STATEMENT OF BASIS For the issuance of Draft Air Permit # 0697-AOP-R13 AFIN: 14-00037 1. PERMITTING AUTHORITY: Arkansas Department of Environmental Quality 5301 Northshore Drive North Little Rock, Arkansas 72118-5317 2. APPLICANT: Deltic Timber Corporation (Waldo Mill) 1720 Highway 82 West Waldo, Arkansas 71770 3. PERMIT WRITER: Charles Hurt, P.E. 4. NAICS DESCRIPTION AND CODE: NAICS Description: Sawmills NAICS Code: }-21113 5. SUBMITTALS: 11/1/2012 6. REVIEWER'S NOTES: This facility is an existing major source under 40 CFR §52.21, Prevention of Significant Deterioration (PSD) regulations because the facility has the potential to emit more than 250 tpy of at least one regulated New Source Review (NSR) pollutant. The following PSD analysis pertains to kiln conversion project and associated increase in production. Modification PSD Applicability The PSD applicability test for the project is presented below and is based on actual to project actual test found at 40 CFR §52.21 (a)(2)(iv)(c). The test determines ifthe difference between the projected actual emissions and the baseline actual emissions for each existing emission unit equals or exceeds the significant amount for that pollutant.
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STATEMENT OF BASIS
For the issuance of Draft Air Permit # 0697-AOP-R13 AFIN: 14-00037
1. PERMITTING AUTHORITY:
Arkansas Department of Environmental Quality5301 Northshore DriveNorth Little Rock, Arkansas 72118-5317
This facility is an existing major source under 40 CFR §52.21, Prevention of SignificantDeterioration (PSD) regulations because the facility has the potential to emit more than250 tpy of at least one regulated New Source Review (NSR) pollutant. The followingPSD analysis pertains to kiln conversion project and associated increase in production.
Modification PSD Applicability
The PSD applicability test for the project is presented below and is based on actual toproject actual test found at 40 CFR §52.21 (a)(2)(iv)(c). The test determines ifthedifference between the projected actual emissions and the baseline actual emissions foreach existing emission unit equals or exceeds the significant amount for that pollutant.
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S02 and Lead, also regulated NSR pollutants, are emitted and have the potential to beemitted in such small quantities that even potential to emit for those pollutants couldnever exceed the significant amount. Therefore, those pollutants are not considered inthe applicability test that follows.
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PSD Applicability Test
Except for GHG, the increase was adjusted for demand growth.The GHG emissions were summed for the boilers and the increase was determined using PTE to BAE test.
Total Increase 16.52 8.10 120.96 24.84 15.69 53,799*PSD SER 25 15/10 40 100 40 75,000
Is Netting Required? No No Yes No No No~
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The applicability test shows only one pollutant, VOC, that exceeds the SER. As such,PSD review for particulates, CO, and NOx is concluded. Deltic declined to provide anetting demonstration to determine if contemporaneous changes result in a significant netemission increase at the facility. In the absence of that demonstration Deltic assumed andconcluded that PSD review is triggered for Ozone for which VOC is the surrogate.
PSD regulations require when the actual to projected actual test is used furtherconsideration as to whether or not a reasonable possibility exists for a pollutant thatincreased but did not trigger PSD review. Reasonable possibility is said to exist if apollutant increases by more than 50% of the significant emission rate for that pollutant.The preceding table shows that PM, PMIO, and PM2.5 are within 50% of their respectivesignificant emission rate. Therefore, a reasonable possibility exists that this project couldresult in increases that would otherwise trigger PSD review. Special provisions to trackthose increases were included in the plantwide conditions.
BACT Analysis Summary
Any major source or major modification subject to PSD review must conduct an analysisto ensure the use of best available control technology (BACT). The requirements forconducting BACT can be found in the PSD regulations and applies to each source foreach pollutant that exceeds the SER. A BACT analysis is required for each new orexisting emission unit at which a net emissions increase in the pollutant would occur as aresult of a physical change or change in the method of operation in the unit. Theemission units and pollutants that require BACT are listed below.
The methodology used here to determine BACT follows the top-down method describedin a 1987 memorandum from the EPA Assistant Administrator for Air and Radiation.Following the top-down method all available control technologies are ranked indescending order of control effectiveness. The most stringent control available for asimilar or identical source or source category is identified, and a determination offeasibility is made. If the most stringent level of control is determined to be infeasiblebased on technical, economic, environmental, or energy related reasons, then the nextmost stringent option is evaluated. The process continues until the BACT level underconsideration cannot be eliminated. If the emission unit and pollutant is subject to anapplicable State Implementation Plan emission limitation, New Source PerformanceStandard (40 CFR Part 60) or a National Emission Standard for Hazardous Pollutants (40
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CFR Part 61) then BACT can be no less stringent than the emission standards specifiedby those applicable regulations. The New Source Review Workshop Manual (Draft Oct1990) lists the five basic steps of conducting this analysis.
BACT Evaluation for Continuous Steam Heated Kilns
Step 1. Identify All Control Technologies. - The following technologies were consideredfor controlling VOC emissions from the proposed kilns:
Pollutant Control TechnologyIncinerationAdsorption
VOC AbsorptionCondensationProper Operation of the Kiln
Step 2. Eliminate Technically Infeasible Control Technologies - The second step is todetermine which control technologies are infeasible for technical reasons. Each controltechnologies for each pollutant is considered, those that are clearly technically infeasibleare eliminated.
Adsorption: With adsorption, the VOC gases pass through an adsorbent (an activatedcarbon bed is most common), and the VOCs are adsorbed in the adsorbent. The cleanedgas is then released to the atmosphere. Because the exhaust gas from a lumber kiln(continuous or batch) has a high moisture content (at or near 100% relative humidity), thewater molecules in the gas stream will compete with the hydrocarbon molecules in thegas stream for activated adsorption sites, and the sites will be filled with water.Therefore, adsorption is not a technically feasible technology for controlling VOCemissions from lumber kilns (continuous or batch).
Absorption: Absorption (or physisorption) is similar to adsorption (or chemisorptions) inthat it employs an absorbent (again, an activated carbon bed is most common) for VOCremoval; however, in absorption, the VOC that is being collected and removed from thegas stream actually penetrates and is absorbed into the absorbent. Similarly toadsorption, gas streams with a high moisture content are not a viable candidate for thistype of control, because the water molecules in the gas stream will compete with thehydrocarbon molecules in the gas stream for activated adsorption sites, and the sites willbe filled with water. Therefore, absorption is not a technically feasible technology forcontrolling VOC emissions from lumber kilns (continuous or batch).
Condensation: Condensation removes VOC from gas steams by cooling the stream to alow enough temperature that most contaminants are condensed as a liquid and thenseparated from the gas stream. Condensation is only effective when the gas stream canbe cooled to a temperature where the vapor pressure of the gas stream is less than theVOC concentration. To reduce the vapor pressure ofterpenes, the primary constituent of
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lumber kiln emissions, the temperature would need to be reduced to -40 of. At thistemperature, the unit would plug up with ice from the water vapor. Therefore,condensation is not a technically feasible technology for controlling VOC emissions fromlumber kilns (continuous or batch).
Incineration/RTO: Regenerative Thermal Oxidizer (RTO) units use beds of ceramicstoneware or other heat exchange media to recover and store heat. The gas stream to becontrolled passes through a heated bed before entering a combustion chamber. In thecombustion chamber, the gas steam is heated by auxiliary fuel (typically natural gas) toan oxidation temperature of typically 1,500 OF or higher to achieve maximum VOCdestruction. The exhaust gas temperature from a lumber kiln (continuous or batch) isbetween 150 OF and 200 OF and the gas stream has a high moisture content, as discussedabove. Essentially, all of the heat needed to achieve an oxidation temperature of 1,500 OFor greater would have to be supplied by the combustion of auxiliary fuel, which wouldgenerate additional air pollutants including NOx and CO. Due to the high moisturecontent and low exit temperature ofthe exhaust stream, an RTO would be technicallyinfeasible technology for controlling VOC emissions from lumber kilns (continuous orbatch). There are no facilities that currently utilize incineration to control VOCemissions at lumber drying kilns (continuous or batch).
Additionally, there have been no variations in the method of operation demonstrated thatwould result in a reduction in VOC emissions. For each of the above listed controltechnologies (including any combinations of these technologies or subsets), the air flowsnecessary for ventilation and air circulation required within the kiln to maintainappropriate temperature and moisture levels would be disrupted by the vacuum necessaryto direct the air flow to a control device. This would also negatively affect the quality ofthe product exiting the kiln.
Step 3. Rank Remaining Control Technologies - The third step is to rank the remainingcontrol technologies based on effectiveness.
The only remaining control option to be considered at the lumber drying kiln is properdesign and operation of the system.
Step 4. Top Down Evaluation ofControl Options - The fourth step is to evaluate theremaining control technologies based on economic, energy, and environmentalconsiderations.
The only remaining control option to be considered at the lumber drying kiln is properdesign and operation of the system. Therefore, evaluation of the other considerations isunnecessary.
Step 5. Select BACT - The most effective control option not eliminated is BACT. ProperKiln Operation is BACT because all other control options have been eliminated.
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Information in the RACT/BACT/LAER Clearinghouse (RBLC), publications fromEPA's Clean Air, Technology Center, and other BACT determinations for VOC werereviewed in order to select an emission limitation. Deltic proposed limits consistent withthose for other similar facilities which dry southern yellow pine.
'Proper KIln Operation" IS taken to mean observmg a proper drymg schedule and a temperature selectedbased on moisture content of the lumber to be dried and the manufacturer's specifications. Propermaintenance will also be completed on all kilns based on the manufacturer's recommendations.
In reviewing the sources of information above Deltic found that there were other facilitieswith limits lower than 3.5 lb VOC/MBF. Those facilities were found to be located in adifferent geographical region and processing species of wood other than southern yellowpine.BACT Evaluation for Wood-Fired Boilers #1, #2, #3
Step 1. Identify All Control Technologies. - The following technologies were consideredfor controlling VOC emissions from the boilers:
Pollutant Control TechnologyIncinerationAdsorption
Step 2. Eliminate Technically Infeasible Control Technologies - The second step is todetermine which control technologies are infeasible for technical reasons. Each controltechnologies for each pollutant is considered, those that are clearly technically infeasibleare eliminated.
Adsorption, absorption, and condensation would not be feasible options based on the lowconcentration ofVOC in the exhaust stream. Additionally, each control technologywould require Waldo to significantly lower the temperature of the exhaust stream beforeentering the control device, which is a difficult and costly step considering the hightemperature of the boiler exhaust. Once the exhaust temperature is reduced, each of thesecontrol processes would have to be sized based on the total exhaust from the boiler onlyto extract a very small amount ofVOC, which would be very costly based on the VOCemission rates at Waldo.
Incineration, or the use of an RTO, to control VOC emissions from another combustionsource would not be a feasible option. The exhaust stream would already be at a high
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temperature and would face the same issues as the other options, in that the VOCconcentration in the exhaust stream is extremely low. This would require large amountsofnatural gas to be introduced to a device to control a small amount of VOC and thusincrease the NOx and CO emissions at the source.
Step 3. Rank Remaining Control Technologies - The third step is to rank the remainingcontrol technologies based on effectiveness.
The only remaining control option to be considered for the boilers is good combustionpractices.
Step 4. Top Down Evaluation ofControl Options - The fourth step is to evaluate theremaining control technologies based on economic, energy, and environmentalconsiderations.
The only remaining control option to be considered for the boilers is good combustionpractices. Therefore, evaluation of the other considerations is unnecessary.
Step 5. Select BACT - The most effective control option not eliminated is BACT. Goodcombustion practices is BACT because all other control options have been eliminated.
Information in the RACT/BACT/LAER Clearinghouse (RBLC), publications fromEPA's Clean Air, Technology Center, and other BACT determinations for VOC werereviewed in order to select an emission limitation. Deltic proposed limits consistent withthose for other similar designed and size (heat input capacity) boilers combusting woodresidue.
Sources Pollutant BACT Determination
Each Boiler 0.07 Ib/MMBtu Stack Testing
(SN-13, SN-14, VOCGood Combustion Method 25A
Practices Once Every FiveSN-20) 25 ppmvd @ 15% O2 Years
Air Quality Analysis
PSD regulations requires the applicant to conduct an air quality analysis for themodification in order to demonstrate that the emissions from the modification along withother applicable increases and decreases will not cause or contribute to the violation ofany National Ambient Air Quality Standard (NAAQS) or PSD increments. For thismodification PSD review was only triggered for CO. The other pollutants identifiedpreviously in the above applicability test are not evaluated here because those pollutantswere not subject to PSD review.
The New Source Review Workshop Manual (Draft Oct 1990) describes a tiered approachthat employs air dispersion modeling for evaluating the impact of modifications (or newsources) that trigger PSD review. This tiered approach begins with preliminary analysis.
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If the results of the preliminary analysis indicate the modification will increase ambientconcentrations by more than the significant ambient impact levels (SIL), then a fullimpact analysis would be performed. The preliminary analysis is used to determinewhether or not the applicant can forgo further analysis (i.e. full impact analysis) for aparticular pollutant, may allow the applicant to be exempted from ambient monitoringdata requirements (preconstruction monitoring), and it is used to define the impact areawithin which a full impact analysis must be performed.
For Ozone or VOC there are no applicable SILs or increments and there is no regulatorysingle source model that has been approved. Oxides of nitrogen emissions are notexpected to increase significantly with this project. Therefore it is presumed little if anyadditional Ozone will be created as a result of the project at Deltic.
Class II Area Additional Impacts Analysis
An additional impact analysis is based existing air quality, the quantity of emissions, andthe sensitivity of local soils, vegetation, and visibility in the project's area of impact. Theadditional impact analysis consists ofthree parts: (1) growth, (2) soils and vegetation, and(3) visibility impairment.
Growth Analysis
The growth analysis evaluates the impact associated with the project on the generalcommercial, residential, and industrial growth within the vicinity of the project. PSDregulations require an assessment of the secondary impacts from applicable projects.Negligible growth during construction of the project is expected and minimal long-termgrowth (i.e., general commercial, residential, industrial or other secondary growth in thearea) is expected following the completion of the project construction due to the smalladditional labor force that will be required to operate and maintain the new equipment.Therefore, it is presumed no adverse impacts from associated growth.
Soils and Vegetation
The purpose of the soil and vegetation analysis is to predict the effect from the increasedemissions on the surrounding area. For most types of soil and vegetation, ambientconcentrations of criteria pollutants below the secondary NAAQS do not result inharmful effect.
The primary soil type around the facility is Bowie-Sacul. These soils are deep,moderately well drained, slowly permeable, nearly level to moderately sloping, and wereformed in marine sediment. The Columbia County area consists mainly of timber. Theagriculture and livestock products usually are of timber, poultry, or cattle but no largescale commercial crops. The maximum ambient impacts are below the secondaryNAAQS, and the impacts on the vegetation and soil are presumed to be negligible.
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Class II Area Visibility
The primary pollutants responsible for visibility impairment are particulates, S02, andNOx. The project will not be subject to PSD review for PM, PM IO, PM2.s, S02 or NOx.As such, implementation ofthe project would not result in modeled degradation ofvisibility.
Class I Area Impact Analysis
Deltic is not located within 100 km of a Class 1. Although the VOC emission increase issignificant, NOx emission increases are not significant. Therefore, it is presumed thatthis project will have little if any additional Ozone formation that would impact any ClassI area.
7. COMPLIANCE STATUS:
The following summarizes the current compliance of the facility including active/pendingenforcement actions and recent compliance activities and issues.
The facility was last inspected on March 22,2012. The inspection report did not identifyany compliance issues.
8. PSD APPLICABILITY:
a) Did the facility undergo PSD review in this permit (i.e., BACT, Modeling, etc.)? Y
b) Is the facility categorized as a major source for PSD? Y• Single pollutant ~ 100 tpy and on the list of28 or single pollutant ~ 250 tpy and not on list, or• C02e potential to emit ~ 100,000 tpy and~lOO tpy/?:250tpy ofcombined GHGs?
If yes, explain why this permit modification is not PSD.
N/A
9. GHG MAJOR SOURCE (TITLE V):
Indicate one:
IZI Facility is classified as a major source for GHG and the permit includes thisdesignation
o Facility does not have the physical potential to be a major GHG sourceo Facility has restrictions on GHG or throughput rates that limit facility to a minor
GHG source. Describe these restrictions:---------------
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10. SOURCE AND POLLUTANT SPECIFIC REGULATORY APPLICABILITY:
Regulation [NSPS, NESHAPSource Pollutant (Part 61 & Part 63), or PSD
only]SN-20 PM/PMIO, VOC, CO, NOx PSD
SN-04, SN-05, SN-07,VOC PSD
SN-08, SN-13, SN-14SN-13, SN-14, SN-20 PM, Opacity 40 CFR Part 60, Subpart De
See emission change and fee calculation spreadsheet in Appendix A.
12. NAAQS EVALUATIONS AND NON-CRITERIA POLLUTANTS:
a) NAAQS:
(i) List the reason for a NAAQS evaluation (i.e. what changes are beingpermitted that would require the evaluation) and pollutants affected. If aNAAQS evaluation is not required, indicate why not.
This permit modification resulted significantly increasing the kiln productioncapacity. The permittee requested to increase emissions ofPMIO due to newsources, modification of existing sources, and increased utilization of sourcesthat emit that pollutant.
(ii) If modeling was proposed and agreed to, list the results below:
Emission RateNAAQS Highest %of
Pollutant(lb/hr)
Standard Averaging Time ConcentrationNAAQS
(ug/m') (ug/rrr')
PMIO 16.7 150 24-Hour 132* 88
Includes Little Rock, AR 2012 background 35 ug/nr'.
The permitted emission rate for criteria pollutants other than PM IO and VOC were notincreased. As such, S02, CO, and NOx were not evaluated for compliance with theNAAQS.
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b) Non-Criteria Pollutants:
1st Tier Screening (PAER)
Estimated hourly emissions from the following sources were compared to thePresumptively Acceptable Emission Rate (PAER) for each compound. The Departmenthas deemed the PAER to be the product, in lb/hr, of 0.1 1 and the Threshold Limit Value(mg/rrr'), as listed by the American Conference of Governmental Industrial Hygienists(ACGIH).
PollutantTLV PAER (lb/hr)=
Proposed lb/hr Pass?(mg/rrr') 0.11 *TLV
Acetaldehyde 45 4.95 1.5 y
Acrolein 0.229 0.02530 0.396 NBenzene 1.60 0.176 0.31 N
Cadmium 0.002 0.00022 0.0024 NChromium 0.05 0.0055 0.0075 N
Lead 0.05 0.0055 0.009 NManganese 0.20 0.022 0.29 N
Mercury 0.01 0.0011 0.0003 YMethanol 262 28.8 7.79 Y
Naphthalene 52.4 5.764 0.07 YNickel 0.1 0.011 0.006 y
Phosphorus 0.1 0.011 0.03 NVinyl Acetate 35.2 3.872 0.50 Y
Xylene 434 47.7 0.86 Y
2nd Tier Screening (PAIL)
AERMOD air dispersion modeling was performed on the estimated hourly emissionsfrom the following sources, in order to predict ambient concentrations beyond theproperty boundary. The Presumptively Acceptable Impact Level (PAIL) for eachcompound has been deemed by the Department to be one one-hundredth of the ThresholdLimit Value as listed by the ACGIH.
Pollutant(PAIL, ug/rrr') = 1/100 of Modeled Concentration
Pass?Threshold Limit Value (ug/rrr')Acrolein 2.29 2.026 YBenzene 16.00 11.57 Y
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Pollutant(PAIL, ug/m') = 1/100 of Modeled Concentration
Pass?Threshold Limit Value (ug/nr')
Cadmium 0.02 0.0029 yChromium 0.50 0.0085 y
Formaldehyde 15.00 5.49 YHCl 29.80 1.85 y
Lead 0.50 0.011 YManganese 2.00 0.110 Y
Phosphorous 1.00 0.036 y
Other Modeling:
Odor:
Odor modeling for hydrogen sulfide or styrene was not performed because the facilityhas not indicated emissions of either pollutant.
