U.S. EPA Region 9 Electronic Permit Submittal System
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Note: * indicates required field. Updated:04/13/1999
Detailed Information
Permitting Authority: NORTH COAST UNIFIED AQMD
County: HUMBOLDT (N. COAST) AFS Plant ID: 06-023-12072
Facility: SIMPSON REDWOOD COMPANY
*Document Type: Minor Modification
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April 13, 1999
Matt Haber, Chief
Air Permits Office
US EPA, Region 9
75 Hawthorne Street
San Francisco, CA 94105
Dear Mr. Haber:
With this letter, the District is providing the EPA with Official Notice of a proposed Title V permit reopening for a minor permit modification in accordance with Title 5 permitting requirements of the federal Clean Air Act of 1990. We believe this project meets the requirements for a minor modification as per section 70.7(e)(2). Attached are copies of the permit review and proposed permit unit addition to the Title V permit.
In accordance with District Regulation 5, EPA will have 45 days from the date of receipt of this letter to provide written comments to the District regarding this proposed permit issuance. Earlier comments are suggested to help speed up this minor permit revision.
Sincerely,
Robert Clark
District Engineer
cc: Simpson Redwood Co.
CARB
AUTHORITY TO CONSTRUCT REVIEW
SIMPSON REDWOOD COMPANY, KORBEL
Simpson Redwood has a new sawmill multi-saw trimmer which trims different size lumber to a variety of lengths. In the process of sawing this lumber, sawdust is created which needs to be removed from the sawing process. The pneumatic system designed for the removal of the sawdust uses a 54” diameter cyclone and a 40 horsepower blower for the conveyance of the sawdust to the storage bin located at the Planing Mill.
From past experience, the emissions from this type of process when processing green(non-dried) lumber produces sawdust which collects easily due to the inherent weight of the moist sawdust. The District has made calculations based upon expected emissions:
Flow, cfm x grain loading, gr/cf x 60 min/hr
---------------------------------------------------------- = pounds/hr emissions
7000 grains/lb
Process flow rate = 7,000 cfm
Expected emission rate, grains/cf = 0.003
lbs/hr = 0.20
Yearly expected emissions = at 20 hrs/day, 6 days/week, 50 weeks/yr
tons/year = 0.60
_ The estimated yearly emissions are well below levels which would call for review of this project under District PSD requirements( 25 tpy PM, 15 tpy PM-10)
_ The expected emissions are well below the requirements of Regulation 1, Rule 420(e) which requires a 0.20 grains/cf not be exceeded.
_ Also Rule 420(e) limits the lbs/hr emission to less than specific amounts based upon process weight rate. The sawmill process produces greater than 60,000 lbs/hr of lumber throughput which is the maximum process weight rate allowance and yields allowable emission rate of 40 lbs/hr for the sawmill. This is the only air emission device at the sawmill, so this rate is not being exceeded.
Recommendation: Issue the ATC and review by EPA for Title V permit inclusion.
1
NORTH COAST UNIFIED AIR QUALITY MANAGEMENT DISTRICT
AUTHORITY TO CONSTRUCT
NAC-328
SIMPSON REDWOOD COMPANY
LEGAL OWNER OR OPERATOR: Simpson Redwood Company
PO Box 68
Korbel CA 95550
Responsible Official: Jim Brown
Plant Contact: Fred Jacobson
707/668-5621
BUSINESS ACTIVITY: A wood processing complex consisting of a sawmill, planing mill and lumber drying facility.
EQUIPMENT LOCATED AT: The plant is located at Korbel in the northwestern portion of California within the County of Humboldt and is about 15 miles to the northeast of Eureka, the County seat and 3 miles to the east of Blue Lake.
Whereas an application for an Authority to Construct and temporary Permit to Operate has been made by Simpson Redwood Company (hereinafter called the Permittee) pursuant to Regulation 1 of the Rules and Regulations of the North Coast Unified Air Quality Management District (hereinafter called the District), and said application has been reviewed and found complete by the Air Pollution Control Officer of said District (hereinafter referred to as the Control Officer or NCUAQMD).
This is your Authority to Construct and temporary Permit to Operate (hereinafter called PERMIT) subject to the following terms and conditions:
Page Number
TABLE OF CONTENTS 2
Abbreviations 3
Permit Units Permit No.
A. Sawmill
(1) Trimmers NAC-328 4
General Provisions
A. Fee Payment 5
B. Inspection and Entry 5
C. Facility Operation 5
D. Compliance 5
E. Severability 6
F. Recordkeeping and Reporting 6
G. Transfer of Ownership 6
H. Reopening for Cause 6
I. Property Rights 7
J. Permit Renewal and Expiration 7
K. Permit Modification 7
L. Prohibitions 7
Permit Certification, authorized signature and date 9
Figure I, Cyclone opacity vs. grain loading 10
LIST OF ABBREVIATIONS
Administrator Administrator of the Environmental Protection Agency
Act Clean Air Act
CARB California Air Resources Board
CEMS continuous emissions monitoring system
CFR Code of federal regulations
CO carbon monoxide
CO2 carbon dioxide
dscf dry standard cubic foot
deg. F degrees Fahrenheit
District North Coast Unified Air Quality Management District
EPA U.S. Environmental Protection Agency
gpm gallons per minute
gr/acf grains per actual cubic foot
gr/dscf grains per dry standard cubic foot
lbs/hr pounds per hour
MMBtu million British thermal units
NOx nitrogen oxides
NSPS New Source Performance Standards
O2 oxygen
pH hydrogen ion concentration in a solution
ppmv parts per million by volume
PSD Prevention of Significant Deterioration
tpy tons per year
unit single emissions unit
A. Sawmill
(1) Permit Number - NAC-328(Collector).
Name - Trimmer
I. BASIC EQUIPMENT - Multi-saw Trimmer for cutting green sawmill lumber to lengths. A 40 HP blower is used to pneumatically convey wood particles to a 4 foot 6 inch diameter cyclone collector(Cyclone C). The exhaust air from the collector is discharged directly to the atmosphere while the wood particles gravity feed to the planning mill storage bin.
II. CONTROL EQUIPMENT - None.
III EMISSIONS LIMITATIONS
A. Particulate Matter
1. Particulate loading -
a. The permittee shall not discharge particulate matter into the atmosphere in excess of 0.20 gr/acf of exhaust gas.
b. All permit units which are a part of the Sawmill shall not discharge particulate matter in total quantities exceeding 40 lbs/hr.
[Regulation 1, Rule 420(e) adopted 1/19/89 and SIP Rule 420(d)].
2. Visible emissions - see General Provisions, section L.
3. Fugitive Dust - see General Provisions, section L
IV. COMPLIANCE MONITORING
A. The following methods shall be used for determining compliance with the above emissions limitations:
1. Particulate Matter - The permittee shall perform at least once per permit term a source test by Oregon DEQ Method 8. A contractor shall be hired to perform such a test. An engineering evaluation will be allowed utilizing the District’s emission factors for collectors which provides grain loading vs. opacity(Figure I, page 26) in support of a test exclusion. Such exclusion will be granted should the evaluation indicate emissions are less than one-half the allowable particulate matter limit of Section III.A.1.a and less than Section III.A.1.b[Regulation 1, Rule 240].
2. Visible Emissions - Federal Method 9. The permittee shall perform a “Visible Emission Evaluation”(VEE) at least once per quarter while the trim saws are in operation. A CARB certified contractor or the District shall be hired to perform such an evaluation[Regulation 1, Rule 240(h)].
3. Fugitive Dust - The permittee shall conduct inspections of the basic equipment on a weekly basis(7 day schedule). Data availability from this manual recordkeeping shall be 90% of the actual operating time of the plant.
a. Any notable blow pipe or collector leak of exhaust gas prior to the discharge point to the atmosphere shall be repaired within 3 days upon detection.
b. Wood particles deposited on the roof of any building or elsewhere shall be removed within 3 days upon detection.
[Regulation 1, Rule 240(d)].
V. REPORTING AND RECORDKEEPING - see General Provisions, section F.
A. A log shall be maintained which specifies the initials of the person inspecting the system, date inspected, location of any leak found, and date of repair.
B. No monitoring other than indicated shall be required for this permit unit.
VI. OPERATING CONDITIONS - see General Provisions, section C.
A. The permittee shall not operate the system should the collector(s) become plugged which causes wood particles to be blown to the atmosphere. Once the system is found to be plugged, the permittee shall stop all pertinent process operations and remove the plug prior to further operation. Such system failures shall be reported to the District in accordance with Rule 540, Breakdown Procedures.
GENERAL PROVISIONS
These general provisions apply to all facilities or sources owned or operated by the permittee as detailed in this permit.
A. Fee Payment - The Permittee shall pay an annual permit fee and other fees as required in accordance with Regulation 1, Rule 300 of the District. Failure to pay these fees will result in forfeiture of this Permit to Operate. Operation without a permit subjects the source to potential enforcement action by the District and the US EPA pursuant to section 502(a) of the Clean Air Act as amended in 1990[40 CFR 70.6(a)(7); Regulation 5, Rule 670].
B. Inspection and Entry - Upon presentation of credentials and other documents as may be required by law, the permittee shall allow the District, CARB, EPA or an authorized representative to perform the following:
1. Enter upon the permittee’s premises where a regulated facility or emissions-related activity is located or conducted, or where records must be kept under the conditions of this permit.
2. Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit.
3. Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit.
4. Sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the conditions of this permit.
[40 CFR 70.6(c)(2); Regulation 5, Rule 610(e)]
C. Facilities Operation
1. Operation under this permit must be conducted in compliance with all data and specifications included in the application which attest to the operator's ability to comply with District Rules and Regulations[Regulation 1, Rule 240(d)].
2. All nonexempt equipment of this permit shall at all times be maintained in good working order and be operated as efficiently as possible to assure compliance with all applicable emission limits[Regulation 1, Rule 240(d)].
3. Operational Limit - This permit is valid for a maximum of 365 days per year at 24 hours per day[Regulation 1, Rule 240(d)].
D. Compliance
1. The permittee must comply with all conditions of this permit. Any permit noncompliance constitutes a violation of the Federal Clean Air Act and is grounds for enforcement action(including monetary civil penalties); for permit termination, revocation and reissuance, or modification; or for denial of an application for reissuance of the permit[40 CFR 70.6(a)(6); Regulation 5, Rule 610(g)].
2. The need to halt or reduce activity is not a defense. It shall not be a defense for a permittee in an enforcement action that it would be necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit[40 CFR 70.6(a)(6); Regulation 5, Rule 610(g)].
3. A pending permit action or notification of anticipated noncompliance does not stay any permit condition[Regulation 5, Rule 610(g)(5)].
4. The permittee shall furnish to the District, within a reasonable time, any information that the District may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit or to determine compliance with this permit. Upon request, the permittee shall also furnish to the District copies of records required to be kept by this permit[40 CFR 70.6(a)(6)].
5. The permittee shall provide to the District on an annual basis a completed “Compliance Certification” form which certifies the compliance status of the facility. The compliance certification form must be signed by a responsible company official and contain a statement that the information contained in the report is true, accurate, and complete. A semi-annual compliance certification report shall be submitted to document the compliance schedule of any source out of compliance[40 CFR 70.6(c); Regulation 5, Rules 460 and 610(g)].
6. Emergency events which occur at the permittee’s plant which affect compliance with the terms of this permit must be reported to the District in accordance with Regulation 1, Rule 540. Emergency events are normally outside influences over which the permittee has no control[Regulation 5, Rule 460].
E. Severability - If any term or condition of this permit shall for any reason be adjudged by a court of competent jurisdiction to be invalid, such judgment shall not affect or invalidate the remainder of this permit[40 CFR 70.6(a)(5); Regulation 5, Rule 610(h)].
F. Recordkeeping and Reporting
1. The permittee shall retain records of all required monitoring data and support information including the date, place, time and results of any sampling or analysis, the operating conditions at the time of sampling for a period of at least five (5) years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and copies of all reports required by this permit[40 CFR 70.6(a)(3)(ii)(B); Regulation 5, Rule 455].
2. The permittee shall report to the District any deviations from these permit requirements, including those attributable to breakdown conditions, the probable cause of the deviations, and any corrective actions or preventive measures taken. Procedures of Regulation 1, Rule 540 shall be followed in the reporting of such deviations. A breakdown log shall be maintained for recordkeeping purposes[40 CFR 70.6(a)(3)(iii)(B); Regulation 5, Rule 460; Regulation 1, Rule 540].
3. The permittee shall submit by February 28th of each year, a combined report to comply with the General Provisions sections D.5[Regulation 1, Rule 240(d)].
4. A semi-annual monitoring report shall be submitted to the District which identifies any deviation from these permit requirements including a summary of those deviations attributable to breakdowns, emergency events, emissions exceedances, and reporting or recordkeeping deviations required by this permit. These reports shall be due no later than July 15th and February 28th of each calendar year[Regulation 1 Rule 240(d)].
G. Transfer of Ownership -In the event of any changes in control or ownership of these facilities, this permit together with its terms and conditions shall be binding on all subsequent owners and operators. The permittee shall notify the succeeding owner and operator of the existence of this permit and its conditions by letter, a copy of which shall be forwarded to the District. Such permit transfer shall occur by application through the District[Regulation 1, Rule 240(j)].
H. Reopening for Cause
1. This permit may be modified, revoked, reopened, reissued, or terminated for the following reasons:
a. Additional requirements under the federal Clean Air Act become applicable to the facility for which three or more years remain on the original term of the permit. Such a reopening shall be completed not later than 18 months after promulgation of the applicable requirement. No such reopening is required if the effective date of the requirement is later than the date on which the permit is to expire.
b. The District or EPA determines that the permit contains a material mistake made in establishing the emissions standards or limitations, or other requirements of the permit.
c. The District or EPA determines that the permit must be revised or revoked to assure compliance with the applicable requirements. [40 CFR 70.7(f); Regulation 5, Rule570]
2. The reopening of this permit for a change to be implemented for a specific permit unit will be allowed without the need to reopen the entire permit and all permit units. Should a general condition be changed, all the associated permit units affected would be reopened[Regulation 1, Rule 240(d)].
3. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition[40 CFR 70.6(a)(6)].
I. Property Rights - This permit does not convey any property rights of any sort, or any exclusive privilege[40 CFR 70.6(a)(6)].
J. Permit Renewal and Expiration - This permit is effective on the date of issuance and will expire in five years and must be renewed every five years thereafter. Permit expiration terminates the permittee’s right to operate unless a timely and complete renewal application is submitted. For renewal of a permit, the designated representative shall submit a complete District application no earlier than 18 months and no later than 6 months before the expiration date of the current permit[40 CFR 70.5(a); Regulation 5, Rule 405(b)].
K. Permit Modification - The permittee shall submit an application for a minor or significant permit modification in accordance with District Regulation 5[40 CFR 70.5(a); Regulation 5, Rule 405].
L. Prohibitions - These limitations apply to all emissions sources at the permittee’s facility unless more specific and limiting requirements are listed for a individual permitted emissions unit in this permit.
1. Public Nuisance - The permittee shall not discharge such quantities of air contaminants or other material which cause injury, detriment, nuisance or annoyance to any considerable number of persons or to the public or which endanger the comfort, repose, health or safety of any such persons or the public or which cause or have an natural tendency to cause injury or damage to business or property[H&S 41700].
2. Visible Emissions - The permittee shall not discharge into the atmosphere from any source whatsoever any air contaminant for a period or periods aggregating more than three (3) minutes in any one hour which is as dark or darker in shade as that designated as No. 2 on the Ringlemann Chart, as published by the United States Bureau of Mines; or of such opacity as to obscure an observer’s view to a degree equal to or greater than Ringlemann 2 or forty (40) percent opacity[Regulation 1, Rule 410(a)].
3. Fugitive Dust Emissions - The handling, transporting, or open storage of material in such a manner which allow unnecessary amounts of particulate matter to become airborne, shall not be permitted. Reasonable precautions shall be taken to prevent particulate matter from becoming airborne[Regulation 1, Rule 430].
4. Sulfur Oxide Emissions - The permittee shall not discharge into the atmosphere from any single source of emissions whatsoever sulfur oxides, calculated as sulfur dioxide (SO2) in excess of 1,000 ppm[Regulation 1, Rule 440].
5. Circumvention - The permittee shall not construct, erect, modify, operate, or use any equipment which conceals an air contaminant emission, which would otherwise constitute a violation of the limitations of this permit, unless the operation or use of said equipment results in a significant reduction in the total emission of air contaminants[Regulation 1, Rule 400(b)].
6. Regulation 2, Open Burning Procedures - The permittee shall not ignite or cause to be ignited or suffer, allow or maintain any open outdoor fire for the disposal of rubber, petroleum or plastic wastes, demolition debris, tires, tar paper, wood waste, asphalt shingles, linoleum, cloth, household garbage or other combustible refuse; or for metal salvage or burning of motor vehicle bodies except as provided in Rule 2-102, Exemptions[Regulation 2].
7. Title VI, Stratospheric Ozone Protection - The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR Part 82, Subpart F, and 40 CFR Part 82, Subpart B, Servicing of Motor Vehicle Air Conditioners.
8. National Emission Standard for Asbestos - The permittee shall comply with the standards of 40 CFR Part 61 Subpart M which regulates demolition and renovation activities at the power plant as pertaining to asbestos materials.
This permit does not authorize the emission of air contaminants in excess of those allowed by the Health and Safety Code of the State of California or the Rules and Regulations of the North Coast Unified Air Quality Management District as stated in this permit. Any regulation or rule not cited in this permit which may be applicable to a particular emission unit will not be enforceable. This permit cannot be considered as permission to violate existing laws, ordinances, regulation or statutes of other governmental agencies. The violation of any of these terms and conditions shall be grounds for revocation of this permit, and shall be a violation of District Rules and Regulations.
N O R T H C O A S T U N I F I E D
A I R Q U A L I T Y
M A N A G E M E N T D I S T R I C T
2300 MYRTLE AVENUE PHONE (707) 443-3093
EUREKA, CALIFORNIA 95501 FAX (707) 443-3099
DATE:___________________ BY:___________________________
WAYNE MORGAN,
AIR POLLUTION CONTROL OFFICER
Permit Seal
permits/SIMPATC
