Oriented Strandboard Mills

TNRCC Rule 116.111(3) in Regulation VI requires that Best
Available Control Technology (BACT) be applied to all
facilities that must obtain a permit.  BACT is defined as any
control method which is technically feasible and economically
reasonable.  BACT determinations are made on a case-by-case
basis.  The applicant is encourage to talk with a TNRCC NSR
Permit Engineer to determine the BACT for the facility. 
Control practices that may be considered as BACT for the OSB
Plants include:  

1.  Dryers:  Regenerative Thermal Oxidizer or any other
    thermal incinerator with a destruction efficiency of
    ninety percent for volatile organic compounds (VOC) and
    carbon monoxide (CO) and ninety-five percent destruction
    efficiency for total suspended particulate (TSP) including
    particulate matter of less than 10 microns (PM10).  
2.  Press Vents:  Close Capture and Total Enclosure.  The
    press exhaust can also be ducted to an incinerator if a
    safety hazard is not anticipated.  
3.  Material Handling (Sanderdust/Material Recycle/Raw and
    Refined Fuel Systems/Aspiration System):  Baghouses with
    an outlet grain loading of 0.01 grains per dry standard
    cubic foot (gr/dscf) or manufacturer's guaranteed
    efficiency of 99.8 percent are considered BACT for these
    sources for TSP.  
4.  Resin/Wax Storage and Daily Use Tanks:  If total VOC
    emission are less than five tons per year then no controls
    may be considered appropriate.  If the VOC emission are
    greater than ten tons per year, then they should be vented
    to a control device with ninety-eight percent efficiency. 
5.  Finish Coating-VOC Controls:  The use of low VOC coatings
    may be considered to be appropriate BACT.  
6.  Gasoline and Diesel Storage Tanks-Total VOC Controls:  If
    tank volumes are less than 5000 gallons, no controls may
    be necessary.  For tank volumes greater than 5000 gallons,
    Stage I vapor recovery will be required.  
7.  Road Emissions-TSP Controls:  Roads can be paved and
    cleaned.  
8.  Debarking and other log processing activities that have
    low emissions may not require controls.  
9.  The wet electrostatic precipitator (WESP) with an outlet
    grain loading of 0.02 gr/dscf and high efficiency cyclones
    (1D3D or 2D2D) can also be used to control TSP emission
    from the dryers.  Cyclones are not efficient in
    controlling PM10.

The control requirements listed are guidelines to help the
applicant determine what the TNRCC is currently considering as
BACT; however these control levels are subject to change.