STATEMENT OF BASIS. (New, Renewal, Modification, Deminimis/Minor Mod, or Administrative Amendment)

Size: px

Start display at page:

Download "STATEMENT OF BASIS. (New, Renewal, Modification, Deminimis/Minor Mod, or Administrative Amendment)"

Vanessa Ross
5 years ago
Views:

1 STATEMENT OF BASIS For the issuance of Draft Air Permit # 0697-AOP-R16 1. PERMITTING AUTHORITY: Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, Arkansas APPLICANT: Deltic Timber Corporation 1720 Highway 82 West Waldo, Arkansas PERMIT WRITER: Charles Hurt, P.E. 4. NAICS DESCRIPTION AND CODE: NAICS Description: Sawmills NAICS Code: SUBMITTALS: Date of Application Type of Application (New, Renewal, Modification, Deminimis/Minor Mod, or Administrative Amendment) 6/4/2015 Minor Modification Short Description of Any Changes That Would Be Considered New or Modified Emissions Change BACT limit for -06 and - 08 and increase production at those sources. Lower PM/ emissions for -06, -07, and -08 based on more recent tests added to the NCASI database 6. REVIEWER S NOTES: Deltic Timber Corporation (Deltic) currently operates a lumber and chip mill at 1720 Highway 82 West in Waldo, Arkansas The facility submitted an application to modify and increase the maximum annual production capacity of two continuous kilns (-06 and -08) and revise PM/ emission limits for all three continuous kilns

2 Page 2 of 8 (-06, -07, and -08). Overall, permitted emissions decreased by 3.5 tpy PM/. 7. COMPLIANCE STATUS: The following summarizes the current compliance of the facility including active/pending enforcement actions and recent compliance activities and issues. The facility was last inspected on December 10, The inspection report noted that there were no areas of concern. 8. PSD APPLICABILITY: a) Did the facility undergo PSD review in this permit (i.e., BACT, Modeling,? N b) Is the facility categorized as a major source for PSD? Y Single pollutant 100 tpy and on the list of 28 or single pollutant 250 tpy and not on list If yes, explain why this permit modification is not PSD. The applicant proposed annual production limits for -06 and -08 which would result in an emissions increase of less than 40 tpy of VOC. 9. SOURCE AND POLLUTANT SPECIFIC REGULATORY APPLICABILITY: Source Pollutant Regulation [NSPS, NESHAP (Part 61 & Part 63), or PSD only] -20 PM/, VOC, CO, NO X PSD -04, -05, -07, -08, -13, -14 VOC PSD -13, -14, -20 PM, Opacity 40 CFR Part 60, Subpart Dc 28 PM, VOC, NO X, Opacity 40 CFR Part 60, Subpart IIII 10. EMISSION CHANGES AND FEE CALCULATION: See emission change and fee calculation spreadsheet in Appendix A. 11. AMBIENT AIR EVALUATIONS: a) Reserved b) Non-Criteria Pollutants:

3 Page 3 of 8 The non-criteria pollutants listed below were evaluated. Based on Department procedures for review of non-criteria pollutants, emissions of all other non-criteria pollutants are below thresholds of concern. 1 st Tier Screening (PAER) Estimated hourly emissions from the following sources were compared to the Presumptively Acceptable Emission Rate (PAER) for each compound. The Department has deemed the PAER to be the product, in lb/hr, of 0.11 and the Threshold Limit Value (mg/m 3 ), as listed by the American Conference of Governmental Industrial Hygienists (ACGIH). Pollutant TLV PAER (lb/hr) = (mg/m 3 ) 0.11 TLV Proposed lb/hr Pass? Acrolein* N/A N/A N/A N/A Methanol Yes * There is no TLV-TWA or PAER for Acrolein. 2 nd Tier Screening (PAIL) AERMOD air dispersion modeling was performed on the estimated hourly emissions from the following sources, in order to predict ambient concentrations beyond the property boundary. The Presumptively Acceptable Impact Level (PAIL) for each compound has been deemed by the Department to be one one-hundredth of the Threshold Limit Value as listed by the ACGIH. PAIL (μg/m 3 ) = 1/100 of Modeled Concentration Pollutant Threshold Limit Value (μg/m 3 Pass? ) Acrolein* N/A N/A N/A * There is no TLV-TWA or PAIL for Acrolein. Additional Screening Acrolein is one of the pollutants identified by the U.S. EPA to be a hazardous air pollutant. In order to evaluate the potential adverse health effects, the predicted offsite concentrations were compared to the Effects Screening Level (ESL) posted by the Texas Commissions Environmental Quality (TCEQ). For Acrolein, TCEQ provides both a short-term (acute) and a long-term (chronic) screening value. The screening levels and the results of the modeling are listed in the table below. Averaging Period TCEQ ESL (mg/m 3 ) 2011 Highest, First High Predicted Offsite Concentration (mg/m 3 ) Short-term (1-hr)

4 Page 4 of 8 Averaging Period TCEQ ESL (mg/m 3 ) 2011 Highest, First High Predicted Offsite Concentration (mg/m 3 ) Long-term (annual) As shown in the table above, the model predicted no concentration above the effects screening level. According to the EPA there is insufficient information to designate acrolein as a carcinogen. Therefore, cancer effects screening is unnecessary. No further evaluation is warranted. c) H2S Modeling: Odor modeling for hydrogen sulfide was not performed because the facility has not identified emissions of that pollutant. 12. CALCULATIONS: Emission Factor Source (AP-42, Testing, 02 AP NCASI Test / Similar Emission Factor and units (lbs/ton, lbs/hr, 0.35 lb PM/ton log 0.2 lb /ton log lb /MBF 3.5 lb VOC/MBF lb Acetaldehyde/M BF lb Acrolein/MBF lb Formaldehyde/ MBF lb Methanol/MBF ,350 cfm Type ( if any) Efficiency Comments (Emission factor controlled/uncontrolled, None N/A uncontrolled None N/A Uncontrolled Each Batch Kiln (-04 and -05) ( MBF / 16hr) Max: 7.28 MBF/hr Each Continuous Kiln (-06, -07, and -08) Max: 13.2 MBF/hr N/A N/A uncontrolled

5 Page 5 of , 14, 20 Emission Factor Source (AP-42, Testing, Test / Similar Vendor (Criteria) AP-42 (HAPs) 16 Test / Tanks Tanks Test / AP AP AP-42 Emission Factor and units (lbs/ton, lbs/hr, ,000 cfm 0.08 lb /MMBTU 0.3 lb NO X /MMBTU lb CO/MMBTU 0.07 lb VOC/MMBTU lb SO 2 /MMBTU ,000 cfm 5.2 lb VOC/hr 2.1 ton VOC/yr 0.4 lb VOC/hr 0.01 ton VOC/yr ,000 cfm Boiler Ash Handling 1 lb /ton Bark and Sawdust Piles lb /ton 0.18 lb VOC/hr lb /ton lb/vmt/hr lb/vmt/yr Type ( if any) Efficiency Comments (Emission factor controlled/uncontrolled, N/A N/A uncontrolled ESP 84% led PM/ 60 MMBTU/hr Wood Waste Boilers Assumed 4,500 BTU/lb heating value for fuel N/A N/A uncontrolled None None N/A N/A uncontrolled 10,000 gallon fixed roof tank stores gasoline uncontrolled 10,000 gallon fixed roof tank stores Diesel N/A N/A uncontrolled None N/A uncontrolled None N/A uncontrolled None N/A Vehicles are limited to 5 mph.

6 Page 6 of 8 28 Emission Factor Source (AP-42, Testing, Vendor (Criteria Except SO 2 ) AP-42 (SO 2 ) 29 AP-42 Emission Factor and units (lbs/ton, lbs/hr, 0.40 g/kw-hr NO X +VOC 7.5 g/kw-hr CO 5.0 g/kw-hr SO lb/hp-hr 7.08 lb/vmt/hr 2.02 lb/vmt/yr Type ( if any) Efficiency Comments (Emission factor controlled/uncontrolled, None N/A Uncontrolled None N/A Vehicles are limited to 5 mph. 13. TESTING REQUIREMENTS: The permit requires testing of the following sources. (s) Pollutant Test Method Test Interval CO NO X VOC` CO NO X VOC` PM/ VOC CO NO X Silt Loading (Paved Road) 5 or 201A 10 7E 25A 5 or 201A 10 7E 25A 5 25 A 10 7E ASTM-C-136 and Appendix C.1 and C.2 of AP-42 Once every 2 years then every 5 Initial then once every 5 years Once every 2 years then every 5 Initial then once every 5 years initial test then once every five years One Time Justification For Test Requirement Compliance Verification BACT Compliance Verification BACT PSD Source Verification of value used to estimate emissions

7 Page 7 of MONITORING OR CEMS: The permittee must monitor the following parameters with CEMS or other monitoring equipment (temperature, pressure differential, 13, 14, 20 Parameter or Pollutant to be Monitored Method of Monitoring (CEM, Pressure Gauge, Frequency* Report (Y/N)** Opacity COMS Continuously Y 15. RECORDKEEPING REQUIREMENTS: The following are items (such as throughput, fuel usage, VOC content, that must be tracked and recorded. Recorded Item Limit (as established in permit) Frequency* Report (Y/N)** 04, 05, 06, 07, Combined Kiln Production 285 MMBf/yr Monthly Y 08, 21 10, 16 Secondary Lumber Production 15 MMBf/yr Monthly Y 13 Steam Production 1,200,000 lb/day Daily Y 14 Steam Production 1,200,000 lb/day Daily Y 18 Gasoline Fuel Throughput 100,000 gallon/yr Monthly Y 19 Diesel Fuel Throughput 160,000 gallon/yr Monthly Y 20 Steam Production 1,200,000 lb/day Daily Y 28 Vehicle Miles Traveled 86,262 VMT/yr Monthly Y 29 Vehicle Miles Traveled 982 VMT/yr Monthly Y 16. OPACITY: Opacity % Justification (NSPS limit, Dept. Guidance, etc) Compliance Mechanism (daily observation, weekly, control equipment operation, 09 5 Dept. Guidance Weekly Dept. Guidance Weekly Dept. Guidance Weekly NSPS Continuously NSPS Continuously NSPS Continuously

8 Page 8 of 8 Opacity % Justification (NSPS limit, Dept. Guidance, etc) Compliance Mechanism (daily observation, weekly, control equipment operation, Dept. Guidance Weekly 17. DELETED CONDITIONS: Former SC Justification for removal 6-7 Revised emission based on maximum hourly production rate 18. GROUP A INSIGNIFICANT ACTIVITIES: Source Name 14 Bulk Oil Storage Tanks (1,000 gallon or less) Debarking Operations Sawdust Conveyors Bark/Chip Conveyors and Drop Points Wood Hog Batten Manufacturing Operation Group A Category PM/ Emissions (tpy) SO 2 VOC CO NO X HAPS A A13 A13 A13 A13 A / / / / / VOIDED, SUPERSEDED, OR SUBSUMED PERMITS: List all active permits voided/superseded/subsumed by the issuance of this permit. Permit # 0697-AOP-R15

9 APPENDIX A EMISSION CHANGES AND FEE CALCULATION

10 Fee Calculation for Major Source Facility Name: Deltic Timber Corporation Permit Number: 697-AOP-R16 Revised $/ton factor Annual Emissions (tpy) Permit Type Minor Mod Permit Fee $ 500 Minor Modification Fee $ 500 Minimum Modification Fee $ 1000 Renewal with Minor Modification $ 500 Check if Facility Holds an Active Minor Source or Minor Source General Permit If Hold Active Permit, Amt of Last Annual Air Permit Invoice $ 0 Total Permit Fee Emissions (tpy) -3.5 Initial Title V Permit Fee Emissions (tpy) HAPs not included in VOC or PM: Air Contaminants: Chlorine, Hydrazine, HCl, HF, Methyl Chloroform, Methylene Chloride, Phosphine, Tetrachloroethylene, Titanium Tetrachloride All air contaminants are chargeable unless they are included in other totals (e.g., H2SO4 in condensible PM, H2S in TRS, Pollutant (tpy) Check if Emission Old Permit New Permit Change in Emissions Permit Fee Emissions Annual Emissions PM SO VOC CO NO X Lead Acrolein

11 Pollutant (tpy) Check if Emission Old Permit New Permit Change in Emissions Permit Fee Emissions Annual Emissions Cadmium Chromium HCl Manganese Mercury Methanol Nickel Acetone

STATEMENT OF BASIS. University of Arkansas for Medical Sciences (UAMS) 4301 West Markham St. Little Rock, Arkansas 72205

STATEMENT OF BASIS. University of Arkansas for Medical Sciences (UAMS) 4301 West Markham St. Little Rock, Arkansas 72205 STATEMENT OF BASIS For the issuance of Draft Air Permit # 2125-AOP-R3 1. PERMITTING AUTHORITY: Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, Arkansas 72118-5317