adeq draft operating air permit · adeq draft operating air permit pursuant to the regulations of...

63
ADEQ DRAFT OPERATING AIR PERMIT Pursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation #26: Permit #: 1533-AOP-R3 IS ISSUED TO: Temple-Inland Forest Products Corporation Route 4, 100 Temple Drive Hope, AR 71801 Hempstead County CSN: 29-0120 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: March 9, 1998 and March 8, 2003 AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Keith A. Michaels Date Modified

Upload: phammien

Post on 18-Apr-2018

217 views

Category:

Documents


2 download

TRANSCRIPT

ADEQDRAFT OPERATING

AIR PERMITPursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation #26:

Permit #: 1533-AOP-R3

IS ISSUED TO:

Temple-Inland Forest Products CorporationRoute 4, 100 Temple Drive

Hope, AR 71801Hempstead County

CSN: 29-0120

THIS PERMIT AUTHORIZES THE ABOVE REFERENCED PERMITTEE TO INSTALL,OPERATE, AND MAINTAIN THE EQUIPMENT AND EMISSION UNITS DESCRIBED INTHE PERMIT APPLICATION AND ON THE FOLLOWING PAGES. THIS PERMIT ISVALID BETWEEN:

March 9, 1998 and March 8, 2003

AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN.

Signed:

Keith A. Michaels Date Modified

2

SECTION I: FACILITY INFORMATION

PERMITTEE: Temple-Inland Forest ProductsCorporation

CSN: 29-0120PERMIT NUMBER: 1533-AOP-R3

FACILITY ADDRESS: Route 4, 100 Temple DriveHope, AR 71801

COUNTY: Hempstead

CONTACT POSITION: Mr. John CummingsTELEPHONE NUMBER: (870) 722-400

REVIEWING ENGINEER: Shawn Hutchings

UTM North-South (Y): 3733.0UTM East-West (Y): 441.4Zone 15

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

3

SECTION II: INTRODUCTION

Summary of Permit Activity

Temple-Inland Forest Products Corporation (TIFPC) (CSN:29-0120) owns and operates aparticleboard manufacturing facility on Route 4, 100 Temple Drive near Hope (HempsteadCounty) Arkansas. This modification allows for TIFPC to divert approximately 20% of theexhaust from the hot oil heater to the pre-dryer (SN-16). The exhaust is to be diverted when thepre-dryer is idle to prevent condensation buildup which causes corrosion. This modification alsoallows TIFPC to use an additive in their resin water mix known as Additive A. This additiveallows for greater penetration and absorption of the resin into the wood particles during theblending operation. Neither of these modifications will affect the facility’s permitted emissionrates.

Process Description

Temple Inland Forest Products Company’s (TIFPC's) particleboard plant in Hope, Arkansas, wasdesigned to utilize wood residue from other wood processing plants in the southwest Arkansasarea. The plant will utilize a maximum 347,600 oven-dried tons (ODT, 0% moisture content) ofwood residue annually for a 7 days/week operation with a maximum annual production rate of220,000 thousand square feet (MSF) of board per year on a 3/4 inch basis. The maximum hourlyshort term level of production for the press is 32,000 square feet (SF) of board on a 3/4 inch basisand 51.3 ODT for the primary dryers.

Raw Material Processing

All raw materials are delivered to the plant by truck then off-loaded and stored in an enclosedstorage building. TIFPC utilizes a hydraulic truck dumper with a receiving screw conveyordischarge hopper for the unloading process. All mechanical conveying is performed in anenclosed system which minimizes fugitive emissions. The truck is backed into the unloaderfacility where it is lifted and tilted backward. The raw material falls into an unloading bin that ishooded and enclosed as much as possible. This style of truck dumper reduces these fugitiveemissions. The raw materials are metered directly to the Raw Material Storage (RMS) buildingutilizing a totally enclosed conveyor. The wood residuals are stored in piles in the enclosed rawmaterial storage building. This stored material is reclaimed as needed, then conveyed to theprocess storage metering bins.

Two types of residue are used as raw material, “green” ($18% Oven Dried (OD) moisturecontent) material and “dry” (<18% moisture content OD) material. The"green” material is

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

4

primarily sawdust generated from sawmills cutting untreated lumber, whereas the "dry" materialis primarily shavings and sawdust produced when planing or cutting kiln dried lumber.

Acceptable material from the RMS building is fed to one of three storage silos; dried material,green material and dried green material which are equipped with bin vent filters (SN-27, 28 & 29respectively). Once the material is in the silos, it is conveyed to the reciprocating shaker screens,which classifies the material. Overs from the screens are conveyed to a hammermill whichrecycles material back to the screens. Dust generated at the hammermill is controlled by a smallbaghouse (SN-35). Reject material from the forming line and hogged trim material from thefinished boards are collected in a separate silo and re-enters the system to optimize materialusage.

Milling and DryingThe two screen systems produce two separate process stream flows; both core and face. Bothscreen systems deliver material via a covered conveying system to the Milling and Drying(M&D) area. The finer portion of the wood fiber is used in the surface layers of the board("face"), while the coarser material is used in the middle board layers ("core").

Face and core materials are processed through hammermills and refiners, respectively. Refiningis accomplished as the material is plug-fed by screw conveyors into the center of each of the fourrefiners and is sheared by the attrition plates. The gap spacing is determined by the type offurnish being produced. The face material leaves the screens and is sent to one of sixhammermills. The hammermills pulverize the material into smaller particle sizes which can thenbe accepted by the process. The refining process controls the geometry of the finished particleand influences both the density and weight of the board. Centrifugal force causes the material toexit the refiners. The refined material is then air conveyed through large cyclones to meteringbins that feed one of three rotary drum dryers. Exhaust from these cyclones is conveyed to four(4) large, designated baghouses (SN-03, 04, 05 & 06) for particulate control.

The green material is initially sent to a MEC Model 1360-T Predryer (SN-16) which reduces themoisture content of the material to <18%. Sander dust is burned on the No. 2 Dust Suspensionburner to provide heat for the predryer. The exhaust from the predryer is first conveyed to aprimary cyclone to remove the product. The remaining exhaust gas is then sent to a WetElectrostatic Precipitator (WESP), which is followed by an incinerator called a RegenerativeThermal Oxidizer (RTO). This system effectively reduces VOC and particulate emissions fromthis source with a control efficiency of 95% for VOC and 90% for particulates.

After the green material is dried in the predryer to approximately 15-18% moisture content, it isconveyed to the Dried Green Material Silo by way of the Predryer Return System Baghouse (SN-07). Material from the predryer is combined with purchased dried material and is further dried in

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

5

one of the three primary dryers. All three dryers are MEC Model 1248-T traditional triple passdryers.

The three rotary dryers are directly heated through a common plenum by exhaust heat generatedfrom the combustion of sander dust and/or natural gas. The flame temperatures of these burnersare usually in the 1700 0F to 2000 0F range. However, this exhaust gas is diluted and cooledimmediately upon exiting the combustion chamber with diluent air. This exhaust gas is combinedwith the exhaust from the hot oil heater system (recirculating oil system for supplying heat to thepress) which also utilizes sander dust for fuel. The rotary dryer furnace or blending box alsobrings in additional diluent air to further lower the air temperature at the entrance of the rotarydryers.

Dryer inlet air averages from 200 0F to 300 0F, and the raw material moisture content is 15-18%on average. The dryer exhaust air ranges in temperatures from 1500F to 2300F. The determiningfactor for the exhaust gas temperature is the inlet air temperature and the moisture contained inthe wood particles. The average moisture content of the wood particles after drying is 3 to 5%.The exhaust gases from each primary dryer enters a dedicated multicyclone separator.

Drying and Former Preparation

The multicyclones are designed to remove wood particles from the exhaust gas of the dryers at arelatively high efficiency. The exhaust gas from each dryer multicyclone is sent to a commonstack (SN-15). The dried material exits the bottom of the multicyclones, and is conveyed into thedry storage bins, one bin for each type of furnish, face and core. Each bin has a bin filter (SN-32and SN-33 respectively).

Material from the dry storage bins is conveyed to the blending area where a urea-formaldehyde(UF) resin (used as a thermosetting binder) is applied in a rotary mixing device. A small amountof wax emulsion is also applied at this point as a moisture inhibitor during the pressing operation.Some excess formaldehyde, which is required as part of the thermosetting chemical reaction,could potentially be released from the resin in the hot pressing operation, but is controlled withan RTO (SN-17A). Usually, a formaldehyde scavenger is used to reduce free formaldehyde. TheUF resin is stored in two storage tanks along with urea and wax storage tanks inside the building.The emissions from all these tanks are vented inside the process building and are consideredinsignificant.

Blending of the resin laden furnish is accomplished in water cooled blenders. The blenders arecooled to prevent pre-curing as the material is discharged to mechanical conveyors which carry itover to the forming line.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

6

Former and Press System

The Hope facility has a moving flexible screen forming line. This forming process is an airclassification process in which bottom face material is first placed on the moving flexible screensby a combination of gravity and induced air to form the bottom quarter of the mat. As the screenenters the former, the face furnish is blown countercurrent onto the screen. This ensures that thefinest, lightest material will blow onto the flexible screen first for a smoother finished boardsurface. As the screen reaches the end of the bottom face chamber, the larger particles fall ontothe mat to form the intermediate levels. The core chambers use gravitational discharge to spreadthe core material through the middle half of the mat. The thickness consistency is controlled byvarying the speed of the belt feeding the chamber. Finally, the top face is put on the mat in thesame manner as the bottom face, except that the air is blown in the same direction as thetraveling screens to ensure that the lightest and finest material will be the top surface of the mat.Once formed, the mat exits the former and travels the length of the line to the press. Along theway, the mat is weighed, the ends are trimmed and tramp metals are removed. The trim materialis pneumatically removed from the former and captured in a cyclone/baghouse combination (SN-8B). The captured material is recycled back to the process. Dust generated at the former iscontrolled by a separate baghouse (SN-8A).

The flexible screen system delivers the formed mats to the press loader where they areaccumulated for simultaneous loading into the hot press. The mats are pressed batchwise on theflexible screens at an average temperature of 3300F and a specific pressure of 800 psi. The heatfor the press operation is provided by the hot oil system.

The controls of the press are accomplished using computers and timing algorithms to achieveprecision and consistency. After the press has opened and the screens with the pressed board areremoved, the boards are separated from the screens. Upon release of the pressure, steam andorganic vapor is liberated. The emissions are collected within an enclosure surrounding the press.The collected vapors are sent to an RTO for reduction of VOC emissions before exiting to theatmosphere through a stack (SN-17A).

Board Finishing Operation

The flexible screens are removed from the press and the particleboard is separated from thescreens. The screens are returned to the beginning of the forming line by the underground returnline. The boards are trimmed by a series of saws that cut approximately two inches off the lengthand the width edges of the board. Dust created by the sawing operation and materials from thereject bin are conveyed to a cyclone exhaust which is controlled by a baghouse (SN-09).

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

7

The boards go to a wicket cooling station with a specified retention time to allow the board tocool and give time for the completion of the curing process. As each board cools, emissions fromthe board are ultimately vented to the atmosphere by way of three roof vents (SN-20, 21, and 22).The cut boards are sent directly to the sanders. The sanders are a multi-head type with theprimary function of removing the excess board thickness and to provide a smooth finished facefor the board. The first set of heads takes the majority of the material off the board, top andbottom, while the remaining heads remove considerably less material each time. The last headacts as a buffer to ensure high quality of the face of the finished board.

The sander dust generated in the sanding operation is collected by high suction pneumatic pickupsystems and sent through either of two baghouses. The sander dust is then pneumaticallyconveyed to the storage silos through the transfer system baghouse (SN-12). Emissions from thissilo are controlled by a bin vent filter (SN-31). The collected material is used to fuel the sanderdust burners of the predryer, the hot oil system, and primary dryers.

Following sanding, the board is cut into the desired lengths, graded for quality, sorted, stacked,and packaged for shipment.

Regulations

The facility is subject to regulation under the Arkansas Air Pollution Control Code (Air Code),the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (SIP), and theRegulations of the Arkansas Operating Air Permit Program (Title V) because it emits over 100tons per year of a criteria pollutant. The facility is also subject to regulation under 40 CFR 52.21(PSD).

The following table is a summary of emissions from the facility. Specific conditions andemissions 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.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

8

EMISSION SUMMARY

SourceNo.

Description Pollutant Emission Rates CrossReference

Pagelb/hr tpy

Total Allowable Emissions PMPM10SO2

VOCCONOx

65.165.124.

110.8107.1106.4

223.6223.6

9.5380.6424.6441.9

HAPs* Formaldehyde 2.33 7.5

Air Contaminants **

03 Refiners (2) PMPM10

0.30.3

1.01.0

20

04 Refiners (2) PMPM10

0.30.3

1.01.0

20

05 Hammermills (3) PMPM10

0.20.2

0.90.9

22

06 Hammermills (3) PMPM10

0.20.2

0.90.9

22

07 Pre-dryer ReturnSystem

PMPM10

0.30.3

1.31.3

24

08A Forming Line DustCollection

PMPM10

0.40.4

1.41.4

24

08B Formers DustCollection

PMPM10

0.40.4

1.51.5

24

09 Rough TrimMaterial Baghouse

PMPM10

0.20.2

0.70.7

44

10 #1 Sander DustCollection System

PMPM10

0.20.2

0.70.7

27

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

EMISSION SUMMARY

SourceNo.

Description Pollutant Emission Rates CrossReference

Pagelb/hr tpy

9

11 #2 Sander DustCollection System

PMPM10

0.20.2

0.70.7

27

12 Sander DustTransfer System

PMPM10

0.20.2

0.80.8

27

13 Finish Saw DustCollection

PMPM10

0.20.2

0.70.7

27

14 Trim ReturnSystem

PMPM10

0.30.3

1.01.0

27

15 Primary Dryers (3units)

PMPM10SO2

VOCCONOx

Formaldehyde

55.455.41.4

88.856.555.90.72

190.5190.5

5.6305.1234.9232.5

1.8

29

16 Pre-dryer PMPM10SO2

VOCCONOx

Formaldehyde

2.32.31.07.9

38.244.50.07

8.08.03.9

27.1140.5184.8

0.3

33

17A Press Vent RTOStack

PMPM10VOCCONOx

Formaldehyde

2.52.53.5

12.46.01.0

8.58.5

12.149.224.63.5

38

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

EMISSION SUMMARY

SourceNo.

Description Pollutant Emission Rates CrossReference

Pagelb/hr tpy

10

20Cooler Vent

PMPM10VOC

Formaldehyde

0.70.7

10.60.54

2.22.2

36.31.87

42

21

22

27 Dry Material SiloBin Vent Filter

PMPM10

0.10.1

0.30.3

44

28 Green MaterialSilo Bin Vent

Filter

PMPM10

0.10.1

0.30.3

44

29 Dried GreenMaterial

Silo Bin VentFilter

PMPM10

0.10.1

0.30.3

44

30 Dried TrimMaterial

Silo Bin VentFilter

PMPM10

0.10.1

0.30.3

44

31 Sander Dust SiloBin Vent Filter

PMPM10

0.10.1

0.30.3

44

32 Dry Face Silo BinVent Filter

PMPM10

0.10.1

0.10.1

44

33 Dry Core Silo BinVent Filter

PMPM10

0.10.1

0.10.1

44

35 Overs Hammermill PMPM10

0.10.1

0.10.1

22

* HAPs included in the VOC totals are indicated by an *. Other HAPs arenot included in any other totals unless specifically stated.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

11

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

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

12

SECTION III: PERMIT HISTORY

1533-A was issued on May 19, 1994. This was the initial air permit for the facility and containedall of the currently permitted sources, with the exception of the press vent RTO (SN-17).

1533-AR-1 was issued on December 28, 1994. This modification was issued to addressmodifications in the process which caused minor increases in emissions and also clarified therecord keeping and stack testing requirements of the facility to ensure compliance with emissionlimits. The facility took a limit of 208,000 MSF/yr of particleboard.

1533-AR-2 was issued on November 7, 1996. This permit modification addressed theinstallation of a regenerative thermal oxidizer (RTO) to control VOC emissions from the hotpress (SN-17 in the previous permit). Also the facility was allowed to burn natural gas only,which prevented the facility from being subject to PSD.

1533-AOP-R0 was issued on March 9, 1998. This permit represented the issuance of the initialRegulation #26 (Title V) permit for the facility. Also the facility was allowed to burn natural gasonly, which prevented the facility from being subject to PSD.

1533-AOP-R1 was issued on November 19, 1999. Temple-Inland modified the permit toincrease annual production to 220,000 MSF/yr, also the facility requested to burn sander dust fuelin its burners that supply heat to the primary dryers. The following tables are the BACT Analysisand PSD Review.

BACT Analysis

Predryer (SN-16)

PM/PM10 Cyclone, WESP, and RTO A facility using EFB and RTO is currently undergoing re-permittingdue to the fact that it cannot meet their permit limits, therefore thiscontrol technology should not be considered BACT. Temple’sproposal has a removal efficiency of >90% which is equal to orhigher than all other listed control technologies.

VOC RTO The RTO has a VOC removal efficiency of 95% compared to the90% removal for the RCO.

CO Good Combustion There are no instances of add-on controls required for COemissions.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

13

NOx Low NOx Burner These burners minimize thermal NOx formation by the use of lowNOx technology and temperature/combustion controls to minimize

excess air and excess temperatures.

Primary Dryers (SN-15)

PM/PM10 Multicyclone Since the moisture content of the wood to be dried is less than 18%there is nothing in the RBLC to compare it to. As part of the BACTresearch conducted for the particleboard industry, an RTO wentthrough the top-down analysis and was eliminated due tounacceptable economic impacts ($11,429/ton removed).

VOC No Control An RTO went through the top-down analysis and was eliminateddue to an unacceptable economic impact of $11,429/ton VOCremoved. RCO to reduce VOC emissions has yet to be installed andits efficiency has not yet been demonstrated. Scrubbers in the woodproducts industry are virtually nonexistent. One reason is theprocess off gas streams is generally associated with high molecularweight organics and therefore would have minimal impact on thesetype of organics, effecting the unit’s overall efficiency. Activatedcarbon absorption is likely to plug up due to high flowrates,particulate loading, and condensable organics. Also, the use of thistechnology for certain organics could result in the generation ofhazardous waste.

CO Good Combustion There are no listings in the RBLC for CO emissions associated withparticleboard facilities.

NOx Good Combustion The only listings in the RBLC is for Low NOx Burners on a gasfired dryer. Since the facility is going to burn sander dust as theprimary fuel there is no technology for the control of NOxemissions using Low NOx Burners.

Press (SN-17)

PM/PM10 RTO All entries in the RBLC have an RTO installed on the press.

VOC RTO All entries in the RBLC have an RTO installed on the press.

CO Good Combustion There are no listings in the RBLC for CO emissions associated withparticleboard facilities.

NOx Low NOx Burners These burners minimize thermal NOx formation by the use of lowNOx technology and temperature/combustion controls to minimizeexcess air and excess temperatures.

Cooling Wheel (SN-20, 21, and 22)

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

14

PM/PM10 No Control There are no listings in the RBLC for PM/PM10 emissionsassociated with Cooling Wheels.

VOC No Control There are no listings in the RBLC for VOC emissions associatedwith Cooling Wheels.

Material Handling and Transferring Operations

PM/PM10 Baghouses Baghouses have a 99.9% removal efficiency.

Maximum Predicted Concentrations with Backgroundin Comparison with the NAAQS

Pollutant Averaging Period Concentrationwith Background

(Fg/m3)

NAAQS(Fg/m3)

PM10

24-hour 104.72 150

Annual 32.64 50

NOX Annual 39.65 100

Maximum Predicted Increment Consumedin Comparison with the PSD Increment

Pollutant Averaging Period Increment Consumed(Fg/m3)

PSD Increment(Fg/m3)

PM10

24-hour 22.13* 30

Annual 6.24 17

NOX Annual 17.66 25* Used the “Highest Sixth High”.

The following table shows the RPM results for three scenarios: ambient level ozone,biogenic+ambient level ozone, and facility+biogenic+ambient level ozone. The three scenarioswere modeled in order to show the contribution from a) no emission sources (ambient), b)biogenic sources, and c) facility sources. The final scenario contains all three types of ozonecontributors and is compared to the ozone NAAQS of 0.12 ppm, 1-hour average. Because theRPM gives 1-hour averages, the model results have been converted to 8-hour averages using themultiplying factor listed in Section 4 of EPA’s Screening Procedures for Estimating the Air

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

15

Quality Impact of Stationary Sources, Revised, dated October 1992. The equation to convert a 1-hour average to an 8-hour average is:x ppm (1-hr) * 0.7 = y ppm (8-hr).

Ozone Reactive Plume Model (RPM) Results

Model Run MaximumDownwind

Distance (km)

Averaging Period Concentration(ppm)

NAAQS(ppm)

Ambient 43.038-hour 0.02183 0.08

1-hour 0.03119 0.12

Ambient +Biogenic

44.76 8-hour 0.02264 0.08

1-hour 0.03234 0.12

Ambient +Biogenic+

Facility

44.63 8-hour 0.02255 0.08

1-hour 0.03222 0.12

The U.S. EPA has established special PSD Increment values for Class I areas for three criteriapollutants (PM10, SO2 and NOX). An air dispersion modeling analysis is performed to determineif the emissions from the proposed facility will impact the ambient air quality in the vicinity ofCaney Creek. The modeling results indicate that the 24-hour average concentration for eachpollutant is less than the 1.0 Fg/m3 Class I MSL. Thus, no further dispersion modeling analysisto evaluate impacts at Caney Creek is warranted. The modeling results can be found in thefollowing table.

Pollutant Short TermHighest Concentration

(Fg/m3)

Long TermHighest Concentration

(Fg/m3)

PM10 0.11 0.02

NOx 0.16* 0.04

* A multiplier of 4 was used to convert the annual concentration to a 24 hour concentration

Permit 1533-AOP-R2 was issued to Temple-Inland on April 17, 2000. This modification was torelocate the primary dryers stack to a position approximately 8 meters to the east of its existinglocation. The height of the stack will be increased to 150 feet.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

16

There were two administrative amendments to permit 1533-AOP-R2. The first was issued onAugust 2, 2000 corrected the stack height listed in Specific Condition 26 and corrected theSpecific Condition numbering. The second was issued on February 19, 2001corrected SpecificCondition 13 to reference the correct sources.

PSD Issues Associated with 1533-AOP-R2

The purpose of the modification is to revise the primary dryer stack location. Temple Inlandintends to relocate the stack to a position approximately 8 meters to the east to its existinglocation. The height of the stack will be increased to 150 feet. All required elements of the PSDair quality analysis were done. The following tables indicate the changes in the maximumconcentrations and predicted increment consumed. All other sections such as the OzoneAnalysis, Class I Area Analysis, and Toxics Impact have remained unchanged and are notexpanded upon in this section.

NAAQS Analysis

The NAAQS are maximum concentration “ceilings” measured in terms of the total concentrationof pollutant in the atmosphere. In the NAAQS analysis, the proposed facility’s emission iscombined with those from other nearby sources that have the potential to contribute significantlyto receptors within the facility’s radius of impact (ROI).

Once the screening analysis is completed, the combined emissions are then modeled. Theresulting impacts are summed with a representative background concentration and then arecompared to the corresponding NAAQS to demonstrate compliance with these criteria. Theresults of the NAAQS analysis are contained in the following table.

Maximum Predicted Concentrations with Backgroundin Comparison with the NAAQS

Pollutant Averaging Period Concentrationwith Background

(Fg/m3)

NAAQS(Fg/m3)

PM10

24-hour 81.93 150

Annual 33.31 50

NOX Annual 39.93 100

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

17

The plants emissions will not exceed the NAAQS and therefore the facility demonstratescompliance with this Standard.

PSD Increment Analysis

In the PSD Increment analysis, creditable emissions increases and decreases from all increment-affected sources located within the baseline area established for each pollutant are modeled withthe facility’s proposed emissions increase to demonstrate compliance with the correspondingPSD Increments. The results of the PSD Increment analysis are contained in the following table.

Maximum Predicted Increment Consumedin Comparison with the PSD Increment

Pollutant Averaging Period Increment Consumed(Fg/m3)

PSD Increment(Fg/m3)

PM10

24-hour 28.79* 30

Annual 6.91 17

NOX Annual 18.32 25* Used the “Highest Sixth High”.

The proposed increment consumed can never exceed the PSD Increment levels set by the EPA.

According to Arkansas regulation §19.904(c)(4), when air quality analyses for the issuance of apermit for any major stationary source would result in the consumption of more than 80% of anyshort term increment or greater than 50% of the available long term increment, the permitteeshall submit to the Department an assessment of the following factors: (i) effects that theproposed consumption would have upon the industrial and economic development within thearea of the proposed source; and (ii) alternatives to such consumption, including alternative sitingof the proposed source or portions thereof. The proposed increase will not consume greater than80% of the short term increment; however, more than 50% of the available NOx long termincrement will be consumed. Therefore the above mentioned analysis is required.

C The location of concentrations of NOX greater than 12.5 Fg/m3 (50% of the available longterm increment) occur either immediately on the fenceline or within 300 meters of thefacility. PM10 concentrations greater that 24 Fg/m3 (80% of any short term increment)occur either immediately on the fenceline or within 30 meters of the fenceline. Industrialgrowth will not be hampered in those areas in the immediate future since from thefenceline to 300 meters to the south is an industrial facility, which sells all of its product

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

18

to Temple, and from the fenceline to 300 meters to the north is an abandoned World WarII military installation. The abandoned World War II military installation is a formerartillery test range with unexploded shells throughout the area. Any industrial expansionaround this site would require an extensive and time consuming reclamation project tomake the area safe. Any such project would extend well beyond the life of this permit. Therefore, the industrial growth in the area will not be hampered in the near future.

C Since the facility has already been constructed, alternative siting will not be possible.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

SECTION IV: EMISSION UNIT INFORMATION

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

20

SN-03 and SN-04Refiners (4)

Source Description

Raw material from the silos is classified by reciprocating shaker screens for use in themanufacturing process. Two size streams of material are created by the screening process. Thelarger material is sent to the hammermills for further size reduction, while other material is sentto the Mill & Drying area to be used in the creation of the particleboard. Emissions generated bythe refining of the wood residue by size are controlled by two cyclones. The exhaust from thesecyclones is further controlled by a pair of baghouses (SN-03 and SN-04).

Specific Conditions

1. Pursuant to §19.501 and §19.901 et seq of the Regulations of the Arkansas StateImplementation Plan for Air Pollution Control (Regulation #19) effective February 15,1999, and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission ratesset forth in the following table. The lb/hr emissions are based upon maximum operatingcapacity of the control equipment. The tpy emissions will be demonstrated by complyingwith Specific Condition 3 and Plantwide Condition 7.

SN Pollutant lb/hr tpy

03 PMPM10

0.30.3

1.01.0

04 PMPM10

0.30.3

1.01.0

2. Pursuant to §18.501 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed 5% opacity from sources SN-03 and SN-04as measured by EPA Reference Method 9. Compliance with this condition will bedemonstrated by complying with Specific Condition 3.

3. Pursuant to §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part 52, Subpart E, andA.C.A. §8- 4-203 as referenced by §8-4-304 and §8-4-311, the permittee shall be limitedto a pressure drop of 0.5 - 6.0 inches H2O at sources SN-03 and SN-04.

4. Pursuant to §19.705 and §19.901 et seq of Regulation 19, and 40 CFR Part 52, Subpart E,the permittee shall take weekly readings of the pressure drop at sources SN-03 and SN-

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

21

04. If the pressure drop is not within the permitted limit, immediate action is to be takento identify the cause of the excursion, implement corrective action, and document that thepressure drop does not appear to be out of the permitted range following the correctiveaction. The permittee shall maintain records of any excursions, the corrective actiontaken, and procedures to prevent the excursion from recurring. These records shall bekept on site and made available to Department personnel upon request.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

22

SN-05, 06, and 35Hammermills

Source Description

The primary hammermills are used to reduce the size of acceptable screened materials for use inthe formation of the outer edges (“face”) of the particleboard sheets. Emissions from these twohammermills are controlled by two baghouses (SN-05, SN-06).

The overs hammermill is used to reduce the size of unacceptable screened materials. Emissionsfrom this hammermill are controlled by a baghouse (SN-35).

Specific Conditions

5. Pursuant to §19.501 et seq and §19.901 et seq of the Regulations of the Arkansas StateImplementation Plan for Air Pollution Control (Regulation #19) effective February 15,1999, and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission ratesset forth in the following table. The lb/hr emissions are based upon maximum operatingcapacity of the control equipment. The tpy emissions will be demonstrated by complyingwith Specific Condition 7 and Plantwide Condition 7.

SN Pollutant lb/hr tpy

05 PMPM10

0.20.2

0.90.9

06 PMPM10

0.20.2

0.90.9

35 PMPM10

0.10.1

0.10.1

6. Pursuant to §18.501 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed 5% opacity from sources SN-05, SN-06 andSN-35 as measured by EPA Reference Method 9. Compliance with this condition will bedemonstrated by complying with Specific Condition 7.

7. Pursuant to §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part 52, Subpart E, andA.C.A. §8- 4-203 as referenced by §8-4-304 and §8-4-311, the permittee shall be limitedto a pressure drop of 0.5 - 6.0 inches H2O at sources SN-05, SN-06, and SN-35.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

23

8. Pursuant to §19.705 and §19.901 et seq of Regulation 19, and 40 CFR Part 52, Subpart E,the permittee shall take weekly readings of the pressure drop at sources SN-05, SN-06and SN-35. If the pressure drop is not within the permitted limit, immediate action is tobe taken to identify the cause of the excursion, implement corrective action, anddocument that the pressure drop does not appear to be out of the permitted rangefollowing the corrective action. The permittee shall maintain records of any excursions,the corrective action taken, and procedures to prevent the excursion from recurring. These records shall be kept on site and made available to Department personnel uponrequest.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

24

SN-07Pre-dryer Return System

SN-08A and SN-08BForming Line and Formers Dust Collection

Source Description

Two baghouses (SN-08A and SN-08B) collect dust from the forming line where the sheets ofparticleboard are first formed and trimmed from the wood residue, before entering the press.

Compliance Assurance Monitoring

The Compliance Assurance Monitoring (CAM) rule applies to any pollutant specific emissionunit that (1) is subject to an emission limitation or standard, (2) uses a control device to achievecompliance with the emission limitation or standard, and (3) has potential pre-control emissionsof the regulated pollutant that exceed or are equivalent to the major source threshold of 100 tpyper pollutant.

The predryer return system baghouse (SN-07), forming line dust collection baghouse (SN-08A),and formers dust collection baghouse (SN-08B) have pre-control PM10 emissions of 117.0,129.0, and 137.0 tpy respectively. Daily opacity and pressure drop readings will be done toinsure that control measures are properly operated and maintained. If the threshold levels set inthe permit are exceeded by greater than 5% of the unit’s total operating time, the facility isrequired to prepare a Quality Improvement Plan (QIP).

A Quality Improvement Plan is a written plan that outlines the procedures that will be used toevaluate problems that effect the performance of control equipment. The Department requires asource to develop and implement a QIP after a determination that the source has failed to useacceptable procedures in responding to an exceedance.

Specific Conditions

9. Pursuant to §19.501 et seq and §19.901 et seq of the Regulations of the Arkansas StateImplementation Plan for Air Pollution Control (Regulation #19) effective February 15,1999, and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission ratesset forth in the following table. The lb/hr emissions are based upon maximum operatingcapacity of the control equipment. The tpy emissions and CAM compliance will bedemonstrated by complying with Specific Conditions 10 and 11 and Plantwide Condition7.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

25

SN Pollutant lb/hr tpy

07 PMPM10

0.30.3

1.31.3

08A PMPM10

0.40.4

1.41.4

08B PMPM10

0.40.4

1.51.5

10. Pursuant to 40 CFR Part 64, §19.503 (Regulation 19) and 40 CFR Part 52, Subpart E, thepermittee shall not exceed 5% opacity from sources SN-07, SN-08A and SN-08B asmeasured by EPA Reference Method 9. Compliance with this condition will bedemonstrated by complying with Specific Condition 11.

11. Pursuant to 40 CFR Part 64, §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part52, Subpart E, and A.C.A. §8- 4-203 as referenced by §8-4-304 and §8-4-311, thepermittee shall be limited to a pressure drop of 0.5 - 6.0 inches H2O at sources SN-07,SN-08A, and SN-08B.

12. Pursuant to 40 CFR Part 64, §19.705 and §19.901 et seq of Regulation 19, and 40 CFRPart 52, Subpart E, the permittee shall take daily readings of the pressure drop at sourcesSN-07, SN-08A and SN-08B. If the pressure drop is not within the permitted limit,immediate action is to be taken to identify the cause of the excursion, implementcorrective action, and document that the pressure drop does not appear to be out of thepermitted range following the corrective action. The permittee shall maintain records ofany excursions, the corrective action taken, and procedures to prevent the excursion fromrecurring. These records shall be kept on site and made available to Departmentpersonnel upon request.

13. Pursuant to 40 CFR Part 64, the permittee shall record the number of excursions that haveoccurred at sources SN-07, SN-08A and SN-08B. for opacity and pressure drop. If thereare nine (9) excursions in a six month period for opacity or pressure drop the facility willbe required to submit a Quality Improvement Plan (QIP). The QIP should provide thefollowing information:

1. procedures to improve the quality of control performance;

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

26

2. procedures that will be implemented to reduce the probability of a recurrence ofthe problem;

3. a schedule for making such improvements.

These records and QIP shall be kept on site and made available to Department personnelupon request.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

27

SN-10 and SN-11#1 and #2 Sander Dust Collection System

SN-12Sander Dust Transfer System

SN-13Finish Saw Dust Collection

SN-14Trim Return System

Source Description

Five baghouses collect waste material from the finishing of pressed and cooled particleboardsheets. These include the collection of sander dust from sanding operations (SN-10 and SN-11),the return of sander dust to the manufacturing process (SN-12), and collection of finish saw dust(SN-13) and trim waste material (SN-14).

Specific Conditions

14. Pursuant to §19.501 et seq and §19.901 et seq of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation #19) effective February 15, 1999and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forthin the following table. The lb/hr emissions are based upon maximum operating capacityof the control equipment. The tpy emissions will be demonstrated by complying withSpecific Condition 16 and Plantwide Condition 7.

SN Pollutant lb/hr tpy

10 and 11 PMPM10

0.40.4

1.41.4

12 PMPM10

0.20.2

0.80.8

13 PMPM10

0.20.2

0.70.7

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

SN Pollutant lb/hr tpy

28

14 PMPM10

0.30.3

1.01.0

15. Pursuant to §18.501 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed 5% opacity from sources SN-10 throughSN-14 as measured by EPA Reference Method 9. Compliance with this condition will bedemonstrated by complying with Specific Condition 16.

16. Pursuant to §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part 52, Subpart E, andA.C.A. §8- 4-203 as referenced by §8-4-304 and §8-4-311, the permittee shall be limitedto a pressure drop of 0.5 - 6.0 inches H2O at sources SN-10 through SN-14.

17. Pursuant to §19.705 and §19.901 et seq of Regulation 19, and 40 CFR Part 52, Subpart E,the permittee shall take weekly readings of the pressure drop at sources SN-10 and SN-14. If the pressure drop is not within the permitted limit, immediate action is to be takento identify the cause of the excursion, implement corrective action, and document that thepressure drop does not appear to be out of the permitted range following the correctiveaction. The permittee shall maintain records of any excursions, the corrective actiontaken, and procedures to prevent the excursion from recurring. These records shall bekept on site and made available to Department personnel upon request.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

29

SN-15Primary Dryers (3 units)

Source Description

The three 58 million Btu per hour primary dryers are used to further reduce the moisture contentof the dry wood residue before it is used in the manufacturing process. Emissions from the threedryers are controlled by three multi-cyclones. The exhaust air from these multi-cyclones isvented to the atmosphere by a common stack (SN-15). The facility is permitted to use sanderdust as the primary fuel. The facility is required to increase the height of the stack to 150 feetand relocate it 8 meters east of its current position so as to ensure compliance with the modelingstandard.

The permittee will be allowed to operate the facility at 25.5 MSF/hr until the Primary Dryer stackis modified. During this interim period the facility will be limited to burning only natural gas atthe Primary Dryer. The facility has provided modeling showing that concentrations will notexceed the maximum predicted concentrations as listed in the table on page 14 of this permit. The facility will be required to meet the Interim Specific Conditions as well as the SpecificConditions listed in this section. Once the Primary Dryer stack is modified the permittee will notbe required to meet the conditions listed in the Interim Specific Conditions section.

Compliance Assurance Monitoring

The Compliance Assurance Monitoring (CAM) rule applies to any pollutant specific emissionunit that (1) is subject to an emission limitation or standard, (2) uses a control device to achievecompliance with the emission limitation or standard, and (3) has potential pre-control emissionsof the regulated pollutant that exceed or are equivalent to the major source threshold of 100 tpyper pollutant.

The primary dryers (SN-15) have pre-control PM10 emissions of 1269.4 tpy. Daily opacityreadings and continuous outlet flowrates for the multicyclone will be used to insure the controlmeasures are properly operated and maintained. If the threshold levels set in the permit areexceeded greater than 5% of the unit’s total operating time, the facility is required to prepare aQuality Improvement Plan (QIP).

A Quality Improvement Plan is a written plan that outlines the procedures that will be used toevaluate problems that effect the performance of control equipment. The Department requires asource to develop and implement a QIP after a determination that the source has failed to useacceptable procedures in responding to an exceedance.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

30

Specific Conditions

18. 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 Part52, Subpart E, the permittee shall not exceed the emission rates set forth in the followingtable. The lb/hr emissions are based upon maximum operating capacity of the controlequipment. The tpy emissions and CAM compliance will be demonstrated by complyingwith Specific Conditions 21 and 25 and Plantwide Condition 7.

Pollutant lb/hr tpy

PMPM10

55.455.4

190.5190.5

SO2 1.4 5.6

VOC 88.8 305.1

CO 56.5 234.9

NOX 55.9 232.5

19. Pursuant to §19.501 et seq and §19.901 et seq of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation #19) effective February 15, 1999and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forthin the following table. The lb/hr emissions are based upon maximum operating capacityof the control equipment. The tpy emissions and CAM compliance will be demonstratedby complying with Specific Conditions 21 and 25 and Plantwide Condition 7.

Pollutant lb/hr tpy

PMPM10

55.455.4

190.5190.5

VOC 88.8 305.1

CO 56.5 234.9

NOX 55.9 232.5

20. 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

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

31

§8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated by Plantwide Condition 9.

Pollutant lb/hr tpy

Formaldehyde 0.72 1.8

21. Pursuant to §19.503 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shallnot exceed 20% opacity from sources SN-15 as measured by EPA Reference Method 9.

22. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, daily observationsof the opacity from source SN-15 shall be conducted by a person trained in EPAReference Method 9. If visible emissions appear to be in excess of 20%, the permitteeshall immediately take action to identify the cause of the excess visible emissions,implement corrective action, and document that visible emissions do not appear to be inexcess of the permitted opacity following the corrective action. The permittee shallmaintain records of any visible emissions which appeared to be in excess of the permittedopacity, the corrective action taken, and if visible emissions were present following thecorrective action. These records shall be kept on site and made available to Departmentpersonnel upon request.

23. Pursuant to §19.705 and §19.901 et seq of Regulation 19, A.C.A. §8-4-203 as referencedby §8-4-304 and §8-4-311, and 40 CFR 70.6, within 180 days of issuance of this permitthe permittee shall increase the height of the stack (SN-15) to 150 feet and relocate it 8meters east of its current position.

24. Pursuant to §19.705 and §19.901 et seq of Regulation 19, and 40 CFR Part 52, Subpart E,the facility shall notify the Department upon completion of the stack modification.

25. Pursuant to 40 CFR Part 64, §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part52, Subpart E, and A.C.A. §8- 4-203 as referenced by §8-4-304 and §8-4-311, thepermittee shall not have an outlet flowrate less than 40,000 ft3/min at source SN-15.

26. Pursuant to 40 CFR Part §19.705 of Regulation 19, and 40 CFR Part 52, Subpart E, thepermittee shall use continuous monitoring of the outlet flowrate for source SN-15. If theoutlet flowrate is below the permitted limit, immediate action is to be taken to identify thecause of the excursion, implement corrective action, and document that the outletflowrate does not appear to be out of the permitted range following the corrective action. The permittee shall maintain records of any excursions, the corrective action taken, and

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

3232

procedures to prevent the excursion from recurring. These records shall be kept on siteand made available to Department personnel upon request.

27. Pursuant to 40 CFR Part 64, the permittee shall record the number of excursions that haveoccurred at SN-15 for opacity and outlet flowrate. If there are nine (9) excursions in a sixmonth period for opacity or outlet flowrate the facility will be required to submit aQuality Improvement Plan (QIP). The QIP should provide the following information:

1. procedures to improve the quality of control performance;2. procedures that will be implemented to reduce the probability of a recurrence of

the problem;3. a schedule for making such improvements.

These records and QIP shall be kept on site and made available to Department personnelupon request.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

3333

SN-16Pre-dryer

Source Description

The 39 million Btu per hour pre-dryer (SN-16) is used to remove moisture from the green woodresidue. Once this is accomplished, the dried wood residue is sent back to a storage silo to beused later in the manufacturing process. Emissions from the pre-dryer are sent through acyclone, wet electrostatic precipitator (WESP), and finally through to a regenerative thermaloxidizer (RTO) for reduction. The facility is permitted to use sander dust as the primary fuel forthe pre-dryer and natural gas for the RTO.

While the pre-dryer is not in operation 20% of the exhaust from the hot oil heater can be routedthrough the pre-dryer to prevent condensation buildup which causes corrosion. While the hot oilheaters emissions are being routed through the pre-dryer TIFPC will continue to operate the wetESP but will not operate the RTO as a control device.

Compliance Assurance Monitoring

The Compliance Assurance Monitoring (CAM) rule applies to any pollutant specific emissionunit that (1) is subject to an emission limitation or standard, (2) uses a control device to achievecompliance with the emission limitation or standard, and (3) has potential pre-control emissionsof the regulated pollutant that exceed or are equivalent to the major source threshold of 100 tpyper pollutant.

The predryer (SN-16) has pre-control VOC and PM10 emissions of 541.0 and 396.0 tpyrespectively. Daily opacity readings, average voltage reading for the WESP, average combustionzone temperature at the RTO, and the average inlet static pressure to insure the control measuresare properly operated and maintained. If the threshold levels set in the permit are exceededgreater than 5% of the unit’s total operating time, the facility is required to prepare a QualityImprovement Plan (QIP).

A Quality Improvement Plan is a written plan that outlines the procedures that will be used toevaluate problems that effect the performance of control equipment. The Department requires asource to develop and implement a QIP after a determination that the source has failed to useacceptable procedures in responding to an exceedance.

Specific Conditions

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

3434

28. 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 Part52, Subpart E, the permittee shall not exceed the emission rates set forth in the followingtable. The lb/hr emissions are based upon maximum operating capacity of the controlequipment. The tpy emissions and CAM compliance will be demonstrated by

complying with Specific Conditions 31, 36, 38, and 39 andPlantwide Condition 7.

Pollutant lb/hr tpy

PMPM10

2.32.3

8.08.0

SO2 1.0 3.9

VOC 7.9 27.1

CO 38.2 140.5

NOX 44.5 184.8

29. Pursuant to §19.501 et seq and §19.901 et seq of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation #19) effective February 15, 1999and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forthin the following table. The lb/hr emissions are based upon maximum operating capacityof the control equipment. The tpy emissions and CAM compliance will be demonstratedby complying with Specific Conditions 31, 36, 38, and 39 and Plantwide Condition 7.

Pollutant lb/hr tpy

PMPM10

2.32.3

8.08.0

VOC 7.9 27.1

CO 38.2 140.5

NOX 44.5 184.8

30. 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

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

3535

§8-4-311, the permittee shall not exceed the emission rates set forth in the followingtable. Compliance with this condition will be demonstrated by Plantwide Condition 9.

Pollutant lb/hr tpy

Formaldehyde 0.07 0.3

31. Pursuant to § 19.503 (Regulation 19) and 40 CFR Part 52, Subpart E, the permittee shallnot exceed 20% opacity from sources SN-16 as measured by EPA Reference Method 9.

32. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, daily observationsof the opacity from source SN-16 shall be conducted by a person trained in EPAReference Method 9. If visible emissions appear to be in excess of 20%, the permitteeshall immediately take action to identify the cause of the excess visible emissions,implement corrective action, and document that visible emissions do not appear to be inexcess of the permitted opacity following the corrective action. The permittee shallmaintain records of any visible emissions which appeared to be in excess of the permittedopacity, the corrective action taken, and if visible emissions were present following thecorrective action. These records shall be kept on site and made available to Departmentpersonnel upon request.

33. Pursuant to §19.705 and §19.901 et seq of Regulation 19, A.C.A. §8-4-203 as referencedby §8-4-304 and §8-4-311, and 40 CFR 70.6, within 60 days of issuance of this permit thepermittee shall increase the height of the stack (SN-16) to 50 feet.

34. Pursuant to §19.705 and §19.901 et seq of Regulation 19, and 40 CFR Part 52, Subpart E,the facility shall notify the Department upon completion of the stack modification.

35. Pursuant to §19.702 of Regulation #19, 19.901 et seq, and 40 CFR Part 52, Subpart E, thepermittee shall test the RTO (SN-16) each year for PM10, NOX, CO, and VOC emissionsusing EPA Reference Methods 5, 7E, 10, and 25A respectively, and for opacity usingEPA Reference Method 9. These tests shall be performed simultaneously. Whileperforming the tests, the dryer shall be operating at least 90% of the maximum throughputrate. If testing is conducted at a rate lower than 90%, the facility shall be limited to anoperating rate of 110% of the tested rate until compliance at a higher rate is demonstrated. The permittee shall submit a written testing protocol to the Compliance Section Managerat least 15 days prior to any scheduled test. If the facility passes three consecutive testsfor this source, the permittee may apply for less stringent testing.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

3636

36. Pursuant to 40 CFR Part 64, §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part52, Subpart E, and A.C.A. §8- 4-203 as referenced by §8-4-304 and §8-4-311, theminimum voltage for the WESP shall not fall below 20 kV.

37. Pursuant to 40 CFR Part 64, §19.705 and §19.901 et seq of Regulation 19, and 40 CFRPart 52, Subpart E, the permittee shall use continuous monitoring of the voltage for theWESP (SN-16). If the voltage is below the permitted limit, immediate action is to betaken to identify the cause of the excursion, implement corrective action, and documentthat the voltage does not appear to be below the permitted limit following the correctiveaction. The permittee shall maintain records of any excursions, the corrective actiontaken, and procedures to prevent the excursion from recurring. These records shall bekept on site and made available to Department personnel upon request.

38. Pursuant to 40 CFR Part 64, §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part52, Subpart E, and A.C.A. §8- 4-203 as referenced by §8-4-304 and §8-4-311, theminimum combustion zone temperature shall not fall below 1450oF.

39. Pursuant to 40 CFR Part 64, §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part52, Subpart E, and A.C.A. §8- 4-203 as referenced by §8-4-304 and §8-4-311, themaximum inlet static pressure reading shall not exceed 5 inches H2O.

40. Pursuant to 40 CFR Part 64, §19.705 and §19.901 et seq of Regulation 19, and 40 CFRPart 52, Subpart E, the permittee shall use continuous monitoring of the combustion zonetemperature and inlet static pressure at source SN-16. If the combustion zonetemperature and inlet static pressure is not within the permitted limit, immediate action isto be taken to identify the cause of the excursion, implement corrective action, anddocument that the pressure drop does not appear to be out of the permitted rangefollowing the corrective action. The permittee shall maintain records of any excursions,the corrective action taken, and procedures to prevent the excursion from recurring. These records shall be kept on site and made available to Department personnel uponrequest.

41. Pursuant to 40 CFR Part 64, the permittee shall record the number of excursions that haveoccurred at SN-16 for opacity, voltage, combustion zone temperature, and inlet staticpressure. If there are nine (9) excursions in a six month period for opacity, combustionzone temperature, or inlet static pressure the facility will be required to submit a QualityImprovement Plan (QIP). The QIP should provide the following information:

1. procedures to improve the quality of control performance;

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

3737

2. procedures that will be implemented to reduce the probability of a recurrence ofthe problem;

3. a schedule for making such improvements.

These records and QIP shall be kept on site and made available to Department personnelupon request.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

3838

SN-17APress Vent RTO Stack

Source Description

Formed sheets of wood residue and thermosetting resin, called mats, are sent to the press loaderby a flexible screen system and loaded into the hot press. Heat for the press is supplied by arecirculating hot oil system which is heated by a wood burner (the exhaust from this burner isvented through the primary dryers). A large vent hood enclosing the hot press collects VOCemissions and routes them to a regenerative thermal oxidizer (RTO) for reduction before beingemitted to the atmosphere.

Compliance Assurance Monitoring

The Compliance Assurance Monitoring (CAM) rule applies to any pollutant specific emissionunit that (1) is subject to an emission limitation or standard, (2) uses a control device to achievecompliance with the emission limitation or standard, and (3) has potential pre-control emissionsof the regulated pollutant that exceed or are equivalent to the major source threshold of 100 tpyper pollutant.

The RTO vent stack (SN-17A) has pre-control VOC emissions of 241.0 tpy. Combustion zonetemperature and inlet static pressure readings will be made continuously, also daily opacityreadings will be used to insure the control measures are properly operated and maintained. If thethreshold levels set in the permit are exceeded greater than 5% of the unit’s total operating time,the facility is required to prepare a Quality Improvement Plan (QIP).

A Quality Improvement Plan is a written plan that outlines the procedures that will be used toevaluate problems that effect the performance of control equipment. The Department requires asource to develop and implement a QIP after a determination that the source has failed to useacceptable procedures in responding to an exceedance.

Specific Conditions

42. Pursuant to §19.501 et seq and §19.901 et seq of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation #19) effective February 15, 1999and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forthin the following table. The lb/hr emissions are based upon maximum operating capacityof the control equipment. The tpy emissions and CAM compliance will be demonstratedby complying with Specific Conditions 44, 47, and 48 and Plantwide Condition 7.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

3939

Pollutant lb/hr tpy

PMPM10

2.52.5

8.58.5

VOC 3.5 12.1

CO 12.4 49.2

NOX 6.0 24.6

43. 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 followingtable. Compliance with this condition will be demonstrated by Plantwide Condition 9.

Pollutant lb/hr tpy

Formaldehyde 1.0 3.5

44. Pursuant to § 19.503 (Regulation 19) and 40 CFR Part 52, Subpart E, the permittee shallnot exceed 20% opacity from sources SN-17A as measured by EPA Reference Method 9.

45. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, daily observationsof the opacity from source SN-17A shall be conducted by a person trained in EPAReference Method 9. If visible emissions appear to be in excess of 20%, the permitteeshall immediately take action to identify the cause of the excess visible emissions,implement corrective action, and document that visible emissions do not appear to be inexcess of the permitted opacity following the corrective action. The permittee shallmaintain records of any visible emissions which appeared to be in excess of the permittedopacity, the corrective action taken, and if visible emissions were present following thecorrective action. These records shall be kept on site and made available to Departmentpersonnel upon request.

46. Pursuant to §19.702 of Regulation #19, 19.901 et seq, and 40 CFR Part 52, Subpart E, thepermittee shall test the RTO in SN-17A each year for PM10, NOX, CO, and VOCemissions using EPA Reference Methods 5, 7E, 10, and 25A respectively, and for opacityusing EPA Reference Method 9. These tests shall be performed simultaneously. Whileperforming the tests, the press shall be operating at least 90% of the maximum throughputrate. If testing is conducted at a rate lower than 90%, the facility shall be limited to an

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

4040

operating rate of 110% of the tested rate until compliance at a higher rate is demonstrated. The permittee shall submit a written testing protocol to the Compliance Section Managerat least 15 days prior to any scheduled test. If the facility passes three consecutive testsfor this source, the permittee may apply for less stringent testing.

47. Pursuant to 40 CFR Part 64, §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part52, Subpart E, and A.C.A. §8- 4-203 as referenced by §8-4-304 and §8-4-311, theminimum combustion zone temperature shall not fall below 1450oF.

48. Pursuant to 40 CFR Part 64, §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part52, Subpart E, and A.C.A. §8- 4-203 as referenced by §8-4-304 and §8-4-311, themaximum inlet static pressure reading shall not exceed 5 inches H2O.

49. Pursuant to 40 CFR Part 64, §19.705 and §19.901 et seq of Regulation 19, and 40 CFRPart 52, Subpart E, the permittee shall use continuous monitoring of the combustion zonetemperature and inlet static pressure at sources SN-17A. If the combustion zonetemperature and inlet static pressure is not within the permitted limit, immediate action isto be taken to identify the cause of the excursion, implement corrective action, anddocument that the pressure drop does not appear to be out of the permitted rangefollowing the corrective action. The permittee shall maintain records of any excursions,the corrective action taken, and procedures to prevent the excursion from recurring. These records shall be kept on site and made available to Department personnel uponrequest.

50. Pursuant to 40 CFR Part 64, the permittee shall record the number of excursions that haveoccurred at SN-17A for opacity, combustion zone temperature, and inlet static pressure. If there are nine (9) excursions in a six month period for opacity, combustion zonetemperature, or inlet static pressure the facility will be required to submit a QualityImprovement Plan (QIP). The QIP should provide the following information:

1. procedures to improve the quality of control performance;2. procedures that will be implemented to reduce the probability of a recurrence of

the problem;3. a schedule for making such improvements.

These records and QIP shall be kept on site and made available to Department personnelupon request.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

4141

SN-20, SN-21, and SN-22Cooler Vent

Source Description

Particleboard sheets are removed from the hot press and allowed to cool and cure beforetrimming and/or cutting to size specifications. VOC emissions during this cooling process areemitted directly to the atmosphere through the cooler vents (SN-20 through SN-22).

Specific Conditions

51. Pursuant to §19.501 et seq and §19.901 et seq of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation #19) effective February 15, 1999and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forthin the following table. Compliance with this condition will be demonstrated byPlantwide Conditions 7 and 9.

SN Pollutant lb/hr tpy

202122

PMPM10VOC

0.70.7

10.6

2.22.2

36.3

52. 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 followingtable. Compliance with this condition will be demonstrated by Plantwide Condition 9.

SN Pollutant lb/hr tpy

202122

Formaldehyde 0.54 1.87

53. Pursuant to §19.503 (Regulation 19) and 40 CFR Part 52, Subpart E, the permittee shallnot exceed 20% opacity from sources SN-20 trough SN-22 as measured by EPAReference Method 9.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

4242

54. Pursuant to §19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, daily observationsof the opacity from source SN-20 through SN-22 shall be conducted by a person trainedin EPA Reference Method 9. If visible emissions appear to be in excess of 20%, thepermittee shall immediately take action to identify the cause of the excess visibleemissions, implement corrective action, and document that visible emissions do notappear to be in excess of the permitted opacity following the corrective action. Thepermittee shall maintain records of any visible emissions which appeared to be in excessof the permitted opacity, the corrective action taken, and if visible emissions were presentfollowing the corrective action. These records shall be kept on site and made available toDepartment personnel upon request.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

4343

SN-09, SN-27 through SN-33Material Silo Bin Vents

Source Description

Several sources at the facility are associated with emissions from the loading of material silos. Dry wood residue received by the facility is stored in the Dry Material Silo (SN-27), while greenwood residue is stored in the Green Material Silo (SN-28). Green wood residue is dried by thepre-dryer and stored in the Dried Green Material Silo (SN-29). Dried waste material from theprocess is returned and stored in one of four other silos (SN-30 through SN-33). Each of thesesilos utilize a fabric bin vent filter to reduce particulate matter emissions.

The remaining silo (SN-09) stores reject material and rough trim saw waste. This material iscollected by a cyclone and sent to the silo. Emissions from the loading of the silo are controlledby a baghouse.

Specific Conditions

55. Pursuant to §19.501 et seq and §19.901 et seq of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation #19) effective February 15, 1999and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forthin the following table. The lb/hr emissions are based upon maximum operating capacityof the control equipment. The tpy emissions will be demonstrated by complying withSpecific Condition 57 and Plantwide Condition 7.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

4444

SN Pollutant lb/hr tpy

09 PMPM10

0.20.2

2.4

27 PMPM10

0.10.1

28 PMPM10

0.10.1

29 PMPM10

0.10.1

30 PMPM10

0.10.1

31 PMPM10

0.10.1

32 PMPM10

0.10.1

33 PMPM10

0.10.1

56. Pursuant to §18.501 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall not exceed 5% opacity from sources SN-09, SN-27through SN-33 as measured by EPA Reference Method 9. Compliance with thiscondition will be demonstrated by complying with Specific Condition 57.

57. Pursuant to §19.703 and §19.901 et seq of Regulation 19, 40 CFR Part 52, Subpart E, andA.C.A. §8- 4-203 as referenced by §8-4-304 and §8-4-311, the permittee shall be limitedto a pressure drop of 0.5 - 6.0 inches H2O at sources SN-09 and SN-27 through SN-33.

58. Pursuant to §19.705 and §19.901 et seq of Regulation 19, and 40 CFR Part 52, Subpart E,the permittee shall take weekly readings of the pressure drop at sources SN-09, SN-27,and SN-33. If the pressure drop is not within the permitted limit, immediate action is tobe taken to identify the cause of the excursion, implement corrective action, anddocument that the pressure drop does not appear to be out of the permitted rangefollowing the corrective action. The permittee shall maintain records of any excursions,the corrective action taken, and procedures to prevent the excursion from recurring.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

4545

These records shall be kept on site and made available to Department personnel uponrequest.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

4646

SECTION V: COMPLIANCE PLAN AND SCHEDULE

Temple-Inland Forest Products Corporation is in compliance with the applicable regulations citedin the permit application. Temple-Inland Forest Products Corporation will continue to operate incompliance with those identified regulatory provisions. The facility will examine and analyzefuture regulations that may apply and determine their applicability with any necessary actiontaken on a timely basis.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

4747

SECTION VI: PLANTWIDE CONDITIONS

1. Pursuant to §19.704 of Regulation 19, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203as referenced by §8-4-304 and §8-4-311, the Director shall be notified in writing withinthirty (30) days after construction has commenced, construction is complete, theequipment and/or facility is first placed in operation, and the equipment and/or facilityfirst reaches the target production rate.

2. Pursuant to §19.410(B) of Regulation 19, 40 CFR Part 52, Subpart E, the Director maycancel all or part of this permit if the construction or modification authorized herein is notbegun within 18 months from the date of the permit issuance or if the work involved inthe 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 betested, unless stated in the Specific Conditions of this permit or by any federally regulatedrequirements, shall be tested with the following time frames: (1) Equipment to beconstructed or modified shall be tested within sixty (60) days of achieving the maximumproduction rate, but in no event later than 180 days after initial start-up of the permittedsource or (2) equipment already operating shall be tested according to the time frames setforth by the Department or within 180 days of permit issuance if no date is specified. Thepermittee shall notify the Department of the scheduled date of compliance testing at leastfifteen (15) days in advance of such test. Compliance test results shall be submitted tothe 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 methodsb. Safe sampling platforms c. Safe access to sampling platformsd. 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 monitoringequipment shall be operated within their design limitations and maintained in goodcondition at all times.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

4848

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.

7. Pursuant to §19.705 and §19.901 et seq of Regulation 19, A.C.A. §8-4-203 as referencedby §8-4-304 and §8-4-311, and 40 CFR 70.6, the permittee shall not receive more than347,600 ODT of dry and green wood; included in this total no more than 128,741 ODT ofgreen wood material, during any twelve consecutive month period.

8. Pursuant to §19.705 and §19.901 et seq of Regulation 19, and 40 CFR Part 52, Subpart E,the permittee shall maintain monthly records on the amount of raw wood purchased andthe amount of green wood purchased each month. Records shall be updated by thefifteenth day of the month following the month for which the records pertain. Theserecords shall be kept on site, and shall be made available to Department personnel uponrequest. A twelve month rolling average and each individual month’s data shall besubmitted in accordance with General Provision 7.

9. Pursuant to §18.1004 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall use no more than 44,000 tons of urea-formaldehyderesin during any twelve consecutive month period.

10. Pursuant to §18.1004 of Regulation 18, and A.C.A. §8-4-203 as referenced by §8-4-304and §8-4-311, the permittee shall maintain monthly records on the amount of urea-formaldehyde resin used each month. Records shall be updated by the fifteenth day of themonth following the month for which the records pertain. These records shall be kept onsite, and shall be made available to Department personnel upon request. A twelve monthrolling average and each individual month’s data shall be submitted in accordance withGeneral Provision 7.

Acid Rain (Title IV)

11. Pursuant to §26.701 of Regulation #26 and 40 CFR 70.6(a)(4), the permittee is prohibitedfrom causing any emissions which exceed any allowances that the source lawfully holdsunder Title IV of the Act or the regulations promulgated thereunder. No permit revisionis required for increases in emissions that are authorized by allowances acquired pursuantto the acid rain program, provided that such increases do not require a permit revisionunder any other applicable requirement. This permit establishes no limit on the numberof allowances held by the permittee. The source may not, however, use allowances as adefense 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 inregulations promulgated under Title IV of the Act.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

4949

Title VI Provisions

12. The permittee shall comply with the standards for labeling of products using ozonedepleting substances pursuant to 40 CFR Part 82, Subpart E:

a. All containers containing a class I or class II substance stored or transported, allproducts containing a class I substance, and all products directly manufacturedwith a class I substance must bear the required warning statement if it is beingintroduced to interstate commerce pursuant to §82.106.

b. The placement of the required warning statement must comply with therequirements pursuant to §82.108.

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

d. No person may modify, remove, or interfere with the required warning statementexcept as described in §82.112.

13. The permittee shall comply with the standards for recycling and emissions reductionpursuant 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 mustcomply with the required practices pursuant to §82.156.

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

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

d. Persons disposing of small appliances, MVACs, and MVAC-like appliances mustcomply with record keeping requirements pursuant to §82.166. (“MVAC-likeappliance” as defined at §82.152.)

e. Persons owning commercial or industrial process refrigeration equipment mustcomply with leak repair requirements pursuant to §82.156.

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

14. If the permittee manufactures, transforms, destroys, imports, or exports a class I or class IIsubstance, the permittee is subject to all requirements as specified in 40 CFR part 82,Subpart A, Production and Consumption Controls.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

5050

15. If the permittee performs a service on motor (fleet) vehicles when this service involvesozone-depleting substance refrigerant (or regulated substitute substance) in the motorvehicle air conditioner (MVAC), the permittee is subject to all the applicablerequirements as specified in 40 CFR part 82, Subpart B, Servicing of Motor Vehicle AirConditioners.

The term “motor vehicle” as used in Subpart B does not include a vehicle in which finalassembly of the vehicle has not been completed. The term “MVAC” as used in Subpart Bdoes not include the air-tight sealed refrigeration system used as refrigerated cargo, or thesystem used on passenger buses using HCFC-22 refrigerant.

16. The permittee shall be allowed to switch from any ozone-depleting substance to anyalternative that is listed in the Significant New Alternatives Program (SNAP)promulgated pursuant to 40 CFR part 82, Subpart G, Significant New Alternatives PolicyProgram.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

5151

SECTION VII: INSIGNIFICANT ACTIVITIES

Pursuant to §26.304 of Regulation 26, the following sources are insignificant activities. Anyactivity for which a state or federal applicable requirement applies is not insignificant even if thisactivity meets the criteria of §304 of Regulation 26 or is listed below. Insignificant activitydeterminations rely upon the information submitted by the permittee in an application datedNovember 25, 1998.

There were no insignificant activities requested in the permit application.

Pursuant to §26.304 of Regulation 26, the emission units, operations, or activities contained inRegulation 19, Appendix A, Group B, have been determined by the Department to beinsignificant activities. Activities included in this list are allowable under this permit and neednot be specifically identified.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

5252

SECTION VIII: GENERAL PROVISIONS

1. Pursuant to 40 CFR 70.6(b)(2), any terms or conditions included in this permit whichspecify and reference Arkansas Pollution Control & Ecology Commission Regulation 18or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as thesole origin of and authority for the terms or conditions are not required under the CleanAir Act or any of its applicable requirements, and are not federally enforceable under theClean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 wasadopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101et seq.). Any terms or conditions included in this permit which specify and referenceArkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Waterand Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the origin of and authority forthe 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 ArkansasOperating Air Permit Program (Regulation 26), effective August 10, 2000, this permitshall be valid for a period of five (5) years beginning on the date this permit becomeseffective and ending five (5) years later.

3. Pursuant to §26.406 of Regulation #26, it is the duty of the permittee to submit acomplete application for permit renewal at least six (6) months prior to the date of permitexpiration. Permit expiration terminates the permittee's right to operate unless a completerenewal application was submitted at least six (6) months prior to permit expiration, inwhich case the existing permit shall remain in effect until the Department takes finalaction on the renewal application. The Department will not necessarily notify thepermittee 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 anapplicable requirement of the Clean Air Act, as amended, 42 U.S.C. 7401, et seq (Act) ismore stringent than an applicable requirement of regulations promulgated under Title IVof the Act, both provisions are incorporated into the permit and shall be enforceable bythe Director or Administrator.

5. Pursuant to 40 CFR 70.6(a)(3)(ii)(A) and §26.701(C)(2) of Regulation #26, records ofmonitoring information required by this permit shall include the following:

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

b. The date(s) analyses were performed;

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

5353

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

7. Pursuant to 40 CFR 70.6(a)(3)(iii)(A) and §26.701(C)(3)(a) of Regulation #26, thepermittee shall submit reports of all required monitoring every 6 months. If no otherreporting period has been established, the reporting period shall end on the last day of theanniversary month of this permit. The report shall be due within 30 days of the end of thereporting period. Even though the reports are due every six months, each report shallcontain a full year of data. All instances of deviations from permit requirements must beclearly identified in such reports. All required reports must be certified by a responsibleofficial as defined in §26.2 of Regulation #26 and must be sent to the address below.

Arkansas Department of Environmental QualityAir DivisionATTN: Compliance Inspector SupervisorPost Office Box 8913Little Rock, AR 72219

8. Pursuant to 40 CFR 70.6(a)(3)(iii)(B), §26.701(C)(3)(b) of Regulation #26, and §19.601and 19.602 of Regulation #19, all deviations from permit requirements, including thoseattributable to upset conditions as defined in the permit shall be reported to theDepartment. An initial report shall be made to the Department by the next business dayafter 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, e. The duration of the deviation,

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

5454

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 ofdiscovery of the occurrence and shall include in addition to the information required byinitial report a schedule of actions to be taken to eliminate future occurrences and/or tominimize the amount by which the permits limits are exceeded and to reduce the lengthof time for which said limits are exceeded. If the permittee wishes, they may submit afull report in writing (by facsimile, overnight courier, or other means) by the nextbusiness day after discovery of the occurrence and such report will serve as both theinitial 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 applicationthereof to any person or circumstance is held invalid, such invalidity shall not affect otherprovisions or applications hereof which can be given effect without the invalid provisionor application, and to this end, provisions of this Regulation are declared to be separableand severable.

10. Pursuant to 40 CFR 70.6(a)(6)(i) and §26.701(F)(1) of Regulation #26, the permitteemust comply with all conditions of this Part 70 permit. Any permit noncompliance withapplicable requirements as defined in Regulation #26 constitutes a violation of the CleanAir Act, as amended, 42 U.S.C. 7401, et seq. and is grounds for enforcement action; forpermit termination, revocation and reissuance, or modification; or for denial of a permitrenewal application. Any permit noncompliance with a state requirement constitutes aviolation 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 andreissuance, 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 adefense for a permittee in an enforcement action that it would have been necessary to haltor reduce the permitted activity in order to maintain compliance with the conditions ofthis permit.

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

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

5555

termination, or of a notification of planned changes or anticipated noncompliance doesnot stay any permit condition.

13. Pursuant to 40 CFR 70.6(a)(6)(iv) and §26.701(F)(4) of Regulation #26, this permit doesnot 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 permitteeshall furnish to the Director, within the time specified by the Director, any informationthat 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 thepermit. Upon request, the permittee shall also furnish to the Director copies of recordsrequired to be kept by the permit. For information claimed to be confidential, thepermittee may be required to furnish such records directly to the Administrator along witha claim of confidentiality.

15. Pursuant to 40 CFR 70.6(a)(7) and §26.701(G) of Regulation #26, the permittee shall payall 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 revisionshall be required, under any approved economic incentives, marketable permits,emissions trading and other similar programs or processes for changes that are providedfor 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 isallowed to operate under different operating scenarios, the permittee shall,contemporaneously with making a change from one operating scenario to another, recordin a log at the permitted facility a record of the scenario under which the facility or sourceis operating.

18. Pursuant to 40 CFR 70.6(b) and §26.702(A) and (B) of Regulation #26, all terms andconditions in this permit, including any provisions designed to limit a source's potential toemit, are enforceable by the Administrator and citizens under the Act unless theDepartment has specifically designated as not being federally enforceable under the Actany terms and conditions included in the permit that are not required under the Act orunder any of its applicable requirements.

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

5656

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 responsibleofficial as defined in §26.2 of Regulation #26.

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

a. Enter upon the permittee's premises where the permitted source is locatedor emissions-related activity is conducted, or where records must be keptunder the conditions of this permit;

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

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

d. As authorized by the Act, sample or monitor at reasonable timessubstances or parameters for the purpose of assuring compliance with thispermit or applicable requirements.

21. Pursuant to 40 CFR 70.6(c)(5) and §26.703(E)(3) of Regulation #26, the permittee shallsubmit a compliance certification with terms and conditions contained in the permit,including emission limitations, standards, or work practices. This compliancecertification shall be submitted annually and shall be submitted to the Administrator aswell as to the Department. All compliance certifications required by this permit shallinclude the following:

a. The identification of each term or condition of the permit that is the basisof 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 monitoringrequirements of this permit; and

e. Such other facts as the Department may require elsewhere in this permit orby §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 thefollowing:

Temple-Inland Forest Products CorporationPermit #: 1533-AOP-R3CSN #: 29-0120

5757

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

b. The liability of the permittee for any violation of applicable requirementsprior 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 §114of the Act.

23. Pursuant to A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311, this permitauthorizes only those pollutant emitting activities addressed herein.

58

APPENDIX A

59

APPENDIX B

60

APPENDIX C

61

APPENDIX D

62

INVOICE REQUEST FORMPDS-

Date October 11, 2001

X Air

NPDES

Stormwater

State Permits Branch

Solid Waste

CSN 29-0120

Facility Name Temple-Inland Forest Products Corporation

Invoice Mailing Address P.O. Box Drawer N

Dibol, TX 75941

Initial

Modification

Annual

Permit Number 1533-AOP-R4 Permit Description Title 5 Permit Fee Code A

Amount Due $ 500

Engineer Shawn Hutchings

Paid? GGGGNo GGGGYes Check #

Comments: Air Permit Fee Calculation Minor Mod Minimum

Public Notice

Pursuant to the Arkansas Operating Air Permit Program (Regulation #26) Section 602, the Air Division ofthe Arkansas Department of Environmental Quality gives the following notice:

Temple-Inland Forest Products Corporation (TIFPC), (CSN:29-0120), owns and operates a particleboardmanufacturing facility on Route 4, 100 Temple Drive near Hope (Hempstead County) Arkansas. Thismodification allows for TIFPC to divert approximately 20% of the exhaust from the hot oil heater to the pre-dryer (SN-16). The exhaust is to be diverted when the pre-dryer is idle to prevent condensation buildupwhich causes corrosion. This modification also allows TIFPC to use an additive in their resin water mixknown as Additive A. This additive allows for greater penetration and absorption of the resin into the woodparticles during the blending operation. Neither of these modifications will affect the facility’s permittedemission rates.

The application has been reviewed by the staff of the Department and has received the Department's tentativeapproval subject to the terms of this notice.

Citizens wishing to examine the permit application and staff findings and recommendations may do so bycontacting Suzanne Carswell, Information Officer. Citizens desiring technical information concerning theapplication or permit should contact Shawn Hutchings, Engineer. Both Suzanne Carswell and ShawnHutchings can be reached at the Department's central office, 8001 National Drive, Little Rock, Arkansas72209, telephone: (501) 682-0744.

The draft permit and permit application are available for copying at the above address. A copy of the draftpermit has also been placed at the Hempstead County Library, Fifth & Elm Streets, Hope, AR, 71801. Thisinformation may be reviewed during normal business hours. Interested or affected persons may also submit written comments or request a hearing on the proposal, or theproposed modification, to the Department at the above address - Attention: Suzanne Carswell. In order tobe 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 significantcomments on the permit provisions are received. If a hearing is scheduled, adequate public notice will begiven 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 inaccordance with Section 2.1 of the Arkansas Pollution Control and Ecology Commission’s AdministrativeProcedures (Regulation #8) and Regulation #26.

Dated this

Richard A. WeissInterim Director