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

ADEQ OPERATING AIR PERMIT

Pursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation 26:

Permit No. : 1533-AOP-R5 Renewal #1

IS ISSUED TO: TIN Inc., dba Temple-Inland Route 4, 100 Temple Drive

Hope, AR 71801 Hempstead County AFIN: 29-00120

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

July 11, 2003 AND July 10, 2008 THE PERMITTEE IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Mike Porta Date AmendedInterim Chief, Air Division

TIN Inc., dba Temple-Inland Permit #: 1533-AOP-R5 AFIN #: 29-00120

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Table of Contents SECTION I: FACILITY INFORMATION .............................................................................. 4 SECTION II: INTRODUCTION ............................................................................................... 5

Summary of Permit Activity .................................................................................................... 5 Process Description ................................................................................................................... 5 Regulations ................................................................................................................................ 9 Emission Summary ................................................................................................................... 9

SECTION III: PERMIT HISTORY ........................................................................................ 13 SECTION IV: SPECIFIC CONDITIONS .............................................................................. 20

SN-03 and 04 ............................................................................................................................ 20 SN-05, 06 and 35 ...................................................................................................................... 23 SN-07 & SN-08A and SN-08B................................................................................................. 26 SN-10 and SN-11...................................................................................................................... 29 SN-15 ........................................................................................................................................ 32 SN-16 ........................................................................................................................................ 35 SN-17A ..................................................................................................................................... 39 SN-20, 21, and 22 ..................................................................................................................... 43 SN-09, SN-27 through SN-33................................................................................................... 45

SECTION V: COMPLIANCE PLAN AND SCHEDULE ..................................................... 48 SECTION VI: PLANTWIDE CONDITIONS ........................................................................ 49

Acid Rain (Title IV).................................................................................................................. 51 Title VI Provisions.................................................................................................................... 51

SECTION VII: INSIGNIFICANT ACTIVITIES .................................................................. 53 SECTION VIII: GENERAL PROVISIONS ........................................................................... 54 Appendix A – 40 CFR 63, Subpart DDDD


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List of Acronyms and Abbreviations

A.C.A. Arkansas Code Annotated

AFIN ADEQ Facility Identification Number

CFR Code of Federal Regulations

CO Carbon Monoxide

HAP Hazardous Air Pollutant

lb/hr Pound Per Hour

MVAC Motor Vehicle Air Conditioner

No. Number

NOx Nitrogen Oxide

PM Particulate Matter

PM10 Particulate Matter Smaller Than Ten Microns

SNAP Significant New Alternatives Program (SNAP)

SO2 Sulfur Dioxide

SSM Startup, Shutdown, and Malfunction Plan

Tpy Tons Per Year

UTM Universal Transverse Mercator

VOC Volatile Organic Compound


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SECTION I: FACILITY INFORMATION

PERMITTEE: TIN Inc., dba Temple-Inland

AFIN: 29-00120

PERMIT NUMBER: 1533-AOP-R5

FACILITY ADDRESS: Route 4, 100 Temple Drive Hope, AR 71801

MAILING ADDRESS: 100 Temple Drive Hope, Arkansas 71801

COUNTY: Hempstead

CONTACT POSITION: Wayne Hargraves, Plant Manager

TELEPHONE NUMBER: (870) 722-4000

REVIEWING ENGINEER: Wesley Crouch

UTM North South (Y): Zone 15: 3733.0

UTM East West (X): Zone 15: 441.4


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SECTION II: INTRODUCTION

Summary of Permit Activity

TIN Inc., dba Temple-Inland (AFIN: 29-00120) located at Route 4, 100 Temple Drive, Hope, AR 71801, has proposed to redesign the crown of the press, replace the 10 hot plates and jack cylinder jugs in the press and (SN-17). These changes will not result in an increase in permitted emissions.

Process Description

Temple Inland Forest Products Company�s (TIFPC's) particleboard plant in Hope, Arkansas, was designed to utilize wood residue from other wood processing plants in the southwest Arkansas area. The plant will utilize a maximum 347,600 oven-dried tons (ODT, 0% moisture content) of wood residue annually for a 7 days/week operation with a maximum annual production rate of 220,000 thousand square feet (MSF) of board per year on a 3/4 inch basis. The maximum hourly short term level of production for the press is 32,000 square feet (SF) of board on a 3/4 inch basis and 51.3 ODT for the primary dryers. Raw Material Processing All raw materials are delivered to the plant by truck then off-loaded and stored in an enclosed storage building. TIFPC utilizes a hydraulic truck dumper with a receiving screw conveyor discharge hopper for the unloading process. All mechanical conveying is performed in an enclosed system which minimizes fugitive emissions. The truck is backed into the unloader facility where it is lifted and tilted backward. The raw material falls into an unloading bin that is hooded and enclosed as much as possible. This style of truck dumper reduces these fugitive emissions. The raw materials are metered directly to the Raw Material Storage (RMS) building utilizing a totally enclosed conveyor. The wood residuals are stored in piles in the enclosed raw material storage building. This stored material is reclaimed as needed, then conveyed to the process storage metering bins. Two types of residue are used as raw material, �green� (�18% Oven Dried (OD) moisture content) material and �dry� (<18% moisture content OD) material. The "green� material is primarily sawdust generated from sawmills cutting untreated lumber, whereas the "dry" material is primarily shavings and sawdust produced when planing or cutting kiln dried lumber. Acceptable material from the RMS building is fed to one of three storage silos; dried material, green material and dried green material which are equipped with bin vent filters (SN-27, 28 & 29 respectively). Once the material is in the silos, it is conveyed to the reciprocating shaker screens, which classifies the material. Overs from the screens are conveyed to a hammermill which recycles material back to the screens. Dust generated at the hammermill is controlled by a small

Date Amended: January 20, 2005


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baghouse (SN-35). Reject material from the forming line and hogged trim material from the finished boards are collected in a separate silo and re-enters the system to optimize material usage. Milling and Drying The two screen systems produce two separate process stream flows; both core and face. Both screen systems deliver material via a covered conveying system to the Milling and Drying (M&D) area. The finer portion of the wood fiber is used in the surface layers of the board ("face"), while the coarser material is used in the middle board layers ("core"). Face and core materials are processed through hammermills and refiners, respectively. Refining is accomplished as the material is plug-fed by screw conveyors into the center of each of the four refiners and is sheared by the attrition plates. The gap spacing is determined by the type of furnish being produced. The face material leaves the screens and is sent to one of six hammermills. The hammermills pulverize the material into smaller particle sizes which can then be accepted by the process. The refining process controls the geometry of the finished particle and influences both the density and weight of the board. Centrifugal force causes the material to exit the refiners. The refined material is then air conveyed through large cyclones to metering bins that feed one of three rotary drum dryers. Exhaust from these cyclones is conveyed to four (4) large, designated baghouses (SN-03, 04, 05 & 06) for particulate control. The green material is initially sent to a MEC Model 1360-T Predryer (SN-16) which reduces the moisture content of the material to <18%. Sander dust is burned on the No. 2 Dust Suspension burner to provide heat for the predryer. The exhaust from the predryer is first conveyed to a primary cyclone to remove the product. The remaining exhaust gas is then sent to a Wet Electrostatic Precipitator (WESP), which is followed by an incinerator called a Regenerative Thermal Oxidizer (RTO). This system effectively reduces VOC and particulate emissions from this source with a control efficiency of 95% for VOC and 90% for particulates. After the green material is dried in the predryer to approximately 15-18% moisture content, it is conveyed to the Dried Green Material Silo by way of the Predryer Return System Baghouse (SN-07). Material from the predryer is combined with purchased dried material and is further dried in one of the three primary dryers. All three dryers are MEC Model 1248-T traditional triple pass dryers. The three rotary dryers are directly heated through a common plenum by exhaust heat generated from the combustion of sander dust and/or natural gas. The flame temperatures of these burners are usually in the 1700 0F to 2000 0F range. However, this exhaust gas is diluted and cooled immediately upon exiting the combustion chamber with diluent air. This exhaust gas is combined with the exhaust from the hot oil heater system (recirculating oil system for supplying heat to the press) which also utilizes sander dust for fuel. The rotary dryer furnace or blending box also


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


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same manner as the bottom face, except that the air is blown in the same direction as the traveling screens to ensure that the lightest and finest material will be the top surface of the mat. Once formed, the mat exits the former and travels the length of the line to the press. Along the way, the mat is weighed, the ends are trimmed and tramp metals are removed. The trim material is pneumatically removed from the former and captured in a cyclone/baghouse combination (SN-8B). The captured material is recycled back to the process. Dust generated at the former is controlled by a separate baghouse (SN-8A). The flexible screen system delivers the formed mats to the press loader where they are accumulated for simultaneous loading into the hot press. The mats are pressed batchwise on the flexible screens at an average temperature of 3300F and a specific pressure of 800 psi. The heat for the press operation is provided by the hot oil system. The controls of the press are accomplished using computers and timing algorithms to achieve precision and consistency. After the press has opened and the screens with the pressed board are removed, the boards are separated from the screens. Upon release of the pressure, steam and organic vapor is liberated. The emissions are collected within an enclosure surrounding the press. The collected vapors are sent to an RTO for reduction of VOC emissions before exiting to the atmosphere through a stack (SN-17A).

Board Finishing Operation The flexible screens are removed from the press and the particleboard is separated from the screens. The screens are returned to the beginning of the forming line by the underground return line. The boards are trimmed by a series of saws that cut approximately two inches off the length and the width edges of the board. Dust created by the sawing operation and materials from the reject bin are conveyed to a cyclone exhaust which is controlled by a baghouse (SN-09). The boards go to a wicket cooling station with a specified retention time to allow the board to cool and give time for the completion of the curing process. As each board cools, emissions from the board are ultimately vented to the atmosphere by way of three roof vents (SN-20, 21, and 22). The cut boards are sent directly to the sanders. The sanders are a multi-head type with the primary function of removing the excess board thickness and to provide a smooth finished face for the board. The first set of heads takes the majority of the material off the board, top and bottom, while the remaining heads remove considerably less material each time. The last head acts as a buffer to ensure high quality of the face of the finished board. The sander dust generated in the sanding operation is collected by high suction pneumatic pickup systems and sent through either of two baghouses. The sander dust is then pneumatically conveyed to the storage silos through the transfer system baghouse (SN-12). Emissions from this


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silo are controlled by a bin vent filter (SN-31). The collected material is used to fuel the sander dust burners of the predryer, the hot oil system, and primary dryers. Following sanding, the board is cut into the desired lengths, graded for quality, sorted, stacked, and packaged for shipment.

Regulations The following table contains the regulations applicable to this permit.

Regulations

Arkansas Air Pollution Control Code, Regulation 18, effective February 15, 1999

Regulations of the Arkansas Plan of Implementation for Air Pollution Control, Regulation 19, effective December 19, 2004 Regulations of the Arkansas Operating Air Permit Program, Regulation 26, effective September 26, 2002

40 CFR Part 52.21, PSD

40 CFR Part 63, Subpart DDDD, Plywood and Composite Wood Products

The following table is a summary of emissions from the facility. This table, in itself, is not an enforceable condition of the permit.

Emission Summary

EMISSION SUMMARY

Emission Rates Source Number Description Pollutant

lb/hr tpy

PM 67.4 226.67

PM10 67.4 226.67

SO2 2.4 9.5

VOC 162.1 557.6

CO 107.1 424.6

Total Allowable Emissions

NOX 106.4 441.9


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HAPs Formaldehyde Methanol

2.47 10.0

7.97 33.93

SN Description Pollutant lb/hr tpy

03 Refiners (2)

PM PM10 VOC

Formaldehyde Methanol

0.3 0.3

10.1 0.02 0.05

1.0 1.0

34.6 0.06 0.2

04 Refiners (2)

PM PM10 VOC


0.3 0.3

10.1 0.02 0.05

1.0 1.0

34.6 0.06 0.2

05 Hammermills (3)

PM PM10 VOC


0.2 0.2

15.1 0.03 0.07

0.9 0.9

51.9 0.09 0.3

06 Hammermills (3)

PM PM10 VOC


0.2 0.2

15.1 0.03 0.07

0.9 0.9

51.9 0.09 0.3

07 Pre-dryer Return System PM PM10

0.3 0.3

1.3 1.3

08A Forming Line Dust Collection

PM PM10

0.4 0.4

1.4 1.4

08B Formers Dust Collector PM PM10

0.4 0.4

1.5 1.5

09 Rough Trim Material Baghouse

PM PM10

0.2 0.2

0.7 0.7

10 #1 Sander Dust Collection System

PM PM10 VOC


0.2 0.2

0.45 0.02 0.25

0.7 0.7 1.5 0.1

0.75

11 #2 Sander Dust Collection System

PM PM10 VOC


0.2 0.2

0.45 0.02 0.25

0.7 0.7 1.5 0.1

0.75


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12 Sander Dust Transfer System

PM PM10

0.2 0.2

0.8 0.8

13 Finish Saw Dust Collection

PM PM10

0.2 0.2

0.7 0.7

14 Trim Return System PM PM10

0.3 0.3

1.0 1.0

15 Primary Dryers (3 Units)

PM PM10 SO2 VOC CO NOx


55.4 55.4 1.4

88.8 56.5 55.9 0.72 4.05

190.5 190.5

5.6 305.1 234.9 232.5

1.8 14.0

16 Pre-dryer

PM PM10 SO2 VOC CO NOx


4.6 4.6 1.0 7.9

38.2 44.5 0.07 0.01

11.07 11.07

3.9 27.1

140.5 184.8

0.3 0.03

17A Press Vent RTO Stack

PM PM10 VOC CO NOx


2.5 2.5 3.5

12.4 6.0 1.0 1.6

8.5 8.5

12.1 49.2 24.6 3.5 5.3

20

21

22

Cooler Vent

PM PM10 VOC


0.7 0.7

10.6 0.54 3.6

2.2 2.2

36.3 1.87 12.1

27 Dry Material Silo Bin Vent Filter

PM PM10

0.1 0.1

0.3 0.3

28 Green Material Silo Bin Vent Filter

PM PM10

0.1 0.1

0.3 0.3

29 Dried Green Material Silo Bin Vent Filter

PM PM10

0.1 0.1

0.3 0.3

30 Dried Trim Material Silo PM 0.1 0.3


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Bin Vent Filter PM10 0.1 0.3

31 Sander Dust Silo Bin Vent Filter

PM PM10

0.1 0.1

0.3 0.3

32 Dry Face Silo Bin Vent Filter

PM PM10

0.1 0.1

0.1 0.1

33 Dry Core Silo Bin Vent Filter

PM PM10

0.1 0.1

0.1 0.1

35 Overs Hammermill PM PM10

0.1 0.1

0.1 0.1

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


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SECTION III: PERMIT HISTORY 1533-A was issued on May 19, 1994. This was the initial air permit for the facility and contained all of the currently permitted sources, with the exception of the press vent RTO (SN-17). 1533-AR-1 was issued on December 28, 1994. This modification was issued to address modifications in the process which caused minor increases in emissions and also clarified the record keeping and stack testing requirements of the facility to ensure compliance with emission limits. The facility took a limit of 208,000 MSF/yr of particleboard. 1533-AR-2 was issued on November 7, 1996. This permit modification addressed the installation of a regenerative thermal oxidizer (RTO) to control VOC emissions from the hot press (SN-17 in the previous permit). Also the facility was allowed to burn natural gas only, which prevented the facility from being subject to PSD. 1533-AOP-R0 was issued on March 9, 1998. This permit represented the issuance of the initial Regulation #26 (Title V) permit for the facility. Also the facility was allowed to burn natural gas only, which prevented the facility from being subject to PSD. 1533-AOP-R1 was issued on November 19, 1999. Temple-Inland modified the permit to increase annual production to 220,000 MSF/yr, also the facility requested to burn sander dust fuel in its burners that supply heat to the primary dryers. The following tables are the BACT Analysis and PSD Review.

BACT Analysis

Predryer (SN-16) PM/PM10

Cyclone, WESP, and RTO

A facility using EFB and RTO is currently undergoing re-permitting due to the fact that it cannot meet their permit limits, therefore this control technology should not be considered BACT. Temple�s proposal has a removal efficiency of 90% which is equal to or higher than all other listed control technologies.

VOC

RTO

The RTO has a VOC removal efficiency of 95% compared to the

90% removal for the RCO.

CO

Good Combustion

There are no instances of add-on controls required for CO emissions.

NOx

Low NOx Burner

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

excess air and excess temperatures.


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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 BACT research conducted for the particleboard industry, an RTO went through the top-down analysis and was eliminated due to unacceptable economic impacts ($11,429/ton removed).

VOC

No Control

An RTO went through the top-down analysis and was eliminated due to an unacceptable economic impact of $11,429/ton VOC removed. RCO to reduce VOC emissions has yet to be installed and its efficiency has not yet been demonstrated. Scrubbers in the wood products industry are virtually nonexistent. One reason is the process off gas streams is generally associated with high molecular weight organics and therefore would have minimal impact on these type of organics, effecting the unit�s overall efficiency. Activated carbon absorption is likely to plug up due to high flowrates, particulate loading, and condensable organics. Also, the use of this technology for certain organics could result in the generation of hazardous waste.

CO

Good Combustion

There are no listings in the RBLC for CO emissions associated with particleboard facilities.

NOx

Good Combustion

The only listings in the RBLC are for Low NOx Burners on a gas fired dryer. Since the facility is going to burn sander dust as the primary fuel there is no technology for the control of NOx emissions using Low NOx Burners.

Press (SN-17) PM/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 with particleboard facilities.

NOx

Low NOx Burners

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

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

PM/PM10

No Control

There are no listings in the RBLC for PM/PM10 emissions associated with Cooling Wheels.

VOC

No Control

There are no listings in the RBLC for VOC emissions associated with Cooling Wheels.


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Material Handling and Transferring Operations PM/PM10

Baghouses

Baghouses have 99.9% removal efficiency.

Maximum Predicted Concentrations with Background

In Comparison with the NAAQS

Pollutant

Averaging Period

Concentration

with Background (�g/m3)

NAAQS (�g/m3)

24-hour

104.72

150

PM10

Annual

32.64

50

NOX

Annual

39.65

100

Maximum Predicted Increment Consumed

In Comparison with the PSD Increment

Pollutant

Averaging Period

Increment Consumed

(�g/m3)

PSD Increment

(�g/m3)

24-hour

22.13*

30

PM10

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 scenarios were 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 ozone contributors and is compared to the ozone NAAQS of 0.12 ppm, 1-hour average. Because the RPM gives 1-hour averages, the model results have been converted to 8-hour averages using the multiplying factor listed in Section 4 of EPA�s Screening Procedures for Estimating the Air 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).


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Ozone Reactive Plume Model (RPM) Results

Model Run

Maximum Downwind Distance

(km)

Averaging Period

Concentration

(ppm)

NAAQS

(ppm)

8-hour

0.02183

0.08

Ambient

43.03

1-hour

0.03119

0.12

8-hour

0.02264

0.08

Ambient

+ Biogenic

44.76

1-hour

0.03234

0.12

8-hour

0.02255

0.08

Ambient

+ Biogenic+ Facility

44.63

1-hour

0.03222

0.12

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

Pollutant

Short Term Highest Concentration

(�g/m3)

Long Term

Highest Concentration

(�g/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 to relocate the primary dryers stack to a position approximately 8 meters to the east of its existing location. The height of the stack will be increased to 150 feet.


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

PSD Issues Associated with 1533-AOP-R2

The purpose of the modification is to revise the primary dryer stack location. Temple Inland intends to relocate the stack to a position approximately 8 meters to the east to its existing location. The height of the stack will be increased to 150 feet. All required elements of the PSD air quality analysis were done. The following tables indicate the changes in the maximum concentrations and predicted increment consumed. All other sections such as the Ozone Analysis, Class I Area Analysis, and Toxics Impact have remained unchanged and are not expanded upon in this section.

NAAQS Analysis The NAAQS are maximum concentration �ceilings� measured in terms of the total concentration of pollutant in the atmosphere. In the NAAQS analysis, the proposed facility�s emission is combined with those from other nearby sources that have the potential to contribute significantly to receptors within the facility�s radius of impact (ROI). Once the screening analysis is completed, the combined emissions are then modeled. The resulting impacts are summed with a representative background concentration and then are compared to the corresponding NAAQS to demonstrate compliance with these criteria. The results of the NAAQS analysis are contained in the following table.

Maximum Predicted Concentrations with Background in Comparison with the NAAQS

Pollutant

Averaging Period

Concentration with Background

(�g/m3)

NAAQS (�g/m3)

24-hour

81.93

150

PM10

Annual

33.31

50

NOX

Annual

39.93

100

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


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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 with the facility�s proposed emissions increase to demonstrate compliance with the corresponding PSD Increments. The results of the PSD Increment analysis are contained in the following table.

Maximum Predicted Increment Consumed

in Comparison with the PSD Increment

Pollutant

Averaging Period

Increment Consumed

(�g/m3)

PSD Increment

(�g/m3)

24-hour

28.79*

30

PM10

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 a permit for any major stationary source would result in the consumption of more than 80% of any short term increment or greater than 50% of the available long term increment, the permittee shall submit to the Department an assessment of the following factors: (i) effects that the proposed consumption would have upon the industrial and economic development within the area of the proposed source; and (ii) alternatives to such consumption, including alternative siting of the proposed source or portions thereof. The proposed increase will not consume greater than 80% of the short term increment; however, more than 50% of the available NOx long term increment will be consumed. Therefore the above mentioned analysis is required. � The location of concentrations of NOX greater than 12.5 �g/m3 (50% of the available

long term increment) occur either immediately on the fence line or within 300 meters of the facility. PM10 concentrations greater that 24 �g/m3 (80% of any short term increment) occur either immediately on the fence line or within 30 meters of the fence line. Industrial growth will not be hampered in those areas in the immediate future since from the fence line to 300 meters to the south is an industrial facility, which sells its entire product to Temple, and from the fence line to 300 meters to the north is an abandoned World War II military installation. The abandoned World War II military installation is a former artillery test range with unexploded shells throughout the area.


19

Any industrial expansion around this site would require an extensive and time consuming reclamation project to make 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.

� Since the facility has already been constructed, alternative siting will not be possible. Permit 1533-AOP-R3 was issued on August 2, 2001, this modification allowed TIFPC to divert approximately 20% of the exhaust from the hot oil heater to the pre-dryer (SN-16). The exhaust is to be diverted when the pre-dryer is idle to prevent condensation buildup which causes corrosion. This modification also allowed TIFPC to use an additive in their resin water mix known as Additive A. This additive allowed for greater penetration and absorption of the resin into the wood particles during the blending operation. Neither of these modifications affected the facility�s permitted emission rates. Permit 1533-AOP-R4 was issued on July 11, 2003. This was the first title V renewal permit for this facility. This was also a modification to the permit allowing the amount of green wood received to be reduced from 128,741 ODT/year to 70,000 ODT/year. Also, the factor used to determine the particulate matter emission rate from SN-16 was lowered from 6.15 lb/ODT to 5.27 lb/ODT due to improved control from the cyclone prior to the WESP and RTO. Emission rates at some sources were changed to take advantage of new NCASI factors. Finally, the Department clarified the BACT limit for SN-16. Previous calculations for this facility were based on a 98% control. The required combined control efficiency of the WESP and RTO is actually 90% and the emission rates were adjusted to reflect this.


20

SECTION IV: SPECIFIC CONDITIONS

SN-03 and 04 Refiners (4)

Source Description

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

Specific Conditions 1. The permittee shall not exceed the emission rates set forth in the following table. The

lb/hr emissions are based upon maximum operating capacity of the control equipment. Compliance with the tpy emission rates shall be demonstrated by complying with Plantwide Conditions 5 and 7. [Regulation 19, §19.501 et seq., effective December 19, 2004 and 40 CFR Part 52, Subpart E]

SN Pollutant lb/hr tpy

PM10 0.3 1.0 03

VOC 10.1 34.6

PM10 0.3 1.0 04

VOC 10.1 35.6

2. The permittee shall not exceed the emission rates set forth in the following table. The

lb/hr emissions are based upon maximum operating capacity of the control equipment. Compliance with the tpy emission rates shall be demonstrated by complying with Plantwide Conditions 5 and 7. [Regulation 18, §18.801, effective February 15, 1999, and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]


03 PM 0.3 1.0


21

Formaldehyde 0.02 0.06

Methanol 0.05 0.2

PM 0.3 1.0

Formaldehyde 0.002 0.06 04

Methanol 0.05 0.2

3. Visible emissions may not exceed the limits specified in the following table of this permit

as measured by EPA Reference Method 9. [A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

SN Limit Regulatory Citation

03

04 5% Regulation 18, §18.501

4. Weekly visible emission observations shall be used as a method of compliance

verification for the opacity limits assigned. The weekly observations shall be conducted by someone familiar with the facility�s visible emissions. If during the observations, visible emissions are detected which appear to be in excess of the permitted opacity limit, the permittee shall:

a. Take immediate action to identify the cause of the visible emissions, b. Implement corrective action, and c. If excessive visible emissions are still detected, an opacity reading shall be conducted

in accordance with EPA Reference Method 9 for point sources and in accordance with EPA Method 22 for non-point sources. This reading shall be conducted by a person trained and certified in the reference method. If the opacity reading exceeds the permitted limit, further corrective measures shall be taken.

d. If no excessive visible emissions are detected, the incident shall be noted in the records as described below.

The permittee shall maintain records related to all visible emission observations and Method 9 readings. These records shall be updated on an as-performed basis. These records shall be kept on site and made available to Department personnel upon request. These records shall contain:


22

a. The time and date of each observation/reading any observance of visible emissions appearing to be above permitted limits or any Method 9 reading which indicates exceedance,

b. The cause of any observed exceedance of opacity limits, corrective actions taken, and results of the reassessment, and

c. The name of the person conducting the observation/reading. [Regulation 18, §18.501 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]


23

SN-05, 06 and 35 Hammermills

Source Description

The primary hammermills are used to reduce the size of acceptable screened materials for use in the formation of the outer edges (�face�) of the particleboard sheets. Emissions from these two hammermills are controlled by two baghouses (SN-05, SN-06). The overs hammermill is used to reduce the size of unacceptable screened materials. Emissions from this hammermill are controlled by a baghouse (SN-35).


lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions will be demonstrated by complying with Plantwide Conditions 5 and 7. [Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]


PM10 0.2 0.9 05

VOC 15.1 51.9

PM10 0.2 0.9 06

VOC 15.1 0.9

35 PM10 0.1 0.1

6. The permittee shall not exceed the emission rates set forth in the following table.

Compliance shall be demonstrated through compliance with Plantwide Conditions 5 and 7. [Regulation 18, §18.801, and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]


PM 0.2 0.9 05



24

Methanol 0.07 0.3

PM 0.2 0.9

Formaldehyde 0.03 0.09 06

Methanol 0.07 0.3

35 PM 0.1 0.1




05

06

35

5% Regulation 18, §18.501








25

a. The time and date of each observation/reading any observance of visible emissions

appearing to be above permitted limits or any Method 9 reading which indicates exceedance,




26

SN-07 & SN-08A and SN-08B Pre-dryer Return System & Forming Line and Formers Dust Collection

Source Description

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

Compliance Assurance Monitoring The Compliance Assurance Monitoring (CAM) rule applies to any pollutant specific emission unit that (1) is subject to an emission limitation or standard, (2) uses a control device to achieve compliance with the emission limitation or standard, and (3) has potential pre-control emissions of the regulated pollutant that exceed or are equivalent to the major source threshold of 100 tpy per pollutant. The predryer return system baghouse (SN-07), forming line dust collection baghouse (SN-08A), and formers dust collection baghouse (SN-08B) have pre-control PM10 emissions of 117.0, 129.0, and 137.0 tpy respectively. Weekly opacity readings will be done to insure that control measures are properly operated and maintained. If the threshold levels set in the permit are exceeded by greater than 5% of the unit�s total operating time, the facility is required to prepare a Quality Improvement Plan (QIP). A Quality Improvement Plan is a written plan that outlines the procedures that will be used to evaluate problems that affect the performance of control equipment. The Department requires a source to develop and implement a QIP after a determination that the source has failed to use acceptable procedures in responding to an exceedance.


lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions and CAM compliance will be demonstrated by complying with Plantwide Conditions 5 and 7. [Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]


07 PM10 0.3 1.3

08A PM10 0.4 1.4



27

08B PM10 0.4 1.5


lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions and CAM compliance will be demonstrated by complying with Plantwide Conditions 5 and 7. [Regulation 18, §18.801, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]


07 PM 0.3 1.3

08A PM 0.4 1.4

08B PM 0.4 1.5




07

08A

08B







28







13. The permittee shall record the number of excursions that have occurred at sources SN-07,

SN-08A and SN-08B for opacity. If there are nine (9) excursions in a six month period for opacity the facility will be required to submit a Quality Improvement Plan (QIP). The QIP should provide the following information:

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

problem; c. a schedule for making such improvements.

These records and QIP shall be kept on site and made available to Department personnel upon request. [40 CFR Part 64 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]


29

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

SN-12

Sander Dust Transfer System

SN-13 Finish Saw Dust Collection

SN-14

Trim Return System

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




PM10 0.4 1.4 10 and 11

VOC 0.9 3.0

12 PM10 0.2 0.8

13 PM10 0.2 0.7

14 PM10 0.3 1.0


lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions will be demonstrated by complying with Plantwide Conditions 5 and


30

7. [Regulation 18, §18.801, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]


PM 0.4 1.4

Formaldehyde 0.04 0.2 10 and 11

Methanol 0.5 1.5

12 PM 0.2 0.8

13 PM 0.2 0.7

14 PM 0.3 1.0




10 and 11

12

13

14




a. Take immediate action to identify the cause of the visible emissions, b. Implement corrective action, and


31

c. If excessive visible emissions are still detected, an opacity reading shall be conducted









32

SN-15 Primary Dryers (3 Units)

Source Description

The three 58 million Btu per hour primary dryers are used to further reduce the moisture content of the dry wood residue before it is used in the manufacturing process. Emissions from the three dryers are controlled by three multi-cyclones. The exhaust air from these multi-cyclones is vented to the atmosphere by a common stack (SN-15). The facility is permitted to use sander dust as the primary fuel.

Compliance Assurance Monitoring The Compliance Assurance Monitoring (CAM) rule applies to any pollutant specific emission unit that (1) is subject to an emission limitation or standard, (2) uses a control device to achieve compliance with the emission limitation or standard, and (3) has potential pre-control emissions of the regulated pollutant that exceed or are equivalent to the major source threshold of 100 tpy per pollutant. The primary dryers (SN-15) have pre-control PM10 emissions of 1269.4 tpy. Daily opacity readings for the multicyclone will be used to insure the control measures are properly operated and maintained. If the threshold levels set in the permit are exceeded greater than 5% of the unit�s total operating time, the facility is required to prepare a Quality Improvement Plan (QIP). A Quality Improvement Plan is a written plan that outlines the procedures that will be used to evaluate problems that affect the performance of control equipment. The Department requires a source to develop and implement a QIP after a determination that the source has failed to use acceptable procedures in responding to an exceedance.


lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions and CAM compliance will be demonstrated by complying with Specific Condition 21 and Plantwide Condition 7. [Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]


33

Pollutant lb/hr tpy

PM10 55.4 190.5

VOC 88.8 305.1

CO 56.5 234.9

NOx 55.9 232.5


lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions and CAM compliance will be demonstrated by complying with Specific Condition 21 and Plantwide Condition 7. [Regulation 18, §18.801, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]

Pollutant lb/hr tpy

PM 55.4 190.5


Methanol 4.05 14.0


as measured by EPA Reference Method 9. [40 CFR Part 52, Subpart E]


15 20% Regulation 19, §19.503

21. Daily visible emission observations shall be used as a method of compliance verification

for the opacity limits assigned. The daily observations shall be conducted by someone familiar with the facility�s visible emissions. If during the observations, visible emissions are detected which appear to be in excess of the permitted opacity limit, the permittee shall: a. Take immediate action to identify the cause of the visible emissions, b. Implement corrective action, and c. If excessive visible emissions are still detected, an opacity reading shall be conducted

in accordance with EPA Reference Method 9 for point sources and in accordance with EPA Method 22 for non-point sources. This reading shall be conducted by a



34

person trained and certified in the reference method. If the opacity reading exceeds the permitted limit, further corrective measures shall be taken.






c. The name of the person conducting the observation/reading. [Regulation 19, §19.503 and 40 CFR Part 52, Subpart E]

22. The permittee shall record the number of excursions that have occurred at SN-15 for

opacity. If there are nine (9) excursions in a six month period for opacity or outlet flowrate the facility will be required to submit a Quality Improvement Plan (QIP). The QIP should provide the following information:

a. procedures to improve the quality of control performance; b. procedures that will be implemented to reduce the probability of a recurrence of the problem; c. a schedule for making such improvements.



35

SN-16 Pre-dryer

Source Description

The 39 million Btu per hour pre-dryer (SN-16) is used to remove moisture from the green wood residue. Once this is accomplished, the dried wood residue is sent back to a storage silo to be used later in the manufacturing process. Emissions from the pre-dryer are sent through a cyclone, wet electrostatic precipitator (WESP), and finally through to a regenerative thermal oxidizer (RTO) for reduction. The facility is permitted to use sander dust as the primary fuel for the pre-dryer and natural gas for the RTO. While the pre-dryer is not in operation 20% of the exhaust from the hot oil heater can be routed through the pre-dryer to prevent condensation buildup which causes corrosion. While the hot oil heaters emissions are being routed through the pre-dryer TIFPC will continue to operate the wet ESP but will not operate the RTO as a control device.

Compliance Assurance Monitoring The Compliance Assurance Monitoring (CAM) rule applies to any pollutant specific emission unit that (1) is subject to an emission limitation or standard, (2) uses a control device to achieve compliance with the emission limitation or standard, and (3) has potential pre-control emissions of the regulated pollutant that exceed or are equivalent to the major source threshold of 100 tpy per pollutant. The predryer (SN-16) has pre-control VOC and PM10 emissions of 541.0 and 396.0 tpy respectively. Daily opacity readings, average voltage reading for the WESP, average combustion zone temperature at the RTO, and the average inlet static pressure to insure the control measures are properly operated and maintained. If the threshold levels set in the permit are exceeded greater than 5% of the unit�s total operating time, the facility is required to prepare a Quality Improvement Plan (QIP). A Quality Improvement Plan is a written plan that outlines the procedures that will be used to evaluate problems that affect the performance of control equipment. The Department requires a source to develop and implement a QIP after a determination that the source has failed to use acceptable procedures in responding to an exceedance.


lb/hr emissions are based upon maximum operating capacity of the control equipment.


36

The tpy emissions and CAM compliance will be demonstrated by complying with Specific Condition 27 and Plantwide Condition 7. [Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]

Pollutant lb/hr tpy

PM10 4.6 11.07

VOC 6.1 14.8

CO 32.44 103.1

NOx 44.5 194.6



Pollutant lb/hr tpy

PM 4.6 11.07


Methanol 0.01 0.03




16 20% Regulation 19, §19.503


for the opacity limits assigned. The daily observations shall be conducted by someone familiar with the facility�s visible emissions. If during the observations, visible emissions are detected which appear to be in excess of the permitted opacity limit, the permittee shall: a. Take immediate action to identify the cause of the visible emissions,



37

b. Implement corrective action, and c. If excessive visible emissions are still detected, an opacity reading shall be conducted








27. The permittee shall test the RTO (SN-16) each year for PM10, NOx, CO and VOC

emissions using EPA Reference Methods 5, 7E, 10 and 25A respectively, and for opacity using EPA Reference Method 9. These tests shall be performed simultaneously. While performing the tests, the dryer shall be operating at least 90% of the maximum throughput rate. If testing is conducted at a rate lower than 90%, the facility shall be limited to an operating rate of 110% of the tested rate until compliance at a higher rate is demonstrated. The permittee shall submit a written testing protocol to the Compliance Section Manager at least 15 days prior to any scheduled test. If the facility passes three consecutive tests for this source, the permittee may apply for less stringent testing. [Regulation 19, §19.702, §19.901 et. seq., and 40 CFR Part 52, Subpart E]

28. The minimum voltage for the WESP shall not fall below 20 kV. Compliance shall be

demonstrated through compliance with Specific Condition 29. [40 CFR Part 64, Regulation 19, �19.703 and �19.901 et seq., 40 CFR Part 52, Subpart E, and A.C.A. �8-4-203 as referenced by A.C.A. �8-4-304 and �8-4-311]

29. The permittee shall use continuous monitoring of the voltage for the WESP (SN-16). If

the voltage is below the permitted limit, immediate action is to be taken to identify the


38

cause of the excursion, implement corrective action, and document that the voltage does not appear to be below the permitted limit following 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 upon request. [40 CFR Part 64, Regulation 19, �19.703 and �19.901 et seq., 40 CFR Part 52, Subpart E, and A.C.A. �8-4-203 as referenced by A.C.A. �8-4-304 and �8-4-311]

30. The minimum combustion zone temperature shall not fall below 1450oF. Compliance

shall be demonstrated through compliance with Specific Condition 32. [40 CFR Part 64, Regulation 19, �19.703 and �19.901 et seq., 40 CFR Part 52, Subpart E, and A.C.A. �8-4-203 as referenced by A.C.A. �8-4-304 and �8-4-311]

31. The maximum inlet static pressure reading shall not exceed 5 inches H2O. Compliance

shall be demonstrated through compliance with Specific Condition 32. [40 CFR Part 64, Regulation 19 �19.703 and �19.901 et seq., 40 CFR Part 52, Subpart E, and A.C.A. �8-4-203 as referenced by A.C.A. �8-4-304 and �8-4-311]

32. The permittee shall use continuous monitoring of the combustion zone temperature and

inlet static pressure at source SN-16. If the combustion zone temperature and inlet static pressure is not within the permitted limit, immediate action is to be taken to identify the cause of the excursion, implement corrective action, and document that the pressure drop 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 procedures to prevent the excursion from recurring. These records shall be kept on site and made available to Department personnel upon request. [40 CFR Part 64, Regulation 19, �19.705 and �19.901 et seq. and 40 CFR Part 52, Subpart E]

33. The permittee shall record the number of excursions that have occurred at SN-16 for


a. procedures to improve the quality of control performance;

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

c. a schedule for making such improvements.



39

SN-17A Press Vent RTO Stack

Source Description

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

Compliance Assurance Monitoring The Compliance Assurance Monitoring (CAM) rule applies to any pollutant specific emission unit that (1) is subject to an emission limitation or standard, (2) uses a control device to achieve compliance with the emission limitation or standard, and (3) has potential pre-control emissions of the regulated pollutant that exceed or are equivalent to the major source threshold of 100 tpy per pollutant. The RTO vent stack (SN-17A) has pre-control VOC emissions of 241.0 tpy. Combustion zone temperature and inlet static pressure readings will be made continuously, also daily opacity readings will be used to insure the control measures are properly operated and maintained. If the threshold levels set in the permit are exceeded greater than 5% of the unit�s total operating time, the facility is required to prepare a Quality Improvement Plan (QIP). A Quality Improvement Plan is a written plan that outlines the procedures that will be used to evaluate problems that affect the performance of control equipment. The Department requires a source to develop and implement a QIP after a determination that the source has failed to use acceptable procedures in responding to an exceedance.


lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions and CAM compliance will be demonstrated by complying with Specific Condition 38 and Plantwide Condition 7. [Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]


40

Pollutant lb/hr tpy

PM10 2.5 8.5

VOC 3.5 12.1

CO 12.4 49.2

NOx 6.0 24.6



Pollutant lb/hr tpy

PM 2.5 8.5


Methanol 1.6 5.3




17A 20% Regulation 19, §19.503






41








38. The permittee shall test the RTO (SN-17A) each year for PM10, NOx, CO and VOC

emissions using EPA Reference Methods 5, 7E, 10 and 25A respectively, and for opacity using EPA Reference Method 9. These tests shall be performed simultaneously. While performing the tests, the press shall be operating at least 90% of the maximum throughput rate. If testing is conducted at a rate lower than 90%, the facility shall be limited to an operating rate of 110% of the tested rate until compliance at a higher rate is demonstrated. The permittee shall submit a written testing protocol to the Compliance Section Manager at least 15 days prior to any scheduled test. If the facility passes three consecutive tests for this source, the permittee may apply for less stringent testing. [Regulation 19, §19.702, §19.901 et. seq., and 40 CFR Part 52, Subpart E]

39. The minimum combustion zone temperature shall not fall below 1450 oF. Compliance

shall be demonstrated through compliance with Specific Condition 41. [40 CFR Part 64, Regulation 19, �19.703 and �19.901 et seq., 40 CFR Part 52, Subpart E, and A.C.A. �8-4-203 as referenced by A.C.A. �8-4-304 and �8-4-311]

40. The maximum inlet static pressure reading shall not exceed 5 inches H2O. Compliance

shall be demonstrated through compliance with Specific Condition 41. [40 CFR Part 64, Regulation 19 �19.703 and �19.901 et seq., 40 CFR Part 52, Subpart E, and A.C.A. �8-4-203 as referenced by A.C.A. �8-4-304 and �8-4-311]

41. The permittee shall use continuous monitoring of the combustion zone temperature and

inlet static pressure at source SN-17A. If the combustion zone temperature and inlet


42

static pressure is not within the permitted limit, immediate action is to be taken to identify the cause of the excursion, implement corrective action, and document that the pressure drop 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 procedures to prevent the excursion from recurring. These records shall be kept on site and made available to Department personnel upon request. [40 CFR Part 64, Regulation 19, �19.705 and �19.901 et seq. and 40 CFR Part 52, Subpart E]

42. The permittee shall record the number of excursions that have occurred at SN-17A for


a. procedures to improve the quality of control performance;

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

c. a schedule for making such improvements.



43

SN-20, 21, and 22 Cooler Vent

Source Description

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

Specific Conditions 43. The permittee shall not exceed the emission rates set forth in the following table.

Compliance with this condition will be demonstrated by compliance with Specific Condition 45 and Plantwide Conditions 7 and 9. [Regulation 19, §19.501 et seq. and 40 CFR Part 52, Subpart E]


20

21

22

PM10 VOC

0.7 10.6

2.2 36.3

44. The permittee shall not exceed the emission rates set forth in the following table.

Compliance with this condition will be demonstrated by compliance with Specific Condition 45 and Plantwide Conditions 7 and 9. [Regulation 18, §18.801, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]


20

21

22

PM Formaldehyde

Methanol

0.7 0.54 3.6

2.2 1.87 12.1




44


20, 21, & 22 20% Regulation 19, §19.503











45

SN-09, SN-27 through SN-33 Material 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 green wood residue is stored in the Green Material Silo (SN-28). Green wood residue is dried by the pre-dryer and stored in the Dried Green Material Silo (SN-29). Dried waste material from the process is returned and stored in one of four other silos (SN-30 through SN-33). Each of these silos utilizes 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 is collected by a cyclone and sent to the silo. Emissions from the loading of the silo are controlled by a baghouse.




09 PM10 0.2

27 PM10 0.1

28 PM10 0.1

29 PM10 0.1

30 PM10 0.1

31 PM10 0.1

32 PM10 0.1

33 PM10 0.1

2.4


lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions will be demonstrated by complying with Plantwide Conditions 5 and


46

7. [Regulation 18, §18.801, and A.C.A. §8-4-203 as referenced by §8-4-304 and §8-4-311]


09 PM 0.2

27 PM 0.1

28 PM 0.1

29 PM 0.1

30 PM 0.1

31 PM 0.1

32 PM 0.1

33 PM 0.1

2.4




09

27 - 33 5% Regulation 18, §18.501






47








TIN Inc., dba Temple-Inland Permit #: 1533-AOP-R5 AFIN: 29-00120

48

SECTION V: COMPLIANCE PLAN AND SCHEDULE

TIN Inc., dba Temple-Inland will continue to operate in compliance with those identified regulatory provisions. The facility will examine and analyze future regulations that may apply and determine their applicability with any necessary action taken on a timely basis.


49

SECTION VI: PLANTWIDE CONDITIONS

1. The permittee shall notify the Director in writing within thirty (30) days after commencing construction, completing construction, first placing the equipment and/or facility in operation, and reaching the equipment and/or facility target production rate. [Regulation 19, §19.704, 40 CFR Part 52, Subpart E, and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

2. If the permittee fails to start construction within eighteen months or suspends

construction for eighteen months or more, the Director may cancel all or part of this permit. [Regulation 19, §19.410(B) and 40 CFR Part 52, Subpart E]

3. The permittee must test any equipment scheduled for testing, unless stated in the Specific

Conditions of this permit or by any federally regulated requirements, within the following time frames: (1) new equipment or newly modified equipment within sixty (60) days of achieving the maximum production rate, but no later than 180 days after initial start up of the permitted source or (2) operating equipment according to the time frames set forth by the Department or within 180 days of permit issuance if no date is specified. The permittee must notify the Department of the scheduled date of compliance testing at least fifteen (15) days in advance of such test. The permittee shall submit the compliance test results to the Department within thirty (30) days after completing the testing. [Regulation 19, §19.702 and/or Regulation 18 §18.1002 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

4. The permittee must provide: [Regulation 19, §19.702 and/or Regulation 18, §18.1002

and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

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

5. The permittee must operate the equipment, control apparatus and emission monitoring

equipment within the design limitations. The permittee shall maintain the equipment in good condition at all times. [Regulation 19, §19.303 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

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

[Regulation 26 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311] 7. The permittee shall not receive more than 347,600 ODT of dry and green wood; included

in this total is no more than 70,000 ODT of green wood material, during any twelve month period. [Regulation 19, §19.705 and §19.1901 et seq., A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311 and 40 CFR Part 70.6]


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8. The permittee shall maintain monthly records of the amount of raw wood purchased and the amount of green wood purchased each month. Records shall be updated by the fifteenth day of the month for which the records pertain. These records shall be kept on site, and shall be made available to Department personnel upon request. A twelve month rolling average and each individual month�s data shall be submitted in accordance with General Provision 7. [Regulation 19, §19.705 and §19.901 et seq. and 40 CFR Part 52, Subpart E]

9. The permittee shall use no more than 44,000 tons of urea-formaldehyde resin during any

twelve consecutive month period. [Regulation 18, §18.1004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

10. 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 the month following the month for which the records pertain. These records shall be kept on site, and shall be made available to Department personnel upon request. A twelve month rolling average and each individual month�s data shall be submitted in accordance with General Provision 7. [Regulation 18, §18.1004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

11. The permittee shall achieve a minimum of 90% control efficiency for PM10 emissions

from the Pre-Dryer (SN-16) control systems (cyclone, WESP and RTO). Compliance shall be demonstrated through compliance with Plantwide Condition #12. [Regulation 19, �19.901 et seq. and 40 CFR Part 52, Subpart E]

12. The permittee shall conduct inlet/outlet testing of the control system for SN-16 to

determine the PM10 control efficiency. This test shall be conducted a minimum of once every 3 years. The permittee shall maintain the results from this test on site and these results shall be made available to Department personnel upon request. [Regulation 19, �19.702 and 40 CFR Part 52, Subpart E]

13. The permittee must prepare and implement a Startup, Shutdown, and Malfunction Plan

(SSM). If the Department requests a review of the SSM, the permittee will make the SSM available for review. The permittee must keep a copy of the SSM at the source’s location and retain all previous versions of the SSM plan for five years. [Regulation 19, §19.304 and 40 CFR 63.6(e)(3)]

14. This facility is considered an affected source under 40 CFR Part 63, Subpart DDDD,

National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products and shall comply with all requirements applicable to a new or existing affected source contained in this subpart no later than October 1, 2007. A copy of this subpart can be found in Appendix A. The permittee shall also submit a permit application by April 1, 2007 which will include all necessary changes to the permit to demonstrate compliance with Subpart DDDD. [Regulation 19, �19.304 and 40 CFR Part


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63, Subpart UUUU, National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products]

Acid Rain (Title IV) 15. The Director prohibits the permittee to cause any emissions exceeding any allowances the

source lawfully holds under Title IV of the Act or the regulations promulgated under the Act. No permit revision is required for increases in emissions allowed by allowances acquired pursuant to the acid rain program, if such increases do not require a permit revision under any other applicable requirement. This permit establishes no limit on the number of allowances held by the permittee. However, the source may not use allowances as a defense for noncompliance with any other applicable requirement of this permit or the Act. The permittee will account for any such allowance according to the procedures established in regulations promulgated under Title IV of the Act. [Regulation 26, §26.701 and 40 CFR 70.6(a)(4)]

Title VI Provisions 16. The permittee must comply with the standards for labeling of products using ozone-

depleting substances. [40 CFR Part 82, Subpart E]

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

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

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

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

17. The permittee must comply with the standards for recycling and emissions reduction,

except as provided for MVACs in Subpart B. [40 CFR Part 82, Subpart F]

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

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

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

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


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

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

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

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

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

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

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

20. The permittee can switch from any ozone depleting substance to any alternative listed in the Significant New Alternatives Program (SNAP) promulgated pursuant to 40 CFR Part 82, Subpart G.


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SECTION VII: INSIGNIFICANT ACTIVITIES The following sources are insignificant activities. Any activity that has a state or federal applicable requirement shall be considered a significant activity even if this activity meets the criteria of §26.304 of Regulation 26 or listed in the table below. Insignificant activity determinations rely upon the information submitted by the permittee in an application dated July 11, 2001.

Description Category

Fluid Bed Processor Baghouse A-13


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SECTION VIII: GENERAL PROVISIONS 1. Any terms or conditions included in this permit which specify and reference Arkansas

Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the sole origin of and authority for the terms or conditions are not required under the Clean Air Act or any of its applicable requirements, and are not federally enforceable under the Clean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 was adopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.). Any terms or conditions included in this permit which specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A. §8-4-101 et seq.) as the origin of and authority for the terms or conditions are enforceable under this Arkansas statute. [40 CFR 70.6(b)(2)]

2. This permit shall be valid for a period of five (5) years beginning on the date this permit

becomes effective and ending five (5) years later. [40 CFR 70.6(a)(2) and §26.701(B) of the Regulations of the Arkansas Operating Air Permit Program (Regulation 26), effective September 26, 2002]

3. The permittee must submit a complete application for permit renewal at least six (6)

months before permit expiration. Permit expiration terminates the permittee’s right to operate unless the permittee submitted a complete renewal application at least six (6) months before permit expiration. If the permittee submits a complete application, the existing permit will remain in effect until the Department takes final action on the renewal application. The Department will not necessarily notify the permittee when the permit renewal application is due. [Regulation 26, §26.406]

4. Where an applicable requirement of the Clean Air Act, as amended, 42 U.S.C. 7401, et

seq. (Act) is more stringent than an applicable requirement of regulations promulgated under Title IV of the Act, the permit incorporates both provisions into the permit, and the Director or the Administrator can enforce both provisions. [40 CFR 70.6(a)(1)(ii) and Regulation 26, §26.701(A)(2)]

5. The permittee must maintain the following records of monitoring information as required

by this permit. [40 CFR 70.6(a)(3)(ii)(A) and Regulation 26, §26.701(C)(2)]

a. The date, place as defined in this permit, and time of sampling or measurements; b. The date(s) analyses performed; c. The company or entity performing 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. The permittee must retain the records of all required monitoring data and support

information for at least five (5) years from the date of the monitoring sample,


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measurement, report, or application. Support information includes all calibration and maintenance records and all original strip chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. [40 CFR 70.6(a)(3)(ii)(B) and Regulation 26, §26.701(C)(2)(b)]

7. The permittee must submit reports of all required monitoring every six (6) months. If

permit establishes no other reporting period, the reporting period shall end on the last day of the anniversary month of the initial Title V permit. The report is due within thirty (30) days of the end of the reporting period. Although the reports are due every six months, each report shall contain a full year of data. The report must clearly identify all instances of deviations from permit requirements. A responsible official as defined in Regulation No. 26, §26.2 must certify all required reports. The permittee will send the reports to the address below: [40 C.F.R. 70.6(a)(3)(iii)(A) and Regulation 26, §26.701(C)(3)(a)]

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

8. The permittee shall report to the Department all deviations from permit requirements,

including those attributable to upset conditions as defined in the permit.

a. For all upset conditions (as defined in Regulation19, § 19.601), the permittee will make an initial report to the Department by the next business day after the discovery of the occurrence. The initial report my be made by telephone and shall include:

i. The facility name and location

ii. The process unit or emission source deviating from the permit limit, iii. The permit limit, including the identification of pollutants, from which

deviation occurs, iv. The date and time the deviation started, v. The duration of the deviation,

vi. The average emissions during the deviation, vii. The probable cause of such deviations,

viii. Any corrective actions or preventive measures taken or being taken to prevent such deviations in the future, and

ix. The name of the person submitting the report.

The permittee shall make a full report in writing to the Department within five (5) business days of discovery of the occurrence. The report must include, in addition to the information required by the initial report, a schedule of actions taken or planned to eliminate future occurrences and/or to minimize the amount the permit’s limits were exceeded and to reduce the length of time the limits were exceeded. The


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permittee may submit a full report in writing (by facsimile, overnight courier, or other means) by the next business day after discovery of the occurrence, and the report will serve as both the initial report and full report.

b. For all deviations, the permittee shall report such events in semi-annual reporting

and annual certifications required in this permit. This includes all upset conditions reported in 8a above. The semi-annual report must include all the information as required by the initial and full reports required in 8a.

[Regulation 19, §19.601 and §19.602, Regulation 26, §26.701(C)(3)(b), and 40 CFR 70.6(a)(3)(iii)(B)]

9. If any provision of the permit or the application thereof to any person or circumstance is

held invalid, such invalidity will not affect other provisions or applications hereof which can be given effect without the invalid provision or application, and to this end, provisions of this Regulation are declared to be separable and severable. [40 CFR 70.6(a)(5), Regulation 26, §26.701(E), and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

10. The permittee must comply with all conditions of this Part 70 permit. Any permit

noncompliance with applicable requirements as defined in Regulation 26 constitutes a violation of the Clean Air Act, as amended, 42 U.S.C. §7401, et seq. and is grounds for enforcement action; for permit termination, revocation and reissuance, for permit modification; or for denial of a permit renewal application. [40 CFR 70.6(a)(6)(i) and Regulation 26, §26.701(F)(1)]

11. It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity to maintain compliance with the conditions of this permit. [40 CFR 70.6(a)(6)(ii) and Regulation 26, §26.701(F)(2)]

12. The Department may modify, revoke, reopen and reissue the permit or terminate the

permit for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition. [40 CFR 70.6(a)(6)(iii) and Regulation 26, §26.701(F)(3)]

13. This permit does not convey any property rights of any sort, or any exclusive privilege.

[40 CFR 70.6(a)(6)(iv) and Regulation 26, §26.701(F)(4)] 14. The permittee must furnish to the Director, within the time specified by the Director, any

information that the Director may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. Upon request, the permittee must also furnish to the Director copies of records required by the permit. For information the permittee claims confidentiality, the Department may require the permittee to furnish such records directly to the Director


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along with a claim of confidentiality. [40 CFR 70.6(a)(6)(v) and Regulation 26, §26.701(F)(5)]

15. The permittee must pay all permit fees in accordance with the procedures established in

Regulation 9. [40 CFR 70.6(a)(7) and Regulation 26, §26.701(G)] 16. No permit revision shall be required, under any approved economic incentives,

marketable permits, emissions trading and other similar programs or processes for changes provided for elsewhere in this permit. [40 CFR 70.6(a)(8) and Regulation 26, §26.701(H)]

17. If the permit allows different operating scenarios, the permittee shall, contemporaneously

with making a change from one operating scenario to another, record in a log at the permitted facility a record of the operational scenario. [40 CFR 70.6(a)(9)(i) and Regulation 26, §26.701(I)(1)]

18. The Administrator and citizens may enforce under the Act all terms and conditions in this

permit, including any provisions designed to limit a source’s potential to emit, unless the Department specifically designates terms and conditions of the permit as being federally unenforceable under the Act or under any of its applicable requirements. [40 CFR 70.6(b) and Regulation 26, §26.702(A) and (B)]

19. Any document (including reports) required by this permit must contain a certification by

a responsible official as defined in Regulation 26, §26.2. [40 CFR 70.6(c)(1) and Regulation 26, §26.703(A)]

20. The permittee must allow an authorized representative of the Department, upon

presentation of credentials, to perform the following: [40 CFR 70.6(c)(2) and Regulation 26, §26.703(B)]

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

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

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

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

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

21. The permittee shall submit a compliance certification with the terms and conditions

contained in the permit, including emission limitations, standards, or work practices. The permittee must submit the compliance certification annually within 30 days following the last day of the anniversary month of the initial Title V permit. The permittee must also


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submit the compliance certification to the Administrator as well as to the Department. All compliance certifications required by this permit must include the following: [40 CFR 70.6(c)(5) and Regulation 26, §26.703(E)(3)]

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

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

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

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

22. Nothing in this permit will alter or affect the following: [Regulation 26, §26.704(C)]

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

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

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

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

23. This permit authorizes only those pollutant emitting activities addressed in this permit.

[A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]


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