Langboard OSB, Quitman City - Georgia Air Protection Branch

Title V Renewal Application Review Langboard OSB, Quitman, TV-20734 

Introduction 

Facility Name: Langboard OSB, Quitman 

City: Quitman 

County: Brooks 

AIRS #: 04-13-027-00013 

Application #: TV-20734 

Date Application Received: October 06, 2011 

Permit No: 2493-027-0013-V-03-0 

Program Review Engineers Review Managers 

SSPP Hem R. Sharma David Matos 

ISMP Bob Scott Richard Taylor 

SSCP John Harrison Douglas Waldron 

Toxics Dika Kuoh Michael Odom 

Permitting Program Manager Eric Cornwell 

This narrative is being provided to assist the reader in understanding the content of the attached draft Part 70 

operating permit. Complex issues and unusual items are explained here in simpler terms and/or greater detail 

than is sometimes possible in the actual permit. This permit is being issued pursuant to: (1) Georgia Air Quality 

Act, O.C.G.A § 12-9-1, et seq. and (2) Georgia Rules for Air Quality Control, Chapter 391-3-1, and (3) Title V 

of the Clean Air Act. Section 391-3-1-.03(10) of the Georgia Rules for Air Quality Control incorporates 

requirements of Part 70 of Title 40 of the Code of Federal Regulations promulgated pursuant to the Federal 

Clean Air Act. The primary purpose of this permit is to consolidate and identify existing state and federal air 

requirements applicable to Langboard OSB, Quitman and to provide practical methods for determining 

compliance with these requirements. The following narrative is designed to accompany the draft permit and is 

presented in the same general order as the permit. It initially describes the facility receiving the permit, the 

applicable requirements and their significance, and the methods for determining compliance with those 

applicable requirements. This narrative is intended as an adjunct for the reviewer and to provide information 

only. It has no legal standing. Any revisions made to the permit in response to comments received during the 

public participation and EPA review process will be described in an addendum to this narrative. 

Printed: November 7, 2012 Page 1 of 34


I. Facility Description 

A. Facility Identification 

1. Facility Name: Langboard OSB, Quitman 

2. Parent/Holding Company Name 

Langdale Industries 

3. Previous and/or Other Name(s); Langboard, Inc. 

4. Facility Location 

U.S. Highway 84 East, Quitman, Brooks County, Georgia 31643 

5. Attainment, Non-attainment Area Location, or Contributing Area 

B. Site Determination 

The facility is located in an attainment area. 

This permit covers the OSB plant constructed in 2005, the details of which are included in Title 

V permit application No. 15084. Note that the original old OSB plant, which was adjacent and 

under common control, ceased to operate after the startup of the exiting new plant. 

C. Existing Permits 

Table 1 below lists all current Title V permits, all amendments, 502(b)(10) changes, and offpermit 

changes, issued to the facility, based on a comparative review of form A.6, Current 

Permits, of the Title V application and the "Permit" file(s) on the facility found in the Air Branch 

office. 

Table 1: List of Current Permits, Amendments, and Off-Permit Changes 

Permit Number and/or Off- Date of Issuance/ Purpose of Issuance 

Permit Change 

Effectiveness 

2493-027-0013-V-02-0 

April 05, 2007 

First Title V permit renewal 



D. Process Description 

1. SIC Codes(s) 

2493 

The SIC Code(s) identified above were assigned by EPD's Air Protection Branch for 

purposes pursuant to the Georgia Air Quality Act and related administrative purposes 

only and are not intended to be used for any other purpose. Assignment of SIC Codes by 

EPD's Air Protection Branch for these purposes does not prohibit the facility from using 

these or different SIC Codes for other regulatory and non-regulatory purposes. 

Should the reference(s) to SIC Code(s) in any narratives or narrative addendum 

previously issued for the Title V permit for this facility conflict with the revised language 

herein, the language herein shall control; provided, however, language in previously 

issued narratives that does not expressly reference SIC Code(s) shall not be affected. 

2. Description of Product(s) 

This plant produces oriented strand board (OSB). 

3. Overall Facility Process Description 

Mixed pine and limited amount of southern hardwoods are received by truck, debarked, 

cut to length, flaked, conveyed to wet flake metering bins, and dried. The wood flakes 

are dried in two single pass rotary flake dryers, each with a maximum input rate of 

75,000 pounds per hour (lb/hr). The drying heat is provided by one of two wood fired 

furnaces (aka Energy Systems). The heat input capacity of each energy system is 160 

million British thermal units per hour (MMBtu/hr), burning wood bark and other wood 

waste fuel recovered from the process, and controlled by an electrostatic precipitator 

(ESP) and nitrogen oxide (NOx) Abatement System. The Energy Systems receive 

exhaust gases from the dryers, board press, and blenders for reduction of VOC emissions. 

The dried flakes are screened for fines removal and then mixed with wax and phenolformaldehyde 

resin in the blenders. Flakes are then aligned in a continuous mat. The mat 

is cut into sections, pressed at high temperature and pressure in a board press, which is 

heated by thermal oil. The boards are then sanded, trimmed to size, graded, edge coated, 

and packaged for shipment. The plant can manufacture up to 500 million square feet per 

year (MMsf/yr) of OSB. 

4. Overall Process Flow Diagram 

The facility provided a process flow diagram in their previous Title V permit application. 

No physical or operational changes have occurred since the current permit. 



E. Regulatory Status 

1. PSD/NSR 

Langboard’s potential to emit (with permit limits) each PSD regulated pollutant does not 

exceed the 250-ton per year PSD major source threshold for any pollutant. The facility is, 

therefore, not a major source for PSD/NSR regulations. This facility is not one of the 28 

named source categories under PSD for which the PTE threshold is 100 tons per year. 

Also the facility is not located in a non-attainment area. Note that the facility is presently 

a synthetic minor source for the purposes of PSD permitting requirements as emissions of 

CO and NOx are limited below the major source threshold of 250 tpy. 

2. Title V Major Source Status by Pollutant 

Table 2: Title V Major Source Status 

Pollutant 

Is the 

Pollutant 

Emitted? Major Source Status 

PM 

PM 10 

If emitted, what is the facility’s Title V status for the pollutant? 

Major Source 

Requesting SM Status 

Non-Major Source 

Status 

SO 2 

VOC 

NO x 

CO 

TRS 

H2S 

 

Greenhouse 

Gases 

Individual 

HAP 

Total HAPs 

3. MACT Standards 

No MACT standards apply to this plant. 

40 CFR 63, Subpart DDDDD, NESHAP for Industrial/Commercial/Institutional Boilers 

and Process heaters (The Boiler MACT), was promulgated on March 21, 2011with an 

affected date of May 20, 2011. However, this MACT is not applicable to the facility 

because potential HAP emissions are estimated to be less than 10/25 tpy, and this is only 

applicable to the major sources of HAPs emissions. 

The promulgated MACT, 40 CFR 63, Subpart DDDD, NESHAP for Plywood and 

Composite Wood Products (PCWP) (Federal Register, Vol. 69, No. 146/Friday, July 30, 



2004/Rules and Regulations), regulates HAP emissions from major HAP sources. As this 

facility is not a major source for HAPs, the facility is not subject to the PCWP MACT. 

A facility is subject to the Area Source Boilers NESHAP (40 CFR 63 Subpart JJJJJJ – 

National Emission Standards for hazardous Air Pollutants for Industrial, Commercial, 

and institutional boilers Area Sources, if the facility owns or operate an industrial, 

commercial, or institutional boiler as defined in §63.11237 that is located at, or is part of, 

an area source of hazardous air pollutants (HAP). A list of the regulated hazardous air 

pollutants can be found at http://www.epa.gov/ttnatw01/orig189.html. 

In accordance with §63.11237 of this NESHAP, a boiler means an enclosed device using 

controlled flame combustion in which water is heated to recover thermal energy in the 

form of steam or hot water. Controlled flame combustion refers to a steady-state, or near 

steady-state, process wherein fuel and/or oxidizer feed rates are controlled. 

However, this NESHAP is not applicable to the facility because the Energy System A 

and Energy System B (Emission Unit ID Nos. P001 and P002) are fuel-burning 

equipment and are not defined as boilers per this NESHAP. 

4. Program Applicability (AIRS Program Codes) 

Program Code 

Applicable 

(y/n) 

Program Code 6 - PSD No 

Program Code 8 – Part 61 NESHAP No 

Program Code 9 - NSPS Yes 

Program Code M – Part 63 NESHAP No 

Program Code V – Title V Yes 



Regulatory Analysis 

II. Facility Wide Requirements 

A. Emission and Operating Caps: 

VOC emissions from the Langboard's existing (new) OSB plant are controlled by Energy System 

incineration, and emissions are estimated to be less than 250 tpy. Therefore, no condition 

limiting the pine usage was included in the existing permit (No. 2493-027-0013-V-02-0). 

However, since the existing (new) plant’s PTE individual and total HAPs emission were 8.5 and 

24.3 tpy respectively, which are very close to the 10/25 tpy HAP major source thresholds, 

emissions of HAPs were capped. Since all major emission sources are to be routed through the 

Energy System, limiting HAP emissions from the Energy System will effectively limit HAP 

emissions facility wide. The following Condition 2.1.1, included in the Title V Permit No. 2493- 

027-0013-V-02-0, is carried over in this permit renewal: 

2.1.1 The Permittee shall not cause, let, suffer, permit or allow the rate of emissions from the 

entire facility any gases, which contain individual and total hazardous air pollutants 

(HAP), including but not limited to acetaldehyde, acrolein, formaldehyde, methanol, 

phenol, and propionaldehyde in amounts in excess of 10 tpy and 25 tpy respectively 

during any twelve (12) consecutive months. 

[MACT and 112(g) Avoidance Limit, 391-3-1-.02(2)(a)3] 

B. Applicable Rules and Regulations 

40 CFR Parts 51, 52, 70, et al.: Prevention of Significant Deterioration and Title V Greenhouse 

Gas Tailoring Rule; Final Rule (Thursday, June 3, 2010). Per PSD Permitting rule of this part, 

Step 2 began on July 1, 2011. Under Step 2, anyway PSD sources—that is, sources already 

subject to PSD based on non-GHGs and covered under Step 1 previously—will remain subject to 

PSD. In addition, sources with the potential to emit 100,000 tpy CO2e or more of GHG will be 

considered major sources for PSD permitting purposes (provided that they also emit GHGs or 

some other regulated NSR pollutant above the 100/ 250 tpy (mass based) statutory thresholds. 

On July 20, 2011, EPA issued a deferral for CO2 emissions from biogenic and other biogenic 

sources under the PSD and Title V permitting programs. The action defers for a period of three 

years the application of PSD permitting requirements for biogenic CO2 emissions only. The 

application indicates that the facility has excluded CO2 emissions only (not CH4 or N2O 

emissions) from the biomass fueled energy systems, for estimating the total facility-wide CO2e 

emissions from the OSB plant. 

The application indicates that the facility-wide GHG potential to emit CO2e is 6,267 tpy which is 

less than 100,000 tons per year. Therefore, the facility is not a major of GHG with respect to 

Title V and PSD. 

C. Compliance Status 

The plant is currently operating in compliance per record. 



D. Operational Flexibility 

The facility did not request any operational flexibility. 

E. Permit Conditions 

Since this permit renewal is only for the operation of the existing (new) OSB plant, which was 

commissioned in the year 2005, only conditions pertaining to the existing OSB plant, from the 

Title V Permit No. 2493-027-0013-V-02-0, are included in this renewal permit. 

Note: The original plant, before this existing OSB plant, which was authorized to operate by 

Permits No. 2493-027-0013-V-01-0 (Initial TV Permit issued on August 31, 1999, No. 2493- 

027-0013-V-01-1 [a 502(b)(10) Permit Amendment issued on July 16, 2002], and an off permit 

change letter dated October 1, 2002, had ceased to operate. The facility, in a letter dated June 30, 

2005, indicated that the original plant equipment, including the Geka Thermal Oil Heater and 

wood fired dryers, had been permanently shut down in June 2005. 

Condition No. 2.1.1: 

Condition No. 2.1.1, which requires the Permittee to limit individual and total HAP emissions to 

less than 10/25 tons per year to avoid being a major source of HAPs, is the same as existing 

permit Condition No. 2.1.1. 



III. Regulated Equipment Requirements 

A. Brief Process Description 

Langboard, Inc. currently operates a plant with a capacity to manufacture 500 million square feet 

per year (MMsf/yr) of Oriented Strand Board (OSB). For the manufacturing of OSB, mixed 

southern hardwoods and pine are received by truck, debarked, cut to length, flaked, and 

conveyed to dryer metering bins and dried. Single pass rotary dryers are indirectly heated by the 

hot air supplied by the energy systems. The dried flakes are screened for fines removal, and 

conveyed to blender metering bins. The flakes are mixed with wax and phenol-formaldehyde 

resin in the blenders. Flakes are then aligned in a continuous mat. The mat is cut into sections 

and pressed at high temperature and pressure. Finally, the boards are sanded, trimmed to size, 

graded, edge coated, and packaged for shipment. Note that, all emissions from the OSB dryers, 

blending, and board press are routed to the energy system for incineration 

B. Equipment List for the Process 

Emission Units Specific Limitations/Requirements Air Pollution Control Devices 

ID No. Description 

P001 

P002 

P003 

P004 

P005 

Energy System A 

(160 MMBtu/hr 

heat input capacity, 

wood-fired combustion 

system) 

Energy System B 

(160 MMBtu/hr 

heat input capacity, 

wood-fired combustion 

system) 

Dryer System A 

(Single pass rotary flake 

dryer) 

Dryer System B 

(Single pass rotary flake 

dryer) 

Fines/Flake Screening 

Applicable 

Requirements/Standards 

40 CFR 60, Subpart A 

40 CFR 60, Subpart Db 

GA Rule 391-3-1-.02(2)(d) 

GA Rule 391-3-1-.02(2)(g) 

40 CFR 60, Subpart A 

40 CFR 60, Subpart Db 

GA Rule 391-3-1-.02(2)(d) 

GA Rule 391-3-1-.02(2)(g) 

GA Rule 391-3-1-.02(2)(e) 

GA Rule 391-3-1-.02(2)(b) 

GA Rule 391-3-1-.02(2)(e) 

GA Rule 391-3-1-.02(2)(b) 

GA Rule 391-3-1-.02(2)(e) 

GA Rule 391-3-1-.02(2)(b) 

Corresponding Permit 

Conditions 

3.2.1, 3.2.3, 3.3.1, 3.3.2, 

3.3.3, 3.4.1, 3.4.2, 3.5.1, 

3.5.2, 3.5.4, 4.2.1, 4.2.2, 

4.2.3, 4.2.4, 4.2.5, 4.2.7, 

4.2.8, 5.2.1, 5.2.2, 5.2.8, 

5.2.9, 5.2.10, 5.2.11, 

5.2.12, 5.2.13, 6.1.7, 6.2.1, 

6.2.3, 6.2.7, 6.2.8 

3.2.1, 3.2.3, 3.3.1, 3.3.2, 

3.3.3, 3.4.1, 3.4.2, 3.5.1, 

3.5.2, 3.5.4, 4.2.1, 4.2.2, 

4.2.3, 4.2.4, 4.2.5, 4.2.7, 

4.2.8, 5.2.1, 5.2.2, 5.2.8, 

5.2.9, 5.2.10, 5.2.11, 

5.2.12, 5.2.13, 6.1.7, 6.2.1, 

6.2.3, 6.2.7, 6.2.8 

3.4.3, 3.4.4, 3.4.5, 3.4.6, 

3.5.1, 3.5.2, 3.5.4, 4.2.5, 

5.2.8, 5.2.11, 5.2.12, 

5.2.13, 6.1.7, 6.2.1, 6.2.4 

3.4.3, 3.4.4, 3.4.5, 3.4.6, 

3.5.1, 3.5.2, 3.5.4, 4.2.5, 

5.2.8, 5.2.11, 5.2.12, 

5.2.13, 6.1.7, 6.2.1, 6.2.4 

3.2.2, 3.4.3, 3.4.4, 3.4.5, 

3.4.6, 3.5.2, 3.5.3, 3.5.4, 

5.2.3, 5.2.4, 5.2.5, 5.2.6, 

6.1.7, 6.2.3, 6.2.9 

Printed: November 7, 2012 Page 8 of 34 

ID 

No. 

C001 

C007 

C001 

C007 

P001 

and 

P002 

P001 

and 

P002 

C002 

Description 

Electrostatic 

Precipitator (ESP) 

NOx Abatement 

System 

(Stack ID. S001) 

Electrostatic 

Precipitator (ESP) 

NOx Abatement 

System 



and 




and 



Fuel Storage Bin Vent 

(OG03) 

(Stack ID. S002)


Emission Units Specific Limitations/Requirements Air Pollution Control Devices 

ID No. Description 

P006 

P007 

P008 

P009 

P010 

P011 

Flake 

Handling/Blending 

Forming Line 

Board Press 

Sander Line 

Saw & Trim Line 

Fuel Relay and 

Storage Silo 

Applicable 

Requirements/Standards 

GA Rule 391-3-1-.02(2)(e) 

GA Rule 391-3-1-.02(2)(b) 

GA Rule 391-3-1-.02(2)(e) 

GA Rule 391-3-1-.02(2)(b) 

GA Rule 391-3-1-.02(2)(e) 

GA Rule 391-3-1-.02(2)(b) 

GA Rule 391-3-1-.02(2)(e) 

GA Rule 391-3-1-.02(2)(b) 

GA Rule 391-3-1-.02(2)(e) 

GA Rule 391-3-1-.02(2)(b) 

GA Rule 391-3-1-.02(2)(e) 

GA Rule 391-3-1-.02(2)(b) 

Corresponding Permit 

Conditions 

3.2.2, 3.4.3, 3.4.4, 3.4.5, 

3.4.6, 3.5.1, 3.5.2, 3.5.3, 

3.5.4, 4.2.5, 5.2.3, 5.2.4, 

5.2.5, 5.2.6, 5.2.7, 5.2.11, 

5.2.13, 5.2.14, 6.1.7, 6.2.1, 

6.2.3, 6.2.4, 6.2.9 

3.2.2, 3.4.3, 3.4.4, 3.4.5, 

3.4.6, 3.5.2, 3.5.3, 3.5.4, 

5.2.3, 5.2.4, 5.2.5, 5.2.6, 

5.2.7, 6.1.7, 6.2.3, 6.2.5, 

6.2.9 

3.4.3, 3.4.4, 3.4.5, 3.4.6, 

3.5.1, 3.5.2, 3.5.4, 3.5.5, 

4.2.5, 4.2.6, 5.2.11, 5.2.13, 

5.2.15, 6.1.7, 6.2.2, 6.2.4, 

6.2.5, 6.2.6 

3.2.2, 3.4.3, 3.4.4, 3.4.5, 

3.4.6, 3.5.2, 3.5.3, 3.5.4, 

5.2.3, 5.2.4, 5.2.5, 5.2.6, 

6.1.7, 6.2.3, 6.2.9 

3.2.2, 3.4.3, 3.4.4, 3.4.5, 

3.4.6, 3.5.2, 3.5.3, 3.5.4, 

5.2.3, 5.2.4, 5.2.5, 5.2.6, 

6.1.7, 6.2.3, 6.2.9 

3.2.2, 3.4.3, 3.4.4, 3.4.5, 

3.4.6, 3.5.2, 3.5.3, 3.5.4, 

5.2.3, 5.2.4, 5.2.5, 5.2.6, 

6.1.7, 6.2.3, 6.2.9 

Printed: November 7, 2012 Page 9 of 34 

ID 

No. 

C004 

P001 

and 

P002 

C003 

P001 

and 

P002 

C006 

C003 

C002 

Description 

Flaker Handling (dry 

bins) Baghouse for PM 

control 



and 


used to incinerate VOC 

and HAP emissions 


Forming Line and 

Saw & Trim Baghouse 

(OG02) 



and 


used to incinerate VOC 

and HAP emissions 


Sander Line Baghouse 


Forming Line and 

Saw & Trim Baghouse 

(OG02) 


Fuel Storage Bin Vent 

(OG03) 


* Generally applicable requirements contained in this permit may also apply to emission units listed above. This table includes all the 

emission sources and control equipment as per revised configuration provided in the updated Title V renewal applications dated 

November 17, 2005, and December 15, 2006. This renewal application No. 20734 confirms this configuration/emission sources. 

___________________________________________________________________________________ 

Note: 1. Energy System A was originally manufactured in 2004. During construction, the primary air heater was severely damaged. 

It was rebuilt and installed in 2005. 

2. NOx abatement system uses a urea injection system, which is automated and controlled by a feedback connection to the 

CERMS installed on the NOx abatement system.


C. Equipment & Rule Applicability 

Emission and Operating Caps: 

The emission and operating Caps, as indicated in the existing Title V Permit No. 2493-027-0013- 

V-02-0 (no amendment issued), which was based on Title V Permit Amendment No. 2491-027- 

0013-V-01-2 ,2491-027-0013-V-01-3 and 2491-027-0013-V-01-4, are as below: 

The Energy System emits NOx and CO. The PTE indicated by the facility in their applications, 

for each of these pollutants, were not much less than the 250 tpy PSD major source threshold for 

each. To help assure that the facility stays a minor source for PSD, the following facility wide 

limits for NOx and CO emissions are imposed in their Title V Permit No. 2493-027-0013-V-02- 

0. 

3.2.1 The Permittee shall not cause, let, suffer, permit or allow the rate of emissions from 

Energy System A and Energy System B (Emission Unit ID Nos. P001 and P002), 

combined, nitrogen oxides (NOx) or carbon monoxide (CO) equal to or in excess of 

57.05 lb/hr (30 day rolling average). 

[PSD Avoidance Limits] 

AP-42, Fifth Edition (9/2003), Section 1.6 (Wood Residue Combustion in Boilers) indicates a 

NOx emission factor of 0.22 lb/MMbtu for bark/bark and wet wood/wet wood-fired boilers, and 

0.44 lb/MMbtu for dry wood-fired boilers. Using the emission factor of 0.22, NOx emissions are 

estimated to be 70.4 lb/hr from both Energy Systems A and B, compared against the emission 

cap of 57.05 lb/hr (Condition 3.2.1). Therefore, it is expected that the facility might not be able 

to comply with the emission standards for CO and NOx without controls. Note that NOx 

emissions from wet bark in wood boilers are typically lower (approximately one-half), in 

comparison to NOx emissions from dry wood-fired boilers. 

The narrative for the existing Title V Permit No. 2493-027-0013-V-02-0 indicates the following: 

“The updated Title V renewal application indicates that the energy systems had not performed up 

to the manufacturer’s specifications. The Permittee has worked with the energy system 

manufacturer on strategies to reduce emissions of CO and NOx in order to meet the guaranteed 

levels and comply with the permit limits. 

To reduce CO emissions, Langboard has determined that it must maintain a higher temperature 

in the combustion chamber. However, while reducing CO emissions, the higher chamber 

temperature is likely to result in more NOx formation and thus higher NOx emissions. That can 

only be countered with add-on control equipment. 

AP-42 literature indicates that, in those areas of the U. S. where NOx emissions must be reduced 

to their lowest levels, the application of selective noncatalytic reduction (SNCR) equipment to 

residue wood fired boilers has achieved reductions; also, that the application of selective 

catalytic reduction (SCR) is being contemplated where better control is required. Both systems 

are post-combustion NOx reduction techniques, in which ammonia (or urea) is injected into the 

flue gas to selectively reduce NOx to nitrogen and water. In one application of SNCR to an 



industrial wood-fired boiler, NOx reduction efficiencies varied between 35 and 75 percent, as the 

ammonia-to-NOx ratio increased from 0.4 to 3.2. 

The updated renewal application indicated that a previously considered NOx abatement system 

would need to be added to the energy system, as recommended by the manufacturer, to lower 

annual NOx emissions to less than the major source threshold. The Permittee has requested that 

EPD authorize the installation and operation of an ammonia injection NOx abatement system. 

The Permittee initially stated that it would only operate the NOx abatement system on an as 

needed basis, using the NOx Continuous Emission Rate Monitoring System (CERMS) to 

demonstrate compliance with the permit limits. However, it now appears that the overall level of 

control needed, in order to be a minor source for NOx, will require them to use the NOx 

abatement system most of the time. 

Therefore, the permit requires that the NOx abatement system be operated at all times when the 

furnaces are operating, except during startup, shutdown and malfunction. For compliance 

purposes, the current NOx CERMS will be used to demonstrate that NOx and CO emissions 

from the plant each remain below the permitted limits of 57.05 lb/hr (30 day rolling average). 

Also, in order to minimize the use of urea and ammonia slip, the urea injection system is to be 

controlled by feedback connection to the CERMS.” 

To ensure that facility wide PM emissions cannot exceed the 250 tpy PSD major source 

threshold, the Permittee accepted a PM emissions limit of 0.060 lb/MMBtu, from Energy System 

Units A and B (Emission Unit ID Nos. P001 and P002). Therefore, the Energy System PTE is 

lower than it would be, if only considering the NSPS limit. It is 84.10 tpy. The PM emissions are 

controlled by a dedicated ESP. Given the reliability of ESPs, it was therefore expected that the 

energy system will be in compliance with the NSPS and this limit. The PM limit is included in 

Condition 3.2.3, which is same as existing permit condition and as indicated below. 

3.2.3 The Permittee shall not cause, let, suffer, permit or allow the rate of emissions from the 

Energy System (Emission Unit ID Nos. P001 and P002) stack (Stack ID. S001), 

downstream of the electrostatic precipitator (APCD ID No. C001), any emissions which 

contain PM in excess of 0.060 lb/MMBtu. 

[PSD Avoidance Limits and 40 CFR 60 Subpart Db-subsumed] 

Manufacturing Processes 

The previous Title V application indicates that the facility wide PTE PM is revised to 249.5 from 

222.5 tpy, and 69.2 tpy from 106.2 tpy for VOC. The Permittee has accepted the following 

revised limits for the following manufacturing processes, each of whose PM emissions are 

controlled by a dedicated baghouse, to ensure that PM emissions stay under the PSD major 

source threshold of 250 tpy, facility wide; the limits are revised, as requested, because the 

configuration of the control equipment was modified: 

a. Forming (Emission Unit ID No. P07) and 

Saw Line (Emission Unit ID No. P10)- 

Controlled by BGH1 (APCD ID No. C03): 12.9 lb/hr. 



b. Sander Line (Emission Unit ID No. P09)- 


c. Flaker Handling/Blending (Emission Unit ID No. P06)- 


d. Fines/Flake Screening (Emission Unit ID No. P05) and 

Fuel Relay and Storage (Emission Unit ID No. P11)- 


e. Flakers (Emission Unit ID Nos. P12 and P13)- 


Further, the above indicated emissions and operating caps were revised, as indicated in the 

existing Title V Permit No. 2493-027-0013-V-02-0 (no amendment issued), as below: 

“The Title V renewal application No. 15084 indicates that, for the existing OSB plant, the 

facility wide PTE for PM is 222.0 tpy. It also states that the Energy System PM PTE is 84.5 tpy 

and a total of about 1.02 tpy PM is emitted from a group of sources which includes the debarker, 

the bark hog, the bark bin, the bark file, truck unloading. I therefore deduce [222.0-(84.5+1.02)] 

that the remaining PM PTE of about 136.48 tpy is emitted by the Fines/Flake Screening 

(Emission Unit ID No. P005), Flake Handling/Blending (Emission Unit ID No. P006), Forming 

(Emission Unit ID No. P007), Sander Line (Emission Unit ID No. P009), and Saw & Trim Line 

(Emission Unit ID No. P010). The Permittee, by their updated renewal application dated Nov 17, 

2005, has excluded Flaker A and Flaker B (earlier assigned Emission Unit ID Nos. P012 and 

P013) from the list of significant sources (Table 3.1). It has been indicated that these flakers have 

insignificant emissions of PM and the facility does not intend to install the flaker baghouse, 

which was earlier proposed to minimize wood dust that could accumulate in the area, for 

housekeeping. The potential PM emission from the flakers was restricted to 3.2 lb/hr or 14.02 

tpy. Therefore, I presume that the remaining PM PTE of 122.46 tpy (136.48-14.02) of PM is 

emitted from the four baghouses that control all the above processes. The Permittee has accepted 

the following limits, as per their renewal application, for the above manufacturing processes, 

each of whose PM emissions are controlled by a dedicated baghouse, to ensure that PM 

emissions stay under the PSD major source threshold of 250 tpy, facility wide. The operating 

emission caps are found in Condition 3.2.2; this is similar to old Condition No. 3.2.6: 

3.2.2 The Permittee shall not discharge or cause the discharge into the atmosphere from the 

following process equipment, any gases that contain Particulate Matter (PM) in excess 

of the indicated rates: 

[PSD Avoidance Limits] 

a. Forming (Emission Unit ID No. P007) and 

Saw & Trim Line (Emission Unit ID No. P010), 

Controlled by Baghouse OG02 (APCD ID No. C003): 12.90 

lb/hr. 

b. Sander Line (Emission Unit ID No. P009), 



Controlled by Sander Line Baghouse (APCD ID No. C006): 10.70 

lb/hr. 

c. Flake Handling/Blending (Emission Unit ID No. P006), 

Controlled by Flaker Handling Baghouse (APCD ID No. C004): 4.29 lb/hr. 

d. Fines/Flake Screening (Emission Unit ID No. P005) and 

Fuel Relay and Storage Silo (Emission Unit ID No. P011), 

Controlled by Fuel Storage Bin Vent Baghouse OG03 

(APCD ID No. C002): 0.54 lb/hr. 

Note that emission rate stated in d. is rounded off to 1.0 lb/hr in the existing permit condition, as 

the PTE will be still less than 250 tpy. 

Applicable Rules and Regulations - 

Rules and Regulations Assessment: 

Rules and Regulations Assessment, as indicated in the existing Title V Permit No. 2493-027- 

0013-V-02-0 (no amendment issued) for Energy System Units A and B (Emission Unit ID Nos. 

P001 and P002) (with language updated), are as below: 

Energy System A and B (Emission Unit ID No. P01 and P02) 

The energy system is a Wellons wood-fired “Detox” combustion system which includes two 160 

MMBtu/hr heat input capacity combustion units (for a combined output of 320 MMBtu/hr). The 

combustion gases supply hot process air to (1) the dryers for flake drying, (2) the thermal oil 

heater to provide thermal oil for the board press and (3) a steam turbine to produce steam for 

electrical power generation. Energy system flue gases are discharged from a single stack (ID # 

S001) after passing through a common dry ESP (APCD ID No. C001), for particulate matter 

removal. 

Since Energy System Units A and B employ indirect heat transfer, they are thus considered to be 

“fuel-burning equipment” according to the Georgia Rules for Air Quality Control. Therefore, 

emissions from these units are subject to Rule (d). 

Being constructed after January 1, 1972, Energy System Units A and B (Emission Unit ID Nos. 

P001 and P002) is subject to the particulate matter limit outlined in Georgia Rule 391-3-1- 

.02(2)(d) for "Fuel Burning Equipment" which contains the following equation: 

Where: 

P = 0.5 (10/R) 0.5 pounds per million BTU heat input; 

P = allowable weight of emissions of fly ash and/or other particulate matter in 

pounds per million BTU heat input 



R = heat input of fuel-burning equipment in million BTU per hour. 

Per Rule (d) the allowable PM emission rate for Energy System Unit A or Energy System Unit B 

can be calculated, for maximum heat input, as follows: 

P = 0.5 (10/160) 0.5 = 0.125 lb/MMBtu 

On an hourly basis: (0.125 lb/MMBtu) (160 MMBtu/hr) = 20.0 lb/hr of PM 

Because the fuel burning equipment is constructed after January 1, 1972, the Energy Systems are 

also subject to Georgia Rule for Air Quality Control 391-3-1-.02(2)(d)3, which limits the opacity 

to 20 percent except for one six-minute period per hour of not more than 27 percent opacity. 

Georgia Rule 391-3-1-.02(2)(g) requires that all fuel burning sources having heat input of 100 

million BTU’s per hour or greater shall not burn a fuel containing more than 3 percent sulfur, by 

weight. The Energy System (Emission Unit ID Nos. P001 and P002) is subject to Rule (g) for 

sulfur dioxide. It burn only wood waste, so the sulfur content will always be much less than 3 

percent; hence no monitoring is needed for sulfur dioxide. 

This Energy System will continue to employ indirect heat transfer and are considered to be “fuelburning 

equipment” according to the Georgia Rules for Air Quality Control. Therefore, PM 

emissions from these units will continue to be subject to state Rule (d). Likewise, the units will 

be subject to NSPS Subpart Db. 

As per 40 CFR Part 60, Subpart Db, these fuel-burning units are defined as steam generating 

units. Each being above 100 MMBtu/hr heat input capacity and constructed after June 19, 1984, 

they are subject to the New Source Performance Standards (NSPS) found in 40 CFR 60, Subpart 

Db-“Standards of Performance for industrial-Commercial Institutional Steam Generating Units”. 

As per the NSPS, the units shall not cause to be discharged any gases that contain PM in excess 

of the following emission limits: 

a. Contain PM in excess of 0.10 lb/MMBtu 

[40 CFR 60.43b(c)][Subsumed by PSD avoidance limit in 3.2.3] 

b. Exhibit equal to or greater than 20 percent opacity (6-minute average), except for one 6minute 

period per hour of not more than 27 percent opacity. The opacity standard shall 

apply at all times except periods of startup, shutdown, and malfunction of the boiler. 

[40 CFR 60.43b(f)] 

The NSPS requires start-up notification, an initial performance test for PM, fuel-usage record 

keeping, and calculation of the annual capacity factor for wood. Because neither Energy System 

Unit A nor B use any fossil fuel, they are not subject to any Subpart Db sulfur dioxide or 

nitrogen oxides limits but are required to calculate capacity factors to prove this status. The 

condition to keep records of wood burned in the combustion units and to calculate the annual 

factor is included in the existing permit as Condition 6.2.9 (renumbered Condition No. 6.2.8). 



The NSPS particulate matter emission standard of 0.10 lb/MMBtu is more stringent than the 

limit of 0.125 lb/MMBtu calculated as per Georgia Rule (d). However, the facility has taken a 

limit of 0.060 lb/MMBtu, which is even more stringent. Therefore, the Energy System is likely 

to be in compliance with Rule (d) while complying with the provisions of the NSPS. 


0013-V-02-0 (no amendment issued) for applicability of CAM, are as below: 

Emission Units P001, P002, P003, P004, P006, and P008 are subject to the provisions of 40 CFR 

Part 64, “Compliance Assurance Monitoring” (CAM) The purpose of CAM is to provide a 

reasonable assurance of compliance with emission limitations and standards for the anticipated 

range of operations at a pollutant-specific emission unit (PSEU) [§64.3(a)]. Applicability of 

CAM for the above indicated emission sources are explained below: 

• They are located at a major source that is required to obtain a Title V Permit. [§64.2(a)] 

• They are subject to emission limitation or standard. [§64.2(a)(1)] 

• They use control device to achieve compliance. [§64.2(a)(2)] 

• Potential pre-controlled emissions of applicable pollutant are at least 100 percent of their 

major source threshold. [§64.2(a)(3)] 

• They are not otherwise exempt. [§64.2(b)] 

The Energy Systems (P001 and P002) are subject to Rule (d), Subpart Db and PSD-avoidance 

limits for PM. An ESP is used to control emissions. The precontrolled allowable PM emission 

rate is 160.2 tpy, which exceeds 100 tons per year threshold. Therefore, CAM is applicable. 

The Dryers (P003 and P004) are subject to emission limits for VOCs and HAPs to avoid being 

subject to PSD. The precontrolled allowable emission rate is above 100 tons per year for VOC 

and 25 tons per year for HAPs. The exhaust is ducted to the energy systems for incineration. 

Therefore, CAM is applicable. 

The Dryer Systems A and B (Emission Units ID Nos. P003 and P004), Fines/Flake Screening 

(Emission Unit ID No. P005), Forming Line (Emission Unit ID No. P007), Board Press 

(Emission Unit ID No. P008), Sander Line (Emission Unit ID No. P009), and Saw & Trim Line 

(Emission Unit ID No. P010) are subject to Rule (e), which contains an emission limit for PM. 

However, their exhaust is uncontrolled. Therefore, CAM is not applicable. 

The applicability of rules and regulations, as indicated in the Title V Permit Amendment No. 

2491-027-0013-V-01-3, are as below: 

“The only change in the applicability of rules and regulation to Energy Systems A and B, with 

this modification, is due to the use of on-site generated waste oil and other waste. Since the 

Energy System is subject to Rule 391-3-1-.02(2)(g), the concentration of sulfur in the oil and 

other material must not exceed 3.0%. It is expected that they will easily comply with this limit, 

since oils used for lubrication (as well as other materials burned) will have very low sulfur 

contents. Note that Rule(g) also applies to wood fuel to be burned in the Energy Systems; that 

was never an issue, since there is very little sulfur present in wood.” 



“The Permittee has requested in their application that they be allowed to obtain up to 2% of total 

heat input by using waste materials as fuel. This is the same as currently allowed by the Division 

at their MDF plant. The application indicates that the waste materials to be combusted will 

consist of the following: used oil which is almost exclusively press hydraulic fluid, and plant 

waste, which will almost exclusively consist of resin tank washout water with a minute VOC 

content. The used oil and plant waste will be sprayed on the wood fuel on the conveyor belt, 

prior to boiler entry. The Permittee has indicated that the amount of used oil to be burned is 

expected no more than 1000 gallons over any given 12 month period. The heat content of used 

oil is close to that of fuel oil (140,000 Btu/gallon) but with almost zero sulfur content. The fuel to 

be combusted is expected to contain some heavy metal, but the contents will be well below the 

parameters specified in 40 CFR 279.11 for burning of used oil.” 

“Under this permit modification, 2491-027-0013-V-01-3, the Permittee is authorized to burn 

various plant and office wastes (non-hazardous) including office paper, used oil, hydraulic fluids 

etc., in the Energy System A and Energy System B) in addition to wood waste. For the purpose 

of this permit, hazardous waste is defined as in 40 CFR Part 261.3.” 

“A consultant for the company clarified the company’s actual intention with regard to this 

request, in conversations with EPD. This was summarized in four points that were e-mailed to 

EPD on December 1, 2003: 

(1) Only on-site generated hydraulic oil from the press will be incinerated. No used oil received 

from off-site, of any kind, will be disposed of in the boilers. 

(2) No more than 1,000 gallons of waste oil will be disposed of per year. 

(3) The amount of other plant waste to be disposed of is not easily predicted, but it will comprise 

almost exclusively resin tank washout water. This water will be sprayed onto the wood chips 

pile, prior to combustion. As best can estimated, the percentage will be less than 0.1%, on an 

annual basis. 

(4) The used press hydraulic oil from the existing plant operations is currently shipped off-site 

for disposal. The contractor that picks up the oil will not dispose of hazardous waste and 

therefore does its own testing to confirm that the press oil is on-spec. If it was off-spec, they 

would have to bring the oil back and then would refuse to make future pickups. The used oil 

from the new press will meet the same non-hazardous waste requirements and Langboard will 

complete quarterly testing prior to incineration to verify this. 

Note that the permit requires an analysis of this used oil (in accordance to specified EPA test 

methods) at least four times per year, to assure that the oil is on-spec.” 

Rules and Regulations Assessment for the Boiler MACT Title V Permit No. 2493-027-0013-V- 

02-0 (no amendment issued) for Energy System Units A and B (Emission Unit ID Nos. P001 and 

P002), are as below: 

“A facility is subject to the Area Source Boilers NESHAP (40 CFR 63 Subpart JJJJJJ –National 

Emission Standards for hazardous Air Pollutants for Industrial, Commercial, and institutional 



boilers Area Sources, if the facility owns or operate an industrial, commercial, or institutional 

boiler as defined in §63.11237 that is located at, or is part of, an area source of hazardous air 

pollutants (HAP). A list of the regulated hazardous air pollutants can be found at 

http://www.epa.gov/ttnatw01/orig189.html. 

In accordance with §63.11237 of this NESHAP, a boiler means an enclosed device using 

controlled flame combustion in which water is heated to recover thermal energy in the form of 

steam or hot water. Controlled flame combustion refers to a steady-state, or near steady-state, 

process wherein fuel and/or oxidizer feed rates are controlled.” 


0013-V-02-0 (no amendment issued) for “Manufacturing Processes,” are as below: 

Manufacturing Processes 

“Georgia Rule (e) “Particulate Emissions from Manufacturing Processes.” limits particulate 

emissions from all manufacturing processes. From new sources (those constructed after July 2, 

1968) with process rates up to 30 tons per hour, it limits emissions according to the rate 

calculated using the formula: E = 4.1P 0.67 ; and with process rates above 30 tons per hour, it 

limits emissions according to the rate calculated using the formula: E = 55P 0.11 - 40; where E 

equals the allowable emission rate in pounds per hour and P equals the process input weight rate 

in tons per hour. The following emission units are subject to these limits: Dryer Systems A and 

B (Emission Units ID Nos. P003 and P004), Fines/Flake Screening (Emission Unit ID No. 

P005), Flake Handling/Blending (Emission Unit ID No. P006), Forming Line (Emission Unit ID 

No. P007), Board Press (Emission Unit ID No. P008), Sander Line (Emission Unit ID No. 

P009), Saw & Trim Line (P010), and Fuel Relay and Storage Silo (P011). [Flakers A and B 

(earlier assigned Emission Unit ID Nos. P012 and P013 in permit amendment) have been moved 

to the insignificant activities list; therefore flaking has been excluded from the new conditions.] 

Condition 3.4.3 subjects these units to Rule (e) which is similar to old Condition 3.4.9.” 

“Georgia Rule (b) “Visible Emissions” limits opacity to 40% and applies to most sources that 

are not subject to another more stringent opacity limit. Processes that are subject to this rule at 

Langboard include Dryer Systems A and B (Emission Units ID Nos. P003 and P004), 

Fines/Flake Screening (Emission Unit ID No. P005), Flake Handling/Blending (Emission Unit 

ID No. P006), Forming Line (Emission Unit ID No. P007), Board Press (Emission Unit ID No. 

P008), Sander Line (P009), Saw & Trim Line (P010), and Fuel Relay and Storage Silo (P011), 

which are also all subject to Rule (e) as indicated above. Condition 3.4.4 subjects these units to 

Rule (b).” 

Rules and Regulations Assessment for the emergency generators, as included by this renewal 

application, are discussed below: 

The renewal application indicates that the facility operates two (2) diesel fired emergency 

generators. One generator is a Cummins DGFA, Model 6CTA8.3 – G2 with a maximum engine 

rating of 201 hp (150 kW), and other unit is a Onan DFM Genset, Model 275 with a maximum 

engine rating of 369 hp (275 kW). Applicability of NSPS and NESHAP rules to these generators 

is as below. 



40 CFR 60, Subpart IIII – “Standards of Performance for Stationary Compression Ignition 

Internal Combustion Engines,” is applicable to stationary compression ignition (CI) internal 

combustion engines that commenced construction after July 11, 2005 and were manufacture after 

April 1, 2006. The renewal application indicates that both engines were installed prior to the July 

11, 2005 applicability date and therefore, both these engines are not subject to this NSPS. 

40 CFR 63, Subpart ZZZZ – “National Emission Standard for Hazardous Air Pollutants for 

Stationary Reciprocating Internal Combustion Engines,” regulates various size stationary internal 

combustion engines, including small engines locates at major and area sources of HAP 

emissions. Under this NESHAP, both engines are considered existing stationary engines and are 

subject to this NESHAP, and therefore, the facility is required to comply with all applicable 

provisions of this NESHAP. The facility is required to operate and maintain the engines 

according to manufacturer’s emission related written instructions, including to change the oil and 

filter every 500 hours of operation or annually and inspect air cleaner every 1,000 hours of 

operation or annually, and inspect hoses and belts every 500 hours of operation or annually. 

Note that the Division has determined that these engines are not significant sources of emissions 

and thus not included in Table 3.0. There are general conditions, which are included in Section 

8.0 (Conditions No. 8.27.1 and 8.27.3) of the latest Title V permit template, to address such 

engines. 

D. Compliance Status 

No noncompliance issue exists per permit application. 

E. Operational Flexibility 

None applicable. 

F. Permit Conditions 

Permit conditions included in this permit renewal, based on the existing Title V Permit No. 

2493-027-0013-V-02-0, are discussed below: 


This condition limits the NOx and CO emissions from the Energy Systems (Emission Unit ID 

Nos. P001 and P002) to 57.05 lb/hr (30 day rolling average) each to ensure that facility wide 

emissions are less than 250 tpy each, for PSD avoidance. This is similar to existing permit 

Condition 3.2.1. [Originally Condition No. 3.2.5 of Title V permit amendment No. 2493-027- 

0013-V-01-2.] 


This condition limits the total emissions of PM from various processes of Fines/Flake Screening 

(Emission Unit ID No. P005), Flake Handling/Blending (Emission Unit ID No. P006), Forming 



line (Emission Unit ID No. P007), Sander Line (P009), Saw & Trim Line (P010), and Fuel Relay 

and Storage Silo (Emission Unit ID No. P011), and other sources, equal to or less than 138.52 

tpy, which ensures that facility wide PM emissions are no more than 222.62 tpy, which is less 

than 250 tpy, including the PM PTE of 84.1 tpy from the Energy System. This is similar to 

existing permit Condition 3.2.2. [Originally old Condition No. 3.2.6 of Title V Permit 

Amendment No. 2493-027-0013-V-01-3.] 


This condition limits the emissions of PM from the Energy System (Emission unit ID Nos. P001 

and P002) to 0.060 lb/MMBtu to ensure that emissions are not more than 84.1 tpy. This is similar 

to existing permit Condition 3.2.3. [Originally old Condition No. 3.2.7 of Title V Permit 

Amendment No. 2493-027-0013-V-01-3.] 


This condition limits visible emissions from the Energy System (Emission unit ID Nos. P001 and 

P002), based on Subpart Db and Georgia Rule (d), to 20% except for one six-minute period per 

hour of not more than 27 %. This is similar to existing permit Condition 3.3.1. [Originally old 

Condition No. 3.3.1 of Title V Permit Amendment No. 2493-027-0013-V-01-2.] 


This condition allows the Permittee to burn plant and office waste (but not hazardous waste) in 

Energy System Units A and B (Emissions Unit ID Nos. P001 and P002), up to 2 percent of total 

fuel heat input. For purposes of this Permit, hazardous waste is defined as in 40 CFR Part 261.3. 

This is similar to existing permit Condition 3.3.2. 

Condition 3.3.2 also limits the total amount of used oil that can be consumed in the Energy 

System to 1000 gallons per twelve consecutive month period. This is similar to old Condition 

No. 3.3.2 of Title V Permit Amendment No. 2493-027-0013-V-01-3. 


This condition provides the specifications to be met for the combustion of used oil (nonhazardous 

only), along with the wood fuel, in the Energy System (Emissions Unit ID Nos. P001 

and P002). This is a requirement of 40 CFR 279.11. This is similar to existing permit Condition 

3.3.3. [Originally old Condition No. 3.3.3 of Title V Permit Amendment No. 2493-027-0013-V- 

01-3.], and updated per vault conditions. Also, it is indicated that used oil cannot be burned 

during periods of startup and shutdown 


This condition limits the emissions of PM from the Energy System (Emission unit ID Nos. P001 

and P002), based on Georgia Rule (d). This is similar to existing permit Condition 3.4.1. 

[Originally Condition No. 3.4.7 of the initial Title V Permit No. 2493-027-0013-V-01-0.] 




This condition limits the sulfur content of fuel fired in the Energy System (Emission unit ID No. 

P001 and P002) based on Georgia Rule (g). This is similar to existing permit Condition 3.4.2. 

[Originally Condition No. 3.4.8 of the initial Title V Permit No. 2493-027-0013-V-01-0.]. 

Conditions No. 3.4.3 and 3.4.4: 

These conditions limit the emissions of PM from Dryer Systems A and B (Emission Units ID 

Nos. P003 and P004), Fines/Flake Screening (Emission Unit ID No. P005), Blending (Emission 

Unit ID No. P006), Forming Line (Emission Unit ID No. P007), Board Press (Emission Unit ID 

No. P008), Sander Line (Emission Unit ID No. P009), Saw & Trim Line (Emission Unit ID No. 

P010), and Fuel Relay and Storage Silo (Emission Unit ID No. P011), based on Georgia Rule (e) 

and visible emissions opacity to 40%, based on Georgia Rule (b). 

This is similar to existing permit Conditions 3.4.3 and 3.4.4. [Originally Conditions No. 3.4.9 

and 3.4.10 of the initial Title V Permit Amendment No. 2493-027-0013-V-01-3.] 

Conditions No. 3.4.5 and 3.4.6: 

These conditions requires that fugitive dust generation be minimized from any process or process 

equipment and other miscellaneous PM emission sources, such as material handling, storage, and 

roads, by adopting reasonable precautions such as the application of water on dirt roads, 

materials and stockpiles. The percent opacity from any fugitive dust source shall not equal or 

exceed 20%. This operational limitation is based on Georgia Rule (n). These are similar to 

existing permit Condition 3.4.5. [Originally Condition No. 3.2.11 of Title V Permit Amendment 

No. 2493-027-0013-V-01-2.]. These are per vault conditions for Rule (n). 


The process emissions from rotary dryers, blending, and board press are routed to the energy 

system for VOC and HAP control by incineration. The significant point source of air emissions 

associated with these is the Energy System stack. Energy system flue gas is discharged from a 

single stack after passing through a common dry ESP for particulate matter removal. Condition 

No. 3.5.1 requires the Permittee to ensure that the process emissions are routed through the 

Energy System; the emissions from the Energy System are vented to the ESP for PM control. 

This is similar to existing permit Condition 3.5.1. [Originally Condition No. 3.5.3 of Title V 

Permit Amendment No. 2493-027-0013-V-01-2.] 


This condition requires that routine maintenance be done on all air pollution control equipment 

and that records be maintained and available for inspection. This condition is based on Georgia 

Rule 391-3-1-.02(2)(a)10. This is similar to existing permit Condition 3.5.2. [Originally 

Condition No. 3.5.4 of Title V Permit Amendment No. 2493-027-0013-V-01-2.] 




There are several baghouses installed by the facility for the control of PM emissions from 

various manufacturing processes. Having an adequate supply of bags on hand for replacements 

of defective bags is required to help assure the control equipment is operating properly. 

Condition No. 3.5.3 requires the Permittee to maintain an inventory of filter bags so that 

defective bags in a baghouse may be replaced when needed. This is similar to existing permit 

Condition 3.5.3. [Old Condition No. 3.5.5 of Title V Permit Amendment No. 2493-027-0013-V- 

01-2.] 


This condition requires the Permittee to operate all control devices (baghouse, ESP, and NOx 

abatement system) when their associated processes are in operation. This is similar to existing 

permit Condition 3.5.4. [Originally Condition No. 3.5.6 of Title V Permit Amendment No. 2493- 

027-0013-V-01-3.] 


This condition requires the Permittee to install capture devices on the board press and the board 

cooling area, which either meet the criteria of Method 204 for permanent enclosure or achieve 

95% capture efficiency. This is same as existing permit condition. 



IV. Testing Requirements (with Associated Record Keeping and Reporting) 

A. General Testing Requirements 

The permit includes a requirement that the Permittee conduct performance testing on any 

specified emission unit when directed by the Division. Additionally, a written notification of any 

performance test(s) is required 30 days (or sixty (60) days for tests required by 40 CFR Part 63) 

prior to the date of the test(s) and a test plan is required to be submitted with the test notification. 

Test methods and procedures for determining compliance with applicable emission limitations 

are listed and test results are required to be submitted to the Division within 60 days of 

completion of the testing. 

B. Specific Testing Requirements 

Testing Requirements included in this renewal permit based on the current Title V Permit No. 

2491-027-0013-V-02-0, which was based on Title V Permit Amendment No. 2491-027-0013-V- 

01-2, No. 2491-027-0013-V-01-3 and No. 2491-027-0013-V-01-3 are described below: 

NOTE: As indicated through various submittals of reports to the SSCP, the facility has already 

conducted all the initial performance tests required by Conditions No. 4.2.1, 4.2.2, 4.2.6, 4.2.8, 

and 4.2.10. Clearly, the Permittee used the initial performance tests to satisfy these conditions, 

subject to Division approval of the test reports. Therefore, the initial testing conditions are 

removed from this renewal permit. 

Energy System (Emission Unit ID Nos. P001 and P002) 

The major pollutant of concern from wood fired combustion systems is particulate matter (PM). 

PM emissions depend primarily on the composition of the wood fuel burned and the particulate 

control device. Oxides of nitrogen (NOx) may also be emitted in significant quantities when 

certain types of wood residue are combusted or under certain operating conditions. Carbon 

monoxide (CO) can be emitted in large amounts under conditions of partial combustion. The 

Energy Systems A and B mainly consume bark (33,230 lbs/hr) as per data provided in Title V 

applications. However, wood residue generated from the various OSB manufacturing processes 

can also be fired in the system. 

The previous Title V applications indicated that PTE PM, NOx and CO is all close to the 250-tpy 

PSD major source threshold. The two Energy System units are each subject to the provisions of 

the NSPS Subpart A general requirements and NSPS Subpart Db boiler rules for PM standards 

and opacity limit, so the Permittee was required to conduct performance tests to demonstrate 

compliance with the NSPS limits. 

Existing Condition 4.2.1 required the Permittee to conduct tests on the Energy System controlled 

by the electrostatic precipitator (ESP) (APCD ID No. C01) after the initial start-up of the system. 

The performance tests were to be used to determine compliance with the particulate matter 

emission limit and to establish a power level for the ESP at which compliance with the PM 

emissions limit is assured. The report of the test results for PM and opacity was also required to 

be submitted. Since the required testing has already been done, this condition is deleted. Note 



that the average total power in the ESP determined by the facility during April 2006 compliance 

test was 33,152 kilowatts (kW). Therefore, any 3-hour period during which the average total 

power in the ESP is less than 24,864 kW (75% of 33,152) is reported as an excursion per 

Condition 6.1.7. The facility has already conducted the initial performance tests required by 

existing Condition No. 4.2.2 for NOx. Therefore, this condition is also deleted. 


Existing Condition 4.2.3, which requires the Permittee to determine compliance for NOx 

emissions following the tests done per Condition 4.2.2, is revised. This is similar to existing 

Condition 4.2.3, and renumbered as Condition No. 4.2.1. 


Existing Condition No. 4.2.4 requires routine tests for PM on a regular basis at 12 or 24 months 

interval depending upon the results. The Permittee has requested, through this renewal 

application No. 20734, to modify this condition as below, because the PM test results for the 

energy systems demonstrated that the emissions from the units have consistently been below 

50% of the applicable PM emission limits. 

4.2.4 Following the initial performance tests, the Permittee shall conduct PM tests on the 

Energy System, at 12-month 24 month intervals. Should the PM emissions for the 

Energy System be fifty (50) percent or less of the emissions limit contained in Condition 

3.2.3, the testing may be conducted at 24 month intervals once per permit term until 

such time that an emissions test indicates an emission rate greater than 50 percent of that 

limit, at which time testing shall revert to 12 month intervals. 

[391-3-1-.02(6)(b)1(i)] 

The latest testing results for PM conducted on April 10, 2012, indicates that the PM emissions 

are 96.7% of the allowable. Thus testing is required to be done at 12-month interval, and it shall 

be 24-months only if emissions are below 50%. 

In view of this, the condition cannot be modified as requested. However, this condition is carried 

over in this renewal with some general language changes as Condition No. 4.2.2. 


Existing Condition 4.2.5, which requires conducting additional tests if fuel material is changed, 

is carried over in this renewal as Condition No. 4.2.3. 


The facility has already conducted the initial performance tests for emissions of CO, as required 

by Condition No. 4.2.6. Therefore, this condition is deleted. Existing Condition 4.2.7, which 

requires the Permittee to determine compliance for CO emissions following the tests done per 

existing Condition 4.2.6, is revised and renumbered as Condition No. 4.2.4. 



Manufacturing Processes (Emission Unit ID Nos. P003, P004, P006, and P008) for VOC and 

HAPs Control 

The narrative for the existing permit indicates that the process emissions from Rotary Flake 

Dryers A and B (Emission Units ID No. P03 and P04), Blending (Emission Unit ID No. P06), 

and Board Press (Emission Unit ID No. P08) which include VOC and HAPs, in addition to PM 

emissions, are routed through the Energy System for control via incineration. Since the dry ESP 

controls the emissions from the Energy System, PM emissions from the above-indicated 

processes are controlled via the ESP. Therefore the Permittee was required to conduct initial 

performance tests for the HAPs (acetaldehyde, acrolein, formaldehyde, methanol, phenol, and 

propionaldehyde) emissions at the outlet of the Energy System, per Condition 4.2.8, in addition 

to tests for PM emissions as required by Condition 4.2.1. The performance tests were required to 

be conducted after startup of the plant. Condition 4.2.9 required the Permittee to thereafter 

conduct performance tests at approximately 24- month interval to establish total HAPs emission 

factors. 

Since the initial performance tests for emissions of individual and total HAPs, per existing 

Condition 4.2.8, is already done, therefore, this condition is deleted. 


Existing Condition No. 4.2.9 requires the Permittee to conduct HAPs emission tests at least once 

in 24-month to demonstrate compliance. The Permittee has requested, through this renewal 

application No. 20734, to modify this condition as below, because the HAPs emissions are well 

below the major source threshold of 10/25 tpy. Note that this condition assures to regulate HAPs 

emissions. The facility is currently demonstrating compliance by using the emission factors from 

the April 2010 tests. 

4.2.9 The Permittee shall conduct performance tests at least once per 24 months permit term 

in order to assure that the HAPs, including acetaldehyde, acrolein, formaldehyde, 

methanol, phenol, and propionaldehyde, emission factors established, per Condition 

4.2.8, remain accurate. 

[391-3-1-.02(2)(a)3 and 391-3-1-.02(6)(b)] 

As indicated in this renewal application, since the HAPs emission tests conducted during 2005 to 

2010 indicates that the emissions are much below the prescribed threshold, the requests can be 

considered. Note that the review conducted by the Division, of the test results done on dated 

April 7, 2010, indicates that the individual and total HAPs are much lower than the threshold 

limits. Therefore, EPD has determined that the testing requirement be changed from once in 24months 

to more flexible testing of once in 48 months. This condition is revised as below, and 

renumbered as Condition No. 4.2.5. 

4.2.5 The Permittee shall conduct performance tests at the outlet of the Energy System 

(Emission Unit ID Nos. P001 and P002) to determine individual and total HAP, 

including acetaldehyde, acrolein, formaldehyde, methanol, phenol, and propionaldehyde 

emissions, while the process emissions from Dryer Systems A and B (Emission Unit ID 

Nos. P003 and P004), Blending (Emission Unit ID No. P006) and Board Press 



(Emission Unit ID No. P008), are vented to the Energy System (Emission Unit ID Nos. 

P001 and P002). at least once per 48 months in order to assure that the HAPs, including 

acetaldehyde, acrolein, formaldehyde, methanol, phenol, and propionaldehyde, 

emission factors established during each performance tests remain accurate. 

[391-3-1-.02(2)(a)3 and 391-3-1-.02(6)(b)] 

The facility has already conducted the performance tests as required by Conditions 4.2.10 and 

4.2.11 for PM emissions from various baghouses. Therefore, these conditions are no longer 

needed and hence deleted. 


Existing Condition 4.2.12, which requires the Permittee to conduct testing once in 24-moths to 

re-determine the enclosure capture efficiency determined and approved by the Division, is 

carried over from the existing permit as Condition No. 4.2.6. Note that this testing is not required 

if the capture device meets the criteria of Method 204 for permanent enclosure. 

Manufacturing Processes (Emission Unit ID Nos. P005 through P0011) for PM Control 

The narrative for the existing permit indicates that the process emissions, which mainly contain 

PM from emission units of Fines/Flake Screening (Emission Unit ID No. P005), Forming Line 

(Emission Unit ID No. P007), Sander Line (Emission Unit ID No. P009), Saw & Trim Line 

(Emission Unit ID No. P010), and the Fuel Relay and Storage Silo (Emission Unit ID No. P011), 

are controlled by dedicated baghouses, APCD ID Nos. C002, C003, C004, C006. Each of these 

processes is subject to a PM limit specified in Condition 3.2.2. To ensure that PM emissions 

from these processes, vented through a baghouse, are not more than their PM limits, performance 

tests were required to be conducted within 180 days after the initial startup of the plant, per 

Condition 4.2.10. During these tests, the Permittee was required to acquire data of the pressure 

drop across each baghouse to establish ranges for the proper functioning of each baghouse which 

will assure continuous compliance with the PM emissions limits for each process (Condition 

4.2.11). 


Existing Condition 4.2.13, which defines an operating day as a 24-hour period between 12:00 

midnight and the following midnight, is carried over as Condition No. 4.2.7. 

Existing Condition 4.2.14 required the Permittee to submit a report containing the results of the 

performance testing required by existing Condition 4.2.1, as well as the secondary voltages and 

secondary currents recorded during the testing, and the average power level of the ESP at which 

compliance with the PM emissions limitation is achieved. This condition is deleted as 

compliance is done. 


Existing Condition 4.2.15 required the Permittee to measure and records the combustion zone 

temperatures for each Energy System. These measurements are then be used to establish the 



minimum temperature at which the Energy System must operate to demonstrate compliance with 

the HAP emission limits of existing Condition 2.1.2. The Permittee has complied with this 

condition. As per records, average combustion temperature for Energy System P001 and P002 is 

1,470°F and 1,467 °F, respectively. However, Permittee is required to measure and record 

combustion zone temperature during each performance test done per Condition No. 4.2.5; 

therefore, this Condition is revised accordingly and included in permit renewal as Condition No. 

4.2.8. 

Existing Condition 4.2.16 and 4.2.17, which required conducting tests for NOx and CO, 

respectively by March 1, 2007, are deleted since compliance is done. 



V. Monitoring Requirements 

A. General Monitoring Requirements 

Condition 5.1.1 requires that all continuous monitoring systems required by the Division be 

operated continuously except during monitoring system breakdowns and repairs. Monitoring 

system response during quality assurance activities is required to be measured and recorded. 

Maintenance or repair is required to be conducted in an expeditious manner. 

B. Specific Monitoring Requirements 

Specific monitoring requirements included in this permit based on current Title V Permit No. 

2491-027-0013-V-02-0, which was based on Title V Permit Amendment Nos. 2491-027-0013- 

V-01-2 and 2491-027-0013-V-01-3, are discussed below: 

Energy System (Emission Unit ID Nos. P001 and P002) 


The narrative for the existing permit (No. 2491-027-0013-V-02-0) indicates that the proper 

operation of the Energy System will help assure that the PM, Visible Emissions (opacity), NOx, 

and CO emissions limitations for the Energy System will not be exceeded. Also, Condition 5.2.1 

requires the installation of a Continuous Emissions Rate Monitoring System (CERMS) for 

measuring and recording NOx and CO concentration and COMS for measuring visible 

emissions. This condition has been carried over from existing permit, Condition 5.2.1. (This is 

similar to Condition 5.2.7 of the Permit Amendment No. 2493-027-0013-V-01-2.) 


The narrative for the existing permit also indicates that the PSD review of this facility concluded 

that proper operation of the Energy System could be assured by monitoring the combustion zone 

temperatures. This will provide reasonable assurance that the emissions limitations for HAPs are 

not exceeded. Condition 5.2.2a requires the Permittee to install combustion zone temperature 

monitors for each of the Energy Systems. The exceedances and excursions, as defined in 

Condition 6.1.7, are required to be reported by the Permittee. This condition has been carried 

over from the existing permit and is similar to existing Condition 5.2.2. 

The proper operation of the ESP will provide reasonable assurance that the applicable PM and 

Visible Emissions (opacity) limitations for the Energy System will not be exceeded. EPD 

believes that the total power level of an ESP is the single most useful operating parameter related 

to ESP performance. By maintaining an adequate level of power, emissions are assured to be 

controlled to below the applicable PM limit. 

Condition 5.2.2b requires the installation of monitoring devices for measuring both secondary 

voltage and secondary current (amperage); readings of these monitors must be made 

continuously. The facility will need a data logger to record the information automatically. The 

secondary voltages and currents must then be used to calculate the total ESP power level. 



Records of the total power determined, as per condition No. 5.2.8, must be kept as hard copy or 

in an electronic format. The calculations of total power must be made according to the equation 

in Condition 5.2.8 of the existing permit. An excursion is defined, in Condition 6.1.7, as each 

three-hour total power average for the electrostatic precipitator (APCD ID No. C001), as 

determined in accordance with Condition 4.2.1, that is less than 75 percent of the value 

determined and reported in accordance with Conditions 4.2.1 and 4.2.14 of the renewal permit. 

This Condition 5.2.2 have been carried over from existing permit, and is same as Condition No. 

5.2.2. 

The Energy System (Emission Unit ID Nos. P001 and P002) is subject to Georgia Rule (g) for 

Sulfur Dioxide. Waste wood consistently has sulfur content much lower than the Rule (g) limit 

of 3.0 percent (Condition No. 3.2.2). Since Rule (g) is not likely to be violated by the Permittee, 

there is no need to monitor the sulfur content of these fuels. Thus, neither such monitoring 

condition had been included in the current permit nor is being included in this renewal permit. 

Manufacturing Processes (Emission Unit ID Nos. P003 through P0011) 

As indicated in the narrative for Title V Permit No. 2493-027-0013-V-02-0, the manufacturing 

process emission sources of Fines/Flake Screening (Emission Unit ID No. P005), Forming line 

(Emission Unit ID No. P007), Sander Line (Emission Unit ID No. P009), Saw & Trim Line 

(Emission Unit ID No. P010), and Fuel Relay and Storage Silo (Emission Unit ID No. P011) are 

all subject to Georgia Rule (b) for visible emissions and Rule (e) for particulate matter (PM) and are 

subject to the monitoring requirements of Conditions 5.2.3 and 5.2.5. The PM emissions from 

each of these emission units are controlled by a dedicated baghouse (APCD ID Nos. C002, C003, 

C004, and C006). To reasonably assure compliance with applicable PM limitations, a Visible 

Emissions (VE) check is required each day of operation of the emissions units controlled by the 

baghouses. Corrective actions are required for the presence of visible emissions. In addition, a 

Preventive Maintenance Program is required on these baghouses. The program requires the 

weekly monitoring of baghouse pressure drop and the weekly performance of operation and 

maintenance checks on the baghouses. Any malfunctions discovered in the functioning of a 

baghouse must be corrected in an expedient manner and any adverse condition(s) discovered by 

weekly inspections are required to be reported. 


Condition 5.2.4 requires the Permittee to conduct weekly inspections of the baghouses to 

determine if any is malfunctioning and to make repairs in an expedient manner. This is carried 

over from the existing permit. Note that this is similar to Condition No. 5.2.10 of Title V permit 

amendment No. 2493-027-0013-V-01-3. Condition 6.1.7c. ii requires malfunctions must be 

reported quarterly as excursions. This is same as existing permit Condition 5.2.4. 


This condition requires the Permittee to check the visible emissions (VE) of each specified 

baghouse daily. This is similar to Condition No. 5.2.11 of Title V permit amendment No. 2493- 

027-0013-V-01-3. Condition 6.1.7c.iii. requires the reporting of two consecutive determinations 



of VE from a baghouse. This condition is updated per current vault conditions and is similar to 

existing permit Condition 5.2.5. 

New Condition No. 5.2.6: 

This new condition requires the Permittee to submit current version of maintenance program for 

the baghouses. This condition is included per standard vault. This condition is used when CAM 

is applicable to obtain indicator ranges required by the 40 CFR 64 that are indicative of proper 

baghouse maintenance. 


This condition requires the Permittee to implement an approved preventive maintenance program 

for each baghouse. This condition is revised and updated per current vault and is similar to 

existing Condition 5.2.6. Note that now this conditions requires the Permittee to implement the 

approved plan in place to develop and implement. 


This condition requires the Permittee to determine all 12-hour block averages of combustion 

zone temperatures for each Energy System. This is similar to Condition No. 5.2.13 of a Title V 

permit amendment. Condition 6.1.7c.iv. requires reporting of any 12-hour block average 

combustion zone temperature, for Energy System Units A or B, which is less than the 

temperature established according to Condition 4.2.15. This is same as existing permit Condition 

5.2.7. 


This condition requires the Permittee to determine and record the total ESP power for each hour 

of operation, using the data required to be collected by Condition 5.2.2. The equation to be used 

to calculate the ESP power is included in the condition. This is similar to Condition No. 5.2.14 of 

Title V permit amendment No. 2493-027-0013-V-01-2. Condition 6.1.7c.v. requires reporting of 

each three-hour period during which the average total power for the ESP (APCD ID No. C001), 

determined as per Conditions 5.2.2 and 5.2.8, is less than 75% of the value determined and 

reported in accordance with Conditions 4.2.1 and 4.2.14. Each clock hour begins a new threehour 

period. This is same as existing permit Condition 5.2.8. 


This is an updated condition and includes test methods for analysis of on-site generated used oil, 

and is similar to existing permit Condition 5.2.9. 

C. Compliance Assurance Monitoring (CAM) 

Applicability of Rules and Regulations related to CAM, per narrative for the existing Title V 

Permit No. 2493-027-0013-V-02-0, indicates that Emission Units P001, P002, P003, and P004 

are subject to the CAM rule. The facility attached an electronic CAM plan to their previous 



electronic Title V renewal application (No. 15084). The facility proposed to monitor pressure 

drop to ensure continuous compliance with Georgia Air Quality Rule (e). EPD agreed with the 

terms specified in their CAM plan and included them in the performance criteria for the ESP 

(APCD ID No. C001) in the existing Conditions 5.2.11 and 5.2.12 of the renewal Permit No. 

2493-027-0013-V-02-0 (current permit). In addition, EPD added visible emission checks as the 

main CAM indicator. Condition 5.2.10 states that Emission Units P001, P002, P003, P004, P006, 

and P008 are subject to the CAM rule, and the regulated pollutants are particulate matter 

(PM/PM10), VOC and HAP. 

The facility has four baghouses that are used for product recovery/transport and operate as an 

inherent part of the OSB production process, as indicated earlier in the previous renewal 

application and consultant’s email of February 10, 2006. These devices either serve to transport 

the raw materials from one OSB process to the next, or recover material for reuse in the fuel 

handling process. As such, these four baghouses are not control devices, in accordance with 40 

CFR 64.1. Per this rule, a control device means equipment, other than inherent process 

equipment, that is used to destroy or remove air pollutant(s) prior to discharge to the 

atmosphere." However, EPD disagrees with the Permittee that all the four baghouses are used for 

product recovery/transport and operate as an inherent part of the OSB production process. EPD 

is of the view that Fuel Storage Bin Vent (C002) and Dry Bin (C004) baghouses primarily 

operates as air pollution control equipment, although the collected material is reused or falls back 

into the storage bins. The performance test done for PM emissions from these baghouses 

indicated that precontrol PTE is 14.45 and 132.7 tpy respectively, assuming 99% PM control 

efficiency. Therefore, Emission Unit P006, controlled by baghouse C004 for PM, is only subject 

to CAM. 

Conditions 5.2.11, 5.2.12, 5.2.13 and 5.2.14 

These conditions related to CAM requirements, are carried over from the existing permit. These 

conditions are same as existing Conditions 5.2.10, 5.2.11, 5.2.12 and 5.2.13. 


This condition requires the Permittee to conduct daily checks that natural draft openings are 

maintained as specified in the testing for capture efficiency required by Condition 4.2.6. This 

condition also requires correction of any adverse condition discovered in this check in the most 

expedient manner possible. Condition 6.1.7.c.vi requires reporting of any two consecutive 

determination made according to this condition in which natural draft openings were determined 

to not have been maintained as required. This is similar to existing permit Condition 5.2.14. 



VI. Record Keeping and Reporting Requirements 

A. General Record Keeping and Reporting Requirements 

The Permit contains general requirements for the maintenance of all records for a period of five 

years following the date of entry and requires the prompt reporting of all information related to 

deviations from the applicable requirements. Records, including identification of any excess 

emissions, exceedances, or excursions from the applicable monitoring triggers, the cause of such 

occurrence, and the corrective action taken, are required to be kept by the Permittee and 

reporting is required on a [quarterly or semiannual] basis. 

Template Conditions 6.1.3 and 6.1.4 were updated in September 2011 to allow ~60 days to 

submit periodic reports. Alternative reporting deadlines are allowed per 40 CFR 70.6, 40 CFR 

60.19(f) and 40 CFR 63.10(a). 

B. Specific Record Keeping and Reporting Requirements 

The Record Keeping and Reporting Requirements carried over from the current Title V Permit 

No. 2493-027-0013-V-02-0 (and no current amendment) are described below: 


Condition 6.1.7, which requires the Permittee to report specified exceedances, excursions, is 

similar to the existing permit condition. Condition 6.1.7b requires reporting specified 

exceedances. Condition 6.1.7b.iii (as per Condition 3.3.2) define, as an exceedance, any time that 

the total amount of heat input, from fuel oil, office waste, and plant waste, calculated in 

accordance with Condition 6.2.8, exceeded 2 percent of the total heat input to the Energy 

System, on a monthly basis. Condition 6.1.7b.iv (as per Condition 3.3.2) to define, as an 

exceedance, any time that the waste oil burned in the Energy System exceeded 1000 gallons. 

Conditions 6.1.7v. and vi. requires reporting exceedances for HAPs emissions. 

Condition No. 6.1.7c requires the Permittee to report excursions. Condition 6.1.7d.i requires that 

semi-annual reports shall include any test results for the used oil to show compliance with 

Condition 3.3.3. Condition 6.1.7d.ii is to require record keeping for waste materials burned in the 

Energy Systems, as allowed by Condition 3.3.2. 

Note that the request of the Permittee to reduce the frequency of compliance report submittal 

from quarterly to semi-annually is not accepted as the facility is subjected to NSPS; quarterly 

reports are the requirements. 


Condition 6.2.1 requires the Permittee to maintain specified records of required data for each 

unit-operating day for the Energy System (Emission Units ID Nos. P001 and P002). This 

condition is carried over from the existing permit, and is same as Condition 6.2.1. 




Condition No. 6.2.2 requires the Permittee to maintain records of the production rates of the 

board press. This condition is carried over from the existing permit, and is same as Condition 

6.2.2. . 


Condition No. 6.2.3 requires the Permittee to maintain records of routine maintenance performed 

on all APCDs. This condition is carried over from the existing permit, and is same as Condition 

6.2.3. 


Condition No. 6.2.4 requires the Permittee to maintain records of the date, time and duration 

when the emissions from the manufacturing units of flake dryers, board press and blending 

process are not vented to the energy system for control. This condition is carried over from the 

existing permit, and is same as Condition 6.2.4. 


Condition No. 6.2.5, which required the Permittee to submit notification regarding completion of 

emission units, is deleted as it no longer needed. 

Existing Condition No. 6.2.6, which provides a detailed procedure for calculating total monthly 

emissions of HAPs. It also requires the Permittee to report if individual or total HAP emissions 

exceed 1/12 the annual limit. This condition is revised to indicate that the emissions shall be 

calculated using the emission factors determined during the initial performance tests. This is 

similar to existing permit Condition 6.2.6 and renumbered. 


Condition No. 6.2.6, which requires the Permittee to calculate 12-month rolling totals for 

individual and total HAPs emissions and to include this information in the quarterly reports 

specified in Condition 6.1.4, is carried over from the existing permit and is same as Condition 

6.2.7 and renumbered. 


Condition No. 6.2.7, which requires the Permittee to maintain records of the fuel combusted in 

the Energy System and to calculate the percentage of waste fuel Btu input to the Energy System, 

is carried over from the existing permit, and is same as Condition 6.2.8 and renumbered. 


Condition No. 6.2.8, which requires the Permittee to calculate the annual capacity factors from 

the records of the fuel combusted in the Energy System maintained per Condition 6.2.8, is 

carried over from the existing Title V permit, and is same as Condition 6.2.9 and renumbered. 




To assure that fugitive dust rules are being complied with, Condition 6.2.9, which requires the 

Permittee to maintain a record of all actions taken to suppress fugitive dust from various sources 

to help assure compliance with Rule (n), is carried over from the existing Title V permit, and is 

same as Condition 6.2.10 and renumbered. 

VII. Specific Requirements 

A. Operational Flexibility 

The applicant did not include any alternative operating scenarios in their Title V permit 

application or SIP application. Special operational flexibility has therefore not been incorporated 

into this Title V permit. 

However, this Title V permit allows the operational flexibility that is generally afforded to 

sawmills and other wood processing plants. For example, they have the flexibility such that (1) 

different species soft wood and hard wood can be used to manufacture OSB, (2) different species 

of wood flakes can be dried in the Dryer System A and B, and (3) the facility can produce OSB 

in various thicknesses and dimensions. This is carried over from the existing permit (and 

previous permit amendment No. 2493-027-0013-V-01-2.) 

B. Alternative Requirements 


C. Insignificant Activities 

Refer to http://airpermit.dnr.state.ga.us/GATV/default.asp for the Online Title V Application. 

Refer to the following forms in the Title V permit application: 

• Form D.1 (Insignificant Activities Checklist) 

• Form D.2 (Generic Emissions Groups) 

• Form D.3 (Generic Fuel Burning Equipment) 

• Form D.6 (Insignificant Activities Based on Emission Levels of the Title V permit 

application) 

D. Temporary Sources 


E. Short-Term Activities 


F. Compliance Schedule/Progress Reports 




G. Emissions Trading 


H. Acid Rain Requirements 


I. Stratospheric Ozone Protection Requirements 

The standard permit condition pursuant to 40 CFR 82 Subpart F has been included in the Title V 

Permit. These Title VI requirements apply to all air conditioning and refrigeration. 

J. Pollution Prevention 


K. Specific Conditions 


VIII. General Provisions 

Generic provisions have been included in this permit to address the requirements in 40 CFR Part 70 that 

apply to all Title V sources, and the requirements in Chapter 391-3-1 of the Georgia Rules for Air 

Quality Control that apply to all stationary sources of air pollution. 

Template Condition 8.14.1 was updated in September 2011 to change the default submittal deadline for 

Annual Compliance Certifications to February 28. 

The following Conditions, No. 8.27 through 8.28, are added to the permit, as per requirements of U.S. 

EPA. These are in the latest Title V Permit template, and were not there in the existing Title V permit. 

1) Condition No. 8.27 for “Internal Combustion Engines”, for the requirements of 40 CFR 60 

Subpart A - "General Provisions", Subpart IIII and Subpart JJJJ, and 40 CFR 63 Subpart A and Subpart 

ZZZZ, and 

2) Condition No. 8.28 for “Boilers and Process Heaters” for the requirements of 40 CFR 63 Subpart 

A, Subpart JJJJJJ and Subpart DDDDD.

Langboard OSB, Quitman City - Georgia Air Protection Branch

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