NSR/PSD/GHGPSD Amendment Application

NSR/PSD/GHGPSD Permit

Amendment Application

Corrigan OSB, L.L.C.

Corrigan OSB

Corrigan, Polk County, Texas

March 2020

Prepared by:

8591 United Plaza Blvd Suite 300

Baton Rouge, LA 70809 225‐755‐1000

CK Project Number: 17466

NSR/PSD/GHGPSD Permit Amendment Application Corrigan OSB, L.L.C. – Corrigan OSB

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TABLE OF CONTENTS

1.0 INTRODUCTION ............................................................................................................ 4

1.1 Project Description ................................................................................................ 5

1.2 Process Description ............................................................................................... 6

1.3 Air Emissions ......................................................................................................... 8

1.4 Total Facility Emissions ........................................................................................ 10

2.0 REGULATORY APPLICABILITY ...................................................................................... 10

2.1 TCEQ Applicable Regulations ............................................................................... 10

2.2 New Source Performance Standards (NSPS) ........................................................ 18

2.3 National Emission Standards for Hazardous Air Pollutants (NESHAP) ................. 19

2.4 Compliance Assurance Monitoring (CAM) ........................................................... 19

2.5 Chemical Accident Prevention Regulation (40 CFR 68) ........................................ 20

2.6 Stratospheric Ozone Protection (40 CFR 82) ....................................................... 20

3.0 PREVENTION OF SIGNIFICANT DETERIORATION REVIEW ............................................ 21

3.1 Introduction ......................................................................................................... 21

3.2 Best Available Control Technology (BACT) Analysis ............................................. 22

3.3 BACT Methodology .............................................................................................. 22

3.4 BACT Analysis for Rotary Dryers .......................................................................... 24

3.4.1 Control Technologies ............................................................................ 24

3.4.2 Technically Infeasible Options .............................................................. 25

3.4.3 Top Down Evaluation of Control Options.............................................. 25

3.5 BACT Analysis for OSB Press ................................................................................ 26

3.5.1 Control Technologies ............................................................................ 27

3.5.2 Technically Infeasible Options .............................................................. 27

3.5.3 Top Down Evaluation of Control Options.............................................. 28

3.5.4 Selection of BACT for OSB Press ........................................................... 28

3.6 BACT Analysis for Thermal Oil Heater and Standby Burners ................................ 29

3.6.1 Potential Control Technologies ............................................................. 29


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3.6.2 BACT Selection ...................................................................................... 29

3.7 BACT Analysis for Emergency Internal Combustion Engines................................ 30

3.7.1 BACT for Particulate Matter (PM10/2.5) .................................................. 30

3.8 Pneumatic, Aspiration, and High Pressure Systems ............................................. 31

3.9 Edge Seal Painting and Stencil Painting ............................................................... 32

3.10 Fugitive Dust from Paved and Unpaved Roads .................................................... 32

4.0 NSR TCEQ FORMS AND ATTACHMENTS ...................................................................... 35

Table 1(a) Emission Point Summary

Table 2 Material Balance

Table 1F Air Quality Application Supplement

Table 2F Project Emission Increase

Table 3F Project Contemporaneous Changes

Table 11 Fabric Filters

TCEQ NSR Workbook

LIST OF TABLES

Table 1‐1 Emission Source List

Table 1‐2 Total Facility‐Wide Emissions Summary

Table 3‐1 PSD Threshold Emissions Summary

Table 3‐2 Source Characterization

Table 3‐3 Potential Control Technologies PM10/PM2.5

Table 3‐4 Control Technology Options for Emissions from Combustion


Table 3‐6 Potential Control Technologies

Table 3‐7 Control Technology Options for Emissions from the OSB Press

Table 3‐8 Control Technology Options for Emissions from the Thermal Oil Heater and

Standby Burners

Table 3‐9 Control Technology Options for Emergency Internal Combustion Engines


Table 3‐11 PM10/PM2.5 Control Technology Options

Table 3‐12 Proposed BACT Emission Limits

Table 3‐13 Control Technology Options for PM10/PM2.5 Emissions from Paved and Unpaved

Roads



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LIST OF FIGURES

Figure 1 Site Location Map

Figure 2 Plot Plan

Figure 3 Process Flow Diagram

LIST OF APPENDICES

Appendix A Enforcement Action Agency Correspondence

Appendix B Modeling Protocol

Appendix C Emission Calculations and Supporting Documentation

Appendix D BACT Analysis Supporting Documentation


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1.0 INTRODUCTION

Corrigan OSB, L.L.C. (Corrigan OSB) own and operates an oriented strand board (OSB) facility

located in Corrigan, Polk County, Texas. A Site Location Map is included as Figure 1. The facility

was permitted as a new facility under New Source Review (NSR) Permit #128854, PSDTX1446,

GHGPSDTX128 issued October 23, 2015 and Title V Standard Operating Permit (SOP) Permit

#O3779 issued December 4, 2017. The facility began operation in February 2018. Corrigan is

registered under Texas Commission on Environmental Quality (TCEQ) Customer Reference

Number CN604724831.

Following a review of the initial stack test results, Corrigan conducted an internal review of

emissions from the three Regenerative Thermal Oxidizers (RTO‐01, RTO‐02, and RTO‐03) and

the basis of the emission calculations. Results of this audit revealed that revisions to the

current permitted emission rates and calculations were necessary to best represent the

emissions from these sources that is reflective of the facility’s original designed maximum

production capacity and operations. Appendix A provides relevant TCEQ correspondence.

Corrigan OSB is submitting a reconciliation to the current Prevention of Significant

Deterioration (PSD) permit reflective of intended operations at the facility. This PSD application

does not represent a physical change or change of method of operation. Rather, it is a

“retroactive” PSD application to establish operating parameters originally intended based on

design of the facility. These revisions necessary to reflect the intended operations will result in

an increase from the current annual permitted rates for PM10 and PM2.5, and an increase in

maximum hourly emission rates for NO2 and CO. However, annual NO2 and CO emission rates

will show a decrease in potential‐to‐emit (PTE).

Unrelated to the PSD reconciliation, Corrigan OSB is proposing to install a new emission source

which will be referenced as Sand & Tongue and Groove Aspiration System Stack (EPN PS‐10).

With this submittal, Corrigan OSB is submitting an updated application for NSR/Title V

(Abbreviated)/Prevention of Significant Deterioration (PSD)/Greenhouse Gas PSD (Voluntary

Update) application with the proposed modification as stated in the Project Description section

of this application. In addition, the Air Quality Analysis (AQA) that was approved by TCEQ in

conjunction with issuance of PSD permit PSDTX1446 is being updated for emissions of

PM10/PM2.5, NO2 (1‐hour standard) and CO. A protocol was submitted to TCEQ on February 13,

2020. An updated protocol is included as Appendix B.


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Section 2.0 of this application contains a regulatory applicability analysis for the facility.

Federally applicable requirements as well as state regulations affecting the emission sources

are identified. Section 3.0 of the application contains the PSD review including a Best Available

Control Technology (BACT) Analysis. The required TCEQ permit application forms are provided

in Section 4.0. Appendix C contains the Emission Calculations for the emission sources and

Appendix D provides the supporting documentation for the BACT analysis performed as part of

the PSD permit application.

1.1 Project Description

As discussed in Section 1.0, this submittal is a reconciliation to the current PSD permit

reflective of the intended operations at the facility. This PSD application does not represent

a physical change or change of method of operations of any existing sources.

As a result, the following modifications are being proposed as a part of this project:

Following a review of the initial stack test results and current/anticipated production

rates, Corrigan OSB proposes to reconcile emissions of criteria pollutants, HAP and GHG

emissions from RTO‐01 (EPN RTO1 Stack ‐Dryer 1, Venturi Scrubber 1, and WESP 1),

RTO‐02 (EPN RTO2 Stack ‐ Dryer 2, Venturi Scrubber 2, and WESP 2), and RTO‐03 (EPN

RTO3 Stack – OSB Press).

Reconciliation of emissions from Dryer Bypass MSS activities based on the

current/anticipated production rates (EPN MSS‐3).

Reconcile emissions of NOX from Standby Thermal Oil Heater based on stack test data

resulting in decrease in emissions (EPN TO‐2).

Reconcile emissions of HAP’s from Standby Thermal Oil Heater resulting in decrease in

total HAP emissions as an incorrect conversion factor to convert from lb/106 to

lb/MMBTU (1020 lb/MMBTU) was used for estimation of HAP emissions (EPN TO‐2).

Request a change in Condition #13 of the operation limitation, work practices and plant

design section of the NSR permit; Condition #13 limits the operational hours of the

Standby Thermal Oil Heater to 500 hours per year; Corrigan is requesting the

operational limit be changed to 720 hours per year to reflect the emissions calculations

submitted in the initial application (EPN TO‐2); this update will not result in any change

and/or increase in emissions.


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Request a change in Condition #16 of the operation limitation, work practices and plant

design section of the NSR permit; Condition #16 limits the operational hours of the

Standby Burner No.1 and 2 to 500 hours per year; Corrigan is requesting the operational

limit be changed to 720 hours per year to reflect the emissions calculations submitted in

the initial application (EPN SB‐1 and SB‐2); this update will not result in change and/or

increase in emissions.

Addition of a new emission source which will be referenced as Sand & Tongue and

Groove Aspiration System Stack (EPN PS‐10).

All other existing emissions sources will continue to operate as currently permitted. No

modification or changes in emissions are being proposed for such sources in this submittal.

The emission increase of particulate matter exceeds the pollutant specific PSD major source

modification significant emission rate as per 40 CFR 51.166(b)(23) and 30 TAC 116.164(a)(2).

All other criteria pollutants including HAP’s and GHG emissions will not result in any net

emissions increases exceeding the PSD signification emission rate. PSD netting and impact

analysis for PM10/PM2.5/PM emissions is required and included in this submittal.

1.2 Process Description

Corrigan OSB is designed to produce 900 MSF 3/8 in/year of OSB. The emission sources are

shown in Figure 2, Plot Plan and the process which is described below is presented in Figure

3, Process Flow Diagram.

Green pine logs are trucked into the facility daily. The logs are processed through two

debarkers, which consists of enclosed drums (which are not emission sources) and routed

to the stranders to produce wafer strands. Particulate emissions from the strander are

controlled by a baghouse (PS‐05). Green strands are routed enclosed bins in the wet flake

storage area. The wafers are sent to one of two rotary dryers (RD‐1 and RD‐2), where

moisture in the wafers is reduced from approximately 40‐45% to 3%. Hot air is provided to

the dryers by two wood –fired furnaces (F‐1 and F‐2). Dry wafers and conveying air are

discharged to primary cyclones where the dry strands are separated from the air flow. The

conveying air from the dryers are discharged through an air pollution control system

consisting of venturi scrubbers (VS‐1 and VS‐2), wet electrostatic precipitators (WESP‐1 and

WESP‐2) and regenerative thermal oxidizers (RTO‐1 and RTO‐2). The RTO abort ports

(RTO(ABORT)‐1 and RTO(ABORT)‐2) are used only during emergency situations and when

dryers are shutdown.


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Dry wafers are screened and then routed to the dry flake storage bins. Particulate

emissions from the screening and dry flake storage are controlled by a baghouse (PS‐07).

Dry wafers are discharged from the dry storage bins onto a Thayer scale where the strands

are precisely weighed to determine the proper resin ratio. The wafers and resin are mixed

in rotary blenders. Particulate emissions from the rotary blenders are controlled by a

baghouse (PS‐09). From the blenders the coated strands are oriented in layers on mats

before proceeding to the multi‐opening OSB press. The particulate emissions from the mat

forming area and mat sawing are controlled by a baghouse (PS‐06). In the press, the wafer

mats are subjected to a pressure of 825 psia and a temperature of 400 deg. F to produce

OSB. Each press cycle lasts approximately three minutes. The furnaces supply heat to the

press through the thermal oil system. A hood collection system gathers volatile organic

emissions from the press area and sends them to an RTO control (RTO‐3). The RTO abort

port (RTO(ABORT)‐3) is used only during emergency situations and when the press is

shutdown.

The OSB is cut and trimmed to produce finished panels. The particulate emissions from

panel sawing are controlled by a baghouse (PS‐08). A new emission source to include sand

and tongue and groove operations is being included with this submittal. The particulate

emissions from tongue and groove are controlled by a baghouse (PS‐10). Material from the

screen building, blender building, former area and saw line are routed to the HP Systems

Receiver (HP), where particulate emissions are controlled by a baghouse (HP). Saw dust is

sent to fuel storage bins for use in the furnaces. The OSB sections are stacked, edge sealed,

stenciled, and bundled for sale. Particulate Matter and VOCs are emitted from the Edge Seal

Booths (PF‐03A and PF‐03B) which are equipped with a fabric filter. Particulate matter is

emitted from the stenciling process (PF‐04A and PF‐04B).

The facility also includes a natural gas fired Standby Thermal Oil Heater (TO‐2) to provide

hot oil when the furnaces (F‐1 and F‐2) are offline. Additionally, Stand‐by Gas Burners No. 1

and No. 2 (SB‐1 and SB‐2) provide hot air to the dryers for short periods of time when the

furnaces (F‐1 and F‐2) are offline.

Storage tanks at the facility include a diesel storage tank (TK‐1) and a gasoline storage tank

(TK‐2) to provide fuel to plant mobile equipment, a used oil storage tank (TK‐3) and edge

seal storage tank (TK‐4). These storage tanks emit VOCs.

Additional emission sources include an Emergency Fire Pump (EFP‐1) and Emergency

Generator (EG‐1), which are both use diesel fuel. These engines emit particulate matter,

sulfur dioxide, carbon monoxide, nitrogen oxide and VOC emissions from diesel fuel


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combustion. There are also fugitive particulate emissions from paved and unpaved roads at

the facility.

Maintenance emissions related to bake out procedures for the RTOs occur about once a

month for each RTO and last about 4‐8 hours. During these maintenance procedures dryer

or press operations are shut down and emissions should not exceed those provided in MSS

emissions calculations. Corrigan OSB operations have Maintenance Startup and Shutdown

(MSS) operations associated with the OSB normal production operations. Engineering for

the operations of the process include mechanism which will immediately initiate shutdown

of the sources in the event of any bypass.

1.3 Air Emissions

The Corrigan OSB is a major source of criteria air pollutants in accordance with Chapters 116

and 122, since emissions of individual criteria pollutants are above 250 tons per year. The

following table (Table 1‐1) provides a description of each existing and proposed emission

source for the Corrigan OSB facility.

Table 1‐1

Emission Source List

EPN/FIN Emission Source Description

PS‐05 Strander Pneumatic System Baghouse Stack

PS‐06 Former Area Pneumatic System Baghouse Stack

PS‐07 Dry Bin Area Aspiration System Baghouse Stack

PS‐08 Sawline Pneumatic System Baghouse Stack

PS‐09 Fines Aspiration System Baghouse Stack

PS‐10 (Proposed) Sand & Tongue and Groove Aspiration System Baghouse Stack

HP High Pressure Systems Received Cyclone Stack

TO‐1 Standby Thermal Oil Heater

PF‐03 (A) Edge Seal Booth Stack

PF‐03 (B) Edge Seal Booth Stack

PF‐04 (A) Stencil Area

PF‐04 (B) Stencil Area

TK‐1 Diesel Storage Tank

TK‐2 Gasoline Storage Tank

TK‐3 Used Oil Storage Tank

TK‐4 Edge Seal Storage Tank


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Table 1‐1

Emission Source List

EPN/FIN Emission Source Description

RO‐1 Paved Roads

RO‐2 Unpaved Roads

EFP‐1 Emergency Fire Pump (Diesel) Stack

EG‐1 Emergency Generator (Diesel) Stack

RTO‐1/RD‐1 Rotary Dryer No. 1

RTO‐1/VS‐1 Venturi Scrubber No. 1

RTO‐1/WESP‐1 Wet Electrostatic Precipitator No. 1

RTO‐01 Regenerative Thermal Oxidizer 1

RTO (ABORT)‐1 Regenerative Thermal Oxidizer 1 Abort Port

RTO‐1/F‐1 Furnace for Dryer No. 1

SB‐1 Stand‐by Gas Burner No. 1 (NG)

RTO‐2/RD‐2 Rotary Dryer No. 2

RTO‐2/VS‐2 Venturi Scrubber No. 2

RTO‐2/WESP‐2 Wet Electrostatic Precipitator No. 2



RTO‐2/F‐2 Furnace for Dryer No. 2

SB‐2 Stand‐by Gas Burner No. 2 (NG)

RTO‐03/P‐1 Regenerative Thermal Oxidizer 3 / OSB Press No. 1

MSS‐1 Pneumatic Transfer System Bypass Stack

MSS‐2 Sawmill Bypass Stack

MSS‐3 Dryer Bypass Stack


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1.4 Total Facility Emissions

Table 1‐2 shows the proposed permitted emission rates and the PSD Significant Emission

Rate for the air permit application.

PSD review is required for PM10, PM2.5, and PM due to PTE exceeding the PSD significant

emission rates for an existing major source.

2.0 REGULATORY APPLICABILITY

2.1 TCEQ Applicable Regulations

Corrigan OSB is an existing major source of criteria pollutants and a minor source of

hazardous air pollutants (HAPs). The facility will be in compliance with all the applicable

provisions of the following Texas regulations.

General Rules (Chapter 101, Subchapter A)

The facility will comply with the General Rules. The site will be subject to the requirements

for annual emissions inventories. The owner/operator will pay annual inspection or

emissions fees for the site as required.

Table 1‐2 Total Facility‐Wide Emissions Summary

Pollutant Proposed Total

Emissions (tpy)

Project Change in Allowable

(tpy)

PM 131.47 35.17

PM10 131.47 35.17

PM2.5 131.25 35.17

SO2 2.27 ‐1.60

NOx 178.61 ‐21.21

CO 306.89 ‐281.14

VOC 12.94 ‐38.96

HAPs 17.11 ‐7.81

CO2e 47,8144 ‐16115


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CONTROL OF AIR POLLUTION FROM VISIBLE EMISSIONS AND PARTICULATE MATTER

(CHAPTER 111)

All requirements of §111.111 (a)(1) will be met. Visible emissions shall not be permitted to

exceed an opacity of 20% for any six‐minute period from all other sources not specified in

§111.111(a)(1)(B). Stationary vents that will have visible emissions and particulate matter

are listed below.

PS‐05 Strander Pneumatic System Baghouse Stack

PS‐06 Former Area Pneumatic System Baghouse Stack

PS‐07 Dry Bin Area Aspiration System Baghouse Stack

PS‐08 Sawline Pneumatic System Baghouse Stack

PS‐09 Fines Aspiration System Baghouse Stack

PS‐10 Sand Tongue & Groove Aspiration System Baghouse Stack

HP High Pressure System Receiver Cyclone Stack

TO‐2 Standby Thermal Oil Heater Stack

PF‐03 (A) Edge Seal Booth

PF‐03 (B) Edge Seal Booth

EFP‐1 Emergency Fire Pump (Diesel)

EG‐1 Emergency Generator (Diesel)

RD‐1* Rotary Dryer No. 1

VS‐1* Venturi Scrubber No. 1

WESP‐1* Wet Electrostatic Precipitator No. 1

F‐1 Furnace for Dryer No. 1

SB‐1* Stand‐by Gas Burner No. 1 (NG)

RD‐2** Rotary Dryer No. 2

VS‐2** Venturi Scrubber No. 2

WESP‐2** Wet Electrostatic Precipitator No. 2

F‐2 Furnace for Dryer No. 2

SB‐2** Stand‐by Gas Burner No. 2 (NG)

P‐1*** OSB Press No. 1 Notes: *Emissions are routed through RTO‐01 or RTO (ABORT)‐1. **Emissions are routed through RTO‐02 or RTO (ABORT)‐2. ***Emissions are routed through RTO‐03.


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Visible emissions shall not be permitted to exceed an opacity of 10% for any six‐minute

period from all other sources not specified in §111.111(a)(1)(C). Stationary vents that will

have visible emissions and particulate matter are listed below.






§111.111 Requirements for Specified Sources Paragraphs 111.11(a)(2) through 111.111(a)(6) do not apply, as there are no steam

generators, catalyst regenerators, gas stream containing condensed water vapor, gas flares,

motor vehicles, railroad locomotives, or ships associated with this application. The

requirements of §111.111(a)(7) and §111.111(a)(8) will be met. Paragraph 111.111(b) does

not require a response. The requirements of §111.111(c) do not apply because the facility is

not located in the City of El Paso.

§111.113 Alternative Opacity Limitations The emission sources described in this application will meet §111.111(a)(1)(B) and

§111.111(a)(1)(C). Therefore, §111.113 does not apply.

Incineration (Chapter 111, Subchapter A, Division 2) Not applicable. The facility will not have incinerators at the site.

Abrasive Blasting of Water Storage Tanks Performed by Portable Operations (Chapter 111, Subchapter A, Division 3) Not applicable. The facility will not have potable water tanks at the site.

Materials Handling, Construction, Roads, Streets, Alleys, and Parking Lots (Chapter 111, Subchapter A, Division 4) Not applicable. The site is not located in the geographic areas of application: City of El Paso;

the portion of Harris County inside the loop formed by Beltway 8; and area of Nueces

County.

Emissions Limits on Nonagricultural Processes (Chapter 111, Subchapter A, Division 5) §111.151 Allowable Emission Limits Particulate matter stack emission rates from the affected emission sources will be within

the limits specified in §111.51(a) and Table 1.


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§111.153 Emissions Limits for Steam Generators There are no steam generators associated with this application. Therefore, §111.153 does

not apply.

Emissions Limits on Agricultural Processes (Chapter 111, Subchapter A, Division 6) Not applicable. The facility will not have agricultural processes at the site.

Outdoor Burning (Chapter 111, Subchapter B) Outdoor burning will not be conducted at the site with the following possible exceptions:

(1) fires used in the non‐commercial preparation of food; (2) burning of hydrocarbon spills

when conducted in compliance with §111.213; and (3) burning for firefighting training when

conducted in compliance with §111.205.

CONTROL OF AIR POLLUTION FROM SULFUR COMPOUNDS (CHAPTER 112)

Control of Air Pollution from Sulfur Compounds (Chapter 112) There are no operations associated with this application which produce hydrogen sulfide,

sulfuric acid, or total reduced sulfur. Small quantities of sulfur dioxide are produced by the

operation of the regenerative thermal oxidizers, furnaces, standby burners and emergency

engines. Therefore, there are no applicable limitations or requirements under this Chapter

STANDARDS OF PERFORMANCE FOR HAZARDOUS AIR POLLUTANTS AND FOR DESIGNATED

FACILITIES AND POLLUTANTS (CHAPTER 113)

Standards of Performance for Hazardous Air Pollutants and For Designated Facilities and Pollutants (Chapter 113) The operations to be covered by this application are not subject to any National Emission

Standards for Hazardous Air Pollutants (NESHAPs) under 40 CFR 61. This facility will not be a

major source of HAPs with the proposed project. As an area source of HAPs, §111.1090,

Reciprocating Internal Combustion Engines (40 CFR Subpart ZZZZ), and §111.1380 Gasoline

Dispensing Facilities Area Sources (40 CFR 63 Subpart CCCCCC) will apply. These

requirements are discussed further in the following section of this application.


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CONTROL OF AIR POLLUTION FROM MOTOR VEHICLES (CHAPTER 114)

Control of Air Pollution from Motor Vehicles (Chapter 114) Not applicable. The facility will not have motor vehicles subject to the requirements of this

chapter. However, all vehicles owned and used by Corrigan OSB for the operations

described in this application will comply with §114.1 through §114.21, as applicable.

CONTROL OF AIR POLLUTION FROM VOLATILE ORGANIC COMPOUNDS (CHAPTER 115)

Storage of Volatile Organic Compounds (Subchapter B, Chapter 115, Division 1) Not applicable. Facilities located in Polk County have no applicable requirements.

Vent Gas Control (Subchapter B, Chapter 115, Division 2) Not applicable. Facilities located in Polk County have no applicable requirements.

Water Separation (Subchapter B, Chapter 115, Division 3) Not applicable. The facility will not have VOC water separators at this site.

Industrial Wastewater (Subchapter B, Chapter 115, Division 4) Not applicable. The facility will not have industrial wastewater streams at this site.

Municipal Solid Waste Landfills (Subchapter B, Chapter 115, Division 5) Not applicable. The facility will not have municipal solid waste landfills at the site.

Batch Processes (Subchapter B, Chapter 115, Division 6) Not applicable. The facility will not have batch processes at this site.

Loading and Unloading of Volatile Organic Compounds (Subchapter C, Chapter 115, Division 1) Not applicable, this facility is not a gasoline terminal.

Filling of Gasoline Storage Vessels (Stage 1) For Motor Vehicle Fuel Dispensing Facilities (Subchapter C, Chapter 115, Division 2) Not applicable. Gasoline will not be transferred at this site.


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Control of Volatile Organic Compound Leaks from Transport Vessels (Subchapter C, Chapter 115, Division 3) Not applicable. Gasoline tank trucks will not be filled or emptied at this facility.

Control of Vehicle Refueling Emissions (Stage II) At Motor Vehicle Fuel Dispensing Facilities (Subchapter C, Chapter 115, Division 4) Not applicable. Facilities located in Polk County have no applicable requirements.

Control of Reid Vapor Pressure of Gasoline (Subchapter C, Chapter 115, Division 5) Not applicable. Facilities located in Polk County have no applicable requirements.

Petroleum Refining, Natural Gas Processing, and Petrochemical Processes (Subchapter D, Chapter 115) Not applicable. The facility will not have petroleum refining, natural gas processing or

petrochemical processes at this site.

Solvent‐Using Processes (Subchapter E, Chapter 115) Not applicable. The facility will not have solvent‐using processes at this site.

Miscellaneous Industrial Sources (Subchapter F, Chapter 115) Not applicable. The facility will not have miscellaneous industrial sources at this site.

Consumer‐Related Sources (Subchapter G, Chapter 115) Not applicable, applies only to persons who manufacture, supply, distribute, or sell

consumer products.

Highly Reactive Volatile Organic Compounds (Subchapter H, Chapter 115) Not applicable. Facility not located in the Houston/Galveston/Brazoria areas.

CONTROL OF AIR POLLUTION BY PERMITS FOR NEW CONSTRUCTION OR MODIFICATION

(CHAPTER 116)

New Source Review Permits: Permit Application (Subchapter B, Chapter 116, Division 1) This amendment application is being submitted to comply with Chapter 116 requirements.

Protection of Public Health and Welfare (Subchapter B 116.111(a)(2)(A)(i) and (ii)) This application is being submitted to comply with Chapter 116 requirements. There are no

schools located within 3,000 feet of the Corrigan OSB facility.


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Measurement of Emissions (Subchapter B 116.111(a)(2)(B)) Corrigan OSB has provisions for measuring the emissions of significant air contaminants as

determined by the Executive Director. Visible emissions for all required sources will be

monitored daily. These sources are addressed in Section 2.1, Visible Emissions (Chapter

111, Subchapter A, Division 1).

Best Available Control Technology (BACT) (Subchapter B 116.111(a)(2)(C)) The Best Available Control Technology for new/modified source is addressed in Section 3.0

of this application.

New Source Performance Standards (NSPS) (Subchapter B 116.111(a)(2)(D)) New Source Performance Standards are addressed in Section 2.2 of this application.

National Emission Standards for Hazardous Air Pollutants (NESHAP) (Subchapter B 116.111(a)(2)(E)) 40 CFR 61 is not applicable to the Corrigan OSB facility.

NESHAP for Source Categories (Subchapter B 116.111(a)(2)(F)) NESHAP for source categories are addressed in Section 2.3 of this application.

Performance Demonstration (Subchapter B 116.111(a)(2)(G)) Performance specified in the permit application will be achieved as required by the

applicable regulations. Extensive information is being submitted as part of this amendment

application which provides the technical basis for the emissions and operational procedures

represented. Included are process flow diagrams, material balances, and emission

calculations. Corrigan OSB believes there is sound technical justification provided to indicate

that the facility will operate in accordance with the representations made in this

application. Corrigan OSB will submit additional engineering data after the permit has been

issued as requested to demonstrate further that the proposed facility will achieve the

performance specified in the permit application.

Nonattainment Review (Subchapter B 116.111(a)(2)(H)) The proposed facility is located in an area in attainment for regulated pollutants.

Prevention of Significant Deterioration (PSD) Review (Subchapter B 116.111(a)(2)(I)) The facility is an existing major source for un‐named sources operating under PSDTX1446

and GHGPSDTX 128, which was issued on December 4, 2017. With the proposed project,

the Particulate emissions exceed the PSD significant emission rate threshold requiring PSD


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netting and impacts evaluation. PSD review is being submitted with this application as per

TCEQ guideline.

Air Dispersion Modeling (Subchapter B 116.111(a)(2)(J)) Corrigan conducted an air dispersion modeling analysis of criteria pollutants for

new/increased emissions in order to demonstrate compliance with PSD and National

Ambient Air Quality Standards (NAAQS) as per the most recent TCEQ Air Quality Modeling

Guidelines.

Hazardous Air Pollutants (Subchapter B 116.111(a)(2)(K)) Corrigan OSB will comply with all applicable regulations governing constructed major

sources; this is discussed in Section 2.3 of the application.

Mass Cap and Trade Allowances (Subchapter B 116.111(a)(2)(L)) The facility will not be subject to Chapter 101, Subchapter H, Division 3 of this title relating

to Mass Emissions Cap and Trade Program.

Public Notification and Comment Procedures (Subchapter B, Chapter 116, Division 3) The facility will comply with all public notification and comment procedures.

Permit Fees (Subchapter B, Chapter 116, Division 4) The facility will comply with all permit fees associated with modification of the facility.

Nonattainment Review (Subchapter B, Chapter 116, Division 5) Corrigan OSB is located in Polk County, which is classified as an attainment county for all

regulated pollutants. Therefore, NNSR does not apply.

Prevention of Significant Deterioration Review (Subchapter B, Chapter 116, Division 6) The facility will comply with all PSD requirements.

Emission Reductions: Offsets (Subchapter B, Chapter 116, Division 7) Not applicable. Emission reductions and offsets are not applicable to this site.

Portable Facilities (Subchapter B, Chapter 116, Division 8) Not applicable. The facility is not a portable site.


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CONTROL OF AIR POLLUTION FROM NITROGEN COMPOUNDS (CHAPTER 117)

Control of Air Pollution from Nitrogen Compounds (Chapter 117) Not applicable, the facility is not located in a non‐attainment county or subject to the multi‐

region combustion control requirements of Subchapter E of this chapter.

CONTROL OF AIR POLLUTION EPISODES (CHAPTER 118)

Corrigan OSB will comply as required. Should the executive director of the TCEQ determine

a Level 1 air pollution episode exists for Polk County, Corrigan, in accordance with 30 TAC

§118.2(a), will determine existing emissions levels for contaminants involved in the episode,

implement reasonably available methods to reduce emissions, and prepare to curtail all

affected emission sources in anticipation of a Level 2 episode.

FEDERAL OPERATING PERMITS PROGRAM (CHAPTER 122)

This facility is subject to Chapter 122. Corrigan is currently authorized under Title V SOP

Permit #O3779. A full federal operating permit modification application will be submitted to

reflect the proposed amendment as required under Chapter 122.

2.2 New Source Performance Standards (NSPS)

The NSPS standards contained in 40 CFR 60 were reviewed to determine their applicability

to the facility. All sources subject to NSPS are subject to the applicable provisions of the

relevant Subpart A.

Subpart Db – NSPS for Industrial‐Commercial‐Institutional Steam Generating Units Subpart Db does not apply to the furnaces for the dryers (F‐1 and F‐2) since they are

considered process heaters as defined by this subpart (40 CFR 60.40b).

Subpart Dc – NSPS for Small Industrial‐Commercial‐Institutional Steam Generating Units Subpart Dc applies to Standby Thermal Oil Heater (EPN TO‐2). This unit is in compliance

with the applicable emission limitations, monitoring, recordkeeping, reporting and testing

requirements.

Subpart Dc does not apply to furnaces for the dryers (FIN F‐1 and F‐2) and standby by

burners (EPN SB‐1 and SB‐2), since they are considered process heaters as defined by this

subpart (40 CFR 60.40c).


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Subpart Kb – NSPS for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 Subpart Kb does not apply to TK‐1 Diesel Storage Tank, TK‐2 Gasoline Storage Tank, TK‐3

Used Oil Storage Tank, and TK‐4 Edge Seal Storage Tank. These tanks have a capacity of less

than 75 m3 (40 CFR 60.110b(a)).

Subpart IIII – NSPS for Compression Ignition Internal Combustion Engines Subpart IIII does apply to Emergency Generator (Diesel) Stack (EPN EG‐1) and Emergency

Fire Pump (Diesel) Stack (EPN EFP‐1). These units meet the applicable emission limitations,

monitoring, recordkeeping, reporting and testing requirements.

2.3 National Emission Standards for Hazardous Air Pollutants (NESHAP)

The NESHAP standards contained in 40 CFR 63 were reviewed to determine their

applicability to facility. All sources subject to NESHAPs are subject to the applicable

provisions of the relevant Subpart A. The Corrigan OSB facility will be an area source since it

is a stationary source of HAPs and is not a major source. Only NESHAP standards applicable

to area sources are discussed in this section.

Subpart ZZZZ – NESHAP for Stationary Reciprocating Internal Combustion Engines Corrigan OSB is in compliance with Subpart ZZZZ by complying with NSPS Subpart IIII as

discussed in Section 2.2. This subpart applies to the Emergency Fire Pump (Diesel) (EFP‐1)

and Emergency Generator (Diesel) (EG‐1).

Subpart CCCCCC – NESHAP for Gasoline‐Dispensing Facilities Corrigan OSB is in compliance with the applicable requirements since Corrigan OSB meets

the definition of a gasoline dispensing facility.

Subpart JJJJJJ – NESHAP for Industrial, Commercial, and Institutional Boilers Area Sources Subpart JJJJJJ does not apply to Corrigan OSB since none of the emission units meet the

definition of industrial, commercial, or institutional boiler as defined in §63.11237.

2.4 Compliance Assurance Monitoring (CAM)

Corrigan OSB is subject to CAM. The Regenerative Thermal Oxidizers 1, 2 and 3 (RTO‐01,

RTO‐02 and RTO‐03) have applicable CAM regulations.


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2.5 Chemical Accident Prevention Regulation (40 CFR 68)

The accidental release prevention program mandated by section 112(r) of the Clean Air Act

(CAA) is codified in 40 CFR 68. This is not applicable to the Corrigan OSB facility since it will

not store regulated substances over threshold quantities. Corrigan OSB will comply with

Part 68 if a regulated substance exceeds the threshold quantity.

2.6 Stratospheric Ozone Protection (40 CFR 82)

Title VI of the Clean Air Act (CAA) Amendments requires phase‐out of ozone‐depleting

chemicals. The stratospheric ozone protection provisions are codified under 40 CFR 82.

The facility shall comply with the applicable requirements of 40 CFR 82.


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3.0 PREVENTION OF SIGNIFICANT DETERIORATION REVIEW

3.1 Introduction

Corrigan OSB was permitted as a new facility under New Source Review (NSR) Permit

#128854, PSDTX1446, GHGPSDTX128 issued October 23, 2015 and Title V Standard

Operating Permit (SOP) Permit #O3779 issued December 4, 2017. Corrigan OSB is

reconciling the current PSD permit to be reflective of intended operations at the facility.

This PSD application does not represent a physical change or change of method of

operation. Rather, it is a reconciliation application to establish operating parameters

originally intended based on design of the facility.

As shown in Table 3‐1 below, these revisions necessary to reflect the intended operations

will result in an increase from the current permitted rates for PM10 and PM2.5 above the

respective significant emission rate (SER) thresholds.

Table 3‐1 PSD Threshold Emissions Summary

Pollutant Proposed Total

Emissions (tpy)

Project Change in Allowable

(tpy)

PSD Significant Emission Rate

(tpy)

PM 131.47 35.17 25

PM10 131.47 35.17 15

PM2.5 131.25 35.17 10

SO2 2.27 ‐1.60 40

NOx 178.61 ‐21.21 40

CO 306.89 ‐281.14 100

VOC 12.94 ‐38.96 40

CO2e 478,144 ‐16,115 75,000 Note: The facility has been in operation less than 2 years. Therefore, permitted rates were used as

actual baseline emissions.

Sources undergoing a PSD review must apply Best Available Control Technology (BACT) to

any new or modified emission unit that emits a PSD triggered pollutant in an amount above

the SER. Federal PSD regulations define BACT as “an emission limitation (including a visible

emission standard) based on the maximum degree of reduction of each pollutant subject to

regulation under the Clean Air Act, emitted from or which results from any major emitting

facility, which the permitting authority, on a case‐by‐case basis, taking into account energy,

environmental, and economic impacts and other costs, determines is achievable for such


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facility through application of production processes and available methods, systems, and

techniques, including cleaning or treatment or innovative fuel combustion techniques for

control of each such pollutant.” No BACT determination may be less stringent than the

applicable NSPS, National Emissions Standards for Hazardous Air Pollutants (NESHAP), or

State Implementation Plan (SIP) limits. Also, the definition allows a design or work practice

to be established as BACT.

BACT is required for the control of any emissions unit that emits a PSD triggering pollutant

and a BACT analysis is required for each emission point that emits a PSD triggering

pollutant. Section 1 of this application identifies the triggered PSD pollutants as PM10 and

PM2.5.

3.2 Best Available Control Technology (BACT) Analysis

This section presents the BACT analysis in support of the proposed amendment to an

existing oriented strand board (OSB) facility located in Corrigan, Polk County, Texas.

Pursuant to 40 CFR 52.21(j), each new major source must employ BACT for each regulated

pollutant that it would have the potential to emit in significant amounts. BACT is generally

defined as:

[A]n emission limitation, including a visible emission standard, based on the

maximum degree of reduction of each pollutant emitted which, on a case by

case basis, taking into account energy, environmental, and economic

impacts, and other costs, is determined to be achievable through application

of production processes and available methods, systems, and techniques

including fuel cleaning or treatment or innovative fuel combustion techniques

for control of each such pollutant. (EPA, 1990)

3.3 BACT Methodology

A December 1, 1987 memorandum from the Environmental Protection Agency (EPA)

Assistant Administrator for Air and Radiation provided guidance on “top‐down”

methodology for determining BACT. The “top‐down” process involves the identification of

all applicable control technologies according to control effectiveness. The owner or

operator then evaluates the “top,” or most stringent, control alternative. If the most

stringent is shown to be technically or economically infeasible, or if environmental impacts

are severe enough to preclude its use, then the next most stringent control technology is


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similarly evaluated. This process continues until the BACT level under consideration cannot

be eliminated by technical or economic considerations, energy impacts, or environmental

impacts.

Five basic steps of a top‐down BACT analysis are listed below:

Step 1. Identify all control technologies;

Step 2. Eliminate all technically infeasible control technologies;

Step 3. Rank remaining control technologies by control effectiveness;

Step 4. Evaluate most effective controls and document results; and

Step 5. Select BACT.

The EPA has consistently interpreted the statutory and regulatory BACT definition as

containing two core requirements that EPA believes must be met by any BACT

determination, irrespective of whether it is conducted in a “top‐down” manner. First, the

BACT analysis must include consideration of the most stringent available technologies; i.e.,

those which provide the “maximum degree of emissions reduction.” Second, any decision

to require a lesser degree of emissions reduction must be justified by an objective analysis

of “energy, environmental, and economic impacts” contained in the record of the permit

decisions.

As part of the analysis, several control options for potential reductions in criteria pollutants

were identified. The control options were identified by three methods: 1) researching the

Reasonably Available Control Technology (RACT)/Best Available Control Technology

(BACT)/Lowest Achievable Emission Rate (LAER) Clearinghouse (RBLC); 2) drawing upon

previous engineering experience; and 3) surveying available literature. A general review of

the RBLC database has been performed and only the most recent determinations for the

previous ten years were considered.

As shown in Table 1‐2, emissions of PM10 and PM2.5 exceed the applicable SERs; therefore,

BACT must be determined for each emission unit, which emits PM10 and PM2.5. The units

subject to a BACT review include: Rotary Dryers, OSB Press, Thermal Oil Heater, Standby

Burners, emergency engines, pneumatic, aspiration and high‐pressure systems, edge seal

painting and stencil painting, and paved and unpaved roads.


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3.4 BACT Analysis for Rotary Dryers

Corrigan OSB includes two direct wood‐fired rotary dryers. The rotary dryers are used to

remove moisture from the wood strands. Hot combustion gases are provided to the dryers

by two wood‐fired furnaces. Characterization of the rotary dryers is provided in Table 3‐2.


Emission Points: RTO‐01 and RTO‐02

Source Descriptions: Rotary Dryer No. 1

Rotary Dryer No. 2

Operating Parameters (each): Production Rate: Oven Dry Tons: Temperature: Furnace Outlet Dryer Inlet Dryer Outlet Furnace Heat Input: Operating Hours:

450,000 MSF 3/8 inch/yr 306,000 ODT/year 1,600° F ‐ 1,800° F 1,000° F 395° F 250 MM Btu/hr (furnace); 150 MM Btu/hr (dryer) 8,760 hr/year

3.4.1 Control Technologies

The first step in a BACT analysis is identifying possible control technologies for PM10/PM2.5

based on previously demonstrated controls on comparable emissions sources. For most

source types, EPA’s RBLC is the preferred reference. Table 3‐3 lists commercially available

controls.

Table 3‐3 Potential Control Technologies PM10/PM2.5

Baghouse Dry Electrostatic Precipitator (DESP) Wet Electrostatic Precipitator (WESP) Venturi Scrubber Good Design/Operation


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3.4.2 Technically Infeasible Options

The second step in a BACT analysis is eliminating any technically infeasible control

technologies. The feasibility of each control technology for each pollutant is considered

below.

Baghouse ‐ A baghouse, also referred to as a fabric filter, consists of a number of fabric bags

placed in parallel. The gas stream is filtered when it passes through the bags, and PM10/2.5 is

collected on the surface of the fabric. The collected PM10/PM2.5 is periodically removed

from the bags to hoppers located beneath the bags. PM10/PM2.5 removal from the filters is

accomplished by reversing airflow or shaking the filters in an isolated compartment of the

baghouse, or by short blasts of high‐pressure air (pulsejet).

A baghouse can be designed to remove up to approximately 99 percent of PM10/2.5

downstream of a primary dust collector. Baghouse efficiency is limited to dry exhaust

streams at temperatures less than 1,000°F. While the wood fired furnace/dryer exhaust has

a temperature of approximately 395°F, the exhaust contains a significant amount of

moisture. The moisture content combined with the presence of condensable PM10/PM2.5

can cause “blinding” of the fabric filter. This will in turn result in lower airflow rates, greater

pressure drop, and finally, reduced PM control efficiency. Therefore, a baghouse is not

considered technically feasible for the wood fired furnace/dryer exhaust.

Dry Electrostatic Precipitator – A dry electrostatic precipitator (DESP) is not suitable for this

application due to the high potential for explosive conditions due to the wood resins

contained in the waste gas.

3.4.3 Top Down Evaluation of Control Options

In the following steps (Steps 3 and 4) in the “top‐down” BACT approach, the highest ranked

control option is evaluated first followed by the second highest ranked option and so on. If

the highest ranked option is technically and economically feasible, and the option has

acceptable energy and environmental impacts, the option is deemed BACT. Otherwise, the

next ranked control option is evaluated. The evaluation process continues until a control

option is found that meets all of the BACT requirements. Once BACT is determined, it is

unnecessary to evaluate any remaining options that are ranked below the selected BACT.

Table 3‐4 presents control technologies which are consistent with EPA’s RBLC.


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Table 3‐4 Control Technology Options for Emissions from Combustion Sources

Pollutant Control Technology Typical Control

Efficiency

In Service for Wood Fired Furnaces?

PM10/PM2.5

Wet Electrostatic Precipitator 90+% Yes

Venturi Scrubber 50‐90% Yes

Good Design/Operation Base Case Yes

In Step 5 of the BACT analysis, Corrigan OSB proposes to use the following air pollution

controls: venturi scrubbers followed by a wet electrostatic precipitator (WESP).

The selected control technologies in Table 3‐3 are consistent with EPA’s RBLC

references in Appendix D1 and will be presented in detail below.

A venturi scrubber uses a combination of scrubbing liquid, velocity, and turbulence to

remove particles (PM10/PM2.5) from the waste gas. Scrubbing liquid is sprayed into the gas

stream as it enters a narrow throat in the duct. The atomized scrubbing liquid interacts

with particles in the gas stream. As the mixture decelerates, the droplets agglomerate and

are removed from the gas stream by a mist eliminator. The gas stream then enters a WESP.

WESPs are used to collect particles in situations where the waste gas stream contains wet,

sticky, flammable, or explosive materials, (e.g. waste gas from wood dryers containing wood

resins). WESPs apply high voltage to generate an electrical field that charges particles as

they pass through. The charge particles are forced to follow the electric field to the wall of

the collecting pipe. Wash water is sprayed into the collector pipes to move the collected

particles to sump. The gas stream is sent through mist eliminator and enters the RTO.

3.5 BACT Analysis for OSB Press

The facility will include a thermal oil heated multi‐opening OSB press. The press is used to

apply heat and pressure to activate resins in formed mats. Once released from the press,

the bonded strands are a solid reconstituted product (i.e. OSB). Characterization of the

press is provided in Table 3‐5.


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Emission Point(s): RTO‐03

Source Description: Regenerative Thermal Oxidizer 3 / OSB Press No. 1

Operating Parameters 31,955 acfm 900,000 MSF 3/8 inch/yr 90°F (Hood Duct) 8,760 hr/yr

Vent Flow Rate: Production Rate: Temperature: Operating Hours:

3.5.1 Control Technologies

As with the previous analysis, the first step in BACT selection is to identify the possible

control technologies for each applicable pollutant for comparable emissions sources. Table

3‐6 lists commercially available controls, regardless of the industrial sector or process.

Emissions of NOx generated by the press (without any form of add‐on control) stem from

the resin formulation used during the board making process. Accordingly, the only method

by which the NOx emitted directly from the press could be controlled would be to

reformulate the resins. NOx control technology designed for combustion control is not

appropriate for this application and is not considered in this BACT analysis.

Table 3‐6 Potential Control Technologies

Pollutant Listed Control Technologies

PM10/PM2.5

Baghouse Dry Electrostatic Precipitator (DESP) Wet Electrostatic Precipitator (WESP) Multi cyclones Good Design/Operation

3.5.2 Technically Infeasible Options

The second step in a BACT analysis is eliminating any technically infeasible control

technologies. The feasibility of each control technology is considered below.

Baghouse – A baghouse can remove up to 99 percent of PM10/PM2.5 downstream of a

primary dust collector. However, the waxes and resins used in the board have the potential


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to blind the baghouse filters. Blinding of the filters results in lower airflow rates, greater

pressure drop, and reduced PM control efficiency. Although a baghouse is effective at

PM10/2.5 control in this context, it would only be able to operate for a short period of time

until the bags are blinded. As a result, the use of a baghouse is considered technically

infeasible for the press vent.

Dry Electrostatic Precipitator – A DESP on an OSB press must accommodate the presence of

adhesive particles in the exhaust airstream. The increased “rapping” needed to clean the

dry ESP of resins/waxes and requisite air stream conditioning would necessitate

modifications to process equipment that are deemed technically infeasible. Therefore, the

dry ESP is no longer considered in this BACT analysis.

Cyclones – Cyclones are technically infeasible in the OSB Press application. The press waste

gas stream contains resin residues that will adhere to the wall of the cyclones.

3.5.3 Top Down Evaluation of Control Options

Following the next step in the “top‐down” BACT approach, the highest ranked control

option is evaluated first. If the highest ranked option is technically and economically

feasible, and the option has acceptable energy and environmental impacts, the option is

deemed BACT. Otherwise, the next ranked control option is evaluated. The evaluation

process continues until a control option is found that meets all of the BACT requirements.

Once BACT is determined, it is unnecessary to evaluate any remaining options that are

ranked below the selected BACT.

Table 3‐7 Control Technology Options for Emissions from the OSB Press

Pollutant Control Technology Typical Control

Efficiency In Service for OSB

Presses?

PM10/2.5 WESP 80+% Yes

Good Design/Operation Base Case Yes

3.5.4 Selection of BACT for OSB Press

The PM10/2.5 emissions from the press are not proposed to be used as fuel for the wood

fired furnace at the facility. Since the PM10/PM2.5 from the press is not used for furnace

fuel, the use of a WESP would not impact the current fuel supply to the furnace and is


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considered technically feasible. An economic analysis was completed using a WESP for PM

control from the press. This analysis is provided in Appendix B. The result of the top‐down

analysis shows that installing a WESP would be economically infeasible as the PM10/PM2.5

emissions from the press are very low when compared to the flow of air out of the press.

Due to the high cost of operating a WESP to control PM10/PM2.5 from the press, no further

analysis of this control is required.

3.6 BACT Analysis for Thermal Oil Heater and Standby Burners

The following section presents BACT evaluations for the proposed Thermal Oil Heater (60

MMBtu/hr) and two Standby Burners (150 MMBtu/hr each). The thermal oil heater is

projected to run no more than 500 hours annually for the unscheduled downtime of the

rotary dryers. The standby burners are projected to run less than 300 hours per year for

emergency situations. This equipment will use only natural gas for fuels.

3.6.1 Potential Control Technologies

Based on review of RBLC results, and available literature, the following technologies in Table

3‐8 were identified as potentially applicable for controlling emissions for the proposed

equipment.

Table 3‐8 Control Technology Options for Emissions from the Thermal Oil

Heater and Standby Burners

Pollutant Potential Control Technology

PM10/2.5

Cyclone

Wet scrubber

Electrostatic precipitator (ESP)

Fabric filter (baghouse)

Good Combustion Practices

3.6.2 BACT Selection

Since the proposed Thermal Oil Heater and Standby Burners are only projected to run

during the emergency situations and major equipment downtime, the emissions for

PM10/PM2.5 are already low (e.g. no more than 0.40 tpy), additional add‐on controls are not

expected to further reduce potential emissions significantly and not economically justified.


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The only technically and economically feasible alternative is good combustion practices with

clean burning fuel and is proposed as BACT for the Thermal Oil Heater and Standby Burners.

3.7 BACT Analysis for Emergency Internal Combustion Engines

The facility proposes to include one diesel fueled emergency generator and one diesel

fueled fire water pump. All engines will burn low sulfur distillate oil. Other than plant

emergency situations, each engine will be operated no more than 100 hours per year for

routine testing, maintenance, and inspection purposes. BACT determination is shown in

Table 3‐9.

Table 3‐9 Control Technology Options for Emergency Internal Combustion Engines

Pollutant Potential Control Technology

PM10/PM2.5 Low Sulfur Fuel

Good Combustion Practices

3.7.1 BACT for Particulate Matter (PM10/PM2.5) PM10 and PM2.5 include trace amounts of metals, non‐combustible inorganic material, and

condensable, semi‐volatile organics which result from volatized lubricating oil, engine wear,

or from products of incomplete combustion. The majority of these emissions from the

engines are PM2.5. Therefore, BACT for PM10 and PM2.5 is addressed together as any control

technology available for control of PM2.5 will also effectively control PM10.

The control technologies that are considered technically feasible are the use of low sulfur

fuel and good combustion practices along with operating and maintaining the emergency

engines according to the manufacturer’s recommendations to maximize fuel efficiency and

minimize emissions. Therefore, Corrigan OSB proposes the use of engines certified by

manufacturers to meet NSPS Subpart IIII emission standards, use of low sulfur diesel, and

the limitation of non‐emergency operation to no more than 100 hours per year will provide

relatively low emissions of PM10/PM2.5 and are proposed as BACT for these emergency

engines.


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3.8 Pneumatic, Aspiration, and High‐Pressure Systems

The Corrigan OSB Plant will include enclosed conveyors and ductwork used to transfer

materials throughout the plant. Fans will be used to create positive and negative pressure

systems to move air and materials. Characterization of the pneumatic, aspiration, and high‐

pressure systems is provided in Table 3‐10.

The first step in evaluating BACT is identifying all candidate control technology options for

the emissions unit under review. Table 3‐11 presents a hierarchy of control technologies

selected as potential BACT candidates for the pneumatic, aspiration, and high‐pressure

systems.

Table 3‐11 PM10/PM2.5 Control Technology Options

Control Technology Typical Control

Efficiency

In Service on Wood Products Pneumatic

Systems?* Technically Feasible?

Cyclone/Baghouse 99 ‐ 99.99% Yes Yes

Baghouse 99 ‐ 99.95%. Yes Yes

Electrostatic Precipitators 95 ‐ 99.9% No Yes

Multi‐Cyclone 80 ‐ 99.9% No Yes

Cyclone 80 ‐ 99% No Yes

*EPA's RACT/BACT/LAER Clearinghouse (RBLC) was used to perform a search of all permitted control technologies for wood products industry pneumatic systems. The search results are provided as Appendix D2.


Emission Point(s): HP, PS‐5, PS‐6, PS‐7, PS‐8, PS‐9, and PS‐10

Source Description(s): Pneumatic, aspiration, and high pressure systems for the strander, former area, dry bin area, saw line, sander, dry fuel transfer system, and saw dust transfer system, and sand & tongue and Groove system

Operating Parameters: Temperature: Ambient Operating Hours: 8,760 hrs/yr

Pollutants: PM10 and PM2.5


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The cyclone followed by a baghouse and baghouse by itself were identified by a review of

existing pneumatic systems at wood products plants in operation. Multi‐cyclones, cyclones,

and electrostatic precipitators (ESP) were identified as potential types of control technology

because they are add‐on PM10/PM2.5 control which has been applied to other types of

PM10/PM2.5 sources.

All five PM10/PM2.5 control options were evaluated, and no basis was found to eliminate any

of these technologies as technically infeasible. However, there are no known examples

where ESP, multi‐cyclones, or cyclones were used in this type of application. Because (1)

cyclone/baghouse and baghouses provided comparable emission reductions to ESP and (2)

there is no known application of ESP to this type source, cyclone/baghouse and baghouses

were selected as BACT for these sources, consistent with the EPA’s RBLC references in

Appendix D2.

3.9 Edge Seal Painting and Stencil Painting

The Corrigan OSB Plant includes edge seal painting and stencil painting. Edge sealing and

stencil paint will include PM10/PM2.5 and VOC emissions. All edge sealing will be performed

in a paint booth equipped with filters to reduce PM10/PM2.5 emissions by 98%. PM10/PM2.5

and VOC emissions from edge seal painting and stencil painting will be very small and add‐

on pollution control devices would yield little benefit of emissions reductions to this

operation. Table 3‐12 presents the proposed BACT emission limits for edge seal painting

and stencil painting.


EPN Description Control

Technology

Emission Limit (lb/hr)

PM10/PM2.5

PF‐03A Edge Seal Paint Booth Paint Booth 0.17

PF‐03B Edge Seal Paint Booth Paint Booth 0.17

3.10 Fugitive Dust from Paved and Unpaved Roads

The Corrigan OSB Plant will include fugitive PM10/PM2.5 emissions from paved and unpaved

roads. Particulate emissions occur whenever vehicles travel over paved or unpaved

surfaces such as a road or parking lot. Particulate emissions from roads are due to direct


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emissions from vehicles in the form of exhaust, brake wear, and tire wear emissions and re‐

suspension of loose material on the road surface.

The first step in evaluating BACT is identifying all candidate control technology options for

the emissions unit under review. Table 3‐13 presents a hierarchy of control technologies

selected as potential BACT candidates for road dust emissions.

All plant roads will be subject to limited access traffic and Corrigan OSB proposes hard

pavement and gravel for the plant road surfaces. Proposed plant paved road surfaces will

have very low silt loading. As such, the use of vacuum sweeping and/or water/chemical

treatment will not provide significant environmental benefit. The plant unpaved roads will

be composed of gravel with low silt content. Additionally, the average climatic conditions

for Texas include sufficient precipitation to maintain very minor levels of PM10 emissions

from unpaved roads.

Because emissions from the plant roads are very small, the application of the control

methods listed in Table 3‐12 will have little environmental benefit. The emissions

generated are not expected to have outstanding issues regarding collateral environmental

impacts. Corrigan OSB proposes restricted access to unpaved roads and to limited access

concrete/asphalt roads with no additional control as BACT.

Table 3‐13 Control Technology Options for PM10/PM2.5 Emissions from

Paved and Unpaved Roads

Road Surface Control Technology Typical Control

Efficiency In Service for at OSB Plants?

Technically Feasible?

Concrete/ Asphalt

Vacuum Sweeping/Water Flushing

< 96% Yes Yes

Water Flushing < 69% Yes Yes

Vacuum Sweeping < 58% Yes Yes

Gravel Chemical Dust Suppressants

< 50 Yes Yes

Watering NIA Yes Yes


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Table 3‐14 presents the proposed BACT emission limits for the plant roads.


EPN Description Control

Technology PM10/PM2.5 Emission Limit

(lb/hr)

R0‐01 Fugitive Dust ‐ Paved Roads Restricted Access 0.001

R0‐02 Fugitive Dust ‐ Unpaved Roads Limited Access 0.06


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4.0 NSR TCEQ FORMS AND ATTACHMENTS

TCEQ NSR WORKBOOK AND MATERIAL

SUBMITTED VIA TCEQ STEERS

Table 1(a)

Emission Point Summary

Date: Mar-20 Permit No.: 128854, PSDTX1446, GHGPSDTX128 Regulated Entity No.: RN107922510

Area Name: Customer Reference No.: CN604724831

Review of applications and issuance of permits will be expedited by supplying all necessary information requested on this Table.

(A) EPN (B) FIN (C) NAME (A) POUND (B) TPY

PS-05 PS-05 Strander Pneumatic System PM10/2.5 0.77 3.38

PS-06 PS-06 Former Area Pneumatic System PM10/2.5 1.28 5.61

PS-07 PS-07 Dry Bin Area Aspiration System PM10/2.5 0.76 3.32

PS-08 PS-08 Sawline Pneumatic System PM10/2.5 1.19 5.23

PS-09 PS-09 Fines Aspiration System PM10/2.5 1.39 6.09

PS-10 PS-10

Sand & Tongue and Groove AspirationSystem Baghouse Stack PM10/2.6 1.19 5.23

HP HP HP-Systems Receiver PM10/2.5 0.30 1.33

TO-2 TO-2 Standby Thermal Oil Heater PM10/2.5 0.45 0.16

TO-2 TO-2 Standby Thermal Oil Heater SO2 0.04 0.01

TO-2 TO-2 Standby Thermal Oil Heater NOx 5.69 2.05

TO-2 TO-2 Standby Thermal Oil Heater CO 4.94 1.78

TO-2 TO-2 Standby Thermal Oil Heater VOC 0.32 0.12

TO-2 TO-2 Standby Thermal Oil Heater Benzene <0.01 <0.01

TO-2 TO-2 Standby Thermal Oil Heater Formaldehyde <0.01 <0.01

TO-2 TO-2 Standby Thermal Oil Heater n-Hexane 0.11 0.04

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY


2. Component or Air Contaminant Name1. Emission Point 3. Air Contaminant Emission Rate


AIR CONTAMINANT DATA

OK MARBLE TABLE 1(a) PRINTED ON RECYCLED PAPER










TO-2 TO-2 Standby Thermal Oil Heater Toluene <0.01 <0.01

TO-2 TO-2 Standby Thermal Oil Heater CO2e NA 2864

PF-03(A) PF-03(A) Edge Seal Booth PM10/2.5 0.17 0.64

PF-03(A) PF-03(A) Edge Seal Booth VOC 0.12 0.44

PF-03(B) PF-03(B) Edge Seal Booth PM10/2.5 0.17 0.64

PF-03(B) PF-03(B) Edge Seal Booth VOC 0.12 0.44

PF-04(A) PF-04(A) Stencil Area VOC 0.04 0.17

PF-04(B) PF-04(B) Stencil Area VOC 0.04 0.17

TK-1 TK-1 Diesel Storage Tank VOC <0.01 0.01

TK-2 TK-2 Gasoline Storage Tank VOC 0.13 0.59

TK-3 TK-3 Used Oil Storage Tank VOC <0.01 <0.01

TK-4 TK-4 Edge Seal Storage Tank VOC <0.01 0.01

RO-01 RO-01 Fugitive Dust (Paved Roads) PM10 <0.01 <0.01

RO-01 RO-01 Fugitive Dust (Paved Roads) PM2.5 <0.01 <0.01

RO-02 RO-02 Fugitive Dust (Unpaved Roads) PM10 0.06 0.24











RO-02 RO-02 Fugitive Dust (Unpaved Roads) PM2.5 0.01 0.02

EFP-1 EFP-1 Emergency Fire Pump (Diesel) PM10/2.5 0.07 <0.01

EFP-1 EFP-1 Emergency Fire Pump (Diesel) SO2 <0.01 <0.01

EFP-1 EFP-1 Emergency Fire Pump (Diesel) NOx 1.32 0.07

EFP-1 EFP-1 Emergency Fire Pump (Diesel) CO 1.15 0.06

EFP-1 EFP-1 Emergency Fire Pump (Diesel) VOC 1.32 0.07

EFP-1 EFP-1 Emergency Fire Pump (Diesel) Benzene <0.01 <0.01

EFP-1 EFP-1 Emergency Fire Pump (Diesel) Formaldehyde <0.01 <0.01

EFP-1 EFP-1 Emergency Fire Pump (Diesel) CO2e NA 12

EG-1 EG-1 Emergency Generator (Diesel) PM10/2.5 0.33 0.02

EG-1 EG-1 Emergency Generator (Diesel) SO2 0.01 <0.01

EG-1 EG-1 Emergency Generator (Diesel) NOx 10.58 0.53

EG-1 EG-1 Emergency Generator (Diesel) CO 5.79 0.29

EG-1 EG-1 Emergency Generator (Diesel) VOC 10.58 0.53

EG-1 EG-1 Emergency Generator (Diesel) Benzene 0.01 <0.01











EG-1 EG-1 Emergency Generator (Diesel) Formaldehyde <0.01 <0.01

EG-1 EG-1 Emergency Generator (Diesel) CO2e 1171.00 59

RTO-01 RTO-01 Regenerative Thermal Oxidizer 1 PM10/2.5 9.38 30.93

RTO-01 RTO-01 Regenerative Thermal Oxidizer 1 SO2 0.33 1.09

RTO-01 RTO-01 Regenerative Thermal Oxidizer 1 NOx 14.56 48.01

RTO-01 RTO-01 Regenerative Thermal Oxidizer 1 CO 42.11 138.86

RTO-01 RTO-01 Regenerative Thermal Oxidizer 1 VOC 1.21 3.98

RTO-01 RTO-01 Regenerative Thermal Oxidizer 1 Acetaldehyde 0.51 1.68

RTO-01 RTO-01 Regenerative Thermal Oxidizer 1 Formaldehyde 0.55 1.82

RTO-01 RTO-01 Regenerative Thermal Oxidizer 1 Methanol 0.21 0.69

RTO-01 RTO-01 Regenerative Thermal Oxidizer 1 Phenol 0.65 2.15

RTO-01 RTO-01 Regenerative Thermal Oxidizer 1 CO2e NA 224506

SB-1 SB-1 Standby Burner No. 1 PM10/2.5 1.12 0.40

SB-1 SB-1 Standby Burner No. 1 SO2 0.09 0.03

SB-1 SB-1 Standby Burner No. 1 NOx 14.71 5.29











SB-1 SB-1 Standby Burner No. 1 CO 12.35 4.45

SB-1 SB-1 Standby Burner No. 1 VOC 0.81 0.29

SB-1 SB-1 Standby Burner No. 1 Formaldehyde 0.01 <0.01

SB-1 SB-1 Standby Burner No. 1 n-Hexane 0.26 0.10

SB-1 SB-1 Standby Burner No. 1 CO2e NA 6676

RTO-02 RTO-02 Regenerative Thermal Oxidizer 2 PM10/2.5 9.38 30.93

RTO-02 RTO-02 Regenerative Thermal Oxidizer 2 SO2 0.33 1.09

RTO-02 RTO-02 Regenerative Thermal Oxidizer 2 NOx 14.56 48.01

RTO-02 RTO-02 Regenerative Thermal Oxidizer 2 CO 42.11 138.86

RTO-02 RTO-02 Regenerative Thermal Oxidizer 2 VOC 1.21 3.98

RTO-02 RTO-02 Regenerative Thermal Oxidizer 2 Acetaldehyde 0.51 1.68

RTO-02 RTO-02 Regenerative Thermal Oxidizer 2 Formaldehyde 0.55 1.82

RTO-02 RTO-02 Regenerative Thermal Oxidizer 2 Methanol 0.21 0.69

RTO-02 RTO-02 Regenerative Thermal Oxidizer 2 Phenol 0.65 2.15

RTO-02 RTO-02 Regenerative Thermal Oxidizer 2 CO2e NA 224506











SB-2 SB-2 Standby Burner No. 2 PM10/2.5 1.12 0.40

SB-2 SB-2 Standby Burner No. 2 SO2 0.09 0.03

SB-2 SB-2 Standby Burner No. 2 NOx 14.71 5.29

SB-2 SB-2 Standby Burner No. 2 CO 12.35 4.45

SB-2 SB-2 Standby Burner No. 2 VOC 0.81 0.29

SB-2 SB-2 Standby Burner No. 2 Formaldehyde 0.01 <0.01

SB-2 SB-2 Standby Burner No. 2 n-Hexane 0.26 0.10

SB-2 SB-2 Standby Burner No. 2 CO2e NA 6676

RTO-03 RTO-03 Regenerative Thermal Oxider 3 / OSB Press No. 1 PM10/2.5 10.47 36.39

RTO-03 RTO-03 Regenerative Thermal Oxider 3 / OSB Press No. 1 NOx 19.96 69.36

RTO-03 RTO-03 Regenerative Thermal Oxider 3 / OSB Press No. 1 CO 5.22 18.14

RTO-03 RTO-03 Regenerative Thermal Oxider 3 / OSB Press No. 1 VOC 0.48 1.65

RTO-03 RTO-03 Regenerative Thermal Oxider 3 / OSB Press No. 1 Formaldehyde 0.03 0.10

RTO-03 RTO-03 Regenerative Thermal Oxider 3 / OSB Press No. 1 Methanol 0.23 0.80

RTO-03 RTO-03 Regenerative Thermal Oxider 3 / OSB Press No. 1 Phenol 0.94 3.27











RTO-03 RTO-03 Regenerative Thermal Oxider 3 / OSB Press No. 1 CO2e NA 12200

MSS-1 MSS-1 Pneumatic Transfer System Bypass PM10/2.5 905.0 (see Note 1) 0.45 (see Note 2)

MSS-2 MSS-2 Sawmill Bypass PM10/2.5 110.0 (see Note 1) 0.06 (see Note 2)

MSS-3 MSS-3 Dryer Bypass VOC 375.78 (see Note 1) 0.19 (see Note 2)

Notes:(1) This is pound per event.(2) This is tons per event.


Date: Mar-20 Permit No.:

Area Name:



5. Building 6. Height Above

EPN FIN Name Zone East North Height Ground Diameter Velocity Temperature Length Width Axis

(A) (B) (C) (Meters) (Meters) (Ft.) (Ft.) (Ft.) (A) (FPS) (B) (°F) (C) (Ft.) (A) (Ft.) (B) Degrees (C)

PS-05 PS-05 Strander Pneumatic System 15 323819.87 3428353.70 N/A 70.0 3.7 47.4 Ambient N/A N/A N/A

PS-06 PS-06 Former Area Pneumatic System 15 323987.99 3428338.70 N/A 70.0 4.5 52.2 Ambient N/A N/A N/A

PS-07 PS-07 Dry Bin Area Aspiration System 15 323950.49 3428333.53 N/A 70.0 3.7 103.3 Ambient N/A N/A N/A

PS-08 PS-08 Sawline Pneumatic System 15 323977.09 3428151.00 N/A 70.0 4.5 48.6 Ambient N/A N/A N/A

PS-09 PS-09 Fines Aspiration System 15 323976.61 3428332.49 N/A 70.0 3.7 103.3 Ambient N/A N/A N/A

HP HP-1(1) Dry Fuel Transfer System 15 323759.31 3428293.14 N/A N/A N/A N/A NA N/A N/A N/A

HP HP-2(1) Saw Dust Transfer System 15 323759.31 3428293.14 N/A N/A N/A N/A NA N/A N/A N/A

HP HP-3(1) Dry Fines To Fuel 15 323759.31 3428293.14 N/A N/A N/A N/A NA N/A N/A N/A

HP HP-4(1) Dry Fines To Fuel 15 323759.31 3428293.14 N/A N/A N/A N/A NA N/A N/A N/A

HP HP HP-Systems Receiver 15 323759.31 3428293.14 N/A 70.0 2.5 40.0 Ambient N/A N/A N/A

TO-2 TO-2 Standby Thermal Oil Heater 15 323949.82 3428295.13 N/A 50.0 4.0 48.6 655 N/A N/A N/A

PF-03(A) PF-03(A) Edge Seal Booth 15 324057.55 3428086.99 47.7 N/A N/A N/A Ambient N/A N/A N/A

PF-03(B) PF-03(B) Edge Seal Booth 15 324063.95 3428079.36 47.7 N/A N/A N/A Ambient N/A N/A N/A

PF-04(A) PF-04(A) Stencil Area 15 324056.82 3428073.70 47.7 N/A N/A N/A Ambient N/A N/A N/A

PF-04(B) PF-04(B) Stencil Area 15 324063.46 3428072.84 47.7 N/A N/A N/A Ambient N/A N/A N/A

TK-1 TK-1 Diesel Storage Tank 15 323980.15 3428043.36 16.8 10.0 0.167 N/A Ambient N/A N/A N/A

TK-2 TK-2 Gasoline Storage Tank 15 323980.42 3428046.61 16.8 5.0 0.167 N/A Ambient N/A N/A N/A

TK-3 TK-3 Used Oil Storage Tank 15 323977.75 3428049.98 16.8 5.0 0.167 N/A Ambient N/A N/A N/A

Point 7. Stack Exit Data 8. Fugitives

EMISSION POINT DISCHARGE PARAMETERS

4. UTM Coordinates of Emission

CN604724831Corrigan OSB, L.L.C.

1. Emission Point Source



128854, PSDTX1446, GHGPSDTX128 Regulated Entity No.: RN107922510

Customer Reference No.:



Area Name:















TK-4 TK-4 Edge Seal Storage Tank 15 324106.17 3428094.90 47.7 18.0 0.33 N/A Ambient N/A N/A N/A

RO-1 RO-1 Fugitive Dust (Paved Roads) 15 323811.73 3428614.07 N/A N/A N/A N/A N/A N/A N/A N/A

RO-2 RO-2 Fugitive Dust (Unpaved Roads) 15 323625.82 3428562.57 N/A N/A N/A N/A N/A N/A N/A N/A

EFP-1 EFP-1 Emergency Fire Pump (Diesel) 15 323800.77 3428208.57 13.8 11.0 0.417 73.95 223 N/A N/A N/A

EG-1 EG-1 Emergency Generator (Diesel) 15 323874.24 3428290.32 20.8 12.0 0.42 64.141 217 N/A N/A N/A

RTO-01 WESP-1(2) Wet Electrostatic Precipitator No. 1 15 323934.26 3428455.26 N/A N/A N/A N/A N/A N/A N/A N/A

RTO-01 VS-1(2) Venturi Scrubber No. 1 15 323934.26 3428455.26 N/A N/A N/A N/A N/A N/A N/A N/A

RTO-01 RTO-01 Regenerative Thermal Oxidizer 1 15 323934.26 3428455.26 N/A 75.0 9.5 56 295 N/A N/A N/A

RTO-01 RTO (ABORT)-1 Regenerative Thermal Oxidizer 1 Abort Port 15 323932.65 3428428.25 N/A N/A N/A N/A N/A N/A N/A N/A

RTO-01 F-1(2) Furnace for Dryer No. 1 15 323923.86 3428275.71 N/A N/A N/A N/A N/A N/A N/A N/A

RTO-01 SB-1(2) Standby Burner No. 1 15 323925.40 3428298.79 N/A N/A N/A N/A N/A N/A N/A N/A

RTO-02 WESP-2(3) Wet Electrostatic Precipitator No. 2 15 323914.48 3428456.42 N/A N/A N/A N/A N/A N/A N/A N/A

RTO-02 VS-2(3) Venturi Scrubber No. 2 15 323914.48 3428456.42 N/A N/A N/A N/A N/A N/A N/A N/A

RTO-02 RTO-02 Regenerative Thermal Oxidizer 2 15 323914.48 3428456.42 N/A 75.0 9.5 56 295 N/A N/A N/A

RTO-02 RTO (ABORT)-2 Regenerative Thermal Oxidizer 2 Abort Port 15 323912.48 3428429.53 N/A N/A N/A N/A N/A N/A N/A N/A

RTO-02 F-2(3) Furnace for Dryer No. 2 15 323907.32 3428280.13 N/A N/A N/A N/A N/A N/A N/A N/A

RTO-02 SB-2(3) Standby Burner No. 2 15 323908.86 3428303.02 N/A N/A N/A N/A N/A N/A N/A N/A



Area Name:















RTO-03 P-1(4) OSB Press No. 1 15 323992.90 3428241.86 N/A N/A N/A N/A N/A N/A N/A N/A

RTO-03 RTO-03 Regenerative Thermal Oxidizer 3 15 323992.90 3428241.86 N/A 85.0 7 69 273 N/A N/A N/A

MSS-1 MSS-1 Pneumatic Transfer System Bypass 15 323769.28 3428285.40 N/A 22.0 3.6 19.5 Ambient N/A N/A N/A

MSS-2 MSS-2 Sawmill Bypass 15 323964.41 3428138.68 N/A 24.0 4.5 48.6 Ambient N/A N/A N/A

MSS-3 MSS-3 Dryer Bypass 15 323942.35 3428447.28 N/A 75.0 9.5 56 295 N/A N/A N/A

Notes:(1) The emission source for this equipment is HP - Systems Receiver.(2) The emission source for this equipment is RTO-01, Regenerative Thermal Oxidizer No. 1.(3) The emission source for this equipment is RTO-02, Regenerative Thermal Oxidizer No. 2.(4) The emission source for this equipment is RTO-03, Regenerative Thermal Oxidizer No. 3.


Table 2

Material Balance

TCEQ-10155 (APDG 6194v3, Revised 06/16) Table 2 This form is for use by facilities subject to air quality permit requirements and may be revised periodically. Page 1 of 1

Texas Commission on Environmental Quality Table 2

Material Balance

This material balance table is used to quantify possible emissions of air contaminants and special emphasis should be placed on potential air contaminants, for example: If feed contains sulfur, show distribution to all products. Please relate each material (or group of materials) listed to its respective location in the process flow diagram by assigning emission point numbers (taken from the flow diagram) to each material.

List every material involved in each of the following groups

Emission Point No. from Flow Diagram

Process Rate1 Check appropriate column at right to indicate process rate method.

Measurement Estimation Calculation

Raw Materials – Input Logs

1

Fuels – Input Bark/Wood Waste Natural Gas

2 3

250 MMBTUH 210 MMBTUH

Products and By-Products – Output OSB

4

900 MSF 3/8 in/yr

Solid Wastes – Output N/A

Liquid Wastes – Output N/A

Airborne Waste (Solid) - Output All emission sources included in PFD

Appendix A X

Airborne Wastes (Gaseous) - Output All emission sources included in PFD

Appendix A X

1 Specify the process rate of the facility using conventional engineering units (e.g., bbl/d, lb/yr, SCFM), and indicate the units next to each number. Standard Conditions: are 68F 14.7 psia (30 Texas Administrative Code, Section 101.1(99).

Table 1F

Air Quality Application Supplement

Table 2F

Project Emission Increase

Projected Actual

Emissions

Difference (B-

A)6Correction7 Project

Increase8

1. -0.07 0 -0.072. -1.45 0 -1.453. -1.45 0 -1.454 -18.24 0 -18.245.

6.

7.

8.

9.

0 -21.21

Explanation: As per the TCEQ Major New Source Review- Applicability determination: 1) The facilities associated with project are considered new for PSD evaluation as it has operated for less than two years. 2) Baseline Actual Emission Rate- For an existing facility that has less than two years of operating history (from the date of initial operation of the facility), the baseline actual emission rate may be taken as the current allowable rate or the PTE of the facility. The baseline actual emission rate for the proposed project is equal to the current allowable MAERT emission rate. 3) Project Actual Emissions : Projected Actual Emissions from the proposed project is assumed to be equal to the Proposed PTE as the facilities asscociated with the project has operated for less than 2 years and require additional record keeping

Page Subtotal9

1 Individual Table 2F=s should be used to summarize the project emission increase for each criteria pollutant2 Emission Point Number as designated in NSR Permit or Emissions Inventory3 All records and calculations for these values must be available upon request4 Correct actual emissions for currently applicable rule or permit requirements, and periods of non-compliance. These corrections, as well as any MSS previously demonstrated under 30 TAC 101, should be explained in the Table 2F supplement5 If projected actual emission is used it must be noted in the next column and the basis for the projection identified in the Table 2F supplement6 Proposed Emissions (column B) minus Baseline Emissions (column A)7 Correction made to emission increase for what portion could have been accommodated during the baseline period. The justification and basis for this estimate must be provided in the Table 2F supplement8 Obtained by subtracting the correction from the difference. Must be a positive number.9 Sum all values for this page. 10 Type of note. Generally would be baseline adjustment, basis for projected actual, or basis for correction (what could have been accommodated).

Pollutant: NOX Line 1 thru 4 Type10

48.01

RTO-3 RTO-3 128854 0 87.6 69.36

RTO-2 RTO-2 128854 0 49.46

2.05

RTO-1 RTO-1 128854 0 49.46 48.01

TO-2 TO-2 128854 0 2.12

Baseline Period: NA

A B

Table 2FProject Emission Increase

Affected or Modified Facilities2 FIN EPN

Permit No. Actual Emissions3 Baseline

Emissions4

Proposed

Emissions5

Pollutant1: Permit:NOx 128854

Projected Actual

Emissions

Difference (B-


Increase8

1. - -11.21 0 -11.212. - -11.21 0 -11.213. - -16.61 0 -16.614 - 0.07 0 0.075.

6.

7.

8.

9.

0 -38.96


Pollutant1: VOC Permit: 128854

3.98

Baseline Period: NA

A B



Emissions4

Proposed

Emissions5

RTO-1 RTO-1 128854 0 15.19

1.65

RTO-2 RTO-2 128854 0 15.19 3.98

RTO-3 RTO-3 128854 0 18.26

MSS-3 MSS-3 128854 0 0.12 0.19

-



Page Subtotal9

Pollutant: VOC Line 1 thru 4 Type10

Projected Actual

Emissions

Difference (B-


Increase8

1. - -146.16 0 -146.162. - -146.16 0 -146.163. - 11.18 0 11.184

5.

6.

7.

8.

9.

0 -281.14


Pollutant1: CO Permit: 128854

138.86

Baseline Period: NA

A B



Emissions4

Proposed

Emissions5

RTO-1 RTO-1 128854 0 285.02

18.14

RTO-2 RTO-2 128854 0 285.02 138.86

RTO-3 RTO-3 128854 0 6.96

-



Page Subtotal9

Pollutant: CO Line 1 thru 4 Type10

Projected Actual

Emissions

Difference (B-


Increase8

1. - -0.8 0 -0.82. - -0.8 0 -0.83.

4

5.

6.

7.

8.

9.

0 -1.6


Pollutant1: SO2 Permit: 128854

1.09

Baseline Period: NA

A B



Emissions4

Proposed

Emissions5

RTO-1 RTO-1 128854 0 1.89

RTO-2 RTO-2 128854 0 1.89 1.09

-



Page Subtotal9

Pollutant: SO2 Line 1 thru 4 Type10

Actual

Emissions3

Projected Actual

Emissions

Difference (B-


Increase8

1. 0 - 17.7 0 17.72. 0 - 17.7 0 17.73. 0 - -5.46 0 -5.464 0 - 5.23 0 5.235.

6.

7.

8.

9. -

0 35.17


Pollutant1: PM Permit: 128854

Baseline Period: NA

A B


Permit No. Baseline

Emissions4

Proposed

Emissions5

RTO-1 RTO-1 128854 13.23 30.93

RTO-2 RTO-2 128854 13.23 30.93

RTO-3 RTO-3 128854 41.85 36.39

PS-10 PS-10 128854 0 5.23

Explanation: As per the TCEQ Major New Source Review- Applicability determination: 1) The facilities associated with project are considered new for PSD evaluation as it has operated for less than two years. 2) Baseline Actual Emission Rate- For an existing facility that has less than two years of operating history (from the date of initial operation of the facility), the baseline actual emission rate may be taken as the current allowable rate or the PTE of the facility. The baseline actual emission rate for the proposed project is equal to the current allowable MAERT emission rate. 3) Project Actual Emissions : Projected Actual Emissions from the proposed project is assumed to be equal to the Proposed PTE as the facilities asscociated with the project has 1 Individual Table 2F=s should be used to summarize the project emission increase for each criteria pollutant2 Emission Point Number as designated in NSR Permit or Emissions Inventory3 All records and calculations for these values must be available upon request4 Correct actual emissions for currently applicable rule or permit requirements, and periods of non-compliance. These corrections, as well as any MSS previously demonstrated under 30 TAC 101, should be explained in the Table 2F supplement5 If projected actual emission is used it must be noted in the next column and the basis for the projection identified in the Table 2F supplement6 Proposed Emissions (column B) minus Baseline Emissions (column A)7 Correction made to emission increase for what portion could have been accommodated during the baseline period. The justification and basis for this estimate must be provided in the Table 2F supplement8 Obtained by subtracting the correction from the difference. Must be a positive number.9 Sum all values for this page. 10 T f t G ll ld b b li dj t t b i f j t d t l b i f ti ( h t ld h b d t d)

Page Subtotal9

Pollutant: PM Line

Actual

Emissions3

Projected Actual

Emissions

Difference (B-


Increase8

1. 0 - 17.7 0 17.72. 0 - 17.7 0 17.73. 0 - -5.46 0 -5.464 0 - 5.23 0 5.235.6.7.8.9. -

0 35.17


Pollutant1: PM10 Permit: 128854

Baseline Period: NA A B


Permit No. Baseline

Emissions4

Proposed

Emissions5

RTO-1 RTO-1 128854 13.23 30.93

RTO-2 RTO-2 128854 13.23 30.93

RTO-3 RTO-3 128854 41.85 36.39

PS-10 PS-10 128854 0 5.23

Explanation: As per the TCEQ Major New Source Review- Applicability determination: 1) The facilities associated with project are considered new for PSD evaluation as it has operated for less than two years. 2) Baseline Actual Emission Rate- For an existing facility that has less than two years of operating history (from the date of initial operation of the facility), the baseline actual emission rate may be taken as the current allowable rate or the PTE of the facility. The baseline actual emission rate for the proposed project is equal to the current allowable MAERT emission rate. 3) Project Actual Emissions : Projected Actual Emissions from the proposed project is assumed to be equal to the Proposed PTE as the facilities asscociated with the project 1 Individual Table 2F=s should be used to summarize the project emission increase for each criteria pollutant2 Emission Point Number as designated in NSR Permit or Emissions Inventory3 All records and calculations for these values must be available upon request4 Correct actual emissions for currently applicable rule or permit requirements, and periods of non-compliance. These corrections, as well as any MSS previously demonstrated under 30 TAC 101, should be explained in the Table 2F supplement5 If projected actual emission is used it must be noted in the next column and the basis for the projection identified in the Table 2F supplement6 Proposed Emissions (column B) minus Baseline Emissions (column A)7 Correction made to emission increase for what portion could have been accommodated during the baseline period. The justification and basis for this estimate must be provided in the Table 2F supplement8 Obtained by subtracting the correction from the difference. Must be a positive number.9 Sum all values for this page. 10

Page Subtotal9

Pollutant: PM10 Line Type10

Projected Actual

Emissions

Difference (B-


Increase8

1. - 17.7 0 17.72. - 17.7 0 17.73. - -5.46 0 -5.464 - 5.23 0 5.235.

6.

7.

8.

9.

0 35.17


Pollutant1: PM2.5 Permit: 128854

30.93

Baseline Period: NA

A B



Emissions4

Proposed

Emissions5

RTO-1 RTO-1 128854 0 13.23

36.39

RTO-2 RTO-2 128854 0 13.23 30.93

RTO-3 RTO-3 128854 0 41.85

PS-10 PS-10 128854 0 0 5.23

-



Page Subtotal9

Pollutant: PM2.5 Line 1 thru 4 Type10

Projected Actual

Emissions

Difference (B-


Increase8

1. - -5090 0 -50902. - -5090 0 -50903. - -5935 0 -59354

5.

6.

7.

8.

9.

0 -16115


Pollutant1: CO2e Permit: 128854

224506

Baseline Period: NA

A B



Emissions4

Proposed

Emissions5

RTO-1 RTO-1 128854 0 229596

12200

RTO-2 RTO-2 128854 0 229596 224506

RTO-3 RTO-3 128854 0 18135

-

Explanation: As per the TCEQ Major New Source Review- Applicability determination: 1) The facilities associated with project are considered new for PSD evaluation as it has operated for less than two years. 2) Baseline Actual Emission Rate- For an existing facility that has less than two years of operating history (from the date of initial operation of the facility), the baseline actual emission rate may be taken as the current allowable rate or the PTE of the facility. The baseline actual emission rate for the proposed project is equal to the current allowable MAERT emission rate. 3) Project Actual Emissions : Projected Actual Emissions from the proposed project is assumed to be equal to the Proposed PTE as the facilities asscociated with the project has operated for less than 2 years and require additional record keeping1 Individual Table 2F=s should be used to summarize the project emission increase for each criteria pollutant2 Emission Point Number as designated in NSR Permit or Emissions Inventory3 All records and calculations for these values must be available upon request4 Correct actual emissions for currently applicable rule or permit requirements, and periods of non-compliance. These corrections, as well as any MSS previously demonstrated under 30 TAC 101, should be explained in the Table 2F supplement5 If projected actual emission is used it must be noted in the next column and the basis for the projection identified in the Table 2F supplement6 Proposed Emissions (column B) minus Baseline Emissions (column A)7 Correction made to emission increase for what portion could have been accommodated during the baseline period. The justification and basis for this estimate must be provided in the Table 2F supplement8 Obtained by subtracting the correction from the difference. Must be a positive number.9 Sum all values for this page. 10 Type of note. Generally would be baseline adjustment, basis for projected actual, or basis for correction (what could have been accommodated).

Page Subtotal9

Pollutant: GHG Line 1 thru 4 Type10

Pollutant

Project Emission

Increases Only (tpy)

Net Emissions

Increase (NEI)

(tpy)

PSD de

minimis Level

(tpy)

PSD de minimis

Level Exceeded

(yes/no)?

PM 35.17 35.17 25 YES

PM10 35.17 35.17 15 YES

PM2.5 35.17 35.17 10 YES

NOx -21.21 -21.21 40 NO

CO -281.14 -281.14 100 NO

O3(1) -38.96 -38.96 40 NO

SO2 -1.60 -1.60 40 NO

CO2e -16115.00 -16115.00 75000 NO

(1) 40 TPY of volatile organic compounds (VOC) or nitrogen oxides (NOx).

Table 3 NSR Applicability Analysis/Significant Increase

Table 3F

Project Contemporaneous Changes

B

Permit No. Project Name or Activity

Proposed Emissions (tons/year)4

Difference (A-B)6

Creditable Decrease or Increase7

1. 2020 RTO-1 RTO-1 128854 2020 Modification 30.93 17.7 17.7


3. 2020 RTO-3 RTO-3 128854 2020 Modification 36.39 -5.46 -5.46

4. 2020 PS-10 PS-10 128854 2020 Modification 5.23 5.23 5.23

5.

6.

7.

8.

9.

10.

35.17

35.17

TABLE 3FPROJECT CONTEMPORANEOUS CHANGES1

Company: Corrigan OSB, L.L.C

Permit Application Number: 128854 Criteria Pollutant: PM

A

Project Date2 Facility at Which Emission Change Occurred3

FIN EPN

Baseline Period (years)

Baseline Emissions (tons/year)5

N/A 13.23

N/A 13.23

N/A 41.85

N/A 0

1 Individual Table 3F=s should be used to summarize the project emission increase and net emission increase for each criteria pollutant.2 The start of operation date for the modified or new facilities. Attach Table 4F for each project reduction claimed.3 Emission Point No. as designated in NSR Permit or Emissions Inventory.4 All records and calculations for these values must be available upon request. 5 All records and calculations for these values must be available upon request. 6 Proposed (column A) - Baseline (column B).7 If portion of the decrease not creditable, enter creditable amount.8 Sum all values for this page.TCEQ - 10156(Revised 03/12) Table 3FThese forms are for use by facilities subject to air quality permit requirements and maybe revised periodically. (APDG 5913v2) Page of

Page Subtotal8

Summary of Contemporaneous Changes Total

B



Difference (A-B)6






5.

6.

7.

8.

9.

10.

35.17

35.17

A



Permit Application Number: 128854 Criteria Pollutant: PM10


FIN EPN



N/A 13.23

N/A 13.23

N/A 41.85

N/A 0


Page Subtotal8


B



Difference (A-B)6






5.

6.

7.

8.

9.

10.

35.17

35.17

A



Permit Application Number: 128854 Criteria Pollutant: PM2.5


FIN EPN



N/A 13.23

N/A 13.23

N/A 41.85

N/A 0


Page Subtotal8


Table 11

Fabric Filters

TCEQ - 10179 (APDG 5981v3, Revised 10/18) Table 11This form is for use by facilities subject to air quality permit requirementsand may be revised periodically. Page 3 of 4

Texas Commission on Environmental QualityTable 11

Fabric Filters

Tables, checklists, and guidance documents pertaining to air quality permits are available from the Texas Commission on Environmental Quality (TCEQ) Air Permits Division (APD) website atwww.tceq.texas.gov/permitting/air.

A. Emission Point Number (EPN) and Emission Point Name

EPN: Emission Point Name:

B. Manufacturer and Model Numbers (No.)

Manufacturer No.: Model No.:

C Name of Source(s) or Equipment Being Controlled

Name EPN FIN

D. Type of Particulate Controlled

E. Gas Stream Characteristics

Design Maximum Average ExpectedFlow Rate

(acfm)

Gas StreamTemperature (oF)

Particulate Grain Loading(grain/scf)

Inlet: Outlet:

Pressure Drop(inches of H2O

Water Vapor Content of Effluent Stream(lb water/lb dry air)

Fan Requirements

hp: ft3/min.:

F. Particulate Distribution (By Weight)

Micron Range Inlet % Outlet %

0.0-0.5

0.5-1.0

1.0-5.0

5-10

10-20

over 20

G. Filter Characteristics

Filtering Velocity(acfm/ft2 of Cloth)

Bag Diameter (inches) Bag Length (feet) Total Number of Bags

PS-10 Sand & Tongue and Groove AS

Reverse Air Baghouse Aircon 16RAB412-10

Sand & Tongue and Groove AS PS-10 PS-10

PM PM10 PM2.5

48720 46400 Ambient 5 0.003

0.5 to 5 (3 average) 0.01 300 46400

< 1% 54%

approximately 1% 32%

6% 11%

13% 2%

25% <1%

55% <1%

7.48 5.75 10 412

TCEQ - 10179 (APDG 5981v3, Revised 10/18) Table 11This form is for use by facilities subject to air quality permit requirementsand may be revised periodically. Page 4 of 4

Texas Commission on Environmental QualityTable 11

Fabric Filters

H. Bag Rows

Indicate the arrangement of the baghouse bag filter rows. Staggered Straight

I. Walkways

Will walkways be provided between banks of bags? YES NO

J. Filtering Material

Identify the filtering media:

Any additional coating or treatment of the baghouse material:

K. Cleaning of the Filter(s)

Describe Bag Cleaning Method and Cycle:

L. Cost

Capital Installed Cost:

Annual Operating Cost:

Note: Attach the details regarding the principle of operation and an assembly drawing (front and top view) of the abatement device drawn to scale clearly showing the design, size and shape.If the device has bypasses, safety valves, etc., include in the drawing and specify when such bypasses are to be used and under what conditions.

16 oz polyester high efficiency mircrodenier bags

144,600

TCEQ NSR Workbook

Texas Commission on Environmental Quality

Form PI-1 General ApplicationGeneral

Date: ____________Permit #: ____________

Company: ____________

I agree

ZIP Code: 70809

First Name: Karen

8591 United Plaza Blvd.,Address Line 2:

225-755-1000

D. Assigned Numbers

CN604724831Enter the CN. The CN is a unique number given to each business, governmental body, association, individual, or other entity that owns, operates, is responsible for, or is affiliated with a regulated entity.

Telephone Number:Fax Number:Email Address: [email protected]

The CN and RN below are assigned when a Core Data Form is initially submitted to the Central Registry. The RN is also assigned if the agency has conducted an investigation or if the agency has issued an enforcement action. If these numbers have not yet been assigned, leave these questions blank and include a Core Data Form with your application submittal. See Section VI.B. below for additional information.

I. Applicant Information

Texas Secretary of State Charter/Registration Number (if given):

C. Technical Contact Information: This person must have the authority to make binding agreements and representations on behalf of the applicant and may be a consultant. Additional technical contact(s) can be provided in a cover letter.

A. Company Information

B. Company Official Contact Information: must not be a consultantPrefix (Mr., Ms., Dr., etc.): Mrs.First Name: Natalie Last Name: MonroeTitle: Corporate Environmental Manager

Permits are issued to either the facility owner or operator, commonly referred to as the applicant or permit holder. List the legal name of the company, corporation, partnership, or person who is applying for the permit. We will verify the legal name with the Texas Secretary of State at (512) 463-5555 or at:

Company or Legal Name:

802868924

Corrigan OSB, L.L.C

Mailing Address: 2189 Memorial Drive

City:

ZIP Code:

Alexandria

Last Name:

City: Baton RougeState: LA

Company or Legal Name: CK Associates

318-473-2624Email Address: [email protected]

Address Line 2:

BlakemoreTitle:

State:

318-483-3807Fax Number:

https://www.sos.state.tx.us

Suite 300

Senior Environmental Scientist

Mailing Address:

Prefix (Mr., Ms., Dr., etc.): Ms.

71301Telephone Number:

LA

I acknowledge that I am submitting an authorized TCEQ application workbook and any necessary attachments. Except for inputting the requested data and adjusting row height and column width, I have not changed the TCEQ application workbook in any way, including but not limited to changing formulas, formatting, content, or protections.

Version 4.0 Page 1



Date: ____________Permit #: ____________

Company: ____________

No

Major Modification

NSR 128854

PSDTX1446

Select from the drop-down the type of action being requested for each permit type. If that permit type does not apply, you MUST select "Not applicable".

Provide all assigned permit numbers relevant for the project. Leave blank if the permit number has not yet been assigned.

https://www.tceq.texas.gov/permitting/air/guidance/authorize.html

Amendment

Permit Type

A. Permit and Action Type (multiple may be selected, leave no blanks)

Special Permit: Not applicable, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Alteration, Extension to Start of Construction

III. Permit Information

De Minimis: Not applicable, Initial Not applicable

Not applicable

PSD: Not applicable, Initial, Major Modification

This cell intentionally left blank

Minor NSR (can be a Title V major source): Not applicable, Initial, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Relocation/Alteration, Change of Location, Alteration, Extension to Start of Construction

Additional information regarding the different NSR authorizations can be found at:

RN107922510

Nonattainment: Not applicable, Initial, Major Modification

Flexible: Not applicable, Initial, Amendment, Renewal, Renewal Certification, Renewal/Amendment, Alteration, Extension to Start of Construction

Not applicable

Action Type Requested(do not leave blank)

Does the applicant have unpaid delinquent fees and/or penalties owed to the TCEQ?This form will not be processed until all delinquent fees and/or penalties owed to the TCEQ or the Office of the Attorney General on behalf of the TCEQ are paid in accordance with the Delinquent Fee and Penalty Protocol. For more information regarding Delinquent Fees and Penalties, go to the TCEQ Web site at:

https://www.tceq.texas.gov/agency/financial/fees/delin

II. Delinquent Fees and Penalties


Not applicable

Permit Number (if assigned)

GHGPSDTX128

Enter the RN. The RN is a unique agency assigned number given to each person, organization, place, or thing that is of environmental interest to us and where regulated activities will occur. The RN replaces existing air account numbers. The RN for portable units is assigned to the unit itself, and that same RN should be used when applying for authorization at a different location.

HAP Major Source [FCAA § 112(g)]: Not applicable, Initial, Major ModificationPAL: Not applicable, Initial, Amendment, Renewal, Renewal/Amendment, AlterationGHG PSD: Not applicable, Initial, Major Modification, Voluntary Update

Not applicable

Voluntary Update

Not applicable

Version 4.0 Page 2



Date: ____________Permit #: ____________

Company: ____________

No

No

Yes

No

D. Incorporation of Standard Permits, Standard Exemptions, and/or Permits By Rule (PBR)

E. Associated Federal Operating Permits

GHG projects: List the non-GHG applications (pending or being submitted) that are associated with the project. Note: All preconstruction authorizations (including authorization for emissions of greenhouse gases, if applicable) must be obtained prior to start of construction.

No

Will NSR permits be consolidated into this permit with this action?

No

Will this permit be consolidated into another NSR permit with this action?

To ensure protectiveness, previously issued authorizations (standard permits, standard exemptions, or PBRs) including those for MSS, are incorporated into a permit either by consolidation or by reference. At the time of renewal and/or amendment, consolidation (in some cases) may be voluntary and referencing is mandatory. More guidance regarding incorporation can be found in 30 TAC § 116.116(d)(2), 30 TAC § 116.615(3) and in this memo:

https://www.tceq.texas.gov/assets/public/permitting/air/memos/pbr_spc06.pdf

C. Consolidating NSR Permits

NSR 128854, PSD TX1446, 03779

How are/will MSS activities for sources associated with this project be authorized?

This permit

Are there any standard permits, standard exemptions, or PBRs to be incorporated by reference?

Is a SOP or GOP review pending for this source, area, or site?

Are there any PBR, standard exemptions, or standard permits associated to be incorporated by consolidation? Note: Emission calculations, a BACT analysis, and an impacts analysis must be attached to this application at the time of submittal for any authorization to be incorporated by consolidation.

B. MSS Activities

Is this facility located at a site required to obtain a site operating permit (SOP) or general operating permit (GOP)?

Version 4.0 Page 3



Date: ____________Permit #: ____________

Company: ____________

No

Corrigan

No

Corrigan OSB

D. Industry Type

1923 HWY 287

Oriented Strand Board Mill

75939

Street Address:

094:49:36

Site Location Description: If there is no street address, provide written driving directions to the site. Identify the location by distance and direction from well-known landmarks such as major highway intersections.

A. LocationIV. Facility Location and General Information

TCEQ Region Region 10

030:58:35

Use USGS maps, county maps prepared by the Texas Department of Transportation, or an online software application such as Google Earth to find the latitude and longitude.

C. Portable FacilityPermanent

Polk

Area Name: Must indicate the general type of operation, process, equipment or facility. Include numerical designations, if appropriate. Examples are Sulfuric Acid Plant and No. 5 Steam Boiler. Vague names such as Chemical Plant are not acceptable.

County attainment status as of Sept. 23, 2019

O3779


Is this a project for a lead smelter, concrete crushing facility, and/or a hazardous waste management facility?

County: Enter the county where the facility is physically located.

attainment or unclassified for all pollutants

Permanent or portable facility?

B. General Information

If required to obtain a SOP or GOP, list all associated permit number(s). If no associated permit number has been assigned yet, enter "TBD":

Site Name:

Are there any schools located within 3,000 feet of the site boundary?

City: If the address is not located in a city, then enter the city or town closest to the facility, even if it is not in the same county as the facility.ZIP Code: Include the ZIP Code of the physical facility site, not the ZIP Code of the applicant's mailing address.

Longitude (in degrees, minutes, and nearest second (DDD:MM:SS)) for the street address or the destination point of the driving directions. Longitude is the angular distance of a location west of the prime meridian and will always be between 93 and 107 degrees west (W) in Texas.

Latitude (in degrees, minutes, and nearest second (DDD:MM:SS)) for the street address or the destination point of the driving directions. Latitude is the angular distance of a location north of the equator and will always be between 25 and 37 degrees north (N) in Texas.

Version 4.0 Page 4



Date: ____________Permit #: ____________

Company: ____________

Yes

Yes

Yes

No

No


C. Enforcement ProjectsProjected Start of Operation:

James White & Trent Ashby

2493Principal SIC code:

District: 3

B. Project Timing

A. DescriptionV. Project Information

19 and 57District:State Representative:


VI. Application Materials

https://www.tceq.texas.gov/assets/public/permitting/centralregistry/10400.docx

A. Confidential Application MaterialsIs confidential information submitted with this application?

https://www.naics.com/sic-codes-industry-drilldown/

Principal Company Product/Business:

Authorization must be obtained for many projects before beginning construction. Construction is broadly interpreted as anything other than site clearance or site preparation. Enter the date as "Month Date, Year" (e.g. July 4, 1776).

Will sources in this project be authorized to operate 8760 hours per year?

Reconciliation of emissions from RTO-1, RTO-2 and RTO-3 based on current production data and stack test results. Addition of a new source PS-10. Update emissions from combustion sources. See Project Description for more information. Corrigan is requesting expedited processing to revise permitted emission rates and address enforcement action and will submit that request separately.

Is this application in response to, or related to, an agency investigation, notice of violation, or enforcement action?

June 1, 2020

Provide a brief description of the project that is requested. (Limited to 500 characters).

A list of SIC codes can be found at:

B. Is the Core Data Form (Form 10400) attached?

All representations regarding construction plans and operation procedures contained in the permit application shall be conditions upon which the permit is issued. (30 TAC § 116.116)

State Senator:

NAICS codes and conversions between NAICS and SIC Codes are available at:

Robert Nichols

https://www.census.gov/eos/www/naics/

E. State Senator and Representative for this site

https://wrm.capitol.texas.gov/This information can be found at (note, the website is not compatible to Internet Explorer):

Oriented Strand Board Mill

321219Principal NAICS code:

D. Operating Schedule

Projected Start of Construction: May 1, 2020

If yes, did you attach copies of any correspondence from the agency and provide the RN associated with the investigation, notice of violation, or enforcement action?

Version 4.0 Page 5



Date: ____________Permit #: ____________

Company: ____________

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

YesYes

Is the area map a current map with a true north arrow, an accurate scale, the entire plant property, the location of the property relative to prominent geographical features including, but not limited to, highways, roads, streams, and significant landmarks such as buildings, residences, schools, parks, hospitals, day care centers, and churches?

Are emission rates and associated calculations for planned MSS facilities and related activities attached?

J. Is a discussion of state regulatory requirements attached, addressing 30 TAC Chapters 101, 111, 112, 113, 115, and 117?For all applicable chapters, does the discussion include how the facility will comply with the requirements of the chapter?For all not applicable chapters, does the discussion include why the chapter is not applicable?K. Are all other required tables, calculations, and descriptions attached?

I. Is a list of MSS activities attached?

D. Is a plot plan attached?Does your plot plan clearly show a north arrow, an accurate scale, all property lines, all emission points, buildings, tanks, process vessels, other process equipment, and two bench mark locations?

Does your plot plan identify all emission points on the affected property, including all emission points authorized by other air authorizations, construction permits, PBRs, special permits, and standard permits?Did you include a table of emission points indicating the authorization type and authorization identifier, such as a permit number, registration number, or rule citation under which each emission point is currently authorized?E. Is a process flow diagram attached?Is the process flow diagram sufficiently descriptive so the permit reviewer can determine the raw materials to be used in the process; all major processing steps and major equipment items; individual emission points associated with each process step; the location and identification of all emission abatement devices; and the location and identification of all waste streams (including wastewater streams that may have associated air emissions)?

F. Is a process description attached?Does the process description emphasize where the emissions are generated, why the emissions must be generated, what air pollution controls are used (including process design features that minimize emissions), and where the emissions enter the atmosphere?

Are the MSS activities listed and discussed separately, each complete with the authorization mechanism or emission rates, frequency, duration, and supporting information if authorized by this permit?

G. Are detailed calculations attached? Calculations must be provided for each source with new or changing emission rates. For example, a new source, changing emission factors, decreasing emissions, consolidated sources, etc. You do not need to submit calculations for sources which are not changing emission rates with this project. Please note: the preferred format is an electronic workbook (such as Excel) with all formulas viewable for review. It can be emailed with the submittal of this application workbook.

Does the process description also explain how the facility or facilities will be operating when the maximum possible emissions are produced?

C. Is a current area map attached?

Does the map show a 3,000-foot radius from the property boundary?

Table 2 (Form 10155), entitled Material Balance: A material balance representation may be required for all applications to confirm technical emissions information. Typically this is required for refining and chemical manufacturing processes involving reactions, separations, and blending. It may also be requested by the permit reviewer for other applications. Table 2 should represent the total material balance; that is, all streams into the system and all streams out. Additional sheets may be attached if necessary. Complex material balances may be presented on spreadsheets or indicated using process flow diagrams. All materials in the process should be addressed whether or not they directly result in the emission of an air contaminant. All production rates must be based on maximum operating conditions.

H. Is a material balance (Table 2, Form 10155) attached?

Version 4.0 Page 6


Form PI-1 General ApplicationTechnical

Date: ____________Permit #: ____________

Company: ____________

Yes

Yes

No

No

I. Additional Questions for Specific NSR Minor Permit Actions

Do NESHAP subpart(s) apply to a facility in this application?

No

C. Title 40 CFR Part 63

Yes

List applicable subparts you will demonstrate compliance with (e.g. Subpart M)

A, Dc, IIII

https://www.tceq.texas.gov/toxicology/apwl/apwl.htmlIs the proposed facility located in a watch list area?

VIII. Federal Regulatory QuestionsIndicate if any of the following requirements apply to the proposed facility. Note that some federal regulations apply to minor sources. Enter all applicable Subparts.

List applicable subparts you will demonstrate compliance with (e.g. Subpart VVVV)

A, ZZZZ, CCCCCC

Do MACT subpart(s) apply to a facility in this application?

Yes

A. Title 40 CFR Part 60Do NSPS subpart(s) apply to a facility in this application?


VII. Greenhouse Gas PermitsA. Voluntary UpdatesDoes the request change values on the current MAERT, stack parameter representations (including location), changes to BACT, and/or changes to monitoring requirements?

B. Title 40 CFR Part 61

Does this project require an impacts analysis?


IX. Emissions ReviewA. Impacts AnalysisAny change that results in an increase in off-property concentrations of air contaminants requires an air quality impacts demonstration. Information regarding the air quality impacts demonstration must be provided with the application and show compliance with all state and federal requirements. Detailed requirements for the information necessary to make the demonstration are listed on the Impacts sheet of this workbook.


B. Disaster ReviewIf the proposed facility will handle sufficient quantities of certain chemicals which, if released accidentally, would cause off-property impacts that could be immediately dangerous to life and health, a disaster review analysis may be required as part of the application. Contact the appropriate NSR permitting section for assistance at (512) 239-1250. Additional Guidance can be found at:https://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/disrev-factsheet.pdfDoes this application involve any air contaminants for which a disaster review is required?

C. Air Pollutant Watch ListCertain areas of the state have concentrations of specific pollutants that are of concern. The TCEQ has designated these portions of the state as watch list areas. Location of a facility in a watch list area could result in additional restrictions on emissions of the affected air pollutant(s) or additional permit requirements. The location of the areas and pollutants of interest can be found at:

Version 4.0 Page 1


Form PI-1 General ApplicationTechnical

Date: ____________Permit #: ____________

Company: ____________

No

D. Mass Emissions Cap and TradeIs this facility located at a site within the Houston/Galveston nonattainment area (Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, and Waller Counties)?

Version 4.0 Page 2


Form PI-1 General ApplicationUnit Types - Emission Rates

Date: ____________Permit #: ____________

Company: ____________

Action Requested (only 1 action per FIN)

Include these emissions in annual (tpy) summary?

Facility ID Number (FIN)

Emission Point Number (EPN) Source Name Pollutant

Current Short-Term (lb/hr)

Current Long-Term (tpy)

ConsolidatedCurrent Short-Term (lb/hr)

Consolidated Current Long-Term (tpy)

Proposed Short-Term (lb/hr)

Proposed Long-Term (tpy)

Short-Term Difference (lb/hr)

Long-Term Difference (tpy)

Unit Type (Used for reviewing BACT and Monitoring Requirements)

Unit Type Notes (only if "other" unit type in Column O)

Not New/Modified Yes PS-05 PS-05Strander Pneumatic System Baghouse Stack

PM 0.77 3.38 0.77 3.38 0 0 Control: Bag Filter/Baghouse

PM10 0.77 3.38 0.77 3.38 0 0PM2.5 0.77 3.38 0.77 3.38 0 0

Not New/Modified Yes PS-06 PS-06Former Area Aspiration System Baghouse Stack


PM10 1.28 5.61 1.28 5.61 0 0PM2.5 1.28 5.61 1.28 5.61 0 0

Not New/Modified Yes PS-07 PS-07Dry Bin Area Aspiration System Baghouse Stack


PM10 0.76 3.32 0.76 3.32 0 0PM2.5 0.76 3.32 0.76 3.32 0 0

Not New/Modified Yes PS-08 PS-08Sawline Pneumatic System Baghouse Stack


PM10 1.19 5.23 1.19 5.23 0 0PM2.5 1.19 5.23 1.19 5.23 0 0

Not New/Modified Yes PS-09 PS-09Fines Aspiration System Baghouse Stack


PM10 1.39 6.09 1.39 6.09 0 0PM2.5 1.39 6.09 1.39 6.09 0 0

Not New/Modified Yes HP HPHigh Pressure System Received Cyclone Stack


PM10 0.3 1.33 0.3 1.33 0 0PM2.5 0.3 1.33 0.3 1.33 0 0

New/Modified Yes TO-2 TO-2Standby Thermal Oil Heater (60 MMBTUH Stack)

VOC 0.32 0.12 0.32 0.12 0 0 Heater > 40 MMBtu/hr

NOx 5.88 2.12 5.69 2.05 -0.1899 -0.07SO2 0.04 0.01 0.04 0.01 0 0PM 0.45 0.16 0.45 0.16 0 0PM10 0.45 0.16 0.45 0.16 0 0PM2.5 0.45 0.16 0.45 0.16 0 0CO 4.94 1.78 4.94 1.78 0 0HAPs 0.45 0.06 0.11 0.04 -0.34 -0.02CH4 1 1 0 0CO2 2,541 2541 0 0CO2 Equivalent 2,864 2864 0 0N2O 1 1 0 0

Not New/Modified Yes PF-03A PF-03AEdge Seal Booth Baghouse Stack

VOC 0.12 0.44 0.12 0.44 0 0 OtherPainting/Enclosed/Fabric Filter

PM 0.17 0.64 0.17 0.64 0 0PM10 0.17 0.64 0.17 0.64 0 0PM2.5 0.17 0.64 0.17 0.64 0 0

Not New/Modified Yes PF-03B PF-03BEdge Seal Booth Baghouse Stack

VOC 0.12 0.44 0.12 0.44 0 0 OtherIndoor Painting good housekeeping practices

PM 0.17 0.64 0.17 0.64 0 0PM10 0.17 0.64 0.17 0.64 0 0PM2.5 0.17 0.64 0.17 0.64 0 0

Not New/Modified Yes PF-04A PF-04A Stencil Area VOC 0.04 0.17 0.04 0.17 0 0 OtherNot New/Modified Yes PF-04B PF-04B Stencil Area VOC 0.04 0.17 0.04 0.17 0 0 Other

Not New/Modified Yes TK-1 TK-1 Diesel Storage Tank VOC <0.01 0.01 <0.01 0.01 0 0 OtherDiesel Storage Tank FR with submerged filled

Not New/Modified Yes TK-2 TK-2 Gasoline Storage Tank VOC 0.13 0.59 0.13 0.59 0 0 OtherGasoline Storage Tank FR with submerged fill

Not New/Modified Yes TK-3 TK-3 Used Oil Storage Tank VOC <0.01 <0.01 <0.01 <0.01 0 0 OtherUsed Oil Storage Tank FR with submerged fill

Not New/Modified Yes TK-4 TK-4Edge Seal Storage Tank

VOC <0.01 0.01 <0.01 0.01 0 0 OtherVOC Storage Tank FR with submerged fill

Not New/Modified Yes RO-01 RO-01 Paved Roads PM <0.01 <0.01 <0.01 <0.01 0 0 RoadsPM10 <0.01 <0.01 <0.01 <0.01 0 0PM2.5 <0.01 <0.01 <0.01 <0.01 0 0

Not New/Modified Yes RO-02 RO-02 Unpaved Roads PM 0.06 0.24 0.06 0.24 0 0 RoadsPM10 0.06 0.24 0.06 0.24 0 0PM2.5 0.01 0.02 0.01 0.02 0 0

Not New/Modified Yes EFP-1 EFP-1Emergency Fire Pump Diesel Stack

VOC 1.32 0.07 1.32 0.07 0 0 Engine: Emergency, Diesel

NOx 1.32 0.07 1.32 0.07 0 0SO2 <0.01 <0.01 <0.01 <0.01 0 0PM 0.07 <0.01 0.07 <0.01 0 0PM10 0.07 <0.01 0.07 <0.01 0 0PM2.5 0.07 <0.01 0.07 <0.01 0 0CO 1.15 0.06 1.15 0.06 0 0HAPs <0.01 <0.01 <0.01 <0.01 0 0CH4 1 1 0 0CO2 12 12 0 0CO2 Equivalent 335 335 0 0N2O 1 1 0 0

Not New/Modified Yes EG-1 EG-1Emergency Generator Diesel Stack

VOC 10.58 0.53 10.58 0.53 0 0 Engine: Emergency, Diesel

NOx 10.58 0.53 10.58 0.53 0 0

this cell is intentionally left blank


Mechanical / Agricultural / ConstructionPermit primary industry (must be selected for workbook to function)

Version 4.0 Page 1


Form PI-1 General ApplicationUnit Types - Emission Rates

Date: ____________Permit #: ____________

Company: ____________

Action Requested (only 1 action per FIN)

Include these emissions in annual (tpy) summary?

Facility ID Number (FIN)

Emission Point Number (EPN) Source Name Pollutant

Current Short-Term (lb/hr)

Current Long-Term (tpy)

ConsolidatedCurrent Short-Term (lb/hr)

Consolidated Current Long-Term (tpy)

Proposed Short-Term (lb/hr)


Short-Term Difference (lb/hr)

Long-Term Difference (tpy)

Unit Type (Used for reviewing BACT and Monitoring Requirements)

Unit Type Notes (only if "other" unit type in Column O)

SO2 0.01 <0.01 0.01 <0.01 0 0PM 0.33 0.02 0.33 0.02 0 0PM10 0.33 0.02 0.33 0.02 0 0PM2.5 0.33 0.02 0.33 0.02 0 0CO 5.79 0.29 5.79 0.29 0 0HAPs 0.01 <0.01 0.01 <0.01 0 0CH4 1 1 0 0CO2 58 58 0 0CO2 Equivalent 381 381 0 0N2O 1 1 0 0

New/Modified Yes RTO-01 RTO-01RTO-1 Stack (Dryer1, Venturi Scrubber 1, and WESP 1)

VOC 3.47 15.19 1.21 3.98 -2.26 -11.21 Dryer

NOx 11.29 49.46 14.56 48.01 3.27 -1.45SO2 0.43 1.89 0.33 1.09 -0.1 -0.8PM 3.02 13.23 9.38 30.93 6.36 17.7PM10 3.02 13.23 9.38 30.93 6.36 17.7PM2.5 3.02 13.23 9.38 30.93 6.36 17.7CO 65.07 285.02 42.11 138.86 -22.96 -146.16HAPs 1.86 8.14 1.92 6.34 0.06 -1.8CH4 17 17 0 0CO2 226439 221481 0 -4958CO2 Equivalent 229596 224506 0 -5090N2O 9 9 0 0

Not New/Modified Yes SB-1 SB-1 Standby Burner No.1 VOC 0.81 0.29 0.81 0.29 0 0 Heater > 40 MMBtu/hrNOx 14.71 5.29 14.71 5.29 0 0SO2 0.09 0.03 0.09 0.03 0 0PM 1.12 0.4 1.12 0.4 0 0PM10 1.12 0.4 1.12 0.4 0 0PM2.5 1.12 0.4 1.12 0.4 0 0CO 12.35 4.45 12.35 4.45 0 0HAPs 0.27 0.07 0.28 0.1 0.01 0.03CH4 1 1 0 0CO2 6353 6353 0 0CO2 Equivalent 6676 6676 0 0N2O 1 1 0 0

New/Modified Yes RTO-02 RTO-02RTO-2 Stack (Dryer2, Venturi Scrubber 2, and WESP 2)

VOC 3.47 15.19 1.21 3.98 -2.26 -11.21 Dryer

NOx 11.29 49.46 14.56 48.01 3.27 -1.45SO2 0.43 1.89 0.33 1.09 -0.1 -0.8PM 3.02 13.23 9.38 30.93 6.36 17.7PM10 3.02 13.23 9.38 30.93 6.36 17.7PM2.5 3.02 13.23 9.38 30.93 6.36 17.7CO 65.07 285.02 42.11 138.86 -22.96 -146.16HAPs 1.86 8.14 1.92 6.34 0.06 -1.8CH4 17 17 0 0CO2 226439 221481 0 -4958CO2 Equivalent 229596 224506 0 -5090N2O 9 9 0 0

Not New/Modified Yes SB-2 SB-2 Standby Burner No.2 VOC 0.81 0.29 0.81 0.29 0 0 Heater > 40 MMBtu/hrNOx 14.71 5.29 14.71 5.29 0 0SO2 0.09 0.03 0.09 0.03 0 0PM 1.12 0.4 1.12 0.4 0 0PM10 1.12 0.4 1.12 0.4 0 0PM2.5 1.12 0.4 1.12 0.4 0 0CO 12.35 4.45 12.35 4.45 0 0HAPs 0.27 0.07 0.28 0.1 0.01 0.03CH4 1 1 0 0CO2 6353 6353 0 0CO2 Equivalent 6676 6676 0 0N2O 1 1 0 0

New/Modified Yes RTO-03 RTO-03RTO-3 Stack (OSB Press)

VOC 4.17 18.26 0.48 1.65 -3.69 -16.61 Oriented Strandboard Mill: Press

NOx 20 87.6 19.96 69.36 -0.0399 -18.24PM 9.55 41.85 10.47 36.39 0.92 -5.46PM10 9.55 41.85 10.47 36.39 0.92 -5.46PM2.5 9.55 41.85 10.47 36.39 0.92 -5.46CO 1.59 6.96 5.22 18.14 3.63 11.18HAPs 1.92 8.42 1.2 4.17 -0.72 -4.25CO2 18135 12200 0 -5935CO2 Equivalent 18135 12200 0 -5935

Not New/Modified Yes MSS-1 MSS-1Pneumatic Transfer System Bypass Stack

PM 905 0.45 905 0.45 0 0 MSS Activities

PM10 905 0.45 905 0.45 0 0PM2.5 905 0.45 905 0.45 0 0

Not New/Modified Yes MSS-2 MSS-2 Sawmill Bypass Stack PM 110 0.06 110 0.06 0 0 MSS ActivitiesPM10 110 0.06 110 0.06 0 0PM2.5 110 0.06 110 0.06 0 0

New/Modified Yes MSS-3 MSS-3 Dryer Bypass Stack VOC 249.66 0.12 375.78 0.19 126.12 0.07 MSS Activities

New/Modified Yes PS-10 PS-10Sand & Tongue and Groove Aspiration System Stack

PM 1.19 5.23 1.19 5.23 Control: Bag Filter/Baghouse

PM10 1.19 5.23 1.19 5.23PM2.5 1.19 5.23 1.19 5.23

0 00 0

Version 4.0 Page 2

Texas Commission on Environmental QualityForm PI-1 General Application

Stack Parameters

Date: ____________Permit #: ____________

Company: ____________

EPNIncluded in EMEW?

UTM Coordinates

ZoneEast (Meters)

North (Meters)

BuildingHeight (ft)

Height Above Ground (ft)

Stack Exit Diameter (ft)

Velocity (FPS)

Temperature (°F)

Fugitives - Length (ft)

Fugitives - Width (ft)

Fugitives - Axis Degrees

PS-05 15 323820 3428354 N/A 70 3.7 47.4 Ambient N/A N/A N/APS-06 15 323988 3428339 N/A 70 4.5 52.2 Ambient N/A N/A N/APS-07 15 323950 3428334 N/A 70 3.7 103.3 Ambient N/A N/A N/APS-08 15 323977 3428151 N/A 70 4.5 48.6 Ambient N/A N/A N/APS-09 15 323977 3428332 N/A 70 3.7 103.3 Ambient N/A N/A N/AHP 15 323759 3428293 N/A 70 2.5 40.04 Ambient N/A N/A N/ATO-2 15 323950 3428295 N/A 50 4 48.6 655 N/A N/A N/APF-03A 15 324058 3428087 46.7 N/A N/A N/A Ambient N/A N/A N/APF-03B 15 324064 3428079 46.7 N/A N/A N/A Ambient N/A N/A N/APF-04A 15 324057 3428074 46.7 N/A N/A N/A Ambient N/A N/A N/APF-04B 15 324063 3428073 46.7 N/A N/A N/A Ambient N/A N/A N/ATK-1 15 323980 3428043 N/A 10 0.167 N/A Ambient N/A N/A N/ATK-2 15 323980 3428047 N/A 5 0.167 N/A Ambient N/A N/A N/ATK-3 15 323978 3428050 N/A 5 0.167 N/A Ambient N/A N/A N/ATK-4 15 324106 3428095 N/A 18 0.33 N/A Ambient N/A N/A N/ARO-01 15 323812 3428614 N/A N/A N/A N/A N/A N/A N/A N/ARO-02 15 323626 3428563 N/A N/A N/A N/A N/A N/A N/A N/AEFP-1 15 323801 3428209 N/A 11 0.417 73.95 223 N/A N/A N/AEG-1 15 323874 3428290 N/A 12 0.83 64.141 217 N/A N/A N/ARTO-01 15 323934 3428455 N/A 75 9.5 55.92 295 N/A N/A N/ASB-1 15 323925 3428299 N/A N/A N/A N/A N/A N/A N/A N/ARTO-02 15 323914 3428456 N/A 75 9.5 55.92 295 N/A N/A N/ASB-2 15 323909 3428303 N/A N/A N/A N/A N/A N/A N/A N/ARTO-03 15 323989 3428243 N/A 50 7 68.62 273 N/A N/A N/AMSS-1 15 323769 3428285 N/A 22 3.6 19.5 Ambient N/A N/A N/AMSS-2 15 323964 3428139 N/A 24 4.5 48.6 Ambient N/A N/A N/AMSS-3 15 323942 3428447 N/A 75 9.5 55.92 295 N/A N/A N/APS-10 15 323965 3428152 N/A 70 4.5 48.6 Ambient N/A N/A N/A

Emission Point Discharge Parameters

Version 4.0 Page 1


Form PI-1 General ApplicationPublic Notice

Date: ____________Permit #: ____________

Company: ____________

Yes

No

Yes

No

No

I. Public Notice Applicability

Is this an application for a new or major modification of a PSD (including GHG), Nonattainment, or HAP permit?

For public notice applicability, the agency does not include consolidation or incorporation of any previously authorized facility or activity (PBR, standard permits, etc.), changes to permitted allowable emission rates when exclusively due to changes to standardized emission factors, or reductions in emissions which are not enforceable through the amended permit. Thus, the total emissions increase would be the sum of emissions increases under the amended permit and the emissions decreases under the amended permit for each air contaminant.

The table below will generate emission increases based on the values represented on the "Unit Types - Emission Rates" sheet. Use the "yes" and "no" options in column B of the "Unit Types - Emission Rates" worksheet to indicate if a unit's proposed change of emissions should be included in these totals.

Notes:1. Emissions of PM, PM10, and/or PM2.5 may have been previously quantified and authorized as PM, PM10,and/or PM2.5. These emissions will be speciated based on current guidance and policy to demonstrate compliance with current standards and public notice requirements may change during the permit review.

2. All renewals require public notice.

A. Application Type

B. Project Increases and Public Notice Thresholds (for Initial and Amendment Projects)

NoDo the facilities handle, load, unload, dry, manufacture, or process grain, seed, legumes, or vegetable fibers (agricultural facilities)?

Is this an application for a minor permit amendment?Is there any change in character of emissions in this application (a new criteria pollutant or a new VOC or PM species)?Is there a new air contaminant in this application?

Is this an application for a GHG voluntary update with a change to a BACT determination? If so, a consolidated public notice is required. If not, no notice is required.

This row is optional. If you do not think the table below accurately represents public notice applicability increases for your project, provide discussion here (1000 characters).

Version 4.0 Page 1



Date: ____________Permit #: ____________

Company: ____________

PollutantCurrent Long-Term (tpy)

Consolidated Emissions (tpy)


Project Change in Allowable (tpy)

PN ThresholdNotice required?

VOC 51.90 0.00 12.94 -38.96 5 No

PM 96.30 0.00 131.47 35.17 5 Yes*

PM10 96.30 0.00 131.47 35.17 5 Yes*

PM2.5 96.08 0.00 131.25 35.17 5 Yes*

NOx 199.82 0.00 178.61 -21.21 5 No

CO 588.03 0.00 306.89 -281.14 50 No

SO2 3.87 0.00 2.27 -1.60 10 No

Pb 0.00 0.00 0.00 0.00 0.6 No

HAPs 24.92 0 17.11 -7.81 5 No

CH4 39 0 39 0 5 No

CO2 486330 0 470479 -15851 5 No

CO2 Equivalent 494259 0 478144 -16115 ** No

N2O 23 0 23 0 5 No


C. Is public notice required for this project as represented in this workbook?If no, proceed to Section III Small Business Classification.Note: public notice applicability for this project may change throughout the technical review.

Yes

First Name:

D. Are any HAPs to be authorized/re-authorized with this project? The category "HAPs" must be specifically listed in the public notice if the project authorizes (reauthorizes for renewals) any HAP pollutants.

Complete this section if public notice is required (determined in the above section) or if you are not sure if public notice is required.

MsNatalie MonroeCorporate Environmental Manager

Yes

II. Public Notice Information

A. Contact InformationEnter the contact information for the person responsible for publishing. This is a designated representative who is responsible for ensuring public notice is properly published in the appropriate newspaper and signs are posted at the facility site. This person will be contacted directly when the TCEQ is ready to authorize public notice for the application.Prefix (Mr., Ms., Dr., etc.):

Last Name:Title:Company Name:Mailing Address: 2189 Memorial Drive

Corrigan OSB, L.L.C

* Notice is required for PM, PM10, and PM2.5 if one of these pollutants is above the threshold.

** Notice of a GHG action is determined by action type. Initial and major modification always require notice. Voluntary updates require a consolidated notice if there is a change to BACT. Project emission increases of CO2e (CO2 equivalent) are not relevant for determining public notice of GHG permit actions.

Version 4.0 Page 2



Date: ____________Permit #: ____________

Company: ____________

Mailing Address:Address Line 2:

ZIP Code:County:

707 North Tyler Avenue

Does the public place have Internet access available for the public?

Company Name:

ZIP Code:Telephone Number:Fax Number:Email Address:

MsKaren

71301

[email protected]

Senior Environmental Scientist

70809225-755-1000

ZIP Code:

318-483-3807318-473-2624

City:

Enter the contact information for the Technical Contact. This is the designated representative who will be listed in the public notice as a contact for additional information.

B. Public placePlace a copy of the full application (including all of this workbook and all attachments) at a public place in the county where the facilities are or will be located. You must state where in the county the application will be available for public review and comment. The location must be a public place and described in the notice. A public place is a location which is owned and operated by public funds (such as libraries, county courthouses, city halls) and cannot be a commercial enterprise. You are required to pre-arrange this availability with the public place indicated below. The application must remain available from the first day of publication through the designated comment period.

If this is an application for a PSD, nonattainment, or FCAA §112(g) permit, the public place must have internet access available for the public as required in 30 TAC § 39.411(f)(3).

If the application is submitted to the agency with information marked as Confidential, you are required to indicate which specific portions of the application are not being made available to the public. These portions of the application must be accompanied with the following statement: Any request for portions of this application that are marked as confidential must be submitted in writing, pursuant to the Public Information Act, to the TCEQ Public Information Coordinator, MC 197, P.O. Box 13087, Austin, Texas 78711-3087.

Address Line 2:City:State:

AlexandriaLA

CK Associates

[email protected]

State:

Yes

Yes

City: Livingston77351Polk

Livingston Muncipal LibraryPhysical Address:

Blakemore

Prefix (Mr., Ms., Dr., etc.):

Last Name:

Address Line 2:

First Name:

Has the public place granted authorization to place the application for public viewing and copying?

Title:

Baton RougeLA

8591 United Plaza Blvd. Suite 300

Telephone Number:

Email Address:Fax Number:

Name of Public Place:

Version 4.0 Page 3



Date: ____________Permit #: ____________

Company: ____________

C. Alternate Language PublicationIn some cases, public notice in an alternate language is required. If an elementary or middle school nearest to the facility is in a school district required by the Texas Education Code to have a bilingual program, a bilingual notice will be required. If there is no bilingual program required in the school nearest the facility, but children who would normally attend those schools are eligible to attend bilingual programs elsewhere in the school district, the bilingual notice will also be required. If it is determined that alternate language notice is required, you are responsible for ensuring that the publication in the alternate language is complete and accurate in that language.

Provide the information for the Presiding Officer(s) of the municipality for this facility site. This is frequently the Mayor.

We must notify the applicable county judge and presiding officer when a PSD or Nonattainment permit or modification application is received. This information can be obtained at:

Title:Last Name:

LivingstonTX77351

75939

Mailing Address:

https://www.txdirectory.com

TX

Travis Kitchens

First Name:

If this is an application for emissions of GHGs, select either "Separate Public Notice" or "Consolidated Public Notice". Note: Separate public notices requires a separate application.

NoIs a bilingual program required by the Texas Education Code in the School District?

Gibson

No

Mailing Address:

Provide the information for the County Judge for the location where the facility is or will be located.

101 West Mill Street, Suite 286


Johnna

Not applicable

Address Line 2:City:State:ZIP Code:

ZIP Code:State:City:Address Line 2:

Corrigan

Mayor101 West Ben Franklin

The Honorable:

D. PSD and Nonattainment Permits Only

NoAre the proposed facilities located within 100 km or less of an affected state or Class I Area?

Are the children who attend either the elementary school or the middle school closest to your facility eligible to be enrolled in a bilingual program provided by the district?

Version 4.0 Page 4



Date: ____________Permit #: ____________

Company: ____________

No

No

Complete this section to determine small business classification. If a small business requests a permit, agency rules (30 TAC § 39.603(f)(1)(A)) allow for alternative public notification requirements if all of the following criteria are met. If these requirements are met, public notice does not have to include publication of the prominent (12 square inch) newspaper notice.

III. Small Business Classification

Small business classification:

Does the company (including parent companies and subsidiary companies) have fewer than 100 employees or less than $6 million in annual gross receipts?

Version 4.0 Page 5


Form PI-1 General ApplicationFederal Applicability

Date: ____________Permit #: ____________

Company: ____________

Yes

PollutantProject Increase (after netting)

Threshold PSD Review Required?

CO

NOx

PM 35.17 25 Yes

PM10 35.17 15 Yes

PM2.5 35.17 10 Yes

SO2

Ozone (as VOC)

Ozone (as NOx)

Pb

H2S

TRS

Reduced sulfur compounds (including H2S)

H2SO4

Fluoride (excluding HF)

CO2eThis cell intentionally left blank

I. County Classification

Polk

II. PSD and GHG PSD Applicability Summary


County (completed for you from your response on the General sheet)

Does the project require retrospective review? Yes

Is netting required for the PSD analysis for this project?

If yes, the project increases listed below should be after netting has been performed. Attach the netting information to the application.

If so, select the nonattainment classification of the county when the project being revisited was authorized. attainment

10/23/2015If so, what is the issuance date of the project being revisited? (xx/xx/xx)

The workbook includes one retrospective review. If the project includes multiple, provide an attachment listing the additional issuance dates, classifications at the time of authorization, and offset data for each additional retrospective review in the project.

Version 4.0 Page 1


Form PI-1 General ApplicationFees

Date: ____________Permit #: ____________

Company: ____________

No

No

I. General Information - Non-Renewal

II. Direct Costs - Non-RenewalThis cell intentionally left blank

Is this project for new facilities controlled and operated directly by the federal government? (30 TAC § 116.141(b)(1) and 30 TAC § 116.163(a))

A fee of $75,000 shall be required if no estimate of capital project cost is included with the permit application. (30 TAC § 116.141(d)) Select "yes" here to use this option. Then skip sections II and III.

Select Application Type Major Application

Installation, including foundations, erection of supporting structures, enclosures or weather protection, insulation and painting, utilities and connections, process integration, and process control equipment.

Type of Cost AmountProcess and control equipment not previously owned by the applicant and not currently authorized under this chapter.Auxiliary equipment, including exhaust hoods, ducting, fans, pumps, piping, conveyors, stacks, storage tanks, waste disposal facilities, and air pollution control equipment specifically needed to meet permit and regulation requirements.Freight charges.Site preparation, including demolition, construction of fences, outdoor lighting, road, and parking areas.

Auxiliary buildings, including materials storage, employee facilities, and changes to existing structures.

For GHG permits: A single PSD fee (calculated on the capital cost of the project per 30 TAC § 116.163) will be required for all of the associated permitting actions for a GHG PSD project. Other NSR permit fees related to the project that have already been remitted to the TCEQ can be subtracted when determining the appropriate fee to submit with the GHG PSD application. Identify these other fees in the GHG PSD permit application.

Ambient air monitoring network.Sub-Total: $0.00

Sub-Total: $0.00


III. Indirect Costs - Non-RenewalType of Cost AmountFinal engineering design and supervision, and administrative overhead.Construction expense, including construction liaison, securing local building permits, insurance, temporary construction facilities, and construction clean-up.

Contractor's fee and overhead.


IV. Calculations - Non-Renewal

Version 4.0 Page 1



Date: ____________Permit #: ____________

Company: ____________

$0.00

$3,000.00

$3,000.00

Yes3,000.00$

$3,000.00

Enter the check, money order, ePay Voucher, or other transaction number:Enter the Company name as it appears on the check: No

Enter the fee amount:Was the fee paid online?

In signing the "General" sheet with this fee worksheet attached, I certify that the total estimated capital cost of the project as defined in 30 TAC §116.141 is equal to or less than the above figure. I further state that I have read and understand Texas Water Code § 7.179, which defines Criminal Offenses for certain violations, including intentionally or knowingly making, or causing to be made, false material statements or representations.


Your estimated capital cost: Minimum fee applies.Permit Application Fee: $3,000.00


VII. Payment Information



VI. Total FeesNote: fees can be paid together with one payment or as two separate payments.Non-Renewal Fee

Total

Greater than $25,000,000 N/A

Less than $300,000 $3,000 (minimum fee)$300,000 - $7,500,000 1.0% of capital cost

$300,000 - $25,000,000 N/AGreater than $7,500,000 $75,000 (maximum fee)

Estimated Capital Cost Major Application Fee

C. Total Paid

A. Payment One (required)

Version 4.0 Page 2



Date: ____________Permit #: ____________

Company: ____________

No

No


VIII. Professional Engineer Seal RequirementIs the estimated capital cost of the project above $2 million?

Is the application required to be submitted under the seal of a Texas licensed P.E.?Note: an electronic PE seal is acceptable.

Version 4.0 Page 3


Form PI-1 General ApplicationImpacts

Date: ____________Permit #: ____________

Company: ____________

PollutantDoes this pollutant require PSD review?

How will you demonstrate that this project meets all applicable requirements?

Notes Additional Notes (optional)

Ozone No Not applicableThis pollutant is not a part of this project or does not require an impacts analysis.

VOC No Not applicableThis pollutant is not a part of this project or does not require an impacts analysis.

PM YesProtocol (required for all PSD projects, excluding GHG PSD)

Attach a protocol meeting all requirements listed on the TCEQ website.

PM10 YesProtocol (required for all PSD projects, excluding GHG PSD)


PM2.5 YesProtocol (required for all PSD projects, excluding GHG PSD)


NOx YesProtocol (required for all PSD projects, excluding GHG PSD)


Maximum hourly emissions of NOx will increase as a result of this change. Therefore, NOx will be modeled in the restrospective PSD application for the 1-hour NAAQS.

SO2 No Not applicableThis pollutant is not a part of this project or does not require an impacts analysis.

CO YesProtocol (required for all PSD projects, excluding GHG PSD)


Maximum hourly emissions of CO will increase as a result of this change. Therefore, CO will be modeled in the restrospective PSD application.

HAPs No Not applicableThis pollutant is not a part of this project or does not require an impacts analysis.

CH4 No Not applicableThis pollutant is not a part of this project or does not require an impacts analysis.

CO2 No Not applicableThis pollutant is not a part of this project or does not require an impacts analysis.

CO2 Equivalent No Not applicableThis pollutant is not a part of this project or does not require an impacts analysis.

N2O No Not applicableThis pollutant is not a part of this project or does not require an impacts analysis.

Version 4.0 Page 1


Form PI-1 General ApplicationBACT

Date: ____________Permit #: ____________

Company: ____________

Current Tier I BACT Confirm Additional Notes

Action Requested FINs Unit Type Pollutant Current Tier I BACT Confirm Additional Notes

New/Modified TO-2 Heater > 40 MMBtu/hr VOC See Additional Notes: YesThe only emission changes for this source is a decrease in NOx and HAPs.

New/Modified TO-2 Heater > 40 MMBtu/hr NOx

Burners with the best NOx performance given the burner configuration and gaseous fuel used. Specify the proposed emission rate (performance is an annual average) and provide justification if NOx>0.01 lb/MMBtu.

Cost data must be submitted for SCR if firing rate is > 300 MMBtu/hr and burner is >0.01 lb/MMBtu.

CEMS required for 100 MMBtu/hr or greater.

YesThe only emission changes for this source is a decrease in NOx and HAPs.

New/Modified TO-2 Heater > 40 MMBtu/hr SO2Maximum 0.6% sulfur content any liquid fuel or 5 grains for pipeline quality sweet natural gas. Provide details.

YesThe only emission changes for this source is a decrease in NOx and HAPs.

New/Modified TO-2 Heater > 40 MMBtu/hr PMThe emission reduction techniques for PM10 and PM2.5 will follow the technique for PM. Maximum opacity 5%

Yes

The only emission changes for this source is a decrease in NOx and HAPs. TO-2 is only projected to run during the emergency situations and major equipment downtime, the emissions for PM10/PM2.5 are already low (e.g. no more than 0.16 tpy), additional add-on controls are not expected to further reduce potential emissions significantly and not economically justified.

New/Modified TO-2 Heater > 40 MMBtu/hr CO 50 ppmv corrected to 3% O2 YesThe only emission changes for this source is a decrease in NOx and HAPs.

New/Modified TO-2 Heater > 40 MMBtu/hr HAPs See additional notes: YesThe only emission changes for this source is a decrease in NOx and HAPs.

New/Modified TO-2 Heater > 40 MMBtu/hr CH4 See additional notes: YesThe only emission changes for this source is a decrease in NOx and HAPs.

New/Modified TO-2 Heater > 40 MMBtu/hr CO2 See additional notes: YesThe only emission changes for this source is a decrease in NOx and HAPs.

New/Modified TO-2 Heater > 40 MMBtu/hr CO2 Equivalent See additional notes: YesThe only emission changes for this source is a decrease in NOx and HAPs.

New/Modified TO-2 Heater > 40 MMBtu/hr N2O See additional notes: YesThe only emission changes for this source is a decrease in NOx and HAPs.

New/Modified TO-2 Heater > 40 MMBtu/hr



New/Modified TO-2 Heater > 40 MMBtu/hr MSS Same as normal operation BACT requirements. Yes

New/Modified RTO-01 Dryer VOC

Firing pipeline quality sweet natural gas and good combustion practices. Specify if other fuel.

Waferized dryer:90% reduction, typically achieved through RTC or RCO

Asphalt plant:0.032 lbs./ton of asphalt produced

Ceramic manufacturing:Scrubbers with 95% DRE

PSD BACT review not triggered for VOC.

New/Modified RTO-01 Dryer NOx

Firing pipeline quality sweet natural gas and good combustion practices. Specify if firing alternate fuel.

Grain elevator drying: Column type dryers with outlet perforations no greater than 0.094 inches in diameter or equivalent (NSPS requirement). Please specify technique.

Iron/Steel dryer:0.01 lb NOX/MMBtu, typically achieved by firing natural gas or LPG fuel. Specify technique.

PSD BACT review not triggered for NOx.

This cell intentionally blank.

Plant Type

Version 4.0 Page 1



Date: ____________Permit #: ____________

Company: ____________


New/Modified RTO-01 Dryer SO2

Firing pipeline quality sweet natural gas and good combustion practices.

Asphalt plant:Maximum 0.6% sulfur content any liquid fuel or 5 grains for pipeline quality sweet natural gas. Provide details.

PSD BACT review not triggered for SO2.

New/Modified RTO-01 Dryer PM

The emission reduction techniques for PM10 and PM2.5 will follow the technique for PM. Firing pipeline quality sweet natural gas and good combustion practices. Specify if other fuel.

Industrial Sand Plant:99% reduction, at least <0.01 gr/dscf outlet grain loading. Specify efficiency and control method.

Waferized dryer:95% reduction, typically achieved with wet ESP or multiclones followed by RTO or RCO. Specify technique.

Asphalt plant:All drum dryers shall meet at least a front half outlet grain loading of 0.01 gr/dscf and a combined (front half and back half) total outlet grain loading of 0.04 gr/dscf, typically achieved with fabric filter baghouses. Specify technique. Maximum opacity 5%. Mechanism required to eliminate scorching when using recycled asphalt products

If using reclaimed industrial oil: Shall meet all standards specified in 40 CFR Part 279, Standard for the Management of Used Oil (antimony: 180 ppm, arsenic: 3 ppm, beryllium 1 ppm, cadmium: 2 ppm, chromium: 9ppm, mercury: 37 ppm, selenium 75 ppm, thallium: 37 ppm, vanadium: 18 ppm, lead: 100 ppm, nickel: 5 ppm, total halogens: 1000 ppm)

Yes

Corrigan OSB currently uses the following air pollution controls: Venturi scrubbers followed by a wet electrostatic precipitator (WESP) to control PM10/2.5 emissions. The selected control technologies are consistent with the U.S. EPA’s RBLC references.

New/Modified RTO-01 Dryer CO Firing pipeline quality sweet natural gas and good combustion practices. PSD BACT review not triggered for CO.New/Modified RTO-01 Dryer HAPs See additional notes: PSD BACT review not applicable for HAPs.New/Modified RTO-01 Dryer CH4 See additional notes: PSD BACT review not triggered for GHG.New/Modified RTO-01 Dryer CO2 See additional notes: PSD BACT review not triggered for GHG.New/Modified RTO-01 Dryer CO2 Equivalent See additional notes: PSD BACT review not triggered for GHG.New/Modified RTO-01 Dryer N2O See additional notes: PSD BACT review not triggered for GHG.New/Modified RTO-01 Dryer

New/Modified RTO-01 Dryer


New/Modified RTO-01 Dryer MSS

No additional controls required for MSS operations beyond normal operation BACT requirements. No bypassing of controls. Fabric filters should be in good repair with an acceptable pressure drop prior to the start of operation.

Removal of spent filters in such a manner to minimize PM emissions and placing the spent filters in sealable bags or other sealable containers prior to removal from the site. Bags or containers shall be kept closed at all times except when adding spent filters.

Oriented strand board mill:Dryer feed must be shut down immediately when associated bypass damper opens. There shall be no more than 5 total dryer bypasses per hour, 10 per day, and 1,000 per year.

New/Modified RTO-02 Dryer VOC

Firing pipeline quality sweet natural gas and good combustion practices. Specify if other fuel.

Waferized dryer:90% reduction, typically achieved through RTC or RCO

Asphalt plant:0.032 lbs./ton of asphalt produced

Ceramic manufacturing:Scrubbers with 95% DRE

PSD BACT review not triggered for VOC.

Version 4.0 Page 2



Date: ____________Permit #: ____________

Company: ____________


New/Modified RTO-02 Dryer NOx

Firing pipeline quality sweet natural gas and good combustion practices. Specify if firing alternate fuel.

Grain elevator drying: Column type dryers with outlet perforations no greater than 0.094 inches in diameter or equivalent (NSPS requirement). Please specify technique.

Iron/Steel dryer:0.01 lb NOX/MMBtu, typically achieved by firing natural gas or LPG fuel. Specify technique.

PSD BACT review not triggered for NOx.

New/Modified RTO-02 Dryer SO2

Firing pipeline quality sweet natural gas and good combustion practices.

Asphalt plant:Maximum 0.6% sulfur content any liquid fuel or 5 grains for pipeline quality sweet natural gas. Provide details.

PSD BACT review not triggered for SO2.

New/Modified RTO-02 Dryer PM

The emission reduction techniques for PM10 and PM2.5 will follow the technique for PM. Firing pipeline quality sweet natural gas and good combustion practices. Specify if other fuel.

Industrial Sand Plant:99% reduction, at least <0.01 gr/dscf outlet grain loading. Specify efficiency and control method.

Waferized dryer:95% reduction, typically achieved with wet ESP or multiclones followed by RTO or RCO. Specify technique.

Asphalt plant:All drum dryers shall meet at least a front half outlet grain loading of 0.01 gr/dscf and a combined (front half and back half) total outlet grain loading of 0.04 gr/dscf, typically achieved with fabric filter baghouses. Specify technique. Maximum opacity 5%. Mechanism required to eliminate scorching when using recycled asphalt products

If using reclaimed industrial oil: Shall meet all standards specified in 40 CFR Part 279, Standard for the Management of Used Oil (antimony: 180 ppm, arsenic: 3 ppm, beryllium 1 ppm, cadmium: 2 ppm, chromium: 9ppm, mercury: 37 ppm, selenium 75 ppm, thallium: 37 ppm, vanadium: 18 ppm, lead: 100 ppm, nickel: 5 ppm, total halogens: 1000 ppm)

Corrigan OSB currently uses the following air pollution controls: Venturi scrubbers followed by a wet electrostatic precipitator (WESP) to control PM10/2.5 emissions. The selected control technologies are consistent with the U.S. EPA’s RBLC references.

New/Modified RTO-02 Dryer CO Firing pipeline quality sweet natural gas and good combustion practices. PSD BACT review not triggered for CO.New/Modified RTO-02 Dryer HAPs See additional notes: PSD BACT review not applicable for HAPs.New/Modified RTO-02 Dryer CH4 See additional notes: PSD BACT review not triggered for GHG.New/Modified RTO-02 Dryer CO2 See additional notes: PSD BACT review not triggered for GHG.New/Modified RTO-02 Dryer CO2 Equivalent See additional notes: PSD BACT review not triggered for GHG.New/Modified RTO-02 Dryer N2O See additional notes: PSD BACT review not triggered for GHG.New/Modified RTO-02 Dryer



New/Modified RTO-02 Dryer MSS

No additional controls required for MSS operations beyond normal operation BACT requirements. No bypassing of controls. Fabric filters should be in good repair with an acceptable pressure drop prior to the start of operation.


Oriented strand board mill:Dryer feed must be shut down immediately when associated bypass damper opens. There shall be no more than 5 total dryer bypasses per hour, 10 per day, and 1,000 per year.

New/Modified RTO-03 Oriented Strandboard Mill: Press VOC 90% reduction, typically achieved through RTO or RCO PSD BACT review not triggered for VOC.New/Modified RTO-03 Oriented Strandboard Mill: Press NOx See Additional Notes: PSD BACT review not triggered for NOx.

Version 4.0 Page 3



Date: ____________Permit #: ____________

Company: ____________


New/Modified RTO-03 Oriented Strandboard Mill: Press PMThe emission reduction techniques for PM10 and PM2.5 will follow the technique for PM. 95% reduction, typically achieved through RTO or RCO

Yes

An economic analysis shows that installing a WESP would be economically infeasible as the PM10/2.5 emissions from the press are very low when compared to the flow of air out of the press. Due to the high cost of operating a WESP, the only technically and economically feasible alternative is good design and operation of the press to control PM10/PM2.5.

New/Modified RTO-03 Oriented Strandboard Mill: Press CO See Additional Notes: PSD BACT review not triggered for CO.New/Modified RTO-03 Oriented Strandboard Mill: Press HAPs See additional notes: PSD BACT review not triggered for GHG.New/Modified RTO-03 Oriented Strandboard Mill: Press CO2 See additional notes: PSD BACT review not triggered for GHG.New/Modified RTO-03 Oriented Strandboard Mill: Press CO2 Equivalent See additional notes: PSD BACT review not triggered for GHG.New/Modified RTO-03 Oriented Strandboard Mill: Press

New/Modified RTO-03 Oriented Strandboard Mill: Press





New/Modified RTO-03 Oriented Strandboard Mill: Press MSS See Additional Notes:New/Modified MSS-3 MSS Activities VOC See Additional Notes: PSD BACT review not triggered for VOC.

New/Modified MSS-3 MSS Activities












New/Modified MSS-3 MSS Activities MSS No established BACT. Specify controls.

New/Modified PS-10 Control: Bag Filter/Baghouse PMThe emission reduction techniques for PM10 and PM2.5 will follow the technique for PM. Opacity shall not exceed 5% and/or no visible emissions from each stack or vent. 99% reduction or outlet grain loading of 0.01 gr/dscf.

YesBaghouse is selected as BACT for this source, consistent with the U.S. EPA’s RBLC references.

New/Modified PS-10 Control: Bag Filter/Baghouse












New/Modified PS-10 Control: Bag Filter/Baghouse MSS

Fabric filters should be in good repair with an acceptable pressure drop prior to the start of operation.


Yes

Version 4.0 Page 4


Monitoring

Date: ____________Permit #: ____________

Company: ____________

FIN Unit Type Pollutant Minimum Monitoring Requirements Confirm Additional Notes for MonitoringProposed Measurement Technique (only complete for pollutants with a project increase above the PSD threshold)

Additional Notes for Measuring:

TO-2Heater > 40 MMBtu/hr

VOC See Additional Notes:

The Thermal Oil Heater is only projected to run during the emergency situations and major equipment downtime. Monitoring and testing requirements are included in Specific Conditions 4, 5, 8, 30 and 31.

TO-2 Heater > 40 MMBtu/hr NOx

≥100 MMBtu/hr: CEMS. Data collected four times per hour and averaged hourly.

<100 MMBtu/hr: Please specify.


TO-2 Heater > 40 MMBtu/hr SO2 See Additional Notes:


TO-2 Heater > 40 MMBtu/hr PMThe emission monitoring techniques for PM10 and PM2.5 will follow the technique for PM. See Additional Notes:

Yes

SR 8 - In accordance with Title 40 Code of Federal Regulations Part60 (40 CFR Part 60), Appendix A,Test Method 9,opacity shall not exceed 10% opacity except during scheduled or planned maintenanced, startup, or shutdown (MSS) activities.

TO-2 Heater > 40 MMBtu/hr CO See Additional Notes:


TO-2 Heater > 40 MMBtu/hr HAPs See additional notes:


TO-2 Heater > 40 MMBtu/hr CH4 See additional notes: Specific Condition 74.TO-2 Heater > 40 MMBtu/hr CO2 See additional notes: Specific Condition 74.TO-2 Heater > 40 MMBtu/hr CO2 Equivalent See additional notes: Specific Condition 74.TO-2 Heater > 40 MMBtu/hr N2O See additional notes: Specific Condition 74.TO-2 Heater > 40 MMBtu/hr

TO-2 Heater > 40 MMBtu/hr

TO-2 Heater > 40 MMBtu/hr

RTO-01 Dryer VOC See Additional Notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 35 through 50, 53, 54, 57, 64.

RTO-01 Dryer NOx See Additional Notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 35 through 50, 53, 54, 57, 64.

RTO-01 Dryer SO2 See Additional Notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 35 through 50, 53, 54, 57, 64.

RTO-01 Dryer PM

The emission monitoring techniques for PM10 and PM2.5 will follow the technique for PM. Quarterly visible emission checks, followed by an opacity observation if visible emissions are observed and/or continuously monitor the natural gas firing rate and/or the raw material feed rate. Temperature records for asphalt dryers.

Yes

Opacity Monitoring System = A continuous emissions monitoring system (CEMS) capable of measuring theopacity of emissions is installed in the vent in accordance with 30 TAC § 111.111(a)(1)(C).CAM - Wet Scrubber - 1. pressure drop, four times per hour, one hour averaging period, the minimum pressure drop shall not fall below 4.5 inches of water.2. Liquid flow rate, four times per day, one hour averaging period, the minimum scrubber liquid flow rate shall not fall below 400 gpm.

COMS

RTO-01 Dryer CO See Additional Notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 35 through 50, 53, 54, 57, 64.

RTO-01 Dryer HAPs See additional notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 35 through 50, 53, 54, 57, 64.

RTO-01 Dryer CH4 See additional notes: Yes Specific Condition 75.RTO-01 Dryer CO2 See additional notes: Yes Specific Condition 75.RTO-01 Dryer CO2 Equivalent See additional notes: Yes Specific Condition 75.RTO-01 Dryer N2O See additional notes: Yes Specific Condition 75.RTO-01 Dryer

RTO-01 Dryer

RTO-01 Dryer

RTO-02 Dryer VOC See Additional Notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 35 through 50, 53, 54, 57, 64.

RTO-02 Dryer NOx See Additional Notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 35 through 50, 53, 54, 57, 64.

RTO-02 Dryer SO2 See Additional Notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 35 through 50, 53, 54, 57, 64.

Version 4.0 Page 1


Monitoring

Date: ____________Permit #: ____________

Company: ____________

RTO-02 Dryer PM

The emission monitoring techniques for PM10 and PM2.5 will follow the technique for PM. Quarterly visible emission checks, followed by an opacity observation if visible emissions are observed and/or continuously monitor the natural gas firing rate and/or the raw material feed rate. Temperature records for asphalt dryers.

Yes

Opacity Monitoring System = A continuous emissions monitoring system (CEMS) capable of measuring theopacity of emissions is installed in the vent in accordance with 30 TAC § 111.111(a)(1)(C).CAM - Wet Scrubber - 1. pressure drop, four times per hour, one hour averaging period, the minimum pressure drop shall not fall below 4.5 inches of water.2. Liquid flow rate, four times per day, one hour averaging period, the minimum scrubber liquid flow rate shall not fall below 400 gpm.

COMS

RTO-02 Dryer CO See Additional Notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 35 through 50, 53, 54, 57, 64.

RTO-02 Dryer HAPs See additional notes: Yes Monitoring and testing requirements are included in SpecificRTO-02 Dryer CH4 See additional notes: Yes Specific Condition 75.RTO-02 Dryer CO2 See additional notes: Yes Specific Condition 75.RTO-02 Dryer CO2 Equivalent See additional notes: Yes Specific Condition 75.RTO-02 Dryer N2O See additional notes: Yes Specific Condition 75.RTO-02 Dryer

RTO-02 Dryer

RTO-02 Dryer

RTO-03Oriented Strandboard Mill: Press

VOC See Additional Notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 38 through 50, 53, 54, 64.

RTO-03 Oriented Strandboard Mill: Press NOx See Additional Notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 38 through 50, 53, 54, 64.

RTO-03 Oriented Strandboard Mill: Press PM

The emission monitoring techniques for PM10 and PM2.5 will follow the technique for PM. Quarterly observations for visible fugitive emissions and/or opacity observations

Recordkeeping of materials processed

Yes

CAM Opacity periodic monitoring - once per month, six-minutes averaging, the maximum opacity for any six-minute period shall not exceed 10%.SR 50 - Inlet pressure shall be recorded at least every 15 minutes and archived in one-hour averages. The press and RTO-3 system must operate under negative pressure measured as RTO inlet pressure during normal plant operation.

RTO-03 Oriented Strandboard Mill: Press CO See Additional Notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 38 through 50, 53, 54, 64.

RTO-03 Oriented Strandboard Mill: Press HAPs See additional notes: YesMonitoring and testing requirements are included in Specific Conditions 8, 30, 31, 38 through 50, 53, 54, 64.

RTO-03 Oriented Strandboard Mill: Press CO2 See additional notes: Yes Specific Condition 75.RTO-03 Oriented Strandboard Mill: Press CO2 Equivalent See additional notes: Yes Specific Condition 75.RTO-03 Oriented Strandboard Mill: Press

RTO-03 Oriented Strandboard Mill: Press





MSS-3 MSS Activities VOC Recordkeeping of MSS activities Yes

SR 50 - the status of the bypass dampers and the operating status of the associated equipment (i.e. bark burner, dryers or press) must be continuously monitored and sufficient data recorded to establish each period that a bypass dmaper is open while the equipment is generating uncontrolled emissions.

MSS-3 MSS Activities












PS-10Control: Bag Filter/Baghouse

PM

The emission monitoring techniques for PM10 and PM2.5 will follow the technique for PM. Pressure drop monitoring and/or quarterly visible emissions and/or opacity observations.

Yes

CAM - pressure drop of 0.5 inches of water and a maximum pressure drop of 5.0 inches of water shall not be exceeded.Minimum frequency - once per day

Conduct quarterly visible emissions determination to demonstrate compliance with opacity limitations.

Version 4.0 Page 2


Materials

Date: ____________Permit #: ____________

Company: ____________

How submitted Date submitted

STEERS 03/31/2020STEERS 03/31/2020Not applicable

STEERS 03/31/2020STEERS 03/31/2020STEERS 03/31/2020STEERS 03/31/2020STEERS 03/31/2020STEERS 03/31/2020

STEERS 03/31/2020STEERS 03/31/2020

STEERS 03/31/2020STEERS 03/31/2020STEERS 03/31/2020STEERS 03/31/2020

STEERS 03/31/2020

Process descriptionProcess flow diagram

Summary and project emission increase determination - Tables 1F and 2F

Plot plan

Item

Core Data Form

Form PI-1 General ApplicationHard copy of the General sheet with original (ink) signature

B. General Information

A. Administrative Information

Professional Engineer Seal

Copy of current permit (both Special Conditions and MAERT)

MERA analysis

PSD modeling protocol

Electronic Modeling Evaluation Workbook: SCREEN3

Qualitative impacts analysis

State regulatory requirements discussion

Area map

BACT discussion, if additional details are attachedMonitoring information, if additional details are attached

List of MSS activities

Electronic Modeling Evaluation Workbook: NonSCREEN3

C. Federal Applicability

E. Impacts Analysis

D. Technical Information

F. Additional Attachments

Material Balance (if applicable)Calculations

Netting analysis (if required) - Tables 3F and 4F as needed

Version 4.0 Page 1

APPENDIX A

ENFORCEMENT ACTION AGENCY

CORRESPONDENCE

APPENDIX B

MODELING PROTOCOL

1

Beth Szewc

From: Beth SzewcSent: Thursday, February 13, 2020 3:24 PMTo: Philip LeungCc: Jean Shaw; Karen BlakemoreSubject: Corrigan OSB Polk County PSDTX1446Attachments: AQA Protocol_Corrigan OSB PSDTX1446 Feb_2020.pdf

Good Afternoon Philip, Please find enclosed the modeling protocol for the PSD reconciliation at the Corrigan OSB, LLC facility in Polk County. Should you have any questions or would like to discuss further, please feel free to email or call me at (225) 923‐6439. Thank you, Beth

Beth Szewc

C-K Associates, LLC 8591 United Plaza Blvd Bldg V, Suite 300 Baton Rouge, La 70809 [email protected] (225) 755-1000 (225) 923-6439

Air Dispersion Modeling Protocol


Corrigan, Polk County, Texas

March 2020

Prepared by:

8591 United Plaza Blvd Suite 300

Baton Rouge, LA 70809 225‐755‐1000

CK Project Number: 17466


March 24, 2020 i CK Associates

TABLE OF CONTENTS

1.0 PROJECT OVERVIEW ......................................................................................... 1

2.0 METHODOLOGY ................................................................................................ 3

2.1 Model Input ............................................................................................... 4

2.1.1 Emissions Inventory .................................................................... 4

2.1.2 Meteorological Data ................................................................... 5

2.1.3 Receptor Grid .............................................................................. 5

2.2 Significant Impact Analysis ......................................................................... 6

2.3 Cumulative Impact Analysis ....................................................................... 8

2.3.1 Emission Sources ......................................................................... 8

2.3.2 NAAQS Analysis and Background Monitors................................. 9

2.3.3 Increment Consumption Analysis ................................................. 9

3.0 BUILDING DOWNWASH AND GEP ................................................................... 14

4.0 PM2.5 SECONDARY FORMATION AND OZONE IMPACTS ANALYSIS ..................... 16

5.0 ADDITIONAL IMPACTS AND CLASS I ANALYSIS ................................................ 17

6.0 REPORT PREPARATION ................................................................................... 17

LIST OF FIGURES

Figure 1 Site Location Map

Figure 2 Plot Plan

LIST OF APPENDICES

Appendix A Stack Parameters


March 24, 2020 1 CK Associates

MODELING PROTOCOL FOR PSD AND NAAQS ANALYSIS CORRIGAN OSB, LLC POLK COUNTY, TEXAS

1.0 PROJECT OVERVIEW

Corrigan OSB, L.L.C. (Corrigan OSB) own and operates an oriented strand board (OSB)

facility located in Corrigan, Polk County, Texas. A Site Location Map is included as Figure

1. The facility was permitted as a new facility under New Source Review (NSR) Permit

#128854, PSDTX1446, GHGPSDTX128 issued October 23, 2015 and Title V Standard

Operating Permit (SOP) Permit #O3779 issued December 4, 2017. The facility began

operation in February 2018. Corrigan is registered under Texas Commission on

Environmental Quality (TCEQ) Customer Reference Number CN604724831.

Following a review of the initial stack test results, Corrigan conducted an internal review

of emissions from the three Regenerative Thermal Oxidizers (RTO‐01, RTO‐02, and RTO‐

03) and the basis of the emission calculations. Results of this audit revealed that revisions

to the current permitted emission rates and calculations were necessary to best represent

the emissions from these sources that is reflective of the facility’s original designed

maximum production capacity and operations.

Corrigan OSB is submitting a reconciliation to the current Prevention of Significant

Deterioration (PSD) permit reflective of intended operations at the facility. This PSD

application does not represent a physical change or change of method of operation.

Rather, it is a “retroactive” PSD application to establish operating parameters originally

intended based on design of the facility. These revisions necessary to reflect the intended

operations will result in an increase from the current annual permitted rates for PM10

and PM2.5, and an increase in maximum hourly emission rates for NO2 and CO. However,

annual NO2 and CO emission rates will show a decrease in potential‐to‐emit (PTE).

As a result of the increases, the Air Quality Analysis (AQA) that was approved by TCEQ in

conjunction with issuance of PSD permit PSDTX1446 is being updated for emissions of

PM10/PM2.5, NO2 and CO. This AQA will include the updated emission rates for

PM10/PM2.5, NO2 and CO. Emissions of PM10/PM2.5 will be modeled for the 24‐hour and

annual averaging periods. Emissions of NO2 and CO will be modeled for their short‐term

averaging periods. Since annual NO2 PTE emissions will decrease, it will not be necessary

to re‐model the annual averaging period as compliance was demonstrated in the original

AQA with the higher emission rates.



Corrigan OSB is submitting this modeling protocol to conduct the Air Quality Analysis for the

OSB facility located in Polk County, Texas. This report contains the proposed methodology

followed in conducting the air dispersion analysis required to demonstrate compliance with

the National Ambient Air Quality Standards (NAAQS) and PSD increment consumption

standards for emissions of PM10, PM2.5, NO2 and CO. The air dispersion modeling analysis

will be conducted in accordance with TCEQ’s Air Quality Modeling Guidelines (November

2019) and the revised US EPA’s Guidelines on Air Quality Models finalized December 20,

2016, where appropriate. Guidance provided for the 1‐hour NO2 NAAQS in the US EPA

Memorandums dated June 28, 2010, June 29, 2010, March 1, 2011, and September 14, 2014

will be implemented in this modeling analysis, as necessary. Also, guidance provided for the

24‐hour PM2.5 NAAQS in the US EPA Memorandums dated May 20, 2014 and April 17, 2018

will be implemented in this modeling analysis, as necessary.

Project Identification is as follows:

Company Name ‐ Corrigan OSB, L.L.C.

Customer Number ‐ CN604724831

Site Name – Corrigan Oriented Strand Board Facility

Regulated Entity Number ‐ RN107922510

Permit Numbers ‐ 128854, PSDTX1446, GHGPSDTX128 and O3779

Nearest City ‐ Corrigan

County ‐ Polk

Modeling Contact Information o Beth Szewc o CK Associates o (225) 923‐6439



2.0 METHODOLOGY

Dispersion modeling was performed using the American Meteorological

Society/Environmental Protection Agency Regulatory Model (AERMOD) version 19191.

AERMAP (version 18081), the terrain preprocessor, AERMET (version 19191) and

AERMINUTE (version 15272), the meteorological preprocessors, and AERSURFACE (version

13016), used to estimate surface characteristics required for input to AERMET, was

employed within the AERMOD system. The rural dispersion coefficient was employed in

the model and the Regulatory Default option will be chosen.

Modeling procedures will follow those specified in the TCEQ Air Quality Modeling Guidelines

(November 2019). Averaging periods for each of the pollutants modeled along with their

significance level, monitoring exemption level, increment consumption standard and NAAQS

are as follows:

Averaging Period Nitrogen Dioxide (ug/m3)

PM2.5 (ug/m3)

PM10 (ug/m3)

Carbon Monoxide (ug/m3)

Significance Level

Annual 1 0.2 1 ‐‐‐

24‐hour ‐‐‐ 1.2 5 ‐‐‐

8‐hour ‐‐‐ ‐‐‐ ‐‐‐ 500

3‐hour ‐‐‐ ‐‐‐ ‐‐‐ ‐‐‐

1‐hour 7.5 ‐‐‐ ‐‐‐ 2,000

Monitoring De Minimis Concentration

Annual 14 ‐‐‐ ‐‐‐ ‐‐‐

24‐hour ‐‐‐ 1 10 ‐‐‐

8‐hour ‐‐‐ ‐‐‐ ‐‐‐ 575

1‐hour ‐‐‐ ‐‐‐ ‐‐‐ ‐‐‐

Increment Consumption Standard

Annual 25 4 17 ‐‐‐

24‐hour ‐‐‐ 9 30 ‐‐‐

3‐hour ‐‐‐ ‐‐‐ ‐‐‐

1‐hour ‐‐‐ ‐‐‐ ‐‐‐

NAAQS

Annual 100 12 ‐‐‐ ‐‐‐

24‐hour ‐‐‐ 35 150 ‐‐‐

8‐hour ‐‐‐ ‐‐‐ ‐‐‐ 10,000

3‐hour ‐‐‐ ‐‐‐ ‐‐‐ ‐‐‐

1‐hour 188 ‐‐‐ ‐‐‐ 40,000

1 Significant Monitoring Concentration for PM2.5 24‐ hour averaging period was vacated in January

2013.



2.1 Model Input

2.1.1 Emissions Inventory

The only sources being reconciled in the AQA are the following:



RTO‐03 Regenerative Thermal Oxidizer 3/OSB Press No. 1

These sources will be modeled at their updated proposed emission rates. All

remaining sources will be represented and modeled as they were in the

approved 2015 AQA. The language below describes the sources at the OSB

facility.

The types of emission sources that will be modeled at the facility include

combustion sources, baghouses and filters, volume sources, fugitive dust

sources from paved and unpaved roads, and emergency equipment. Stack

height and other related modeling stack parameters are based on design

data and input for the proposed stacks. The volume sources include

emissions that exit out the continuous roof vent on the building. Parameters

for modeling the volume sources are given below:

The height of release input is the building height.

The initial vertical dimension was calculated based on the building height divided by 2.15.

The initial lateral dimension is based on the length of the side of the building divided by 4.3.

There are two proposed emissions sources that are emergency equipment

and permitted to operate less than 100 hours per year each. These are as

follows:

EG1 – Emergency Generator (Diesel) EFP1 – Emergency Fire Water Pump (Diesel)

These sources will be operated once per week for one to two hours for

testing purposes. Both sources will be tested on the same day of the week.

Therefore, these sources qualify as intermittent sources and were

modeled following the TCEQ intermittent source guidelines.



For the 1‐hour NO2 standard, these emissions were included in the model

using an average hourly emission rate, consistent with EPA guidance.

The engines will only be tested between the hours of 9 am and 3 pm and

scalars were used in the model for the PM10 and PM2.5 24‐hour averaging

periods to represent this scenario.

Emission sources with their stack parameters and emission rates are given in

Appendix B.

2.1.2 Meteorological Data

The Air Dispersion Modeling Team (ADMT) of the TCEQ has prepared

meteorological data sets for each county to be used in AERMOD for PSD

analyses. The data set for Polk County uses surface data from Lufkin

Angelina CO Airport in Lufkin, Texas (Surface Station No. 93987) and upper

air data from Lake Charles, Louisiana (Upper Air Station No. 3937). For the

AQA reconciliation, meteorological data will be updated to more recent

years which will consist of years 2011 through 2015. The profile base

elevation for the meteorological station is 96.3 meters and the

anemometer height is 7.92 meters. The meteorological data sets have

been developed using three surface roughness categories (high, medium,

and low). Surface roughness determination was based on evaluating an

area with a 1‐kilometer radius centering on the plant site and using the

EPA tool AERSURFACE. The results of this analysis give a surface roughness

length of 0.777 which falls into the high surface roughness category.

Therefore, the high category for surface roughness was used to choose the

meteorological data. The electronic copy of the AERSURFACE output files

will be included with the modeling report.

2.1.3 Receptor Grid

No changes in receptor placement is being proposed for the reconciled AQA.

Receptors for the model will be placed so that the maximum off‐property

ground‐level concentrations from the facility emission sources can be

determined. A Cartesian system [Universal Transverse Mercator (UTM)] will

be implemented for all receptors, as well as for the property boundary and



emission sources. Receptors will be placed along the property line. A

perimeter fence will not be installed at the facility. However, at any

accessible areas of entrance to the plant site adequate barricades have

been installed extending into the wooded areas to prohibit any traffic. Any

roadway accessing adjoining woods have gates installed. The main

entrance directs all traffic to the Scales/security building where all visitors

sign in and receive the necessary safety directions in order to enter the

plant site.

Discrete receptors will be placed at 25‐meter intervals along the facility

property line. Additional receptors were placed at 25‐meter intervals from

the property line out to 200 meters, 100‐meter intervals from 200 meters to

1 kilometer, 500‐meter intervals from 1 kilometer to 5 kilometers, and one‐

kilometer spacing out to 10 kilometers. The receptor grid will be extended

and refined to capture the maximum concentration, if necessary. For the

cumulative impact analysis, receptors will be placed in the area of impact

(AOI) only.

Terrain elevation for each receptor was determined using United States

Geological Survey (USGS) National Elevation Dataset (NED) 1‐ arc second

data. The pre‐processor program, AERMAP (version 18081), was used to

process terrain data including terrain height and hill height scale. AERMAP

was also used to calculate terrain heights for emission sources and buildings

used for the downwash analysis.

2.2 Significant Impact Analysis

Screening runs will be conducted to determine whether the proposed emissions

of each pollutant could cause a significant impact. If the results of the preliminary

impact determination are significant beyond the property, then a second phase

consisting of refined modeling will be performed. In the preliminary impact

determination, the project emissions of NOx, PM10, CO and PM2.5 (as reconciled)

will be evaluated to determine whether they have the potential for a significant

impact upon the area surrounding the facility. The project emissions for each

pollutant and applicable averaging period will be modeled and compared to the

significant impact level (SIL).



As a result of the U.S. Court of Appeals decision to vacate and remand 40 CFR

51.166(k)(2) based on EPA’s lack of authority to exempt sources from the

requirements of the Federal Clean Air Act when it established SILs for PM2.5, an

analysis was conducted to justify the use of the SILs in the screening analysis. This

analysis was based on comparing the difference between the NAAQS and the

measured background concentrations to the SIL. If the difference between the

NAAQS and the background concentration is greater than the SIL, then the SIL will

be used to determine if a cumulative impact analysis is necessary. This analysis is

as follows:

PM2.5 SIL Justification

PM2.5 Averaging Period

NAAQS (ug/m3)

Vinton Monitor

22‐019‐0009 Average 2016 through 2018

(ug/m3)

Difference (NAAQS – Monitor) (ug/m3)

PM2.5 SIL

(ug/m3)

Greater Than SIL?

24‐Hour 35 21.2 13.8 1.2 Yes

Annual 12 7.8 4.2 0.2 Yes

An AOI will be established if there is an exceedance of the modeling SIL. The AOI is

defined as a circular area whose radius is equal to the greatest distance from the

source to the farthest receptor showing a concentration equal to the SIL during the

screen model run. The AOI will not exceed 50 kilometers due to model limitations.

Per EPA guidance, all predicted impacts for annual PM2.5 are reported as the

highest of the five‐year averages of the maximum modeled concentrations

predicted each year at each receptor based on five years of National Weather

Service (NWS) meteorological data. All predicted impacts for annual PM10 are

reported as the high‐first‐high of the modeled concentrations predicted each year

at each receptor based on five years of NWS meteorological data.

Per EPA guidance, in the screening analysis, predicted impacts for 1‐hour NO2, and

24‐hour PM2.5 are reported as the highest of the five‐year averages of the

maximum modeled concentrations predicted each year at each receptor based on

five years of NWS meteorological data. While the NAAQS for annual PM10 has been

revoked, the annual PM10 PSD increment standard remains in effect. Therefore, a

comparison to the SIL for annual PM10 was performed to determine if an annual

PM10 PSD increment analysis is required.



For the remaining pollutants/averaging time combinations (CO 1‐hour and 8‐hour,

and PM10 24‐hour), predicted impacts are reported as the high‐first‐high of the

modeled concentrations predicted each year at each receptor based on five years

of NWS meteorological data.

As part of the assessment of off‐site impacts from PM2.5, secondary formation of

PM2.5 attributed to emissions of SO2 and NOx must be addressed. The US EPA has

developed a method to estimate single source impacts of secondary pollutants as

a Tier 1 approach. This assessment is addressed in Section 4.0 of this report.

The facility proposes to update the 1‐hour NO2 processing by utilizing the option

of performing the 1‐hour NO2 significance analysis using the Tier 2 Ambient Ratio

Method 2 (ARM2) with a minimum and maximum ratio of 0.5 and 0.9.

2.3 Cumulative Impact Analysis

Those pollutants that exceed the modeling significance level are required to be

modeled in the cumulative impact analysis. However, based on preliminary

modeling, Corrigan does not anticipate that there will be exceedances of the SILs for

PM10 and CO. Should a cumulative impact analysis be required, a summary of the

methodology that will be followed is given below:

2.3.1 Emission Sources

The 2015 AQA prepared for the current PSD, PSDTX1446, included an off‐site

retrieval of the inventory from TCEQ. This data was reviewed for accuracy

and missing data was populated based on a file search of the most recent

permits. This AQA was approved by the TCEQ.

The reconciled AQA will include updating this inventory by following the

steps below:

1. Request a retrieval from the Air Permits Allowable Database (APAD)

and cross‐check updated inventory.

2. Review the inventory and update as necessary using the following

TCEQ Online Records site and/or the 2015 completed inventory:



https://www.tceq.texas.gov/agency/data/records‐

services/welcome‐to‐tceq‐records‐online

2.3.2 NAAQS Analysis and Background Monitors

The proposed facility is located near Corrigan in Polk County,

approximately 75 miles north‐northeast of Houston. The site location is

very rural with only minor industrial facilities and two major roadways in

the near vicinity.

Population within 10 Km = 4,101

Nearby major industrial facilities = Georgia Pacific – Camden

Plywood and Lumber Complex; Georgia Pacific – Corrigan Plywood

Mill

Major roadways = State Hwy 287 and State Hwy 59

The following monitors were approved in the 2015 AQA for background

concentrations. These monitors will be used in the reconciled AQA with

updated monitor values using the most recent three‐year set of complete

data. The proposed years of current data for each pollutant/averaging

period will be 2016 through 2018 unless any of these years are deemed

incomplete per guidelines.

No changes are required for the PSD Pre‐application analysis used in the

original 2015 AQA as the reconciled emission rates will not affect that

analysis.

2.3.3 Increment Consumption Analysis Proposed allowable emissions will be modeled for emission sources at the

facility. As a tier 1 conservative approach, permitted allowable emissions will

be modeled for the off‐site sources without subtracting any baseline

emissions.

Pollutant/ Averaging Period

Station Name Station Number

PM2.5 – 24 hour Vinton, La. 22‐019‐009

PM2.5 ‐ Annual Vinton, La. 22‐019‐009

PM10 – 24 hour Karnack 48‐203‐0002

NO2 – 1 hour Karnack 48‐203‐0002



The resulting concentration from the modeling runs will be compared to the

Class II allowable PSD increment consumption level. If the modeled

concentration is equal to or greater than the Increment Consumption

standard, a culpability analysis will be performed to determine the facility’s

contribution to the exceedance.

For the PM2.5 increment consumption standards, the minor source

baseline date is established in Polk County by the submission of the

Corrigan permit application January 2, 2015. The major source baseline

date was established by EPA to be October 20, 2010. All major increases

of PM2.5 within Polk County after this date must be considered in this

analysis.

According to the EPA Guidance for PM2.5 Permit Modeling, May 2014, for

sources which set the minor baseline date, i.e., are the first source with

increment consuming emissions in the area, it may be concluded that

“…the impacts of the new or modified source ... may be compared directly

to the allowable increments, without the need for a cumulative modeling

analysis. Such an approach would be appropriate when the new or

modified source represents the first PSD application in the area after the

trigger date, which establishes the minor source baseline date and

baseline area, and no relevant major source construction has already

occurred since the major source baseline date.” The TCEQ guidelines are

consistent with this determination.

In response to TCEQ’s comment on the 2015 AQA, the following permitting

actions were evaluated in the increment consumption analysis for PM2.5

based on a search of the TCEQ Central Registry and the GroupWise Remote

Document Server. As a conservative approach for those actions included

in the model, sources modified source after October 20, 2010 were

modeled at the permitted emission rates in lieu of the actual emissions

increase. Stack parameters were obtained from the annual emissions

inventory report or the NAAQS analysis inventory.

1. GeorgiaPacific Wood Products South LLC, Corrigan, Polk County, RN100543073 – Project No. 214048 Modeled Source ID: FUG16

Description: Flying Saws Material Transfer Handling Fugitives



PM2.5 emission rate: 0.01 lb/hr

INCLUDED

2. GeorgiaPacific Wood Products South LLC, Corrigan, Polk County, RN100543073 – Project No. 172852, PBR 100149 Modeled Source ID: 336949

Description: S11 Sander Baghouse Stack


INCLUDED

3. GeorgiaPacific Wood Products South LLC, Corrigan, Polk County, RN100543073 – Project No. 179300, 179301, and PBR 95222 Modeled Source ID: 336950

Description: S12 Dry Waste Baghouse Stack


INCLUDED

4. GeorgiaPacific Wood Products South LLC, Corrigan, Polk County, RN100543073 – Project No. 179300, 179301, and PBR 101493 Modeled Source ID: FUG10

Description: Briquetter System


INCLUDED

5. GeorgiaPacific Wood Products South LLC, Corrigan, Polk County, RN100543073 – Project No. 171162, and PBR 92897 Modeled Source ID: STEMPBLR

Description: 80 MMBtu/hr temporary boiler


INCLUDED

Emissions decrease from S‐06, Wood‐Fired Boiler No. 1

NOT INCLUDED

6. GeorgiaPacific Wood Products South LLC, Camden, Polk County, RN101286227 – Project No. 219753, and PBR 124368 No hourly emissions increases

NOT INCLUDED

7. GeorgiaPacific Wood Products South LLC, Camden, Polk County, RN101286227 – Project No. 220709 Modeled Source ID: 345064



Description: F18/Sawmill Building


INCLUDED

Modeled Source ID: 345055

Description: F02/Fiber Line


INCLUDED

Modeled Source ID: 345054

Description: F04/Drum Debarker


INCLUDED


Description: S10/Veneer Dryer No. 3


INCLUDED


Description: K‐03/Continuous Kiln No. 3


INCLUDED


Description: S15/Plywood Sander Baghouse


INCLUDED


Description: F23 /Material Handling Transfer Points


INCLUDED




Description: S22 /Fuel Silo Cyclone

PM2.5 emission rate: 1.31 lb/hr (on PBR 102504, higher than

current MAERT Table)

INCLUDED

13. GeorgiaPacific Wood Products South LLC, Corrigan, Polk County, RN100543073 – Permit No. 83020 NOT INCLUDED – prior to October 20, 2010

14. GeorgiaPacific Wood Products South LLC, Corrigan, Polk County, RN100543073 – PBR 79112 NOT INCLUDED – prior to October 20, 2010

A review of recent facility permitting data subsequent to submittal of the 2015 AQA will

be conducted and any additional increment consuming sources will be added to the

increment consumption modeling.



3.0 BUILDING DOWNWASH AND GEP

Effects of building downwash on stack plumes will be evaluated at the facility using the

Building Profile Input Program (BPIP) ‐ Plume Rise Model Enhancements (PRIME) model.

BPIP‐PRIME utilizes Good Engineering Practice (GEP) to determine whether or not a stack is

subject to wake effects from a structure or structures. The BPIP‐PRIME model was

developed to incorporate two fundamental features associated with building downwash:

enhanced plume dispersion coefficients due to the turbulent wake, and reduced plume rise

caused by a combination of the descending streamlines in the lee of the building and the

increased entrainment in the wake. Where applicable, sources will be modeled at the

physical stack height unless that height exceeds the GEP stack height. The GEP stack height

is defined as the highest of:

a. Sixty‐five meters, or

b. A height established by applying the formula: HS = Hb + 1.5L where:

HS = GEP stack height measured from the ground level elevation at the base of the stack, Hb = height of nearby structure(s) measured from the ground level elevation at the base of the stack, L = lesser dimension (height or projected width) of nearby structures. "Nearby" is defined as "that distance up to five times the lesser of the height

or width dimension of a structure, but not greater than 0.8 kilometers (0.5 miles).

Building dimensions to be used in the modeling analysis are shown below:



Building Height (ft)Strander Bldg/Bark Hog 60.88

Screens/RTO EC Bldg 18.69

Dryer/EC Room 20.84

Greens Screens bldg 20.86

Magnet Tower 34.00

Dry Screens Bldg 39.00

Thermal Oil Pump Bldg 24.60

Blender Bldg 70.55

Secondary Wax Thermal Oil Bldg 17.65

Fork Truck fuel Island Bldg 16.75

Main Process Bldg (Forming Line/Press Area) Tier 1 52.00



Main Process Bldg (Finishing Area) 47.71

Administration/Scale house 22.54

Vacuum Breaker Bldg 13.50

Fire Pump House Bldg 13.84

Water Treatment bldg 16.94

DRYSCRN 27

Bldg 1 47.00

Bldg 2 30.00

Bldg 3 25.00

Bldg 4 43.00

Bldg 5 43.00

Bldg 6 43.00

FUELBIN 51.00



4.0 PM2.5 SECONDARY FORMATION AND OZONE IMPACTS ANALYSIS

As part of the assessment of off‐site impacts from PM2.5 and ozone, secondary formation

of PM2.5 attributed to emissions of SO2 and NOx, and ozone impacts attributed to

emissions of NOx and VOC, must be addressed. For this reconciliation, NOx emissions are

decreasing. However, due to change in methodology, an analysis will be conducted for

the revised NOx emissions with the current methodology. Please note that reconciled SO2

and VOC emissions are less than the PSD significant emission rates. Therefore, significant

secondary PM2.5 and ozone formation is not expected, consistent with EPA guidance.

US EPA has developed a method to estimate single source impacts of secondary

pollutants as a Tier 1 approach. This assessment is contained in the US EPA document,

Guidance on the Development of Modeled Emission Rates for Precursors (MERPs) as a Tier

1 Demonstration Tool for Ozone and PM2.5 Under the PSD Permitting Program (EPA‐454/R‐

16‐006, December 2016). The guidance uses existing empirical relationships between

precursors and secondary impacts. A MERP is defined as an emission rate of a precursor

that is expected to result in a change in the ambient ozone or PM2.5 that would be less

than a specific air quality concentration threshold for ozone or PM2.5. MERPs for each

precursor may be based on either the most conservative (lowest) values across a

region/area or the source‐specific value derived from a more similar hypothetical source

modeled by a permit applicant, permitting authority, or US EPA.

Step 1 of the ozone evaluation requires the determination of local ozone concentrations.

Fortunately, USEPA maintains a monitor in Polk County and publishes the results of this

monitoring on their AirData website. This monitor is the “Alabama‐Coushatta”, AQS Site

ID: 48‐373‐9991. This monitor is located approximately 20 miles south‐southeast of the

proposed facility. From this data, the 4th highest 8‐hour values for 2016, 2017, and 2018

were obtained and averaged. Based on this, the ambient background concentration of

ozone in this region, in the form of the 8‐hour NAAQS, is 60 ppb.

The MERP analysis following the guidelines in Appendix Q and R of the TCEQ Air Quality

modeling Guidelines (November 2019) will be addressed in the AQA report.



5.0 ADDITIONAL IMPACTS AND CLASS I ANALYSIS

The Additional Impacts and Class I Analyses approved in the original 2015 AQA is not

affected by the proposed reconciliations. Therefore, no changes to these sections are

being proposed.

6.0 REPORT PREPARATION

The modeling report will contain a discussion of all items listed on TCEQ’s Modeling Protocol

Checklist. In addition, it will contain all of the information set forth in the TCEQ Air Quality

Modeling Guidelines, Section VI, Reporting Requirements.

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