AIR QUALITY PERMIT. Anthony Forest Products Company, LLC

Transcription

1 AIR QUALITY PERMIT Permit No. Effective Date January 22, 2016 In accordance with the provisions of the Georgia Air Quality Act, O.C.G.A. Section , et seq and the Rules, Chapter , adopted pursuant to and in effect under that Act, Facility Name: Anthony Forest Products Company, LLC Mailing Address: P.O. Box 676 Washington, Georgia is issued a Permit for the following: The Manufacture of Laminated Wooden Structural Beams This Permit is issued for the purpose of establishing practically enforceable emission limitations such that the facility will not be considered a major source with respect to Title V of the Clean Air Act Amendments of Facility Location: 256 Edison Road Washington, Georgia (Wilkes County) This Permit is conditioned upon compliance with all provisions of The Georgia Air Quality Act, O.C.G.A. Section , et seq, the Rules, Chapter , adopted and in effect under that Act, or any other condition of this Permit. This Permit may be subject to revocation, suspension, modification or amendment by the Director for cause including evidence of noncompliance with any of the above; or for any misrepresentation made in Application No dated November 25, 2015; any other applications upon which this Permit is based; supporting data entered therein or attached thereto; or any subsequent submittals or supporting data; or for any alterations affecting the emissions from this source. This Permit is further subject to and conditioned upon the terms, conditions, limitations, standards, or schedules contained in or specified on the attached 10 pages. [Signed] Director

2 Permit No. Page 1 of General Requirements 1.1 At all times, including periods of startup, shutdown, and malfunction, the Permittee shall maintain and operate this source, including associated air pollution control equipment, in a manner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to, monitoring results, opacity observations, review of operating and maintenance procedures, and inspection or surveillance of the source. 1.2 The Permittee shall not build, erect, install or use any article, machine, equipment or process the use of which conceals an emission which would otherwise constitute a violation of an applicable emission standard. Such concealment includes, but is not limited to, the use of gaseous diluents to achieve compliance with an opacity standard or with a standard that is based on the concentration of a pollutant in the gases discharged into the atmosphere. 1.3 The Permittee shall submit a Georgia Air Quality Permit application to the Division prior to the commencement of any modification, as defined in (pp), which may result in air pollution and which is not exempt under (6). Such application shall be submitted sufficiently in advance of any critical date involved to allow adequate time for review, discussion, or revision of plans, if necessary. The application shall include, but not be limited to, information describing the precise nature of the change, modifications to any emission control system, production capacity and pollutant emission rates of the plant before and after the change, and the anticipated completion date of the change. 1.4 Unless otherwise specified, all records required to be maintained by this Permit shall be recorded in a permanent form suitable for inspection and submission to the Division and shall be retained for at least five (5) years following the date of entry. 1.5 In cases where conditions of this Permit conflict with each other for any particular source or operation, the most stringent condition shall prevail. 2. Allowable Emissions 2.1 The Permittee shall not cause, let, suffer, permit, or allow any emissions from the entire facility, contain any single hazardous air pollutant (HAP), which is listed in Section 112 of Clean Air Act, in an amount equal to or exceeding 10 tons during any twelve consecutive month period, or any combination of such listed pollutants in an amount equal to or exceeding 25 tons during any twelve consecutive month period. [Title V Avoidance]

3 Permit No. Page 2 of CFR 63 Subpart JJJJJJ 2.2 The Permittee shall comply with all applicable provisions of the New Source Performance Standards (NSPS), 40 CFR 63 Subpart A General Provisions, and Subpart JJJJJJ National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources, for the operation of the wood-fired boiler (ID No. BL3). [40 CFR 63 Subparts A and JJJJJJ] 2.3 The Permittee shall fire only clean cellulosic biomass which may include clean construction and demolition wood in the wood-fired boiler (ID No. BL3) as defined below and in 40 CFR 241. [ (2)(c); (2)(g)2. (subsumed); 40 CFR (b); and 40 CFR 241.2] Clean cellulosic biomass means those residuals that are akin to traditional cellulosic biomass, including, but not limited to: Agricultural and forest derived biomass (e.g., green wood, forest thinnings, clean and unadulterated bark, sawdust, trim, tree harvesting residuals from logging and sawmill materials, hogged fuel, wood pellets, untreated wood pallets); urban wood (e.g., tree trimmings, stumps, and related forest-derived biomass from urban settings); corn stover and other biomass crops used specifically for the production of cellulosic biofuels (e.g., energy cane, other fast growing grasses, byproducts of ethanol natural fermentation processes); bagasse and other crop residues (e.g., peanut shells, vines, orchard trees, hulls, seeds, spent grains, cotton byproducts, corn and peanut production residues, rice milling and grain elevator operation residues); wood collected from forest fire clearance activities, trees and clean wood found in disaster debris, clean biomass from land clearing operations, and clean construction and demolition wood. These fuels are not secondary materials or solid wastes unless discarded. Clean biomass is biomass that does not contain contaminants at concentrations not normally associated with virgin biomass materials. Any wood that has been treated with compounds such as chromate copper arsenate or comingled with such compounds or lead is not considered clean cellulosic biomass.

4 Permit No. Page 3 of 10 Georgia State Rules 2.4 The Permittee shall not cause, let, suffer, permit, or allow any emissions from any of the following emission units, the opacity of which is equal to or greater than forty (40) percent. [ (2)(b)1.] ID No. GRD FJC FJL FIN DKN BPL BPL Emission Units Description Grinding Finger Joint Cutting Finger Joint Curing Finishing Dry Kiln Continuous Press Batch Press 2.5 The Permittee shall not cause, let, suffer, permit, or allow any emissions from the wood-fired boiler (ID No. BL3) which: a. Contain fly ash and/or other particulate matter in amounts equal to or exceeding 0.5 pound per million BTU (lb/mmbtu) heat input. [ (2)(d)2.(i)] b. Exhibit visible emissions, the opacity of which is equal to or greater than 20 percent except for one six minute period per hour of not more than 27 percent opacity. [ (2)(d)3.] 2.6 The Permittee shall operate the baghouse (ID No. BH1) at all times when any of the following emission units are in operation. The Permittee shall not shall not cause, let, suffer, permit or allow emissions from the following emission units, which exhaust through Baghouse BH1 contain particulate matter (PM) in excess of 18.8 pounds per hour (lbs/hr). [ (2)(e)1.(i)] ID No. GRD FJC FJL FIN Emission Units Description Grinding Finger Joint Cutting Finger Joint Curing Finishing

5 Permit No. Page 4 of The Permittee shall not cause, let, suffer, permit, or allow the emission from the drying kiln (ID No. DKN), contain particulate matter (PM) in total quantities equal to or exceeding the allowable rate as calculated using the applicable equation below. [ (2)(e)1.(i)] a. E = 4.1 * P 0.67 ; for process input weight rate up to and including 30 tons per hour. b. E = 55 * P ; for process input weight rate above 30 tons per hour. 3. Fugitive Emissions Where: E = allowable emission rate in pounds per hour; P = process input weight rate in tons per hour. 3.1 The Permittee shall comply with the Georgia Air Quality Control Rule (2)(n), Fugitive Dust, for the entire processing facility including all roadways and processing equipment not otherwise subject to any other rule or regulation governing fugitive visible emissions. Subject to this rule, the Permittee shall not cause, let, permit, suffer, or allow visible emissions from any fugitive source to equal or exceed 20% opacity. [ (2)(n)2.] 3.2 The Permittee shall take all reasonable precautions with any operation, process, handling, transportation, or storage facilities to prevent fugitive emissions of air contaminants. 4. Process & Control Equipment 4.1 Routine maintenance shall be performed on all air pollution control equipment. Maintenance records shall be in a form suitable for inspection or submittal to the Division. 4.2 The Permittee shall maintain an inventory of filter bags such that adequate supplies of bags are on hand to replace any defective bags in Baghouse BH1. 40 CFR 63 Subpart JJJJJJ 4.3 The Permittee shall operate and maintain the boiler (ID No. BL3), including the associate air pollution control equipment and associate monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. [40 CFR (a)] 5. Monitoring 5.1 The Permittee shall install, calibrate, maintain, and operate monitoring devices for the measurement of the pressure drop across Baghouse BH1. Data shall be recorded in accordance with the requirements of Condition 5.3. Where such performance specification(s) exist, each device shall meet the applicable performance specification(s) of the Division's monitoring requirements.

6 Permit No. Page 5 of The Permittee shall perform a check of the visible emissions from Baghouse BH1. Checks shall be daily, for each day of operation. The Permittee shall retain a record in a visible emissions (VE) log suitable for inspection or submittal. The checks shall be conducted using the procedure below except when atmospheric conditions or sun positioning prevent any opportunity to perform the daily VE check. Any operational day when atmospheric conditions or sun position prevent a daily reading shall be reported as monitor downtime in the VE log. a. The person performing the determination shall stand at a distance of at least 15 feet which is sufficient to provide a clear view of the plume against a contrasting background with the sun in the 140 sector at his/her back. Consistent with this requirement, the determination shall be made from a position such that the line of vision is approximately perpendicular to the plume direction. Only one exhaust point shall be in the line of sight at any time when multiple emission points are in proximity to each other. b. If Baghouse BH1 exhibits visible emissions, the Permittee shall determine the cause of the excursion and correct the problem in the most expedient manner possible. The Permittee shall note the cause of the excursion, the pressure drop, any other pertinent operating parameters, and the corrective action taken in the maintenance log. 5.3 The Permittee shall implement the Division-approved Preventive Maintenance Program for Baghouse BH1 to assure that the provisions of Condition 1.1 are met. The program shall be subject to review and modification by the Division and shall include the pressure drop range that indicates proper operation for Baghouse BH1. At a minimum, the following operation and maintenance checks shall be made on at least a weekly basis, and a record of the findings and corrective actions taken shall be recorded and kept in a maintenance log: a. Record the pressure drop across the baghouse and ensure that it is within the appropriate range. b. If the baghouse is equipped with reverse air cleaning system, check the system for proper operation. This may include checking damper, bypass, and isolation valves for proper operation. c. Check dust collector hopper and conveying system for proper operation. 5.4 The Permittee shall perform the following operation and maintenance checks and retain a record suitable for inspection or submittal for each week or portion of each week of operation of the emission units controlled by Cyclone HEC. A checklist or other similar log may be used for this purpose: a. Check exterior for holes in the body or evidence of malfunction in interior of the cyclone.

7 Permit No. Page 6 of 10 b. Check hopper for bridging and plugging. c. Check particulate transfer device for proper operation to ensure dust removal. Any adverse condition discovered by this inspection shall be corrected in the most expedient manner possible. The Permittee shall record the incident as an excursion and note the corrective action taken. 40 CFR 63 Subpart JJJJJJ 5.5 The Permittee shall conduct a performance tune-up of the wood-fired boiler (ID No. BL3) biennially as specified in 40 CFR (a) and (b). Each biennial tune-up must be conducted no more than 25 months after the previous tune-up. The biennial tune-up shall include the following: [ (6)(b)1.; 40 CFR (b); 40 CFR (b); 40 CFR (a) and (b); Item 6 of Table 2 to 40 CFR 63 Subpart JJJJJJ] a. As applicable, inspect the burner, and clean or replace any components of the burner as necessary (the Permittee may delay the burner inspection until the next scheduled unit shutdown, but the Permittee must inspect each burner at least once every 36 months). b. Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer s specifications, if available. c. Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly. d. Optimize total emissions of carbon monoxide (CO). This optimization should be consistent with the manufacturer s specifications, if available. e. Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. f. Maintain onsite and submit, if requested by the Division, a report containing the following information: i. The concentrations of CO in the effluent stream in parts per million, by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler. ii. A description of any corrective actions taken as a part of the tune-up of the boiler.

8 Permit No. Page 7 of 10 iii. The type and amount of fuel used over the 12 months prior to the biennial tune-up of the boiler. g. If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 days of startup. 6. Performance Testing 6.1 The Permittee shall cause to be conducted a performance test at any specified emission point when so directed by the Division. The following provisions shall apply with regard to such tests: a. All tests shall be conducted and data reduced in accordance with applicable procedures and methods specified in the Division s Procedures for Testing and Monitoring Sources of Air Pollutants. b. All test results shall be submitted to the Division within sixty (60) days of the completion of testing. c. The Permittee shall provide the Division thirty (30) days prior written notice of the date of any performance test(s) to afford the Division the opportunity to witness and/or audit the test, and shall provide with the notification a test plan in accordance with Division guidelines. d. All monitoring systems and/or monitoring devices required by the Division shall be installed, calibrated and operational prior to conducting any performance test(s). For any performance test, the Permittee shall, using the monitoring systems and/or monitoring devices, acquire data during each performance test run. All monitoring system and/or monitoring device data acquired during the performance testing shall be submitted with the performance test results. 7. Notification, Reporting and Record Keeping Requirements 7.1 The Permittee shall maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, any malfunction of the air pollution control equipment or any periods during which a continuous monitoring system or monitoring device is inoperative. 7.2 The Permittee shall maintain a file of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by this Permit. The information shall be recorded in a permanent form suitable and available for inspection.

9 Permit No. Page 8 of The Permittee shall maintain monthly usage records of all materials used at the facility that contain one or more listed hazardous air pollutants (HAP). These records shall include the total weight of each material used and the amount of each listed HAP contained in each material (expressed as a weight percentage). The Permittee may subtract from the monthly usage the individual HAP content of any material disposed as waste provided that the total weight, the individual HAP content (expressed as a weight percentage), and documentation of the method for determining the individual HAP content of any such waste material be included as part of the record. All other calculations used to determine usages should also be kept as part of the monthly record. 7.4 The Permittee shall use the monthly usage records required in Condition 7.3 and the manufacturer supplied emission factors to calculate total monthly emissions of each listed hazardous air pollutant emitted from the entire facility. The Permittee shall notify the Division in writing if the emissions of any individual hazardous air pollutant exceed 0.83 tons (or one-twelfth of any lesser quantity for a single hazardous air pollutant that the U.S. EPA may establish by rule), or if emissions of all listed hazardous air pollutants, combined, exceed 2.08 tons, during any calendar month. This notification shall be postmarked by the fifteenth day of the following month and shall include an explanation of how the Permittee intends to maintain compliance with the emission limit in Condition The Permittee shall use the calculations required by Condition 7.4 to determine the total hazardous air pollutant emissions from the entire facility for each twelve consecutive month period. The Permittee shall notify the Division in writing if, during any twelve consecutive month period, the emissions of any individual hazardous air pollutant equal or exceed 10 tons, or if the emissions of all listed hazardous air pollutants, combined, equal or exceed 25 tons. This notification shall be postmarked by the fifteenth day of the following month and shall include an explanation of how the Permittee intends to attain future compliance with the emission limit in Condition CFR 63 Subpart JJJJJJ 7.6 The Permittee shall prepare, by March 1 of every other year, and submit to the Division, a biennial compliance certification report for the previous calendar year containing the information specified below for the wood-fired boiler (ID No. BL3). [ (6)(b)1. and 40 CFR (b)] a. Company name and address. b. Statement by a responsible official, with the official s name, title, phone number, address, and signature, certifying the truth, accuracy and completeness of the notification and a statement of whether the source has complied with all the relevant standards and other requirements of 40 CFR 63 Subpart JJJJJJ. The notification must include the following certification(s) of compliance, as applicable, and signed by a responsible official:

10 Permit No. Page 9 of 10 i. The Permittee complies with the requirements in 40 CFR to conduct a biennial tune-up. ii. For units that do not qualify for a statutory exemption as provided in section 129(g)(1) of the Clean Air Act: No secondary materials that are solid waste were combusted in any affected unit. c. If the Permittee experiences any deviations from the applicable requirements during the reporting period, include a description of deviations, the time periods during which the deviations occurred, and the corrective actions taken. 7.7 The Permittee shall maintain the following records for the wood-fired boiler (ID No. BL3). The records shall be available for inspection or submittal to the Division upon request and contain: [ (6)(b)1. and 40 CFR (c)] a. As required in 40 CFR 63.10(b)(2)(xiv), the Permittee shall keep a copy of each notification and report that is submitted to comply with 40 CFR 63 Subpart JJJJJJ and all documentation supporting any Initial Notification or Notification of Compliance Status that is submitted. b. The Permittee must keep records to document conformance with the management practices required by Condition 5.5 as specified below: i. Records must identify the boiler, the date of tune-up, the procedures followed for tune-up, and the manufacturer s specifications to which the boiler was tuned. ii. Records documenting the fuel type(s) used monthly by the boiler, including, but not limited to, a description of the fuel, including whether the fuel has received a non-waste determination by the Permittee or EPA, and the total fuel usage amount with units of measure. c. Records of the occurrence and duration of each malfunction of the boiler, or of the associated air pollution control and monitoring equipment. d. Records of actions taken during periods of malfunction to minimize emissions in accordance with the general duty to minimize emissions in Condition 4.3, including corrective actions to restore the malfunctioning boiler, air pollution control, or monitoring equipment to its normal or usual manner of operation.

11 Permit No. Page 10 of Special Conditions 8.1 At any time that the Division determines that additional control of emissions from the facility may reasonably be needed to provide for the continued protection of public health, safety and welfare, the Division reserves the right to amend the provisions of this Permit pursuant to the Division's authority as established in the Georgia Air Quality Act and the rules adopted pursuant to that Act. 8.2 The Permittee shall calculate and pay an annual Permit fee to the Division. The amount of the fee shall be determined each year in accordance with the Procedures for Calculating Air Permit Fees. 8.3 All previous Georgia Air Quality Permits that were issued to Anthony Forest Products Company, including the following permit and amendments, are hereby revoked in their entirety. Table 2: Previous Permits That Are Revoked by This Permit Permit No. Date of Issuance/ Effectiveness S-01-0 December 3, S-01-1 February 26, S-01-2 April 7, 2005