Facility Name: Huber Engineered Woods, LLC City: Commerce County: Jackson AIRS #: 04-13-157-00014 Application #: 23530 Date SIP Application Received: Date Title V Application Received: Permit No: 2493-157-0014-V-03-2 Not Applicable September 21, 2015 (with additional information received November 19, 2015 (via a conference call) and January 14, 2016) Program Review Engineers Review Managers SSPP Susan Jenkins David Matos SSCP Sharita Jenkins Farhana Yasmin ISMP Anna Gray Daniel McCain TOXICS N/A N/A Permitting Program Manager Eric Cornwell Introduction This narrative is being provided to assist the reader in understanding the content of the referenced SIP permit to construct and operate and Section 502(b)(10) change to the Part 70 source. Complex issues and unusual items are explained in simpler terms and/or greater detail than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Sections 391-3-1-.03(1), 391-3-1-.03(2), and 391-3-1-.03(10) of the Georgia Rules for Air Quality Control, (2) Part 70 of Chapter I of Title 40 of the Code of Federal Regulations, and (3) Title V of the Clean Air Act Amendments of 1990. The following narrative is designed to accompany the permit and is presented in the same general order as the permit amendment. This narrative is intended only as an adjunct for the reviewer and has no legal standing. Huber Engineered Woods, LLC, TV-23530 Page 1 of 7
I. Facility Description A. Existing Permits Table 1 below lists the current Title V permit, all administrative amendments and minor and significant modifications to that permit, and any 502(b)(10) changes. Comments are listed in Table 2 below. Table 1: Current Title V Permit and Amendments Comments Permit/Amendment Number Date of Issuance Yes No 2493-157-0014-V-03-0 November 15, 2012 X 2493-157-0014-V-03-1 October 4, 2013 X Off-Permit Change August 13, 2015 X Table 2: Comments on Specific Permits Permit Number Comments 2493-157-0014-V-03-0 Title V Renewal 2493-157-0014-V-03-1 Correct typographical error in Condition 5.2.12. Off-Permit Change Like-kind replacement of baghouse BH04 B. Regulatory 1. PSD/NSR/RACT: Huber Engineered Woods, LLC (Huber) is not listed as one of the 28 named source categories under 40 CFR 52.21(b). Therefore the PSD major source threshold is 250 tons per year for each regulated NSR pollutant. Huber is classified as an existing PSD major source for volatile organic compounds (VOC), nitrogen oxides (NOx), carbon monoxide (CO), filterable particulate matter (PM), total PM10 (filterable and condensable), total PM2.5 (filterable and condensable) and sulfur dioxide. In 2011, Huber underwent a PSD review and accepted BACT limits for VOC, NOx, CO, PM, PM10, and PM2.5. Huber avoided PSD review for SO2 emissions by accepting a limit on the mass of accelerant used to 151 tons during any twelve consecutive month period. 2. Title V by Table 3: Title V If emitted, what is the facility s Title V status for the? Requesting SM Non- PM Yes PM 10 Yes PM 2.5 Yes SO 2 Yes VOC Yes NO x Yes CO Yes TRS H 2 S Unknown Unknown Huber Engineered Woods, LLC, TV-23530 Page 2 of 7
Table 3: Title V If emitted, what is the facility s Title V status for the? Requesting SM Non- Individual HAP Yes Total HAPs Yes Total GHGs Yes II. Proposed Modification A. Description of Modification: Huber plans to relocate, replace, and upgrade its existing board conveyor, trim and grade, and sanding operations. By physically decoupling the sawing operations from the edging operations within the trim and grade process, Huber will improve product flow by reducing excess handling of the product, which will also improve the quality of the OSB sheet by maintaining a consistent thickness in the produce. As part of this operation change, Huber is proposing to replace existing baghouse 4 (BH04) [authorized under Off- Permit Change dated August 13, 2015] which controls PM emissions from emission unit ID BDFN with a new baghouse(bh04a). PM emissions from the existing tongue and groove operations will be routed to either existing baghouse BH05 which also controls PM emissions from emission unit ID BDFN or new baghouse BH04A. Huber is requesting the flexibility to tie the PM emissions from the existing tongue and groove operations to either existing baghouse BH05 or new baghouse BH04A. Huber is requesting a new permit condition to link the tongue and groove operations to baghouse BH04A. Existing permit condition 3.2.10.f will not need to be modified to allow for this operational flexibility. B. Emissions Change: The project involves transferring a subset of the PM, PM10, PM2.5 emissions that are currently emitted from baghouse BH05 to the new baghouse BH04A. This project will not involve an increase in production or throughput from the existing operations, including the board conveyor, trim and grade, and sanding operations. Therefore, this project does not involve a net emissions increase of PM, PM10, and PM2.5 from the facility. Table 4: Emissions Change Due to Modification Net Actual Emissions PM Yes 0.0 0.0 PM 10 Yes 0.0 0.0 PM 2.5 Yes 0.0 0.0 SO 2 No 0.0 0.0 VOC No 0.0 0.0 NO x No 0.0 0.0 CO No 0.0 0.0 TRS Unknown 0.0 0.0 H 2 S Unknown 0.0 0.0 Net Potential Emissions Huber Engineered Woods, LLC, TV-23530 Page 3 of 7
Table 4: Emissions Change Due to Modification Net Actual Emissions Net Potential Emissions C. Title I Modification Individual HAP No 0.0 0.0 Total HAPs No 0.0 0.0 Total GHGs No 0.0 0.0 PSD/NSR Applicability: The project does not require a re-analysis of the PSD BACT limits for the various equipment in the Emission Group BDFN because the applicant is not requesting relaxation of the existing PSD BACT limits for Emission Group BDFN. In addition, the proposed physical changes will not result in an increase in emissions from Emission Group BDFN. NSPS Modification: The proposed project does not trigger an NSPS regulation. NESHAP Modification: The proposed project does not trigger any new NESAP requirements. III. Facility Wide Requirements A. Emission and Operating Caps: Not applicable based on the proposed project. B. Applicable Rules and Regulations: No new rules/regulations apply based on the proposed project. There are no changes to existing requirements for the equipment covered by the proposed project. C. Compliance : The facility appears to be in compliance with their Title V permit based on a review of the facility s air permit compliance files. D. Operational Flexibility: No facility-wide operational flexibility is requested for the proposed project. E. Permit Conditions: No changes to Section 2 of the facility s Title V permit is recommended based on the proposed project. IV. Regulated Equipment Requirements A. Brief Process Description: Please refer to Section II.A of this narrative for a discussion of the proposed project. B. Equipment List for the New or Modified Process(es): This project pertains to existing Emission Group BDFN (trim and grade equipment, sanding, and tongue & groove equipment) C. Equipment & Rule Applicability: The following table specifies the current PSD requirements for the applicable equipment. The alternative flexibility to exhaust sawing and tongue & groove process flow is added as a permit condition in Section 7.3 of the Title V permit. Equipment PSD/BACT Emissions Limit Trim and Grade Total PM 0.0038 gr/scf Equipment in Emission Group BDFN Total PM10 0.0038 gr/scf Note(s) Currently exhausts through baghouse BH04 which is a radial exhaust baghouse. Huber Engineered Woods, LLC, TV-23530 Page 4 of 7
Equipment PSD/BACT Emissions Limit Note(s) *trim and grade are removes rough edges from the four sides of the board. PM2.5 3.17 x 10-4 gr/scf New BH04A discharges through one stack and is not a radial discharge baghouse. New baghouse BH04A has a volume flow rate of 43,800 cfm. Edging volume flow rate = 21,000 cfm Sawing volume flow rate = 9,600 cfm Alternative operation has the tongue & groove operation exhaust through BH04A. Tongue & groove operation has a volume flow rate of 4,800 cfm. Alternative operation has 8,400 cfm of air flow from the cleanout of BH05. Sanding and Tongue & Groove Equipment in Emission Group BDFN *Sander removes rough surface from top side of board. Total PM Total PM10 PM2.5 0.0038 gr/scf 0.0038 gr/scf 3.17 x 10-4 gr/scf Potential volume flow rate to BH04A = 21,000 cfm + 9,600 cfm + 4,800 cfm + 8,400 = 43,800 cfm Tongue and Groove currently exhausts through baghouse BH05. Sanding currently exhausts through baghouse BH05. Baghouse BH05 is a radial discharge baghouse. BH05 has a volume flow rate of 56,200 cfm down from 61,000 cfm. Sander has a volume flow rate of 56,200 cfm. Alternative operation has 8,400 cfm of air flow being sent to BH04A. So not all of the Sanding operations will be vented to BH05. Total CFM = 56,200 cfm -8,400 cfm = 47,800 cfm Huber Engineered Woods, LLC, TV-23530 Page 5 of 7
D. Compliance : A review of Huber s air compliance files shows that the facility is complying with the requirements of its Title V air permit. E. Operational Flexibility: A new Permit Condition is added to Section 7.14 authorizing the emissions from sawing and tongue and groove to be vented to BH04A as needed. The PM, PM10, and PM2.5 BACT limits of existing Permit Condition No. 3.2.10.e and f will still apply. F. Permit Conditions: No changes to Section 3 of the permit are recommended based on the proposed project. V. Testing Requirements (with Associated Record Keeping and Reporting) A. Individual Equipment: Georgia EPD will require testing of PM, PM10, and PM2.5 emissions from new baghouse BH04A to verify compliance with the PSD BACT emission limits. No testing will be required from existing baghouse BH05 because this baghouse is a radial discharge baghouse. New baghouse BH04A will discharge through one stack. B. Equipment Groups (all subject to the same test requirements): No changes are recommended for testing of PM, PM10, and PM2.5 emissions from Emission Group BDFN. VI. Monitoring Requirements (with Associated Record Keeping and Reporting) A. Individual Equipment: Existing Permit Condition No. 5.2.2 needs to include new baghouse BH04A. Existing Permit Condition No. 5.2.2 is deleted and replaced with new Permit Condition No. 5.2.20. Existing Permit Condition No. 5.2.5 requires a daily visible emissions (VE) check from baghouses BH01, BH23, BH04 (existing), and BH05. Each of these existing baghouses are classified as radial discharge baghouses and VE cannot be checked using the procedures in existing Permit Condition No. 5.2.5. Therefore existing Permit Condition No. 5.2.5 is deleted and replaced with new Permit Condition No. 5.2.21. New baghouse BH04A will exhaust through a single stack and Huber will equip this baghouse with a bag leak detection system in lieu of a daily VE check. This new requirement will be incorporated as new Permit Condition No. 5.2.22. The bag leak detection system must be installed within 120 days of baghouse BH04A commencing operation. An excursion for the bag leak detection system is defined as any alarm signal as described in New Permit Condition 5.2.22. Existing Permit Condition Nos. 5.2.8 and 5.2.9 specifies CAM requirements for baghouses with source codes BH01, BH23, BH04, and BH05. This Permit Condition is deleted as VE checks as defined in this Permit Condition are no longer required by the Permit (i.e., these existing baghouses are radial discharge baghouses). New Permit Condition Nos. 5.2.23 and 5.2.24 establishes CAM for baghouses with source codes BH01, BH23, BH04, BH04A, and BH05 using two existing indicators (Pressure Drop and PMP Program Implementation). Existing Permit Condition No. 5.2.9 specifies the CAM requirement that Huber measure the gas stream inlet pressure. Huber requested that this parameter be changed to read pressure drop. Existing Permit Condition No. 5.2.9 is deleted and replaced with New Permit Condition No. 5.2.24. B. Equipment Groups (all subject to the same monitoring requirements): Not applicable. Huber Engineered Woods, LLC, TV-23530 Page 6 of 7
VII. Other Record Keeping and Reporting Requirements The definition of an excursion for the baghouses is revised as follows: Permit Condition 6.1.7.c.vi is deleted and replaced by Permit Condition 6.1.7.c.ix; and Permit Condition 6.1.7.c.x is added for the bag leak detection system to be in place in new baghouse BH04A. New recordkeeping and reporting requirements are imposed by New Permit Condition No. 6.2.9 and 6.2.10 in order to track the date of effectiveness of Permit Condition Nos. 5.2.20, 5.2.22, and 5.2.23 for baghouse BH04A. VIII. Specific Requirements A. Operational Flexibility: A new Permit Condition No. 7.14.1 is added to allow the sawing and tongue and groove operations to exhaust through baghouses BH04, BH04, or BH05 as needed by the applicant. B. Alternative Requirements: Not applicable. C. Insignificant Activities: No changes or additions are being made to the insignificant activities portion of Huber s Title V air permit. D. Temporary Sources: Not Applicable. E. Short-Term Activities: Not Applicable. F. Compliance Schedule/Progress Reports: Not Applicable. G. Emissions Trading: Not Applicable. H. Acid Rain Requirements: Not Applicable. I. Prevention of Accidental Releases: The proposed project does not change the source s applicability to 40 CFR 68. J. Stratospheric Ozone Protection Requirements: The proposed project does not change the source s applicability to Title VI. K. Pollution Prevention: Not Applicable. L. Specific Conditions: A new Permit Condition No. 7.14.1 is added to allow the sawing and tongue and groove operations to exhaust through baghouses BH04, BH04A or BH05 as needed by the applicant. Note: Huber requested revision of PSD BACT limits specified in existing Permit Condition Nos. 3.2.10 to only apply to filterable PM emissions on January 25, 2016. This request is outside the scope of the applicable permit application and is not considered in this review. Huber Engineered Woods, LLC, TV-23530 Page 7 of 7