NARRATIVE. Manny Patel. DATE: April 1, 2015

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1 Georgia Department of Natural Resources Environmental Protection Division Air Protection Branch 4244 International Parkway Suite 120 Atlanta Georgia / Fax: 404/ Judson H. Turner, Director NARRATIVE TO: FROM: Manny Patel S. Ganapathy DATE: April 1, 2015 Facility Name: Callaway Farms, LLC AIRS No.: Location: Washington, GA (Wilkes County) Application #: Date of Application: September 17, 2014 Background Information Callaway Farms Manufacturing LLC operates a plant that processes southern yellow pine lumber to produce pine shavings that are sold for use as animal bedding. The plant is located at 371 Harris Road in Washington (Wilkes County). According to the application, this facility utilizes 21,100 tons per year whole pine logs as the raw material for producing 10,000 tons per year of pine shavings (10% moisture) that is baled and sold for use as animal bedding. Note that the plant s actual capacity is much higher. The plant is located in an attainment area, which has Title V major source thresholds of 100 tons per year for VOCs, NO x, CO, SO 2 and PM; 10 tpy for any single Hazardous Air Pollutant (HAP); and 25 tpy for total HAPs. The PSD major source threshold for criteria pollutants is 250 tons per year for this facility. Potential emissions of CO, PM and VOC are higher than 100 tpy if the facility were to operate at peak capacity for 8760 hours per year, therefore the facility is potentially a major source with regard to Title V regulations for CO, PM and VOC. However, it was made a synthetic minor source with respect to Title V by limiting processing of whole pine logs to 21,500 oven dry tons (ODT) per year in the current permit amendment. This translates to a wet wood weight of 43,000 tons per year for pine logs with 50% moisture content. Compliance order No. EPD-AQC-6647 dated September 5, 2013 required Callaway Farms to submit a permit amendment application for installing and operating an oxygen monitoring system for better control of combustion air in order to minimize stack opacity and CO emissions. This was based on EPD s determination that monitoring oxygen concentration in the burner/dryer system and work practice standards are necessary to provide reasonable assurance of ongoing compliance with the synthetic minor permit limits for CO and VOC. Callaway submitted Air Quality Permit Amendment application No on October 7, 2013 per the above consent order. EPD issued Air Quality Permit Amendment S-01-1 on December 31, 2013.

2 Callaway Farms source tested the dryer emissions for PM, CO and opacity in December 2012 and for opacity in July 2013 and demonstrated compliance with opacity, PM and CO limits in the permit. In the December 2012 tests the average opacities were above the Georgia Rule (b) limit of 40%. The opacity was very close to the 40% permit limit during the July 2013 opacity test. The tested PM rate was also around 80% of the allowable rate. In view of this source test result EPD sent a letter to Callaway Farms on November 13, 2014 requesting additional source tests. 1. Callaway Farms submitted a permit amendment application (Application No ) on September 17, 2014 stating that they have an advanced closed loop feedback (using the Allen- Bradley Program Logic Control (PLC)) system for monitoring the burner/dryer temperature to minimize CO, VOC, HAPs and PM emissions and stated that the oxygen monitoring system required by Permit Amendment No S-01-1 was not needed. They also requested that several work practice requirement conditions are not needed and should be removed from the permit. In the permit application they stated that the requirement to install and operate an oxygen monitoring system will impose an undue financial burden on their small business. After review of the application and numerous discussions amongst the Company, EPD s Small Business Environmental Assistance Program (SBEAP), and other key Air Protection Branch Programs (SSCP, SSPP, and ISMP); the Division requested (in the November 14, 2014 letter) that the Callaway Farms conduct performance tests listed below per the Authority of Georgia Air Quality Rules and Condition 6.1 of the Company's current Air Quality Permit No S The tests were requested to be conducted within 60 days were: Carbon Monoxide (CO) [pounds per ton of green wood processed for drying]; Volatile Organic Chemicals (VOC) [pounds per ton of green wood processed for drying]; Particulate Matter (PM) [pounds per hour]; Opacity (VE); Nitrogen Oxides (NOx) [pounds per ton of green wood processed for drying]. In its letter EPD stated that these tests need to be conducted in order to prepare a suitable permit amendment as required by the Georgia Rules and the Federal Regulations. The key need is a relationship between the temperature control scheme proposal in the permit application and the emissions of the above-named regulated pollutants. EPD met with Callaway Farms and their consultant at the plant on November 19, 2014 to discuss the permit amendment issues and the additional source tests requested by EPD s November 14, 2014 letter. This permit amendment is a direct result of issues discussed and agreed upon by Callaway, their consultant and EPD personnel at the meeting. Callaway Farms informed EPD that the requested testing would impose a massive financial burden on the facility that it can ill afford under the present business climate. Page 2

3 EPD then proposed to Callaway that it will be allowed to operate at the throughput rates that existed during the December 2012 and July 2013 source tests without having to perform the source tests requested in EPD s November 14, 2014 letter or any other additional source tests at this time. This permit amendment is a result of issues agreed upon by all parties during the meeting. No public advisory was issued for this permit application since there will be no increase in emissions and no new source is being added to the facility. Updated Equipment List There is no change to existing currently permitted equipment at the facility. Emissions Summary The proposed permit amendment will result in reduction of emissions of all pollutants since the synthetic minor throughput limit is being reduced from 24,400 tons of dry wood process rate per year to 21,500 tons of dry wood process rate from the shavings dryer. CO source test conducted on December 18 and 19, 2012 registered a CO emission rate (highest of the three test runs) at 13.5 lb/hour which was an order of magnitude higher than the CO emission rate of the other two test runs. At this highest CO emission rate potential CO emissions are estimated at 59 tons/year or 3.5 lb/odt which is lower than 4.4 lb/odt (average of the AP-42 emission factors for OSB and Particleboard manufacturing). Potential CO emissions at the SM operating limit of 21,500 tons/year is 37.7 tons/year. The facility is actually a minor source for CO based on the December 2012 source test results. The VOC emission factor of 6.4 lb/odt is also on the conservative side. The facility operates three days each week. The production rate during the source test was 3.9 oven dry tons (ODT)/hour. Using the VOC emission factor of 6.4 lb/odt, and the production rates during the source tests, potential VOC emissions are estimated at tons/year for 8760 hours of operation. Potential VOC emission for the SM production limit of 21,500 tons/year is 68.8 tons/year. Thus, at the new synthetic minor permit limit of 21,500 tons of dry wood produced from the shaving dryer, emissions of all criteria pollutants are expected to be lower than the Title V major source threshold of 100 tons per year. Thus the facility is a minor source for VOC as well. Typically NOx emission usually is not of great concern with shavings operation. The highest PM emission rate during the December 2012 PM source test was 9.23 lb/hour at 3.87 ODT/hour of shavings production. This translates to 2.4 lb PM/ODT which is slightly lower than the average PM rate of the AP-42 factors for OSB and Particleboard production of 3.2 lb/odt. Potential PM emission using the highest source tested rate of 9.23 lb/hr gives 40.4 tons of potential PM emissions per year for 8760 hours of operation. Potential PM emission for the SM production limit of 21,500 tons/year is 25.6 tons/year. Therefore potential emissions of PM, CO and VOC will be less than the Title V major source threshold of 100 tons/year at the revised production limit for the shavings dryer in this permit amendment. Page 3

4 Regulatory Applicability There is no change to the currently applicable regulations to production processes at the facility. Permit Condition Change Request and EPD s Response: 1. Permit Condition 2.2: Opacity During normal operation the triple-pass dryer uses a cyclone for controlling PM emissions. The burner temperature is controlled to minimize CO and VOC emissions. The combination of these controls acts as a surrogate for opacity and minimizes any opacity and eliminates the need for an opacity permit limit. Therefore, Callaway Farms requests that this portion of this permit condition be deleted. Response: Condition 2.2 is the opacity limit for the burner/dryer stack emission per Georgia Rule (b) which is an applicable requirement for the burner/dryer system. This condition is in all air permits issued by EPD to all shavings plants and pellet mills operating in Georgia. If this condition is deleted there will be no way for EPD to enforce this applicable requirement. This condition cannot be deleted. 2. Permit Condition 5.4: Visible Emission Checks The permit requires that visible emissions be checked two times each operating day. In order to comply with this requirement at all times Callaway Farms has to certify five personnel for Method 9 by sending them to smoke school every six months. As previously described Callaway Farms feels that an opacity limit is no longer required and this permit condition places an excessive burden on the small business. Therefore, Callaway Farms requests that this permit condition be deleted. Response: Callaway Farms may feel that an opacity limit is no longer required. However the 40% opacity limit applies to the burner/dryer stack emissions per Georgia Rule (b) which is an applicable requirement. The twice daily visible emission observation is made during the day shift. This condition is all the more important in view of the opacity problem observed at the dryer stack during the December 2012 source tests and inspections. Also a Method 9 reading will be needed when the visible emissions from the dryer stack approaches the opacity action level of 30% listed in this condition. Therefore when the visible emission from the stack is extremely low a Method 9 observation may be substituted with a visual observation of the stack emission (Method 22 check). For Method 22 to determine if visible emissions are present from the dryer stack a Method 9 certified observer is not needed. This condition is there in all air permits issued by EPD to all shavings plants and pellet mills operating in Georgia. Callaway needs only one certified observer during the day shifts for this determination. Page 4

5 EPD feels that this condition is necessary for the Callaway Permit since stack emissions failed the 40% opacity during the performance test in December 2012 where average opacity of 56% were noted by Method 9 observations. When the opacity was tested subsequently in July 2013 the visible emissions observed were around 39.4% which is very close to the 40% opacity limit. EPD has found out that for the shaving plant and the pellet mills opacity tends to be an issue. Hence this condition cannot be deleted. 3. Permit Condition 5.5: Eliminate the Oxygen Monitoring System This condition requires Callaway Farms to install, calibrate, maintain, and operate an oxygen monitoring system for measuring oxygen levels in the exhaust of the wood residue fired burner. The system would continuously record the raw oxygen concentration data and calculate three hour averages of the oxygen concentration. Project Integration (PI) conducted a thorough analysis of the oxygen monitoring system as a means to reduce emissions of carbon monoxide (CO) and volatile organic compounds (VOCs). The conclusion reached was that Callaway Farms is currently monitoring and controlling the oxygen in the flue gas by controlling burner temperature since the oxygen concentration is a dependent variable of the combustion temperature. The detailed evaluation is included in Appendix A. Therefore, Callaway Farms requests that this permit condition be deleted. Response: Callaway Farms explained to EPD during the November 19, 2014 meeting that it has good handle on the burner temperature control since it uses a closed loop feedback system with a program logic control (PLC)) for controlling the temperatures in combustion zone of the wood-fired burner, the burner exit temperature and the shavings dryer inlet and outlet temperatures. The PLC controls the burner exit temperature and the output of two of the four ID fans supplying combustion air to the burner via the VFD (variable frequency drive). Therefore EPD has removed this condition requiring installation and operation of the Oxygen Monitoring System and all conditions associated with the oxygen monitoring system from Callaway s Air Quality Permit. 4. Permit Condition 5.6: Work Practice and Preventative Maintenance Program The permit cites GA Air Rule Chapter (6)(b)1 which requires the source to: Install and use emission monitoring devices; Sample specific emissions; Make periodic reports on the nature and amounts of emissions; Provide such other information as the Director may reasonably require to determine whether emissions are in compliance with the Act or any promulgated rules or regulations. While many permits and regulations require some form of a Preventative Maintenance Plan it is unusual for a source of this relatively small size. Page 5

6 Callaway Farms agrees that a preventative maintenance program is important to ensure product quality and to minimize emissions. However, Callaway Farms believes that the work practice standards included in Condition 5.6 are burdensome for a small business and are either not directly related to minimizing emissions or should not be considered work practice standards. Condition 5.6a.i. : The final moisture content of the pine shavings is not related to emissions and Callaway Farms requests that this permit condition be deleted. Response: This condition has been removed in this permit amendment. This parameter is an important process parameter for conversion of dry wood weight to wet wood weight and in calculation of emission factors for CO, VOC and PM in terms of pounds per oven dry tons. Condition 5.6a.ii. : The exit temperature of the rotary dryer is not related to emissions and Callaway Farms requests that this permit condition be deleted. Response: The exit temperature is one of the dryer operational parameters that may be linked to the opacity of visible emissions from the dryer stack. Since this parameter is being monitored and controlled using a closed loop feedback system (the Allen-Bradley PLC system), this condition has been deleted from the permit. Condition 5.6a.iii. : The inlet temperature of the dryer is not related to emissions and Callaway Farms requests that this permit condition be deleted. Response: The inlet temperature is one of the dryer operational parameters tied to VOC emissions released from the wood shavings during the drying process. Higher dryer inlet temperatures have been known to result in the wood shavings fire and over drying. Higher inlet temperature may result in a more drier product since more moisture is driven out of the wood shavings and may result in slightly higher VOC and HAPs emissions from the dryer. However, this parameter is being monitored and controlled using the closed loop feedback system (the Allen-Bradley PLC system), this condition has been deleted from the permit. Condition 5.6a.iv. : The burner temperature is related to CO and VOC emissions. The burner temperature has been established as a range in accordance with Conditions 5.2 and 5.3 and Callaway Farms requests that this permit condition be deleted. Response: Condition 5.6a.iv has been deleted in this amendment since Condition 4.2 in this amendment requires the burner to be operated at or above 1600 o F. Page 6

7 Condition 5.6a.v. : As previously described and detailed in Appendix A, the oxygen concentration is not related to emissions and Callaway Farms requests that this permit condition be deleted. Response: This condition has been removed from the permit in this amendment as Callaway has stated that they can achieve good control of CO and VOC emission via good combustion/temperature control of the burner and the dryer which is achieved using a closed loop feedback system (Allen Bradley System). Condition 5.6a.vi: Checking the operation of the temperature sensing devices is part of the Callaway Farms preventative maintenance program. Response: This condition has not been removed/deleted in this amendment since it is part of Callaway s operation and maintenance plan for the shavings plant. Compliance of CO and VOC emissions now hinges on good temperature control since the Oxygen monitoring system is no longer required for the Callaway Shavings Plant. Condition 5.6a.vii: Callaway Farms requests that this permit condition be deleted along with the requirement for the oxygen monitoring system. Response: This condition has been removed from the permit in this amendment since oxygen monitors are no longer required for optimum control of CO and VOC emissions. Condition 5.6a.viii: Optimizing the burner operation is part of the Callaway Farms preventative maintenance program. Response: This condition has been removed/deleted in this amendment since this function is achieved using the closed loop feedback (Allen Bradley System) control system and the burner preventive maintenance program involving regular burner inspections, maintenance and the dryer stack opacity monitoring on a daily basis. Condition 5.6a.ix. : Inspecting and calibrating the air to fuel ratio to ensure that it is operating properly is part of the Callaway Farms preventative maintenance program. Response: This condition has been removed/deleted in this amendment since it is part of Callaway s operation and maintenance plan for the shavings plant and is being achieved by the closed loop feedback system (Allen Bradley System) via two fans with variable frequency drives (VFD) that control the air supply to the wood fired burners for optimizing the air to fuel ratio and to control the burner exit temperature. Page 7

8 Condition 5.6a.x. : Optimizing CO emissions by measuring CO emissions before and after a tune-up will be incorporated into the Callaway Farms preventative maintenance program. Response: This condition has been removed/deleted in this amendment since it is part of Callaway s operation and maintenance plan for the shavings plant and it appears that monitoring of CO concentration in dryer exhaust using portable CO analyzers may not be practical. In addition, the permit does not require annual tune-up of the dryer burner and all conditions associated with a burner tune-up has also been removed from the permit. The periodic burner tune up may be part of Callaway Farm s preventive maintenance plan. In summary, Callaway Farms requests that permit conditions 5.6a. i, ii, iii, iv, v, and vii be deleted. 5. Permit Condition 5.7: Monitoring Operating Parameters The only operating parameters that relate to permitted emissions are the process input rate (PM, CO, and VOC), the burner temperature (CO and VOC), and the visible emissions (VE). Callaway Farms requests that the other parameters (oxygen monitors, pressure monitors, fuel feed monitors, damper position indicators, and motor speed indicators be deleted. Response: EPD has removed this condition from the permit since the process parameters are controlled using the closed loop feedback system (Allen Bradley System Program Logic Control system). Operational parameters such as greenwood process rate, burner temperature and dryer stack visible emissions are monitored and controlled. 6. Permit Condition 6.5: Initial Performance Test Callaway Farms conducted an initial performance test for PM, CO, and opacity on December 18-19, 2012 in accordance with Permit Condition 6.2. The test demonstrated compliance with Permit Conditions 2.1, 2.2, 2.3, and 2.4. An additional initial performance test for CO and VOC was added to the permit amendment after installation of the oxygen monitoring system. Since Callaway Farms has proposed to eliminate the oxygen monitoring system this permit condition should be deleted. Response: This permit condition has been removed from the Callaway s permit in this permit amendment. EPD s letter to Callaway Farms after its meeting on November 19, 2014 states that no additional source tests are required at this time provided Callaway Farms operates closer to operating conditions during the December 2012 and July 2013 source test that established compliance with the CO, PM and Opacity limits in the permit. Page 8

9 Permit Condition 6.6, 7.8: VOC Testing and Emission Factors Callaway Farms conducted an initial performance test for PM, CO, and opacity in accordance with Permit Condition 6.2 on December 18-19, The test demonstrated that Callaway Farms was in compliance with the emission limits in Permit Conditions 2.1 (PM), 2.2 (opacity), 2.3 (green wood throughput), 2.4 (CO), and 2.5 (fuel sulfur) in the amended permit. In addition, as required by Permit Condition 6.2, Callaway Farms established an operating burner temperature range of 1,440 F to 1,788 F. This data from the compliance test was then used to calculate a CO emission factor of 1.27 lb CO/ODT (includes the 1.15 uncertainty factor) as required by Permit Condition 7.3. Callaway Farms uses this emission factor to calculate CO emissions for the previous 12 months and maintain those records. Permit Condition 2.3 in the amended permit added a limit for VOC emissions at less than 99 tons per year the same as for CO emissions. Permit Condition 6.6 requires a test for VOC emissions and Permit Condition 7.8 requires the calculation of a VOC emission factor from the test data. Callaway Farms is requesting that the additional testing for VOC and the establishment of a VOC emission factor be deleted. Callaway Farms has demonstrated compliance with the CO limit and CO is much more difficult to destroy than VOC, therefore, maintaining the annual CO emissions at < 99 tpy also ensures that the VOC emissions are < 99 tpy. The two primary factors which make the destruction of CO more difficult than VOCs are the auto ignition temperatures and the equilibrium of CO with carbon dioxide (CO 2 ) and oxygen (O 2 ) in the in the products of combustion. The autoignition temperature is the lowest temperature at which a gas or vapor will spontaneously ignite in air without the presence of a flame or spark. The autoignition temperature is required to supply the activation energy needed for combustion. The autoignition temperature for some typical VOCs is: Benzene : 1,040 F Toluene: 986 F Acetaldeh yde: 347 F Formaldeh yde: 806 F Acetone: 869 F. The autoignition temperature for CO is much higher at 1,128 F. This makes CO destruction that much more difficult. Page 9

10 The products of combustion (POC) from a typical fuel (including wood residue) include CO2 and O2. CO is a product of incomplete combustion (PIC) and it is chemically in equilibrium with the CO2 and O2. Because of this equilibrium there will always be trace quantities of CO in the flue gas. Alternately, VOC destruction can be percent. CO is used as an indicator of combustion efficiency. CO is also used by the United States Environmental Protection Agency (EPA) as an indicator, or surrogate, for VOC destruction for compliance assurance monitoring (CAM) for thermal oxidizers. Since CO is more difficult to destroy than VOC and since it is used as a surrogate for VOC efficiency Callaway Farms proposes that CO be used as a surrogate for VOC and that any requirement for VOC testing or for the calculation of a VOC emission factor be deleted from the permit. Response: Callaway can estimate VOC emissions using the AP-42 emission factor of 6.4 lb/odt which is the average VOC AP-42 emission factor for OSB and Particleboard plants. Condition 6.5 has been removed from Callaway s permit since Oxygen monitoring is not required and Callaway Farms has demonstrated compliance with the CO emission limit in the permit through initial performance testing in December Therefore, Callaway is limited to operating at the source tested rate under source test conditions without the need to perform any additional source tests. New source tests may be required if Callaway increases production rate in the future. Using the AP-42 VOC emission factors and production rate during the 2012 source test potential VOC emissions have been estimated at less than 70 tons/year. Therefore, Condition 6.6 requiring periodic performance test for CO and VOC emissions once every four years has been removed/deleted in this permit amendment. VOC emissions can be calculated using EPD approved emission factors based on AP-42 emission factors. 8. Permit Condition 6.7: Oxygen Monitoring The only operating parameters that should be monitored and submitted to the Division from the initial performance test should be the process (green wood) input rate, the burner temperature, and the visible emissions. This was done. Callaway Farms requests that the requirement for oxygen concentration be deleted. Response: Condition 6.7 has been deleted in the amended permit since Callaway has stated that they can control the process and emissions of CO, VOC, PM and opacity using the closed loop feedback (Allen Bradley PLC control) system. 9. Permit Condition 7.5 c. : Oxygen Concentration Callaway Farms requests that this condition be deleted since oxygen monitoring should no longer be required. Response: Condition 7.5.c. has been removed in the amended condition since oxygen monitoring is not needed. 10. Permit Condition 7.6 c.: Fuel Usage The permit does not specify how the annual fuel usage would be used to calculate emissions. Callaway Farms requests that this permit condition be deleted. Page 10

11 Response: Annual fuel usage is used to estimate the burner emissions (mainly CO and NOx emissions from the burner) using AP-42 emission factor for NOx for wood residue combustion and source tested emissions rates for CO. Condition 7.6 was deleted in the amended permit since the permit does not require burner tune-up and condition 7.6 pertains to burner tune-up. 11. Permit Condition 7.7: Oxygen Monitoring System Callaway Farms requests that this condition be deleted since oxygen monitoring should no longer be required. Response: Condition 7.7 was deleted in the amended permit since the oxygen monitoring system is not required anymore at Callaway Farms. Permit Condition 7.9: VOC Monitoring Data Callaway Farms requests that this condition be deleted since VOC monitoring should no longer be required. Response: Condition 7.9 requires the Permittee to calculate the rolling 12 month total CO and VOC emissions each month in order to assure compliance with CO and VOC synthetic minor permit limit of 99 tons per year for these pollutants. Estimation of CO and VOC emissions are required each month. This condition was not deleted in this permit amendment. VOC emissions can be estimated from the AP-42 emission factor and green wood process rate which are converted to dry wood feed rate using the moisture content of the wet wood and the dry wood shavings. CO emissions will be calculated using CO emission factor calculated from the highest source tested CO emission rate from the most recent performance tests and the amount of dry wood shavings produced (in Oven Dry Tons). Therefore this Condition was not deleted in the amended permit. This condition assures that Callaway Farms complies with the CO and VOC synthetic minor permit limit of 99 tons/year and is a tool for Callaway to demonstrate compliance with the CO and VOC synthetic minor permit limits. Permit Conditions Existing Condition 2.3 is amended limiting the dry wood production rate from the shavings dryer 21,500 tons per year in order to prevent the facility from being a Title V major source. The dry wood feed rate can be calculated from the wet wood feed rate and the moisture content of the wet wood and the dried wood shavings. New Condition 4.2 requires the sawdust-fired burner to be operated in such a manner that temperature at the burner exit shall equal or exceed 1600 o F at all times the shavings dryer is in operation. This condition ensures optimum CO emissions from the burner. Existing Condition 5.2 is amended requiring the Permittee to continuously monitor the burner exit temperature using thermocouples and maintain this temperature at or above 1600 o F using a closed loop feedback (Allen Bradley program logic controller (PLC)) system and record three-hour averages of the burner exit temperature in order to minimize emissions of CO, VOC and HAPs from the facility. Page 11

12 Existing Condition 5.3 was deleted since it pertains to the initial testing and has been satisfied by the Permittee. Existing Condition 5.5 requiring installation and operation of an oxygen monitoring system for monitoring the oxygen levels in the burner/dryer system was deleted in this permit amendment since the Permittee has indicated that it can have the same or better level of control of emissions in the wood-fired burner using closed loop feedback (Allen Bradley program logic controller (PLC)) system for temperature control in the burner and other dryer operating parameters. Existing Condition 5.6 is amended deleting the oxygen level range that needs to be maintained. The operation and maintenance condition pertaining to the oxygen sensors has been deleted. This condition now requires checks for proper functioning of the temperature control system and monitoring the opacity of dryer stack emissions during startup, shutdown and any malfunction and for taking of corrective actions promptly. Condition 5.7 is deleted in the permit amendment since emissions are optimized using the closed loop feedback (Allen Bradley PCL) system. Existing testing Conditions 6.2 and 6.3 are deleted since these are initial performance test conditions that have been complied with. Existing test Condition 6.5 is deleted since the Permittee has already conducted a performance test for CO that demonstrated compliance with the CO synthetic minor permit limit in the December 2012 source test. EPD has determined that compliance test for VOC emission from the dryer is not needed at this time since potential VOC emissions have been estimated at less than 70 tons per year using AP-42 VOC emission factors. Existing Condition 6.6 is deleted since periodic testing is not required for synthetic minor sources and no additional tests are required by EPD at this time for operating the facility at conditions that existed during the source tests in December 2012 and July 2013 that demonstrated compliance with PM, CO and Opacity limits in the permit. Existing Condition 6.7 has been deleted since it pertains to initial performance testing that has been conducted in December 2012 and July New Condition 6.8 has been added to the permit requiring Callaway Farms to acquire and record all VOC and CO emissions pre-test and post-test data for two days before and after the source test and submit this data to EPD along with the source test report. This condition has been added since EPD has observed that the source test team tunes the system (burner/dryer system) for hours before the source test and EPD wants to ensure that operating conditions during the source test are maintained during normal/routine operations of the plant. The purpose of this Condition is to document operating conditions prior to, during and after adjustments of operating parameters and applies to any engineering testing, burner tuning, or other pre/post-test sampling conducted for source testing required by the Division. This condition is to ensure that the shavings plant is operated under conditions similar to those during the source tests for ensuring continuous compliance with the synthetic minor permit limits. Page 12

13 Existing Condition 7.1 was amended by requiring Callaway to record the hours of operation of the burner and dryer each month for use in calculating emissions of CO and PM using the hourly source tested hourly emission rates for these pollutants and the production of dry shavings (in oven dry tons). Existing Condition 7.2 has been amended by revising the SM throughput limit for green wood processed and expressing the SM permit limit as production of dry tons of wood shavings. Existing Condition 7.3 is amended requiring the Permittee to use the highest source tested CO emission rate of 13.5 lb/hr to estimate CO emission factor for wood shavings production to estimate emissions of CO. Existing Condition 7.5 is amended by deleting the excursion of oxygen levels in the burner since oxygen monitors are no longer needed. Existing Condition 7.6 was deleted since the permit does not require annual burner tune-ups and this condition pertains to burner Tune-up. Existing Condition 7.7 is deleted since the oxygen monitors are not required by the permit anymore. Existing Condition 7.8 is amended by requiring use of the AP-42 VOC emission factor of 6.4 lbs/odt till the next source test and use of the source tested CO emission rate of 3.5 lb/odt for estimating VOC and CO emissions each month. Summary & Recommendations I recommend that Air Quality Permit Amendment No S-01-2 be issued to Callaway Farms Manufacturing LLC allowing them to operate the facility at the source tested throughput rates at which compliance has been demonstrated for PM, CO and Opacity during the December 2012 and July 2013 source tests. This amendment does not require Callaway Farms to conduct any additional performance test to operate at the currently tested throughput rates. If the facility were to increase production rates beyond the rates during the successful performance tests in December 2012 and July 2013, Callaway may have to demonstrate compliance at the higher production rate by conducting new source tests at the higher production rate. The facility continues to be a SM source. The Compliance office (SSCP) in Atlanta continues to be responsible for the inspections and compliance oversight for this facility. No public advisory was issued for this application as no new sources are added to this facility and there is no increase in emission of any pollutant. Page 13