ADEQ OPERATING AIR PERMIT · PERMIT NUMBER: 1714-AOP-R3 FACILITY ADDRESS: 757 Del-Tin Highway El...

ADEQ OPERATING AIR PERMIT Pursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation #26: Permit #: 1714-AOP-R3

Renewal #1 IS ISSUED TO: Del-Tin Fiber, L.L.C 757 Del-Tin Highway

El Dorado, AR 71730 Union County

AFIN: 70-00480 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: and AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Keith A. Michaels Date

Amended

SECTION I: FACILITY INFORMATION

PERMITTEE: Del-Tin Fiber, L.L.C AFIN: 70-00480 PERMIT NUMBER: 1714-AOP-R3

FACILITY ADDRESS: 757 Del-Tin Highway

El Dorado, AR 71730

COUNTY: Union

CONTACT POSITION: Gary Griffis, General Manager TELEPHONE NUMBER: (870) 309-3100

REVIEWING ENGINEER: Shawn Hutchings

UTM North-South (X): 3670.692 UTM East-West (Y): 524.261

Zone 15

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Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480

SECTION II: INTRODUCTION

Del-Tin Fiber, L.L.C., a limited liability company, is a joint venture between Deltic Farm and Timber Co., Inc. and Temple-Inland Forest Products Corporation. Del-Tin Fiber, L.L.C. (Del-Tin), located on 395 acres southwest of El Dorado, Arkansas, is operating a manufacturing facility for medium density fiberboard (MDF)(SIC Code 2493). The finished product is used as a lumber substitute in the furniture, flooring, and molding industries. The plant=s construction began in 1996 with the first product being manufactured April 29,1998.

Summary of Permit Activity

This permit is the first Title V renewal permit for the facility. As part of the renewal Del-Tin requested an increase in the raw material handling limit of SN-20 and an increase in the VOC limits for SN-05. The application states that modifications to the press enclosure caused more VOC to be captured than previously anticipated. The requested increase in VOC emissions required review under Prevention of Significant Deterioration regulations. Del Tin also submitted an application for a minor modification to their permit. This modification added the baghouse SN-17A. This source will handle the same material as SN-17 but will allow the collected material to be transferred elsewhere in the plant. Summary of PSD issues in 1714-AOP-R3 The modification to the press enclosure caused more VOC to be captured than previously anticipated which caused higher than anticipated emissions from SN-05. The requested increase in the application was more than 40 tons per year and the modification was required to undergo PSD review. The BACT level of control for the press emissions was determined to be 95%. This is the same level of control as the previous PSD permit for the source. The previous permit only required outlet testing to verify compliance. This permit will require testing to verify the control efficiency as well as outlet emission rate. There was no modeling performed because the only pollutant undergoing PSD review is VOC.

Regulations This facility is subject to the following regulations: Regulation 18, Arkansas Air Pollution Control Code; Regulation 19, Regulations of the Arkansas Plan of Implementation for Air Pollution Control; Regulation 26, Regulations of the Arkansas Operating Air Permit Program; 40 CFR 52.21, Prevention of Significant Deterioration, and 40 CFR Part 60, Subpart Db, Standards of Performance for Industrial, Commercial, Institutional Steam Generating Units.

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Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480 The following table is a summary of emissions from the facility. Specific conditions and emissions for each source can be found starting on the page cross referenced in the table. This table, in itself, is not an enforceable condition of the permit.

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EMISSION SUMMARY

Emission Rates

Source

No.

Description

Pollutant

lb/hr

tpy

Cross

Reference Page

Total Allowable Emissions

PM

PM10 SO2

VOC CO NOx

50.4 50.4 8.0 34.2

228.3 87.2

137.6 137.6 35.1

149.6 1000 382

HAPs*

Formaldehyde

12.2

52.3

Air Contaminants **

Ammonia

88.2

386.1

01

Chip Silo Bin Vent

PM

PM10

0.1 0.1

0.1 0.1

15

02

Green Saw Dust Bin

Vent

PM

PM10

0.1 0.1

0.1 0.1

15

03

Core/Face Refiner Abort Cyclone Vents (Start-up)

PM

PM10

18.8 18.8

3.8 3.8

17

04

Mat Trim Pneumatic

System Baghouse

PM

PM10

0.2 0.2

0.7 0.7

19

05 and 05A

Heat Energy System

Stack (Callidus) and

Closed Loop Gasification System Heat

Vent Stack

PM

PM10 SO2

VOC CO NOx

Formaldehyde Ammonia

28.2 28.2 8.0 21.2

228.3 87.2 11.6 88.2

123.5 123.5 35.1 92.9

1000.0 382.0 50.8

386.1

21

06A

Former Infeed Area

System Vent A (Core)

PM

PM10

0.2 0.2

0.9 0.9

26

06B

Former Infeed Area

System Vent B (Face)

PM

PM10

0.2 0.2

0.9 0.9

26


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EMISSION SUMMARY

Emission Rates

Source

No.

Description

Pollutant

lb/hr

tpy

Cross

Reference Page

07 Scalper System Vent PM PM10

0.2 0.2

0.5 0.5

28

08

Mat Reject System Vent

PM

PM10

0.2 0.2

0.1 0.1

30

09A

Board Cooler Vent A

PM

PM10 VOC

Formaldehyde

0.2 0.2 3.4 0.2

0.8 0.8 14.8 0.5

31

09B

Board Cooler Vent B

PM

PM10 VOC

Formaldehyde

0.2 0.2 3.4 0.2

0.8 0.8 14.8 0.5

31

09C

Board Cooler Vent C

PM

PM10 VOC

Formaldehyde

0.2 0.2 3.4 0.2

0.8 0.8 14.8 0.5

31

10

Saw System #1 Baghouse Vent

PM

PM10

0.2 0.2

0.9 0.9

33

11


PM

PM10

0.2 0.2

0.9 0.9

33

12

Sander System #1

Baghouse Vent

PM

PM10

0.2 0.2

0.9 0.9

35

13

Sander System #2

Baghouse Vent

PM

PM10

0.2 0.2

0.9 0.9

35

14

Sander Dust Silo Bin

Vent

PM

PM10

0.1 0.1

0.1 0.1

37

15

Rough Trim/Sawdust

Silo Bin Vent

PM

PM10

0.1 0.1

0.1 0.1

37

16

Sawdust High Pressure

Filter

PM

PM10

0.1 0.1

0.1 0.1

41

17

Fuel Mixing Bin

Transfer System Vent

PM

PM10

0.1 0.1

0.1 0.1

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EMISSION SUMMARY

Emission Rates

Source

No.

Description

Pollutant

lb/hr

tpy

Cross

Reference Page

17A Dry Trim Baghouse PM PM10

0.1 0.1

0.1 0.1

39

18

Sander Dust High

Pressure Filter

PM

PM10

0.1 0.1

0.2 0.2

41

19

Former Area Transfer

System Vent

PM

PM10

0.1 0.1

0.1 0.1

43

20

Raw Material Handling

PM

PM10 VOC

0.1 0.1 2.8

0.2 0.2 12.3

44

* HAPs included in the VOC totals are indicated by an *. Other HAPs are not included in any other totals unless specifically stated.

** Air Contaminants such as ammonia, acetone, and certain halogenated solvents are not classified as VOC or HAPs.

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SECTION III: PERMIT HISTORY Permit 1714-AOP-R0, issued July 3, 1997, was the first permit issued to Del-Tin Fiber, L.L.C. Del-Tin was a newly formed company which began construction of their facility in 1996 and manufactured their first product on April 29, 1998. Permit 1714-AOP-R1 was issued on March 12, 1999. Del-Tin requested this modification to cover four previously unlisted sources and adjustments in emissions from seven other sources. 1714-AOP-R2 was issued on May 9, 2001. Del-Tin had replaced the baghouse on the Callidus unit, SN-05, with an ESP because clogging bags were causing back pressure in the Callidus unit. Del-Tin discovered after testing the CEMs on the new ESP that NOx emissions from the Callidus unit, SN-05, where higher than predicted. The potential to emit of the facility was discovered to be greater than the 250 tpy of NOx. Therefore, Del-Tin had to submit a PSD application for the facility. Permit 1714-AOP-R2 incorporated all PSD issues into the facility=s air permit. Summary of PSD issues in 1714-AOP-R2

Ambient Air Impact Analysis An applicant for a Prevention of Significant Deterioration (PSD) permit is required to conduct an air quality analysis of the ambient impacts associated with the construction and operation of the proposed new source or modification. The primary purpose of the air quality analysis is to demonstrate that new emissions emitted from a major stationary source, in conjunction with other applicable emissions from existing sources (including secondary emissions from growth associated with the new project), will not cause or contribute to a violation of any applicable National Ambient Air Quality Standard (NAAQS) or PSD increment. The US EPA requires that PSD modeling be performed in two stages: the significance analysis and the full impact analysis. The significance analysis considers the net emissions change associated with PSD affected emissions units to determine if the increased emissions will have a significant impact upon the surrounding area. If the results of the significance analysis are below the corresponding Modeling Significance Levels the full impact analysis is not required. Refined modeling was performed on the PM10 emissions from the facility and surrounding existing sources to determine if the facility will not cause or contribute to a violation of any applicable National Ambient Air Quality Standard (NAAQS) or PSD increment. The results of

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Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480 the model show no violation of the NAAQS occurred at any location for either the annual or 24 hour NAAQS standard. A summary of the NAAQS modeling results are in the table below.

Averaging

Time Period

Highest Modeled

Concentration with

Background

NAAQS Standard

Percent of NAAQS

Standard

24 Hour

121.2 µg/m3

150 µg/m3

80.8%

Annual

36.2 µg/m3

50 µg/m3

72.4%

Modeling was also performed to determine if there was a violation of the PSD increment for both the 24 hour and annual averaging periods. The highest model concentration on the annual averaging period was 11.4 µg/m3 with a increment standard of 17 µg/m3. Del-Tin=s contribution was modeled at 0.28 µg/m3 , 1.6% of the increment. The model for the 24 hour averaging period showed concentrations above the PSD increment standard. All the receptors which showed concentrations higher than the increment were within the property boundary of Great Lakes Chemical Company. The Highest modeled concentration was 66.9 µg/m3. This modeling was also performed with only Del-Tin=s emissions to show what contribution the Del-Tin facility had to the receptors with concentrations above the PSD increment. Del-Tin=s contribution to this receptor was a 0.7 µg/m3 which is 2.3% of the PSD increment. Additionally, at each of the receptors where the PSD increment was exceeded the maximum contribution by Del-Tin was 1.2 µg/m3. This contribution represents 4% of the 30 µg/m3 PSD Increment and is therefore not a limiting factor in allowing the continued operation of this facility. The following table is a summary of the PM10 PSD modeling results.

Averaging

Period

PSD Class II

Increment (µg/m3)

Increment Available (µg/m3)

Highest Maximum

Contribution to PSD Increment (µg/m3)

Maximum Increment Consumed

Available Increment Consume

d

24-Hour

30

-

0.7

2.3%

-

annual

17

5.6

0.28

1.6

28.5% Screening analysis was conducted on the CO emissions from the facility to determine if refined modeling was required. The highest concentration for any of the 5 years processed in the model is 27.8 µg/m3 for the one hour average and 8.1 µg/m3 for the eight hour average. The screening

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Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480 significance level is 2000 µg/m3 for the one hour average and 500 µg/m3 for the eight hour average. The screening results are well below the significance levels. Therefore, refined modeling was not required for this permit. Screening analysis was conducted on the NOx emissions from the facility to determine if refined modeling was required. The highest concentration for any of the 5 years processed in the model is 0.15 µg/m3. The screening significance level is 1 µg/m3. The screening results are well below the significance levels. Therefore, refined modeling was not required for this permit.

Additional Impact Review An applicant for a Prevention of Significant Deterioration (PSD) permit must prepare additional impact analyses for each pollutant subject to the regulation under the Clean Air Act Amendments. Three areas constitute the Additional Impact Review: a growth analysis, a soils and vegetation analysis, and a visibility analysis.

Growth Analysis The Growth Analysis estimates the impact that will be generated by atmospheric emissions generated by the projected growth from industrial, commercial, and residential growth associated with the project. The only increase in emissions from associated growth results from the increase in workers traveling to and from work. Emissions from this are assumed to be insignificant and would not have a minor impact (if any) to the area.

Soils and Vegetation Analysis

A PSD applicant must also conduct a soil and vegetation air pollution impact analysis based on an inventory of the soils and vegetation types found in the impact area. For most types of soils and vegetation ambient concentrations of criteria pollutants below the secondary NAAQS will not result in harmful effects. The modeling results discussed in the Ambient Air Impact Analysis above show that all pollutant=s ground level concentrations are below the secondary NAAQS levels set forth by the US EPA. Therefore, Del-Tin=s emissions are not expected to result in harmful effects to the soils and vegetation in the area.

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Visibility Impact Analysis

PSD regulations require that emissions from a major source be evaluated for potential impacts on visibility in any nearby Class I area. The closest Class I area to the Del-Tin facility is the Caney Creek Wilderness, at a distance of approximately 195 km. Due to this great distance, the impact on visibility at Caney Creek is expected to be minimal. A plume visual impact model was selected for further analysis. Del-Tin, in the preparation of their permit application, ran EPA=s VISCREEN model to determine the effect that the facility would have on the visibility in the Caney Creek Wilderness. The model showed that the screening criteria was not exceeded and that Del-Tin should cause no detrimental impact on the visibility in the Caney Creek Wilderness.

Best Available Control Technology Analysis The PSD regulations mandate that a case-by-case Best Available Control Technology (BACT) analysis be performed on all sources at the Del-Tin Facility. A summary of the BACT determination is below.

BACT Analysis Summary

Source

Description

Pollutant

Control Technology

Bact Limit 01

Chip Silo Bin Vent

PM10

Baghouse

0.004 lb/hr

02

Green Saw Dust Bin Vent

PM10

Baghouse

0.004 lb/hr

03

Core/Face Refiner Abort Cyclone Vents (Start-up)

PM10

Cyclone

18.72 lb/hr

04

Mat Trim Pneumatic System Baghouse

PM10

Cyclone and Baghouse

0.15 lb/hr

05

Heat Energy System Stack (Callidus)

PM10 VOC NOx

ESP Thermal Incineration SNCR and low NOx Burners

28.19 lb/hr 10.0 lb/hr 0.3 lb/ Million BTU

06A

Former Infeed Area

PM10 Cyclone and

0.19 lb/hr

10


System Vent A (Core)

Baghouse

06B

Former Infeed Area System Vent B (Face)

PM10


0.19 lb/hr

07

Scalper System Vent

PM10


0.11 lb/hr

08


PM10


0.19 lb/hr

09A

Board Cooler Vent A

PM10 VOC

no control

0.18 lb/hr 3.4 lb/hr

09B

Board Cooler Vent B

PM10 VOC

no control


09C

Board Cooler Vent C

PM10 VOC

no control


10


PM10

Baghouse

0.19 lb/hr

11


PM10

Baghouse

0.19 lb/hr

12

Sander System #1 Baghouse Vent

PM10

Baghouse

0.19 lb/hr

13

Sander System #2 Baghouse Vent

PM10

Baghouse

0.19 lb/hr

14

Sander Dust Silo Bin Vent

PM10

Baghouse

0.004 lb/hr

15

Rough Trim/Sawdust Silo Bin Vent

PM10

Baghouse

0.004 lb/hr

16

Sawdust High Pressure Filter

PM10

Baghouse

0.02 lb/hr

17

Fuel Mixing Bin

PM10

Baghouse

0.01 lb/hr

11


Transfer System Vent

18

Sander Dust High Pressure Filter

PM10

Baghouse

0.04 lb/hr

19

Former Area Transfer System Vent

PM10

Baghouse

0.01 lb/hr

20

Raw Material Handling

PM10

no control

0.04 lb/hr

BACT Requirements for PM10 Emissions The majority of the particulate sources at the Del-Tin Facility are controlled by baghouses. Since baghouse control technologies represent the highest level of pollution control for these types of sources, no further review of alternative control options is warranted, and these baghouses with a minimum removal efficiency of 99.9% represent BACT for these sources. The CLGS system, SN-05, is a unique system that not only provides the technology to control VOC and CO emissions from the dryers and press but also provides process steam. The CLGS system originally had a series of baghouses controlling particulate emissions. The baghouses did not allow the facility to maintain constant operation due to excess build-up and clogging in the baghouses. The baghouses were replaced with an ESP. The ESP will provide 95% reduction in the particulate emissions. This control efficiency is equal to the highest control efficiencies found on the RACT/BACT/LAER clearinghouse for dryer and press operations. The Refiner Startup Cyclone, SN-03, operates during the start up of the refiner system. Wood material not yet up to optimum temperature is rerouted from the production system to a cyclonic separator. The wood material routed to the cyclone has a high moisture content and the collection efficiency of the cyclone is expected to be 99.95%. The start up system is permitted to operate for 400 hours per year. The addition of a baghouse would result in a $8,700 per ton of particulate removal. Therefore, the cyclone is considered BACT for this source. The Board Cooling Vents=, SN-09A, B, and C, combined emissions are 2.31 ton per year particulate sources. The addition of a baghouse to control particulate emissions from the vents would cost $78,000 per ton of particulate removed on an annual basis. This control is not cost effective, and for this source no controls represent BACT due to the low amount of emissions from this source. 12

Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480 BACT Requirements for VOC Emissions Del-Tin uses the CLGS, SN-05, to control VOC emissions from the facility=s driers and press. Data from the RBLC clearinghouse show most facilities of this type use an RTO with 90 to 95% VOC reduction to control VOC emissions from dryers and presses. Del-Tin=s proposes to operate their CLGS system which can achieve a 95% destruction efficiency equal to that of a RTO. Therefore, the CLGS system is BACT for controlling VOC emissions from the dryers and presses. The other VOC sources at the facility are uncontrolled. The first of these sources is the Material Handling and Conveying Fugitive Emissions. The cost building a collection system which could route the emissions to the CLGS system would cost around $12,000 per ton of VOC removed on an annual basis. The other source at the facility which has uncontrolled VOC emissions is the Board Cooling Vents. Placing RTOs on this source to control the emissions would cost $14,000 per ton of VOC removed on an annual basis . The Board Cooling Wheels cannot be routed to the CLGS system because the CLGS system cannot handle the high volume of air flow from the board cooling wheels. The cost of any add on controls to this source would not be cost effective, and therefore, no control equipment BACT for this source. BACT Requirements for NOx Emissions The only NOx source at the Del-Tin facility is the CLGS, SN-05. The RBLC shows the most common types of NOx controls are low NOx Burners, SCR, and SNCR. The CLGS system is equipped with low NOx burners, and the facility is further controlling NOx emissions from the CLGS with a SNCR by injecting aqueous ammonia. The additional controls were necessary to bring NOx emissions below the limits established in NSPS Subpart Db. Costs analysis were performed on adding SCR and costs were estimated at $8,900 per ton of NOx removed on an annual basis. The SNCR and low NOx burners are BACT for this source. BACT Requirements for CO Emissions The only CO source at the Del-Tin facility is the CLGS, SN-05. The RBLC shows the primary CO controls were good combustion for boilers and furnaces and RTOs as control devices for presses and dryers. The CLGS system is essentially a boiler and a control device for the press and dryers. BACT for CO emissions from the CLGS system is good combustion practice.

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SECTION IV: EMISSION UNIT INFORMATION


SN-01 and SN-02

Chip Silo Bin Vent Green Sawdust Silo Bin Vent

Source Description

Raw material is received through one of two truck dumpers. The raw material is conveyed to a chip-sawdust separator. From the separator the sawdust is conveyed directly to the green sawdust silo bin (SN-02). The chips are conveyed to the chip screen where oversize chips are diverted to a rechipper. The Aresized@ chips join the chips that have passed through the chip screen at the rotary chip screens machine. From the rotary chip screens machine the chips are conveyed to the chip silo bin (SN-01) and any newly generated sawdust is conveyed to the green sawdust silo bin (SN-02). Each silo is vented to a baghouse.

Specific Conditions 1. Pursuant to '19.901 et seq of the Regulations of the Arkansas Plan of Implementation

for Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Plantwide Condition 5.

Source No.

Pollutant

lb/hr

tpy

01

PM10

0.1

0.1

02

PM10

0.1

0.1 2. Pursuant to '18.801 of the Arkansas Air Pollution Control Code (Regulation #18)

effective February 15, 1999, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Plantwide Condition 5.

Source No.

Pollutant

lb/hr

tpy

01

PM

0.1

0.1

02

PM

0.1

0.1

15

Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480 3. Pursuant to '18.501 and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the

permittee shall not cause to be discharged to the atmosphere from the chip silo bin vent, (SN-01), and the green sawdust silo bin vent, (SN-02), gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

16


SN-03

Face and Core Refiner Abort Cyclone Vent (Start-up Only)

Source Description During start-up, while everything is coming up to temperature, the wet wood fiber from the refiners is diverted via a >Y= valve in the refiner discharge line, to a cyclonic separator prior to the flash dryer tubes. The wet collected material ends up in a dumpster bucket or concrete dump bin and the conveying air is released to the atmosphere.


for Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition 6.

Pollutant

lb/hr

tpy

PM10

18.8


effective February 15, 1999, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition 6.

Pollutant

lb/hr

tpy

PM

18.8

3.8 6. Pursuant to '19.901, A.C.A.'8-4-203 as referenced by A.C.A.'8-4-304, and 40 CFR

70.6, the face and core refiner cyclone vent Face and Core Refiner Abort Cyclone Vent (SN-03) shall only be operated during system start-up and the total operating time shall not exceed 400 hours during any consecutive 12 month period. Compliance with this condition will be demonstrated by Specific Condition 7.

7. Pursuant to '19.705 and 40 CFR Part 52, the permittee shall maintain records of hours of

operation of both refiner cyclones. These records shall be kept on site, made available to

17


Department personnel upon request, and updated on a daily basis. Records shall contain the following information:

the hours the refiner cyclone is receiving fiber each day; the total hours the refiner cyclone is receiving fiber each month; and the total hours the refiner cyclone received fiber during the last consecutive 12-month period.

8. Pursuant to '19.503 and 40 CFR Part 52, the permittee shall not cause to be discharged to

the atmosphere from the Face and Core Refiner Abort Cyclone Vent, (SN-03) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A.

18


SN-04

Mat Trim Pneumatic System Baghouse

Source Description Dry resinated fiber is metered into the three formers which lay up or form the material into a Amat@ of fiber across a moving belt. After forming, the mat is carried by a belt conveyor through a pre-press where the mat is pressed into a manageable height with enough strength to be conveyed into the continuous press. On the end of the pre-press are two saws that trim the edges to a uniform dimension. The mat trim pneumatic system collects the trimmed material, the sawdust, and other loose material from the pre-press and conveys it to the mat trim pneumatic system cyclone. The material in the cyclone is discharged into the face fiber storage bin and the air is exhausted through the baghouse (SN-04).

Specific Conditions 9. Pursuant to '19.901 et seq of the Regulations of the Arkansas Plan of Implementation for

Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Plantwide Condition 5.

Pollutant

lb/hr

tpy

PM10

0.2



Pollutant

lb/hr

tpy

PM

0.2

0.7 11. Pursuant to '18.501 and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the

permittee shall not cause to be discharged to the atmosphere from the Mat Trim Pneumatic System Baghouse, (SN-04) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A.

19


Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

20


SN-05 and SN-05A

Heat Energy System Stack (Callidus) And Closed Loop Gasification System Heat Vent Stack

Source Description

The heat energy system is a Callidus Closed Loop Gasification System (CLGS) which gasifies biomass fuel, which is bark, sawdust, sander dust, chips, and other residual wood materials, in a rotary kiln to produce a combustible gas used as fuel in a secondary combustion chamber (SCC). The CLGS is a 291 MM Btu/hr unit that uses natural gas as a secondary fuel source and for start-up. The CLGS consists primarily of a fuel feed system, two rotary gasifiers, a secondary combustion chamber (SCC), hot air heat exchanger, recuperative heat exchanger, hot oil heat exchanger, boiler, ESP, SNCR system to reduce NOx emissions, induced draft fan, and exhaust vent stack. The system is considered closed loop in that the hot air supplied to the dryers returns to the system as combustion air and is not released to the atmosphere until after the VOCs are destroyed and the particulate captured. The press vent and dryer exhaust gases, laden with VOCs, pass through a recuperative heat exchanger to be heated to 875°F before being routed into the rotary gasifier and SCC. The rotary gasifier is operated in the starved air mode, where the oxygen level is too low for complete combustion to occur. As a result combustible gases are formed, primarily carbon monoxide (CO) and hydrogen (H2). The gasifier has a wood fuel residence time of approximately 60 minutes. The flue gas leaving the gasifier is oxidized in a vertical secondary combustion chamber (SCC) to assure complete destruction of any remaining VOC, fine wood particles, and CO. The remainder of the dryer exhaust gas is used as an oxygen source to complete the combustion process in the SCC. The hot flue gases leaving the SCC pass through a series of heat exchangers to extract heat required for the different processes of manufacturing MDF. The cooled flue gases pass through the ESP to remove any suspended particulate. The flue gases are then exhausted out the vent stack (SN-05) with the aid of an induced draft fan. Del-Tin has added a SNCR system to the CLGS for NOx control. The system injects ammonia into the combustion chamber. The ammonia reacts with the nitrogen oxides to form nitrogen and water vapor. The CLGS is a 291 MM Btu/hr unit that uses natural gas as a secondary fuel source and for start-up. The natural gas usage during normal operation is 850 cubic feet per hour. More than 90% of the heat from the CLGS is supplied by the combustion of biomass fuel, and less than 10% is

21

Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480 supplied by natural gas. But the unit is capable of operating at a natural gas capacity factor greater than 10%. Therefore the unit will be subject to nitrogen oxides emission standards and monitoring of NSPS Subpart Db. The Closed Loop Gasification System (Heat Vent Stack), SN-05A, is diverted exhaust from the CLGS, SN-05 which is used to heat the dirty press air duct. The warm exhaust is diverted from the CLGS stack after the ESP and is routed along the outside of the dirty press air duct. Heating the duct prevents organic compounds from condensing in the ductwork.


for Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Emissions for SN-05A shall be not more than 10% of the emissions allowed for SN-05 and SN-05A combined. Compliance with this condition will be demonstrated by Specific Conditions 17 and 18. Complaince with the NOx pound per hour limit will be show by complying with the NOx BACT limit in Specific Condition 16.

Source

Pollutant

lb/hr

tpy

PM10

28.2

123.5

SO2

8.0

35.1

VOC

21.2

92.9

CO

228.3

1000.0

SN-05

and SN-05A

NOX

87.2

386.1

13. Pursuant to '18.801 of the Arkansas Air Pollution Control Code (Regulation #18)

effective February 15, 1999, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Emissions for SN-05A shall be not more than 10% of the emissions allowed for SN-05 and SN-05A combined. Compliance with this condition will be demonstrated by Specific Condition 18.

22 Amended

Source

Pollutant

lb/hr

tpy

SN-05


Source

Pollutant

lb/hr

tpy

PM 28.2 123.5

Formaldehyde

11.6

50.8

and SN-05A

Ammonia

88.2

386.1

14. Pursuant to '19.304 and 40 CFR Part 60 Subpart Db, the permittee shall not cause to be

discharged to the atmosphere from the Heat Energy System Stack (Callidus), (SN-05 and SN-05A) gases which exhibit an opacity greater than 15% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Specific Condition 17.

15. Pursuant to '19.901 et seq of the Regulations of the Arkansas Plan of Implementation

for Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part 52, Subpart E, the permittee shall control VOC emissions routed to the secondary combustion chamber of the SN-05 to 95% or better by weight. Compliance with this condition shall be verified by compliance with Specific Condition 19.

16. Pursuant to '19.901, '19.304 and 40 CFR Part 60 Subpart Db, the permittee shall not

cause to be discharged to the atmosphere from the Heat Energy System Stack (Callidus), (SN-05 and SN-05A) gases which contain 0.3 lb/million BTU of NOx on a 30 day averaging period or 0.10 lb/ million BTU of PM. Compliance with this condition shall be verified by compliance with Specific Condition 17.

17. Pursuant to '19.304 and 40 CFR Part 60 Subpart Db, the permittee shall install, calibrate,

maintain, and operate continuous emission monitoring systems (CEMS) for measuring opacity of the emission and the quantity of NOx discharged to the atmosphere from the Heat Energy System (SN-05) and record the output of the systems.

18. Pursuant to '19.702 and 40 CFR Part 52, Subpart E, the permittee shall conduct a stack

emissions test on the Heat Energy System (SN-05) to measure the following pollutants by the indicated EPA test method as listed in 40 CFR Part 60, Appendix A. Testing shall be performed in accordance with Plantwide Condition 3 of this permit.

Pollutant

EPA Test Method

PM/PM10

5

23


Pollutant

EPA Test Method

SO2 6C NOX

7E

CO

10

VOC

25A

Formaldehyde

Acetylacetone Method

or NCASI Chilled

Impinger Method

Ammonia

206 Exhaust Gas Volumetric Flow Rate

2

The test shall be conducted within 180 days of the issuance of this permit and shall be repeated annually thereafter. If the initial compliance test is conducted with less than 90% of the heat input being supplied by biomass fuel, then the test must be repeated within 60 days of the CLGS achieving 90% or greater biomass fuel capability. All tests shall be conducted with the CLGS operating at 90% or greater of capacity on biomass fuel. To show compliance with the emission limits for SN-05 Del Tin must either test both SN-05 and SN-05a simultaneously or close the bypass from SN-05 to SN-05a. The ADEQ Air Division Compliance Inspector Supervisor shall be notified at least 15 days prior to the test.

19. Pursuant to '19.702 and 40 CFR Part 52, Subpart E, the permittee shall conduct a stack

emissions test on the Heat Energy System (SN-05) to measure the VOC destruction efficiency of the press emissions across the CLGS or the VOC destruction efficiency of the secondary combustion chamber of the CLGS. Testing shall be performed in accordance with Plantwide Condition 3 of this permit.

The test shall be conducted within 180 days of the issuance of this permit and shall be repeated annually thereafter. The test shall be conducted with the CLGS operating at 90% or greater of capacity on biomass fuel. To show compliance with the emission limits for SN-05 Del Tin must either test both SN-05 and SN-05A simultaneously or close the bypass from SN-05 to SN-05A. The ADEQ Air Division Compliance Inspector Supervisor shall be notified at least 15 days prior to the test.

24

Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480 SN-06A and SN-06B Former Infeed Area System Vent A Former Infeed Area System Vent B Source Description After the raw material is separated into sawdust and properly sized chips, the refining process is the next step in the manufacturing of medium density fiberboard (MDF). The raw material, which has been separated into Acore@ and Aface@ material, passes through a Apre-steam@ bin where it is injected with steam. Next the material is fed into the digesters where it is held under pressure and elevated temperature for several minutes until it is fed into a pressurized refiner system. In the refiner, by mechanical means, the wood is Afiberized@ or broken down into individual wood fibers. The fiber is discharged from the refiners via Ablowlines@ directly into a two-stage flash tube fiber dryer system. Resin is metered into the blowline at the refiner discharge to impregnate the fiber. The dried fiber is conveyed to fiber bins before being metered into the formers. The dry fiber is conveyed by air to the formers where cyclones separate the fiber from the air. The discharge air from the cyclones passes through baghouses SN-06A and SN-06B.



Source No.

Pollutant

lb/hr

tpy

06A

PM10

0.2

0.9

06B

PM10

0.2



25


Source No.

Pollutant

lb/hr

tpy

06A

PM

0.2

0.9

06B

PM

0.2

0.9

22. Pursuant to '18.501 and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the

permittee shall not cause to be discharged to the atmosphere from the Former Infeed Area System Vents A and B, (SN-06A and SN-06B) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

26


SN-07

Scalper System Vent

Source Description Dried resin impregnated wood fiber material is fed into three forming machines for Alaying up@ of the Amats@ by layers in a Aface-core-face@ material orientation. The term Amat@ refers to the accumulation of thin layers of dried resin impregnated wood fibers deposited on the moving belt prior to any pressing which activates heat-set resins and binds the fibers together. The scalper is a vacuum system that collects stray wood fiber from the formers and pneumatically conveys it to the scalper pneumatic system cyclone which discharges into the core fiber bin. The air is exhausted through the baghouse vent (SN-07).


for Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Plantwide Condition 5.

Pollutant

lb/hr

tpy

PM10

0.2



Pollutant

lb/hr

tpy

PM

0.2


permittee shall not cause to be discharged to the atmosphere from the Scalper System Vent, (SN-07) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

27


SN-08


Source Description Following the side trim saw and prior to the heat setting press, the quality of the mat is checked. All below standard mats are rejected to a pneumatic pick-up. The material is conveyed to a cyclone which can discharge to the core fiber bin. The exhaust from the cyclone passes through the mat reject system vent baghouse (SN-08).



Pollutant

lb/hr

tpy

PM10

0.2



Pollutant

lb/hr

tpy

PM

0.2


permittee shall not cause to be discharged to the atmosphere from the Mat Reject System Vent, (SN-08) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

28


SN-09A, B, and C

Board Cooler Vents A, B, and C

Source Description The board cooling wheels are rotating trays into which the pressed panels are arranged, then rotated through a vertical orientation, with spacing of several inches between panels, to allow cooling to occur prior to cutting and stacking. The cooler vents are three large, shrouded building vent-fans, located in the ceiling above the cooling trays, to pull heat from the area.


Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition 32.

Source No.

Pollutant

lb/hr

tpy

PM10

0.2

0.8

09A

VOC

3.4

14.8

PM10

0.2

0.8

09B

VOC

3.4

14.8

PM10

0.2

0.8

09C

VOC

3.4



29

Source No.

Pollutant

lb/hr

tpy

09A

PM

0.2

0.8


Source No.

Pollutant

lb/hr

tpy

Formaldehyde

0.2

0.5

PM

0.2

0.8

09B

Formaldehyde

0.2

0.5

PM

0.2

0.8

09C

Formaldehyde

0.2

0.5


permittee shall not cause to be discharged to the atmosphere from the Board Cooler Vents A, B, and C, (SN-09A, SN-09B and SN-09C) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

32. Pursuant to '19.901 and 40 CFR Part 52, the quantity of MFD board processed at the

cooling wheels shall not exceed 237,913 MSF, calculated on a 3/4" thickness basis, during any consecutive twelve month period. Compliance with this condition shall be verified by compliance with Specific Condition 33.

33. Pursuant to '19.705 and 40 CFR Part 52, the permittee shall maintain records of the

quantity of equivalent 3/4" MDF board cooled in the cooling wheels which demonstrate compliance with the limit set in Specific Condition 32 and may be used by the Department for enforcement purposes. The records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel upon request. An annual total and each individual month=s data shall be submitted in accordance with General Provision 7. Records shall contain the following information:

the total quantity of 3/4" equivalent board feet processed each day; the total quantity of 3/4" equivalent board feet processed each month; and the total quantity of 3/4" equivalent board feet processed during the last consecutive 12 month period

30


SN-10 and SN-11 Saw System #1 Baghouse Vent Saw System #2 Baghouse Vent Source Description The panels are manufactured oversize and each panel is cut into various sizes by two saws. The rip saw cuts the sheets to the proper width and the cross cut saw cuts the sheets to the proper length. The saws have aspirators that collect the saw dust and convey it directly to the baghouse (SN-10). The trim scrap and some sawdust are conveyed to a strip hog where the material is pulverized and pneumatically conveyed to a second baghouse (SN-11). The cyclones discharge into either the rough trim and sawdust silo (SN-15) or the sander dust silo (SN-14). The baghouses discharge into the fuel mixer bin.



Source No.

Pollutant

lb/hr

tpy

10

PM10

0.2

0.9

11

PM10

0.2



Source No.

Pollutant

lb/hr

tpy

10

PM

0.2

0.9

11

PM

0.2

0.9

31


permittee shall not cause to be discharged to the atmosphere from the Saw System #1 Baghouse Vent and the Saw System #2 Baghouse Vent, (SN-10 and SN-11) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

32


SN-12 and SN-13 Sander System #1 Baghouse Vent Sander System #2 Baghouse Vent Source Description After cooling and before the panels are cut into sheets, the panels go through two sanding modules and one polishing module to insure a smooth and flat product. The sander dust in the first module is controlled by Sander System #1 and the dust from the second module is controlled by Sander System #2. Each sander system pneumatically conveys the dust to a baghouse, SN-12 and SN-13 respectfully. The baghouses discharge material into the fuel mixer bin.



Source No.

Pollutant

lb/hr

tpy

12

PM10

0.2

0.9

13

PM10

0.2

0.9

38. Pursuant to '18.801 of the Arkansas Air Pollution Control Code (Regulation #18)


Source No.

Pollutant

lb/hr

tpy

12

PM

0.2

0.9

13

PM

0.2

0.9

33


permittee shall not cause to be discharged to the atmosphere from the Saw System #1 Baghouse Vent and the Saw System #2 Baghouse Vent, (SN-12 and SN-13) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

34


SN-14 and SN-15

Sander Dust Storage Silo Bin Vent Rough Trim and Sawdust Storage Silo Bin Vent

Source Description

The sander dust storage silo receives the fine dust collected in the two sander systems cyclones and it may receive sawdust from either or both of the saw systems cyclones. Material collected in the sander dust storage silo is pneumatically conveyed to the fuel mixing bin. The silo=s emissions are controlled by a bin vent filter (SN-14). The rough trim and sawdust storage silo receives the material collected in the two saw systems cyclones. The material discharged from the silo is conveyed to the fuel storage bin. The silo=s emissions are controlled by a bin vent filter (SN-15).



Source No.

Pollutant

lb/hr

tpy

14

PM10

0.1

0.1

15

PM10

0.1



35

Source No.

Pollutant

lb/hr

tpy

14

PM

0.1

0.1

15

PM

0.1

0.1


permittee shall not cause to be discharged to the atmosphere from the Sander Dust Storage Silo Bin Vent and Rough Trim and Sawdust Storage Silo Bin Vent, (SN-14 and SN-15) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

36


SN-17 and SN-17A

Fuel Mixing Bin Transfer System Vent and Dry Trim Baghouse

Source Description Sanderdust is collected from baghouses SN-12 and SN-13, and storage silo SN-14. This material is conveyed pneumatically to the fuel mixing bin through baghouse SN-17. The fuel mixing bin is a large hopper where all biomass fuel is blended together and metered into the two gasifiers. The bin can handle a maximum fuel input of 7.5 tons per hour. The Dry Trim Baghouse, SN-17A, handles the same material as SN-17. Material goes to SN-17 or 17A. SN-17A allows material to be used as raw material for MDF.


Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table for source SN-17. Compliance with this condition will be demonstrated by Plantwide Condition 5.

Pollutant

lb/hr

tpy

PM10

0.1

0.1 44. Pursuant to '19.501 et seq of the Regulations of the Arkansas Plan of Implementation for

Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table for source SN-17A. Compliance with this condition will be demonstrated by Plantwide Condition 5.

Pollutant

lb/hr

tpy

PM10

0.1



37


Source

Pollutant

lb/hr

tpy

SN-17

PM

0.1

0.1

SN-17A

PM

0.1

0.1


permittee shall not cause to be discharged to the atmosphere from the Fuel Mixing Bin Transfer System Vent, (SN-17) and the Dry Trim Baghouse, (SN-17A) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

38


SN-16 and SN-18

Sander Dust High Pressure Filter Sawdust High Pressure Filter

Source Description

Sander dust and chip fines are collected from baghouses SN-10 and SN-11, and storage silo SN-15. This material is conveyed pneumatically to the fuel storage bin through baghouse SN-18. The baghouse-hopper (SN-18) discharges by screw and belt conveyors into the fuel storage bin.



Source No.

Pollutant

lb/hr

tpy

16

PM10

0.1

0.1

18

PM10

0.1



Source No.

Pollutant

lb/hr

tpy

16

PM

0.1

0.1

18

PM

0.1

0.2

39

49. Pursuant to '18.501 and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall not cause to be discharged to the atmosphere from the Sander Dust High Pressure Filter and the Sawdust High Pressure Filter, (SN-16 and SN-18) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference


Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

40


SN-19 Former Area Transfer System Vent Source Description Dust from the Mat Trim System baghouse (SN-04), both Former Infeed Area baghouses (SN-06A and SN-06B), the Scalper System baghouse (SN-07), and the Mat Reject System baghouse (SN-08) is conveyed by air to the former Area Transfer System baghouse. This dust is discharged into the Face Material Storage Bin.

Specific Conditions

50. Pursuant to '19.901 et seq of the Regulations of the Arkansas Plan of Implementation for


Pollutant

lb/hr

tpy

PM10

0.1



Pollutant

lb/hr

tpy

PM

0.1


permittee shall not cause to be discharged to the atmosphere from the Former Area Transfer System Vent, (SN-19) gases which exhibit an opacity greater than 5% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A. Compliance with this condition shall be verified by compliance with Plantwide Condition 13.

41


SN-20 Raw Material Handling System (Fugitive Emissions) Source Description There are fugitive emissions from the initial handling and from the preparation of the raw material for manufacturing and for its use as fuel. The following areas are listed as fugitive emission areas:

1. truck dumps (3 each);

2. outside storage area;

3. bark hogging; and

4. chip screens


Air Pollution Control (Regulation #19) effective February 15, 1999 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Specific Condition 56.

Pollutant

lb/hr

tpy

PM10

0.1

0.2

VOC

2.8



Pollutant

lb/hr

tpy

42


Pollutant

lb/hr

tpy

PM 0.1 0.2 55. Pursuant to '18.501 and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the

permittee shall not cause to be discharged to the atmosphere from the Raw Material Handling System, (SN-20) gases which exhibit an opacity greater than 20% as measured in accordance with EPA Reference Method 9 as found in 40 CFR Part 60, Appendix A.

56. Pursuant to '19.901 and 40 CFR Part 52, the quantity of wood residue raw material

received at the facility shall not exceed 672,414 oven dried tons per any consecutive twelve month period, and the quantity of biomass fuel received at the facility shall not exceed 128,000 oven dried tons per any consecutive twelve month period. Compliance with this condition shall be verified by compliance with Specific Condition 57.

57. Pursuant to '19.705 and 40 CFR Part 52, the permittee shall maintain records which

demonstrate compliance with the limit set in Specific Condition 56. These records may be used by the Department for enforcement purposes. The records shall be updated on a monthly basis, shall be kept on site, and shall be provided to Department personnel upon request. An annual total and each individual month=s data shall be submitted in accordance with General Provision 7.

43


SECTION V: COMPLIANCE PLAN AND SCHEDULE Del-Tin Fiber, L.L.C is in compliance with the applicable regulations cited in the permit application. Del-Tin Fiber, L.L.C will continue to operate in compliance with those identified regulatory provisions. The facility will examine and analyze future regulations that may apply and determine their applicability with any necessary action taken on a timely basis.

44


SECTION VI: PLANTWIDE CONDITIONS 1. Pursuant to '19.704 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A. '8-4-203 as

referenced by '8-4-304 and '8-4-311, the Director shall be notified in writing within thirty (30) days after construction has commenced, construction is complete, the equipment and/or facility is first placed in operation, and the equipment and/or facility first reaches the target production rate.

2. Pursuant to '19.410(B) of Regulation 19, 40 CFR Part 52, Subpart E, the Director may

cancel all or part of this permit if the construction or modification authorized herein is not begun within 18 months from the date of the permit issuance or if the work involved in the construction or modification is suspended for a total of 18 months or more.

3. Pursuant to '19.702 of Regulation 19 and/or '18.1002 of Regulation 18 and A.C.A.

'8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311, any equipment that is to be tested, unless stated in the Specific Conditions of this permit or by any federally regulated requirements, shall be tested with the following time frames: (1) Equipment to be constructed or modified shall be tested within sixty (60) days of achieving the maximum production rate, but in no event later than 180 days after initial start-up of the permitted source or (2) equipment already operating shall be tested according to the time frames set forth by the Department or within 180 days of permit issuance if no date is specified. The permittee shall notify the Department of the scheduled date of compliance testing at least fifteen (15) days in advance of such test. Compliance test results shall be submitted to the Department within thirty (30) days after the completed testing.

4. Pursuant to '19.702 of Regulation 19 and/or '18.1002 of Regulation 18 and A.C.A.

'8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311, the permittee shall provide:

a. Sampling ports adequate for applicable test methods b. Safe sampling platforms c. Safe access to sampling platforms d. Utilities for sampling and testing equipment

5. Pursuant to '19.303 of Regulation 19 and A.C.A. '8-4-203 as referenced by A.C. A.

'8-4-304 and '8-4-311, the equipment, control apparatus and emission monitoring equipment shall be operated within their design limitations and maintained in good condition at all times.

45

Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480 6. Pursuant to Regulation 26 and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311,

this permit subsumes and incorporates all previously issued air permits for this facility.

Acid Rain (Title IV) 7. Pursuant to '26.701 of Regulation #26 and 40 CFR 70.6(a)(4), the permittee is prohibited

from causing any emissions which exceed any allowances that the source lawfully holds under Title IV of the Act or the regulations promulgated thereunder. No permit revision is required for increases in emissions that are authorized by allowances acquired pursuant to the acid rain program, provided that such increases do not require a permit revision under any other applicable requirement. This permit establishes no limit on the number of allowances held by the permittee. The source may not, however, use allowances as a defense to noncompliance with any other applicable requirement of this permit or the Act. Any such allowance shall be accounted for according to the procedures established in regulations promulgated under Title IV of the Act.

Title VI Provisions

8. The permittee shall comply with the standards for labeling of products using ozone

depleting substances pursuant to 40 CFR Part 82, Subpart E:

a. All containers containing a class I or class II substance stored or transported, all products containing a class I substance, and all products directly manufactured with a class I substance must bear the required warning statement if it is being introduced to interstate commerce pursuant to '82.106.

b. The placement of the required warning statement must comply with the requirements pursuant to '82.108.

c. The form of the label bearing the required warning must comply with the requirements pursuant to '82.110.

d. No person may modify, remove, or interfere with the required warning statement except as described in '82.112.

9. The permittee shall comply with the standards for recycling and emissions reduction

pursuant to 40 CFR Part 82, Subpart F, except as provided for MVACs in Subpart B:

a. Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to '82.156.

b. Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to '82.158.

46


c. Persons performing maintenance, service repair, or disposal of appliances must be certified by an approved technician certification program pursuant to '82.161.

d. Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply with record keeping requirements pursuant to '82.166. (AMVAC-like appliance@ as defined at '82.152.)

e. Persons owning commercial or industrial process refrigeration equipment must comply with leak repair requirements pursuant to '82.156.

f. Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to '82.166.

10. If the permittee manufactures, transforms, destroys, imports, or exports a class I or class II

substance, the permittee is subject to all requirements as specified in 40 CFR part 82, Subpart A, Production and Consumption Controls.

11. If the permittee performs a service on motor (fleet) vehicles when this service involves

ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is subject to all the applicable requirements as specified in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners.

The term Amotor vehicle@ as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The term AMVAC@ as used in Subpart B does not include the air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger buses using HCFC-22 refrigerant.

12. The permittee shall be allowed to switch from any ozone-depleting substance to any

alternative that is listed in the Significant New Alternatives Program (SNAP) promulgated pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives Policy Program.

13. Pursuant to '19.705, 40 CFR Part 52, Subpart E, and A.C.A. '8-4-203 as referenced by

'8-4-304 and '8-4-311, the permittee shall conduct weekly observations of the opacity from the following sources SN-01, 02, 04, 06A, 06B, 07, 08, 09A, 09B, 09C, 10, 11, 12, 13, 14, 15, 16, 17, 17A, 18, and 19. These weekly observations shall be conducted in accordance with EPA Reference Method 9. If visible emissions in excess of the permitted opacity are detected, the permittee shall immediately take action to identify the cause of the excess visible emissions, implement corrective action, and document that the visible emissions did not exceed the permitted opacity following the corrective action. Compliance with this conditions shall be verified the reporting requirements in Plantwide Condition 14.

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Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480 14. Pursuant to '19.705 and 40 CFR Part 52, Subpart E, the permittee shall maintain records

which demonstrate compliance with Plantwide Condition 13. These records shall contain the following items.

a. The date and time of the observation; b. if visible emissions above the permitted limit were detected; c. if visible emissions above the permitted limits, list the cause of the

exceedance of the opacity limits, the corrective action taken, and if the visible emissions are below the permitted limit after the corrective actions was taken; and

d. the person conducting the opacity observations.

These records shall be updated weekly, kept on site, and made available to Department personnel upon request. These records shall not be required when the EPA Reference Method 9 training sessions offered by the Department are in session.

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Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480 SECTION VII: INSIGNIFICANT ACTIVITIES Pursuant to '26.304 of Regulation 26, the following sources are insignificant activities. Any activity for which a state or federal applicable requirement applies is not insignificant even if this activity meets the criteria of '304 of Regulation 26 or is listed below. Insignificant activity determinations rely upon the information submitted by the permittee in an application dated December 21, 2002.

Description

Category

Resin Storage Tanks and Metering Tanks (4)

A-3

Wax Emulsion Tanks (2)

A-3

Diesel Storage Tank

A-3

Propane Tank

A-13

Hydraulic Oil Storage Tank

A-3

Thermal Oil Expansion Tank

A-3

Thermal Oil System High Point Vents

A-13

All Breathers and Vents on Oil Reservoirs for

Hydraulic Units

A-13

Electrical Transformers Pressure Relief Valve

A-13

Urea Storage Tanks (2)

A-3

Presteamer Vents A, B, and C

A-13

Pursuant to '26.304 of Regulation 26, the emission units, operations, or activities contained in Regulation 19, Appendix A, Group B, have been determined by the Department to be insignificant activities. Activities included in this list are allowable under this permit and need not be specifically identified.

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Del-Tin Fiber, L.L.C Permit #: 1714-AOP-R3 AFIN #: 70-00480 SECTION VIII: GENERAL PROVISIONS 1. Pursuant to 40 CFR 70.6(b)(2), any terms or conditions included in this permit which

specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A. '8-4-101 et seq.) as the sole origin of and authority for the terms or conditions are not required under the Clean Air Act or any of its applicable requirements, and are not federally enforceable under the Clean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 was adopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. '8-4-101 et seq.). Any terms or conditions included in this permit which specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A. '8-4-101 et seq.) as the origin of and authority for the terms or conditions are enforceable under this Arkansas statute.

2. Pursuant to 40 CFR 70.6(a)(2) and '26.701(B) of the Regulations of the Arkansas

Operating Air Permit Program (Regulation 26), effective August 10, 2000, this permit shall be valid for a period of five (5) years beginning on the date this permit becomes effective and ending five (5) years later.

3. Pursuant to '26.406 of Regulation #26, it is the duty of the permittee to submit a complete

application for permit renewal at least six (6) months prior to the date of permit expiration. Permit expiration terminates the permittee's right to operate unless a complete renewal application was submitted at least six (6) months prior to permit expiration, in which case the existing permit shall remain in effect until the Department takes final action on the renewal application. The Department will not necessarily notify the permittee when the permit renewal application is due.

4. Pursuant to 40 CFR 70.6(a)(1)(ii) and '26.701(A)(2) of Regulation #26, where an

applicable requirement of the Clean Air Act, as amended, 42 U.S.C. 7401, et seq (Act) is more stringent than an applicable requirement of regulations promulgated under Title IV of the Act, both provisions are incorporated into the permit and shall be enforceable by the Director or Administrator.

5. Pursuant to 40 CFR 70.6(a)(3)(ii)(A) and '26.701(C)(2) of Regulation #26, records of

monitoring information required by this permit shall include the following:

a. The date, place as defined in this permit, and time of sampling or measurements;

b. The date(s) analyses were performed;

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c. The company or entity that performed the analyses; d. The analytical techniques or methods used; e. The results of such analyses; and f. The operating conditions existing at the time of sampling or measurement.

6. Pursuant to 40 CFR 70.6(a)(3)(ii)(B) and '26.701(C)(2)(b) of Regulation #26, records of

all required monitoring data and support information shall be retained for a period of at least 5 years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit.

7. Pursuant to 40 CFR 70.6(a)(3)(iii)(A) and '26.701(C)(3)(a) of Regulation #26, the

permittee shall submit reports of all required monitoring every 6 months. If no other reporting period has been established, the reporting period shall end on the last day of the anniversary month of this permit. The report shall be due within 30 days of the end of the reporting period. Even though the reports are due every six months, each report shall contain a full year of data. All instances of deviations from permit requirements must be clearly identified in such reports. All required reports must be certified by a responsible official as defined in '26.2 of Regulation #26 and must be sent to the address below.

Arkansas Department of Environmental Quality Air Division ATTN: Compliance Inspector Supervisor Post Office Box 8913 Little Rock, AR 72219

8. Pursuant to 40 CFR 70.6(a)(3)(iii)(B), '26.701(C)(3)(b) of Regulation #26, and '19.601

and 19.602 of Regulation #19, all deviations from permit requirements, including those attributable to upset conditions as defined in the permit shall be reported to the Department. An initial report shall be made to the Department by the next business day after the discovery of the occurrence. The initial report may be made by telephone and shall include:

a. The facility name and location, b. The process unit or emission source which is deviating from the permit

limit, c. The permit limit, including the identification of pollutants, from which

deviation occurs, d. The date and time the deviation started,

51


e. The duration of the deviation, f. The average emissions during the deviation, g. The probable cause of such deviations, h. Any corrective actions or preventive measures taken or being taken to

prevent such deviations in the future, and i. The name of the person submitting the report.

A full report shall be made in writing to the Department within five (5) business days of discovery of the occurrence and shall include in addition to the information required by initial report a schedule of actions to be taken to eliminate future occurrences and/or to minimize the amount by which the permits limits are exceeded and to reduce the length of time for which said limits are exceeded. If the permittee wishes, they may submit a full report in writing (by facsimile, overnight courier, or other means) by the next business day after discovery of the occurrence and such report will serve as both the initial report and full report.

9. Pursuant to 40 CFR 70.6(a)(5) and '26.701(E) of Regulation #26, and A.C.A.'8-4-203, as

referenced by '8-4-304 and '8-4-311, if any provision of the permit or the application thereof to any person or circumstance is held invalid, such invalidity shall not affect other provisions or applications hereof which can be given effect without the invalid provision or application, and to this end, provisions of this Regulation are declared to be separable and severable.

10. Pursuant to 40 CFR 70.6(a)(6)(i) and '26.701(F)(1) of Regulation #26, the permittee must

comply with all conditions of this Part 70 permit. Any permit noncompliance with applicable requirements as defined in Regulation #26 constitutes a violation of the Clean Air Act, as amended, 42 U.S.C. 7401, et seq. and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application. Any permit noncompliance with a state requirement constitutes a violation of the Arkansas Water and Air Pollution Control Act (A.C.A. '8-4-101 et seq.) and is also grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application.

11. Pursuant to 40 CFR 70.6(a)(6)(ii) and '26.701(F)(2) of Regulation #26, it shall not be a

defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

12. Pursuant to 40 CFR 70.6(a)(6)(iii) and '26.701(F)(3) of Regulation #26, this permit may be modified, revoked, reopened, and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or

52


termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition.

13. Pursuant to 40 CFR 70.6(a)(6)(iv) and '26.701(F)(4) of Regulation #26, this permit does

not convey any property rights of any sort, or any exclusive privilege. 14. Pursuant to 40 CFR 70.6(a)(6)(v) and '26.701(F)(5) of Regulation #26, the permittee shall

furnish to the Director, within the time specified by the Director, any information that the Director may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Director copies of records required to be kept by the permit. For information claimed to be confidential, the permittee may be required to furnish such records directly to the Administrator along with a claim of confidentiality.

15. Pursuant to 40 CFR 70.6(a)(7) and '26.701(G) of Regulation #26, the permittee shall pay

all permit fees in accordance with the procedures established in Regulation #9. 16. Pursuant to 40 CFR 70.6(a)(8) and '26.701(H) of Regulation #26, no permit revision shall

be required, under any approved economic incentives, marketable permits, emissions trading and other similar programs or processes for changes that are provided for elsewhere in this permit.

17. Pursuant to 40 CFR 70.6(a)(9)(i) and '26.701(I)(1) of Regulation #26, if the permittee is

allowed to operate under different operating scenarios, the permittee shall, contemporaneously with making a change from one operating scenario to another, record in a log at the permitted facility a record of the scenario under which the facility or source is operating.

18. Pursuant to 40 CFR 70.6(b) and '26.702(A) and (B) of Regulation #26, all terms and

conditions in this permit, including any provisions designed to limit a source's potential to emit, are enforceable by the Administrator and citizens under the Act unless the Department has specifically designated as not being federally enforceable under the Act any terms and conditions included in the permit that are not required under the Act or under any of its applicable requirements.

53


20. Pursuant to 40 CFR 70.6(c)(2) and '26.703(B) of Regulation #26, the permittee shall allow an authorized representative of the Department, upon presentation of credentials, to perform the following:

19. Pursuant to 40 CFR 70.6(c)(1) and '26.703(A) of Regulation #26, any document (including reports) required by this permit shall contain a certification by a responsible official as defined in '26.2 of Regulation #26.

a. Enter upon the permittee's premises where the permitted source is located

or emissions-related activity is conducted, or where records must be kept under the conditions of this permit;

b. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;

c. Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit; and

d. As authorized by the Act, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with this permit or applicable requirements.

21. Pursuant to 40 CFR 70.6(c)(5) and '26.703(E)(3) of Regulation #26, the permittee shall

submit a compliance certification with terms and conditions contained in the permit, including emission limitations, standards, or work practices. This compliance certification shall be submitted annually and shall be submitted to the Administrator as well as to the Department. All compliance certifications required by this permit shall include the following:

a. The identification of each term or condition of the permit that is the basis

of the certification; b. The compliance status; c. Whether compliance was continuous or intermittent; d. The method(s) used for determining the compliance status of the source,

currently and over the reporting period established by the monitoring requirements of this permit; and

e. Such other facts as the Department may require elsewhere in this permit or by '114(a)(3) and 504(b) of the Act.

22. Pursuant to '26.704(C) of Regulation #26, nothing in this permit shall alter or affect the

following:

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a. The provisions of Section 303 of the Act (emergency orders), including the authority of the Administrator under that section;

b. The liability of the permittee for any violation of applicable requirements prior to or at the time of permit issuance;

c. The applicable requirements of the acid rain program, consistent with '408(a) of the Act; or

d. The ability of EPA to obtain information from a source pursuant to '114 of the Act.

23. Pursuant to A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, this permit

authorizes only those pollutant emitting activities addressed herein.

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APPENDIX A

APPENDIX B

APPENDIX C

APPENDIX D

Request for PDS Invoice Invoice Number (assigned when invoice printed)

PDS-

AFIN r

70-00480

Name (for confirmation only)

Del - Tin

Initial

Mod

Variance

Invoice Type (pick one) r

Annual

Renewal X

Interim Authority

Permit Number r

1714-AOP-R3

Media Code r

A

Fee Code or Pmt Typer

T5

Fee Description (for confirmation only)

Title V

Amount Due r (whole dollar amount only)

$1000

Printed Comment (600 characters maximum)

Modification as part of renewal fee minimum.

Note: The information below is for use by the requesting division if desired; it will not print on the invoice. Engineer

Paid? (yes/no)

Check number

Comments

r Required data(See "g:\Misc\PDS_FeeCodes.wpd" for descriptions and discussions of fee codes) Request submitted by:

Date:

Public Notice Pursuant to the Arkansas Operating Air Permit Program (Regulation #26) Section 602, the Air Division of the Arkansas Department of Environmental Quality gives the following notice: Del-Tin Fiber L.L.C., a limited liability company, is a joint venture between Deltic Farm and Timber Co., Inc. and Temple-Inland Forest Products Corporation. Del-Tin Fiber L.L.C. (Del-Tin), located on 395 acres southwest of El Dorado, Arkansas, is operating a manufacturing facility for medium density fiberboard (MDF)(SIC Code 2493). The finished product is used as a lumber substitute in the furniture, flooring, and molding industries. This permit is the Title V renewal permit for the facility. As part of the renewal Del-Tin requested an increase the raw material handling limit of SN-20 and an increase in the VOC limits for SN-05. The application states that modifications to the press enclosure caused more VOC to be captured than previously anticipated. The requested increase in VOC emissions required review under PSD regulations. Del-Tin also submitted an application for a minor modification to their permit. This modification added the baghouse SN-17A. This source will handle the same material as SN-17 but will allow the collected material to be transferred elsewhere in the plant. The application has been reviewed by the staff of the Department and has received the Department's tentative approval subject to the terms of this notice. Citizens wishing to examine the permit application and staff findings and recommendations may do so by contacting Doug Szenher, Public Affairs Supervisor. Citizens desiring technical information concerning the application or permit should contact Shawn Hutchings, Engineer. Both Doug Szenher and can be reached at the Department's central office, 8001 National Drive, Little Rock, Arkansas 72209, telephone: (501) 682-0744. The draft permit and permit application are available for copying at the above address. A copy of the draft permit has also been placed at the Barton Library E.Fifth & N. Jefferson, El Dorado, AR, 71730. This information may be reviewed during normal business hours. Interested or affected persons may also submit written comments or request a hearing on the proposal, or the proposed modification, to the Department at the above address - Attention: Doug Szenher. In order to be considered, the comments must be submitted within thirty (30) days of publication of this notice. Although the Department is not proposing to conduct a public hearing, one will be scheduled if significant comments on the permit provisions are received. If a hearing is scheduled, adequate public notice will be given in the newspaper of largest circulation in the county in which the facility in question is, or will be, located. The Director shall make a final decision to issue or deny this application or to impose special conditions in accordance with Section 2.1 of the Arkansas Pollution Control and Ecology Commission=s Administrative Procedures (Regulation #8) and Regulation #26. Dated this Marcus C. Devine Director

ADEQ OPERATING AIR PERMIT · PERMIT NUMBER: 1714-AOP-R3 FACILITY ADDRESS: 757 Del-Tin Highway El...

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