OREGON DEP AR'fMENT OF ENVIRONMENTAL QUALITY .~ OREGON ... · PDF fileOREGON DEP AR'fMENT OF ENVIRONMENTAL QUALITY OREGON TITLE V OPERATING PERMIT ... CH4 co co,e COMS CPMS DEQ

Pennitnumber: 22,0143-TV-01 Expiration date: 02/01/18

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.~ OREGON DEP AR'fMENT OF ENVIRONMENTAL QUALITY

OREGON TITLE V OPERATING PERMIT

.t•1K•1 Stale Cf Oreg:ln Department of Envlronmenlal Quality

Air Quality Division Western Region

750 Front St. NE, Suite 120 Salem, OR 97301-1039

Telephone (503) 378-8240

Issued in accordance with the provision of ORS 468A.040 and based on the land use compatibility findings included in the permit record,

"····

Fiakebb~1rlf11ti~~~~~~ iim·Aed -;-~·.:; ::;~!~-\ :~·~~ );; ~:· P.o,;:eqn:'fl2.8, ··<·. ·:.); Jl,,:·: ., ,---:~.-Albany, OR 97321

.. , , ,,, iJ:lE.O~TION RELIED UPON: ,_, ' '

J:· l_,_i .-~_)' t-'i l, :-:.;,";\._1 \. I · .... >.Applicatiol:FN'umber:

;e-.;· ~r'i'I:·Re.ce;ivec;I:··.i !.1'h' Updated:

25269 . 08!18/10

03/08/11; 03/09/11; 04/11/11

PLANT SITE LOCATION: LAND USE COMPATIBILITY STATEMENT: Dura flake 2550 Old Salem Road NE Millersburg, OR 97321

Nature of Business: Particleboard Manufacturing, 10,000 or more ft2/bour, %" fmished product basis Fuel Burning Equipment, outside AQMA, 10 million or more Btufbour heat input

RESPONSIBLE OFFICIAL

Title: Plant Manager

Issued by: City of Millersburg Dated: 11/22/93

SIC 2493

4961

NAICS 321219

221330

FACILITY CONTACT PERSON

Name: Jason Young Title: Technical Director/Enviromnental Manager Phone: (541) 928-3341

Alt.: Dave Lyon Title: EHS Manager, Eugene MDF Phone: (541) 744-4639 ·

TABLE OF CONTENTS

Permitnumber: 22-0143-TV-01 Expiration date: 02/01/18

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LIST OF ABBREVIATIONS ..................................................................................... Error! Bookmark not defined.

PERMITTED ACTIVITIES .......................................................................................................................................... 5

EMISSIONS UNIT (EU) AND POLLUTION CON1ROL DEVICE (PCD) IDENTIFICATION .............................. 5

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING REQUIREMENTS ........................................................................................................................................................ 6

Facility Wide ............................................................................................................................................................. 6 Plywood and Composite Wood NESHAP ................................................................................................................. 9 Boiler #1 and Boiler #2 (Boil-! and Boil-2) ............................................................................................................ 21 #4 Green Dryer (GD) .............................................................................................................................................. 23 Face Dryer FD-1 (FD) ............................................................................................................................................. 25 Core Dryers CD-I and CD-2 (CD) .......................................................................................................................... 27 Press 3 (Press-3E) .................................................................................................................................................... 3 0 Board Cooler 3 (BC3) ............................................................................................................................................. 32 Press 4 (Press-4E) .................................................................................................................................................... 3 3 Board Cooler 4 (BC4) ............................................................................................................................................. 35 Material Handling-!, 3, 4, 5 (MH -1, 3, 4, 5) ........................................................................................................... 36 Material Handling -2 (MH-2) ................................................................................................................................... 37 Piles and Truck Dump Building (Piles and TDB) ................................................................................................... 39 Coating Usage ( CU) ................................................................................................................................................ 40

INSIGNIFICANT ACTIVITIES EMISSION LIMITS AND STANDARDS ............................................................ 40

PLANT SITE EMISSION LIMITS ............................................................................................................................. 41

GENERAL TESTING REQUIREMENTS ................................................................................................................. 47

General NESHAP Testing Requirements ................................................................................................................ 48

GENERAL MONITORING AND RECORDKEEPING REQUIREMENTS ............................................................ 51

General Title V Monitoring Requirements .............................................................................................................. 51 General Title V Recordkeeping Requirements ........................................................................................................ 52 NESHAP Recordkeeping Requirements ................................................................................................................. 52

REPORTING REQUIREMENTS ............................................................................................................................... 54

General Title V Reporting Requirements ................................................................................................................ 54 Semi-annual and Annual Title Reports ................................................................................................................ , ... 55 Greenhouse Gas Reporting ...................................................................................................................................... 56 Other Title V Reporting Requirements ................................................................................................................... 57 NESHAP Notifications ............................................................................................................................................ 57 NESHAP Reporting ................................................................................................................................................ 59

EMISSION FEES ........................................................................................................................................................ 62

NON-APPLICABLE REQUIREMENTS ................................................................................................................... 63

Permit number: 22-0143-TV-01 Expiration date: 02/01/18

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GENERAL CONDITIONS ......................................................................................................................................... 64

TABLES to Subpart DDDD orPart 63 ....................................................................................................................... 70

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LIST OF ABBREVflrriONS THAT MAY BE USED IN THIS PERMIT

ACDP Act Annual ASTM BDT Btu CFR CEMS CH4 co co,e COMS CPMS DEQ dscf EF EPA EU FCAA FSA GHG gr/dscf HAP ID I&M Mlbs Msf N20 NA NESHAP NOx NSPS o, OAR ODEQ ORS O&M Pb PCD PM PM10

PMz.s ppm PSEL so, SSM ST VE VMT voc

Air Contaminant Discharge Permit Federal Clean Air Act Any 12 month consecutive period American Society of Testing and Materials Bone dry ton British thermal unit Code of Federal Regulations Continuous emissions monitoring system Methane (greenhouse gas) Carbon Monoxide Carbon dioxide equivalent Continuous opacity monitoring system Continuous parameter monitoring system Department ofEnviromnental Quality Dry standard cubic feet Emission factor US Enviromnental Protection Agency Emissions Unit Federal Clean Air Act Fuel sampling and analysis Greenhouse gas Grain per dry standard cubic foot (1 pound~ 7000 grains) Hazardous Air Pollutant as defined by OAR 340-244-0040 Identification label or code Inspection and maintenance One thousand pounds Thousand square feet Nitrous oxide (greenhouse gas) Not applicable National Emission standard for Hazardous Air Pollutants Nitrogen oxides New Source Performance Standards Oxygen Oregon Administrative Ruies Oregon Department of Enviromnental Quality Oregon Revised Statutes Operation and maintenance Lead Pollution Control Device Particulate matter Particulate matter less than 10 microns in size Particulate matter less than 2.5 microns in size Parts per million Plant 'Site Emission Limit Sulfur dioxide Startup, shutdown and malfunction Source test Visible emissions Vehicle miles traveled Volatile organic compounds

PERMITTED ACTIVITIES

P01mit number: 22-0143-TV-01 Expiration date: 02/01/18

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I. Until such tirue as this permit expires or is modified or revoked, the permittee is allowed to discharge air contaminants from those processes and activities directly related to or associated with air contaminant source(s) in accordance with the requirements, limitations, and conditions of this permit. [OAR340-218-00IO, 340-218-2200(2), and 340-032-0240]

2. All conditions in this permit are federally enforceable, meaning that they are enforceable by DEQ, EPA, and citizens under the Clean Air Act, except as noted below:

2.a. Conditions 5, 6, 7, G5, and G9 (OAR 340-248-0005 through 0180) are only enforceable by the state. [OAR 340-218-0060]

2.b. Conditions 13 (RICE,N(l~,HA~) a~\1 42 (Boiler NESHAP) are only federally enforceable until DEQ adopts the rules iJJto the Oregon SIP.

·~MISSIONS UNIT(EU) AND POLLUTION CONTROL DEVICE (PCD) IDENTIFICATION

3. The emissions units regulated by this permit are the following [OAR 340-218-0040(3)]: .

Emission Unit Description EUID Pollution Control Device Description PCDID

Boiler I Boil-! None NA

Boiler 2 Boil-2 None NA

Green Dryer #4 GD Wet Electrostatic Precipitator ET-1 & ET-2

Regenerative Thermal Oxidizer RT0-1

Face Dryer (FD-1) FD Baghouses BH-50 BH-51

Core Dryers (CD-I & CD-2) CD Baghouses BH-52 . BH-53

Press 3 Press-3E Enclosures and Baghouses BH-45 &46

Regenerative Catalytic Oxidizer RC0-1

Board Cooler 3 BC3 None NA

Press 4 Press-4E Enclosures and Baghouses BH-47, 48 & 49

Regenerative Catalytic Oxidizer RC0-2

Board Cooler 4 BC4 None NA

Truck Dump Building TDB Enclosure and Baghouse BH-55

Material Handling-! MH-1 Baghouses BH-1, 2, 11, 12, 14, 15, 16, 17, 20

Material Handling-2 MH-2 Baghouses BH-13, BH-24

Material Handling-3 MH-3 Baghouses BH-8, 9, 18, 54, 56, 57

Material Handling-4 MH-4 Baghouses BH-22, 23, 25, 28,29,30

Emission Unit Description EUID

Material Handllng-5 MH-5

Raw Material Storage Piles Piles

Resin Storage Tanks Tanks

Coating Usage cu Aggregate Insignificant (VOC, PM, PM10, AI PM2.s)


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Pollution Control Device Description PCDID

Baghouses BH-4, 26, 27, 32,33,34,35

Enclosure NA

None NA

None NA

None NA

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING REQUIREMENTS

The following tables and conditions contain the applicable requirements along with the testing, monitoring, and recordkeeping requirements for the emissions units to which those requirements apply .

. Facility Wide

Table 1 Summary of Facility Wide Emission Limits and Standards

Applicable Condition Pollutant/ Monitoring Requirement Number Parameter Limit/Standard Monitoring Requirement Condition

340-208-0210 4 Fugitive emissions Minimize by taking Complaint investigation 7 reasonable precautions to prevent PM from becoming airborne

340-208-0300 5 Air contaminants No nuisance Complaint investigation 7

340-208-0450 6 PM>250)..tm No fallout Complaint investigation 7

340-228-0100 8 Sulfur content of oil Residual oil< 1.75% Determine sulfur content 9

340-228-0110(1) fuels No.2 oil< 0.5% of :fuel oils by vendor certificates or laboratory

340-228-0110(2) No. 1 oil< 0.3% an'alysis

340-234-0520(2) 10 Particulate Matter 140.3 lbslhour per Record keeping 11 Particleboard Rule

(daily average)

340-244-0240 12 Gasoline Dispensing Work Practices Recordkeeping 12

40 CFR Part 63, 13 Organic HAPs See Subpart ZZZZ See Subpart z;zzz, 13 Subpart ZZZZ

63.2232(a) 14 HAP Must operate PWCP sources Recordkeeping 119-125 in compliance with requirements ofDDDD.

63.2240(b) 15 HAP Must use a control system and Performance Testing 25 demonstrate that emissions and operating parameters meet the requirements in Continuous Compliance

26-35 Tables lB and 2 to DDDD Requirements

63.2241 16, 17 HAP Must meet work practice Continuous Compliance 27,28 requirements in Table 3 to Requirements DDDD or approved alternative.

63.4 18-21 HAP General NESHAP compliance None NA requirements: Prohibited Activities, Circumventiori,

<~

Applicable Requirement

63.2250(a)- (b), 63.6(e)(1), 63.6(!)(1)

63.2250(c), 63.6(e)(3), 63.8(c)(1)(Hi)

63.2251

Condition Number

22

23

24

•

Pollutant/ Parameter

HAP

HAP

HAP

Fugitive Emissions Requirements

Limit/Standard

and Fragmentation


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Monitoring Monitoring Requirement Condition

Must be in compliance with Recordkeeping 119 - 125 NESHAP requirements at all times except during periods of SSM. Must operate all equipment in a manner consistent with safety and good air pollution control practices. Malfunctiori.s must be· corrected as soon as practicable.

Must develop and implement Recordkeeping a written startup, shutdown, and malfunction plan

Routine control. device·:· - Recordkeeping maintenance e:Xempti0n_:·1

119, 123-125

119

4. The permittee must not allow or permit any materials to be handled, transported, or stored; or a building, its appurtenances, or a road to be nsed, constructed, altered, repaired or demolished; or any equipment to be operated, without taking reasonable precautions to prevent particulate matter from becoming airborne. [OAR 340-208-0210(2)]

Nuisance Conditions

5. The permittee must not cause or allow air contaminants from any source to cause a nuisance. Nuisance conditions will be verified by Department personnel. [OAR 340-208-0300] This condition is enforceable only by the State.

6. The permittee must not cause or permit the emission of any particulate matter that is larger than250 microns in size at sufficient duration or quantity, so as to create an observable deposition upon the real property of another person. The Department will verify that the deposition exists and will notify the permittee that the deposition must be controlled. [OAR 340-208-0450] This condition is enforceable only by the State.

Fugitive Dust and Nuisance Conditions Monitoring Requirement

7. The permittee must maintain a log of each nuisance, particulate matter fallout, or fugitive dust complaint received by the permittee during the operation of the facility. Documentation must include date of contact, time of observed nuisance condition, description of nuisance condition, location of receptor, status of plant operation during the observed period, and time of response to complainant. A plant representative must promptly investigate the condition following the receipt of the nuisance complaint and a plant representative must provide a response to the complainant within 24 hours, if possible. This condition is only enforceable by the state. [OAR 340-218-0050(3)(a)]

Fuel Standards

8. Fnel oils must not contain more than:

8.a. 0.3% sulfur by weight for ASTM Grade I distillate oil; [OAR 340-228-0110(1)] 8.b. 0.5% sulfur by weight for ASTM Grade 2 distillate oil; [OAR 340-228-0110(2)]

Permit number: 22-0143-TV-01 Expiration date: 02/01/1S

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S.c. 1.75% sulfur by weight for residual oil; [OAR 340-22S-0100] S.d. The permittee is allowed to use on-specification used oil that contains no more than 0.5% sulfur

by weight. The permittee must obtain analyses from the marketer or, if generated on site, have the· used oil analyzed, so that it can be demonstrated that each shipment of oil does not exceed the used oil specifications contained in 40 CFR Part 279.11, Table 1.

Fuel Monitoring Requirements

9. The permittee must monitor the sulfur content of each shipment of fuel received by: [OAR 340-21S-0050(3)(a)]

9.a. Obtaining a sulfur content certificate from each vendor for each shipment of fuel received; or

9.b. Analyzing or having analyzed by a contract laboratory a representative sample taken by the permittee from each shipment of fuel received.

Particleboard Rule

10. Particulate matter (PM) emissions from the entire facility, excluding emission units Boil-1, Boil-2, TDB, Piles, and Coating Usage must not exceed 140.3 pounds per hour as a daily average. [OAR 340-234-0520(2)]

Particleboard Rule Monitoring

11. The permittee must perform the following monitoring to demonstrated compliance with the requirements of Condition 10.

11.a. The permittee must calculate the combined daily hourly average particulate emission rate from emissions uults GD, FD, CD, Press-3E, BC3, Press-4E, BC4, MH-1, MH-2, MH-3, MH-4 and MH-5 by dividing the total daily emissions from these emissions units by the number of hours Press-3E or Press-4E, whichever is greater, was operated that day. The results of these calculations will then be compared to the standard in Condition 10.

ll.b. As an alternative to the above emission calculation monitoring, the permittee may keep daily records demonstrating that the combined production ofPress-3E and Press-4E does not exceed 46,764 square feet per hour, o/4 inch finished basis as a daily hourly average (i.e., the total average hourly production is calculated by dividing the total daily production from Press-3E and Press-4E by the number of hours either Press-3E or Press-4E, whichever is greater, was operated that day).

Gasoline Dispensing Facilities (GDF Facilities) [OAR 340-244-0240]

12. The permittee must not:

12.a. Allow gasoline to be handled in a manner that would result in vapor releases to the atroosphere for extended periods of time. Measures to be taken include, but are not limited to, the following:

12.a.i. 12.a.ii.

12.a.iii.

12.a.iv.

Minimize gasoline spills; Do not top off or overfill vehicle tanks. If a person can confrrm that a vehicle tank is not full after the nozzle clicks off (such as by checking the vehicle's fuel tank gauge), the person may continue to dispense fuel using best judgment and caution to prevent a spill; Post a sign at the gasoline dispensing facility instructing a person filling up a motor vehicle to not top the vehicle tank; Clean up spills as expeditiously as practicable;

12.a.v.

12.a.vi.

12.a.vii.


Page 9 of75

Cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when not in use; Minimize gasoline sent to open waste collection systems that collect and transport gasoline to reclamation and recycling devices, such as oil/water separators. Ensure that cargo tanks unloading at the gasoline dispensing facility comply with Conditions 12.a.i through 12.a.vi above.

12.b. Transfer or allow the transfer of gasoline into any storage tank with a capacity of250 gallons or more unless the tank is equipped with a submerged fill pipe as follows:

12.b.i.

12.b.ii.

Submerged fill pipes installed after 11/9/06 must be no more than 6 inches fi·om the bottom of the storage tank. Submerged fill pipes installed on or before 11/9/06 must be no more than 12 inches from the bottom of the storage tank.

Recii)_r~cating Internal Combustion Engine (RICE) NESHAP ,,. i'

13. If applicable, the permittee must comply with all relevant provisions of the Reciprocating Internal Combustion Engine NESHAP ( 40 CFR Part 63, Subpart ZZZZ) for any equipment at the facility.

Plywood and Composite Wood Products (PCWP) NESHAP

14. The permittee shall operate and maintain the PCWP NESHAP affected source in compliance with the requirements of 40 CFR Part 63 Subpart DDDD. The PCWP NESHAP affected source is the collection of all the facility's emission units except for Boiler I, Boiler 2, and Coating Usage. [40 CFR 63.2232(a)]

Compliance Options, Operating Requirements, and Work Practice Requirements

Compliance Options and Operating Requirements

15. The pennittee must use an emissions control system and demonstrate that the resulting emissions meet the compliance options and operating requirements in Tables lB ap.d 2. If owning or operating a reconstituted wood product press at a. new or existing affected source or a reconstituted wood product board cooler at a new affected source, and choosing to comply with one of the concentration-based compliance options for a control system outlet (presented as- option numbers 2, 4, and 6 in Table lB), the permittee must have a capture device that either meets the definition of wood products enclosure in 40 CFR 63.2292 or achieves a capture efficiency of greater than or equal to 95 percent. [40 CFR 63.2240(b)]

W ark Practice Requirements

16. The permittee must meet each work practice requirement in Table 3 that applies. [40 CFR 63.224l(a)]

17. As provided in 40 CFR 63.6(g), the Department may choose to grant permission to use an alternative to the work practice requirements in 40 CFR 63.2241. [40 CFR 63.224l(b)]

General Compliance Requirements

Prohibited Activities

18. The permittee must not operate any affected source in violation of the requirements of 40 CFRPart 63. Affected sources subject to and in compliance with either an extension of compliance or an exemption from compliance are not in violation of the requirements of 40 CFR Part 63. An extension of compliance can be granted by the Department under 40 CFR Part 63 or by the President under section 112(i)(4) of the Clean Air Act. [40 CFR 63.4(a)(l)]


Page 10 of75

19. The permittee must not fail to keep records, notify, report, or revise reports as required under 40 CFR Part 63. [40 CFR 63.4(a)(2)]

Circumvention

20. The permittee must not build, erect, install, or use any article, machine, equipment, or process to conceal an emission that would otherwise constitute noncompliance with a relevant standard. Such conceahnent includes, but is not limited to: [40 CFR 63.4(b)]

20.a. The nse of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere.

20.b; The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions.

Fragmentation

21. Fragmentation which divides ownership of an operation within the same facility among various owners where there is no real change in control will not affect applicability. The permittee must not use fragmentation or phasing of reconstruction activities (i.e., intentionally dividing reconstruction into multiple parts for purposes of avoiding new source requirements) to avoid becoming subject to new source requirements. [40 CFR 63.4(c)]

22. The permittee must be in compliance with the compliance options, operating requirements, and the work practice requirements ill the NESHAP at all times, except during periods of process unit or control device startup, shutdown, and malfunction; prior to process unit initial startup; and during the routine control device maintenance exemption specified in Condition 24. The compliance options, operating requirements, and work practice requirements do not apply during times when the process unit( s) subj eel to the compliance options, operating requirements, and work practice requirements are not operating, or during scheduled startup and shutdown periods, and during malfunctions. These startup and shutdown periods must not exceed the minimum amount of time necessary for these events. [40 CFR 63.2250(a)]

22.a. If a startup, shutdown, or malfunction of one portion of an affected source does not affect the ability of particular emission points within other portions of the affected source to comply with the non-opacity emission standards set forth in 40 CFR Part 63, then that emission point must still comply with the non-opacity emission standards and other applicable requirements. [40 CFR 63.6(:f)(l)]

22.b. At all times, including periods of startup, shutdown, and malfunction, the permittee must always operate and maintain the affected source, including associated air pollution control and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. During a period of startup, shutdown, or malfunction, this general duty to minimize emissions requires that the permittee reduce emissions from the affected source to the greatest extent which is consistent with safety and good air pollution control practices. The general duty to minimize emissions during a period of startup, shutdown, or malfunction does not require the permittee to achieve emission levels that would be required by the applicable standard at other times ifthis is not consistent with safety and good air pollution control practices, nor does it require the permittee to make any further efforts to reduce emissions iflevels required by the applicable standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Department which may include, but is not limited to, monitoring results, review of operation and maintenance procedures (including the startup, shutdown, and malfunction plan required in Condition 23), review of operation and maintenance records, and inspection of the source. [40 CFR 63 .6( e )(1 )(i) and 63.2250(b)]


Page II of75

22.c. Malfunctions must be corrected as soon as practicable after their occurrence. To the extent that an unexpected event arises during a startup, shutdown, or malfunction, the pe1mittee must comply by minimizing emissions during such a startup, shutdown, and malfunction event consistent with safety and good air pollution control practices. [40 CFR 63.6(e)(l)(ii)]

Startup, Shutdown, and Malfunction Plan

23. The permittee must develop and implement a written startup, shutdown, and malfunction plan that describes, in detail, procedures for operating and maintaining the source during periods of startup, shutdown, and malfunction, and a program of corrective action for malfunctioning process and air pollution control and monitoring equipment used to comply with the relevant standard. The startup, shutdown, and malfunction plan need not address any scenario that would not cause the permittee to exceed an applicable PCWP NESHAP emission limitation. This plan must be developed by the permittee by the source's compliance date for that relevant standard. [ 40 CFR 63.6( e )(3), 63.8( c )(!)(iii), and 63.2250( c)]

23.a. The purpose of the startup, shutdown, and malfunction plan is to: [ 40 CFR 63 .6( e )(3)(i)] .. , 23.a.i.

23.a.ii.

23.a.iii.

Ensure that, at all times, the permittee operates and maintains each affected source, including associated air pollution control and monitoring equipment, in a marmer which satisfies the general duty to minimize emissions established by Condition 22.b; [40 CFR 63.6(e)(3)(i)(A)]

Ensure that the permittee is prepared to correct malfunctions as soon as practicable after their occurrence in order to minimize excess emissions of hazardous air pollutants; and [40 CFR 63.6(e)(3)(i)(B)]

Reduce the reporting burden associated with periods of startup, shutdown, and malfunction (including corrective action taken to restore malfunctioning process and air pollution control equipment to its normal or usual mauner of operation). [ 40 CFR 63.6(e)(3)(i)(c)]

23.b. When actions taken during a startup or shutdown and the startup or shutdown causes the source to exceed any applicable PCWP NESHAP emission limitation, or malfunction (including actions taken to correct a malfunction) are consistent with the procedures specified in the affected source's startup, shutdown, and malfunction plan, the permittee must keep records for that event which demonstrate that the procedures specified in the plan were followed. These records may take the form of a "checklist," or other effective form ofrecordkeeping that confnms conformance with the startup, shutdown, and malfunction plan and describes the actions taken for that event. In addition, the permittee must keep records of these events as specified in Condition 119, including records of the occurrence and duration of each startup or shutdown (if the startup or shutdown causes the source to exceed any applicable PCWP NESHAP emissions limitation), or malfunction of operation and each malfunction of the air pollution control and monitoring equipment. Furthermore, the permittee must confnm that actions taken during the relevant reporting period during periods of startup, shutdown, and malfunction were consistent with the affected source's startup, shutdown and malfunction plan in the semiaunual report required in Condition 128. [40 CFR 63.6(e)(3)(iii)]

23.c. If an action taken by the permittee during a startup, shutdown, or malfunction (including an action taken to correct a malfunction) is not consistent with the procedures specified in the affected source's startup, shutdown, and malfunction plan, and the source exceeds any applicable emission limitation in the relevant emission standard, then the permittee must record the actions taken for that event and must report such actions within 2 working days after commencing actions inconsistent with the plan, followed by a letter within 7 working days after the end of the event, in accordance with Condition 145 (unless the permittee makes alternative reporting arrangements, in


Page 12 of75

advance, with the Department). A working day means any day on which the State of Oregon's govermnent offices are open for normal business and does not include Saturday, Sunday and State holidays. [40 CFR 63.6(e)(3)(iv)]

23 .d. The pennittee must maintain at the affected source a current startup, shutdown, and malfunction plan and must make the plan available upon request for inspection and copying by the Department. In addition, if the startup,. shutdown, and malfunction plan is subsequently revised as provided in Condition 23 .g, the permittee must maintain at the affected source each previous (i.e., superseded) version of the startup, shutdown, and malfunction plan, and must make each such previous version available for inspection and copying by the Department for a period of 5 years after revision of the plan. If at any time after adoption of a startup, shutdown, and malfunction plan the affected source ceases operation or is otherwise no longer subject to the provisions of 40 CFR Part 63, the permittee must retain a copy of the most recent plan for 5 years from the date the source ceases operation or is no longer subject to 40 CFR Part 63 and must make the plan available upon request for inspection and copying by the Department. The Department may at any time request in writing that the permittee submit a copy of any startup, shutdown, and malfunction plan (or a portion thereof) which is maintained at the affected source or in the possession of the pennittee. Upon receipt of such a request, the permittee must promptly submit a copy of the requested plan (or a portion thereof) to the Department. The pennittee may elect to submit the required copy of any startup, shutdown, and malfunction plan to the Department in an electronic format. If the permittee claims that any portion of such a startup, shutdown, and malfunction plan is confidential business information entitled to protection from disclosure under section 114( c) of the Act or 40 CFR 2.301, the material which is claimed as confidential must be clearly designated in the submission. [40 CFR 63.6(e)(3)(v)]

23.e. To satisfy the requirements of this Condition to develop a startup, shutdown, and malfunction plan, the permittee may use the affected source's standard operating procedures (SOP) manual, or an Occupational Safety and Health Administration (OSHA) or other plan, provided the alternative plans meet all the requirements ofthis section and are made available for inspection or submitted when requested by the Department. [ 40 CFR 63. 6( e )(3 )(vi)]

23 .f. Based on the results of a determination made under Condition 22.b, the Department may require that the pennittee make changes to the stmtup, shutdown, and malfunction plan for that source. The Department must require appropriate revisions to a startup, shutdown, and malfunction plan, ifthe Department fmds that the plan: [40 CFR 63.6(e)(3)(vii)]

23.f.i.

23.f.ii.

23.f.iii.

23.f.iv.

Does not address a startup, shutdown, or malfunction event that has occurred; [ 40 CFR 63.6( e )(3)(vii)(A)]

Fails to provide for the operation of the source (including associated air pollution control and monitoring equipment) during a startup, shutdown, or malfunction event in a maJIDer consistent with the general duty to minimize emissions established by Condition 22.b; [40 CFR 63.6(e)(3)(vii)(B)]

· Does not provide adequate procedures for correcting malfunctioning process and/or air pollution control and monitoring equipment as quickly as practicable; or [ 40 CFR 63.6(e)(3)(vii)(C)]

Includes an event that does not meet the definition of startup, shutdown, or malfunction listed in 40 CFR 63.2. [ 40 CFR 63 .6( e )(3)(vii)(D)]

23.g. The pennittee may periodically revise the startup, shutdown, and malfunction plan for the affected source as necessary to satisfy the requirements of 40 CFR Part 63 or to reflect changes in equipment or procedures at the affected source. Unless the Department provides otherwise, the


Page 13 of75

permittee may make such revisions to the startup, shutdown, and malfunction plan without prior approval by the Department. However, each such revision to a startup, shutdown, and malfunction plan must be reported in the semiannual report required by Condition 14 7. If the startup, shutdown, and malfunction plan fails to address or inadequately addresses an event that meets the characteristics of a malfunction but was not included in the startup, shutdown, and malfunction plan at the thne the plan was developed, the permittee must revise the startup, shutdown, and malfunction plan within 45 days after the event to include detailed procedures for operating and maintaining the source during shnilar malfunction events and a program of corrective action for shnilar malfunctions of process or air pollution control and monitoring equipment. In the event that the permittee makes any revision to the startup, shutdown, and malfunction plan which alters the scope of the activities at the source which are deemed to be a startup, shutdown, or malfunction, or otherwise modifies the applicability of any emission limit, work practice requirement, or other requirement in a standard established under 40 CFR Part 63, the revised plan must not take effect until after the permittee has provided a written notice

" · describing the revision to the Department. [40 CFR 63.6(e)(3)(viii)]

23 .h. Any revisions made to the startup, shutdown, and malfunction plan in accordance with the ·'· procedures established in the permit shall not be deemed to constitute permit revisions under 40

CFR Part 70 or 71 and the elements of the startup, shutdoWn, and malfunction plan shall not be considered an applicable requirement under 40 CFR Part 70 or 71. Moreover, none of the procedures specified by the startup, shutdown, and malfunction plan for this source shall be deemed to fall within the permit shield provision in section 504(f) of the Clean Air Act. [ 40 CFR 63.6( e)(3)(ix)]

Routine Control Device Maintenance Exemption Requirements

24. The permittee may operate emissions units GD, Press-3E, and Press-4E without the associated oxidizer during the performance ofthe routine control device maintenance procedures identified below and subject to the requirements stated below. [40 CFR 63.225l(a)]

24.a. The maintenance procedures within the scope of the routine control device maintenance exemption are: 24.a.i. Bakeout; 24.a.ii. Bakeout/cleanout; 24.a.iii. Media changeout; 24.a.iv. Catalyst changeout; 24.a.v. Acid washout; 24.a.vi. Catalyst sampling; and 24.a.vii. Other procedures approved in advance by the Department.

24.b. The thne during which the routine control device maintenance exemption is relied upon must not exceed the percentages of process unit operating upthne in Conditions 24.b.i and 24.b.ii. [40 CFR 63.225l(b)]

24.b.i.

24.b.ii.

For R TO 1, the routine control device maintenance exemption must not exceed 3 percent of annual operating upthne of the Green Dryer. [40 CFR 63.225l(b)(l)]

For RCO 1 and RCO 2, the routine control device maintenance exemption must not exceed 0.5 percent of annual operating upthne for the press controlled. [40 CFR 63.225l(b)(2)]

24.c. The duration and frequency of the routine control device maintenance exemption events must not exceed the following. [40 CFR63.225l(c)]

Maintenance Procedures Bakeout Bakeout!Cleanout Media Changeout Catalvst Changeout Acid Washout Catalyst Samnling

Notes:

Duration

6-8 hrs 10-12hrs

7 days 3 davs

3-4 days 2-3 days

Frequency

Pennit number: 22-0143-TV-01 Expiration date: 02/01/18

Page 14 of75

Every 4 weeks1

Every 4 weeks1

Every 3-5 yrs Every 3-5 vrs Every 1-3 yrs

Annual

1Bakeout occurs every two weeks. Once a month the bakeout is followed by cleanout.

24.d. The compliance options and operating requirements do not apply during times when control device maintenance covered under the approved routine control device maintenance exemption is performed. The pennittee must minimize emissions to the greatest extent possible during these routine control device maintenance periods. [40 CFR 63.225l(d)]

24.e. To the extent practical, startup and shutdown of emission control systems must be scheduled during times when process equipment is also shut down. [40 CFR 63.225l(e)]

Performance Testing Requirements

Performance Testing and the Establishment of Operating Requirements

25. The pennittee must conduct each performance test according to the following requirements and according to the methods specified in Table 4 and Conditions 109 and 110. [40 CFR 63.2262(a)]

Periods when performance tests must be conducted

25.a. The permittee must not conduct performance tests during periods of startup, shutdown, or malfunction. [40 CFR 63.2262(b)(l)]

25.b. The pennittee must test under representative operating conditions as defioed in 40 CFR 63.2292. The pennittee must describe representative operating conditions in the performance test report for the process and control systems and explain why they are representative. [40 CFR 63.2262(b)(2)]

Number of test runs

25.c. The pennittee must conduct three separate test runs for each performance test required in this section. Each test run must last at least 1 hour except for: testing of a temporary total enclosure (TIE) conducted using Methods 204A through 204F of40 CFRPart 51, AppendixM, which require three separate test runs of at least 3 hours each; and testing of an enclosure conducted using the alternative tracer gas method in Appendix A to the NESHAP, which requires a minimum of three separate runs of at least 20 minutes each. [40 CFR 63.2262(c)]

Location of sampling sites

25.d. Sampling sites must be located at the inlet (if emission reduction testing or documentation of inlet methanol or formaldehyde concentration is required) and outlet of the control device and prior to any releases to the atmosphere. [40 CFR 63.2262(d)(l)]

Penni! number: 22-0143-TV-01 Expiration date: 02/01/18

Page 15 of75

Collection ofmonitoriog data duriog the performance test

25.e. The pennittee must collect operatiog parameter monitoriog system data at least every 15 mioutes duriog the entire performance test and determioe the parameter or concentration value for the operatiog requirement duriog the performance test usiog the methods specified io Conditions 25 .h through25.i. [40 CFR63.2262(e)]

Nondetect data

25.f. All nondetect data (40 CFR 63.2292) must be treated as one-half of the method detection limit when determiniog total HAP, fonnaldehyde, methanol, or total hydrocarbon (THC) emission rates. [40 CFR 63.2262(g)(l)]

Calculation of percent reduction across a control system

25.g. When complying with any of the compliance options based on percent reduction across a control system io Table IB, as part of the performance test, the permittee must calculate percent reduction usiog Equation 4: [40 CFR 63.2262(h)]

ERin - ERo"' ( ) PR = CE X 100 (Equation4) ERin

Where:

PR = percent reduction, percent;

CE = capture efficiency, percent ( determioed for reconstituted wood product presses and board coolers as required io Table 4);

ER;, = emission rate of total HAP (calculated as the sum ofthe emission rates of acetaldehyde, acroleio, formaldehyde, methanol, phenol, and propionaldehyde ), THC, formaldehyde, or methanol io the iolet vent stream of the control device, pounds per hour;

ER."' = emission rate of total HAP (calculated as the sum of the emission rates of acetaldehyde, acroleio, formaldehyde, methanol, phenol, and propionaldehyde ), THC, formaldehyde, or methanol io the outlet vent stream of the control device, pounds per hour.

Establishiog thennal oxidizer operating requirements

25.h. The permittee must establish operating parameters for RTO 1 according to Conditions 25.h.i through 25 .h.iii. [ 40 CFR 63 .2262(k)]

25 .h.i. Duriog the performance test, the permittee must continuously monitor the firebox temperature during each ofthe required !-hour test runs. The permittee may measure the temperature in multiple locations (e.g., one location per burner) in the combustion chamber and calculate the average ofthe temperature measurements prior to reducing the temperature data to 15-minute averages for purposes of establishing the minimum firebox temperature. The minimum firebox temperature must then be established as the average of the three minimum 15-mioute frrebox temperatures monitored during the three test runs. Multiple three-run performance tests may be conducted to establish a range of parameter values under different operating Conditions. [ 40 CFR 63 .2262(k)(l)]

25 .h.ii. The permittee may establish a different minimum frrebox temperature for the thermal oxidizer by submitting the notification specified in Condition 141 and conducting a repeat performance test as specified in Condition 25.h.i that demonstrates compliance with the applicable compliance options of the NESHAP. [40 CFR

25.h.iii.

63.2262(k)(2)]

Permit number: 22-0143-TV -01 Expiration date: 02/01/18

Page 16 of75

If the thermal oxidizer is a combustion unit that accepts process exhaust into the flame zone, then the permittee is exempt from the performance testing and monitoring requirements specified in Conditions 25.h.i and 25.h.ii. To demonstrate initial compliance, the permittee must submit documentation with the Notification of Compliance Status showing that process exhausts controlled by the combustion unit enter into the flame zone. [40 CFR 63.2262(k)(3)]

Establishing cataMic oxidizer operating requirements

25.i. The permittee must establish catalytic oxidizer operating parameters for RCO I and RCO 2 according to Conditions 25.i.i and 25.i.ii. [40 CFR 63.2262(1)]

25.i.i.

25.i.ii.

During the performance test, the permittee must continuously monitor during the required !-hour test runs either the temperature at the inlet to each catalyst bed or the temperature in the combustion chamber. The permittee must calculate the average of the temperature measurements from each catalyst bed inlet or within the combustion chamber prior to reducing the temperature data to 15-minute averages for purposes of establishing the minimum catalytic oxidizer temperature. The minimum catalytic oxidizer temperature must then be established as the average of the three minimum 15-minute temperatures monitored during the three test runs. Multiple three-run performance tests may be conducted to establish a range of parameter values under different operating conditions. [40 CFR63.2262(1)(1)]

The permittee may establish a different minimum catalytic oxidizer temperature by submitting the notification specified in Condition 141 and conducting a repeat performance test as specified in Conditions 25.i.i and 25.i.ii that demonstrates compliance with the applicable compliance options ofthe NESHAP. [40 CFR 63 .2262(1)(2)]

Continuous Compliance Requirements

Monitoring and Data Collection to Demonstrate Continuous Compliance

26. The permittee must monitor and collect data according to this Condition. [40 CFR 63.2270(a)]

26.a. Except for, as appropriate, monitor malfunctions, associated repairs, and required quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the permittee must conduct all monitoring in continuous operation at all times that the process unit is operating. For purposes of calculating data averages, the permittee must not use data recorded during monitoring malfunctions, associated repairs, out-of-control periods, or required quality assurance or control activities. The permittee must use all the data collected during all other periods in assessing compliance. A monitoring malfunction is any sudden, infrequent, not reasonably preventable failure of the monitoring to provide valid data. Monitoring failures that are caused in part by poor maintenance or careless operation are not malfunctions. Any period for which the monitoring system is out-of-control and data are not available for required calculations constitutes a deviation from the monitoring requirements. [40 CFR 63.2270(b)]

26.b. The permittee may not use data recorded during monitoring malfunctions, associated repairs, and required quality assurance or control activities; data recorded during periods of startup, shutdown, and malfunction; or data recorded during periods of control device downtime covered in any approved routine control device maintenance exemption in data averages and calculations used to


Page 17 of75

report emission or operating levels, nor may such data be used in fulfilling a minimum data availability requirement, if applicable. The permittee must use all the data collected during all other periods in assessing the operation ofthe control system. [ 40 CFR 63 .2270( c)]

26.c. The permittee must determine the 3-hour block average of all recorded readings, calculated after every 3 hours of operation as the average of the evenly spaced recorded readings in the previous 3 operating hours (excluding periods described in Conditions 26.a and 26.b ). [ 40 CFR 63.2270( d)]

26.d. For dry rotary dryer wood moisture monitoring and dry rotary dryer temperature monitoring, determine the 24-hour block average of all recorded readings, calculated after every 24 hours of operation as the average ofthe evenly spaced recorded readings in the previous 24 operating hours (excluding periods described in Conditions 26.a and 26.b). [40 CFR 63.2270(e)]

26.e. To calculate the data averages for each 3-hour or 24-hour averaging period, the permittee must have at least 75 percent ofthe required recorded readings for that period using only recorded readings that are based on valid data (i.e., not from periods described in Conditions 26.a and 26.b ). [40 CFR 63.2270(±)]

Demonstrating Continuous Compliance with the Compliance Options, Operating Requirements, and Work Practice Requirements

27. The permittee must demonstrate continuous compliance with the compliance options, operating requirements, and work practice requirements in this permit that apply according to the methods specified in Tables 7 and 8. [40 CFR 63.2271(a)]

28. The permittee must report each instance in which the permittee did not meet each compliance option, operating requirement, and work practice requirement in Tables 7 and 8 that applies. This includes periods of startup, shutdown, and malfunction and periods of control device maintenance specified in Conditions 28.a and 28.b. These instances are deviations from the compliance options, operating requirements, and work practice requirements in the NESHAP. These deviations must be repmted according to the requirements in Conditions 146 through 149. [40 CFR 63.227l(b)]

28.a. Deviations that occur during a period of startup, shutdown, or malfunction are not violations if the permittee demonstrates to the Department's satisfaction that the permittee was operating in a manner consistent with safety and good air pollution control practices for minimizing emissions. The Department will determine whether deviations that occur during a period of startup, shutdown, or malfunction are violations, according to the provisions in Conditions 22.b, 22.c, and 23. [40 CFR63.227l(b)(2)]

28.b. Deviations that occur during periods of control device maintenance covered by any approved routine control device maintenance exemption are not violations if the permittee demonstrates to the Department's satisfaction that the permittee was operating in accordance with the approved routine control device maintenance exemption. [ 40 CFR 63.2271 (b )(3)]

Emissiou and Parameter Monitoring Requirements

General Continuous Parameter Monitoring Requirements

29. The permittee must install, operate, and maintain each continuous parameter monitoring system (CPMS) in accordance with the following requirements: [ 40 CFR 63 .8(b) and 63 .2269( a)]

29.a. When the emissions from two or more affected sources are combined before being released to the atmosphere, the owner or operator may install an applicable CMS for each emission stream or for the combined emissions streams, provided the monitoring is sufficient to demonstrate compliance

with the relevant standard. [40 CFR 63.8(b)(2)(i)]


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29.b. Ifthe relevant standard is a mass emission standard and the emissions from one affected source are released to the atmosphere through more than one point, the permittee must install an applicable CMS at each emission point unless the installation of fewer systems is approved by the Administrator or provided for in a relevant standard (e.g., instead of requiring that a CMS be installed at each emission point before the effluents from those points are channeled to a common control device, the standard specifies that only one CMS is required to be installed at the vent of the control device). [40 CFR63.8(b)(2)(ii)]

29.c. When more than one CMS is used to measure the emissions from one affected source (e.g., multiple breechings, multiple outlets), the pennittee must report the results as required for each CMS. However, when one CMS is used as a backup to another CMS, the permittee must report the results from the CMS used to meet the monitoring requirements of 40 CFRPart 63. If both such CMS are used during a partlcular reporting period to meet the monitoring requirements of 40 CFR part 63, then the permittee must report the results from each CMS for the relevant compliance period. [40 CFR 63.8(b)(3)]

29.d. The CPMS must be capable of completing a minimum of one cycle of operation (sampling, analyzing, and recording) for each successive 15-minute period. [40 CFR 63.2269(a)(1)]

29 .e. At all times, the permittee must maintain the monitoring equipment including, but not limited to, maintaining necessary parts for routine repairs of the monitoring equipment. [40 CFR 63.2269(a)(2)]

29.f. Record the results of each inspection, calibration, and validation check. [40 CFR 63.2269(a)(3)]

Operation and Maintenance of Continuous Monitoring Systems (CMS)

30. The permittee must maintain and operate each CMS as specified in this section, or in a relevant standard, and in a manner consistent with good air pollution control practices. [40 CFR 63.8(c)(l)]

30.a. The permittee must maintain and operate each CMS as specified in Conditions 22.b and 22.c. [40 CFR 63.8(c)(l)(i)]

30.b. Thepermittee must keep the necessary parts for routine repairs ofthe affected CMS equipment readily available. [40 CFR 63.8(c)(l)(ii)]

30.c. All CMS must be installed such that representative measures of emissions or process parameters from the affected source are obtained. In addition, CEMS must be located according to procedures contained in the applicable performance specification(s). Unless the individual subpart states otherwise, the permittee must ensure the read out (that portion of the CMS that provides a visual display or record), or other indication of operation, from any CMS required for compliance with the emission standard is readily accessible on site for operational control or inspection by the operator of the equipment. [40 CFR 63.8(c)(2)(i) & (ii)]

30.d. All CMS must be installed, operational, and the data verified as specified in the relevant standard either prior to or in conjunction with conducting performance tests under Conditions 25, 109, and 110. Verification of operational status must, at a minimum, include completion of the manufacturer's written specifications or recommendations for installation, operation, and calibration of the system. [40 CFR 63.8(c)(3)]

30.e. Except for system breakdowns, out-of-control periods, repairs, maintenance periods, calibration checks, and zero (low-level) and high-level calibration drift adjustments, all CMS must be in continuous operation and must complete a minimum of one cycle of operation (sampling,


Page 19 of75

analyzing, and data recording) for each successive 15-minute period. [40 CFR 63.8(c)(4)]

Temperature Monitoring

31. For each temperature monitoring device, the permittee must meet the requirements in Conditions 29 and 3l.a through 3l.f. [40 CFR 63.2269(b)]

3l.a. Locate the temperature sensor in a position that provides a representative temperature.

3l.b. Use a temperature sensor with a minimum accuracy of 4"F or 0.75 percent of the temperature value, whichever is larger.

3l.c. If a chart recorder is used, it must have a sensitivity with minor divisions of not more than 20°F.

3l.d. Perform an electronic calibration at least semiannually according to the procedures in the manufacturer's owner's manual. Following the electronic calibration, the permittee must conduct a temperature sensor validation check in which a second or redundant temperature sensor placed nearby the process temperature sensor must yield a reading within 30°F ofthe process temperature sensor's reading.

3l.e. Conduct calibration and validation checks any time the sensor exceeds the manufacturer's specified maximum operating temperature range or install a new temperature sensor.

3l.f. At least quarterly, inspect all components for integrity and all electrical connections for continuity, oxidation, and galvanic corrosion.

Wood Moisture Monitoring

32. For each furnish moisture meter, the permittee must meet the requirements in Conditions 29.d, 29.e, and 29.fand Conditions 32.a through 32.d. [40 CFR 63.2269(c)]

32.a. For the dry rotary dryers, use a continuous moisture monitor with a minimum accuracy of 1 percent (dry basis) moisture or better in the 25 to 35 percent (dry basis) moisture content range. Alternatively, the permittee may use a continuous moisture monitor with a minimum accuracy of 5 percent (dry basis) moisture or better for dry rotary dryers used to dry furnish with less than 25 percent (dry basis) moisture.

32.b. Locate the moisture monitor in a position that provides a representative measure of furnish moisture.

32.c. Calibrate the moisture monitor based on the procedures specified by the moisture monitor manufacturer at least once per semiannual compliance period (or more frequently if recommended by the moisture monitor manufacturer).

32.d. At least quarterly, inspect all components of the moisture monitor for integrity and all electrical connections for continuity.

32.e. Use Equation 7 to convert percent moisture measurements wet basis to a dry basis:

MCwot/1 00 ( ) M C&y = ( ) 1 00 (Equation 7)

1- MCwot/100

Where:

MC&y =percent moisture content of wood material (weight percent, dry basis);


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MCwet ~percent moisture content of wood material (weight percent, wet basis).

CMS Quality Control Program

33. The results of the quality control program required iu this Condition will be considered by the Department when it determines the validity ofmonitoriug data. [40 CFR 63.8(d)(1)]

33.a. If required to use a CMS and if subject to the monitoring requirements of this section and a relevant standard, the permittee must develop and implement a CMS quality control program. Each quality control program must iuclude, at a miuimum, a written protocol that describes procedures for each of the followiug operations: [40 CFR 63.8(d)(2)]

33.a.i. Initial and any subsequent calibration of the CMS;

33.a.ii. Determination and adjusttnent of the calibration drift of the CMS;

33.a.iii. Preventive maiutenance of the CMS, iucluding spare parts iuventory;

33.a.iv. Data recordiug, calculations, and reportiug;

33.a.v. Accuracy audit procedures, includiug sampling and analysis methods; and

33.a.vi. Program of corrective action for a malfunctioning CMS.

33.b. The permittee must keep these written procedures on record for the life of the affected source or until the affected source is no longer subject to the provisions of 40 CFR Part 63, to be made available for inspection, upon request, by the Department. If the performance evaluation plan is revised, the owner or operator must keep previous (i.e., superseded) versions of the performance evaluation plan on record to be made available for inspection, upon request, by the Department, for a period of 5 years after each revision to the plan. Where relevant, e.g., program of corrective action for a malfunctioning CMS, these written procedures may be incorporated as part of the permittee's startup, shutdown, and malfunction plan to avoid duplication of planning and recordkeeping efforts. [40 CFR 63.8(d)(3)]

Performance Evaluation of Continuous Monitoring Systems

34. When required by a relevant standard, and at any other time the Admioistrator may require under section 114 of the Clean Air Act, the permittee must conduct a performance evaluation of the CMS. Such performance evaluation must be according to the applicable specifications and procedures described iu 40 CFR 63.8(e)(2) through (5) or in the relevant standard. [40 CFR 63.8(e)(1)]

Reduction ofMonitoriug Data

35. Monitoring data recorded during periods of unavoidable CMS breakdowns, repairs, maiutenance periods, and calibration checks must not be included in any data average computed under 40 CFRPart 63. [40 CFR 63.8(g)(5)]

Boiler #1 (Boil-1) Boiler #2 (Boil-2)

Permitnumber: 22-0143-TV-01 Expiration date: 02/01118

Page 21 of75

Table 2 Summary of Requirements for Emissions Units Boil-1 and Boil-2

Applicable Condition Pollutant! Monitoring Requirement Number Parameter Limit/Standard Monitoring Requirement Condition

340-208-0110 36 Visible emissions 20% opacity (3 min. Monthly VE tests/surveys 37

aggregate in 60 minutes) on oil

No monitoring if on natural gas

340-228-021 0(1 )(a) 38 PM 0.2 gr/dscf@12%C02 Yearly ST if on oil more 39

(avg. of3 test runs) than 400 hours

340-Zl8-0050 40 Fuels Use natural gas or"bil Recordkeeping 41 only (i.e, no solid fuels)

40 CFR Part 63 42 HAP Must operate Boilers in Recordkeeping 42 Subpart DDDDD compliance with

requirements ofDDDDD

Visible Emissions Standard

36. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, from emissions unit Boil-! or Boil-2. [OAR 340-208-0 110]

Visible Emissions Monitoring

37. The permittee must monitor visible emissions from the stack of Boiler I and the stack of Boiler 2 by conducting a Modified EPA Method 9 test. Each Modified EPA Method 9 test must be a minhnum of 6 minutes long uniess any one reading is greater than 20% opacity, then the observation period must be 60 minutes or until a violation of the applicable standard in Condition 36 is documented, whichever period is shorter.

37.a. The Modified EPA Method 9 test method may be waived provided the permittee conducts a six (6) minute visible emissions survey on the device at the compliance demonstration point using EPA Method 22 and visible emissions, excluding water vapor, are not detected for more than 5% (18 seconds) of the survey time.

37.b. The visible emissions tests on each boiler stack must be conducted at least once per month unless gaseous fuels are burned during the entire month, then no testing is required for that boiler.

37.c. If any test result exceeds the applicable standard in Condition 36, the permittee must initiate corrective action within !-hour to bring the boiler into compliance with the applicable standards. Once the conective actions are completed, a Modified EPA Method 9 test must be conducted as soon as is practicable to demonstrate that the source is in compliance with the applicable standard.

37.d. Ifthe observer is unable to conduct the tests and/or surveys due to darkness or visual interference caused by other visible emission sources or due to adverse weather conditions such as fog, heavy rain, or snow, the observer must note such conditions on the observation form and make at least three attempts to conduct the tests and/or surveys at approximately 2-hour intervals throughout the


Page 22 of75

day during daylight hours. The permittee must attempt to make the tests daily until a valid observation period is completed.

37.e. Recordkeeping: The permittee must maintain records of all visible emissions tests and surveys, including date, time, observer, observations, results, type of fuel being burned, and any corrective actions taken. If a test is waived, this must be noted on the record.

PM Emissions Standard

38. The permittee must not cause or allow the emissions of particulate matter in excess of0.2 gr/dscf corrected to 12% C02 from emissions units Boil-! or Boil-2. [OAR 340-228-0210(1)(a)]

PM Emissions Monitoring

39. Oregon Method 5 must be used for measuring particulate matter emissions from Boiler 1 and Boiler 2. Each test run must be a minimum of 60 minutes long with a minimum sample volume of31.8 dscf. Test results must be reported as grains per dry standard cubic feet (gr/dscf) corrected to 12% 0 2, pounds per hour, and pounds per thousand pounds steam.

39.a. Testing must be conducted once each calendar year for a given boiler when fuel oil is burned for 400 or more hours in any 12-consecutive month period in that boiler. If two consecutive test results are each less than 75% (0.15 gr/dscf@ 12% C02) of the applicable standard in Condition 38, then no further testing is required for this boiler during the term of the permit. Consecutive tests must be separated by a least 6 months, but not more than 18 months.

39.b. The type of fuel oil burned during the tests must be of the same as that which was being used during the period that triggered the tests.

39.c. During each test run, the permittee must record the following information:

39.c.i. Amount of fuel oil burned (gallons).

39.c.ii. Sulfur content of fuel oil(% weigbt basis).

39.c.iii. Boiler steaming rate (lb!hr).

39.c.iv. Boiler excess oxygen(%).

39.c.v. Visible emissions as measured by modified EPA Method 9 for a minimum of6 minutes during or within 30 minutes before or after each Oregon Method 5 test run.

Fuel Use Restrictions

40. The permittee must use only oil (ASTM grades 1 or 2) or natural gas fuels in the emission unit Boil-! or Boil-2. [OAR 340-218-0050]

Fuel Use Monitoring

41. The permittee must maintain monthly records of the number of hours that each type of fuel is burned in Boil-! and Boil-2. Oil usage in Boil-1 and Boil-2 caunot exceed the time period allowed under 40 CFR Part 63 Subpart DDDDD per year in each boiler for testing purposes or any period of natural gas curtallment or natural gas supply emergencies. [ 40 CFR Part 63 Subpart DDDDD]

Boiler and Process Heater NESHAP


Page 23 of75

42. The permittee shall operate and maiotain the Boiler and Process Heater NESHAP affected sources, Boil-! and Boil-2, in compliance with the applicable requirements of 40 CFR Part 63 Subpart DDDDD.

#4 Green Dcyer (GD)

Table 4 Summary of Requirements for Emissions Unit GD

Applicable Condition Pollutant/ Monitoring Requirement Number Parameter Limit/Standard ·Monitoring Requirement Condition

340-208-0110 43 Visible emissions 20% opacity (3 min. Quarterly VE tests/surveys 44 aggregate in 60 minutes)

340-226-021 0(1 )(b) 45 PM 0.1 gr/dscf (avg. of3 test Continuous secondary 47 runs) voltage monitor on ET ~ 1 &

ET~2. Corrective action if kV < 30 for 6 min. [40 CFR 64]

Annual I & M ofET-1 & 48 ET-2

Initial source test 49

340-226-0310 46 PM Table 1 Same as for Condition 45 47, 48,49

340-218-0050 50 Fuels Flue gas, Sanderdust, Recordkeeping 51 Natural Gas, Oil


43. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minntes io any one hour which is equal to or greater than 20% opacity, excluding uncombined water, from emissions unit GD. [OAR340-208-0110]


44. The permittee must monitor visible emissions from the GD by conductiog a Modified EPA Method 9 test at the outlet of the RTO. Each Modified EPA Method 9 test must be a minimum of6 mioutes long unless any one reading is greater than 20% opacity, then the observation period must be 60 minutes or until a violation of the applicable standard in Condition 43 is documented, whichever period is shorter.

44.a. The Modified EPA Method 9 test method may be waived provided the permittee conducts a six (6) minute visible emissions survey on the device at the compliance demonstration poiot usiog EPA Method 22 and visible emissions, excluding water vapor, are not detected for more than 5% (18 seconds) of the survey time.

44.b. The visible emissions tests on the RTO stack must be conducted at least once per calendar quarter.

44.c. If any test result exceeds the applicable standard io Condition 43, the permittee must initiate corrective action withio !-hour to bring the dryer iota compliance with the applicable standards.

Petmit number: 22-0143-TV-01 Expiration date: 02/01/18

Page 24 of75

Upon completion of the corrective actions, a Modified EPA Method 9 test mnst be conducted as soon as is practicable to demonstrate that the source is in compliance with the applicable standard.

44.d. If the observer is unable to conduct the tests and/or surveys due to darkness or visual interference caused by other visible emission sources or due to adverse weather conditions such as fog, heavy rain, or snow, the observer shall note such conditions on the observation form and make at least three attempts to conduct the tests and/or surveys at approximately 2-hour intervals throughout the day during daylight hours. The permittee must attempt to conduct the tests daily until a valid observation period is completed.

44.e. Recordkeeping: The permittee must maintain records of all visible emissions tests and surveys, including: date, time, observer, observations, results, and any corrective actions taken.

PM Emission Standards

45. The permittee must not cause or allow the emissions of particulate matter in excess ofO.l gr/dscffrom emissions unit GD. [340-226-0210(1)(b)]

46. The permittee must not cause, suffer, allow, or permit the emissions of particulate matter in any one hour from emissions unit GD in excess ofthe amount shown in Table I, for the process weight allocated to that process. [OAR 340-226-031 OJ


Compliance Assurance Monitoring [40 CFR Part 64]

47. The permittee must operate and maintain a continuous voltage monitor for the collectors on the emission control devices ET -I and ET-2 in accordance with the manufacturer's written instructions when GD is in operation.

47.a. The permittee must take corrective action if the collector voltage is less than 30 kilovolts for 6 minutes or longer. The permittee must operate an alarm system that will notify the control room operator when an excursion occurs. Conective action must be initiated within one-hour of the start of the excursion to return the dryer to highest and best treatment and control.

47 .b. If the excursion lasts longer than 72 hours, the permittee must conduct daily visible emissions tests using Modified EPA Method 9, and must notify the Department within 48 hours of the cause and corrective actions taken and proposed.

47.c. A voltage excursion is not necessarily a violation of the particulate matter emission standards for GD.

47.d. Recordkeeping: The permittee must maintain daily records of collector voltages, any excursions, and any conective actions taken.

inspection and Maintenance Monitoring

48. At least once per calendar year, the electrostatic precipitators ET-1 and ET -2 must be inspected for physical degradation that could affect the performance of the control device including but not limited to collection plates, seals, demister, and mechanical and electrical systems. The permittee must make all necessary repairs to the unit to ensure efficient operation.

Permit number: 22-0143-TV-01 Expiration date: 02/0 Ill 8

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48.a. Recordkeeoing: The permittee must maintain records of the inspections including date, fmdings, and corrective action.

Testing Requirement

49. GD emissions from RTO I must be tested for VOC emissions (pounds per hour and pounds per BDT material dried) and confirm MACT destruction efficiency requirements once during the permit term prior to the permit renewal application date.

49.a. Test Methods:

49.a.i. For VOCs, use EPA Method 25A (as propane) plus methanol and formaldehyde.

49.a.ii. For MACT destruction efficiency, according to Table 4.

49.b. Process and control device information to be collected during the tests include:

49.b.i.

49.b.ii.

49.b.iii.

49.b.iv.


Production throughput (BDT) and moisture contents of raw and dried materials.

Fuel types and measured or calculated usage rates

Inlet and outlet dryer and RTO I temperatures.

Control device operating parameters including voltages, currents, and quench flow rate for the ESP and RTO I firebox temperatures.

50. The permittee must use only sanderdust, oil (ASTM grades I or 2), or natural gas fuels in the emissions unit GD. Flue gas from Boil-! and/or Boil-2 may be used as an alternative or supplemental source of heat ·for this emissions unit. [OAR-340-218-0050]

Fuel Use Monitoring

51. The permittee must maintain monthly and aunual records of the number of hours that each type of fuel is burned in GD.

Face Dryer FD-1 (FD)

Table 6 Summary of Requirements for Emissions Unit FD

Applicable Condition Pollutant/ Monitoring Requirement Number Parameter Limit/Standard Monitoring requirement Condition


340-226-021 O(l)(b) 54 PM 0.1 gr/dscf (avg. of3 test Daily pressure drop readings at 56 runs) each baghouse. Corrective

action if outside normal range of>O.O and::::; 4.0 inches water. [40 CFR64]

Quarterly external inspection 57 ofbaghouses

Applicable Condition Pollutant/


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Monitoring Requirement Number Parameter Limit/Standard Monitoring requirement Condition

340-226-0310 55 PM Table I Same as Condition 54 56,57

340-218-0050 58 Fuels Natural Gas, Oil Recordkeeping 59


52. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, from emissions unit FD. [OAR 340-208-0110]


53. The permittee must monitor visible emissions from emissions unit FD by conducting a Modified EPA Method 9 test at the control device exhaust outlets ofBH-50 and BH-51. Each Modified EPA Method 9 test must be a minimum of 6 minutes long unless any one reading is greater than 20% opacity, then the observation period must be 60 minutes or until a violation of the applicable standard in Condition 52 is documented, whichever period is shorter.


53.b. The visible emissions tests for each baghouse exhaust outlet must be conducted at least once per calendar quarter.

53.c. If any test result exceeds the applicable standard in Condition 52, the permittee must initiate corrective action within !-hour to bring the dryer into compliance with the applicable standards. Upon completion of the corrective actions, a Modified EPA Method 9 test must be conducted as soon as is practicable to demonstrate that the source is in compliance with the applicable standard.

53 .d. If the observer is unable to conduct the tests and/or surveys due to darkness or visual interference caused by other visible emission sources or due to adverse weather conditions such as fog, heavy rain, or snow, the observer shall note such conditions on the observation form and make at least three attempts to conduct the tests and/or surveys at approximately 2-hour intervals throughout the day during daylight hours. The permittee must attempt to conduct the tests daily until a valid observation period is completed.

53.e. Recordkeeping: The permittee must maintain records of all visible emissions tests and surveys, including: date, time, observer, observations, results, and any corrective actions taken

PM Emissions Standards

54. The permittee must not cause or allow the emissions of particulate matter in excess of0.1 gr/dscffrom emissions unit FD. [OAR 340-226-0210(l)(a)]

55. The permittee must not cause, suffer, allow, or permit the emissions of particulate matter in any one hour from FD in excess of the amount shown in Table 1, for the process weight allocated to that process. [OAR 340-226-0310]

Permit number: 22-0143-TV-01 Expiration date: 02/01118

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Compliance Assurance Monitoring [40 CFRPart 64]

56. The permittee must operate and maintain a pressure monitoring device in accordance with the manufacturer's instructions to monitor the pressure drops across baghouses BH-50 and BH-51 whenever FD is operating.

56.a. The permittee must take a pressure drop reading at least once each day that FD is operating.

56.b. The permittee must take corrective action if the pressure drop is outside the normal operating pressure drop range of>O.O and<: 4.0 inches of water on either baghouse.

56.c. If the excursion lasts longer than 72 hours, the permittee must conduct daily visible emissions tests using Modified EPA Method 9, and must notify the Department within 48 hours ofthe cause and corrective actions taken and proposed.

56.d. An excursion of the pressure operating range is not necessarily a violation of the particulate matter emission standards for FD.

56.e. Recordkeeping: The permittee must maintain records of pressure drop readings, any excursion periods, and corrective actions taken.

Inspection and Maintenance Monitoring

57. At least once per calendar quarter, the permittee must conduct external inspections ofBH-50 and BH-51 and associated ductwork for structural integrity, corrosion and air leaks and must take corrective action as needed to maintain the system in proper operating condition.

57 .a. Recordkeeping: The permittee must maintain records of the inspections including date, findings, and con-ective actions taken.


58. The permittee must use only oil (ASTM grades 1 or 2) or natural gas fuels in the emissions unit FD. [OAR 340-218-0050]

Fuel Use Monitoring

59. The permittee must maintain monthly and annual records of the number of hours that each type of fuel is bumedinFD.

Core Dryers CD.:1 and CD-2 (CD)

Table 8 Summary of Requirements for Emissions Unit CD

Applicable Condition Pollutant/ Monitoring Requirement Number Parameter Limit/Standard Monitoring Requirements Condition

340-208-0110(2) 60 Visible emissions 20% opacity (3 min. Quarterly VB tests/surveys 61 aggregate in 60 minutes)

340-226-0210(1 )(a) 62 PM 0.2 gr/dscf (avg. of3 test Daily pressure drop readings at 64 for CD-2; runs) for CD-2; each baghouse. Corrective

action if outside normal range


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of>O.O and:$. 4.0 inches water. 340-226-021 0(1)(b) 0.1 gr/dscf(avg. of3 test [40CFR64] for CD-I runs) for CD-1

Quarterly external inspection 65 of baghouses

340-226-0310 63 PM Table 1 Same as Condition 62 64,65

340-218-0050 66 Fuels Natural Gas, Oil, Flue gas Recordkeeping 67


60. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, fi·om emissions unit CD. [OAR 340-208-0110(2)]


61. The permittee must monitor visible emissions from emissions unit CD by conducting a Modified EPA Method 9 test at the control device exhaust outlets ofBH-52 and BH-53. Each Modified EPA Method 9 test must be a minimum of 6 minutes long unless any one reading is greater than 20% opacity, then the observation period must be 60 minutes or until a violation of the applicable standard in Condition 60 is documented, whichever period is shorter,

6l.a. The Modified EPA Method 9 test method may be waived provided the permittee conducts a six (6) minute visible emissions survey on the device at the compliance demonstration point using EPA Method 22 and visible emissions, excluding water vapor, are not detected for more than 5% (18 seconds) of the survey time.

6l.b. The visible emissions tests for each baghouse exhaust outlet must be conducted at least once per calendar quarter.

6l.c. If any test result exceeds the applicable standard in Condition 60, the permittee must initiate corrective action within !-hour to bring the dryer into compliance with the applicable standards. Upon completion ofthe corrective actions, a Modified EPA Method 9 test must be .conducted as soon as is practicable to demonstrate that the source is in compliance with the applicable standard.

6l.d. Ifthe observer is unable to conduct the tests and/or surveys due to darkness or visual interference caused by other visible emission sources or due to adverse weather conditions such as fog, heavy rain, or snow, the observer shall note such conditions on the observation form and make at least three attempts to conduct the tests and/or surveys at approxhnately 2-hour intervals throughout the day during daylight hours. The permittee must attempt to conduct the tests daily until a valid observation period is completed,

6l.e. Recordkeeping: The permittee must maintain records of all visible emissions tests and surveys, including: date, time, observer, observations, results, and any corrective actions taken.


62. The permittee must not cause or allow the emissions of particulate matter in excess of0.2 gr/dscffrom CD-2 of emissions unit CD and 0.1 gr/dscffrom CD-I of emissions unit CD. [OAR 340-226-0210(l)(a) and 340-226-0210( I )(b)]


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63. The permittee must not cause, suffer, allow, or permit the emissions of particulate matter in any one hour from CD in excess of the amount shown in Table 1, for the process weigbt allocated to that process. [OAR 340-226-0310]


Compliance Assurance Monitoring [40 CFRPart 64]

64. The permittee must operate and maintain a pressure monitoring device in accordance with the manufacturer's instructions to monitor the pressure drops across bagbouses BH-52 and BH-53 whenever CD is operating.

64.a. The permittee must take a pressure drop reading at least once each day that CD is operating.

64.b. The permittee must take corrective action if the pressure drop is outside the normal operating pressure drop range of>O.O and:<: 4.0 inches of water on either bagbouse.

64.c. If the excursion lasts longer than 72 hours, the permittee must conduct daily visible emissions tests using Modified EPA Method 9, and must notify the Departtnent within 48 hours of the cause and corrective actions taken and proposed.

64.d. An excursion of the pressure operating range is not necessarily a violation of the particulate matter emission standards for CD.

64.e. Recordkeeping: The pennittee must maintain records of pressure drop readings, any excursion periods, and corrective actions taken.


65. At least once per calendar quarter, the permittee must conduct external inspections ofBH-52 and BH-53 and associated ductwork for structoral integrity, corrosion and air leaks and must take corrective action as needed to maintain the system in proper operating condition.

65.a. Recordkeeping: The permittee must maintain records of the inspections including date, findings, and corrective actions taken.


66. The permittee must use only oil (ASTM grades 1 or 2) or natural gas in CD or flue gas from Boil-2 in CD-2 only. [OAR 340-218-0050]

Fuel Use Monitoring

67. The permittee must maintain monthly and annual records of the number of hours that each type of fuel is burned in CD-1 and CD-2.


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Press 3 (Press-3E)

Table 9 Summary of Requirements for Emissions Unit Press-3E

Applicable Condition Pollutant/ Monitoring Requirement Number Parameter Limit/Standard Monitoring Requirement Condition


340-226-021 0(1 )(a) 70 PM 02 gr/dscf (avg. of3 test Weekly pressure drop 71 runs) readings across baghouses.

Corrective action if outside normal range of>O.O and::; 4.0 inches water. [40 CFR 64]



68. The pennittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, from emissions unit Press-3E. [OAR 340-208-0 II 0]


69. The pennittee must monitor visible emissions from emissions unit Press-3E by conducting a Modified EPA Method 9 test at the control device exhaust outlet of the RCO. Each Modified EPA Method 9 test must be a minimum of 6 minutes long unless any one reading is greater than 20% opacity, then the observation period must be 60 minutes or until a violation of the applicable standard in Condition 68 is documented, whichever period is shorter.


69.b. The visible emissions tests for the RCO exhaust outlet must be conducted at least once per calendar quarter.

69.c. If any test result exceeds the applicable standard in Condition 68, the permittee must initiate corrective action within !-hour to bring the press into compliance with the applicable standards. Upon completion of the corrective actions, a Modified EPA Method 9 test must be conducted as soon as is practicable to demonstrate that the source is In compliance with the applicable standard.

69.d. If the observer is unable to conduct the tests and/or surveys due to darkness or visual interference caused by other visible emission sources or due to adverse weather conditions such as fog, heavy rain, or snow, the observer shall note such conditions on the observation form and make at least three attempts to conduct the tests and/or surveys at approximately 2-hour intervals throughout the day during daylight hours. The pennittee must attempt to conduct the tests daily until a valid observation period is completed ..




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70. The permittee must not cause or allow the emissions of particulate matter in excess of 0.2 gr/dscf from emissions uoit Press-3E. Should the permittee choose to measure the amouot of particulate matter being emitted from emissions unit Press-3E, the emissions testing must be done in accordance with the requirements of Condition 107. [OAR 340-226-0210(I)(a)]


71. The permittee must operate and maintain a pressure monitoring device in accordance with the manufacturer's instructions to monitor the pressure drops across baghouses BH-45 and BH-46 whenever Press-3E is operating.

7l.a. The permittee must take a pressure drop reading at each baghouse at least once each week that Press-3E is operating.

7l.b. The permittee must take corrective action if the pressure drop is outside the normal operating pressure drop range of>O.O and :S 4.0 inches of water on either baghouse.

7l.c. Ifthe excursion lasts longer than 72 hours, the permittee must conduct daily visible emissions tests using Modified EPA Method 9, and must notify the Department within 48 hours of the cause and corrective actions taken and proposed.

7l.d. An excursion ofthe pressure operating range is not necessarily a violation of the particulate matter emission standard for Press-3E.

7l.e. Recordkeeping: The permittee must maintain records of pressure drop readings, any excursion periods, and corrective actions taken.


72. At least once per calendar quarter, the permittee must conduct external inspections of baghouses BH-45 and BH -46 and associated ductwork for structural integrity, corrosion and air leaks and will take corrective action as needed to maintain the system in proper operating condition.

72.a. Recordkeeping: The permittee must maintain records of the inspections including date, fmdings, and corrective actions taken.

Testing Requirement

73. Press-3E emissions from RCO 1 must be tested for VOC emissions (pouods per hour and pouods per MCF raw) and confrrm MACT destruction efficiency requirements once during the permit term prior to the permit renewal application date.

73.a. Test Methods:




73.b.i.

73.b.ii.

73.b.iii.

73.b.iv.

Press production throughput (MCF)

Fuel usage rate (measured or calculated) for RCO I

Baghouse (BH 45 and BH 46) pressure drop readings


Page 32 of75

Control device operating parameters including RCO I inlet and firebox temperatures.

Board Cooler 3 (BC3)

Table 10 Summary of Requirements for Emissions Unit BC3

Applicable Condition Pollutant/ Monitoring Requirement Number Parameter Limit/Standard Condition

Monitoring Requirement

340-208-0110 74 Visible emissions 20% opacity (3 min. Quarterly VE test 76 aggregate in 60 minutes)

340-226-021 0(1 )(a) 75 PM 0.2 gr/dscf (avg. of3 test Quarterly VE test 76 runs)

Visible and PM Emissions Standards

74. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, from emissions unit BC3. [OAR 340-208-0110]

75. The permittee must not cause or allow the emissions of particulate matter in excess of0.2 gr/dscf from emissions unit BC3. [OAR 340-226-0210(1)(a)]

Visible and PM Emissions Monitoring

76. At least once per calendar quarter, the permittee must conduct Modified EPA Method 9 visible emissions tests on emissions unit BC3. Should a test exceed the applicable standard in Condition 74, corrective action will be initiated within !-hour to bring the source into compliance with the applicable requirement.


76.b. If the observer is unable to conduct the tests and/or surveys due to visual interference caused by other visible emission sources or due to adverse weather conditions such as fog, heavy rain, or snow, the observer must note such conditions on the observation form and make at least three attempts to conduct the tests and/or surveys at approximately 2-hour intervals throughout the day during daylight hours. The permittee must attempt to make the tests daily until a valid observation period is completed.

76.c. Recordkeeping: The permittee must maintain records of all visible emissions tests and surveys, including date, time, observer, observations, results, and any corrective actions taken.

Press 4 (Press-4E)

Table 11 Summary of Requirements for Emissions Unit Press-4E:

Applicable Condition Pollutant/ Requirement Number Parameter Limit/Standard

340-208-0110 77 Visible emissions 20% opacity (3 min. aggregate in 60 minutes)

340-226-021 0(1 )(b) 79 PM 0.1 gr/dscf (avg. of3 test runs)



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Monitoring Monitoring Requirement Condition

Quarterly VE test 78

Weekly pressure drop readings across baghouses. Corrective action if outside

80 normal range of>O.O and~ 4.0 inches water. [40 CFR 64]


77. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, from emissions unit Press-4E. [OAR340-208-0110]


78. The permittee must monitor visible emissions from emissions unit Press-4E by conducting a Modified EPA Method 9 test at the control device exhaust outlet of the RCO. Each Modified EPA Method 9 test must be a minimum of 6 minutes long uniess any one reading is greater than 20% opacity, then the observation period must be 60 minutes or until a violation of the applicable standard in Condition 77 is documented, whichever period is shorter.

7 B.a. The Modified EPA Method 9 test method may be waived provided the permittee conducts a six (6) minute visible emissions survey on the device at the compliance demonstration point using EPA Method 22 and visible emissions, excluding water vapor, are not detected for more than 5% (18 seconds) of the survey time. ·

78.b. The visible emissions tests for the RCO exhaust outlet must be conducted at least once per calendar quarter.

78.c. If any test result exceeds the applicable standard in Condition 77, the permittee must initiate corrective action within !-hour to bring the press into compliance with the applicable standards. Upon completion of the corrective actions, a Modified EPA Method 9 test must be conducted as soon as is practicable to demonstrate that the source is in compliance with the applicable standard.

78.d. If the observer is unable to conduct the tests and/or surveys due to darkness or visual interference caused by other visible emission sources or due to adverse weather conditions such as fog, heavy rain, or snow, the observer shall note such conditions on the observation form and make at least three attempts to conduct the tests and/or surveys at approximately 2-hour intervals throughout the day during daylight hours. The permittee must attempt to conduct the tests daily until a valid observation period is completed.


Page 34 of75



79. The permittee must not cause or allow the emissions of particulate matter in excess of 0.1 gr/dscf from emissions unit Press-4E. Should the permittee choose to measure the amount of particulate matter being emitted from emissions unit Press-4 E, the emissions testing must be done in accordance with the requirements of Condition 107. [OAR 340-226-021 0(1 )(b)]


80. The permittee must operate and maintain a pressure monitoring device in accordance with the manufacturer's instructions to monitor the pressure drops across baghouses BH-47, BH-48 and BH-49 whenever Press-4E is operating.

80.a. The permittee must take a pressure drop reading at each baghouse at least once each week that Press-4 E is operating.

80.b. The permittee must take corrective action if the pressure drop is outside the normal operating pressure drop range of>O.O and S 4.0 inches of water on either baghouse.

80.c. If the excursion lasts longer than 72 hours, the permittee must conduct daily visible emissions tests using Modified EPA Method 9, and must notifY the Department within 48 hours of the cause and corrective actions taken and proposed.

80.d. An excursion of the pressure operating range is not necessarily a violation of the particulate matter emission standard for Press-4E.

80.e. Recordkeeping: The permittee must maintain records of pressure drop readings, any excursion periods, and corrective actions taken.


81. At least once per calendar quarter, the permittee must conduct external inspections ofbaghouses BH-47, BH-48 and BH-49 and associated ductwork for structural integrity, corrosion and air leaks and take corrective action as needed to maintain the system in proper operating condition.

81.a. Recordkeeping: The permittee must maintain records of the inspections including date, findings, and corrective action.

Testing Requirement

82. Press-4E emissions from RCO 2 must be tested for VOC emissions (pounds per hour and pounds per MCF raw) and confirm MACT destruction efficiency requirements once during the permit term prior to the permit renewal application date.

82.a. Test Methods:




Page 35 of75


82.b.i. Press production throughput (MCF)

82.b.ii. Fuel usage rate (measured or calculated) for RCO 2

82.b.iii. Baghouse (BH 47, BH 48, and BH 49) pressure drop readings

82.b.iv. Control device operating parameters including RCO 2 inlet and frrebox temperatures.


Table 12 Summary of Requirements for Emissions Unit BC4:

Applicable Condition Pollutant/ Monitoring Requirement Monitoring Requirement Number Parameter Limit/Standard Condition

340-208-0110 83 Visible emissions 20% opacity (3 min. Quarterly VE test 85 aggregate in 60 minutes)

340-226-0210(1 )(b) 84 PM 0.1 gr/dscf (avg. of3 test Quarterly VE test 85 runs)

Visible and PM Emissions Standards

83. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, from emissions unit BC4. [OAR 340-208-0 II OJ

84. The permittee must not cause or allow the emissions of particulate matter in excess ofO.l gr/dscffrom emissions unit BC4. [OAR 340-226-0210(l)(b)]

Visible and PM Emissions Monitoring

85. At least once per calendar quarter, the permittee must conduct Modified EPA Method 9 visible emissions tests on emissions unit BC4. Should a test exceed the applicable standard in Condition 83, corrective action will be initiated within !-hour to bring the source into compliance with the applicable requirement.

85.a. The Modified EPA Method 9 test method may be waived provided the permittee conducts a six (6) minute visible emissions survey on the device at the compliance demonstration point using EPA Method 22 and visible emissions, excluding water vapor, are not detected for more than 5% (IS seconds) of the survey time.

85.b. Ifthe observer is unable to conduct the tests and/or surveys due to visual interference caused by other visible emission sources or due to adverse weather conditions such as fog, heavy rain, or snow, the observer must note such conditions on the observation form and make at least three attempts to conduct the tests and/or surveys at approximately 2-hour intervals throughout the day during daylight hours. The permittee must attempt to make the tests daily until a valid observation period is completed.

85.c. Recordkeeping: The pennittee must maintain records of all visible emissions tests and surveys, including date, time, observer, observations, results, and any corrective actions taken.


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Material Handling-1, Material Handling-3, Material Handling-4, Material Handling-S (MH-1, MH-3, MH-4-& MH-5)

Table 13 Summary of Requirements for Emissions Units MH-1, MH-3, MH-4 and MH-5

plicable Condition Pollutant! Monitoring Requirement Monitoring quirement Number Parameter Limit/Standard Condition

340-208-0110 86 Visible emissions 20% opacity (3 min. aggregate Quarterly VB test 87 in 60 minutes)

340-228-0210 (l)(b) 88 PM 0.1 gr/dscf (avg. of3 test Quarterly I&M 89 runs)


86. The pennittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, from emissions units MH-1, MH-3, MH-4 and MH-5. [OAR 340-208-0110]


87. The pe1mittee must monitor visible emissions from emissions units MH-1, MH-3, MH-4 and MH-5 by conducting a Modified EPA Method 9 test at the control device exhaust outlet of each baghouse in MH-1, MH-3, MH-4 andMH-5. Each Modified EPA Method 9 test must be a minimum of6 minutes long unless any one reading is greater than 20% opacity, then the observation period must be 60 minutes or until a violation ofthe applicable standard in Condition 86 is documented, whichever period is shorter.


87.b. Tbe visible emissions tests for each baghouse exhaust outlet must be conducted at least once per calendar quarter.

87.c. If any test result exceeds the applicable standard in Condition 86, the permittee must initiate corrective action within 1-hour to bring the unit into compliance with the applicable standards. Upon completion of the corrective actions, a Modified EPA Method 9 test must be conducted as. soon as is practicable to demonstrate that the source is in compliance with the applicable standard.

87.d. If the observer is unable to conduct the tests and/or surveys due to darkness or visual interference caused by other visible emission sources or due to adverse weather conditions such as fog, heavy rain, or snow, the observer shall note such conditions on the observation form and make at least tluee attempts to conduct the tests and/or surveys at approximately 2-hour intervals tluoughout the day during daylight hours. The pennittee must attempt to conduct the tests daily until a valid observation period is completed.

87 .e. Recordkeeping: Tbe pennittee must maintain records of all visible emissions tests and surveys, including: date, time, observer, observations, results, and any corrective actions taken.


88. The pennittee must not cause or allow the emissions of particulate matter in excess of 0.1 gr/dscf from emissions units MH-1, MH-3, MH-4 and MH-5. Should the pennittee choose to measure the amount of


Page 37 of75

particulate matter being emitted from emissions units MH-1, MH-3, MH-4 and MH-5, the emissions testing must be done in accordance with the requirements of Condition I 07. [OAR 340-228-0210(1 )(b)]


89. At least once per calendar quarter, the permittee must conduct an external inspection of each baghouse and associated ductwork for sttuctural integrity, corrosion and air leaks and will take corrective action as needed to maintain the system in proper operating condition.

89.a. Recordkeeping: The permittee must maintain records of the inspections including date, fmdings, and corrective action.

Material· Handling-2 (MH-2)

Table 14 Summary of Requirements for Emissions Units MH-2

Applicable Condition Pollutant/ Monitoring Requirement Monitoring Requirement Number Parameter ·. Limit/Standard Condition

340-208-0110 90 Visible emissions 20% opacity (3 min. Quarterly VB test 91 aggregate in 60 minutes)

340-228-021 0(1 )(b) 92 PM 0.1 gr/dscf (avg. of3 test Daily pressure drop readings runs) across baghouses. 93

Corrective action if outside normal range of>O.O and :S 4.0 inches water. [40 CFR 64]

Quarterly external 94 inspection ofbaghouses


90. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, from emissions unit MH-2. [OAR 340-208-0110]


91. The permittee must monitor visible emissions from emissions unit MH-2 by conducting a Modified EPA Method 9 test at the control device exhaust outlet ofBH-13 and BH-24. Each Modified EPA Method 9 test must be a minhnum of 6 minutes long unless any one reading is greater than 20% opacity, then the observation period must be 60 minutes or until a violation of the applicable standard in Condition 90 is documented, whichever period is shorter.

9l.a. The Modified EPA Method 9 test method may be waived provided the permittee conducts a six (6) minute visible emissions survey on the device at the compliance demonstration point using EPA Method 22 and visible emissions, excluding water vapor, are not detected for more than 5% ( 18 seconds) of the survey time.

9l.b. The visible emissions tests for each baghouse exhaust outlet must be conducted at least once per calendar quarter.

9l.c. If any test result exceeds the applicable standard in Condition 90, the permittee must initiate corrective action within I -hour to bring the unit into compliance with the applicable standards. Upon completion of the corrective actions, a Modified EPA Method 9 test must be conducted as soon as is practicable to demonstrate that the source is in compliance with the applicable standard.


Page 38 of75

9l.d. If the observer is unable to conduct the tests and/or surveys due to darkness or visual interference caused by other visible emission sources or due to adverse weather conditions such as fog, heavy rain, or snow, the observer shall note such conditions on the observation form and make at least three attempts to conduct the tests and/or surveys at approximately 2-hour intervals throughout the day during daylight hours. The permittee must attempt to conduct the tests daily until a valid observation period is completed.

9l.e. Recordkeeping: The permittee must maintain records of all visible emissions tests and surveys, including: date, time, observer, observations, results, and any corrective actions taken.


92. The permittee must not cause or allow the emissions of particulate matter in excess of 0.1 gr/dscf from emissions unit MH-2. Should the permittee choose to measure the amount of particulate matter being emitted from emissions unit MH-2, the emissions testing must be done in accordance with the requirements of Condition 107. [OAR 340-228-0210(l)(b)]


Compliance Assurance Monitoring [40 CFR Part 64]

93. The permittee must operate and maintain a pressure monitoring device in accordance with the manufacturer's instructions to monitor the pressure drops across baghouses BH-13 and BH-24 whenever MH-2 is operating.

93.a. The permittee must take a pressure drop reading at least once each day that MH-2 is operating.

93.b. The permittee must take corrective action ifthe pressure drop is outside the normal operating pressure drop range of>O.O and :S 4.0 inches of water on either baghouse.

93.c. If the excursion lasts longer than 72 hours, the permittee must conduct daily visible emissions tests using Modified EPA Method 9, and must notify the Department within 48 hours of the cause and corrective actions taken and proposed.

93 .d. An excursion of the pressure operating range is not necessarily a violation of the particulate matter emission standard for MH-2.

93 .e. Recordkeeping: The permittee must maintain records of pressure drop readings, any excursion periods, and corrective actions taken.


94. At least once per calendar quarter, the permittee must conduct external inspections ofbaghouses BH-13 and BH-24 and associated ductwork for structural integrity, corrosion and air leaks and must take corrective action as needed to maintain the system in proper operating condition.

94.a. Recordkeeping: The permittee must maintain records of the inspections including date, findings, and corrective actions taken.

Truck Dump Building (TDB) Raw Material Storag.e P.iles (Piles)


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Table 16 Summary of Requirements for Emissions Units Piles and TDB

Applicable Condition Pollutant/ Monitoring Requirement Monitoring Requirement Number Parameter Limit/Standard Condition

340-208-0110 95 Visible emissions 20% opacity (3 min. Complaint investigation 96 aggregate in 60 minutes)

340-234-0520(1) 97 Fugitive PM Piles and truck dumps Quarterly enclosure 98 enclosed inspection

Quarterly truck dump and 99 . negative air system inspection


95. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, from emissions units TDB and Piles. [OAR 340-208-011 OJ The reference test method for measuring the opacity of the visible emissions from emissions units TDB and Piles is Modified EPA Method 9 as specified in Condition 107.f.


96. The permittee must investigate and maintain records of fugitive dust complaints related to emissions units TDB and Piles in accordance with the requirements of Condition 7.

Fugitive PM Standard

97. Emissions units Piles and TDB must be enclosed to prevent windblown particle emissions fi·om these sources from being deposited upon property not under the ownership of the permittee. [OAR 340-234-0520(1)]

Fugitive PM Monitoring

98. At least once each calendar quarter, the permittee must inspect the TDB and Piles enclosures for signs of deterioration or wear such that particulate matter may become airborne and leave the plant site.

98.a. Recordkeeping: The permittee must maintain records of the enclosure inspections including date, fmdings, and corrective actions taken.

99. At least once each calendar quarter the permittee must observe the dumping of dry material in the truck dump building and ensure that the negative air pick up system at the front opening of the building is functioning properly.

99.a. Recordkeeping: The permittee must maintain records of the truck dumping and negative air system inspections including date, fmdings, and any corrective actions taken as a result of the inspections.

Coating Usage (CU)

Table 17 Summary of Requirements for Emissions Unit CU:

Applicable Condition Pollutant/ Requirement Number Parameter Limit/Standard

340-208-0110 100 Visible emissions 20% opacity (3 min. aggregate in 60 minutes)

340-218-0050(1) 101 Coating usage Annual coating usage rate <1100 gallons



Page 40 of75

Monitoring Requirement Monitoring Conditions

None NA

Recordkeeping 102

100. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere for a period or periods aggregating more than three minutes in any one hour which is equal to or greater than 20% opacity, excluding uncombined water, from emissions uuit Coating Usage. [OAR 340-208-0110] The reference test method for measuring the opacity of the visible emissions from emissions uuit Coating Usage is Modified EPA Method 9 as specified in Condition 107.f.

Coating Usage Limit

101. The permittee must not use more than 1,100 gallons per year of coatings on wood building products. [OAR 340-218-0050(1)]

Coating Usage Monitoring

I 02. The permittee must maintain records ofthe gallons of coatings used on wood building products each month and the yearly total.

INSIGNIFICANT ACTIVITIES EMISSION LIMITS AND STANDARDS

103. The Department acknowledges that insignificant emissions units (!BUs) identified by rule as either categorically insignificant activities or aggregate insignificant emissions [OAR 340-200-0020] exist at facilities required to obtain an Oregon Title V Operating Permit. !BUs must comply with all applicable requirements. In general, the requirements that could apply to !BUs are incorporated as follows:

103.a. 103.b.

103.c. I03.d.

OAR 340-208-0 II 0 (20% opacity) OAR 340-228-0210 (0.1 gr/dscf corrected to 12% C02 or 50% excess air for fuel burning equipment) OAR 340-226-0210 (0.1 gr/dscffor non-fuel burning equipment) OAR 340-226-0310 (process weight limit for non-fuel burning process equipment)

I 04. Testing, Monitoring. and Recordkeeping Requirements: Uniess otherwise specified in this permit, the Department is not requiring any testing, monitoring, recordkeeping, or reporting for the applicable emissions limits and standards that apply to !BUs. However, iftesting were performed for compliance purposes, the permittee would be required to use the test methods identified in the definitions of "opacity" and "particulate matter" in OAR 340-226-0010 and perform the testing in accordance with the Department's Source Sampling Manual.


Page 41 of75

PLANT SITE EMISSION LIMITS

105. The plant site emissions must not exceed the following limits for any 12 consecutive calendar month period: [OAR 340-222-0040 through OAR 340-222-0043]

Note: When a PSEL changes the 12-month period begins anew, that is, the actual emissions are accumulated for the frrst 12 months a new PSEL is in effect.

Plant Site Emission Limits Unassigned Emissions

(tons/year) (tons/year)

Pollutant

PM 69 25 I

PMIO 62 15

PM25 48 10

co 227 None

NOX 262 13

S02 41 None

voc 230 40

GHGs (C02e) 228,700 None

207,500 metric tons

105.a. The permittee may only use unassigned emissions after any necessar:• constroction (OAR 340-218-0 190) and permit revision applications (OAR 340-218-0120 through 340-218-0 180) bave been approved by the Department,

105.b. For annual Title V fee purposes, the permittee need only pay based on the assigned PSEL and in accordance with Oregon Administrative Rules, Division 220 or according to Condition !50.

PSEL Monitoring

I 06. The permittee must conduct the following monitoring activities to demonstrate compliance witb the emission limit requirements of Condition I 05. [OAR 340-218-0050(3)]

106.a. The permittee must maintain records of the following process parameters:

Emissions Unit(s)/Process Process Parameter Units Frequency

Boil-! & Boil-2 Steam produced Mlbs Monthly and Annual

GD Wood dried Bone Dry Tons Monthly and Annual

FD&CD Dried material to each Bone Dry Tons Monthly and Annual

Permitnumber: 22-0143-TV-01 Expiration date: 02/01118

Page 42 of75

Emissions Unit(s)/Process Process Parameter Units Frequency

former

Oil combusted (facility Oil consumed Gallons and sulfur content Monthly and Annual wide)

Press-3E, BC3, Press-4E Board production Msf- %" raw basis Monthly and Annual andBC4

Board production Msf- W' fmished basis

Board production (RCO Mcf- raw basis operating)

Board production (RCO Mcf- raw basis not operating due to routine maintenance)

Press time Hours

RT0-1, RC0-1, & RC0-2 Natural gas consumption* MMBtu Monthly and Annual

MH-1, MH-2, MH-3, MH- Board production Msf- %"raw basis Monthly and Annual 4, MH-5, Piles

Coating Usage (other than Solvent & Coating used Gallons Monthly and Annual Group 1 Miscellaneous Coatings")

Tanks Board production :M:Msf- %" raw basis Monthly and Annual

* Gas consumptiOn can be estllllated based on hours of operatiOn and maXImum heat mput. * * Group 1 miscellaneous coatings are accounted for within the AI emission unit.

1 06.b. The permittee must calculate pollutant mass emissions for all pollutants except GHGs for each rolling 12 month period using the followlug equation:

where:

E ~ L(P,.xEF,.)xK

E ~ pollutant emissions (tons/year); p eu ~ process parameters identified in condition 1 06.a; EF,. ~ emission factor identified for each emissions unit and pollutant in

condition 106.e; and K conversion constant: 1 ton/2000 lbs

for annual calcniations.

106.c. Compliance with PSELs must be determined uslug the calculations contained in Condition 106.b using the monitored parameters recorded during the reporting period and the emission factors contained in Condition 1 06.e, unless the permittee elects to pay emission fees based on actual emissions uslug a verified emission factor determined in accordance with OAR 340-220-0170. If the permittee is paying on actual emissions based on a verified emission factor, the verified emission factor must be used for determluiug compliance with the PSEL in accordance with Condition 113.

1 06.d. As an alternative to calculating emissions on a monthly and annual basis, the permittee may keep monthly and annual records demonstrating that none of the following operational parameters are

Permit nwnber: 22-0143-TV-01 Expiration date: 02/01118

Page 43 of75

exceeded. The annual comparison will be performed by the last day ofthe following month. An exceedance of an operational parameter is not necessarily a violation of the PSEL. Should an operational exceedance occur, the penuittee must calculate actual emissions for the period in accordance with Condition 1 06.b.

Annual (12 month rolling)

Total Stearn Production from Boilers #1 and #2: 569,400 Mlbs Line #3 Particleboard Production: 122,541 Msf- %"raw Liue #4 Particleboard Production: 259,501 Msf- %"raw Total Oil Combusted: 1,078,000 gallons,,;; 0.5% S Total RCO & RTO Natural Gas Usage: 136,654 MM Btu Coating usage: 1100 gallons

1 06.e. The emission factors for calculatiug pollutant emissions are as follows:

Emission Emissions_ Unit/Device Pollutant Factor Units

Boiler #1 and Boiler #2 (Boil-1 and Boil-2)

Fuel: Natural Gas PM 0.014 lbs/Mlb steam

Fuel: Oil PM 0.026 lbs/Mlb steam

Fuel: Natural Gas PM10 0.014 lbs/Mlb steam

Fuel: Oil PMIO 0.018 lbs!Mib steam

Fuel: Natural Gas PM2.s 0.014 lbs/Mlb steam

Fuel: Oil PM2s 0.0126 lbs/Mlb steam

Fuel: Natural Gas co 0.028 lbs/Mlb steam

Fuel: Oil co 0.039 lbs/Mlb steam

Fuel: Natural Gas so2 0.0019 lbs!Mib steam

Fuel: Oil so2 See Condition lbs/Mgal 106.f

Fuel: Natural Gas NOx 0.170 lbs/Mlb steam

Fuel: Oil NOx 0.157 lbs/Mlb steam

Fuel: Natural Gas voc 0.0061 lbs/Mlb steam

Fuel: Oil voc 0.0016 lbs/Mlb steam

#4 Green Drver (GD)

Fuel: Sanderdust PM&PM10 0.0262 lbs/BDT processed &PM2.s

Fuel: Natural Gas or Oil PM&PM10 0.0294 lbs/BDT processed & PM2.s

p, • ions Unit/Device Pollutant

Fuel: Sanderdust co Fuel: Natural Gas co Fuel: Oil co

Fuel: Sauderdust so, Fuel: Natural Gas so, Fuel: Oil so,

Fuel: Sanderdust NOx

Fuel: Natural Gas NOx

Fuel: Oil NO,

Fuel: Sanderdust (RTO voc operating)

Fuel: Sanderdust ( RTO not voc operating due to routine maintenance)

Fuel: Natural Gas or Oil voc (RTO operating)

Fuel: Natural Gas or Oil voc (R TO not operating due to routine maintenance)

Core Dryer #1 (CD)

Fuel: Natural Gas or Oil PM&PM10

&PM2.s

Fuel: Natural Gas co Fuel: Oil co

Fuel: Natural Gas so, Fuel: Oil so,


Fuel: Oil NOx

Fuel: Natural Gas or Oil voc Core Dryer #2 (CD)

Emission Factor

0.90

0.084

0.0357

0.025

0.0017

See Condition 106.£

0.95

0.10

0.143

0.060

0.60

0.060

0.60

0.070

0.084

0.0357

0.0017

See Condition 106.f

0.10

0.143

0.41


Page 44 o£75

Units

lbs/BDT processed

lbs!MMBtu

lbs!MMBtu

lbs!MMBtu

lbs!MMBtu

lbs/Mgal

lbs/BDT processed

lbs!MMBtu

lbs!MMBtu

lbs/BDT processed

lbs/BDT processed

lbs/BDT processed

lbs/BDT processed

lbs/BDT processed

lbs/MMBtu

lbs!MMBtu

1bs!MMBtu

lbs!MMBtu

lbs!MMBtu

lbs/BDT processed

Emissions Unit/Device Pollutant

Fuel: Natural Gas or Oil PM&PMw &PM,.s




Fuel: Oil NOx

Fuel: Natural Gas or Oil voc Face Dryer (FD)

Fuel: Natural Gas or Oil PM&PMw &PM2.s




Fuel: Oil NOx

Fuel: Natural Gas or Oil voc Press 3 (Press-3E)

PM&PMw &PM,.s

RCO operating voc RCO not operating due voc to routine maintenance


Cooler Vent 610 PM

PM10

PM,.s

Emission Factor

0.038

0.084

0.0357

0.0017

· See Condition 106.f

0.10

0.143

0.26

0.097

0.28

0.28

0.0017

See Condition 106.f

0.03

0.043

0.27

0.0018

0.876

8.76

0.096

0.082

0.041


Page 45 of75

Units

lbs/BDT processed

lbs/MMBtu

lbs/MMBtu

lbs/MM Btu

lbs/Mgal

lbs/MMBtu

lbs/MM Btu

lbs/BDT processed

lbs/BDT processed

lbs/BDT processed

lbs/BDT processed

lbs/MMBtu

lbs/Mgal

lbs/BDT processed

lbs/BDT processed

lbs/BDT processed

lbs/Msf -3/4 raw

lbs/Mcfraw

lbs/Mcfraw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw


voc Fugitives Press 3 PM

PM to

PM25

Fugitives Press 3 voc Press 4 (Press-4E)

PM&PMto &PM25

RCO operating voc RCO not operating due voc to routine maintenance


Cooler Vent 533 PM

PM to

PM2.5

voc Fugitives Press 4 PM

PM to

PM2.5

Fugitives Press 4 voc RCO & RTO Natural Gas PM&PM10

Combustion & PM25

co so, NOx

voc Material Handling-1 PM&PMto

(MH-1) &PM2•5

MH-1 + MH-3 + MH-4 + voc MH-5

Material Haudliug-2 PM&PMto

(MH-2) & PM25

voc Material Handling-3 PM&PMto

(MH-3) &PMz.s

Material Handliug-4 PM&PMto

(MH-4) & PM2.s

Material Handling-S PM&PM10

(MH-5) &PM2.5

Piles PM

Emission Factor

2.426

0.067

0.057

0.029

1.463

0.0004

0.85

8.50

0.017

0.014

0.007

0.576

0.135

0.115

0.058

3.901

0.0025

0.084

0.0017

0.1

0.0055

0.0019

0.2386

0.0083

0.0144

0.0026

0.0085

0.0025

0.0008


Page 46 of75

Units

lbs/Mcfraw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Mcfraw

lbs/Msf -3/4 raw

lbs/Mcfraw

lbs/Mcfraw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Mcf raw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Mcf raw

Lb/MMBtu

Lb/MMBtu

Lb/MMBtu

Lb/MMBtu

Lb/MMBtu

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw

lbs/Msf -3/4 raw


PMw

PM25

voc Coatings Usage (CU) . voc .. Tanks (TANKS) voc

Emission Factor

0.0004

0.00006

0.121

I

0.054


Page 47 of75

Units

lbs!Msf -3/4 raw

lbs!Msf -3/4 raw

lbs!Msf -3/4 raw

lbs VOC/lb VOC

lbs!MMsf -3/4 raw

106.f. The S02 emission factor when burning oil must be determined using the following equation:

EFs02 ~ 142S where: EFs02 ~Oil burning emission factor (lb!Mgal) S ~sulfur content of oil (0.05% sulfur content ~0.05)

I 06.g. The emission factors in condition 106.e of this permit are not enforceable limits unless otherwise specified in the permit.

GENERAL TESTING REQUIREMENTS

107. Unless otherwise specified in this permit, the permittee must conduct all testing in accordance with the Department's Source Sampling Manual. [OAR 340-212-0120]

I 07 .a. Unless otherwise specified by a state or federal regulation, the permittee must submit a source test plan to the Department at least 30 days prior to the date of the test. The test plan must be prepared in accordance with the Source Sampling Manual and address any planned variations or alternatives to prescribed test methods. The permittee should be aware that if significant variations are requested, it may require more than 30 days for the Department to grant approval and may require EPA approval in addition to approval by the Department.

I 07.b. Only regular operating staff may adjust the processes or emission control device parameters during a compliance source test and within two (2) hours prior to the tests. Any operating adjustments made during a compliance source test, which are a result of consultation during the tests with source testing personnel, equipment vendors, or consultants, may render the source test invalid.

I 07.c. Unless otherwise specified by permit condition or Department approved source test plan, all compliance source tests must be perfmmed as follows:

107.c.i. at least 90% of the design capacity for new or modified equipment;

I 07 .c.ii. at least 90% of the maximum operating rate for existing equlpment; or

107.c.iii. at 90 to 110% of the normal maximum operating rate for existing equipment. For purposes of this permit, the normal maximum operating rate is defmed as the 90'" percentile of the average hourly operating rates during a 12 month period immediately preceding the source test. Data supporting the normal maximum operating rate must be included with the source test report.


Page 48 of75

107.d. Each source test must consist of at least three (3) test runs and the emissions results must be reported as the arithmetic average of all valid test runs. If for reasons beyond the control of the permittee a test run is invalid, the Department may accept two (2) test runs for demonstrating compliance with the emission lhnit or standard.

107.e. Source test reports prepared in accordance with the Department's Source Sampling Manual must be submitted to the Department within 60 days of completing any required source test, unless a different time period is approved in the source test plan submitted prior to the source test.

I 07.f. "Modified EPA Method 9" means the minhnum visible emission observation period must be six minutes, though longer periods may be required by a specific rule or permit condition. During the test period, if any one reading is equal to or equal to or greater than the visible emissions lhnit for the emissions unit, then the observation period must be a minimum of 60 minutes or until a violation of the emissions standard has been documented; whichever is a shorter period. Aggregate thnes (e.g., 3 minutes in any one hour) consist of the total duration of all readings during the observation period that are equal to or exceed the opacity percentage in the standard, whether or not the readings are consecutive. Each modified EPA Method 9 reading represents 15 seconds of thne. [See the definition of"Opacity" in OAR 340-208-0010]

General NESHAP Testing Requirements

Performance Test Dates

108. If required to performance testing by a relevant NESHAP standard, the permittee must perform such tests within 180 days ofthe compliance date for such source except as allowed by a force majeure event under 40 CFR 63. 7( a)( 4 ). The Administrator may require the permittee to conduct performance tests at the affected source at any other time when the action is authorized by section 114 of the Clean Air Act. [40 CFR 63.7(a)(2)- (4)]

Performance testing facilities

109. If required to do performance testing, for each new source and, at the request of the Department, for each existing source, the permittee must provide performance testing facilities as follows: [40 CFR 63.7(d)]

109.a. Sampling ports adequate for test methods applicable to such source. This includes: [40 CFR 63.7(d)(l)]

l09.a.i. Constructing the air pollution control system such that volumetric flow rates and pollutant emission rates can be accurately determined by applicable test methods and procedures; and [40 CFR 63.7(d)(l)(i)]

109.a.ii. Providing a stack or duct free of cyclonic flow during performance tests, as demonstrated by applicable test methods and procedures. [40 CFR 63.7(d)(l)(ii)]

109.b. Safe sampling platform(s). [40 CFR 63.7(d)(2)]

109.c. Safe access to sarnplingplatform(s). [40 CFR63.7(d)(3)]

109.d. Utilities for sampling and testing equipment; and[40 CFR 63.7(d)(4)]

I 09.e. Any other facilities that the Department deems necessary for safe and adequate testing of a source. [40 CFR 63.7(d)(5)]

Quality Assurance Program


Page 49 of75

110. The results of the quality assurance program will be considered by the Department when he/she determines the validity of a performance test. [40 CFR 63.7(c)(l)]

Submission of site-specific test plan

II O.a. Before conducting a required performance test, the permittee must develop and, if requested by the Department, must submit a site-specific test plan to the Department for approval. The test plan must include a test program summary, the test schedule, data quality objectives, and both an internal and external quality assurance (QA) program. Data quality objectives are the pretest expectations of precision, accuracy, and completeness of data. [40 CFR63.7(c)(2)(i)]

11 O.b. The internal QA program must include, at a miniroum, the activities planned by routine operators and analysts to provide an assessment of test data precision; an example of internal QA is the sampling and analysis of replicate samples. [ 40 CFR 63 .7( c )(2)(ii)]

llO.c. The external QA program must include, at a minimum, application of plans for a test method performance audit (P A) during the performance test. The FA's consist of blind audit samples provided by the Administrator and analyzed during the performance test in order to provide a measure of test data bias. The external QA program may also include systems audits that include the opportunity for on-site evaluation by the Administrator of instrument calibration, data validation, sample logging, and documentation of quality control data and field maintenance activities. [40 CFR 63.7(c)(2)(iii)]

11 O.d. The permittee must submit the site-specific test plan to the Department upon the Department's request at least 60 calendar days before the performance test is scheduled to take place, that is, siroultaneously with the notification of intention to conduct a performance test required under Condition 133, or on a mutually agreed upon date. [40 CFR 63.7(c)(2)(iv]

11 O.e. The Department may request additional relevant information after the submittal of a site-specific test plan. [40 CFR 63.7(c)(2)(v)]

Approval of the site-specific test plan.

II 0 .f. The Department will noti:ty the permittee of approval or intention to deny approval of the sitespecific test plan (if review of the site-specific test plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days after receipt of any supplementary information that is submitted under Condition llO.f.ii. Before disapproving any site-specific test plan, the Department will noti:ty the applicant of the Department's intention to disapprove the plan together with: [40 CFR 63.7(c)(3)(i)]

llO.f.i.

llO.f.ii.

Notice of the information and fmdings on which the intended disapproval is based; and [40 CFR 63.7(c)(3)(i)(A)]

Notice of opportnnity for the permittee to present, within 30 calendar days after he/she is notified of the intended disapproval, additional information to the Department before fmal action on the plan. [40 CFR 63.7(c)(3)(i)(B)]

llO.g. In the event that the Department fails to approve or disapprove the site-specific test plan within the tiroe period specified in Condition llO.f, the following Conditions must apply: [40 CFR 63.7( c)(3)(ii)]

llO.g.i. If intending to demonstrate compliance using the test method(s) specified in the relevant standard or with ouly minor changes to those tests methods (see 40 CFR 63.7(e)(2)(i)), the permittee must conduct the performance test within the tiroe specified in this section using the specified method( s ); [ 40 CFR 63. 7( c )(3)(ii)(A)]

llO.g.ii.

Pe1mitnumber: 22-0143-TV-01 Expiration date: 02/01/18

Page 50 of75

If intendiog to demonstrate compliance by usiog an alternative to any test method specified in the relevant standard, the permittee is authorized to conduct the performance test using an alternative test method after the Administrator approves the use of the alternative method when the Administrator approves the site-specific test plan (if review ofthe site-specific test plan is requested) or after the alternative method is approved (see 40 CFR 63.7(1)). However, the permittee is authorized to conduct the performance test using an alternative method in the absence of notification of approval45 days after submission of the site-specific test plan or request to use an alternative method. The permittee is authorized to conduct the performance test within 60 calendar days after he/she is authorized to demonstrate compliance usiog an alternative test method. Notwithstandiog the requirements in the precediog three sentences, the permittee may proceed to conduct the performance test as required io this section (without the Administrator's prior approval of the sitespecific test plan) if he/she subsequently chooses to use the specified testiog and monitoring methods iostead of an alternative. [ 40 CFR 63 .7( c )(3)(ii)(B)]

II 0 .h. Neither the submission of a site-specific test plan for approval, nor the Department's approval or disapproval of a plan, nor the Department's failure to approve or disapprove a plan in a timely marmer must: [40 CFR 63.7(c)(3)(iii)]

llO.h.i.

llO.h.ii.

Relieve the permittee of legal responsibility for compliance with any applicable provisions of 40 CFR part 63 or with any other applicable Federal, State, or local requirement; or [40 CFR 63.7(c)(3)(iii)(A)]

Prevent the Admioistrator from implementing or enforciog 40 CFR part 63 or taking any other action under the Act. [40 CFR 63.7(c)(3)(iii)(B)]

Performance test method audit program

11 O.i. The permittee must analyze performance audit (P A) samples during each performance test. The permittee must request performance audit materials 30 days prior to the test date. Audit materials includiog cylinder audit gases may be obtaioed by contacting the appropriate EPA Regional Office or the Department. The Department will have sole discretion to require any subsequent remedial actions of the permittee based on the P A results. If the Department fails to provide required P A materials to the permittee in time to analyze the P A samples during a performance test, the requirement to conduct a PA must be waived for such source for that performance test. Waiver of the requirement to conduct a PA for a particular performance test does not constitute a waiver of the requirement to conduct a PA for future required performance tests. [40 CFR 63.7(c)(4)]

Conduct of Performance Tests

111. Performance tests must be conducted under such conditions as the Department specifies to the permittee based on representative performance (i.e., performance based on normal operating conditions) of the affected source. Operations during periods of startup, shutdown, and malfunction shall not constitute representative conditions for the purpose of a performance test, nor shall emissions in excess of the level of the relevant standard during periods of startup, shutdown, and malfunction be considered a violation ofthe relevant standard unless otherwise specified io the relevant standard or a deternrioation of noncompliance is made under 40 CFR 63.6( e). Upon request the permittee must make available to the Department such records as may be necessary to deternrioe the conditions of performance tests. [ 40 CFR 63. 7( e)(!)]

lll.a. Performance tests must be conducted and data must be reduced in accordance with the test methods and procedures set forth io 40 CFR 63.7, in each relevant standard, and, if required, in applicable appendices of Parts 51, 60, 61, and 63 of 40 CFR unless the Admioistrator or the Department, as applicable- [40 CFR63.7(e)(2)]

Permit number: 22-0143-TV-01 Expiration date: 02/01118

Page 51 of75

lll.a.i. Specifies or approves, in specific cases, the use of a test method with minor changes in methodology. Such changes may be approved in conjunction with approval of !be site-specific test plan; or

lll.a.ii. Approves the use of an intermediate or major change or alternative to a test method (see definitions in 40 CFR 63.90(a)), the results of which tbe Administrator has determined to be adequate for indicating whether a specific affected source is in compliance; or

lll.a.iii. Approves shorter sampling tirues or smaller sample volumes when necessitated by process variables or other factors; or

11l.a.iv. Waives the requirement for performance tests because the permittee has demonstrated by other means to the Administrator's satisfaction that the affected source is in compliance with the relevant standard.

lll.b. For the purpose of determining compliance with a relevant standard, tbe arithmetic mean of !be results of the three runs must apply. Upon receiving approval from the Department, results of a test run may be replaced with results of an additional test run in the event that: [40 CFR 63.7(e)(3)]

lll.b.i.

lll.b.ii.

A sample is accidentally lost after tbe testing team leaves the site; or

Conditions occur in which one of !be three runs must be discontinued because of forced shutdown; or

lll.b.iii. Extreme meteorological conditions occur; or

lll.b.iv. Other circumstances occur !bat are beyond tbe permittee's control.

lll.c. Use of an alternative test method-Until autbmized to use an intermediate or major change under Condition lll.a.ii or alternative test method under 40 CFR 63 .7(f), tbe permittee remains subject to the requirements of 40 CFR 63.7 and the relevant standard. [40 CFR 63.7(f)]

lll.d. Performance test recordkeeping-Uuless otherwise specified in a relevant standards or test method, or as otherwise approved by tbe Department in writing, results of performance test must include the analysis of samples, determination of emissions, and raw data. A performance test is "completed" when field sample collection is terminated. [40 CFR 63.6(g)]

11l.e. Waiver of performance tests-Until a waiver of a performance testing requirement has been granted by tbe Administrator under 40 CFR 63.7(h), the permittee remains subject to the requirements of40 CFR63.7. [40 CFR63.7(h)]

GENERAL MONITORING AND RECORDKEEPING REQUIREMENTS [OAR 340-218-0050(3)(a) and (b)]

General Title V Monitoring Requirements

112. The permittee must not knowingly render inaccurate any required monitoring device or method. [OAR 340-218-0050(3)(a)(E)]

113. Methods used to determine actual emissions for fee purposes must also be used for compliance determination and can be no less rigorous than tbe requirements of OAR 340-218-0080.


Page 52 of75

[OAR 340-218-0050(3)(a)(F)]

114. Monitoring requirements must commence on the date of permit issuance unless otherwise specified in the permit or an applicable requirement. [OAR 340-218-0050(3)(a)(G)]

General Title V Recordkeeping Requirements

115. The permittee must maintain the following general records of testing and monitoring required by this permit: [OAR 340-218-0050(b)(A)]

115.a. 115.b. 115.c. 115.d. 115.e. 115.f. 115.g.

the date, place as defined in the permit, and time of sampling or measurements; the date(s) analyses were performed; the company or entity that performed the analyses; the analytical techniques or methods used; the results of such analyses; the operating conditions as existing at the time of sampling or measurement; and the records of quality assurance for continuous monitoring systems (including but not limited to quality control activities, audits, calibration drift checks).

116. Uniess otherwise specified by permit condition, the permittee must make every effort to maintain 100 percent of the records required by the permit. If information is not obtained or recorded for legitimate reasons (e.g., the monitor or data acquisition system malfunctions due to a power outage), the missing record(s) will not be considered a permit deviation provided the amount of data lost does not exceed 10% of the averaging periods in a reporting period or I 0% ofthe total operating hours in a reporting period, if no averaging time is specified. Upon discovering that a required record is missing, the permittee must document the reason for the missing record. In addition, any missing record that can be recovered from other available information will not be considered a missing record. [OAR 340-214-0110, 340-214-0114, and 340-218-0050(3)(b)]

117. Recordkeeping requirements must commence on the date of permit issuance uniess otherwise specified in the permit or an applicable requirement. [OAR 340-218-0050(3)(b)(C)]

118. Uniess otherwise specified, the permittee must retain records of all required monitoring data and support information for a period of at least five (5) years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. [OAR 340-218-0050(b)(B)]

NESHAP Recordkeeping Requirements

119. The permittee must keep the records listed in Conditions 119.a through 119.k. [40 CFR 63.10(b)(l), and 63.2282(a)]

119.a. A copy of each notification and report that was submitted to comply with the NESHAP, including all documentation supporting any Initial Notification or Notification of Compliance Status that was submitted. [40 CFR 63.2282(a)(l)]

119.b. The occurrence and duration of each startup or shutdown when the startup or shutdown causes the source to exceed any applicable emissions limitation in Subpart DDDD). [ 40 CFR 63.1 O(b )(2)(i)]

Pe1mitnumber: 22-0143-TV-01 Expiration date: 02/01118

Page 53 of75

119.c. The occurrence and duration of each malfunction of operation (i.e., process equipment) or the required air pollution control and monitoring equipment. [40 CFR 63.10(b)(2)(ii)]

119.d. All required maintenance performed on the air pollution control aud monitoring equipment. [40 CFR 63.10(b)(2)(iii)]

119.e. Actions taken during periods of: 119.e.i. startup or shutdown when the source exceeded the applicable SubpartDDDD

emissions limitations and when the actions taken are different from the procedures specified in the SSM Plan, or

119.e.ii. malfunction (including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation) when actions taken are different from the procedures specified in the SSM Plan (see Condition 23). [40 CFR 63.10(b)(2)(iv) and 63.2282(a)(2)]

119.f. All information necessary to demonstrate conformance with the permittee's SSM Piau (see Condition 23) when all actions taken dming periods of startup or shutdown (and the startup or shutdown causes the permittee to exceed any applicable Subpart DDDD emissions limitation), aud malfunction (including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal or usual manner of operation) are consistent with the procedures specified in such plan. (The information needed to demonstrate conformance with the startup, shutdown, and malfunction plan may be recorded using a "checklist," or some other effective form ofrecordkeeping, in order to minimize the recordkeeping burden for conforming events). [40 CFR 63.10(b)(2)(v) and 63.2282(a)(2)]

119.g. Each period during which a CMS is malfunctioning or inoperative (including out-of-control periods). [40 CFR 63.10(b)(2)(vi)]

119.h. All required measurements needed to demonstrate compliance with a relevant standard (including, but not limited to, 15-minute averages of CMS data, raw performance testing measurements, and raw performance evaluation measurements, that support data that the source is required to report); [40 CFR 63.10(b)(2)(vii)]

119.i. Docmnentation of the approved routine control device maintenance exemption. [40 CFR 63.2282(a)(3)]

119 j. Records of performance tests and performance evaluations. [ 40 CFR 63.1 O(b )(2)( viii) and 63.2282(a)(4)]

119.k. All measurements as may be necessary to determine the conditions of performance tests and performance evaluations. [40 CFR 63.10(b)(2)(ix)]

119.1. All CMS calibration checks. [40 CFR 63.10(b)(2)(x)]

119.m. All adjustments and maintenance perfmmed on CMS. [ 40 CFR 63.1 O(b )(2)(xi)]

119 .n. All documentation supporting initial notifications and notifications of compliance status under 40 CFR 63.9. [40 CFR 63.10(b)(2)(xiv)]

120. The pennittee must keep the records required in Tables 7 and 8 to show continuous compliance with each compliance option, operating requirement, and work practice requirement that apply. [40 CFR 63 .2282(b )]

121. For each CMS, the permittee must keep the following records. [40 CFR 63.10(c)]


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121.a. All required CMS measurements (including monitoring data recorded during unavoidable CMS breakdowns and out-of-control periods). [40 CFR 63.10(c)(1)]

12l.b. The date and time identifying each period during which a CMS is malfunctioning or inoperative (including out-of-control periods). [40 CFR 63.10(c)(5)]

12l.c. The date and time identifying each period during which the CMS was out of control. [40 CFR 63.10(c)(6)]

12l.d. The nature and cause of any malfunction (if known). [40 CFR 63.10(c)(10)]

12l.e. The corrective action taken or preventive measures adopted. [ 40 CFR 63.1 0( c )(11)]

12l.f. The nature of the repairs or adjustments to the CMS that was inoperative or out of control. [40 CFR 63.10(c)(12)]

12l.g. The total process operating time during the reporting period. [ 40 CFR 63.1 0( c )(13)]

12l.h. All procedures that are part of a quality control program developed and implemented for CMS under Condition 33. [40 CFR 63.10(c)(14)]

12l.i. In order to satisfy the requirements of Conditions 12l.d through 12l.f and to avoid duplicative recordkeeping efforts, the permittee may use the affected source's startup, shutdown, and malfunction plan or records kept to satisfy the recordkeeping requirements of the startup, shutdown, and malfunction plan specified in Condition 23, provided that such plan and records adequately address the requirements of Conditions 12l.d through 12l.f. [ 40 CFR 63.1 0( c )(15)]

122. The permittee must keep records of annual catalyst activity checks and subsequent corrective actions. [40 CFR 63.2282(e)]

Form and Longevitv of Records

123. Records must be in a form suitable and readily available for expeditious review. [40 CFR 63.10(b)(l) and 63.2283(a)]

124. The permittee must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. [40 CFR 63.1 O(b )(1) and 63.2283(b )]

125. The permittee must keep each record on site for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, report, or record. The permittee can keep the records offsite for the remaining 3 years. [40 CFR 63.10(b)(1) and 63.2283(c)]

REPORTING REQUIREMENTS

General Title V Reporting Requirements

126. Excess Emissions Reporting: The permittee must report all excess emissions as follows: [OAR 340-214-0300 through 340-214-0360]

126.a. Inrmediately (within 1 hour ofthe event) notify DEQ of an excess emission event by phone, email, or facsimile; and

126.b. Within 15 days of the excess emissions event, submit a written report that contains the following information: [OAR 340-214-0340(1)]

126.b.i.

126.b.ii. 126.b.iii. 126.b.iv.

126.b.v.

126.b.vi.

126.b.vii. 126.b.viii.


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The date and tiroe of the beghmiog of the excess emissions event and the duration or best estimate of the tiroe until return to normal operation; The date and time the owner or operator notified DEQ of the event; The equipment iovolved; Whether the event occurred duriog planned startup, planned shutdown, scheduled maintenance, or as a result of a breakdown, malfunction, or emergency; Steps taken to mitigate emissions and corrective action taken, includiog whether the approved procedures for a planned startup, shutdown, or maintenance activity were followed; The magnitude and duration of each occurrence of excess emissions duriog the course of an event and the increase over normal rates or concentrations as determioed by contiouous monitoriog or best estimate (supported by operatiog data and calculations); The fmal resolution ofthe cause of the excess emissions; and Where applicable, evidence supportiog any claim that emissions io excess of technology-based liroits were due to any emergency pursuant to OAR 340-214-0360.

126.c. In the event of any excess emissions which are of a nature that could endanger public health and occur during non-busioess hours, weekends, or holidays, the permittee must iromediately notify DEQ by calling the Oregon Accident Response System (OARs). The current number is 1-800-452-0311. .

126.d. If startups, shutdowns, or scheduled maintenance may result io excess emissions, the permittee must submit startup, shutdown, or scheduled maintenance procedures used to mioiroize excess emissions to DEQ for prior authorization, as required in OAR 340-214-0310 and 340-214-0320. New or modified procedures must be received by DEQ in writing at least 72 hours prior to the first occurrence ofthe excess emission event. The permittee must abide by the approved procedures and have a copy available at all tiroes.

126.e. The permittee must notify DEQ of planned startup/shutdown or scheduled maiotenance events that cause excess emissions.

126.f. The permittee must contioue to maiotaio a log of all excess emissions io accordance with OAR 340-214-0340(3). However, the permittee is not required to submit the detailed log with the semiannual and annual monitoriog reports. The permittee is only required to submit a brief sununary listiog the date, tiroe, and the affected emissions units for each excess emission that occuned duriog the reportiog period. [OAR 340-218-0050(3)(c)]

127. Permit Deviation Reportiog. The permittee must promptly report deviations from permit requirements that do not cause excess emissions, iocludiog those attributable to upset conditions, as defined in the permit, the probable cause of such deviations, and any corrective actions or preventive measures taken. "Prompt" means withio fifteen (15) days of the deviation. Deviations that cause excess emissions, as specified io OAR 340-214-0300 through 340-214-0360 must be reported io accordance with OAR 340-214-0340. [OAR 340-218-0050(3)(c)(B)]

Semi-annual and Annual Title V Reports

128. The permittee must submit three (3) copies of reports of any required monitoring at least every 6 months, completed on forms approved by the Department. Six month periods are January 1 to June 30, and July 1 to December 31. One copy of the report must be submitted to the EPA and two copies to the DEQ regional office. All iostances of deviations from permit requirements must be clearly identified io snch reports: [OAR 340-218-0050(3)(c)(A) and 340-218-0080(6)(d)] and [40 CFR 63.2281(g)]

128.a. The first semi-annual report must be submitted no later than August 30 and must ioclude the followiog:


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128.a.i. The frrst semi-annual compliance certification (Form Rl002 and if applicable Rl003). [OAR 340-218-0080].

128.a.ii. A summary of excess emission events in accordance with Condition 126.f.

128.a.iii. PCWP NESHAP Reports as required by Conditions 146 through 149.

128.b. The annual report must be submitted no later than March 15 and must consist ofthe following:

128.b.i. The emission fee report (Forms FllOI- Fll06, as applicable). [OAR 340-220-0100]

128.b.ii. The annual emission inventory report for the prior calendar year (Form Rl 001 ). [40 CFRpart 51]

128.b.iii. A summary of excess emission events in accordance with Condition 126.£.

128.b.iv. The second semi-annual compliance certification (Form RI002 and if applicable Rl003). [OAR340-218-0080]

128.b.v. PCWP NESHAP Reports as required by Conditions 146 through 149.

129. The semi-annual compliance certification must include the following (provided that the identification of applicable information may cross-reference the permit or previous reports, as applicable): [OAR 340-218-0080(6)(c)]

129.a. The.identification of each term or condition ofthe permit that is the basis of the certification;

129.b. The identification of the method(s) or other means used by the owner or operator for determining the compliance status with each term and condition during the certification period. Such methods and other means must include, at a minimum, the methods and means required under OAR 340-218-0050(3). Note: Certification of compliance with the monitoring conditions in the permit is sufficient to meet this requirement, except when the permittee must certify compliance with new applicable conditions that are not yet in the permit but are incorporated by reference. When certifying compliance with new applicable conditions that are not yet in the permit but are incorporated by reference, the permittee must pravide the information required by this condition. If necessary, the owner or operator also must identify any other material information that must be included in the certification to comply with section 113( c )(2) of the FCAA, which prohibits knowingly making a false certification or omitting material information;

129.c. The status of compliance with terms and conditions of the permit for the period covered by the certification, based on the method or means designated in Condition 129.b. The certification must identify each deviation and take it into account in the compliance certification. The certification must also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance, as defmed under OAR 340-200-0020, occurred; and

129.d. Such other facts as the Department may require to determine the compliance status of the source.

129.e. Notwithstanding any other provision contained in any applicable requirement, the owner or operator may use monitoring as required under OAR 340-218-0050(3) and incorporated into the permit, in addition to any specified compliance methods, for the purpose of submitting compliance certifications. [OAR 340-218-0080(6)(e)]

Greenhouse Gas Reporting


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130. If the calendar year emission rate of greenhouse gases (C02e) is greater than or equal to 2,756 tons (2,500 metric tons), the permittee must register and report its greenhouse gas emissions with DEQ in accordance with OAR 340-215. The greenhouse gas report must be certified by the responsible official consistent with OAR 340218-0040(5).

Other Title V Reporting Requirements

131. All required reports must be certified by a responsible official consistent with OAR 340-218-0040(5). [OAR 340-218-0050(3)(c)(D)]

132. Reporting requirements shall commence on the date of permit issuance unless otherwise specified in the permit. [OAR 340~218-0050(3)(c)(E)]

Addresses of regulatory agencies are the following, unless otherwise instructed:

DEQ- Western Region 750 Front Street NE, Suite 120 Salem, OR 97301-1039 (503) 378-8240

NESHAP Notifications

Notification of Performance Test.

DEQ- Air Quality Division 811 SW Sixth Avenue Portland, OR 97204 (503) 229-5359

Air Operating Pmmits US Environmental Protection Agency Mail Stop OAQ-1 08 1200 Sixth Avenue Seattle, WA98101

133. If required to conduct a performance test, the permittee must submit a written notification of intent to conduct a performance test at least 60 calendar days before the perfmmance test is scheduled to begin to allow the Department to review and approve the site-specific test plan required under Condition II 0, if requested by the Department, and to have an observer present during the test. [40 CFR 63.7(b)(l), 63.9(e), and 63 .2280( c)]

134. In the event the permittee is unable to conduct the performance test on the date specified in the notification requirement specified in Condition 133 due to unforeseeable circumstances beyond his or her control, the permittee must notify the Department as soon as practicable and without delay prior to the scheduled performance test date and specify the date when the performance test is rescheduled. This notification of delay in conducting the performance test must not relieve the permittee of legal responsibility for compliance with any other applicable provisions of 40 CFR Part 63 or with any other applicable Federal, State, or local requirement, nor will it prevent the Administrator from implementing or enforcing 40 CFR Part 63 or taking any other action under the Clean Air Act. [40 CFR 63.7(b)(2)]

Notification of Compliance Status

135. If required to conduct a performance test, design evaluation, or other initial compliance demonstration as specified in Tables 4, 5, and 6, the permittee must submit a Notification of Compliance Status. [40 CFR 63.2280(d)]

135.a. For each initial compliance demonstration required in Table 5 or 6 that does not include a performance test, the J?ermittee must submit the Notification of Compliance Status before the close ofbusiness on the 30 calendar day following the completion of the initial compliance demonstration. [40 CFR 63.2280(d)(l)]


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135.b. For each initial compliance demonstration required in Tables 5 and 6 that includes a performance test conducted according to the requirements in Table 4, the permittee must submit the Notification of Compliance Status, including the performance test results, before the close of business on the 60th calendar day following the completion of the performance test. [40 CFR 63.2280(d)(2)]

Request for Extension of Compliance

136. If the permittee of an affected source cannot comply with a relevant standard by the applicable compliance date for that source, he/she may submit to the Department a request for an extension of complianpe as specified in 40 CFR 63.6(i)(4) through (6). [40 CFR 63.9(c)]

Additional Notification Requirements for Sources with CMS

137. The permittee of an affected source required to use a CMS by a relevant standard must furnish the Department written notification of the date the CMS performance evaluation is scheduled at least 60 calendar days before the evaluation is scheduled to begin. [40 CFR 63.9(g)]

Notification of Compliance Status

138. The following requirements apply when an affected source becomes subject to a relevant standard: [40 CFR 63.9(h)(l)]

138.a. The permittee must comply with all requirements for compliance status reports contained in this permit and 40 CFR Part 63. Each time a notification of compliance status is required under 40 CFR Part 63, the permittee must submit the notification of compliance status to the Department following completion of the relevant compliance demonstration activity specified in the relevant standard. [40 CFR 63.9(h)(3)

138.b. If the permittee of an affected source submits estimates or preliminary information in the approval of construction or reconstruction in place of the actual emissions data or control efficiencies, he/she must submit the actual emissions data or other cotTect information as soon as available but no later than with the initial notification of compliance status. [40 CFR 63.9(h)(5).

Adjustments to Time Periods or Postmark Deadlines for Submittal and Review ofReguired Communications

139. Until an adjustment of a time period or postmark deadline has been approved by the Department under Conditions 139.a and 139.b, the permittee of an affected source remains strictly subject to the requirements of 40 CFRPart 63. The permittee must request the adjustment provided for in Conditions 139.a and 139.b each time he/she wishes to change an applicable time period or postmark deadline specified in 40 CFR Part 63. [40 CFR 63.9(i)

139.a. Notwithstanding time periods or postmark deadlines specified in 40 CFR Part 63 for submittal of information to the Department by the permittee, or review of such information by the Department, such time periods or deadlines may be change by mutual agreement between the permittee and the Department. If the permittee wishes to request a change in a time period or postmark deadline for a particular requirement, then he/she must request the adjustment in writing as soon as practicable before the subject activity is required to take place.

l39.b. If, in the Department's judgment, the permittee's request for an adjustment to a particular time period or postmark deadline is warranted, the Department will approve the adjustment. The Department will notify the permittee in writing or approval or disapproval of the request for an adjustment within 15 calendar days of receiving sufficient information to evaluate the request.

139.c. If the Department is unable to meet a specified deadline, he/she will notify the permittee of any significant delay and inform the permittee of the amended schedule.

Change in Information Already Provided


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140. Any change io the ioformation already provided under 40 CFR 63.9 must be provided to the Department in writing within 15 calendar days after the change. [40 CFR 63.90)]

Other Subpart DDDD Notifications

141. The permittee must notifY the Department withio 30 days before taking any ofthe actions specified io Conditions 14l.a and 14l.b. [40 CFR 63.2280(g)]

141.a. The permittee modifies or replaces the control system for any process unit subject to the compliance options and operatiog requirements io the NESHAP.

14l.b. The permittee changes a continuous monitoriog parameter or the value or range of values of a continuous monitoring parameter for any process unit or control device.

NESHAP Reporting

General Reportiog Requirement

142. Notwithstandiog the requirements in 40 CFR 63.10(d) or (e), and except as provided io 40 CFR 63.16, the permittee of an affected source subject to reportiog requirements under 40 CFR Part 63 must submit reports to the Department io accordance with the reportiog requirements io the relevant standard(s). [40 CFR 63.10(d)(l)]

Reportiog Results of Performance Tests

143. If required to iostall a CMS, the permittee must furnish the Department a copy of a written report of the results of the performance evaluation simultaneously with the results of the performance test required under Conditions 25, 109 and 110 or within 60 days of completion of the performance evaluation if no test is required, unless otherwise specified in a relevant standard. The Department may request that the permittee submit the raw data from a performance evaluation io the report ofthe performance evaluation results. [40 CFR 63.10(d)(2)]

Progress Reports

144. If required to submit progress reports as a condition ofreceiviog an extension of compliance under 40 CFR 63.6(i), the permittee must submit such reports to the Department by the dates specified io the written extension of compliance. [ 40 CFR 63.1 O(d)( 4)]

Immediate Startup, Shutdown, and Malfunction reports

145. Any time an action taken during a startup or shutdown that caused the permittee to exceed any applicable Subpart DDDD emissions limitation, or malfunction (iocluding actions taken to correct a malfunction) is not consistent with the procedures specified io the affected source's startup, shutdown, and malfunction plan, and the source exceeds any applicable entission limitation io the relevant emission standard, the permittee must report the actions taken for that event within 2 working days after commencing actions ioconsistent with the plan followed by a letter withio 7 working days after the end of the event. The immediate repmt must consist of a telephone call (or facsimile (FAX) transmission) to the Department withiti. 2 working days after commenciog actions ioconsistent with the plan, and it must be followed by a letter, delivered or postmarked withio 7 working days after the end ofthe event, that contaios the name, title, and signature of the permittee or other responsible official who is certityiog its accuracy, explaioiog the circumstances of the event, the reasons for not followiog the startup, shutdown, and malfunction plan, and describiog all excess emissions and/or parameter monitoriog exceedances which are believed to have occurred. Notwithstandiog the requirements of the previous sentence, the permittee may make alternative reportiog arrangements, io advance, with the Department. Procedures governing the arrangement of


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alternative reporting requirements are specified in 40 CFR 63 .9(i). [ 40 CFR 63.1 0( d)(5)(ii)]

PCWP NESHAP Reports

146. The pennittee must submit each report in Table 9 to Subpart DDDD of Part 63 that applies. Unless the Department has approved a different schedule for submission of reports under 40 CFR 63.10(a), the permittee must submit each report by the date in Table 9 to Subpart DDDD and as specified in Conditions 146.a. and 146.b. [40 CFR 63.228l(a) and (b)]

146.a. Each compliance report must cover the semiannual reporting period from January I through June 30 or the semiannual reporting period from July I through December 31. [40 CFR 63.228l(b)(3)]

146.b. Each compliance report must be submitted as part of the semiannual report submitted in compliance with Condition 128. [40 CFR 63.2281(b)(4)]

147. The compliance report mnst contain the infonnation in Conditions 147.a through 147.g. [40 CFR 63.2281(c)]

147.a. Company name and address. [40 CFR 63.2281(c)(l)]

147.b. Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. [ 40 CFR 63.2281 ( c )(2)]

147.c. Date of report and beginning and ending dates of the reporting period. [40 CFR 63.228l(c)(3)]

147.d. Ifthe permittee took actions during a startup or shutdown (and the startup or shutdown caused the source to exceed any applicable Subpart DDDD emission limitation), or malfunction of an affected source (including actions taken to correct a malfunction) and those actions were consistent with the pennittee's SSM Plan, then the permittee shall state such infonnation in SSM report. Action taken by the permittee to minimize emissions during such startups, shutdowns, or malfunctions shall be summarized in the report and may be in the fonn of a checklist; if actions taken are the same for each event, only one checklist is necessary. The report must also include the number, duration, and a brief description for each type of malfunction which occurred during the reporting period and which caused or may have caused any applicable emission limitation to be exceeded. Reports shall only .be required if a startup or shutdown caused the permittee to exceed any applicable Subpart DDDD emissions limitation or if a malfunction occurred druing the reporting period. [40 CFR 63.10(d)(5)(i) and 63.2281(c)(4)]

147.e. A description of control device maintenance performed while the control device was offline and one or more of the process units controlled by the control device was operating, including the information specified in Conditions 147.e.i through 147.e.iii. [40 CFR 63.2281(c)(5)]

147.e.i. The date and time when the control device was shut down and restarted.

147.e.ii. Identification of the process units that were operating and the number of hours that each process unit operated while the control device was offline.

147.e.iii. A statement of whether or not the control device maintenance was included in the approved routine control device maintenance exemption in Condition 24. Ifthe control device maintenance was included in the approved routine control device maintenance exemption, then the permittee must report the information in Conditions 147.e.iii.A through 147.e.iii.C.

147.e.iii.A.

147.e.iii.B.

147.e.iii.C.


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The total amount oftime that each process unit controlled by the control device operated during the semiannual compliance period and during the previous semiannual compliance period.

The amount oftime that each process unit controlled by the control device operated while the control device was down for maintenance covered under the routine control device maintenance exemption during the semiannual compliance period and during the previous semiannual compliance period.

Based on the information recorded under Conditions 147.e.iii.A and 147.e.iii.B for each process unit, compute the annual percent of process unit operating uptime during which the control device was offline for routine maintenance using Equation 8.

DTP+DT, RM = (Equation 8)

PUp+PU,

Where:

RM =Annual percentage of process unit uptime during which control device is down for routine control device maintenance;

PUP= Process unit uptime for the previous semiannual compliance period;

PU, =Process unit uptime for the cuJTent semiannual compliance period;

DTP =Control device downtime claimed under the routine control device maintenance exemption for the previous semiannual compliance period;

DT, = Control device downtime claimed under the routine control device maintenance exemption for the current semiannual compliance period.

147.f. The results of any performance tests conducted during the semiannual reporting period. [40 CFR 63.228l(c)(6)]

147.g. If there are no deviations from any applicable compliance option or operating requirement, and there are no deviations from the requirements for work practice requirements in Table 8, a statement that there were no deviations from the compliance options, operating requirements, or work practice requirements during the reporting period. [ 40 CFR 63.2281( c )(7)]

148. For each deviation from a compliance option or operating requirement and for each deviation from the work practice requirements in Table 8 that occurs at an affected source where the permittee is not using a CMS to comply with the compliance options, operating requirements, or work practice requirements in the NESHAP, the compliance report must contain the information in Conditions 14 7 .a through 147 .f and in Conditions 148.a and 148.b. This includes periods of startup, shutdown, and malfunction and routine control device maintenance. [40 CFR 63.228l(d)]

148.a. The total operating time of each affected source during the reporting period. [40 CFR 63.228l(d)(l)]


Page 62 of75

148.b. Information on the number, duration, and cause of deviations (including unknown cause, if applicable), as applicable, and the corrective action taken. [40 CFR 63.228l(d)(2)]

149. For each deviation from a compliance option or operating requirement occurring at an affected source where using a CMS to comply with the compliance options and operating requirements in the NESHAP, the permittee must include the information in Conditions 147.a through 147.f and Conditions 149.a through 149J. This includes periods of startup, shutdown, and malfunction and routine control device maintenance. [40 CFR 63.228l(e)]

149.a. The date and time that each malfunction started and stopped. [40 CFR 63.228l(e)(l)]

149.b. The date and time that each CMS was inoperative, except for zero (low-level) and high-level checks. [40 CFR63.228l(e)(2)]

149.c. The date and time that each deviation started and stopped, and whether each deviation occurred during a period of startup, shutdown, or malfunction; during a period of control device maintenance covered in the approved routine control device maintenance exemption; or during another period. [40 CFR63.228l(e)(4)]

149.d. A summary of the total duration of the deviation during the reporting period and the total duration as a percent of the total source operating time during that reporting period. [40 CFR 63.228l(e)(5)]

149.e. A breakdown of the total duration of the deviations during the reporting period into those that are due to startup, shutdown, control system problems, control device maintenance, process problems, other known causes, and other unknown causes. [40 CFR 63.228l(e)(6)]

149.f. A summary of the total duration ofCMS downtime during the reporting period and the total duration of CMS downtime as a percent of the total source operating time during that reporting period. [40 CFR 63.228l(e)(7)]

149.g. A brief description of the process units. [40 CFR 63.228l(e)(8)]

149.h. A brief description of the CMS. [40 CFR 63.228l(e)(9)]

149.i. The date of the latest CMS certification or audit. [40 CFR 63.228l(e)(10)]

149.j. A description of any changes in CMS, processes, or controls since the last reporting period. [40 CFR 63.228l(e)(ll)]

EMISSION FEES

150. Emission fees will be based on the Plant Site Emission Limits in Condition 105, uniess the permittee elects to report actual emissions for one or more permitted processes/pollutants using the procedures in OAR 340 Division 220. Ifthe permittee reports actual emissions for one or more permitted processes/pollutants, the permitted emissions for the remaining permitted processes/pollutants will be based on the following table: [OAR 340-220-0090]

Emission Source Description Permitted PM10 Process Code (tons) (DEQ Codes)

NON-APPLICABLE REQUIREMENTS


Page 63 o£75

so, NOx voc (tons) (tons) (tons

.

151. State and Federal air quality requirements (e.g., rules and regulations) currently determined not applicable to tbe permittee are listed below along witb the reason for the non-applicability: [OAR 340-218-0110]

Reason Code

OAR Chapter 340:

Division 202: b

Division 206:

0050 c

Division 208:

0510 through 0640 d

Division 210:

0 I 00 through 0120 b

Division 214:

0130(2) and (3) h

0210 and 0220 b

Division 218:

0050(4) b

0050(8) h

0090 b

0100 b

Division 222:

0060 h

0090 h

Division 226:

0400 h

Division 228:

0120 f

0200 e

0300 b

Division 230: e

Division 232: h ore

Division 234:

OliO through 0140 e

0210 through 0270 b

0310 through 0360

0410 through 0430

0510

Division 236:

Division 238:

0100

Division 240:

Division 242:

Division 244:

OliO through 0180

0230

Division 250:

Division 252:

Reason Code

b

b

b

b

e

c

c

h

b

Division 254 e

Division 256: b or c

Division 258: b

Division 260: b

Division 262: b

Division 264:

0100 d

0120through0170 d

0190 e

Division 266: b

40CFR

Part 55 b

Part 57 b

Part 60, except b subpart A and appendices

Rule

Part 61, except subparts A. M, and appendices

Part 63, except subparts A, DDDD, DDDDD, ZZZZand appendices

Part 68

Parts 72 through 78

Part 82, except subpart F

Parts 85 through 89

Reason Code

b

b

b

b

b

b

Reason code definitions:

a this pollutant is not emitted by the facility b the facility is not in this source category c the facility is not in a special controVnonattahnnent area d the facility is not in this county e the facility does not have this emissions unit f the facility does not use this fuel type

Pe1mit number: 22-0143-TV-01 Expiration date: 02/01/18

Page 64 of75

g the rule does not apply because no changes have been made at the facility that would trigger these procedural requirements

h this method/procedure is not used by the facility this rule applies only to DEQ and regional authorities

j there are no emissions units with add-on control devices or the pre-controlled potential emissions are is less than I 00 tons per year or the emissions units with add-on control devices and pre-controlled emissions greater than 100 tons per year are subject to emissions standards promulgated after November of 1990

GENERAL CONDITIONS

G I. General Provision

Terms not otherwise defined in this permit have the meaning assigned to such terms in the referenced regulation.

G2. Reference materials

Where referenced in this permit, the versions of the following materials are effective as of the dates noted unless otherwise specified in this permit:

a. Source Sampling Manual; January 23, 1992- State Implementation Plan Volume 3, Appendix A4; b. Continuous Monitoring Manual; January 23, 1992- State Implementation Plan Volume 3,

Appendix A6; and c. All state and federal regulations as in effect on the date of issuance of this permit.

G3. Applicable Requirements [OAR 340-218-0010(3)(b)]

Oregon Title V Operating Permits do not replace requirements in Air Contaminant Discharge Permits (ACDP) issued to the source even ifthe ACDP(s) have expired. For a source operating under a Title V permit, requirements established in an earlier ACDP remain in effect notwithstanding expiration of the ACDP or Title V permit, unless a provision expires by its terms or unless a provision is modified or terminated following the procedures used to establish the requirement initially. Source specific requirements, including, but not limited to TACT, RACT, BACT, and LAER requirements, established in an ACDP must be incorporated into the Oregon Title V Operating Permit and any revisions to those requirements must follow the procedures used to establish the requirement initially.

G4. Compliance [OAR 340-218-0040(3)(n)(C), 340-218-0050(6), and 340-218-0080(4)]

a. The permittee must comply with all conditions of this permit. Any permit condition noncompliance constitutes a violation of the Federal Clean Air Act and/or state rules and is grounds for enforcement action; for permit termination, revocation andre-issuance, or modification; or for denial of a permit renewal application. Any noncompliance with a permit condition specifically designated as enforceable only by the state constitutes a violation of state rules only and is grounds for enforcement action; for permit termination, revocation andreissuance, or modification; or for denial of a permit renewal application.


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b. Any schedule of compliance for applicable requirements with which the source is not iu compliance at the tirue of permit issuance is supplemental to, and does not sanction noncompliance with the applicable requirements on which it is based.

c. For applicable requirements that will become effective during the permit term, the source must meet such requirements on a tiruely basis unless a more detailed schedule is expressly required by the applicable requirement.

G5. Masking Emissions:

The permittee must not iustall or use any device or other means designed to mask the emission of an air contamiuant that causes or is likely to cause detriment to health, safety, or welfare of any person or otherwise violate any other regulation or requirement. [OAR 340-208-0400] This condition is enforceable only by the State.

G6. Credible Evidence:

Notwithstandiug any other provisions contained in any applicable requirement, any credible evidence may be used for the purpose of establishiug whether a person has violated or is iu violation of any such applicable requirements. [OAR 340-214-0120]

G7. Certification [OAR 340-214-0110, 340-218-0040(5), 340-218-0050(3)(c)(D), and 340-218-0080(2)]

Any document submitted to the Department or EPA pursuant to this permit must contaiu certification by a responsible official of truth, accuracy and completeness. All certifications must state that based on iuformation and belief formed after reasonable iuquiry, the statements and iuformation iu the document are true, accurate, and, complete. The permittee must promptly, upon discove1y, report to the Department a material error or omission in these records, reports, plans, or other documents.

G8. Open Burning [OAR Chapter 340, Division 264]

The permittee is prohibited from conductiug open buruiug, except as may be allowed by OAR 340-264-0020 through 340-264-0200.

G9. Asbestos [ 40 CFR Part 61, Subpart M (federally enforceable), OAR Chapter 340-248-0005 through 340-248-0180 (state-only enforceable) and 340-248-0205 through 340-248-0280]

The permittee must comply with OAR Chapter 340, Division 248, and 40 CFR Part 61, Subpart M when conductiug any renovation or demolition activities at the facility.

G 10. Stratospheric Ozone and Climate Protection [40 CFR 82 Subpart F, OAR 340-260-0040]

The permittee must comply with the standards for recycliug and emissions reduction pursuant to 40 CFR Part 82, Subpart F, Recycliug and Emissions Reduction.

Gll. Permit Shield [OAR340-218-0ll0]

a. Compliance with the conditions ofthe permit is deemed compliance with any applicable requirements as of the date of permit issuance provided that:

i. such applicable requirements are iucluded and are specifically identified iu the permit, or ii. the Department, in acting on the permit application or revision, determiues iu writiug that

other requirements specifically identified are not applicable to the source, and the permit iucludes the determiuation or a concise summary thereof.


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b. Nothing in this rule or in any federal operating permit alters or affects the following:

i. the provisions of ORS 468.115 (enforcement in cases of emergency) and ORS 468.035 (function of department);

ii. the liability of an owner or operator of a somce for any violation of applicable requirements prior to or at the time of permit issuance;

iii. the applicable requirements of the national acid rain program, consistent with section 408(a) of the FCAA; or

iv. the ability of the Department to obtain information from a somce pmsuant to ORS 468.095 (investigatory authority, entry on premises, status of records).

c. Somces are not shielded from applicable requirements that are enacted dnring the permit term, unless such applicable requirements are incorporated into the permit by administrative amendment, as provided in OAR 340-218-0150(1)(h), significant permit modification, or reopening for cause by the Department.

Gl2. Inspection and Entry [OAR 340-218-0080(3))

Upon presentation of credentials and other documents as may be required by law, the permittee must allow the Department ofEnviromnental Quality, or an authorized representative (including an authorized contractor acting as a representative of the EPA Administrator), to perform the following:

a. enter upon the permittee's premises where an Oregon Title V Operating Permit program somce is located or emissions-related activity is conducted, or where records must be kept under the conditions of the permit;

b. have access to and copy, at reasonable times, any records that must be kept under conditions of the permit;

c. inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit; and

d. as authorized by the FCAA or state rules, sample or monitor, at reasonable times, substances or parameters, for the purposes of assuring compliance with the pennit or applicable requirements.

G 13. Fee Pavment [OAR 340-220-0010, and 340-220-0030 through 340-220-0190)

The permittee must pay an annual base fee and an annual emission fee for particulates, sulfur dioxide, nitrogen oxides, and volatile organic compounds. The permittee must submit payment to the Department ofEnviromnental Quality, Business Office, 811 SW 6th Avenue, Portland, OR 97204, within 30 days of the date the Department mails the fee invoice or August 1 of the year following the calendar year for which emission fees are paid, whichever is later. Disputes must be submitted in writing to the Department of Environmental Quality. Payment must be made regardless of the dispute. User-based fees will be charged for specific activities (e.g., computer modeling review, ambient monitoring review, etc.) requested by the permittee.

G14. Off-Permit Changes to the Sonrce [OAR 340-218-0140(2))

a. The permittee must monitor for, and record, any off-permit change to the sonrce that:

i. is not addressed or prohibited by the permit; ii. is not a Title I modification; iii. is not subject to any requirements under Title IV of the FCAA; iv. meets all applicable requirements; v. does not violate any existing permit term or condition; and


Page 67 of75

vi. may result in emissions of regulated air pollutants subject to an applicable requirement but not otherwise regulated under this permit or may result in insignificant changes as defmed in OAR 340-200-0020.

b. A contemporaneous notification, if required under OAR 340-218-0140(2)(b ), must be submitted to the Department and the EPA.

c. The permittee must keep a record describing off-permit changes made at the facility that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under the permit, and the emissions resulting from those off-permit changes.

d. The permit shield of condition G9 does not extend to off-permit changes.

Gl5. Section 502(b)(l0) Changes to the Source [OAR 340-218-0140(3)]

a. The permittee must monitor for, and record, any section 502(b )(1 0) change to the source, which is defmed as a change that would contravene an express permit term but would not:

i. violate an applicable requirement; ii. contravene a federally enforceable permit term or condition that is a monitoring,

recordkeeping, reporting, or compliance certification requirement; or iii. be a Title I modification.

b. A minimum 7-day advance notification must be submitted to the Department and the EPA in accordance with OAR 340-218-0140(3)(b).

c. The permit shield of condition G9 does not extend to section 502(b )(10) changes.

Gl6. Administrative Amendment [OAR 340-218-0150]

Administrative amendments to this permit must be requested and granted in accordance with OAR 340-218-0150. The permittee must promptly submit an application for the following types of administrative amendments upon becoming aware of the need for one, but no later than 60 days of such event:

a. legal change of the registered name of the company with the Corporations Division of the State of Oregon, or

b. sale or exchange of the activity or facility.

Gl7. Minor Permit Modification [OAR 340-218-0170]

The permittee must submit an application for a minor permit modification in accordance with OAR 340-218-0170.

Gl8. Significant Permit Modification [OAR 340-218-0 180]

The permittee must submit an application for a significant permit modification in accordance with OAR 340-218-0180

G 19. Staying Permit Conditions [OAR 340-218-0050(6)(c)]

Notwithstanding conditions G 16 and Gl7, the filing of a request by the permittee for a permit modification, revocation andre-issuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition.

G20. Construction/Operation Modification [OAR 340-218-0190]


Page 68 of75

The permittee must obtain approval from the Departruent prior to construction or modification of any stationary source or air pollution control equipment in accordance with OAR 340-210-0200 tinough OAR 340-210-0250.

G2l. New Source Review Modification [OAR 340-224-0010]

The permittee may not begin construction of a major source or a major modification of any stationary source without having received an air contaminant discharge permit (ACDP) from the Departruent and having satisfied the requirements of OAR 340, Division 224.

G22. Need to Halt or Reduce Activity Not a Defense [OAR 340-218-0050(6)(b)]

The need to halt or reduce activity will not be a defense. It will not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

G23. Dutv to Provide Information [OAR 340-218-0050(6)(e) and OAR 340-214-0110]

The permittee must furnish to the Departruent, within a reasonable time, any information that the Departruent may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit, or to determine compliance with the permit. Upon request, the permittee must also furnish to the Departruent copies of records required to be retained by the permit or, for information claimed to be confidential, the permittee may furnish such records to the Departtnent along with a claim of confidentiality.

G24. Reopening for Cause [OAR 340-218-0050(6)(c) and 340-218-0200]

a. The permit may be modified, revoked, reopened and reissued, or terminated for cause as determined by the Departruent.

b. A permit must be reopened and revised under any of the circumstances listed in OAR 340-218-0200(1)(a).

c. Proceedings to reopen and reissue a permit must follow the same procedures as apply to initial permit issuance and affect only those parts of the permit for which cause to reopen exists.

G25. Severability Clause [OAR 340-218-0050(5)]

Upon any administrative or judicial challenge, all the emission limits, specific and general conditions, monitoring, recordkeeping, and reporting requirements ofthis permit, except those being challenged, remain valid and must be complied with.

G26. Permit Renewal and Expiration [OAR 340-218-0040(1)(a)(D) and 340-218-0130]

a. This permit expires at the end of its term, unless a timely and complete renewal application is submitted as described below. Permit expiration terminates the permittee's right to operate.

b. Applications for renewal must be submitted at least 12 months before the expiration of this permit, unless the Department requests an earlier submittal. If more than 12 months is required to process a permit renewal application, the Departruent must provide no less than six (6) months for the owner or operator to prepare an application.

c. Provided the permittee submits a timely and complete renewal application, this permit will remain in effect until final action has been taken on the renewal application to issue or deny the permit.

G27. Permit Transference [OAR 340-218-0150(l)(d)]


Page 69 of75

The permit is not transferable to any person except as provided in OAR 340-218-0 150(1)( d).

G28. Property Rights [OAR 340-200-0020 and 340-218-0050(6)( d)]

The permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement offederal, state, or local laws or regulations, except as provided in OAR 340-218-0110.

G29. Permit Availability [OAR 340-200-0020 and 340-218-0120(2)]

The permittee must have available at the facility at all times a copy ofthe Oregon Title V Operating Permit and must provide a copy oftbe permit to the Department or an authorized representative upon request.

ALL INQillRlES SHOULD BE DIRECTED TO:

D EQ-Western Region 750 Front St. NE, Suite 120 Salem, OR 97301-1039 (503) 378-8240

Tables to Subpart DDDD of Part 63

Table 1A: Production-Based Compliance Option NOTE: Table 1 A is not applicable to Flakeboard

Table 1B: Add-on Contr-ol Systems Compliance Options


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For eacb ofthe following The permittee must comply with one of the following six process units ... compliance options by using an emissions control system ... Fiberboard mat dryer heated (1) Reduce emissions of total HAP, measured as THC (as zones (at new affected sources carbon)', by 90 percent; or only); green rotary dryers; hardboard ovens; press predryers (2) Limit emissions oftotalHAP, measured as THC (as (at new affected sources only); carbon)', to 20 ppmvd; or pressurized refmers; primary tube dryers; secondary tube dryers; (3) Reduce methanol emissions by 90 percent; or reconstituted wood product board coolers (at new affected sources ( 4) Limit methanol emissions to less than or equal to 1 ppmvd if only); reconstituted wood product uncontrolled methanol emissions entering the control device are presses; softwood veneer dryer greater than or equal to 10 ppmvd; or heated zones; rotary strand dryers; conveyor strand dryer zone one (5) Reduce formaldehyde emissions by 90 percent; or (at existing affected sources); and conveyor strand dryer zones one (6) Limit formaldehyde emissions to less than or equal to 1 and two (at new affected sources) ppmvd if uncontrolled formaldehyde emissions entering the

control device are greater than or equal to 10 ppmvd.

(a) The penruttee may choose to subtract methane Ji·om THC as carbon measurements.

Table 2: Operating Requirements

If operating a(n) The permittee must ... Or the permittee must ... ... (!)Thermal Maintain the 3-hour block average Maintain the 3-hour block average THC oxidizer firebox temperature above the rninlmum concentration' in the thermal oxidizer exhaust

temperature established during the below the maximum concentration established performance test during the performance test.

(2) Catalytic Maintain the 3-hour block average Maintain the 3-hour block average THC oxidizer catalytic oxidizer temperature above the concentration' in the catalytic oxidizer exhaust

minimum temperature established during below the maximum concentration established the performance test; AND check the during the performance test. activity level of a representative sample of the catalyst at least every 12 months

(a)The penruttee may choose to subtract methane from THC measurements.

T bl 3 W kP f R t a e : or rae Ice eqmremen s For the following process units at The permittee must ... existing or new affected sources ...


Page 71 of75

( 1) Dry rotary dryers Process furnish with a 24-hour block average iulet moisture content of less than or equal to 30 percent (by weight, dry basis); AND operate with a 24-hour block average iulet dryer temperature ofless than or equal to 600"F.

(2) Group 1 miscellaneous coating Use non-HAP coatings as defmed in 40 CFR 63.2292. operations

.

Table 4: Requirements for Performance Tests For ... The permittee Using ...

must ... (I) Each process unit subject to a Select sampling Method 1 or !A of 40 CFR part 60, appendix compliance option in Table lB. port's location A (as appropriate).

and the number of traverse ports.

(2) Each process unit subject to a Determine Method 2 in addition to Method 2A, 2C, 2D, compliance option in Table lB. velocity and 2F, or 2G in appendix A to 40 CFR part 60 (as

volumetric flow appropriate). rate.

(3) Each process unit subject to a Conduct gas Method 3, 3A, or 3B in appendix A to 40 CFR compliance option in Table lB. molecular weight part 60 (as appropriate).

analysis. ( 4) Each process unit subject to a Measure Method 4 in appendix A to 40 CFR part 60; compliance option in Table lB. moisture content OR Method 320 in appendix A to 40 CFR part

ofthe stack gas. 63; OR ASTM D6348-03 (IBR, see 40 CFR 63.14(b))

(5) Each process unit subject to a Measure Method 25A in appendix A to 40 CFR part compliance option in Table IB for which emissions of 60. The permittee may measure emissions of the permittee chooses to demonstrate total HAP as methane using EPA Method 18 in appendix A compliance using a total HAP as THC THC. to 40 CFR part 60 and subtract the methane compliance option. emissions from the emissions of total HAP as

THC. (6) Each process unit subject to a Measure Method 308 in appendix A to 40 CFR part 63; compliance option in Table lB for which emissions of OR Method 320 in appendix A to 40 CFR part the permittee chooses to demonstrate methanol. 63; OR the NCASI Method CIIWP-98.01 compliance using a methanol compliance (IBR, see 40 CFR63.14(f)); OR the NCASI option. Method IM/CAN/WP-99.02 (IBR, see 40

CFR 63.14(±)). (7) Each process unit subject to a Measure Method 316 in appendix A to 40 CFRpart 63; compliance option in Table lB for which emissions of OR Method 320 in appendix A to 40 CFR part the permittee chooses to demonstrate formaldehyde. 63; OR Method 0011 in "Test Methods for compliance using a formaldehyde Evaluating Solid Waste, Physical/Chemical compliance option. Methods" (EPA Publication No. SW-846) for

formaldehyde; OR the NCASI Method CIIWP-98.01 (IBR, see 40 CFR 63.14(±)); OR the NCASI Method IM/CANIWP-99.02 (IBR, see 40 CFR63.14(f)).

~tuted wood product press Meet the design Methods 204 and 204A through 204F of 40 e specifications CFR part 51 appendix M, to determine

For ... The permittee must ...

reconstituted wood product board cooler at included in the a new affected source subject to a definition of compliance option in Table 1B wood products

enclosure in 40 CFR63.2292

OR

Determine the percent capture efficiency of the enclosure directing emissions to an add-on control device.

(9) Each reconstituted wood product press Determine the at a new or existing affected source. percent capture

efficiency.

(10) Each process unit subject to a Establish the site compliance option in Table lB. specific

operating requirements (including the parameter limits orTHC concentration limits) in Table 2.

Using ...


Page 72 of75

capture efficiency (except for wood products enclosures as defined in 40 CFR 63 .2292). Enclosures that meet the definition of wood products enclosure or that meet Method 204 requirements for a permanent total enclosure (PTE) are assumed to have a capture efficiency of 100 percent. Enclosures that do not meet either the PTE requirements or design criteria for a wood products enclosure must determine the capture efficiency by constructing a TTE according to the requirements of Method 204 and applying Methods 204A tlu·ough 204F (as appropriate). As an alternative to Methods 204 and 204A through 204F, the permittee may use the tracer gas method contained in appendix A to the NESHAP. A TTE and Methods 204 and 204A through 204F (as appropriate) of40 CFRpart 51, appendix M. As an alternative to installing a TIE and using Methods 204 and 204A through 204F, the permittee may use the tracer gas method contained in appendix A to the NESHAP. Data fi'om the parameter monitoring system or THC CEMS and the applicable performance test method(s).

Table 5: Performance Testing and Compliance Demonstrations for the Compliance Options and Operating R ' t eqmremen s

For the following compliance options and operating The permittee has demonstrated compliance if ...

For each ... requirements ... (I) Process unit listed in Reduce emissions of Total HAP emissions, measured using the methods in Table lB. total HAP, measured Table 4 over the 3-hour performance test, are reduced by

as THC, by90 at least 90 percent, as calculated using the procedures in percent. Conditions 25, 109, and 110; AND the permittee has a

record of the operating requirement(s) listed in Table 2 for the process unit over the performance test during which emissions were reduced by at least 90 percent.

(2) Process unit listed in Limit emissions of The average total HAP emissions, measured using the Table lB. total HAP, measured methods in Table 4 over the 3-hour performance test, do

For the following compliance options and operating

For each ... requirements ... as THC, to20 ppmvd.

(3) Process unit listed in Reduce methanol or Table lB. formaldehyde

emissions by 90 percent.

(4) Process unit listed in Limit methanol or Table lB. formaldehyde

emissions to less than or equal to 1 ppmvd (if uncontrolled emissions are greater than or equal to 10 ppmvd).

(5) Reconstituted wood Compliance options product press at a new or in Table lB existing affected source.


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The permittee has demonstrated compliance if ...

not exceed 20 ppmvd; AND the permittee has a record of the operating requirement(s) listed in Table 2 for the process unit over the performance test during which emissions did not exceed 20 ppmvd. The methanol or formaldehyde emissions measured using the methods in Table 4 over the 3.hour performance test, are reduced by at least 90 percent, as calculated using the procedures in Conditions 25, 109, and 110; AND the permittee has a record of the operating requirement(s) listed in Table 2 for the process unit over the performance test during which emissions were reduced by at least 90 percent. The average methanol or formaldehyde emissions, measured using the methods in Table 4 over the 3-hour performance test, do not exceed 1 ppmvd; AND the permittee has a record of the operating requirement( s) listed in Table 2 for the process unit over the performance test during which emissions did not exceed 1 ppmvd. If the process unit is a reconstituted wood product press or a reconstituted wood product board cooler, the capture device either meets the EPA Method 204 criteria for a PTE or achieves a capture efficiency of greater than or equal to 95 percent. The permittee submits the results of capture efficiency verification using the methods in Table 4 with the Notification of Compliance Status.

Table 6: Compliance Demonstrations for Work·Prac!tce R equ1rements For each ... For the following work practice The permittee has demonstrated

requirements ... compliance if ... (1) Dry rotary dryer Process furnish with an inlet The permittee meets the work

moisture content less than or equal practice requirement AND submits to 30 percent (by weight, dry basis) a signed statement with the AND operate with an inlet dryer Notification of Compliance Status temperature of less than or equal to that the dryer meets the criteria of a 600"F. "my rotary dryer" AND has a

record of the inlet moisture content and inlet dryer temperature (as required in § 63.2263.

(2) Group 1 miscellaneous coating Use non-HAP coatings as defmed The permittee meets the work operations in 40 CFR 63.2292. practice requirement AND submits

a signed statement with the Notification of Compliance Status that the permittee is using non-HAP coatings AND has a record showing that the permittee is using non-HAP coatings.


Page 74 of75

T b1 7 C a e : ontmuous c r . b b c ompJrance wit t e r 0 . ompnance Jphons and 0 Jperatmg R equuements For ... For the following compliance The permittee must demonstrate

options and operating continuous compliance by ... requirements ...

(I) Each process unit listed in Table Compliance options in Table 1B Collecting and recording the lB. and the operating requirements in operating parameter monitoring

Table 2 based on monitoring of system data listed in Table 2 for the operating parameters. process unit according to

Conditions 26, 29, and 31; AND reducing the operating parameter monitming system data to the specified averages in units of the applicable requirement according to calculations in Condition 26; AND maintaining the average operating parameter at or above the minimum, at or below the maximum, or within the range (whichever applies) established according to Conditions 25, 109, and llO.

(2) Each process unit listed in Table Compliance options in Table 1B Collecting and recording the THC lB. and the operating requirements in monitoring data listed in Table 2 for

Table 2 based on THC CEMS data. the process unit according to 40 CFR 63.2269(d); AND reducing the CEMS data to 3-hour block averages according to calculations in 40 CFR 63.2269(d); AND maintaining the 3-hour block average THC concentration in the exhaust gases less than or equal to the THC concentration established according to Condition 25, 109, and 110.

(3) Each process unit using a Compliance options in Table lB or Checking the activity level of a catalytic oxidizer. the emissions averaging compliance representative sample ofthe catalyst

option in 40 CFR 63.2240(c) at least every 12 mouths and taking any necessary corrective action to ensure that the catalyst is performing within its design range.

T bl 8 C t' a e : on lDUOUS c I' 'thth W kP t' R t ompnance WI e or rae 1ce eqmremen s For ... For the following work The permittee must demonstrate continuous compliance

practice requirements ... by ... (1) Dry rotary Process furnish with an Maintaining the 24-hour block average inlet furnish dryer. inlet moisture content less moisture content at less than or equal to 30 percent (by

than or equal to 30 weight, dry basis) AND malutaluing the 24-hour block percent (by weight, dry average inlet dryer temperature at less than or equal to basis) AND operate with 600'F; AND keeping records of the inlet temperature, of au inlet dryer temperature furnish moisture content, and inlet dryer temperature.

Pe1mit number: 22-0143-TV-01 Expiration date: 02/01/18

Page 75 of75

For ... For the following work The permittee must demonstrate continuous compliance practice requirements ... by ••• of less than or equal to 600'F.

(2) Group 1 Use non-HAP coatings as Continuing to use non-HAP coatings AND keeping records miscellaneous defmed in 40 CFR showing that the permittee is using non-HAP coatings. coating 63.2292. operations.

T bl 9 R f R a e : eqmrements or eports

The report must contain ... You must submit the report ...

You must submit a(n) ... (1) Compliance report The information in 40 CFR Semiannually according to the requirements in

63.2281(c) through (g) 40 CFR 63.228l(b)

(2) Immediate startup, (i) Actions taken for the event By fax or telephone within 2 working days shutdown, and malfunction after starting actions inconsistent with the report if you had a startup, plan. shutdown, or malfunction during the reporting period (ii) The information in 40 CFR By letter within 7 working days after the end that is not consistent with your 63 .10( d)(5)(ii) of the event unless you have made SSMP. arrangements with the Departtnent.

Documents

OREGON DEP AR'fMENT OF ENVIRONMENTAL QUALITY .~ OREGON ... · PDF fileOREGON DEP AR'fMENT OF ENVIRONMENTAL QUALITY OREGON TITLE V OPERATING PERMIT ... CH4 co co,e COMS CPMS DEQ