NORTH CAROLINA DIVISION OF
Region: Raleigh Regional Office County: Johnston NC Facility ID: 5100026 Inspector’s Name: Matthew Mahler Date of Last Inspection: 08/19/2015 Compliance Code: 3 / Compliance - inspection Permit Applicability (this application only)
NORTH CAROLINA DIVISION OF AIR QUALITY
Air Permit Review Permit Issue Date: INSERT DATE Facility Data Applicant (Facility’s Name): Lampe and Malphrus Lumber Company
SIP: 2D .0504, .0516, .0521, 1806 NSPS: 2D .0524 Subpart Dc NESHAP: 2D .1111 MACT JJJJJJ PSD: PSD Avoidance: 2Q .0317 for 2D .0530 and 2D .1111 NC Toxics: 112(r): Other: Avoidance - 2Q .0317 for 2D .1100
Facility Address: Lampe and Malphrus Lumber Company 210 North 10th Street Smithfield, NC 27577 SIC: 2421 / Sawmills & Planing Mills General NAICS: 321113 / Sawmills Facility Classification: Before: Title V After: Title V Fee Classification: Before: Title V After: Title V Contact Data Facility Contact James Malphrus President & CEO (919) 934-6152 PO Box 150 Smithfield, NC 27577
Authorized Contact James Malphrus President & CEO (919) 934-6152 PO Box 150 Smithfield, NC 27577
Application Data Technical Contact
Application Number: 5100026.15A Date Received: 05/15/2015 Application Type: Modification Application Schedule: TV-Significant Existing Permit Data Existing Permit Number: 04369/T19 Existing Permit Issue Date: 11/03/2014 Existing Permit Expiration Date: 10/31/2017
James Malphrus President & CEO (919) 934-6152 PO Box 150 Smithfield, NC 27577
Total Actual emissions in TONS/YEAR: CY
SO2
NOX
VOC
CO
PM10
Total HAP
Largest HAP
2014
2.54
23.38
116.27
17.29
31.11
11.96
5.57 [Methanol (methyl alcohol)]
2013
2.72
26.29
115.61
19.00
33.35
12.18
5.53 [Methanol (methyl alcohol)]
2012
2.80
27.81
118.66
19.87
34.44
12.52
5.68 [Methanol (methyl alcohol)]
2011
3.61
30.91
104.85
22.78
40.17
12.26
4.99 [Methanol (methyl alcohol)]
Review Engineer: Charles F. Yirka Review Engineer’s Signature:
Date: INSERT DATE
Comments / Recommendations: Issue 04369/T20 Permit Issue Date: INSERT DATE Permit Expiration Date: October 31, 2017
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I. Purpose of Application The North Carolina Division of Air Quality (DAQ) received Application No. 5100026.15A from Lampe and Malphrus Lumber Company (Lampe and Malphrus) for a Title V significant modification (1-step process) of their lumber mill located in Smithfield, Johnston County, North Carolina on May 15, 2015. The applicant has requested a revised PSD avoidance limit on the number of operating hours on the existing diesel-fired peak shaver/generator (ID No. ES-5) and a new MACT avoidance condition with limits on the throughput of wood processed by the kilns. Application was also made for the transfer and installation of one new/relocated wood-fired boiler (ID No. ES-6) with associated multicyclones (ID Nos. CD06a/06b) and one new/relocated batch lumber drying kiln (ID No. K-9). The applicant provided additional information on October 19, 2015 indicating that when the new kiln begins operation two existing kilns will cease operation. As it appeared the addition of the boiler would trigger a state air toxics review and facility-wide emissions would exceed those emissions rates requiring a permit, a permit condition with operational restrictions was placed in the permit. Finally, Lampe and Malphrus’ potential emissions were reevaluated for NOx, VOCs, HAPs and State Air Toxics. II. Facility Description Lampe and Malphrus produces finished dried lumber. Green southern yellow pine logs are processed by the sawmill into lumber. The lumber is then dried in the steam heated batch kilns. The steam for the kilns is provided by on-site NSPS/Boiler MACT/GACT affected wood-fired boilers which fire green sawdust from the mill. The wood chips generated in the mill are collected and sold. There is are no pneumatic wood chips or sawdust handling operations on site. Lampe and Malphrus also operates an existing RICE MACT/GACT affected diesel-fired generator at the mill for peak shaving. II. Permit Modifications/Changes and TVEE Discussion The following table describes the modifications to the current permit. Page(s)
Section
Cover letter
N/A
3
4-6
6 9 13
Description of Change(s)
-Modified to reflect current permit number, effective date, signatures and latest changes to cover letter. -Inserted increment consumption statement. - Inserted pages nos. for reference purposes. 1 - Permitted Emission Sources - Added new/relocated wood fired boiler ES-6 and new/relocated kiln K-9. - Removed footnote for the previous minor modification. -Inserted new/relocated wood fired boiler ES-6. 2.1 A -Inserted 2D .0504 limitation, HAP and State Air Toxics avoidance in table. 2.1 A c-h -Rewrote condition for 2D .0504 inserting limitation and requiring a stack test and revised MMR for the boiler ES-3. 2.1 A 2.a -Inserted boiler ES-3 into 2D .0516 condition. 2.1 A 3.a and c -Inserted boiler ES-3 into 2D .0521 condition. Required normal to be established. -Inserted boiler ES-3 into 2D .1111 Boiler GACT condition. 2.1 A 5 -Inserted 2D .1111 HAP avoidance in table. 2.1 B -Inserted kiln K-9 and 2D .1111 HAP and 2D .1100 Control of Toxic Air 2.1 C Pollutatnts avoidance in table. -Corrected citation. 2.1 C.1.b
Page 2 of 13
Page(s)
Section
Description of Change(s)
14
2.2 A 2.2 A.2
15
2.2 A.3 2.2 A.4
16-26
3
-Inserted 2D .1111 HAP and 2D .1100 Control of Toxic Air Pollutants avoidance in table. -Revised PSD avoidance allowed hours of operation for peak shaver/generator. -Added new 2D .1111 HAP avoidance condition into permit. -Added new 2D .1100 Control of Toxic Air Pollutants avoidance condition into permit. -Inserted latest General Conditions version 3.7 09/21/15. Conditions were corrected by replacing DENR with DEQ.
Changes to the Title V Equipment Editor (TVEE) were approved by Ms. Jenny Sheppard on November 20, 2015. III.
Statement of Compliance Lampe and Malphrus was issued a Notice of Violation/Notice of Recommendation for Enforcement (NOV/NRE) dated July 10, 2009 for operating an unpermitted 1,250 kW peak shaving generator. No fine was assessed. A Notice of Deficiency (NOD) was issued dated February 7, 2012 for 2D .0524 recordkeeping, which not available for review during the on-site inspection. A NOD was issued dated February 27, 2013 for 2Q .0508 monitoring, which was not being conducted and for recordkeeping, which was not available for review during the on-site inspection. A NOD was issued dated February 28, 2014 for the late submittal of a second half semiannual report. A NOD was issued dated April 11, 2014 for missing the deadlines on four 40 CFR Part 63 (NESHAP), Subpart ZZZZ milestones. A NOV was issued dated March 19, 2015 for the submittal of an incomplete ACC. The last inspection report indicates the facility appears to be in compliance. The permit modification application for Lampe and Malphrus Lumber Company located in Smithfield, Johnston County, North Carolina has been reviewed by NC DAQ to determine compliance with all procedures and requirements. NC DAQ has determined that this facility is complying or will achieve compliance, as specified in the permit, with all requirements that are applicable to the affected sources.
IV.
Regulatory Review The facility is currently subject to the following regulations: 15A NCAC 2D .0504, Particulates from Wood Burning Heat Exchangers 15A NCAC 2D .0516, Sulfur Dioxide Emissions from Combustion Sources 15A NCAC 2D .0521, Control of Visible Emissions 15A NCAC 2D .0524, NSPS 40 CFR Part 60 Subpart Dc 15A NCAC 2D .1111, Maximum Achievable Control Technology (40 CFR 63, Subpart JJJJJJ) 15A NCAC 2D .1111, Maximum Achievable Control Technology (40 CFR 63, Subpart ZZZZ) 15A NCAC 2D .1806, Control and Prohibition of Odorous Emissions 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .0530, Prevention of Significant Deterioration) As a result of this modification the facility will be subject to the following additional regulations: 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1111, Maximum Achievable Control Technology) 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1100, Control of Toxic Air Pollutants) A regulatory review for the following sources affected by this modification will be included in this document: One sawdust-fired boiler (ID No. ES-6, 29 million Btu per hour maximum heat input) with multiclone collectors (ID Nos. CD-6A and CD-7B) Page 3 of 13
This new/relocated wood-fired boiler will be subject to the following regulations: The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Boiler ES-6 0.43 pounds per million Btu
15A NCAC 2D .0504
Sulfur dioxide
2.3 pounds per million Btu
15A NCAC 2D .0516
Visible emissions
20 percent opacity
15A NCAC 2D .0521
N/A
New source performance standards
15A NCAC 2D .0524 40 CFR Part 60, Subpart Dc
Hazardous air pollutants
Work practice standards
15A NCAC 2D .1111 40 CFR Part 63, Subpart JJJJJJ
Odors
State-Enforceable Only Control of odorous emissions See Multiple Emissions Section 2.2.A.1
15A NCAC 2D .1806
Nitrogen oxides
PSD Avoidance Condition Facility-wide NOx emissions shall be less than 250 tons per consecutive 12-month period. See Multiple Emissions Section 2.2.A.2
15A NCAC 2Q .0317 for 15A NCAC 2D .0530
HAPs
MACT Avoidance Condition Facility-wide HAP emissions shall be less than 10/25 tons per consecutive 12-month period. See Multiple Emissions Section 2.2.A.3
15A NCAC 2Q .0317 for 15A NCAC 2D .1111
State Toxic Air Pollutants
State-Enforceable Only See Multiple Emissions Section 2.2.A.4
15A NCAC 2Q .0317 for 15A NCAC 2D .1100
15A NCAC 2D .0504, Particulates from Wood Burning Heat Exchangers - This regulation applies to the two existing wood fired boilers and the new/relocated boiler ES-6. The addition of the third boiler ES-6 will allow lumber drying operations to continue when boilers are shut-down for maintenance and repairs. These boilers supply steam for indirect heating the wood drying kilns. Each boiler has two series multicyclones that control the boiler's particulate emissions. Each boiler has its own particulate limitations. Particulate matter emissions from the existing boilers ES-3 and ES-4 are limited to 0.49 and 0.47 pounds per million Btu, respectively. The allowable particulate emissions limit for the relocated boiler ES-6 is calculated below: E = 1.1698 (Q-0.2230) where; E = allowable emission limit for particulate matter in lb/million Btu. Q = Maximum heat input in million Btu/hour. The total of maximum heat inputs of all wood burning indirect heat exchangers at a plant site in operation, under construction, or with a permit shall be used to determine the allowable emission limit of a wood burning indirect heat exchanger. E = 1.1698 (87-0.2230) Page 4 of 13
E = 0.43 pounds per million Btu The facility conducted emissions testing in 1998 for the existing boilers ES-3 and ES-4 and the results were approved May 10, 2000 by DAQ. The testing demonstrated, while firing green wood sawdust and with fly ash re-injection, existing boilers ES-3 and ES-4, compliance with the 2D .0504 limits. The monitoring requirement requires a monthly external visual inspection of the system ductwork and the multiclones for leaks, and any maintenance and repairs. In conformance with the Permitting Section’s SOP, the new/relocated wood fired boiler ES-6 will be required to conduct a particulate emissions stack test. A test is required within 180 days of the startup. Also, in conformance with the SOP and as this requirement did not appear in the permit, all multiclones associated with the all the boilers will now be required to conduct annual internal inspections. Finally, since emissions testing has not been required since 1998, this engineer recommends when the permit is renewed additional stack testing be required for the existing boilers ES-3 and ES-4 consistent with the testing required for the new/relocated boiler ES-6 that is a stack test be required at least every 5 years. Continued compliance is expected. 15A NCAC 2D .0516, Sulfur Dioxide Emissions from Combustion Sources – The boilers all fire green wood sawdust. This fuel is intrinsically low in sulfur content. Combustion sources firing this fuel will always have emissions rates of less than the allowable emissions rate of 2.3 pounds per million Btu. Therefore, no monitoring recordkeeping or reporting is required. Continued compliance is expected. 15A NCAC 2D .0521, Control of Visible Emissions - This regulation requires visible emissions from the boilers ES-3, ES-4 and new/relocated boiler ES-6 to not be more than 20 percent opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. Based on the compliance history and inspection reports the boilers ES-3 and ES-4, which are similar to new/relocated boiler ES-6, appear to have a history of compliance with this rule. Continued compliance is expected. Within 30 days of the start-up of new/relocated boiler ES-6 the Permittee will observe the stack emissions to establish what normal visible emission are. In conformance with the permitting Section’s SOP a daily observation is required for the wood-fired boilers along with the standard associated monitoring and recordkeeping. Continued compliance is expected. 15A NCAC 2D .0524, NSPS 40 CFR Part 60 Subpart Dc – The existing boilers ES-3 and ES-4 and the new/relocated boiler ES-6 are subject to this rule. The relocation of boiler does not constitute reconstruction, and according to the application, the cost of reconstruction will not exceed 50% the cost of a new unit. See definition of a reconstructed unit as per the general provisions of the NSPS. This rule only requires the Permittee to record and maintain records of the amount of fuel fired each month. Continued compliance is indicated for existing boilers ES-3 and ES-4 while compliance is expected for the new/relocated boiler ES-6. 15A NCAC 2D .1111, Maximum Achievable Control Technology (40 CFR 63, Subpart JJJJJJ) – This facility is considered a HAP minor source and, therefore, the existing boilers ES-3 and ES-4 are subject to the GACT provisions of the Boiler MACT. In addition the new/relocated boiler ES-6 will also be subject to this rule. The rule requires work practice standards to be followed including a tune-up of the new/relocated boiler ES-6 within one week of start-up and biennial tune-ups of all boilers thereafter. A one-time energy assessment is also required for all boilers. The Permittee is also required to follow prescribed notification, reporting and recordkeeping requirements. As there appears to be a history of compliance continued compliance is indicated for existing boilers ES-3 and ES-4 while compliance is expected for the new/relocated boiler ES-6.
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15A NCAC 2D .1806, Control and Prohibition of Odorous Emissions – See Multiple Emissions Section, below. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .0530, Prevention of Significant Deterioration) See Multiple Emissions Source section, below. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1111, Maximum Achievable Control Technology) - See Multiple Emissions section, below. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1100, Control of Toxic Air Pollutants) - See Multiple Emissions section, below.
One diesel-fired peak shaving generator (1250 kW and 1,676 horsepower; ID No. ES-5) with associated diesel oxidation catalyst (ID No. CD-5) Application was made to reduce the NOx PSD avoidance condition limitation on the allowed annual hours of operation. By limiting only the hours of operation this will effectively keep facility-wide NOx emissions from exceeding the major source threshold of 250 tons per year and the facility will remain a PSD minor source. The peak shaver/generator is subject to the following regulations. Changes to the existing permit are indicated by highlighting below: The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Sulfur dioxide
2.3 pounds per million Btu heat input
15A NCAC 2D .0516
Visible emissions
20 percent opacity each
15A NCAC 2D .0521
Hazardous air pollutants
Diesel fuel with a maximum sulfur content of 15 ppm; and Outlet concentration of less than 23 ppmvd of CO corrected to 15% O2 or Reduce CO emissions by 70 percent or more PSD Avoidance Condition Facility-wide NOx emissions shall be less than 250 tons per consecutive 12-month period. See Multiple Emissions Section 2.2.A.2 MACT Avoidance Condition Facility-wide HAP emissions shall be less than 10/25 tons per consecutive 12-month period. See Multiple Emissions Section 2.2.A.3
15A NCAC 2D .1111 40 CFR Part 63, Subpart ZZZZ
Nitrogen oxides
HAPs
15A NCAC 2Q .0317 for 15A NCAC 2D .0530
15A NCAC 2Q .0317 for 15A NCAC 2D .1111
15A NCAC 2D .0516, Sulfur Dioxide Emissions from Combustion Sources – The specific condition associated with the rule did not require changing. As the diesel fuel fired has a maximum sulfur content of 15 ppm compliance will always be demonstrated for this rule, therefore, no monitoring, recordkeeping or reporting is required. Continued compliance is indicated. 15A NCAC 2D .0521, Control of Visible Emissions - The specific condition associated with the rule did not require changing. As no visible emissions are expected no monitoring, recordkeeping or reporting is required. Continued compliance is indicated.
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15A NCAC 2D .1111, Maximum Achievable Control Technology (40 CFR 63, Subpart ZZZZ) - The specific condition associated with the rule did not require changing. Continued compliance is indicated. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .0530, Prevention of Significant Deterioration) See Multiple Emissions section, below. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1111, Maximum Achievable Control Technology) - See Multiple Emissions section, below. Ten steam-heated batch dry kilns (ID Nos. K-0 to K-9) Application was made to construct and operate a new/relocated kiln K-9 and insert a board feet limit of 99.5 MMBF/yr in order to ensure HAP emissions would not exceed 10/25 tons per year and the facility will remain a HAP area source. Additional information as per email dated 10/19/2015 from Tim Monroe, consultant with Bensinger Garrison Environmental, indicated kilns K-5 and K-6 will no longer continue to operate when K-9 begins operation. See discussion below under Multiple Emissions Sources section regarding state air toxics allowing DAQ to establish there will not be an adverse impact on human health. Changes to the existing permit table are indicated by highlighting below: The following table provides a summary of limits and standards for the emission sources described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Visible emissions
20 percent opacity
15A NCAC 2D .0521
Odors
State-Enforceable Only Control of odorous emissions See Multiple Emissions Section 2.2.A.1
15A NCAC 2D .1806
HAPs
MACT Avoidance Condition Facility-wide HAP emissions shall be less than 10/25 tons per consecutive 12-month period. See Multiple Emissions Section 2.1.A.3
15A NCAC 2Q .0317 for 15A NCAC 2D .1111
State Toxic Air Pollutants
State-Enforceable Only See Multiple Emissions Section 2.2.A.4
15A NCAC 2Q .0317 for 15A NCAC 2D .1100
15A NCAC 2D .0521, Control of Visible Emissions - This regulation requires visible emissions existing kilns and new/relocated kiln K-9 to not be more than 20 percent opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. Since it appears visible emissions are negligible from the existing kilns K-0 through K8, negligible visible emission are expected from the new/relocated kiln K-9, therefore, and the Permittee will not be required to observe the stack emissions to establish what normal visible emission are. Therefore, no monitoring, recordkeeping or reporting is required. Continued compliance is indicated. 15A NCAC 2D .1806, Control and Prohibition of Odorous Emissions – See Multiple Emissions Section, below. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1111, Maximum Achievable Control Technology) - See Multiple Emissions section, below.
Page 7 of 13
15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1100, Control of Toxic Air Pollutants) - See Multiple Emissions section, below.
Multiple Emission Sources: All emission sources Changes to the existing permit table are indicated by highlighting below: The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Odors
Odorous emissions must be controlled State-enforceable only
15A NCAC 2D .1806
Nitrogen Oxides
PSD Avoidance Condition Facility-wide NOx emissions shall be less than 250 tons per consecutive 12-month period
15A NCAC 2Q .0317 for 15A NCAC 2D .0530
HAPs
MACT Avoidance Condition Facility-wide HAP emissions shall be less than 10/25 tons per consecutive 12-month period.
15A NCAC 2Q .0317 for 15A NCAC 2D .1111
State Toxic Air Pollutants
Avoidance Conditions - The Permittee shall notify the Regional office that Kiln 9 is in operation; and - Maximum of two boilers shall be operated at any time State-enforceable only
15A NCAC 2Q .0317 for 15A NCAC 2D .1100
15A NCAC 2D .1806, Control and Prohibition of Odorous Emissions – This rule is to provide for the control and prohibition of odorous emissions. The facility will not operate without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. As there appears to be a history of compliance continued compliance is expected. 15A NCAC 2Q .0317, Avoidance Conditions (15A NCAC 2D .0530, Prevention of Significant Deterioration) – Application was made to change the PSD NOx avoidance limit associated with the diesel-fired peak shaver/ generator in order to ensure NOx PTE would not exceed the major source threshold of 250 tons per year. Specifically it was requested the allowed hours of operation be reduced from 8,445 to 8,000 hours per year. As such a conservative estimate of calculated PTE for facility-wide NOx emissions are as follows: Summary of NOx emissions for boilers at 8760 hours: 3 boilers X 27.94 ton/yr = 83.82 tons/yr Say; 39.89 lb/hr for peak shaver/generator operating at requested limit of 8,000 hr/year 39.89 lb/hr X 8,000 hr/yr = 159.96 ton/yr Total NOx PTE = 243.4 ton/yr
Page 8 of 13
Notes: 1. The 3rd new/relocated boiler is for continued plant operation during maintenance and inspection downtime for any single boiler and not for additional connected load (lumber processed by the kilns). So actually only one or two boilers will be operating at any one time. Boiler emissions were based on AP-42 factors and DAQ spreadsheet. 2. No NOx reductions are claimed for the DOC control on the peak/shaver generator, therefore, emissions are conservatively estimated to be uncontrolled. Therefore, the requested operating limit of 8,000 hours per year will ensure facility-wide emissions of NOx will not exceed 250 tons per year. No other limitation is required and as such the only monitoring, recordkeeping and reporting required is the hours of operation. Compliance with 2Q .0317 for 2D. 0530 is expected. Following are changes to the current condition as indicated by strikethrough and highlighting: 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION a. To avoid the applicability of 15A NCAC 2D .0530, the Permittee shall limit the facility-wide NOx emission to less than 250 tons per consecutive 12-month period by limiting the number of hours of operation of the peak shaving generator (ID No. ES-5) to 8,445 8,000 hours per consecutive 12-month period. Testing [15A NCAC 2Q .0508(f)] b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If the results of this test are above the NOx emissions limit in 2.2 A.2.a. above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530. Monitoring/ Recordkeeping [15A NCAC 2Q .0508 (f)] c. The Permittee shall record the number of hours of operation for the peak shaving generator (ID No. ES-5) each month. The Permittee shall be deemed in noncompliance with NCAC 2D .0530 if hours are not recorded or if they exceed the consecutive 12-month operational limit in Section 2.2 A.2.a. above. Reporting [15A NCAC 2Q .0508(f)] d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December, and July 30 of each calendar year for the preceding six-month period between January and June. The report shall contain the monthly NOx emissions for the previous 17 months. The emissions must be calculated for each of the 12-month periods over the previous 17 months. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1111, Maximum Achievable Control Technology) - Application was made to insert a board feet limit of 99.5 MMBF/year in order to ensure HAP emissions PTE would not exceed the major source of 10/25 tons per year and the facility will remain a HAP area source A summary of the PTE for HAP emissions from the kilns follows based on the DAQ Wood Kiln Emissions Calculator Revision C: HAP Potential Emissions Potential Emissions (lb/yr) (tons/yr) Acetaldehyde 5,174 2.59 Page 9 of 13
HAP Acrolein Formaldehyde Methanol Phenol Total
Potential Emissions (lb/yr) 746 1,821 19,801 995 28,537
Potential Emissions (tons/yr) 0.91 0.91 9.90 0.50 14.27
Therefore, the requested operating limit of 99.5 MMBF/year will ensure HAP emissions will not exceed 10/25 tons per year. No other limitation is required and as such the only monitoring, recordkeeping and reporting required is the board feet throughput of operation. Compliance with 2Q .0317 for 2D .1111 is expected. Following is a new permit condition requiring the applicant to track the total board feet of lumber produced each month and calculate emissions for the previous year. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY a. To avoid the applicability of 15A NCAC 2D .1111, the Permittee shall limit the facility-wide emissions of the HAP methanol to less than 10 tons and total HAPs to less than 25 tons per year per consecutive 12-month period by limiting the production of kiln dried wood to 99.5 MMMBF/ year number per consecutive 12-month period. Testing [15A NCAC 2Q .0508(f)] b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If the results of this test are above the HAP emissions limit in 2.2 A.3.a., above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530. Monitoring/ Recordkeeping [15A NCAC 2Q .0508 (f)] c. The Permittee shall record the amount of kiln dried wood each month. The Permittee shall be deemed in noncompliance with NCAC 2D .1111 if the amount of kiln dried wood is not recorded or if the consecutive 12-month operational limit in Section 2.2 A.2.a., above, is exceeded. Reporting [15A NCAC 2Q .0508(f)] d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December, and July 30 of each calendar year for the preceding six-month period between January and June. The report shall contain the board feet of kiln dried wood (MMBF) for the previous 17 months. State Enforceable Only 15A NCAC 2Q .0317, Avoidance Conditions (15A NCAC 2D .1100, Control of Toxic Air Pollutants) – Application was made to include operating conditions to avoid triggering a state air toxics review. During the course of the review the applicant indicated that two kilns, of a total higher capacity, would be decommissioned when the new/relocated kiln begins operation. Even so with the addition of the new/relocated boiler combined the new/relocated kiln and the remaining kilns it was determined that this source would trigger a state air toxics review. For example, the state air toxic pollutant formaldehyde was found to exceed the hourly emissions rate requiring a permit for emissions of formaldehyde if all the boiler emissions were combined with the kilns even when the two kilns ceased operation. As such only two of the three boilers shall be operating at one time.
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Following is a new permit condition with operational restrictions: State Only Requirement 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 2D .1100: CONTROL OF TOXIC AIR POLLUTANTS a. To avoid the applicability of 15A NCAC 2D .1100, the Permittee shall follow the following operating conditions. i. A maximum of two of the three boilers (ID Nos. B-3, B-4 and B-6) shall be operated at one time; and ii. Kiln 5 and Kiln 6 shall cease operating when Kiln 9 begins operation. Monitoring/ Recordkeeping [15A NCAC 2Q .0508 (f)] b. The Permittee shall monitor and maintain daily records of boiler operations. Notification Requirement [15A NCAC 2Q .0508(f)] c. The Permittee shall notify the Regional Air Quality Supervisor within 30 days of the shutdown of Kiln 5 and Kiln 6 ant the start-up of Kiln 9. Reporting [15A NCAC 2Q .0508(f)] d. The Permittee shall submit a quarterly summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding 3-month period between October and December; postmarked on or before April 30 of each calendar year for the preceding 3-month period between January and March; postmarked on or before July 30 of each calendar year for the preceding 3-month period between April and June; postmarked on or before October 30 of each calendar year for the preceding 3-month period between July and September V. Compliance Assurance Monitoring: Pursuant to 40 CFR 64.2, the provisions of the Compliance Assurance Monitoring (CAM) rule are applicable to emission units that meet all of the following criteria: Criteria #1: The unit is subject to an emission limitation AND uses a control device to achieve compliance with the limit; Criteria #2: The unit has pre-control potential emissions that are equal to or greater than 100% of the amount (in tpy) required for a source to be classified as a major source (i.e., 100 tpy of any criteria pollutant or 10 tpy of any HAP; and Criteria #3: The unit is not exempt under 40 CFR 64.2(b). The following table summarizes CAM applicability at Lampe and Malphrus Smithfield, NC mill for the new boiler ES-6 controlled by multiclones: Criteria #2: Criteria #1: Pre-control PTE >100% Criteria #3: Emission Does the Source Use a Control of major source Exempt Under 40 Unit Device? thresholds? CFR 64.2(b)? CAM Source? Yes No Yes No ES-6
Dual multicyclones for PM/PM10 emissions control
(PM10 PTE 8.90 lb/hr @ 39% of the major source threshold)
Post 11/15/90 NESHAP standard applies
Therefore, this source at the Lampe and Malphrus facility is not subject to CAM. Page 11 of 13
VI.
NSPS, NESHAPS, Attainment Status/PSD, Increment Consumption/Generation112(r), Insignificant Activities, PE Requirement, Local Zoning Consistency Requirement NSPS - The facility is subject to New Source Performance Standards, Subpart Dc. NSPS Subpart Dc does apply to the new/relocated boiler ES-6. NESHAPS - The applicant requested a board feet limit be placed in the permit. This ensures that facility-wide potential HAP emissions are less than 10 tons per year for each HAP and less than 25 tons per year for total HAPs. The area source MACT 40 CFR 63 Subpart ZZZZ [National Emission Standards for Hazardous Air Pollutants from Stationary Reciprocating Internal Combustion Engines] will continue to apply to the generator. See discussion above. Attainment Status/PSD - This facility is located in Johnston County, which is in attainment for the ozone NAAQS. The facility currently complies with Prevention of Significant Deterioration Avoidance Condition limiting facility-wide NOx emissions to less than 250 tons per consecutive 12-month period. The permit currently had a limitation on the hours of operation for the peak shaver. With this permit modification the limit of 8,445 hours per consecutive 12-month period was changed to 8,000 hours per consecutive 12month period. In addition a new/relocated wood-fired boiler will be installed at this facility and a new/relocated wood drying kiln will be installed at the facility. As such the facility’s potential to emit of PSD affected criteria pollutants was considered. Potential emissions increases of PM10, VOC attributable to the new boiler and kiln were determined to be less than a major source increase therefore PSD applicability was not a concern. The facility would appear to remain a minor PSD source with this modification. Increment Consumption/Generation – Johnson County is a NC county with a triggered PSD minor source baseline date. Actual hourly emissions increases and decreases are considered for increment purposes. County Johnston
Pollutants PM-10
Baseline Date 10/28/81
Triggered By Diversified Fuels
SO2 Even though the allowable hours of operation are reduced, actual emissions decreases from the peak shaver/generator are not likely as the PM-10 and S02 emissions are insignificant from this emissions unit. Actual emission increases, particularly PM10, due to the installation of a third boiler are not likely. The boilers are to be operated in such a way as to allow two boilers to operate while one is shut-down for maintenance purposes. Actual emission increases of PM10 from the installation of the ninth kiln would be 90,000 BF capacity / 52 hour cycle = 1,731 BF/hr 1,731 BF/hour X 22.42 lb PM10/MMBF/1E 106 BF/MMBF = 0.38 lb/hr of PM/PM10 Even if the removal of kiln 5 and kiln 6 is considered, the emissions decrease will be insignificant, therefore, there is no increment consumed or generated by this modification. 112(r) - This facility is not subject to Section 112(r) of the Clean Air Act requirements. Insignificant Activities – There are no insignificant activities at this facility.
Page 12 of 13
PE Requirement - A professional engineer’s seal (Timothy W. Monroe, Seal No. 028331) was included for this application specifically for the new/relocated boiler with dual multicyclones controls with this modification. Local Zoning Consistency Requirement – Application included documentation indicating the local zoning authority received a copy of the application VII. Facility Wide Air Toxics Air toxics regulations have not been triggered previously for this facility. The state air toxics regulations were last amended May 1, 2014. As per 2Q .0703 – Definitions, a modification means a physical change or change in the method of operation that results in a net increase in emissions or ambient concentration of any pollutant listed in 2Q .0711. The physical changes are the addition of a wood-fired boiler and a kiln and the decommissioning of two kilns. The new combustion source will trigger a toxics review as such SL2012-91 requires DAQ to make a determination that there will be no adverse health effects. It was found that the boilers and kilns have state air toxic air pollutants in common e.g., formaldehyde. It was found that when combined there would be a net increase in emissions. As such, the Permittee requested a permit condition to ensure the emissions of TAPs would not exceed the MEER. With the operational restrictions it was determined the MEERs would not be exceeded. Therefore, there does not appear to be an unacceptable risk to human health as a result of this modification. VIII. Public Notice/EPA and Affected State(s) Review A notice of the DRAFT Title V Permit will be made available pursuant to 15A NCAC 2Q .0521. The notice will provide for a 30-day comment period, with an opportunity for a public hearing. Copies of the public notice will be sent to persons on the Title V mailing list and EPA. Pursuant to 15A NCAC 2Q .0522 the proposed permit and final permit pursuant will be provided to EPA. Also pursuant to 2Q .0522, a notice of the DRAFT Title V Permit will be provided to each affected State at or before the time notice provided to the public under 2Q .0521 above. The Public Notice and EPA Review periods were over on INSERT DATES. Following are comments and responses received from the EPA, the public and/or affected states. INSERT COMMENTS AND REPONSES IX.
Draft/Proposed Permit Review Summary and Recommendations Mr. Charles McEachern of the RRO provided the following comments, RCO’s responses follow: Comment - In the permit the requirement to not operate kilns 5 and 6 needs to be an actual permit condition, not just a footnote. We’ve been told that we can’t enforce footnotes. Response – We agree and have inserted a specific condition in the permit. Comment - In your review where you discuss the toxics, doesn’t SL2012-91 still require DAQ to demonstrate that there will be no adverse health effects from the addition of the boiler? Response – We agree and have inserted an avoidance condition with operational restrictions that will ensure the state air toxics emissions will remain below the MEERs. Issue Permit No. 04369T20.
Page 13 of 13
NORTH CAROLINA DIVISION OF AIR QUALITY
Air Permit Review Permit Issue Date: INSERT DATE Facility Data Applicant (Facility’s Name): Lampe and Malphrus Lumber Company
SIP: 2D .0504, .0516, .0521, 1806 NSPS: 2D .0524 Subpart Dc NESHAP: 2D .1111 MACT JJJJJJ PSD: PSD Avoidance: 2Q .0317 for 2D .0530 and 2D .1111 NC Toxics: 112(r): Other: Avoidance - 2Q .0317 for 2D .1100
Facility Address: Lampe and Malphrus Lumber Company 210 North 10th Street Smithfield, NC 27577 SIC: 2421 / Sawmills & Planing Mills General NAICS: 321113 / Sawmills Facility Classification: Before: Title V After: Title V Fee Classification: Before: Title V After: Title V Contact Data Facility Contact James Malphrus President & CEO (919) 934-6152 PO Box 150 Smithfield, NC 27577
Authorized Contact James Malphrus President & CEO (919) 934-6152 PO Box 150 Smithfield, NC 27577
Application Data Technical Contact
Application Number: 5100026.15A Date Received: 05/15/2015 Application Type: Modification Application Schedule: TV-Significant Existing Permit Data Existing Permit Number: 04369/T19 Existing Permit Issue Date: 11/03/2014 Existing Permit Expiration Date: 10/31/2017
James Malphrus President & CEO (919) 934-6152 PO Box 150 Smithfield, NC 27577
Total Actual emissions in TONS/YEAR: CY
SO2
NOX
VOC
CO
PM10
Total HAP
Largest HAP
2014
2.54
23.38
116.27
17.29
31.11
11.96
5.57 [Methanol (methyl alcohol)]
2013
2.72
26.29
115.61
19.00
33.35
12.18
5.53 [Methanol (methyl alcohol)]
2012
2.80
27.81
118.66
19.87
34.44
12.52
5.68 [Methanol (methyl alcohol)]
2011
3.61
30.91
104.85
22.78
40.17
12.26
4.99 [Methanol (methyl alcohol)]
Review Engineer: Charles F. Yirka Review Engineer’s Signature:
Date: INSERT DATE
Comments / Recommendations: Issue 04369/T20 Permit Issue Date: INSERT DATE Permit Expiration Date: October 31, 2017
Page 1 of 13
I. Purpose of Application The North Carolina Division of Air Quality (DAQ) received Application No. 5100026.15A from Lampe and Malphrus Lumber Company (Lampe and Malphrus) for a Title V significant modification (1-step process) of their lumber mill located in Smithfield, Johnston County, North Carolina on May 15, 2015. The applicant has requested a revised PSD avoidance limit on the number of operating hours on the existing diesel-fired peak shaver/generator (ID No. ES-5) and a new MACT avoidance condition with limits on the throughput of wood processed by the kilns. Application was also made for the transfer and installation of one new/relocated wood-fired boiler (ID No. ES-6) with associated multicyclones (ID Nos. CD06a/06b) and one new/relocated batch lumber drying kiln (ID No. K-9). The applicant provided additional information on October 19, 2015 indicating that when the new kiln begins operation two existing kilns will cease operation. As it appeared the addition of the boiler would trigger a state air toxics review and facility-wide emissions would exceed those emissions rates requiring a permit, a permit condition with operational restrictions was placed in the permit. Finally, Lampe and Malphrus’ potential emissions were reevaluated for NOx, VOCs, HAPs and State Air Toxics. II. Facility Description Lampe and Malphrus produces finished dried lumber. Green southern yellow pine logs are processed by the sawmill into lumber. The lumber is then dried in the steam heated batch kilns. The steam for the kilns is provided by on-site NSPS/Boiler MACT/GACT affected wood-fired boilers which fire green sawdust from the mill. The wood chips generated in the mill are collected and sold. There is are no pneumatic wood chips or sawdust handling operations on site. Lampe and Malphrus also operates an existing RICE MACT/GACT affected diesel-fired generator at the mill for peak shaving. II. Permit Modifications/Changes and TVEE Discussion The following table describes the modifications to the current permit. Page(s)
Section
Cover letter
N/A
3
4-6
6 9 13
Description of Change(s)
-Modified to reflect current permit number, effective date, signatures and latest changes to cover letter. -Inserted increment consumption statement. - Inserted pages nos. for reference purposes. 1 - Permitted Emission Sources - Added new/relocated wood fired boiler ES-6 and new/relocated kiln K-9. - Removed footnote for the previous minor modification. -Inserted new/relocated wood fired boiler ES-6. 2.1 A -Inserted 2D .0504 limitation, HAP and State Air Toxics avoidance in table. 2.1 A c-h -Rewrote condition for 2D .0504 inserting limitation and requiring a stack test and revised MMR for the boiler ES-3. 2.1 A 2.a -Inserted boiler ES-3 into 2D .0516 condition. 2.1 A 3.a and c -Inserted boiler ES-3 into 2D .0521 condition. Required normal to be established. -Inserted boiler ES-3 into 2D .1111 Boiler GACT condition. 2.1 A 5 -Inserted 2D .1111 HAP avoidance in table. 2.1 B -Inserted kiln K-9 and 2D .1111 HAP and 2D .1100 Control of Toxic Air 2.1 C Pollutatnts avoidance in table. -Corrected citation. 2.1 C.1.b
Page 2 of 13
Page(s)
Section
Description of Change(s)
14
2.2 A 2.2 A.2
15
2.2 A.3 2.2 A.4
16-26
3
-Inserted 2D .1111 HAP and 2D .1100 Control of Toxic Air Pollutants avoidance in table. -Revised PSD avoidance allowed hours of operation for peak shaver/generator. -Added new 2D .1111 HAP avoidance condition into permit. -Added new 2D .1100 Control of Toxic Air Pollutants avoidance condition into permit. -Inserted latest General Conditions version 3.7 09/21/15. Conditions were corrected by replacing DENR with DEQ.
Changes to the Title V Equipment Editor (TVEE) were approved by Ms. Jenny Sheppard on November 20, 2015. III.
Statement of Compliance Lampe and Malphrus was issued a Notice of Violation/Notice of Recommendation for Enforcement (NOV/NRE) dated July 10, 2009 for operating an unpermitted 1,250 kW peak shaving generator. No fine was assessed. A Notice of Deficiency (NOD) was issued dated February 7, 2012 for 2D .0524 recordkeeping, which not available for review during the on-site inspection. A NOD was issued dated February 27, 2013 for 2Q .0508 monitoring, which was not being conducted and for recordkeeping, which was not available for review during the on-site inspection. A NOD was issued dated February 28, 2014 for the late submittal of a second half semiannual report. A NOD was issued dated April 11, 2014 for missing the deadlines on four 40 CFR Part 63 (NESHAP), Subpart ZZZZ milestones. A NOV was issued dated March 19, 2015 for the submittal of an incomplete ACC. The last inspection report indicates the facility appears to be in compliance. The permit modification application for Lampe and Malphrus Lumber Company located in Smithfield, Johnston County, North Carolina has been reviewed by NC DAQ to determine compliance with all procedures and requirements. NC DAQ has determined that this facility is complying or will achieve compliance, as specified in the permit, with all requirements that are applicable to the affected sources.
IV.
Regulatory Review The facility is currently subject to the following regulations: 15A NCAC 2D .0504, Particulates from Wood Burning Heat Exchangers 15A NCAC 2D .0516, Sulfur Dioxide Emissions from Combustion Sources 15A NCAC 2D .0521, Control of Visible Emissions 15A NCAC 2D .0524, NSPS 40 CFR Part 60 Subpart Dc 15A NCAC 2D .1111, Maximum Achievable Control Technology (40 CFR 63, Subpart JJJJJJ) 15A NCAC 2D .1111, Maximum Achievable Control Technology (40 CFR 63, Subpart ZZZZ) 15A NCAC 2D .1806, Control and Prohibition of Odorous Emissions 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .0530, Prevention of Significant Deterioration) As a result of this modification the facility will be subject to the following additional regulations: 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1111, Maximum Achievable Control Technology) 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1100, Control of Toxic Air Pollutants) A regulatory review for the following sources affected by this modification will be included in this document: One sawdust-fired boiler (ID No. ES-6, 29 million Btu per hour maximum heat input) with multiclone collectors (ID Nos. CD-6A and CD-7B) Page 3 of 13
This new/relocated wood-fired boiler will be subject to the following regulations: The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Particulate matter
Boiler ES-6 0.43 pounds per million Btu
15A NCAC 2D .0504
Sulfur dioxide
2.3 pounds per million Btu
15A NCAC 2D .0516
Visible emissions
20 percent opacity
15A NCAC 2D .0521
N/A
New source performance standards
15A NCAC 2D .0524 40 CFR Part 60, Subpart Dc
Hazardous air pollutants
Work practice standards
15A NCAC 2D .1111 40 CFR Part 63, Subpart JJJJJJ
Odors
State-Enforceable Only Control of odorous emissions See Multiple Emissions Section 2.2.A.1
15A NCAC 2D .1806
Nitrogen oxides
PSD Avoidance Condition Facility-wide NOx emissions shall be less than 250 tons per consecutive 12-month period. See Multiple Emissions Section 2.2.A.2
15A NCAC 2Q .0317 for 15A NCAC 2D .0530
HAPs
MACT Avoidance Condition Facility-wide HAP emissions shall be less than 10/25 tons per consecutive 12-month period. See Multiple Emissions Section 2.2.A.3
15A NCAC 2Q .0317 for 15A NCAC 2D .1111
State Toxic Air Pollutants
State-Enforceable Only See Multiple Emissions Section 2.2.A.4
15A NCAC 2Q .0317 for 15A NCAC 2D .1100
15A NCAC 2D .0504, Particulates from Wood Burning Heat Exchangers - This regulation applies to the two existing wood fired boilers and the new/relocated boiler ES-6. The addition of the third boiler ES-6 will allow lumber drying operations to continue when boilers are shut-down for maintenance and repairs. These boilers supply steam for indirect heating the wood drying kilns. Each boiler has two series multicyclones that control the boiler's particulate emissions. Each boiler has its own particulate limitations. Particulate matter emissions from the existing boilers ES-3 and ES-4 are limited to 0.49 and 0.47 pounds per million Btu, respectively. The allowable particulate emissions limit for the relocated boiler ES-6 is calculated below: E = 1.1698 (Q-0.2230) where; E = allowable emission limit for particulate matter in lb/million Btu. Q = Maximum heat input in million Btu/hour. The total of maximum heat inputs of all wood burning indirect heat exchangers at a plant site in operation, under construction, or with a permit shall be used to determine the allowable emission limit of a wood burning indirect heat exchanger. E = 1.1698 (87-0.2230) Page 4 of 13
E = 0.43 pounds per million Btu The facility conducted emissions testing in 1998 for the existing boilers ES-3 and ES-4 and the results were approved May 10, 2000 by DAQ. The testing demonstrated, while firing green wood sawdust and with fly ash re-injection, existing boilers ES-3 and ES-4, compliance with the 2D .0504 limits. The monitoring requirement requires a monthly external visual inspection of the system ductwork and the multiclones for leaks, and any maintenance and repairs. In conformance with the Permitting Section’s SOP, the new/relocated wood fired boiler ES-6 will be required to conduct a particulate emissions stack test. A test is required within 180 days of the startup. Also, in conformance with the SOP and as this requirement did not appear in the permit, all multiclones associated with the all the boilers will now be required to conduct annual internal inspections. Finally, since emissions testing has not been required since 1998, this engineer recommends when the permit is renewed additional stack testing be required for the existing boilers ES-3 and ES-4 consistent with the testing required for the new/relocated boiler ES-6 that is a stack test be required at least every 5 years. Continued compliance is expected. 15A NCAC 2D .0516, Sulfur Dioxide Emissions from Combustion Sources – The boilers all fire green wood sawdust. This fuel is intrinsically low in sulfur content. Combustion sources firing this fuel will always have emissions rates of less than the allowable emissions rate of 2.3 pounds per million Btu. Therefore, no monitoring recordkeeping or reporting is required. Continued compliance is expected. 15A NCAC 2D .0521, Control of Visible Emissions - This regulation requires visible emissions from the boilers ES-3, ES-4 and new/relocated boiler ES-6 to not be more than 20 percent opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. Based on the compliance history and inspection reports the boilers ES-3 and ES-4, which are similar to new/relocated boiler ES-6, appear to have a history of compliance with this rule. Continued compliance is expected. Within 30 days of the start-up of new/relocated boiler ES-6 the Permittee will observe the stack emissions to establish what normal visible emission are. In conformance with the permitting Section’s SOP a daily observation is required for the wood-fired boilers along with the standard associated monitoring and recordkeeping. Continued compliance is expected. 15A NCAC 2D .0524, NSPS 40 CFR Part 60 Subpart Dc – The existing boilers ES-3 and ES-4 and the new/relocated boiler ES-6 are subject to this rule. The relocation of boiler does not constitute reconstruction, and according to the application, the cost of reconstruction will not exceed 50% the cost of a new unit. See definition of a reconstructed unit as per the general provisions of the NSPS. This rule only requires the Permittee to record and maintain records of the amount of fuel fired each month. Continued compliance is indicated for existing boilers ES-3 and ES-4 while compliance is expected for the new/relocated boiler ES-6. 15A NCAC 2D .1111, Maximum Achievable Control Technology (40 CFR 63, Subpart JJJJJJ) – This facility is considered a HAP minor source and, therefore, the existing boilers ES-3 and ES-4 are subject to the GACT provisions of the Boiler MACT. In addition the new/relocated boiler ES-6 will also be subject to this rule. The rule requires work practice standards to be followed including a tune-up of the new/relocated boiler ES-6 within one week of start-up and biennial tune-ups of all boilers thereafter. A one-time energy assessment is also required for all boilers. The Permittee is also required to follow prescribed notification, reporting and recordkeeping requirements. As there appears to be a history of compliance continued compliance is indicated for existing boilers ES-3 and ES-4 while compliance is expected for the new/relocated boiler ES-6.
Page 5 of 13
15A NCAC 2D .1806, Control and Prohibition of Odorous Emissions – See Multiple Emissions Section, below. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .0530, Prevention of Significant Deterioration) See Multiple Emissions Source section, below. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1111, Maximum Achievable Control Technology) - See Multiple Emissions section, below. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1100, Control of Toxic Air Pollutants) - See Multiple Emissions section, below.
One diesel-fired peak shaving generator (1250 kW and 1,676 horsepower; ID No. ES-5) with associated diesel oxidation catalyst (ID No. CD-5) Application was made to reduce the NOx PSD avoidance condition limitation on the allowed annual hours of operation. By limiting only the hours of operation this will effectively keep facility-wide NOx emissions from exceeding the major source threshold of 250 tons per year and the facility will remain a PSD minor source. The peak shaver/generator is subject to the following regulations. Changes to the existing permit are indicated by highlighting below: The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Sulfur dioxide
2.3 pounds per million Btu heat input
15A NCAC 2D .0516
Visible emissions
20 percent opacity each
15A NCAC 2D .0521
Hazardous air pollutants
Diesel fuel with a maximum sulfur content of 15 ppm; and Outlet concentration of less than 23 ppmvd of CO corrected to 15% O2 or Reduce CO emissions by 70 percent or more PSD Avoidance Condition Facility-wide NOx emissions shall be less than 250 tons per consecutive 12-month period. See Multiple Emissions Section 2.2.A.2 MACT Avoidance Condition Facility-wide HAP emissions shall be less than 10/25 tons per consecutive 12-month period. See Multiple Emissions Section 2.2.A.3
15A NCAC 2D .1111 40 CFR Part 63, Subpart ZZZZ
Nitrogen oxides
HAPs
15A NCAC 2Q .0317 for 15A NCAC 2D .0530
15A NCAC 2Q .0317 for 15A NCAC 2D .1111
15A NCAC 2D .0516, Sulfur Dioxide Emissions from Combustion Sources – The specific condition associated with the rule did not require changing. As the diesel fuel fired has a maximum sulfur content of 15 ppm compliance will always be demonstrated for this rule, therefore, no monitoring, recordkeeping or reporting is required. Continued compliance is indicated. 15A NCAC 2D .0521, Control of Visible Emissions - The specific condition associated with the rule did not require changing. As no visible emissions are expected no monitoring, recordkeeping or reporting is required. Continued compliance is indicated.
Page 6 of 13
15A NCAC 2D .1111, Maximum Achievable Control Technology (40 CFR 63, Subpart ZZZZ) - The specific condition associated with the rule did not require changing. Continued compliance is indicated. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .0530, Prevention of Significant Deterioration) See Multiple Emissions section, below. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1111, Maximum Achievable Control Technology) - See Multiple Emissions section, below. Ten steam-heated batch dry kilns (ID Nos. K-0 to K-9) Application was made to construct and operate a new/relocated kiln K-9 and insert a board feet limit of 99.5 MMBF/yr in order to ensure HAP emissions would not exceed 10/25 tons per year and the facility will remain a HAP area source. Additional information as per email dated 10/19/2015 from Tim Monroe, consultant with Bensinger Garrison Environmental, indicated kilns K-5 and K-6 will no longer continue to operate when K-9 begins operation. See discussion below under Multiple Emissions Sources section regarding state air toxics allowing DAQ to establish there will not be an adverse impact on human health. Changes to the existing permit table are indicated by highlighting below: The following table provides a summary of limits and standards for the emission sources described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Visible emissions
20 percent opacity
15A NCAC 2D .0521
Odors
State-Enforceable Only Control of odorous emissions See Multiple Emissions Section 2.2.A.1
15A NCAC 2D .1806
HAPs
MACT Avoidance Condition Facility-wide HAP emissions shall be less than 10/25 tons per consecutive 12-month period. See Multiple Emissions Section 2.1.A.3
15A NCAC 2Q .0317 for 15A NCAC 2D .1111
State Toxic Air Pollutants
State-Enforceable Only See Multiple Emissions Section 2.2.A.4
15A NCAC 2Q .0317 for 15A NCAC 2D .1100
15A NCAC 2D .0521, Control of Visible Emissions - This regulation requires visible emissions existing kilns and new/relocated kiln K-9 to not be more than 20 percent opacity when averaged over a six-minute period. However, six-minute averaging periods may exceed 20 percent not more than once in any hour and not more than four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity. Since it appears visible emissions are negligible from the existing kilns K-0 through K8, negligible visible emission are expected from the new/relocated kiln K-9, therefore, and the Permittee will not be required to observe the stack emissions to establish what normal visible emission are. Therefore, no monitoring, recordkeeping or reporting is required. Continued compliance is indicated. 15A NCAC 2D .1806, Control and Prohibition of Odorous Emissions – See Multiple Emissions Section, below. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1111, Maximum Achievable Control Technology) - See Multiple Emissions section, below.
Page 7 of 13
15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1100, Control of Toxic Air Pollutants) - See Multiple Emissions section, below.
Multiple Emission Sources: All emission sources Changes to the existing permit table are indicated by highlighting below: The following table provides a summary of limits and standards for the emission source(s) described above:
Regulated Pollutant
Limits/Standards
Applicable Regulation
Odors
Odorous emissions must be controlled State-enforceable only
15A NCAC 2D .1806
Nitrogen Oxides
PSD Avoidance Condition Facility-wide NOx emissions shall be less than 250 tons per consecutive 12-month period
15A NCAC 2Q .0317 for 15A NCAC 2D .0530
HAPs
MACT Avoidance Condition Facility-wide HAP emissions shall be less than 10/25 tons per consecutive 12-month period.
15A NCAC 2Q .0317 for 15A NCAC 2D .1111
State Toxic Air Pollutants
Avoidance Conditions - The Permittee shall notify the Regional office that Kiln 9 is in operation; and - Maximum of two boilers shall be operated at any time State-enforceable only
15A NCAC 2Q .0317 for 15A NCAC 2D .1100
15A NCAC 2D .1806, Control and Prohibition of Odorous Emissions – This rule is to provide for the control and prohibition of odorous emissions. The facility will not operate without implementing management practices or installing and operating odor control equipment sufficient to prevent odorous emissions from the facility from causing or contributing to objectionable odors beyond the facility's boundary. As there appears to be a history of compliance continued compliance is expected. 15A NCAC 2Q .0317, Avoidance Conditions (15A NCAC 2D .0530, Prevention of Significant Deterioration) – Application was made to change the PSD NOx avoidance limit associated with the diesel-fired peak shaver/ generator in order to ensure NOx PTE would not exceed the major source threshold of 250 tons per year. Specifically it was requested the allowed hours of operation be reduced from 8,445 to 8,000 hours per year. As such a conservative estimate of calculated PTE for facility-wide NOx emissions are as follows: Summary of NOx emissions for boilers at 8760 hours: 3 boilers X 27.94 ton/yr = 83.82 tons/yr Say; 39.89 lb/hr for peak shaver/generator operating at requested limit of 8,000 hr/year 39.89 lb/hr X 8,000 hr/yr = 159.96 ton/yr Total NOx PTE = 243.4 ton/yr
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Notes: 1. The 3rd new/relocated boiler is for continued plant operation during maintenance and inspection downtime for any single boiler and not for additional connected load (lumber processed by the kilns). So actually only one or two boilers will be operating at any one time. Boiler emissions were based on AP-42 factors and DAQ spreadsheet. 2. No NOx reductions are claimed for the DOC control on the peak/shaver generator, therefore, emissions are conservatively estimated to be uncontrolled. Therefore, the requested operating limit of 8,000 hours per year will ensure facility-wide emissions of NOx will not exceed 250 tons per year. No other limitation is required and as such the only monitoring, recordkeeping and reporting required is the hours of operation. Compliance with 2Q .0317 for 2D. 0530 is expected. Following are changes to the current condition as indicated by strikethrough and highlighting: 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 2D .0530: PREVENTION OF SIGNIFICANT DETERIORATION a. To avoid the applicability of 15A NCAC 2D .0530, the Permittee shall limit the facility-wide NOx emission to less than 250 tons per consecutive 12-month period by limiting the number of hours of operation of the peak shaving generator (ID No. ES-5) to 8,445 8,000 hours per consecutive 12-month period. Testing [15A NCAC 2Q .0508(f)] b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If the results of this test are above the NOx emissions limit in 2.2 A.2.a. above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530. Monitoring/ Recordkeeping [15A NCAC 2Q .0508 (f)] c. The Permittee shall record the number of hours of operation for the peak shaving generator (ID No. ES-5) each month. The Permittee shall be deemed in noncompliance with NCAC 2D .0530 if hours are not recorded or if they exceed the consecutive 12-month operational limit in Section 2.2 A.2.a. above. Reporting [15A NCAC 2Q .0508(f)] d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December, and July 30 of each calendar year for the preceding six-month period between January and June. The report shall contain the monthly NOx emissions for the previous 17 months. The emissions must be calculated for each of the 12-month periods over the previous 17 months. 15A NCAC 2Q .0317, Avoidance of (15A NCAC 2D .1111, Maximum Achievable Control Technology) - Application was made to insert a board feet limit of 99.5 MMBF/year in order to ensure HAP emissions PTE would not exceed the major source of 10/25 tons per year and the facility will remain a HAP area source A summary of the PTE for HAP emissions from the kilns follows based on the DAQ Wood Kiln Emissions Calculator Revision C: HAP Potential Emissions Potential Emissions (lb/yr) (tons/yr) Acetaldehyde 5,174 2.59 Page 9 of 13
HAP Acrolein Formaldehyde Methanol Phenol Total
Potential Emissions (lb/yr) 746 1,821 19,801 995 28,537
Potential Emissions (tons/yr) 0.91 0.91 9.90 0.50 14.27
Therefore, the requested operating limit of 99.5 MMBF/year will ensure HAP emissions will not exceed 10/25 tons per year. No other limitation is required and as such the only monitoring, recordkeeping and reporting required is the board feet throughput of operation. Compliance with 2Q .0317 for 2D .1111 is expected. Following is a new permit condition requiring the applicant to track the total board feet of lumber produced each month and calculate emissions for the previous year. 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 2D .1111: MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY a. To avoid the applicability of 15A NCAC 2D .1111, the Permittee shall limit the facility-wide emissions of the HAP methanol to less than 10 tons and total HAPs to less than 25 tons per year per consecutive 12-month period by limiting the production of kiln dried wood to 99.5 MMMBF/ year number per consecutive 12-month period. Testing [15A NCAC 2Q .0508(f)] b. If emissions testing is required, the Permittee shall perform such testing in accordance with General Condition JJ. If the results of this test are above the HAP emissions limit in 2.2 A.3.a., above, the Permittee shall be deemed in noncompliance with 15A NCAC 2D .0530. Monitoring/ Recordkeeping [15A NCAC 2Q .0508 (f)] c. The Permittee shall record the amount of kiln dried wood each month. The Permittee shall be deemed in noncompliance with NCAC 2D .1111 if the amount of kiln dried wood is not recorded or if the consecutive 12-month operational limit in Section 2.2 A.2.a., above, is exceeded. Reporting [15A NCAC 2Q .0508(f)] d. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding six-month period between July and December, and July 30 of each calendar year for the preceding six-month period between January and June. The report shall contain the board feet of kiln dried wood (MMBF) for the previous 17 months. State Enforceable Only 15A NCAC 2Q .0317, Avoidance Conditions (15A NCAC 2D .1100, Control of Toxic Air Pollutants) – Application was made to include operating conditions to avoid triggering a state air toxics review. During the course of the review the applicant indicated that two kilns, of a total higher capacity, would be decommissioned when the new/relocated kiln begins operation. Even so with the addition of the new/relocated boiler combined the new/relocated kiln and the remaining kilns it was determined that this source would trigger a state air toxics review. For example, the state air toxic pollutant formaldehyde was found to exceed the hourly emissions rate requiring a permit for emissions of formaldehyde if all the boiler emissions were combined with the kilns even when the two kilns ceased operation. As such only two of the three boilers shall be operating at one time.
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Following is a new permit condition with operational restrictions: State Only Requirement 15A NCAC 2Q .0317: AVOIDANCE CONDITIONS for 15A NCAC 2D .1100: CONTROL OF TOXIC AIR POLLUTANTS a. To avoid the applicability of 15A NCAC 2D .1100, the Permittee shall follow the following operating conditions. i. A maximum of two of the three boilers (ID Nos. B-3, B-4 and B-6) shall be operated at one time; and ii. Kiln 5 and Kiln 6 shall cease operating when Kiln 9 begins operation. Monitoring/ Recordkeeping [15A NCAC 2Q .0508 (f)] b. The Permittee shall monitor and maintain daily records of boiler operations. Notification Requirement [15A NCAC 2Q .0508(f)] c. The Permittee shall notify the Regional Air Quality Supervisor within 30 days of the shutdown of Kiln 5 and Kiln 6 ant the start-up of Kiln 9. Reporting [15A NCAC 2Q .0508(f)] d. The Permittee shall submit a quarterly summary report, acceptable to the Regional Air Quality Supervisor, of monitoring and recordkeeping activities postmarked on or before January 30 of each calendar year for the preceding 3-month period between October and December; postmarked on or before April 30 of each calendar year for the preceding 3-month period between January and March; postmarked on or before July 30 of each calendar year for the preceding 3-month period between April and June; postmarked on or before October 30 of each calendar year for the preceding 3-month period between July and September V. Compliance Assurance Monitoring: Pursuant to 40 CFR 64.2, the provisions of the Compliance Assurance Monitoring (CAM) rule are applicable to emission units that meet all of the following criteria: Criteria #1: The unit is subject to an emission limitation AND uses a control device to achieve compliance with the limit; Criteria #2: The unit has pre-control potential emissions that are equal to or greater than 100% of the amount (in tpy) required for a source to be classified as a major source (i.e., 100 tpy of any criteria pollutant or 10 tpy of any HAP; and Criteria #3: The unit is not exempt under 40 CFR 64.2(b). The following table summarizes CAM applicability at Lampe and Malphrus Smithfield, NC mill for the new boiler ES-6 controlled by multiclones: Criteria #2: Criteria #1: Pre-control PTE >100% Criteria #3: Emission Does the Source Use a Control of major source Exempt Under 40 Unit Device? thresholds? CFR 64.2(b)? CAM Source? Yes No Yes No ES-6
Dual multicyclones for PM/PM10 emissions control
(PM10 PTE 8.90 lb/hr @ 39% of the major source threshold)
Post 11/15/90 NESHAP standard applies
Therefore, this source at the Lampe and Malphrus facility is not subject to CAM. Page 11 of 13
VI.
NSPS, NESHAPS, Attainment Status/PSD, Increment Consumption/Generation112(r), Insignificant Activities, PE Requirement, Local Zoning Consistency Requirement NSPS - The facility is subject to New Source Performance Standards, Subpart Dc. NSPS Subpart Dc does apply to the new/relocated boiler ES-6. NESHAPS - The applicant requested a board feet limit be placed in the permit. This ensures that facility-wide potential HAP emissions are less than 10 tons per year for each HAP and less than 25 tons per year for total HAPs. The area source MACT 40 CFR 63 Subpart ZZZZ [National Emission Standards for Hazardous Air Pollutants from Stationary Reciprocating Internal Combustion Engines] will continue to apply to the generator. See discussion above. Attainment Status/PSD - This facility is located in Johnston County, which is in attainment for the ozone NAAQS. The facility currently complies with Prevention of Significant Deterioration Avoidance Condition limiting facility-wide NOx emissions to less than 250 tons per consecutive 12-month period. The permit currently had a limitation on the hours of operation for the peak shaver. With this permit modification the limit of 8,445 hours per consecutive 12-month period was changed to 8,000 hours per consecutive 12month period. In addition a new/relocated wood-fired boiler will be installed at this facility and a new/relocated wood drying kiln will be installed at the facility. As such the facility’s potential to emit of PSD affected criteria pollutants was considered. Potential emissions increases of PM10, VOC attributable to the new boiler and kiln were determined to be less than a major source increase therefore PSD applicability was not a concern. The facility would appear to remain a minor PSD source with this modification. Increment Consumption/Generation – Johnson County is a NC county with a triggered PSD minor source baseline date. Actual hourly emissions increases and decreases are considered for increment purposes. County Johnston
Pollutants PM-10
Baseline Date 10/28/81
Triggered By Diversified Fuels
SO2 Even though the allowable hours of operation are reduced, actual emissions decreases from the peak shaver/generator are not likely as the PM-10 and S02 emissions are insignificant from this emissions unit. Actual emission increases, particularly PM10, due to the installation of a third boiler are not likely. The boilers are to be operated in such a way as to allow two boilers to operate while one is shut-down for maintenance purposes. Actual emission increases of PM10 from the installation of the ninth kiln would be 90,000 BF capacity / 52 hour cycle = 1,731 BF/hr 1,731 BF/hour X 22.42 lb PM10/MMBF/1E 106 BF/MMBF = 0.38 lb/hr of PM/PM10 Even if the removal of kiln 5 and kiln 6 is considered, the emissions decrease will be insignificant, therefore, there is no increment consumed or generated by this modification. 112(r) - This facility is not subject to Section 112(r) of the Clean Air Act requirements. Insignificant Activities – There are no insignificant activities at this facility.
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PE Requirement - A professional engineer’s seal (Timothy W. Monroe, Seal No. 028331) was included for this application specifically for the new/relocated boiler with dual multicyclones controls with this modification. Local Zoning Consistency Requirement – Application included documentation indicating the local zoning authority received a copy of the application VII. Facility Wide Air Toxics Air toxics regulations have not been triggered previously for this facility. The state air toxics regulations were last amended May 1, 2014. As per 2Q .0703 – Definitions, a modification means a physical change or change in the method of operation that results in a net increase in emissions or ambient concentration of any pollutant listed in 2Q .0711. The physical changes are the addition of a wood-fired boiler and a kiln and the decommissioning of two kilns. The new combustion source will trigger a toxics review as such SL2012-91 requires DAQ to make a determination that there will be no adverse health effects. It was found that the boilers and kilns have state air toxic air pollutants in common e.g., formaldehyde. It was found that when combined there would be a net increase in emissions. As such, the Permittee requested a permit condition to ensure the emissions of TAPs would not exceed the MEER. With the operational restrictions it was determined the MEERs would not be exceeded. Therefore, there does not appear to be an unacceptable risk to human health as a result of this modification. VIII. Public Notice/EPA and Affected State(s) Review A notice of the DRAFT Title V Permit will be made available pursuant to 15A NCAC 2Q .0521. The notice will provide for a 30-day comment period, with an opportunity for a public hearing. Copies of the public notice will be sent to persons on the Title V mailing list and EPA. Pursuant to 15A NCAC 2Q .0522 the proposed permit and final permit pursuant will be provided to EPA. Also pursuant to 2Q .0522, a notice of the DRAFT Title V Permit will be provided to each affected State at or before the time notice provided to the public under 2Q .0521 above. The Public Notice and EPA Review periods were over on INSERT DATES. Following are comments and responses received from the EPA, the public and/or affected states. INSERT COMMENTS AND REPONSES IX.
Draft/Proposed Permit Review Summary and Recommendations Mr. Charles McEachern of the RRO provided the following comments, RCO’s responses follow: Comment - In the permit the requirement to not operate kilns 5 and 6 needs to be an actual permit condition, not just a footnote. We’ve been told that we can’t enforce footnotes. Response – We agree and have inserted a specific condition in the permit. Comment - In your review where you discuss the toxics, doesn’t SL2012-91 still require DAQ to demonstrate that there will be no adverse health effects from the addition of the boiler? Response – We agree and have inserted an avoidance condition with operational restrictions that will ensure the state air toxics emissions will remain below the MEERs. Issue Permit No. 04369T20.
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