Review Report/Permit No.: I 0-0030-TV -0 I Application No ...€¦ · OREGON TITLE V OPERATING PERMIT REVIEW REPORT Slate of Omgon ... INTRODUCTION ... Saw Mills and Barker, Planer

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Review Report/Permit No.: I 0-0030-TV -0 I Application No.: 27325

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r.t.: I •1 i(•J

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY OREGON TITLE V OPERATING PERMIT

REVIEW REPORT Slate of Omgon Department of Environmental OI.Jality

SIC

NAICS

Source Information·

2421,4961

321113, 221330

Western Region

I Source Categories (Pmt and code)

c r ompuance an dE ' . M 't . R ~miSSIOns om ormg _ eqmremen s: t

Unassigned emissions X COMS

Emission credits CEMS

Compliance schedule CPMS

Source test [date( s)] Hog fuel boiler KB (once)

Ambient monitoring

R R eportmg eqmrements

Annual report (due date) 2/15 Monthly report (due dates)

Emission fee report (due date) 2/15 Excess emissions report

SACC (due date) 2/15 and 8/15 Other reports (type)

Quarterly report (due dates)

A' p If rograms

NSPS (list subparts) A, De ( CBB-II) TACT

NESHAP (list subparts) A, JJJJJJ (KB), Title V

CCCCCC (GDF) ACDP (SIP)

CAM KB Major HAP source

Regional Haze (RH) Federal major source

Synthetic Minor (SM) NSR

Part 68 Risk Management PSD

CFC GDF

RACT Acid Rain

KB (02, breach temp., multiclones pressure

drop)

X

GHG

X

X

X

TABLE OF CONTENTS


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INTRODUCTION ......................................................................................................................................................... 4

RENEWAL AND PROPOSED CHANGES ................................................................................................................. 4

PERMITTEE IDENTIFICATION ................................................................................................................................ 4

FACILITYDESCRIPTION .......................................................................................................................................... 4

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION .................................................. 5

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING ......................... 8

PLANT SITE EMISSION LIMITS ............................................................................................................................... 4

SIGNIFICANT EMISSION RATE ............................................................................................................................... 4

HAZARDOUS AIR POLLUTANTS .......................................................................................................................... II

GENERAL BACKGROUND INFORMATION ........................................................................................................ 12

COMPLIANCE HISTORY ......................................................................................................................................... l2

SOURCE TEST RESULTS ........................................................................................................................................ 12

PUBLICNOTICE ....................................................................................................................................................... 13

ATTACHMENTS ....................................................................................................................................................... 13

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LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT

AQMA Air Quality Management Area N,O nitrous oxide (greenhouse gas) ASTM American Society of Testing and NA not applicable

Materials NESHAP National Emission Standard for BDT bone dry ton Hazardous Air Pollutants GEMS continuous emissions monitoring NOx oxides ofnin·ogen

system NSPS New Source Performance Standard CFR Code of Federal Regulations NSR New Source Review CH4 methane (greenhouse gas) o, oxygen CMS continuous monitoring system OAR Oregon Administrative Rules co carbon monoxide ORS Oregon Revised Statutes co,e carbon dioxide equivalent O&M operation and maintenance COMS continuous opacity monitoring Pb lead

system PCD pollution control device DEQ Oregon DEQ ofEnvironmental PEMS predictive emissions monitoring

Quality system dscf dry standard cubic feet PM particulate matter EF emission factor PMw particulate matter less than 10 EPA United State Environmental microns in size

Protection Agency PMz.s particulate matter less than 2.5 EU emissions unit microns in size FCAA Federal Clean Air Act PSD Prevention of Significant GHG greenhouse gas Deterioration gr/dscf grains per dry standard cubic feet PSEL Plant Site Emission Limit HAP hazardous air pollutant so, sulfur dioxide ID identification code ST source test I&M inspection and maintenance VE visible emissions MB material balance VMT vehicle mile traveled Mlb 1000 pounds voc volatile organic compound MM million

INTRODUCTION

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I. DEQ proposes to renew the existing Title V operating permit for the Swanson Group Mfg. LLC, Roseburg Stud Division plant and to incorporate DEQ rule changes adopted on April16, 2015. The existing permit was issued on 5/15/06 and was scheduled to expire on 711/11. However, the company submitted a timely renewal application on 1/25/10 such that the existing permit, as modified, remains in effect until the renewal permit is issued.

RENEWAL AND PROPOSED CHANGES

2. In accordance with OAR 340-218-0120(l)(f), this review report is intended to provide the legal and factual basis for the draft permit conditions. In most cases, the legal basis for a permit condition is included in the permit by citing the applicable regulation. In addition, the factual basis for the requirement may be the same as the legal basis. However, when the regulation is not specific and only provides general requirements, this review report is used to provide a more thorough explanation of the factual basis for the draft permit conditions.

3. Since the last Title V permit issuance, DEQ has issued the following construction authorizations or permit modifications:

Date Pennit revision or notification Brief explanation 9/28/07 Significant permit modification Add HAP PSELs to the permit and name change 6/17/08 Administrative amendment Changes to excess emission rules

4. The following changes have been made to the permit:

• Contact information is updated. • The emission unit inventory has been updated to reflect the existing facility configuration. • Baseline emissions have been recalculated for some emission units due to more recent updated

emission factors and emissions from truck loading, gasoline dispensing facilities, and wood residuals calculated for the first time.

• The production rates and emission calculations have been updated to reflect proposed operations and cunent emission factors.

• Proposed PSELs have been updated to reflect proposed operations and current emission factors. • Due to DEQ rule changes adopted on April 16, 2015 the following changes are also included:

o A greenhouse gas (GHG) baseline emission rate, netting basis, and plant site emission limit (PSEL) are being established for the first time.

o PMz5 netting basis and PSEL are also being established in this permitting action. o The grain loading and opacity standards have been updated. o Categorically insignificant activities have been revised. o Nuisance and fugitive emission condition requirements are updated. o Rule references have been updated as needed.

PERMITTEE IDENTIFICATION

5. The Roseburg Stud Division operates a sawmill and planing mill located at 2635 Old Highway 99S, Roseburg, Oregon. The process includes the manufacturing of dimension lumber and green lumber. The main buildings at the facility are: Offices, Saw Mills and Barker, Planer Mill, Dry kilns, and Boiler House.

FACILITY DESCRIPTION


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6. Logs received by the facility are debarked and sawed to make lumber. Most of the lumber is dried in wood dtying kilns prior to shipment; the remainder is marketed as green lumber. The kilns utilize steam supplied by boilers in their operations. Wood waste generated fi·om wood working operations is used as fuel for the hogged fuel boiler or transported offsite for sale.

Currently at the fucility there are two boilers [Kipper hogged fuel boiler (!<B), and a Cleaver Brooks (CBB-II) natural gas boiler], one (I) cyclone which exhausts directly to the atmosphere (handling sawdust), one baghouse handling shavings, and four (4) target boxes (Sawdust, Chip System, Bark (2)).

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION

7. Roseburg Studs Division is a wood products mill producing kiln dried and green lumber. The emission units at the facility are shown in the table below and described in more detail following the Iaible.

Emissions Unit EUID Pollution Control PCD Device/Practice ID

Cleaver Brooks, natural gas with #2 oil CBB-II Low NOx burner n/a backup

Kipper hog fuel boiler KB Multiclones none

Lumber drying kilns (6) LDK None n/a

Air system (Materials Handling) AS None n/a Sawdust target box (fugitives) Chip system target box (fugitives) Bark target boxes (2) (fugitives) Sawdust cyclone

Industrial paved roads (fugitives) PR Watering n/a

Unpaved roads (fugitives) UPR Watering n/a

Bark storage pile (fugitives) BSP None n/a

Chip storage pile (fugitives) CSP None n/a

Wood residuals WR None n/a

Truck loadout of chips, sawdust, shavings, TLD None n/a and bark (fugitives)

Gasoline dispensing facilities GDF Submerged fill n/a

Aggregate insignificant (PM, PM10, PM2.s AI u/a n/a and VOC)

The typical operating scenario is as follows (Emission Units are in Bold Type):

7.a. Raw logs are transported to the facility by either truck or rail. These logs are stored in decks or sent directly to the Debarker/Blocksaw (AS). Those logs stored in decks may be sent to a Mobile De barker & Chipper or sent to the Debarker/Blocksaw. Bark that falls off in the log yard is gathered into the Bark Storage Pile (BSP) and shipped off site. Bark from the Mobile Debarker & Chipper is handled in the same way. Chips from the Mobile De barker & Chipper are gathered into the Chip Storage Piles (CSP) and shipped off site.

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?.b. Logs sent to the Debarker/Blocksaw are cut into blocks. These blocks are transported to the Waste Wood Chipper, or the Sawmill. Bark removed in the Debarker/Blocksaw is pneumatically conveyed to the Bark Target Boxes (AS). The Bark Target Boxes (AS) discharge to either truck bins or the Hog Fuel Silo. Bark in the truck bins is shipped off site. Bark ft·om the Hog Fuel Silo is burned in the Kipper Boiler (KB). Sawdust produced in the Debarker/Blocksaw is pneumatically conveyed to the Sawdust Target Box (AS), which discharges to truck bins, and is shipped off site.

7.c. Blocks sent to the Sawmill are converted to rough lumber. The rough lumber is sent either to the Lumber Drying Kilns (LDK) and then to the Planer, or directly to the Planer. Chips produced in the Sawmill Waste Wood Chippers are pneumatically conveyed to the Chip System Target Box (AS), which discharges to either truck bins or the Chip Storage Piles (CSP). Chips are then shipped off site. Sawdust produced in the Sawmill is pneumatically conveyed to the Sawdust Target Box (AS), which discharges to truck bins, and is shipped off site.

?.d. Rough lumber sent to the Lumber Drying Kilns (LDK) is dried with air heated by steam produced by the Kipper Boiler (KB), and/or the Cleaver Brooks Natural Gas Boiler (CBB-II). In the planer, rough lumber (green or kiln dried) is planed to produce finished lumber. Shavings produced in the Planer are pneumatically conveyed to the Shavings Baghouse (AS), which discharges into truck bins. Shavings are then shipped off site.

7.e. The Air System (AS) includes fugitive particulate matter generated from log debarking, log sawing, and all associated material handling (target boxes, and cyclones). There are both Paved Roads (PR) and Unpaved Roads (UPR) on the site, which are sources for vehicle-generated particulate matter in the form of fugitive dust.

8. The following are the emission units and control devices at the facility:

8.a. Emission Unit CBB-11: Cleaver Brooks Boiler with Low NO, burner, normal firing on natural gas (with #2 oil backup), rated design capacity of27,600 lbs steamlhr (33,480,000 BTUs/hr), maximum operating steam temperature of 401 degrees F, installed 1998.

8.b. Emission Unit KB: Kipper Engineers Boiler; pin hole grate, mechanical stoker ID 6542-70, hogged fueled 35-65% moisture, rated design capacity 31,800 lb steamlhr, maximum operating steam pressure 260 psi relief, maximum operating steam temperature 411 degrees F, design airto-fuel ratio of?, design excess combustion air 68%, installed 1968. On 11/3/11, DEQ limited the steaming rate to 26,800 lbs steam/hour as a 3-hour average as a result of source tests showing compliance with the grain loading standard at that steaming rate.

8.b.i. PCD: Multiclone, Zern Industries MTSA-66-9CVT-A, 40,000 ACFM, 66-9" tubes, 36" length design pressure drop of2.57" of water, installed 2002.

8.c. Emission Unit LDK: Six Lumber Drying Kilns; steam heated pipes in walls of the kilns. The kilns are capable of dtying 193,000,000 board feet per year. The kilns operate at less than 200 degrees F drying Douglas fir, white fir, and hemlock. Four kilns (2 double track, 2 single track) were installed In 1970 with two additional kilns (2 double track) installed in 2006.

8.d. Emission unit AS: Air System; The air system and mechanical conveyors collect wood waste from saws, planer and chippers and convey the wood waste to the shaving baghouse, the sawdust cyclone, the sawdust target box, the chip system target box, and the bark target boxes.

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8.e. EU CSP: Chip storage piles; 2 piles, 65' x 20' x 100', 30,000 BOT/year

8.f. EU BSP: Bark storage pile; I pile, 6,100 BOT/year

8.g. EU PR: Paved roads; 250,000 VMT/yr, silt -loading factor of0.4 g/m2, mean vehicle weight 32.7 tons. Watering of paved roads occurs during the dry periods ofthe year.

8.h. EU UPR: Unpaved roads; 940 VMT/yr, silt content of 10%, mean vehicle weight of38.7 tons, covered with Dust Sealer (lignon sulfonate) and watered during the dry periods ofthe year..

8.i. EU GDF: This emission unit includes emissions from gasoline dispensing facilities at the plant which utilize a 1000 gallon gasoline storage tank.

8.j. EU WR: This emissions unit consists ofVOCs from wood residuals produced at the facility.

8.k. EU TLD: This emissions uuit consists of fugitive particulate emissions from the truck loadout of chips, sawdust, shavings, and bark at the facility.

8.1. AGGREGATE INSIGNIFICANT ACTIVITIES

The following activities which are present at the facility are insignificant in the aggregate:

8.l.i. PM/PM10/PM25 from log debarking, log sawing, and the shavings baghouse. 8 .l.ii. V OC from gasoline dispensing.

9. Categorically insignificant activities at this facility include the following:

• Evaporative and tail pipe emissions from on-site motor vehicle operation • Distillate oil, kerosene, gasoline, natural gas or propane burning equipment, provided the

aggregate expected actual emissions ofthe equipment identified as categorically insignificant do not exceed the de minimis level for any regulated pollutant, based on the expected maximum annual operation ofthe equipment. If a source's expected emissions from all such equipment exceed the de minimis levels, then the source may identif'y a subgroup of such equipment as categorically insignificant with the remainder not categorically insignificant. The following equipment may never be included as categorically insignificant: (A) Any individual distill oil, kerosene or gasoline burning equipment with a rating greater than 0.4 million Btu/hour; (B) Any individual natural gas or propane burning equipment with a rating greater than 2.0 million Btu/hour.

• Distillate oil, kerosene, gasoline, natural gas or propane burning equipment brought on site for six months or less for maintenance, construction or similar purposes, such as but not limited to generators, pumps, hot water pressure washers and space heaters, provided that any such equipment that performs the same function as the permanent equipment, must be operated within the source's existing PSEL

• Office activities • Janitorial activities • Personal care activities • Groundskeeping activities including, but not limited to building painting and road and parking lot

maintenance • Instrument calibration • Maintenance and repair shop • Automotive repair shops or storage garages • Air cooling or ventilating equipment not designed to remove air contaminants generated by or

released from associated equipment

• Temporary construction activities • Warehouse activities • Accidental fires • Air vents from air compressors • Air purification systems

• Demineralized water tanks

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• Pre-treatment of municipal water, including use of deionized water purification systems • Instrument air dryers and distribution • Fire suppression • Routine maintenance, repair, and replacement such as anticipated activities most often associated

with and performed during regnlarly scheduled equipment outages to maintain a plant and its equipment in good operating condition, including but not limited to steam cleaning, abrasive use, and woodworking

• Electric motors • Storage tanks, reservoirs, transfer and lubricating equipment used for ASTM grade distillate or

residual fuels, lubricants, and hydraulic fluids • On-site storage tanks not subject to any New Source Performance Standards (NSPS), including

underground storage tanks (UST), storing gasoline or diesel used exclusively for fueling ofthe facility's fleet of vehicles

• Natural gas, propane, and liquefied petroleum gas (LPG) storage tanks and transfer equipment • Pressurized tanks containing gaseous compounds • Storm water setting basins • Fire suppression and training • Non-contact steam vents and leaks and safety and relief valves for boiler steam distribution

systems • Non-contact steam condensate flash tanks • Non-contact steam vents on condensate receivers, deaerators and similar equipment • Boiler blowdown tanks • Ash piles maintained in a wetted condition and associated handling systems and activities

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING

Oregon Administrative Rules (OAR)

10. Facility-wide standards in Division 208 regarding fugitive emissions and nuisance conditions from odors or particle fallout apply to the facility. Monitoring for compliance with these standards will be done by the facility perfmming complaint investigations and maintenance of a complaint log. These facility-wide standards are only enforceable by the state. In addition, a quruterly visible emissions survey must be conducted at the plant boundaries and corrective actions taken if needed for visible emissions which leave the plant boundaries. Only one complaint has been received by the company or DEQ during the prior permit period.

II. Visible emissions (opacity) fi·om the hog fuel boiler at the facility must now meet the 40% opacity standard in OAR 340-208-0110(5). This standard will be reduced to 20% opacity on 1/1/20. Compliance with the standards will be monitored by quarterly visible emissions (VE) surveys using EPA Method 9.

12. Particulate emissions from the hog fuel boiler at the facility must now meet the 0.24 gr/dscf grain loading standard in OAR 340-228-0210(2)(a)(B)(i). This standard will be reduced to 0.15 gr/dscf on 1/1/20.

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Compliance with the standards will be monitored by recording residual oxygen levels, breach temperature, multiclones pressure drop, and an annual Inspection of the multiclones. In addition, a source test will be required during the permit term to measure PM emissions.

13. Particulate emissions from the natural gas boiler at the facility must meet the 0.14 gr/dscf standard for fuel burning equipment in OAR 340-228-0210(2)(b)(B). In lieu oftesting, quarterly VE surveys will be used as the surrogate monitoring method for compliance with the grain loading standard.

14. Visible emissions (opacity) fi·om all other non-fugitive emission sources at the facility must meet the 20% opacity standard in OAR 340-208-0110(3)(b or (4)). Compliance with the standard will be monitored by quarterly visible emissions surveys using EPA Method 22 (or EPA Method 9 ifVE are noted).

15. Particulate emissions from all other non-fugitive emission sources at the facility (except the sawdust cyclone) must meet the 0.14 gr/dscf grain loading standard in OAR 340-226-0210(2)(b )(B). The sawdust cyclone must now meet the 0.24 gr/dscf grain loading standard in OAR 340-226-0210 (2)(a)(B). This standard will be reduced to 0.15 gr/dscf on 111/20. In lieu of testing, the quarterly VE surveys will be used as the surrogate monitoring method for compliance with the grain loading standard. The equipment will also have quarterly inspections performed externally for structural integrity, corrosion, and air leaks and repairs made if necessary. No problems with control equipment have ever been noted in prior DEQ inspections.

16. The process weight standards in OAR 340-226-0310 and -80 I 0 apply to the sawdust cyclone in emissions unit AS. Since the process weight standard is usually less stringent than the grain loading limits, monitoring by VE tests and inspection and maintenance ofthe cyclone will be used as the smTogate monitoring method for compliance.

17. The source has gasoline dispensing facilities onsite utilizing a 1000 gallon tank. Emissions fi·om gasoline dispensing have not been previously calculated but will be for this permit as part of the PSEL and baseline. GDF rules in OAR 340 Division 244 will be added to the permit In this renewal.

18. Plant Site Emission Limits (PSELs) are required for the facility by OAR 340 Division 222. Projected maximum emissions have been calculated using anticipated production values and emission factors updated to the most current standards. Monitoring for compliance with the PSELs will be done by calculating monthly and rolling annual emissions using production data and emission factors. The calculations are performed on a monthly basis because this is the shortest reasonable time period that is compatible with source operations and will give reliable data for all operations.

19. The facility is required to submit reports semi-annually to DEQ. The first semi-annual report will include only the semi-annual compliance certification. The annual report will include the second semiannual compliance certification as well as the excess emission upset log, the emission fee report, and the calendar year and rolling 12-month actual emission calculations.

20. The facility is required by OAR 340-214-0300 through -0360 to report excess emissions immediately. For this source inunediately will be no later than by 9:00 am the following business day. A written report is due within 15 days.

Federal Requirements

21. Federal rules applicability detmminations for the facility are described below:

2l.a. The accidental release provisions of 40 CFR Part 68 do not apply to the facility as it does not store, use, or have quantities in excess of any of the specified chemicals subject to this regulation.

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2l.b. 40 CFR Part 60, Subpart De, New Source Performance Standards, apply to the natural gas boiler (CBB-11) at tbe facility and requires that the type and amount of fuel burned in the boiler be recorded monthly. No other emissions units at the facility are currently subject to any specific federal NSPS.

2l.c. The hog fuel boiler KB is the only emissions unit at the facility subject to the Compliance Assurance Monitoring (CAM) requirements of 40 CFRPart 64 because the emission unit meets the applicability requirements. The CAM applicability analysis table for the facility is included in the detail sheets attached to this report. CAM for KB consists of a residual oxygen action level (<3.5%), a breach temperature action level (>750 degrees F), daily multiclones pressure drop measurements, and an annual inspection of the multiclones.

2l.d. The facility is not subject to any major source National Emission Standards for Hazardous Air Pollutants (NESHAP) standards as the facility is not a major source ofHAPs.

The NG boiler (CBB-II) is not subject to the Area Source Boiler GACT rules in 40 CFRPart 63, Subpart JJJJJJ since it is only NG frred. Should the boiler frre diesel fuel oil in the future, it would become subject to the Area Source Boiler GACT rules in 40 CFR Part 63, Subpart JJJJJJ.

The hog fuel boiler KB is subject to the Area Source Boiler GACT rules in 40 CFR Part 63, Subpart JJJJJJ. The Boiler GACT initial notification was submitted on 9/13/11. Boiler tune ups were completed in February 2014 and February 2016. The one-time energy assessment was completed in January 2014. Part 2 of the permit contains the detailed Subpart JJJJJJ requirements which include a biennial tune-up of the boiler.

The source has gasoline dispensing facilities onsite which are subject to 40 CFR Part 63 Subpart CCCCCC which is incorporated into DEQ rules in Division 244.

22. Insignificant activities

As identified earlier in this Review Report, this facility has insignificant emissions units (IEUs) that include categorically insignificant activities and aggregate insignificant emissions, as defmed in OAR 340-200-0020. For the most part, the standards that apply to IEUs are for opacity (20% limit) and particulate matter (grain loading). DEQ does not consider it likely that IEUs could exceed an applicable emissions limit or standard because IE Us are generally equipment or activities that do not have any emission controls (e.g., small natural gas fired space heaters) and do not typically have visible emissions. Since there are no controls, no visible emissions, and the emissions are less than one ton per year, DEQ does not believe monitoring, recordkeeping, or reporting is necessary for assuring compliance with the standards

PLANT SITE EMISSION LIMITS

23. Provided below is a summary of the baseline emission rates, netting basis, and the plant site emission limits.

Baseline Plant Site Emission Limit (PSEL) Emission Netting Basis Previous Proposed PSEL

Rate Previous Proposed PSEL PSEL Increase Pollutant (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr) (tons/yr)

PM 316 316 280 271 255 -16 PMw 128 128 100 108 85 -23 PM2.s --- 41 41 --- 48 ---co 285 285 285 346 344 -2 NO, 30 30 30 41 48 +7 so2 I I 1 39 39 ---

voc 40 40 40 GHG (CO,e) 31,500 --- 31,500 Single HAP --- --- ---Combined --- --- ---

HAPs

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47 79 +32 --- 42,000 ---

9 9 ---24 24 ---

23 .a. In accordance with OAR 340-222-0048 the 1978 baseline production rates were "frozen" in a previous permitting action. The baseline emission rate has been recalculated in this permitting action due to some new emission units not previously accounted for in baseline and new emission factors.

23.b. The previous netting basis is equal to tbe revised baseline emission rates except for PM and PMw .. The initial netting basis for PM,.s was established for the first time in this permitting action based on tbe PM10 netting basis as of 5/1/11. The baseline and netting basis are being established for GHGs for the first time in this permitting action. The baseline and netting basis for GHGs is derived from 2007 actual emissions as requested by the company.

23 .c. The netting basis has also been recalculated and is either equal to tbe baseline emission rate or the proposed PSEL plus the SER. The facility has not had any Prevention of Significant Deterioration approvals under OAR 340-224-0070 and no rule reductions have been required since baseline.

23.d. The proposed PSELs for PM, PMw, PM2.s, CO, NOx, VOC, and GHG have been set at the facility's potential to emit in accordance with OAR 340-222-0041(2).

23.e. The proposed PSEL for SO, has been set at the DEQ's Generic PSEL level in accordance with OAR 340-222-0041 (I) since the projected emission level is less than the Generic PSEL level but greater than the de minimis level.

23.f The PSEL is a fuderally enforceable limit on the potential to emit PSELs for HAPs are being established to insure that the source remains a minor source of HAPs.

SIGNIFICANT EMISSION RATE

24. The proposed PSELs are less !ban the significant emission rate (SER) over the prior netting basis for all pollutants as shown below and no further air quality analysis is required.

Increase due to Increase due to Prior Requested increased physical or Increase due to

Netting Requested increase over utilization of operational use of Generic Pollutant SER Basis PSEL netting basis existing equipment changes PSEL

PM 25 315.8 254.9 -60.9 +82.0 -142.9 PMw 15 127.5 85.4 -42.1 +21.8 -63.9 PM,.s 10 40.56 48.13 +7.57 +12.69 -5.12 co 100 285.0 344.1 +59.1 +52.8 +6.3

NOx 40 29.5 47.6 +18.1 +14.3 +3.8 so, 40 1.3 39.0 +37.7 +0.3 +0.1 +37.3 voc 40 39.7 79.0 +39.3 +18.7 +20.6 GHG 75,000 31,537 41,979 +10,442 +10,442

HAZARDOUS AIR POLLUTANTS

25. The facility is not and has not been a major source for HAPs. Esthnated annual emissions of HAPs for the proposed operating period are as follows:

Pollutant Acetaldehyde Formaldehyde HCl Methanol Propionaldehyde Acrolein Hexane Other organic HAPs All metal HAPs

TOTAL

Tons/year 5.72 0.35 0.68 7.49 0.12 0.14 0.14 0.67 0.07

15.38

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HAP emissions are dependent primarily on the species of wood dried in the kilns. If 100% white fir were dried at capacity, the facility emissions of methanol would be 11.77 tons/year. To insure that the facility remains a minor source of HAPs, the company has requested that HAP PSELs be established below the major source thresholds at 9 TIY for an Individual HAP and 24 T/Y for total HAPs. Compliance with the HAP PSELs will be determined by multiplying species specific HAP emission factors for each species dried by the production rate of that species. Since the normal mix of wood dried is only 42% white fir, it is unlikely that the major source thresholds (10/25 T/Y) will ever be approached.

GENERAL BACKGROUND INFORMATION

26. A Land Use Compatibility Statement was signed by Douglas County on 11/29/94.

27. Other permits issued or required by DEQ for this facility include a General Stormwater Permit.

COMPLIANCE HISTORY

28. The facility was inspected on 7/23/15, 9/25113, 9/6/11, 9/27/09, and 9/26/07 and found to be in compliance with all existing permit conditions at the time of the inspections.

29. One complaint was received on 8/23/08 concerning high opacity from the boiler. An inspection of the boiler was done and adjustments made to the fuel diverter plates and grates and the high opacity was corrected.

30. A formal enforcement actions was taken against the source on 2/2/11 for exceedance of the grain loading standard from the hog fuel boiler and a civil penalty of $3200 was assessed. A warning letter was issued on 10/3/07 for exceeding the allowed steaming rate of the boiler, another warning letter on 017/09 for late submittal ofthe Emissions Fee Report, and a third warning letter was issued on 9/9/15 for a late semiannual compliance repmt. These violations have been resolved.

SOURCE TEST RESULTS

31. Source tests have been conducted at the facility in the past on the hog fuel boiler. DEQ is requiring emissions factor verification testing requirements on the hog fuel boiler again for PM, CO, and NOx in this permitting action.

PUBLIC NOTICE

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32. This penni! was put on public notice from June 27, 2017, to August I, 2017. No public comments were received. After the comment period and hearing, if requested, DEQ will review the comments and modify the permit as may be appropriate. A proposed permit was sent to EPA for an expedited review of 5 days on August 2, 2017. EPA did not comment on the proposed permit.

If EPA does not object in writing, any person may petition the EPA within 60 days after the expiration of EPA's 45-day review period to make such objection. Any such petition must be based only on objections to the permit that were raised with reasonable specificity during the public comment period provided for in OAR 340-218-0210, unless the petitioner demonstrates it was impracticable to raise such objections within such period, or unless the grounds for such objection arose after such period.

ATTACHMENTS

Emission Detail Sheets Baseline Emissions PM2.s Initial Netting Basis Proposed Emissions Aggregate Insignificant Activities Emissions HAP Emissions Source Test Results Equipment Installation Dates CAM Analysis

Emission Unit/Point

Hogged fuel boiler

log sawing

log debarking

Shavings cyclone

Sawdust cyclone

Chip target box

Bark target boxes

Paved roads

Unpaved roads

Chip storage pile

Bark storage pile

Lumber drying kiln

Truck loadout

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Swanson, Roseburg

Baseline Emissions

PM (1978)

Operating Emission Factor

Parameter Rate Reference

190,000,000 lb steam 0.5 lb/M lb steam Source Tests

177,870 tons logs 0.00175 lb/ton 1993 Draft AP-42 10.3.1 adjusted

442,938 ton logs 0.00024 lb/ton 1993 Draft AP-42 10.3.1 adjusted

5024 BDT 0.5lb/BDT AQ-EF-02

14,361 BDT 0.5 lb/BDT AQ-EF02

83,839 BDT 0.11b/BDT AQ-EF02

26,958 BDT 0.11b/BDT AQ-EF02

125,687VMT 1.0 lb/VMT AP-42

62,727VMT 4.69lb/VMT AP-42

87,044 BDT 1.0 lb/BDT EPA FIRE factor

4555 BDT 1.0 lb/BDT EPA FIRE factor

63,830,100 bd ft 0.02 lb/M bd ft DEQEst.

5024 BDT shavings 0.02lb/BDT AP-42 10.4.2

14,361 BDT sawdust adjusted

87,044 BDT chips

26,958 BDT bark

Total

Emissions

(tons/year}

47.5

0.2

0.1

1.3

3.6

4.2

1.3

62.8

147.1

43.5

2.3

0.6

1.3

315.8

Emission Unit/Point

Hogged fuel boiler

Log sawing

Log debarking

Shavings cyclone

Sawdust cyclone

Chip target box

Bark target boxes

Paved roads

Unpaved roads

Chip storage pile

Bark storage pile

Lumber drying kiln

Truck load out


Page 15 of29

PM10 (1978)

Operating Emission Factor Emissions

Parameter Rate Reference (tons/year)

190,000,000 lb steam 0.25lb/M lb AQ-EF03 23.8 steam

177,870 tons logs 0.00088 lb/ton 1993 Draft AP-42 0.1 10.3.1 adjusted

442,938 ton logs 0.00012 lb/ton 1993 Draft AP-42 Neg I. 10.3.1 adjusted

5024 BDT 0.425 lb/BDT AQ-EF03 1.1

14,361 BDT 0.425 lb/BDT AQ-EF03 3.1

83,839 BDT 0.051b/BDT DEQ Est. 2.1

26,958 BDT 0.05lb/BDT DEQ Est. 0.7

125,687 VMT 0.21b/VMT AP-42 12.6

62,727 VMT 2.111b/VMT AP-42 66.2

87,044 BDT 0.361b/BDT EPA FIRE factor 15.7

4555 BDT 0.36lb/BDT EPA FIRE factor 0.8

63,830,100 bd ft 0.02 lb/M bd ft DEQ Est. 0.6

5024 BDT shavings 0.011b/BDT AP-42 10.4.2 0.7

14,361 BDT sawdust adjusted

87,044 BDT chips

26,958 BDT bark

Total 127.5

Emission Unit/Point

Hogged fuel boiler

Emission Unit/Point

Hogged fuel boiler

Emission Unit/Point

Hogged fuel boiler


Page 16 of29

NOx (1978)

Operating Parameter Emission Factor Emissions

Rate Reference (tons/year)

190,000,000 lb steam 0.311b/M lb Source Tests 29.5 steam

502 (1978)



190,000,000 lb steam 0.014 lb/M lb AQ-EF02 1.3 steam

co (1978)



190,000,000 ·lb steam 3.0 lb/M lb Source Tests 285.0 steam

Emission Unit/Point

Hogged fuel boiler

Lumber drying kiln

Steam tunnels

Wood Residuals

GDF

Emission Unit/Point

Hogged fuel boiler

Review Report/Permit No.: 10-0030-TV-0 I Application No.: 27325

Page 17 of29

voc (1978}



190,000,000 lb steam 0.131b/M lb AQ-EF02 12.4 steam

44,681,070 bd ft WF 0.5875lb/M DEQ/EPA 13.1

bd ft data 2013

15,957,525 bd ft DF 0.7679lb/M 6.1

bd ft 3,191,505 bd ft Cedar 0.3062lb/M 0.5

bd ft

117,804,400 bd ft 0.06 lb/M bd ft Mod. AP- 3.5

42

5024 BOT shavings 0.15lb/BDT NCASI TB 0.4 14,361 BOT sawdust 0.165 lb/BDT 723 1.2

87,044 BOT chips 0.05lb/BDT 2.2 26,958 BOT bark 0.024 lb/BDT 0.3

3000 10.5 lb/M gal DEQ Negl.

General Permit

Total 39.7

Greenhouse Gas Baseline (2007)



17,075 BOT HF 3693.9 40 CFR Part 31,537 lb/BOT HF 98

PM2.s Netting Basis


Page 18 of29

(5/1/11 initial netting basis based on PM2.s fraction of PM10 netting basis)

Emission Unit/Point PM1o Netting Emission Factor PMz.s

Basis PMz.s% of Reference Emissions

(tons/year) PM10 (tons/year)

Hogged fuel boiler 23.8 100 AQ-EF03 23.80

Log sawing 0.1 50 AQ-EF08 0.05

Log debarking 0.02 50 AQ-EF08 O.Dl

Shavings cyclone 1.1 50 AQ-EF08 0.55

Sawdust cyclone 3.1 50 AQ-EF08 1.55

Chip target box 2.1 50 AQ-EF08 1.05

Bark target boxes 0.7 50 AQ-EF08 0.35

Paved roads 12.6 25 AQ-EF08 3.15

Unpaved roads 66.2 10 AQ-EF08 6.62

Chip storage pile 15.7 15 AQ-EF08 2.36

Bark storage pile 0.8 15 AQ-EF08 0.12

Lumber drying kiln 0.6 100 DEQ Est. 0.60

Truck loadout 0.7 50 AQ-EF08 0.35

Total 40.56

Emission Unit/Point

Hogged fuel boiler

Cleaver Brooks boiler

Sawdust cyclone

Sawdust target box

Chip target box

Bark target boxes (2)

Paved roads

Unpaved roads

Chip storage pile

Bark storage pile

Lumber drying kilns

Truck load out

AI


Page 19 of29

Swanson, Roseburg Projected Emissions

PM



223,000,000 lb steam 0.606 lb/M lb 2002,2010, 67.6 steam 2011 STs

150,000,000 ft3 NG 2.5 lb/MM ft3 AQ-EF05 0.2 NG

5600 BDT O.Sib/BDT AQ-EF02 1.4

36,400 BDT 0.11b/BDT AQ-EF02 1.8

83,839 BDT 0.11b/BDT AQ-EF02 4.2

26,958 BDT 0.11b/BDT AQ-EF02 1.3

250,000VMT 1.0 lb/VMT AP-42 125.0

940VMT 4.691b/VMT AP-42 2.2

87,044 BDT 1.0 lb/BDT EPA FIRE factor 43.5

6100 BDT 1.0 lb/BDT EPA FIRE factor 3.1


19,500 BDT shavings 0.02lb/BDT AP-42 10.4.2 1.7 36,400 BDT sawdust adjusted

87,044 BDT chips 26,958 BDT bark

1.0

Total 254.9

Emission Unit/Point

Hogged fuel boiler


Sawdust cyclone

Sawdust target box

Chip target box


Paved roads

Unpaved roads

Chip storage pile

Bark storage pile

Lumber drying kilns

Truck loadout

AI

Review Report/Permit No.: 10-0030-TV -0 I Application No.: 27325

Page20 of29

PM10



223,000,000 lb steam 0.303 lb/M lb AQ-EF03 33.8 steam

150,000,000 ft3 NG 2.5 lb/MM ft3 NG AQ-EF05 0.2

5600 BDT 0.425 lb/BDT AQ-EF03 1.2

36,400 BDT 0.051b/BDT DEQ Est. 0.9

83,839 BDT 0.051b/BDT DEQ Est. 2.1

26,958 BDT 0.05lb/BDT DEQ Est. 0.7

250,000VMT 0.21b/VMT AP-42 25.0

940VMT 2.111b/VMT AP-42 1.0

87,044 BDT 0.361b/BDT EPA FIRE 15.7 factor

6100 BDT 0.36lb/BDT EPA FIRE 1.1 factor


19,500 BDT shavings 0.01lb/BDT AP-42 10.4.2 0.8 36,400 BDT sawdust adjusted

87,044 BDT chips 26,958 BDT bark

1.0

Total 85.4

Emission Unit/Point PM1o Emission

Rate

(tons/year)

Hogged fuel boiler 33.8

Cleaver Brooks boiler 0.2

Sawdust cyclone 1.2

Sawdust target box 0.9

Chip target box 2.1

Bark target boxes 0.7

Paved roads 25.0

Unpaved roads 1.0

Chip storage pile 15.7

Bark storage pile 1.1

Lumber drying kilns 1.9

Truck loadout 0.8

AI 1.0


Page 21 of29

Emission Factor PM2.s

PMz.s% of Reference Emissions

PM10 (tons/year)

100 AQ-EF03 33.80

100 AQ-EF08 0.20

50 AQ-EF08 0.60

50 DEQ Est. 0.45

50 DEQ Est. 1.05

50 DEQ Est. 0.35

25 AQ-EF08 6.25

10 AQ-EF08 0.10

15 AQ-EF08 2.36

15 AQ-EF08 0.17

100 DEQ Est. 1.90

50 AQ-EF08 0.40

50 DEQ Est. 0.50

Total 48.13

co

Emission Unit/Point Operating Parameter

Hogged fuel boiler 223,000,000 lb steam

Cleaver Brooks boiler 150,000,000 ft3 NG

NOx







Review Report/Petmit No.: 10-0030-TV -01 Application No.: 27325

Page22 of29

Emission Factor Emissions


3.03 lb/M lb 2002-2010 STs 337.8 steam

841b/MM ft3 AQ-EFOS 6.3 NG

Total 344.1



0.393 lb/M lb 2002-2010 STs 43.8 steam

50 lb/MM ft3 AQ-EFOS 3.8 NG

Total 47.6



0.014 lb/M lb AQ-EF02 1.6 steam

1.7 lb/MM ft3 AQ-EFOS 0.1 NG

Total 1.7

Emission Unit/Point

Hogged fuel boiler


Lumber drying kiln

Wood Residuals

AI

Emission Unit/Point

Hogged fuel boiler


voc

Operating Parameter

223,000,000 lb steam

150,000,000 ft3 NG

94,570,000 bd ft DF

81,060,000 bd ft WF

17,370,000 bd ft Hemlock

19,500 BOT shavings

36,400 BOT sawdust

87,044 BOT chips

26,958 BOT bark

Review Report/Permit No.: 10-0030-TV -01 Application No.: 27325

Page 23 of29



0.065 lb/M lb 2002 STs 7.2 steam

5.5 lb/MM ft3 AQ-EF05 0.4 NG

0.76791b/M DEQ/EPA 36.3

bd ft data 2013

0.58751b/M 23.8

bd ft 0.3803lb/M 3.3

bd ft

0.151b/BDT NCASI TB 1.5

0.165 lb/BOT 723 3.0

0.05lb/BDT 2.2

0.024 lb/BDT 0.3

1.0

Total 79.0

Greenhouse Gases



17,850 BOT HF 3693.9 lb/BOT HF 40 CFR Part 32,968 98

150,000,000 ft3 NG 120,141lb/MM ft3 NG 40 CFR Part 9011 98

Total 41,979

Emission

Unit/Point

PM Log sawing

Log debarking

Shavings baghouse

voc Gasoline

dispensing

FWVOC


Page 24 of29

Swanson, Roseburg Aggregate Insignificant Activities

Operating Emission Factor Emissions Parameter Rate Reference (tons/year)

580,000 tons logs 0.00175 lb/ton 1993 Draft AP-42 0.5 10.3.1 adjusted

580,000 ton logs 0.00024 lb/ton 1993 Draft AP-42 0.1 10.3.1 adjusted

19,500 BOT 0.0011b/BDT AQ-EF02 0.01

Total 0.61

5000 gallons 10.5 lb/M gal DEQGeneral 0.03 Permit

Co. Est. Negl.

Unit

Hog Fuel Boiler 312,018 MM Btu/yr

17,850 BDT HF

ueaver mooKS 150.0MM ft3

Boiler NG

Lumber Drying 94,570 M bd ft Kilns DF

<200 degrees F

Lumbe\ Drying Ktns

81,06~bd ft

<200 degrees F

Lumber Drying 17,370 M bd ft Kilns Hemlock

<200 degrees F

GDF 5000 gallons

l'WVUL

Review Report/Penni! No.: I 0-0030-TV -0 I Application No.: 27325

Page25 of29

Swanson, Roseburg

HAP Emissions

HAP Factor Rate

"J 0.000283 lb/MM NCASITB 0.044 Btu 1013

Formaldehyde 0.00102lb/MM 0.159 Btu

Methanol B~b/MM 0.114

' B~b/MM 0.039

0.000260 lb/MM 0.041 Btu

Hydrogen 0.00436 lb/MM 0.680 chloride Btu

Oth~;1~~anic 0,004 · J lb/MM 0.644 Btu

All metal HAPs B~b/MM 0.068

0.002llb/MMft3 AP-42 Table 0.0002 O.Q75 lb/MM ft3 1.4-3 0.006

Hexane 1.8 lb/MM ft' 0.135

Oth~~anic ~lb/MM 0.0009

All metal HAPs 0.0060~31b/MM ,~;4;n~a~~:4 0.0005

0.0510 lb/M bd ft nFO/FP A data 2.41 0.0389lb/M bd ft 2013 1.84 0.0013 lb/M bd ft 0.06 0.0005 lb/M bd ft 0.02 0.0007 lb/M bd ft 0.03

0.055 lb/M bd ft ~zo13

2.23

0.122 lb/M bd ft 4.94 Formalrlehvrle 0.0028 lb/M bd ft 0.11

0.0012lb/M bd ft 0.05 0.0015lb/M bd ft 0.06

0.1200 lb/M bd ft DEQ/EPA data 1.04 0.0809 lb/M bd ft 2013 0.70 0.0013 lb/M bd ft 0.01 0.0012 lb/M bd ft 0.01 0.0015lb/Mbdft O.Ql

Benzene I 0.5 lb/M gal DEQ General 0.026 Permit

Neg!.

Summary HAP

Methanol Formaldehyde Acetaldehyde

Propionaldehyde Acrolein Hexane

HCI Other organics

Metals

Total


Page26 of29

DEQ Estimate based on 20 16

usages

Emission (tons/year)

7.491 0.345 5.724 0.119 0.141 0.135 0.680 0.671 0.069

15.375

Date Run

9/26/02 1 2 3 4

11/19/02 1 2 3

6/9/10 1 2 3 4

10/1/10 1 2 3

10/6/11 1 2 3

Avg.

Review Report/Penni! No.: 10-0030-TV-01 Application No.: 27325

Page 27 of29

Swanson, Roseburg

Hog Fuel Boiler Source Tests

PM co Steam

gr/dscf lb/M lb ppm lb/M lb Produced

steam steam (lb/hr) ' 1.5 0.42 1970 4.81 32,000

0.39 1.3 2040 4.78 32,000 0.4Q 1.4 --- --- 31,500 --- --- 2050 4.95 31,500

0.15 0.50 1051 2.73 28,155 0.14 0.49 1046 2.85 27,415 0.11 0.40 868 2.51 25,430

0.586 :2.04 1248 2.54 31,062 0.318 1.09 986 1.94 31,083 0.260 0.87 684 1.44 30,329 0.365 1.27 784 1.78 28,793

0.19 0.91 18,700 0.17 0.75 19,600 0.16 0.62 19,900

0.137 0.46 27,400 0.156 0.54 26,100 0.212 0.78 26,800

0.158 0.606 3.03

Shaded source test results exceeded the allowable grain loading standard and were not used in calculating the average emission rate for PM.

Emission Unit

KB

CBB-11

AS

CSP

BSP

PV

UPR

Sawmill/Planer

LDK


Page 28 of29

Swanson, Roseburg Equipment Installation Dates

Equipment

Control Equipment Hog fuel boiler

Multiclone

Cleaver Brooks NG Boiler

Sawdust cyclone

Sawdust target box

Chip target box


Chip storage pile

Bark storage pile

Paved roads

Unpaved roads

Sawmill

Planer

Shavings baghouse

Lumber drying kilns #1-4

#2a

#2b

Installation Year

1968 2002

1998

1965

1965

1965

1965

1970

2006

2006

1970

2002

2002

Review Repmt/Permit No.: 10-0030-TV-0 I Application No.: 27325

Page 29 of29

Swanson, Roseburg

CAM Applicability Analysis 2017*

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