1. Purpose of Application
This revision is for the replacement of the permitted, but not yet constructed, 77.6 mmBtu/hr natural gas/landfill gas-fired boiler with a 64.0 mmBtu/hr natural gas/landfill gas and No. 2 fuel oil-fired boiler. The existing Title V permit (03469T17) was issued on January 6, 2006 and is scheduled to expire on December 31, 2010. Additionally, permit Application No. 6200015.06A was consolidated with this application. That application seeks to correct the heat input to two previously permitted kilns.
2. Facility Description
Jordan Lumber & Supply Company (Jordan) is a large sawmill that produces dimension lumber from southern yellow pine. Boilers are fueled on hardwood bark that is brought in from chip mills.
3. Application Chronology
December 27, 2005 – Application No. 6200015.06A for correcting the kiln heat input was received by DAQ RCO.
January 19, 2006 – Application No. 6200015.06B for the addition of a 20.92 mmBtu/hr temporary boiler was received by DAQ FRO.
January 24, 2006 – Application No. 6200015.06B was received by DAQ RCO.
January 24, 2006 – FRO Air Permit Review for Application No. 6200015.06A was received by DAQ RCO.
January 28, 2006 – FRO Air Permit Review for Application No. 6200015.06B was received by DAQ RCO.
February 15, 2006 – Application No. 6200015.06C for the replacement of a permitted (but not yet constructed) boiler with a 64.0 mmBtu/hr boiler was received by DAQ FRO. Application No. 6200015.06B was withdrawn.
February 20, 2006 – Application No. 6200015.06C was received by DAQ RCO.
February 24, 2006 – FRO Air Permit Review for Application No. 6200015.06C was received by DAQ RCO.
4. Permit Modification/Changes
The following table represents the changes to the current Title V permit:
Page 1 - Revised issue date, permit number, and application dates. Added language re. 502(b)(10) notification to EPA.
Page 2 - Revised dates and corrected engineer phone number.
Page 1 - Revised permit number, application numbers, and dates.
Page 3 - Emission Source Listing: Replaced B05 with B06, added No. 2 fuel oil and changed heat input. Added 502(b)(10) footnote. Removed B05 from the .0501(c)(2) footnote.
Page 5 - Changed heat input of kilns K-1 and K-2 to 30 mmBtu/hr each.
Page 11 - Changed boiler fuel description and heat input rate.
Page 12 - Added PSD avoidance for SO2. Added PM and HCl language for liquid fired boiler MACT. Added language regarding fuel oil as regulated under NSPS.
Page 13 - Added language regarding fuel oil as regulated under NSPS.
Page 13/14 - Added fuel oil requirements for NSPS.
Page 14 – Added fuel oil requirements for MACT.
Page 17 - Added PSD avoidance for SO2.
Page 37 - Replaced B05 with B06, added No. 2 fuel oil and changed heat input. Added 502(b)(10) footnote. Removed B05 from the .0501(c)(2) footnote.
5. Regulatory Review
The replacement boiler is subject to the following regulations:
2D .0503 “Particulates from Fuel Burning Indirect Heat Exchangers”
2D .0516 “Sulfur Dioxide Emissions from Combustion Sources”
2D .0521 “Control Of Visible Emissions”
2D .0524 “New Source Performance Standards”
2D .1111 “Maximum Achievable Control Technology”
2Q .0317 “Avoidance Conditions For 15A NCAC 2D. 0530: Prevention of Significant Deterioration”
A. One natural gas/landfill gas/No. 2 fuel oil-fired boiler (64.0 million Btu per hour maximum heat input)
1. Description
This boiler burns primarily natural gas with No.2 fuel oil serving as a backup fuel. A source of landfill gas is being considered for use in the boiler.
2. Applicable Regulatory Requirements
The following provides a summary of emission and/or operation limits for the emission source(s) described above. A review of the information in the application was performed to ensure the appropriate limits and associated calculations used to show compliance were correct.
particulate matter - 0.35 pounds per million Btu - 15A NCAC 2D .0503
sulfur dioxide 2.3 pounds per million Btu when not firing No. 2 fuel oil - 15A NCAC 2D .0516
visible emissions - 20 percent opacity when not firing No. 2 fuel oil - 15A NCAC 2D .0521
visible emissions - 20 percent opacity when firing No. 2 fuel oil - 15A NCAC 2D .0524Subpart Dc, 40 CFR Part 60.48c
sulfur dioxide - 0.5 percent sulfur fuel oil - 15A NCAC 2D .0524Subpart Dc, 40 CFR Part 60.48c
hazardous air pollutants - 0.03 lbs PM/million Btu heat input of particulate matter; 0.0005 lbs/million Btu heat input of hydrogen chloride; 400 ppm by volume of carbon monoxide on a dry basis, corrected to 3 percent oxygen - 15A NCAC 2D .111140 CFR Part 63 Subpart DDDDD
sulfur dioxide 40 tons per year - 15A NCAC 2Q .0317
6. NSPS, NESHAPS, PSD, Attainment Status, 112(r), CAM
New Source Performance Standards (NSPS) apply to this modification as described above.
The boiler is subject to 40 CFR Part 63 Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants (NESHAP): Industrial, Commercial and Institutional Boilers and Process Heaters. Subpart DDDD was published on July 30, 2004. The boiler is classified as small as the hybrid boiler is considered a fire tube boiler. Detailed requirements for emission standards for particulate matter, hydrogen chloride and carbon monoxide are included in the permit
This facility is recently underwent PSD permitting for VOCs including the 77.6 mmBtu/hr boiler being replaced by boiler B06. With the addition of No. 2 fuel oil, this boiler requires a PSD avoidance condition for sulfur dioxide. The permit contains monitoring, recordkeeping and reporting for fuel consumption and sulfur content.
For purposes of increment tracking, sulfur dioxide emissions from this facility have increased by 32.5 pounds per hour.
This facility is located in Montgomery County which is in attainment for all criteria pollutants.
This facility is not subject to Section 112(r) of the Clean Air Act requirements because it does not store any of the regulated substances in quantities above the thresholds in the Rule.
Compliance Assurance Monitoring (CAM) (40 CFR Part 64) does not apply to this applicaiton.
7. Facility Wide Air Toxics
Air toxics does not apply to this application.
8. Facility Compliance Status
The facility was inspected by Bob Kennedy, FRO on March 10, 2005. The facility “… appeared to be in compliance with all requirements outlined in air permit 03469T14.”
9. Comments, Conclusions, and Recommendations
A professional engineer’s seal was not required for this renewal.
FRO recommends issuance of the permit per Robert Kennedy’s review dated February 22, 2006.
RCO concurs with FRO’s recommendation to issue air permit.