adeq operating air permit · bins that feed one of three rotary drum dryers. ... the rotary dryer...

ADEQ OPERATING AIR PERMIT Pursuant to the Regulations of the Arkansas Operating Air Permit Program, Regulation #26: Permit #: 1533-AOP-R4 Renewal #1 IS ISSUED TO: Temple-Inland Forest Products Corporation 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:

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

SECTION I: FACILITY INFORMATION

PERMITTEE: Temple-Inland Forest Products Corporation AFIN: 29-00120 PERMIT NUMBER: 1533-AOP-R4

FACILITY ADDRESS: Route 4, 100 Temple Drive

Hope, AR 71801

COUNTY: Hempstead

CONTACT POSITION: Mr. Ron Tews, Plant Manager TELEPHONE NUMBER: (870) 722-4000

REVIEWING ENGINEER: Wesley Crouch

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

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Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120

SECTION II: INTRODUCTION

Summary of Permit Activity

Temple-Inland Forest Products Corporation (TIFPC) (AFIN:29-00120) owns and operates a particleboard manufacturing facility on Route 4, 100 Temple Drive near Hope (Hempstead County) Arkansas. This is the first title V renewal permit for this facility. This is 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 is being 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 have been changed to take advantage of new NCASI factors. Finally, the Department is clarifying 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 have been adjusted to reflect this.

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.

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Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 Two types of residue are used as raw material, Agreen@ ($18% Oven Dried (OD) moisture content) material and Adry@ (<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 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.

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Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 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 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 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 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.

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Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 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 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

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Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 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 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 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 the Regulations of the Arkansas Operating Air Permit Program (Title V) because it emits over 100 tons 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 and emissions for each source can be found starting on the page cross referenced in the table. This table, in itself, is not an enforceable condition of the permit.

EMISSION SUMMARY

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Emission Rates

Source

No.

Description

Pollutant

lb/hr

tpy

Cross

Reference Page

Total Allowable Emissions

PM

PM10 SO2 VOC CO NOx

67.4 67.4 2.4

162.1 107.1 106.4

226.67 226.67

9.5 557.6 424.6 441.9

HAPs*

Formaldehyd

e Methanol

2.47 10.0

7.97 33.93

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

20

04

Refiners (2)

PM

PM10 VOC

Formaldehyde

Methanol

0.3 0.3 10.1 0.02 0.05

1.0 1.0 35.6 0.06 0.2

20

05

Hammermills (3)

PM

PM10 VOC

Formaldehyde

Methanol

0.2 0.2 15.1 0.03 0.07

0.9 0.9 51.9 0.09 0.3

23

06

Hammermills (3)

PM

PM10 VOC

Formaldehyde

0.2 0.2 15.1 0.03 0.07

0.9 0.9 51.9 0.09 0.3

23

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EMISSION SUMMARY

Emission Rates

Source

No.

Description

Pollutant

lb/hr

tpy

Cross

Reference Page

Methanol

07

Pre-dryer Return System

PM

PM10

0.3 0.3

1.3 1.3

26

08A

Forming Line Dust

Collection

PM

PM10

0.4 0.4

1.4 1.4

26

08B

Formers Dust

Collection

PM

PM10

0.4 0.4

1.5 1.5

26

09

Rough Trim

Material Baghouse

PM

PM10

0.2 0.2

0.7 0.7

45

10

#1 Sander Dust

Collection System

PM

PM10 VOC

Formaldehyde

Methanol

0.2 0.2 0.45 0.02 0.25

0.7 0.7 1.5 0.1 0.75

29

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#2 Sander Dust

Collection System

PM

PM10 VOC

Formaldehyde

Methanol

0.2 0.2 0.45 0.02 0.25

0.7 0.7 1.5 0.1 0.75

29

12

Sander Dust

Transfer System

PM

PM10

0.2 0.2

0.8 0.8

29

13

Finish Saw Dust

Collection

PM

PM10

0.2 0.2

0.7 0.7

29

14

Trim Return

System

PM

PM10

0.3 0.3

1.0 1.0

29

9


10

EMISSION SUMMARY

Emission Rates

Source

No.

Description

Pollutant

lb/hr

tpy

Cross

Reference Page

15 Primary Dryers (3 units)

PM PM10 SO2 VOC CO NOx

Formaldehyde Methanol

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

32

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

35

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

39

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

43

27

Dry Material Silo

Bin Vent Filter

PM

PM10

0.1 0.1

0.3 0.3

45

28

Green Material

PM

0.1

0.3

45


EMISSION SUMMARY

Emission Rates

Source

No.

Description

Pollutant

lb/hr

tpy

Cross

Reference Page

Silo Bin Vent Filter

PM10 0.1 0.3

29

Dried Green

Material Silo Bin Vent

Filter

PM

PM10

0.1 0.1

0.3 0.3

45

30

Dried Trim

Material Silo Bin Vent

Filter

PM

PM10

0.1 0.1

0.3 0.3

45

31

Sander Dust Silo Bin Vent Filter

PM

PM10

0.1 0.1

0.3 0.3

45

32

Dry Face Silo Bin

Vent Filter

PM

PM10

0.1 0.1

0.1 0.1

45

33

Dry Core Silo Bin

Vent Filter

PM

PM10

0.1 0.1

0.1 0.1

45

35

Overs Hammermill

PM

PM10

0.1 0.1

0.1 0.1

23

* HAPs included in the VOC totals are indicated by an *. 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

12


13

NOx 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 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 is 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.

Material Handling and Transferring Operations PM/PM10

Baghouses

Baghouses have a 99.9% removal efficiency.

Maximum Predicted Concentrations with Background

in Comparison with the NAAQS

Pollutant

Averaging Period

Concentration with Background

(Fg/m3)

NAAQS (Fg/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

(Fg/m3)

PSD Increment

(Fg/m3)

24-hour

22.13*

30

PM10

Annual

6.24

17

NOX

Annual

17.66

25 * Used the AHighest 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

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Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 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

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 Fg/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

(Fg/m3)

Long Term

Highest Concentration

(Fg/m3)

PM10

0.11

0.02

15


Pollutant

Short Term

Highest Concentration (Fg/m3)

Long Term

Highest Concentration

(Fg/m3) 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. 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 Aceilings@ 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

16


in Comparison with the NAAQS

Pollutant

Averaging Period

Concentration with Background

(Fg/m3)

NAAQS (Fg/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.

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

(Fg/m3)

PSD Increment

(Fg/m3)

24-hour

28.79*

30

PM10

Annual

6.91

17

NOX

Annual

18.32

25 * Used the AHighest Sixth High@. The proposed increment consumed can never exceed the PSD Increment levels set by the EPA.

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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

Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 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. C The location of concentrations of NOX greater than 12.5 Fg/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 Fg/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 all of its 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. 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.

C 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.

18


SECTION IV: EMISSION UNIT INFORMATION


SN-03 and SN-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. Pursuant to '19.501et seq and '19.901 et seq of the Regulations of the Arkansas State Implementation 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 rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions will be demonstrated by complying with Specific Condition 4 and Plantwide Condition 7.

SN

Pollutant

lb/hr

tpy

03

PM PM10 VOC

0.3 0.3 10.1

1.0 1.0 34.6

04

PM

PM10 VOC

0.3 0.3 10.1

1.0 1.0 35.6

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

effective February 15, 1999, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance shall be demonstrated through compliance with Plantwide Condition 7.

20

SN

Pollutant

lb/hr

tpy

Formaldehyde

0.02

0.06


SN

Pollutant

lb/hr

tpy

03 Methanol 0.05 0.2

04 Formaldehyde

Methanol

0.02 0.05

0.06 0.2

3. Pursuant to '18.501 of Regulation 18, and A.C.A. '8-4-203 as referenced by '8-4-304

and '8-4-311, the permittee shall not exceed 5% opacity from sources SN-03 and SN-04. Compliance with this condition will be demonstrated by complying with Specific Condition 5.

4. Pursuant to '19.303 of Regulation 19 and A.C.A. '8-4-203 as referenced by '8-4-304

and '8-4-311, the permittee shall operate the control equipment associated with these sources in a manner consistent with good air pollution control practices in order to comply with the applicable emission limits.


and '8-4-311, 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:

21


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.

22


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 (Aface@) 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).

Specific Conditions

6. Pursuant to '19.501 et seq and '19.901 et seq of the Regulations of the Arkansas State Implementation 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 rates set forth in the following table. The lb/hr emissions are based upon maximum operating capacity of the control equipment. The tpy emissions will be demonstrated by complying with Specific Condition 9 and Plantwide Condition 7.

SN

Pollutant

lb/hr

tpy

05

PM PM10 VOC

0.2 0.2 15.1

0.9 0.9 51.9

06

PM

PM10 VOC

0.2 0.2 15.1

0.9 0.9 51.9

35

PM

PM10

0.1 0.1

0.1 0.1



23


SN

Pollutant

lb/hr

tpy

05

Formaldehyde

Methanol

0.03 0.07

0.09 0.3

06

Formaldehyde

Methanol

0.03 0.07

0.09 0.3


and '8-4-311, the permittee shall not exceed 5% opacity from sources SN-05, SN-06 and SN-35. Compliance with this condition will be demonstrated by complying with Specific Condition 10.




and '8-4-311, weekly visible emission observations shall be used as a method of compliance verification for the opacity limits assigned for the sources whose Specific Conditions reference this Plantwide Condition. 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:





24





25


SN-07 Pre-dryer Return System

SN-08A and SN-08B

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. Daily 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 effect 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.

Specific Conditions

11. Pursuant to '19.501 et seq and '19.901 et seq of the Regulations of the Arkansas State Implementation 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 rates set forth in the following table. The 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 Conditions 12 and Plantwide Condition 7.

26


SN

Pollutant

lb/hr

tpy

07

PM

PM10

0.3 0.3

1.3 1.3

08A

PM

PM10

0.4 0.4

1.4 1.4

08B

PM

PM10

0.4 0.4

1.5 1.5

12. Pursuant to 40 CFR Part 64, '19.503 of Regulation 19 and 40 CFR Part 52, Subpart E,

the permittee shall not exceed 5% opacity from sources SN-07, SN-08A and SN-08B. Compliance with this condition will be demonstrated by complying with Specific Condition 13.


and '8-4-311, daily visible emission observations shall be used as a method of compliance verification for the opacity limits assigned for the sources whose Specific Conditions reference this Plantwide Condition. 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:





27




c. The name of the person conducting the observation/reading. 14. Pursuant to 40 CFR Part 64, 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:

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 personnel upon request.

28


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).

Specific Conditions

15. 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, 1999 and 40 CFR Part 52, Subpart E, 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. The tpy emissions will be demonstrated by complying with Specific Condition 18 and Plantwide Condition 7.

29

SN

Pollutant

lb/hr

tpy

10 and 11

PM

PM10 VOC

0.4 0.4 0.9

1.4 1.4 3.0

12

PM

PM10

0.2 0.2

0.8 0.8

13

PM

PM10

0.2 0.2

0.7 0.7

PM

0.3

1.0


SN

Pollutant

lb/hr

tpy

14 PM10 0.3 1.0 16. Pursuant to '18.801 of the Arkansas Air Pollution Control Code (Regulation #18)


SN

Pollutant

lb/hr

tpy 10 and 11

Formaldehyde

Methanol

0.04 0.5

0.2 1.5


and '8-4-311, the permittee shall not exceed 5% opacity from sources SN-10 through SN-14. Compliance with this condition will be demonstrated by complying with Specific Condition 19.




and '8-4-311, daily visible emission observations shall be used as a method of compliance verification for the opacity limits assigned for these sources. 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:



30




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,



31


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 effect 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.

Specific Conditions

20. 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, 1999 and 40 CFR Part 52, Subpart E, 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. The tpy emissions and CAM compliance will be demonstrated by complying with Specific Conditions 22 and Plantwide Condition 7.

32


Pollutant

lb/hr

tpy

PM

PM10

55.4 55.4

190.5 190.5

VOC

88.8

305.1

CO

56.5

234.9

NOX

55.9

232.5


effective February 15, 1999, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by Plantwide Condition 9.

Pollutant

lb/hr

tpy


0.72 4.05

1.8 14.0

22. Pursuant to '19.503 of Regulation 19 and 40 CFR Part 52, Subpart E, the permittee shall

not exceed 20% opacity from sources SN-15. Compliance shall be demonstrated through compliance with Specific Condition 23.

23. Pursuant to '19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, the visible

emission observations shall be used as a method of compliance verification for the opacity limits assigned for this source. 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:



33







c. The name of the person conducting the observation/reading. 24. Pursuant to 40 CFR Part 64, 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:


problem; 3. a schedule for making such improvements.


34


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 effect 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.

35 35


Specific Conditions

25. 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, 1999 and 40 CFR Part 52, Subpart E, 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. The tpy emissions and CAM compliance will be demonstrated by complying with Specific Conditions 28, 29, 31 and 32 and Plantwide Condition 7.

Pollutant

lb/hr

tpy

PM PM10

4.6 4.6

11.07 11.07

VOC

6.1

14.8

CO

32.44

103.1

NOX

44.5

194.6



Pollutant

lb/hr

tpy


0.07 0.01

0.3 0.03

27. Pursuant to ' 19.503 (Regulation 19) and 40 CFR Part 52, Subpart E, the permittee shall

not exceed 20% opacity from sources SN-16. Compliance shall be demonstrated through compliance with Specific Condition 28.

28. Pursuant to '19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, the visible


36 36









c. The name of the person conducting the observation/reading. 29. Pursuant to '19.702 of Regulation #19, 19.901 et seq, and 40 CFR Part 52, Subpart E, 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.

30. Pursuant to 40 CFR Part 64, '19.703 and '19.901 et seq of Regulation 19, 40 CFR Part

52, Subpart E, and A.C.A. '8- 4-203 as referenced by '8-4-304 and '8-4-311, the minimum voltage for the WESP shall not fall below 20 kV. Compliance shall be demonstrated through compliance with Specific Condition 31.

37 37

Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 31. Pursuant to 40 CFR Part 64, '19.705 and '19.901 et seq of Regulation 19, and 40 CFR

Part 52, Subpart E, 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 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.


52, Subpart E, and A.C.A. '8- 4-203 as referenced by '8-4-304 and '8-4-311, the minimum combustion zone temperature shall not fall below 1450oF. Compliance shall be demonstrated through compliance with Specific Condition 34.


52, Subpart E, and A.C.A. '8- 4-203 as referenced by '8-4-304 and '8-4-311, the maximum inlet static pressure reading shall not exceed 5 inches H2O. Compliance shall be demonstrated through compliance with Specific Condition 34.

34. Pursuant to 40 CFR Part 64, '19.705 and '19.901 et seq of Regulation 19, and 40 CFR

Part 52, Subpart E, 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.

35. Pursuant to 40 CFR Part 64, the permittee shall record the number of excursions that

have occurred at SN-16 for opacity, voltage, combustion zone temperature, and inlet static pressure. If there are nine (9) excursions in a six month period for opacity, combustion zone temperature, or inlet static pressure the facility will be required to submit a Quality Improvement Plan (QIP). The QIP should provide the following information:


problem;

38 38


3. a schedule for making such improvements.


39 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 effect 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.

Specific Conditions

36. 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, 1999 and 40 CFR Part 52, Subpart E, 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. The tpy emissions and CAM compliance will be demonstrated by complying with Specific Conditions 38, 41, and 42 and Plantwide Condition 7.

40 40


Pollutant

lb/hr

tpy

PM

PM10

2.5 2.5

8.5 8.5

VOC

3.5

12.1

CO

12.4

49.2

NOX

6.0

24.6



Pollutant

lb/hr

tpy


1.0 1.6

3.5 5.3

38. Pursuant to ' 19.503 (Regulation 19) and 40 CFR Part 52, Subpart E, the permittee shall

not exceed 20% opacity from sources SN-17A. Compliance shall be demonstrated through compliance with Specific Condition 40.

39. Pursuant to '19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, daily visible




41 41







c. The name of the person conducting the observation/reading. 40. Pursuant to '19.702 of Regulation #19, 19.901 et seq, and 40 CFR Part 52, Subpart E, the

permittee shall test the RTO in 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.


52, Subpart E, and A.C.A. '8- 4-203 as referenced by '8-4-304 and '8-4-311, the minimum combustion zone temperature shall not fall below 1450oF. Compliance shall be demonstrated through compliance with Specific Condition 43.


52, Subpart E, and A.C.A. '8- 4-203 as referenced by '8-4-304 and '8-4-311, the maximum inlet static pressure reading shall not exceed 5 inches H2O. Compliance shall be demonstrated through compliance with Specific Condition 43.

43. Pursuant to 40 CFR Part 64, '19.705 and '19.901 et seq of Regulation 19, and 40 CFR

Part 52, Subpart E, the permittee shall use continuous monitoring of the combustion zone temperature and inlet static pressure at sources SN-17A. If the combustion zone temperature and inlet static pressure is not within the permitted limit, immediate action is

42 42


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.

44. Pursuant to 40 CFR Part 64, the permittee shall record the number of excursions that

have occurred 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 zone temperature, or inlet static pressure the facility will be required to submit a Quality 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.


43 43


SN-20, SN-21, and SN-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

45. 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, 1999 and 40 CFR Part 52, Subpart E, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by compliance with Specific Condition 47 and Plantwide Conditions 7 and 9.

SN

Pollutant

lb/hr

tpy

20 21 22

PM

PM10 VOC

0.7 0.7 10.6

2.2 2.2 36.3


effective February 15, 1999, and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311, the permittee shall not exceed the emission rates set forth in the following table. Compliance with this condition will be demonstrated by compliance with Plantwide Condition 9.

SN

Pollutant

lb/hr

tpy

20 21 22


0.54 3.6

1.87 12.1

47. Pursuant to '19.503 (Regulation 19) and 40 CFR Part 52, Subpart E, the permittee shall

not exceed 20% opacity from sources SN-20 through SN-22. Compliance shall be demonstrated through compliance with Specific Condition 48.

44 44

Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 48. Pursuant to '19.705 of Regulation 19 and 40 CFR Part 52, Subpart E, daily visible

emission observations shall be used as a method of compliance verification for the opacity limits assigned for these sources. 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:









45 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 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 is collected by a cyclone and sent to the silo. Emissions from the loading of the silo are controlled by a baghouse.

Specific Conditions

49. 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, 1999 and 40 CFR Part 52, Subpart E, 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. The tpy emissions will be demonstrated by complying with Specific Condition 51 and Plantwide Condition 7.

SN

Pollutant

lb/hr

tpy

09

PM PM10

0.2 0.2

27

PM

PM10

0.1 0.1

28

PM

PM10

0.1 0.1

29

PM

PM10

0.1 0.1

30

PM

PM10

0.1 0.1

31

PM

0.1

2.4

46 46


SN

Pollutant

lb/hr

tpy

PM10 0.1

32

PM PM10

0.1 0.1

33

PM

PM10

0.1 0.1


and '8-4-311, the permittee shall not exceed 5% opacity from sources SN-09, SN-27 through SN-33. Compliance with this condition will be demonstrated by complying with Specific Condition 52.




and '8-4-311, weekly visible emission observations shall be used as a method of compliance verification for the opacity limits assigned for these sources. 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:




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

47 47


records shall be kept on site and made available to Department personnel upon request. These records shall contain:





48 48


SECTION V: COMPLIANCE PLAN AND SCHEDULE Temple-Inland Forest Products Corporation is in compliance with the applicable regulations cited in the permit application. Temple-Inland Forest Products Corporation 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 49


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

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

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

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

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

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

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

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

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

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

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

50 50

Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 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 referenced

by '8-4-304 and '8-4-311, and 40 CFR 70.6, the permittee shall not receive more than 347,600 ODT of dry and green wood; included in this total no more than 70,000 ODT of green 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 and the amount of green wood purchased 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.


and '8-4-311, the permittee shall use no more than 44,000 tons of urea-formaldehyde resin during any twelve consecutive month period.


and '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 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.

11. Pursuant to '19.901 et seq of Regulation 19 and 40 CFR Part 52, Subpart E, 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.

12. Pursuant to '19.702 of Regulation 19 and 40 CFR Part 52, Subpart E, 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.

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Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 Acid Rain (Title IV) 13. Pursuant to '26.701 of Regulation #26 and 40 CFR 70.6(a)(4), the permittee is prohibited

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

Title VI Provisions 14. The permittee shall comply with the standards for labeling of products using ozone

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

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

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

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

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

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

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

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

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

52 52


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

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

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

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

16. 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.

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

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

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

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

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

53 53

Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 SECTION VII: INSIGNIFICANT ACTIVITIES Pursuant to '26.304 of Regulation 26, the following sources are insignificant activities. Any activity for which a state or federal applicable requirement applies is not insignificant even if this activity meets the criteria of '304 of Regulation 26 or is listed below. Insignificant activity determinations rely upon the information submitted by the permittee in an application dated November 25, 1998 and comments received July 11, 2001.

Description

Category

Fluid Bed Processor Baghouse

A-13

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

54 54

Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 SECTION VIII: GENERAL PROVISIONS 1. Pursuant to 40 CFR 70.6(b)(2), any terms or conditions included in this permit which

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

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

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

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

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

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

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

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

monitoring information required by this permit shall include the following:

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

b. The date(s) analyses were performed;

55 55


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

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

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

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

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

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

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

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

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

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

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

56 56


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

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

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

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

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

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

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

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

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

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

57 57


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

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

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

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

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

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

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

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

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

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

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

58 58

Temple-Inland Forest Products Corporation Permit #: 1533-AOP-R4 AFIN #: 29-00120 19. Pursuant to 40 CFR 70.6(c)(1) and '26.703(A) of Regulation #26, any document

(including reports) required by this permit shall contain a certification by a responsible official as defined in '26.2 of Regulation #26.

20. Pursuant to 40 CFR 70.6(c)(2) and '26.703(B) of Regulation #26, the permittee shall

allow an authorized representative of the Department, upon presentation of credentials, to perform the following:

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

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

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

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

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

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

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

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

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

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

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

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

following:

59 59


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

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

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

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

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

authorizes only those pollutant emitting activities addressed herein.

60 60

APPENDIX A

APPENDIX B

APPENDIX C

APPENDIX D

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

PDS-

AFIN r

29-00120

Name (for confirmation only)

Temple-Inland Forest Products Corporation

Initial

Mod X

Variance

Invoice Type (pick one) r

Annual

Renewal X

Interim Authority

Permit Number r

1533-AOP-R4

Media Code r

A

Fee Code or Pmt Typer

T5

Fee Description (for confirmation only)

Title V

Amount Due r (whole dollar amount only)

$3528

Printed Comment (600 characters maximum)

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

Paid? (yes/no)

Check number

Comments

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

Date:

Public Notice Pursuant to the Arkansas Operating Air Permit Program (Regulation #26) Section 602, the Air Division of the Arkansas Department of Environmental Quality gives the following notice: Temple-Inland Forest Products Corporation (TIFPC) (AFIN:29-00120) owns and operates a particleboard manufacturing facility on Route 4, 100 Temple Drive near Hope (Hempstead County) Arkansas. This is the first title V renewal permit for this facility. This is 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 is being 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 have been changed to take advantage of new NCASI factors. Finally, the Department is clarifying 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 have been adjusted to reflect this. The application has been reviewed by the staff of the Department and has received the Department's tentative approval subject to the terms of this notice. Citizens wishing to examine the permit application and staff findings and recommendations may do so by contacting Doug Szenher, Public Affairs Supervisor. Citizens desiring technical information concerning the application or permit should contact Wesley Crouch, Engineer. Both Doug Szenher and Wesley Crouch can be reached at the Department's central office, 8001 National Drive, Little Rock, Arkansas 72209, telephone: (501) 682-0744. The draft permit and permit application are available for copying at the above address. A copy of the draft permit has also been placed at the Hempstead County Public Library located at 500 South Elm Street in Hope, Arkansas 71801. This information may be reviewed during normal business hours. Interested or affected persons may also submit written comments or request a hearing on the proposal, or the proposed modification, to the Department at the above address - Attention: Doug Szenher. In order to be considered, the comments must be submitted within thirty (30) days of publication of this notice. Although the Department is not proposing to conduct a public hearing, one will be scheduled if significant comments on the permit provisions are received. If a hearing is scheduled, adequate public notice will be given in the newspaper of largest circulation in the county in which the facility in question is, or will be, located. The Director shall make a final decision to issue or deny this application or to impose special conditions in accordance with Section 2.1 of the Arkansas Pollution Control and Ecology Commission=s Administrative Procedures (Regulation #8) and Regulation #26. Dated this Marcus C. Devine Director

adeq operating air permit · bins that feed one of three rotary drum dryers. ... the rotary dryer...

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