, and A.C.A as referenced by A.C.A and ] SN Pollutant lb/hr tpy 03 PM

17 Formaldehyde Methanol PM Formaldehyde Methanol Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. [A.C.A as referenced by A.C.A and ] SN Limit Regulatory Citation % Regulation 18, Weekly visible emission observations shall be used as a method of compliance verification for the opacity limits assigned. The weekly observations shall be conducted by someone familiar with the facility=s visible emissions. If during the observations, visible emissions are detected which appear to be in excess of the permitted opacity limit, the permittee shall: a. Take immediate action to identify the cause of the visible emissions, b. Implement corrective action, and c. If excessive visible emissions are still detected, an opacity reading shall be conducted in accordance with EPA Reference Method 9 for point sources and in accordance with EPA Method 22 for non-point sources. This reading shall be conducted by a person trained and certified in the reference method. If the opacity reading exceeds the permitted limit, further corrective measures shall be taken. d. If no excessive visible emissions are detected, the incident shall be noted in the records as described below. The permittee shall maintain records related to all visible emission observations and Method 9 readings. These records shall be updated on an as-performed basis. These records shall be kept on site and made available to Department personnel upon request. These records shall contain: 17

18 a. The time and date of each observation/reading any observance of visible emissions appearing to be above permitted limits or any Method 9 reading which indicates exceedance, b. The cause of any observed exceedance of opacity limits, corrective actions taken, and results of the reassessment, and c. The name of the person conducting the observation/reading. [Regulation 18, and A.C.A as referenced by A.C.A and ] 18

19 SN-05, 06 and 35 Hammermills Source Description The primary hammermills are used to reduce the size of acceptable screened materials for use in the formation of the outer edges of the particleboard sheets. Emissions from these two hammermills are controlled by two baghouses (SN-05, SN-06). The overs hammermill is used to reduce the size of unacceptable screened materials. Emissions from this hammermill are controlled by a baghouse (SN-35). Specific Conditions 5. The permittee shall not exceed the emission rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions will be demonstrated by complying with Plantwide Conditions 5 and 7. [Regulation 19, et seq. and 40 CFR Part 52, Subpart E] SN Pollutant lb/hr tpy PM VOC PM VOC PM The permittee shall not exceed the emission rates set forth in the following table. Compliance shall be demonstrated through compliance with Plantwide Conditions 5 and 7. [Regulation 18, , and A.C.A as referenced by A.C.A and ] SN Pollutant lb/hr tpy 05 PM Formaldehyde

20 06 Methanol PM Formaldehyde Methanol PM Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. [A.C.A as referenced by A.C.A and ] SN Limit Regulatory Citation % Regulation 18, Weekly visible emission observations shall be used as a method of compliance verification for the opacity limits assigned. The weekly observations shall be conducted by someone familiar with the facility=s visible emissions. If during the observations, visible emissions are detected which appear to be in excess of the permitted opacity limit, the permittee shall: a. Take immediate action to identify the cause of the visible emissions, b. Implement corrective action, and c. If excessive visible emissions are still detected, an opacity reading shall be conducted in accordance with EPA Reference Method 9 for point sources and in accordance with EPA Method 22 for non-point sources. This reading shall be conducted by a person trained and certified in the reference method. If the opacity reading exceeds the permitted limit, further corrective measures shall be taken. d. If no excessive visible emissions are detected, the incident shall be noted in the records as described below. The permittee shall maintain records related to all visible emission observations and Method 9 readings. These records shall be updated on an as-performed basis. These records shall be kept on site and made available to Department personnel upon request. These records shall contain: 20

21 a. The time and date of each observation/reading any observance of visible emissions appearing to be above permitted limits or any Method 9 reading which indicates exceedance, b. The cause of any observed exceedance of opacity limits, corrective actions taken, and results of the reassessment, and c. The name of the person conducting the observation/reading. [Regulation 18, and A.C.A as referenced by A.C.A and ] 21

22 SN-07 & SN-08A and SN-08B Pre-dryer Return System & Forming Line and Formers Dust Collection Source Description Two baghouses (SN-08A and SN-08B) collect dust from the forming line where the sheets of particleboard are first formed and trimmed from the wood residue, before entering the press. Compliance Assurance Monitoring The Compliance Assurance Monitoring (CAM) rule applies to any pollutant specific emission unit that (1) is subject to an emission limitation or standard, (2) uses a control device to achieve compliance with the emission limitation or standard, and (3) has potential pre-control emissions of the regulated pollutant that exceed or are equivalent to the major source threshold of 100 tpy per pollutant. The predryer return system baghouse (SN-07), forming line dust collection baghouse (SN-08A), and formers dust collection baghouse (SN-08B) have pre-control PM 10 emissions of 117.0, 129.0, and tpy respectively. Weekly opacity readings will be done to insure that control measures are properly operated and maintained. If the threshold levels set in the permit are exceeded by greater than 5% of the unit=s total operating time, the facility is required to prepare a Quality Improvement Plan (QIP). A Quality Improvement Plan is a written plan that outlines the procedures that will be used to evaluate problems that affect the performance of control equipment. The Department requires a source to develop and implement a QIP after a determination that the source has failed to use acceptable procedures in responding to an exceedance. Specific Conditions 9. The permittee shall not exceed the emission rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions and CAM compliance will be demonstrated by complying with Plantwide Conditions 5 and 7. [Regulation 19, et seq. and 40 CFR Part 52, Subpart E] SN Pollutant lb/hr tpy 07 PM A PM

23 08B PM The permittee shall not exceed the emission rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions and CAM compliance will be demonstrated by complying with Plantwide Conditions 5 and 7. [Regulation 18, , and A.C.A as referenced by and ] SN Pollutant lb/hr tpy 07 PM A PM B PM Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. [A.C.A as referenced by A.C.A and ] SN Limit Regulatory Citation 07 08A 08B 5% Regulation 18, Weekly visible emission observations shall be used as a method of compliance verification for the opacity limits assigned. The weekly observations shall be conducted by someone familiar with the facility=s visible emissions. If during the observations, visible emissions are detected which appear to be in excess of the permitted opacity limit, the permittee shall: a. Take immediate action to identify the cause of the visible emissions, b. Implement corrective action, and c. If excessive visible emissions are still detected, an opacity reading shall be conducted in accordance with EPA Reference Method 9 for point sources and in accordance with EPA Method 22 for non-point sources. This reading shall be conducted by a person trained and certified in the reference method. If the opacity reading exceeds the permitted limit, further corrective measures shall be taken. 23

24 d. If no excessive visible emissions are detected, the incident shall be noted in the records as described below. The permittee shall maintain records related to all visible emission observations and Method 9 readings. These records shall be updated on an as-performed basis. These records shall be kept on site and made available to Department personnel upon request. These records shall contain: a. The time and date of each observation/reading any observance of visible emissions appearing to be above permitted limits or any Method 9 reading which indicates exceedance, b. The cause of any observed exceedance of opacity limits, corrective actions taken, and results of the reassessment, and c. The name of the person conducting the observation/reading. [Regulation 18, and A.C.A as referenced by A.C.A and ] 13. The permittee shall record the number of excursions that have occurred at sources SN-07, SN-08A and SN-08B for opacity. If there are nine (9) excursions in a six month period for opacity the facility will be required to submit a Quality Improvement Plan (QIP). The QIP should provide the following information: a. procedures to improve the quality of control performance; b. procedures that will be implemented to reduce the probability of a recurrence of the problem; c. a schedule for making such improvements. These records and QIP shall be kept on site and made available to Department personnel upon request. [40 CFR Part 64 and A.C.A as referenced by A.C.A and ] 24

25 SN-10 and SN-11 #1 and #2 Sander Dust Collection System SN-12 Sander Dust Transfer System SN-13 Finish Saw Dust Collection SN-14 Trim Return System Source Description Five baghouses collect waste material from the finishing of pressed and cooled particleboard sheets. These include the collection of sander dust from sanding operations (SN-10 and SN-11), the return of sander dust to the manufacturing process (SN-12), and collection of finish saw dust (SN-13) and trim waste material (SN-14). Specific Conditions 14. The permittee shall not exceed the emission rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions will be demonstrated by complying with Plantwide Conditions 5 and 7. [Regulation 19, et seq. and 40 CFR Part 52, Subpart E] SN Pollutant lb/hr tpy 10 and 11 PM VOC PM PM PM The permittee shall not exceed the emission rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions will be demonstrated by complying with Plantwide Conditions 5 and 25

26 7. [Regulation 18, and A.C.A as referenced by and ] SN Pollutant lb/hr tpy 10 and 11 PM Formaldehyde Methanol PM PM PM Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. [A.C.A as referenced by A.C.A and ] SN Limit Regulatory Citation 10 and % Regulation 18, Weekly visible emission observations shall be used as a method of compliance verification for the opacity limits assigned. The weekly observations shall be conducted by someone familiar with the facility=s visible emissions. If during the observations, visible emissions are detected which appear to be in excess of the permitted opacity limit, the permittee shall: a. Take immediate action to identify the cause of the visible emissions, b. Implement corrective action, and 26

27 c. If excessive visible emissions are still detected, an opacity reading shall be conducted in accordance with EPA Reference Method 9 for point sources and in accordance with EPA Method 22 for non-point sources. This reading shall be conducted by a person trained and certified in the reference method. If the opacity reading exceeds the permitted limit, further corrective measures shall be taken. d. If no excessive visible emissions are detected, the incident shall be noted in the records as described below. The permittee shall maintain records related to all visible emission observations and Method 9 readings. These records shall be updated on an as-performed basis. These records shall be kept on site and made available to Department personnel upon request. These records shall contain: a. The time and date of each observation/reading any observance of visible emissions appearing to be above permitted limits or any Method 9 reading which indicates exceedance, b. The cause of any observed exceedance of opacity limits, corrective actions taken, and results of the reassessment, and c. The name of the person conducting the observation/reading. [Regulation 18, and A.C.A as referenced by A.C.A and ] 27

28 SN-15 Primary Dryers (3 Units) Source Description The three 58 million Btu per hour primary dryers are used to further reduce the moisture content of the dry wood residue before it is used in the manufacturing process. Emissions from the three dryers are controlled by three multi-cyclones. The exhaust air from these multi-cyclones is vented to the atmosphere by a common stack (SN-15). The facility is permitted to use sander dust as the primary fuel. Compliance Assurance Monitoring The Compliance Assurance Monitoring (CAM) rule applies to any pollutant specific emission unit that (1) is subject to an emission limitation or standard, (2) uses a control device to achieve compliance with the emission limitation or standard, and (3) has potential pre-control emissions of the regulated pollutant that exceed or are equivalent to the major source threshold of 100 tpy per pollutant. The primary dryers (SN-15) have pre-control PM 10 emissions of tpy. Daily opacity readings for the multicyclone will be used to insure the control measures are properly operated and maintained. If the threshold levels set in the permit are exceeded greater than 5% of the unit=s total operating time, the facility is required to prepare a Quality Improvement Plan (QIP). A Quality Improvement Plan is a written plan that outlines the procedures that will be used to evaluate problems that affect the performance of control equipment. The Department requires a source to develop and implement a QIP after a determination that the source has failed to use acceptable procedures in responding to an exceedance. Specific Conditions 18. The permittee shall not exceed the emission rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions and CAM compliance will be demonstrated by complying with Specific Condition 21 and Plantwide Condition 7. [Regulation 19, et seq. and 40 CFR Part 52, Subpart E] 28

29 Pollutant lb/hr tpy PM SO VOC CO NO x The permittee shall not exceed the emission rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions and CAM compliance will be demonstrated by complying with Specific Condition 21 and Plantwide Condition 7. [Regulation 18, , and A.C.A as referenced by and ] Pollutant lb/hr tpy PM Formaldehyde Methanol Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. [40 CFR Part 52, Subpart E] SN Limit Regulatory Citation 15 20% Regulation 19, Daily visible emission observations shall be used as a method of compliance verification for the opacity limits assigned. The daily observations shall be conducted by someone familiar with the facility=s visible emissions. If during the observations, visible emissions are detected which appear to be in excess of the permitted opacity limit, the permittee shall: a. Take immediate action to identify the cause of the visible emissions, b. Implement corrective action, and 29

30 c. If excessive visible emissions are still detected, an opacity reading shall be conducted in accordance with EPA Reference Method 9 for point sources and in accordance with EPA Method 22 for non-point sources. This reading shall be conducted by a person trained and certified in the reference method. If the opacity reading exceeds the permitted limit, further corrective measures shall be taken. d. If no excessive visible emissions are detected, the incident shall be noted in the records as described below. The permittee shall maintain records related to all visible emission observations and Method 9 readings. These records shall be updated on an as-performed basis. These records shall be kept on site and made available to Department personnel upon request. These records shall contain: a. The time and date of each observation/reading any observance of visible emissions appearing to be above permitted limits or any Method 9 reading which indicates exceedance, b. The cause of any observed exceedance of opacity limits, corrective actions taken, and results of the reassessment, and c. The name of the person conducting the observation/reading. [Regulation 19, and 40 CFR Part 52, Subpart E] 22. The permittee shall record the number of excursions that have occurred at SN-15 for opacity. If there are nine (9) excursions in a six month period for opacity the facility will be required to submit a Quality Improvement Plan (QIP). The QIP should provide the following information: a. procedures to improve the quality of control performance; b. procedures that will be implemented to reduce the probability of a recurrence of the problem; c. a schedule for making such improvements. These records and QIP shall be kept on site and made available to Department personnel upon request. [40 CFR Part 64 and A.C.A as referenced by A.C.A and ] 30

31 SN-16 Pre-dryer Source Description The 39 million Btu per hour pre-dryer (SN-16) is used to remove moisture from the green wood residue. Once this is accomplished, the dried wood residue is sent back to a storage silo to be used later in the manufacturing process. Emissions from the pre-dryer are sent through a cyclone, wet electrostatic precipitator (WESP), and finally through to a regenerative thermal oxidizer (RTO) for reduction. The facility is permitted to use sander dust as the primary fuel for the pre-dryer and natural gas for the RTO. While the pre-dryer is not in operation 20% of the exhaust from the hot oil heater can be routed through the pre-dryer to prevent condensation buildup which causes corrosion. While the hot oil heaters emissions are being routed through the pre-dryer TIFPC will continue to operate the wet ESP but will not operate the RTO as a control device. Compliance Assurance Monitoring The Compliance Assurance Monitoring (CAM) rule applies to any pollutant specific emission unit that (1) is subject to an emission limitation or standard, (2) uses a control device to achieve compliance with the emission limitation or standard, and (3) has potential pre-control emissions of the regulated pollutant that exceed or are equivalent to the major source threshold of 100 tpy per pollutant. The predryer (SN-16) has pre-control VOC and PM 10 emissions of and tpy respectively. Daily opacity readings, average voltage reading for the WESP, average combustion zone temperature at the RTO, and the average inlet static pressure to insure the control measures are properly operated and maintained. If the threshold levels set in the permit are exceeded greater than 5% of the unit=s total operating time, the facility is required to prepare a Quality Improvement Plan (QIP). A Quality Improvement Plan is a written plan that outlines the procedures that will be used to evaluate problems that affect the performance of control equipment. The Department requires a source to develop and implement a QIP after a determination that the source has failed to use acceptable procedures in responding to an exceedance. Specific Conditions 23. The permittee shall not exceed the emission rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. 31

32 The tpy emissions and CAM compliance will be demonstrated by complying with Specific Condition 27 and Plantwide Condition 7. [Regulation 19, et seq. and 40 CFR Part 52, Subpart E] Pollutant lb/hr tpy PM SO VOC CO NO x The permittee shall not exceed the emission rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions and CAM compliance will be demonstrated by complying with Specific Condition 27 and Plantwide Condition 7. [Regulation 18, , and A.C.A as referenced by and ] Pollutant lb/hr tpy PM Formaldehyde Methanol Visible emissions may not exceed the limits specified in the following table of this permit as measured by EPA Reference Method 9. [40 CFR Part 52, Subpart E] SN Limit Regulatory Citation 16 20% Regulation 19, Daily visible emission observations shall be used as a method of compliance verification for the opacity limits assigned. The daily observations shall be conducted by someone familiar with the facility=s visible emissions. If during the observations, visible emissions are detected which appear to be in excess of the permitted opacity limit, the permittee shall: 32

33 a. Take immediate action to identify the cause of the visible emissions, b. Implement corrective action, and c. If excessive visible emissions are still detected, an opacity reading shall be conducted in accordance with EPA Reference Method 9 for point sources and in accordance with EPA Method 22 for non-point sources. This reading shall be conducted by a person trained and certified in the reference method. If the opacity reading exceeds the permitted limit, further corrective measures shall be taken. d. If no excessive visible emissions are detected, the incident shall be noted in the records as described below. The permittee shall maintain records related to all visible emission observations and Method 9 readings. These records shall be updated on an as-performed basis. These records shall be kept on site and made available to Department personnel upon request. These records shall contain: a. The time and date of each observation/reading any observance of visible emissions appearing to be above permitted limits or any Method 9 reading which indicates exceedance, b. The cause of any observed exceedance of opacity limits, corrective actions taken, and results of the reassessment, and c. The name of the person conducting the observation/reading. [Regulation 19, and 40 CFR Part 52, Subpart E] 27. The permittee shall test the RTO (SN-16) each year for PM 10, NO x, CO and VOC emissions using EPA Reference Methods 5, 7E, 10 and 25A respectively, and for opacity using EPA Reference Method 9. These tests shall be performed simultaneously. While performing the tests, the dryer shall be operating at least 90% of the maximum throughput rate. If testing is conducted at a rate lower than 90%, the facility shall be limited to an operating rate of 110% of the tested rate until compliance at a higher rate is demonstrated. The permittee shall submit a written testing protocol to the Compliance Section Manager at least 15 days prior to any scheduled test. If the facility passes three consecutive tests for this source, the permittee may apply for less stringent testing. [Regulation 19, , et. seq., and 40 CFR Part 52, Subpart E] 28. The minimum voltage for the WESP shall not fall below 20 kv. Compliance shall be demonstrated through compliance with Specific Condition 29. [40 CFR Part 64, Regulation 19, ' and ' et seq., 40 CFR Part 52, Subpart E, and A.C.A. ' as referenced by A.C.A. ' and ' ] 33