Oregon Title V Operating Permit Number: 18-0006-TV-01 Expiration Date: 02/01/2018 Page 1 of 67 OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY OREGON TITLE V OPERATING PERMIT Eastern Region

Permit Number: 18-0006-TV-01

Expiration Date: 02/01/2018

Page 1 of 67

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

OREGON TITLE V OPERATING PERMIT

Eastern Region

475 NE Bellevue Dr., Suite 110

Bend, OR 97701

Telephone (541) 388-6146

Issued in accordance with the provisions of

ORS 468A.040 and based on the land use compatibility findings included in the permit record.

ISSUED TO: INFORMATION RELIED UPON:

JELD-WEN, Inc.

dba JELD-WEN

Application Number:

Received

26596

12/14/2011

PO Box 1329

Klamath Falls, OR 97601

PLANT SITE LOCATION: LAND USE COMPATIBILITY STATEMENT:

3303 Lakeport Blvd. Issued by: Klamath County Planning Dept.

Klamath Falls, OR 97601 Dated: 07/12/1995

ISSUED BY THE DEPARTEMENT OF ENVIRONMENTAL QUALITY

__________(Signature on File)___________________ ___________(January 30, 2013)_________________

Mark W. Bailey, Eastern Region Air Quality Manager Date

Nature of Business: SIC

Sawmills, planing mills, reconstituted wood products.

Supporting activities, including fabrication of signs and

advertising specialties, metal working (such as welding,

chrome plating, milling and forming), and fuel burning

equipment greater than 30 million Btu per hour heat

input located inside an AQMA

2421, 2431, 2493, 3444

3471, 3535, 3993, 4961

RESPONSIBLE OFFICIAL FACILITY CONTACT PERSON

Titles: The General Managers for the following

facilities: Millwork Manufacturing-Thomas

and/or Wood Fiber Division-Oregon and/or

Millwork Manufacturing-Klamath Falls

and/or JELD-WEN Engineering and/or

JELD-WEN-Marketing Services

Name: Aaron Brite

Title: Environmental Manager

Phone: (541) 883-3373 x2834



Page 2 of 67

TABLE OF CONTENTS

LIST OF ABBREVIATIONS THAT MAY BE USED IN THIS PERMIT .................................................................. 3

PERMITTED ACTIVITIES .......................................................................................................................................... 4

EMISSIONS UNIT (EU) AND POLLUTION CONTROL DEVICE (PCD) IDENTIFICATION .............................. 4

EMISSION LIMITS AND STANDARDS .................................................................................................................... 6

PLANT SITE EMISSION LIMITS ............................................................................................................................. 32

TESTING REQUIREMENTS ..................................................................................................................................... 33

MONITORING REQUIREMENTS ............................................................................................................................ 34

EMISSION FEES ........................................................................................................................................................ 39

RECORDKEEPING REQUIREMENTS .................................................................................................................... 39

REPORTING REQUIREMENTS ............................................................................................................................... 42

NON-APPLICABLE REQUIREMENTS .................................................................................................................... 48

GENERAL CONDITIONS ......................................................................................................................................... 49

ATTACHMENT 1: RULE NUMBERING CROSS REFERENCE ........................................................................... 55

ATTACHMENT 2: HAZARDOUS AIR POLLUTANT EMISSION FACTORS .................................................... 56

ATTACHMENT 3: NESHAP GENERAL PROVISIONS ........................................................................................ 58



Page 3 of 67

LIST OF ABBREVIATIONS THAT MAY BE USED IN THIS PERMIT

AQMA Air Quality Management Area

ASTM American Society of Testing and

Materials

CFR Code of Federal Regulations

CH4 Methane (greenhouse gas)

CO Carbon Monoxide

CO2 Carbon Dioxide (greenhouse gas)

CO2e Carbon Dioxide Equivalent (greenhouse

gases)

DEQ Oregon Department of Environmental

Quality

dscf dry standard cubic foot

dscm dry standard cubic meter

EF Emission Factor

ENG JELD-WEN Engineering

EPA US Environmental Protection Agency

EU Emissions Unit

FCAA Federal Clean Air Act

GHG Greenhouse Gases

gr/dscf grains per dry standard cubic foot

HAP Hazardous Air Pollutant as defined by

OAR 340-032-0130

HCFC Chloro-Fluoro-Hydrocarbon

ID Identification Number (code)

I&M Inspection and Maintenance

JW-MS JELD-WEN-Marketing Services

M Thousand

MM Million

MMBtu Million British thermal units

MM-KF Millwork Manufacturing-Klamath Falls

MM-T Millwork Manufacturing-Thomas

MBF Thousand Board Feet

MS Marketing Services

MSF Thousand Square Feet

N2O Nitrous Oxide (greenhouse gas)

NA Not Applicable

NOx Nitrogen Oxides

OAR Oregon Administrative Rules

ORS Oregon Revised Statutes

O&M Operation and Maintenance

Pb Lead

PCD Pollution Control Device

PM Particulate Matter

PM10 Particulate Matter less than 10 microns

in size

PM2.5 Particulate Matter less than 2.5 microns

in size

PSEL Plant Site Emission Limit

SO2 Sulfur Dioxide

ST Source Test

VE Visible Emissions

VOC Volatile Organic Compounds

WFD-O Wood Fiber Division-Oregon

Other Definitions:

As used in this permit, “Modified EPA Method 9” is the same as EPA Method 9, except the data is not reduced to

6-minute averages. Instead, each observation represents 15 seconds for the purpose of determining the amount of

aggregate time in a 60-minute period that the visible emissions are equal to or greater than the opacity limit. Unless

otherwise specified in this permit, the test duration must be 6 minutes with readings every 15 seconds. If any one

reading during the 6 minute observation period is greater than the opacity standard, the observer must perform a full

60-minute test. The observation period can be less than 60 minutes if the observer documents a violation of the

standard before the 60-minute observation period is completed.



Page 4 of 67

PERMITTED ACTIVITIES

1. Until such time 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. [OAR 340-218-

0010 and 340-218-0120(2)]

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 specified below:

2.a. Conditions 4, 5, 68, G5 and G9 (OAR 340-248-0005 through 340-248-0180) are only enforceable

by the state; and [OAR 340-218-0060]

2.b. Attachment 1 of this permit provides a cross-reference for SIP rules that have been renumbered in

the current Oregon Administrative Rules. [OAR 340-218-0060 and 340-218-0070]

EMISSIONS UNIT (EU) AND POLLUTION CONTROL DEVICE (PCD) IDENTIFICATION

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

Emissions Unit

Description EU ID Device Description Facility

Pollution Control Devices

Description PCD ID

Facility Wide VOC FW VOC material usage for the millwork,

hardboard, paint booths, JELD-WEN Engineering, and Marketing Support

All None NA

Chrome Plating CP Hard chrome electroplating ENG Mist Eliminator (composite

mesh pad) ME1

Baghouses 1

BH1 Shaker Baghouse (Cyclones E, Q and Q’; Silos R, S2, and T)

WFD-O Shaker Baghouse F08

BH1 Fiber main baghouse WFD-O Fiber Main Baghouse F07

BH1 Line 1 former baghouse WFD-O Line 1 Former Baghouse F09

BH1 Line 2 former baghouse WFD-O Line 2 Former Baghouse F09

BH1 Fiber south baghouse WFD-O Fiber South Baghouse F06

Fiber Dryers/Press Vents/Biofilter

FD/PV Particle dryer line 1, particle dryer line 2, press vent line 1, press vent line 2

WFD-O

3 Baghouses for fiber dryers and 2 baghouses for

press vents that all vent to a

Biofilter

FDBH-1, 2 & 3,

PVBH-1 & 2,

Biofilter

Cyclones, Fiber CF Cyclone Z WFD-O None NA

CF Target box: furnish silo S WFD-O None NA

Material Handling, Fiber

MHF Truck bin: door residuals WFD-O None NA

MHF Receiving furnish WFD-O None NA

Paint Drying Ovens O Three ovens WFD-O None NA

Veneer Drying V Veneer dryer MM-KF None NA

Dehumidification

Kilns DHK Dehumidification Kilns MM-KF None NA



Page 5 of 67

Emissions Unit

Description EU ID Device Description Facility

Pollution Control Devices

Description PCD ID

Boiler G BLRG Wood/bark fired boiler MM-T Multiclone, ESP B7847

Natural Gas

Combustion Devices NGCD Natural gas combustion devices MM-T Low NOx burner, FGR NA

Cyclones, Thomas

CT1 Cyclone A MM-T None NA

CT2 Target box G: truck bin MM-T None NA

CT2 Target box L: chip truck bin MM-T None NA

CT2 Cyclone B MM-T None NA

CT2 Cyclone C MM-T None NA

CT2 Cyclone D MM-T None NA

CT2 Target box: fuel silo H MM-T None NA

CT2 Target box: fuel silo I MM-T None NA

Kilns K Kilns 1-6, 7, 8 MM-T None NA

Material Handling, Thomas

MHT Truck storage bin: chips MM-T None NA

MHT Truck storage bin: fiber MM-T None NA

MHT Storage bin: green hogged fuel MM-T None NA

MHT Truck storage bin: shavings MM-T None NA

Sawing & Debarking S&D Saws and Debarkers MM-T None NA

Storage Piles SP Storage piles MM-T None NA

Unpaved Roads UPR Unpaved roads MM-T None NA

Aggregate Insignificant

AI Die cleaning WFD-O Baghouse

AI Die heater process WFD-O None

AI MDI storage tank WFD-O None

AI Door assembly line WFD-O None

AI Doorskin sanding operation WFD-O Baghouse

AI Cyclone C MM-KF Baghouse C-C 632

AI Cyclone D MM-KF Baghouse D-D 633

AI Cyclone F MM-KF Baghouse WK 931

AI Pneumatic conveyor: milling operations

MM-KF Baghouse K 911

AI Pneumatic conveyor: milling operations

MM-KF Baghouse WK 931

AI Mechanical conveyors MM-T None NA

AI Mechanical conveyors MM-T None NA

AI Paint Booth Heater JW-MS None NA

3.a. The permittee must not operate the rotary dryer (RD) that was included in the previous permit.

3.b. If the permittee plans to resume operation of the rotary dryer (RD), the permittee must submit an

application to modify the permit to incorporate all requirements that would apply to the rotary

dryer and obtain the permit modification before resuming operation. [OAR 340-218-0190]



Page 6 of 67

EMISSION LIMITS AND STANDARDS

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.

Table 1. Facility Wide Emission Limits and Standards

Applicable

Requirement

Condition

Number

Pollutant/

Parameter Limit/ Standard

Monitoring Requirements

Method Condition #

340-208-0300 4 Nuisance

Conditions No Nuisance Recordkeeping 68

340-208-0450 5 PM Fallout Prohibited Recordkeeping 68

340-208-0020(2) 6 Fugitive

Emissions Minimize emissions and implement control plan

VE periodic monitoring and I&M recordkeeping

69 and 70

340-222-0080 7 Fuels Natural gas, propane,

resinated and non-resinated

wood waste

Recordkeeping 80

340-234-0530(1)(a) 8 Fugitive

Emissions

Enclosure or alternative

control

VE periodic monitoring and

I&M recordkeeping 69 and 70

340-234-0530(1)(b) 9 Fugitive

Emissions Temporary storage approval Recordkeeping 69 and 70

340-206-0050 10 SERP Source emissions reduction

plan Recordkeeping 71

40 CFR Part 68 11 Risk

Management Risk management plan Recordkeeping 11

4. The permittee must not cause or allow air contaminants to cause a nuisance. [OAR 340-208-0300(1)] This

condition is only enforceable by the state.

4.a. Nuisance conditions will be verified by DEQ personnel in accordance with OAR 340-208-0310.

4.b. The creation of nuisance conditions may, in addition to any other action the DEQ may take, result

in a Best Work Practices Agreement in accordance with OAR 340-208-0320.

4.c. Nuisance complaints must be monitored in accordance with Condition 68.

5. The permittee must not cause or permit the emission of any particulate matter larger than 250 microns in

size at sufficient duration or quantity as to create an observable deposition upon the real property of another

person. [OAR 340-208-0450] This condition is only enforceable by the state.

6. The permittee must not allow any materials to be handled, transported or stored; or a building, its

appurtenances; or a road to be used, constructed, altered, repaired or demolished; or any equipment to be

operated, without taking reasonable precautions to prevent particulate matter from becoming airborne in

accordance with OAR 340-208-0210(2). The permittee must develop, implement and maintain a fugitive

emission control plan that includes the following minimum inspection and maintenance activities: [OAR

340-208-0210(1)]

6.a. At least once each day, the permittee must inspect areas of potential fugitive particulate emissions

and clean up any accumulation of particulate matter.

6.b. At least once each week, the permittee must inspect all roof areas and clean, if necessary, unless

weather conditions (such as high winds, ice, snow or rain) prohibit safe access to the roof. The

permittee must log weather conditions if weather prohibits access to roof areas and inspect roof

areas as soon as weather conditions permit safe access.

6.c. In the event of a spill or upset where fugitive particulate matter has accumulated, the permittee

must immediately, or as soon as possible, clean up the area and prevent the material from

becoming airborne.



Page 7 of 67

6.d. In the event of a baghouse fire suppression system abort, the permittee must immediately, or as

soon as safely possible, clean up the area to prevent the material from becoming airborne. Fire

suppression system aborts must be documented in accordance with Condition 70, but the permittee

is not required to notify DEQ of the baghouse abort unless it causes an excess emissions. Fire

suppression system aborts are not necessarily a violation of the opacity and particulate matter

emissions standards.

7. The permittee may only burn natural gas or propane in the natural gas combustion devices (NGCD) and

resinated or non-resinated wood (bark and wood and fiber) in boiler G. [OAR 340-222-0080]

8. The permittee must maintain enclosures around all truck dump and storage areas holding, or intended to

hold, raw materials to prevent windblown particle emissions from these areas from being deposited upon

property not under the ownership of the permittee in accordance with OAR 340-234-0530(1)(a).

9. The temporary storage of raw materials outside the regularly used areas of the plant site is prohibited unless

the permittee first notifies DEQ and receives written approval in accordance with OAR 340-234-

0530(1)(b).

10. In the event DEQ declares an Air Pollution Alert, Warning, or Emergency Episode in the Klamath Falls

area, the permittee must take the actions listed in JELD-WEN’s Source Emission Reduction Plan (SERP)

on file with DEQ. The SERP must be available on the source premises for inspection by DEQ personnel.

The SERP must be reviewed at least annually and may be changed upon written approval by DEQ.

Revision does not constitute a reopening of this permit. [340-206-0050]

11. Should this stationary source become subject to the accidental release prevention regulations in 40 CFR

Part 68, then the permittee must submit a risk management plan (RMP) by the date specified in 40 CFR

68.10 and comply with the plan and all other applicable Part 68 requirements. [40 CFR Part 68]

Table 2. Emissions Unit Specific Emission Limits and Standards for the JELD-WEN Engineering Operations:

EU ID Applicable Requirement Condition

Number

Pollutant/

Parameter Limit/Standard


Method Condition #

Hard Chrome Electroplating

(CP)

40 CFR 63.340(b), 63.342(b)(1), and 63.342(g)

12 - 15 General

Requirements See Specific Conditions

Recordkeeping 72, 73 and 88

40 CFR §63.342(c)(1)(i) 16 Total

Chromium 6.6 x 10-6 gr/dscf CPMS 72 and 73

40 CFR §63.342(f) 17 Work

Practices Operation and

Maintenance Plan Recordkeeping 88

Painting of Metal Parts

40 CFR Part 63, subpart MMMM

18 to 26 Organic HAP See Condition 19 Recordkeeping 89 and 90

Table 3. Emissions Unit Specific Emission Limits and Standards for the JELD-WEN-Marketing Services operations:


Number

Pollutant/



Method Condition #

Painting of

Wood Products

40 CFR Part 63, Subpart QQQQ




Page 8 of 67

Table 4. Emissions Unit Specific Emission Limits and Standards for the Wood Fiber Division-Oregon Operations:


Number

Pollutant/



Method Condition #

Baghouses (BH1)

340-208-0110(2) and 340-208-0110(3)(a)

46 Visible

Emissions 20% Opacity, 3 min. in

60 minutes VE Periodic Monitoring

75 and 76

340-226-0210(1)(b) 53 PM 0.1 gr/dscf I & M

Recordkeeping 75 and 76

FD/PV/ Baghouses/

Biofilter

340-208-0110(2) and 340-208-0110(3)(a)

46 Visible



75

340-226-0210(1)(b) 53 PM 0.1 gr/dscf I & M

Recordkeeping 75 and 76

Cyclones

(CF)

340-208-0110(2) and 340-

208-0110(3)(a) 46

Visible

Emissions

20% Opacity, 3 min. in

60 minutes

VE Periodic

Monitoring 74

340-226-0210(1)(b) 53 PM 0.1 gr/dscf VE Periodic

Monitoring 74

Material

Handling (MHF)

340-208-0110(2) and 340-208-0110(3)(a)

47 Visible



69

Baghouses, Cyclones,

Ovens, Press vents (FD,

BH1, CF, O,

PV)

340-234-0530(2)(b)(B) 54 PM 28.4 lb/hr

Recordkeeping

and ST Periodic

Testing

74 and 75

Surface

Coating of Wood

Products



Plywood and

Composite Wood

Products

NESHAP

40 CFR Part 63, Subpart

DDDD 36 HAP 90% Reduction

Continuous Parameter

Monitoring

38.a

Table 5. Emissions Unit Specific Emission Limits and Standards for the Millwork Manufacturing-Klamath Falls Operations:

EU ID Applicable

Requirement

Condition

Number

Pollutant/



Method Condition #

Veneer Drying

340-234-0510(1)(b) 56 Visible

Emissions

10% Average (see below); 20% Maximum

as a 6 min. avg.

VE Periodic Monitoring

74

340-226-0210(1)(b) 57 PM 0.1 gr/dscf VE Periodic Monitoring

74

340-234-0510(1)(e) 58 Highest and

Best Minimize Emissions

VE Periodic Monitoring

74

340-234-0510(1)(f) 59 Concealing Emissions

Not Allowed VE Periodic Monitoring

74

Paint Drying Ovens

(O)

340-208-0110(2) and 340-208-0110(3)(a)

46 Visible



74

340-226-0210(1)(b) 50 PM 0.1 gr/dscf VE Periodic

Monitoring 74


27 to 35 Organic

HAP See Condition 28 Recordkeeping 89 and 90



Page 9 of 67

Table 6. Emission Unit Specific Emission Limits and Standards for the Millwork Manufacturing-Thomas Operations:

EU ID Applicable

Requirement

Condition

Number

Pollutant/



Method Condition #

BLRG

340-208-0110(2) and

340-208-0110(3)(a) 46

Visible

Emissions


60 minutes COMS 77

1989 ACDP Condition 3 and 340-

228-0210(1)(b)

49 PM 0.07 gr/dscf @ 12% CO2 COMS 77, 78 and 79

40 CFR Part 63, Subpart JJJJJJ

39 - 45 HAPs Tune ups and Energy

Assessment Recordkeeping 41 and 43

NGCD

340-208-0110(2) and 340-208-0110(3)(a)

46 Visible


60 minutes Fuel

Recordkeeping 80

340-228-0210(1)(b) 48 PM 0.1 gr/dscf @ 12% CO2 Fuel

Recordkeeping 80

CT1 and CT2

(cyclones)

340-208-0110(2) and

340-208-0110(3)(a) 46

Visible

Emissions


60 minutes

VE Periodic

Monitoring 74

340-226-0310 55 PM Table 1 of OAR 340-

226-0320 VE Periodic Monitoring

74

CT1 (cyclones) 340-226-0210(1)(a) 52 PM 0.2 gr/dscf VE Periodic Monitoring

74

CT2 (cyclones) 340-226-0210(1)(b) 53 PM 0.1 gr/dscf VE Periodic

Monitoring 74

K (kilns) 340-208-0110(2) and

340-208-0110(3)(a) 46

Visible

Emissions


60 minutes

VE Periodic

Monitoring 74

MHT, S&D, SP,

and UPR

340-208-0110(2) and

340-208-0110(3)(a) 47

Visible

Emissions


60 minutes

VE Periodic

Monitoring 69

Hard Chromium Electroplating NESHAP (Subpart N):

12. This facility is subject to 40 CFR Part 63, Subpart N (Hard Chromium Electroplating NESHAP). The

specific requirements from the regulations are included in this permit in the appropriate sections or listed in

the non-applicable section of this permit. Unless otherwise stated in this permit or the applicable

requirements, the general provisions from Subpart A of Part 63 are applicable and incorporated by

reference as shown in Attachment 2. [40 CFR §63.340(b)]

13. The standards in Condition 16 may not be met by using a reducing agent to change the form of chromium

from hexavalent to trivalent. [40 CFR §63.342(g)]

14. At all times, each owner or operator must operate and maintain any affected source subject to the

requirements of 40 CFR Part 63, Subpart N, including associated air pollution control equipment and

monitoring equipment, in a manner consistent with safety and good air pollution control practices for

minimizing emissions. The general duty to minimize emissions does not require the owner or operator to

make any further efforts to reduce emissions if levels required by this standard have been achieved.

Determination of whether such operation and maintenance procedures are being used will be based on

information available to the Administrator which may include, but is not limited to, monitoring results,

review of operation and maintenance procedures, review of operation and maintenance records, and

inspection of the source. [40 CFR 63.342(a)(1)]

15. The emission limitations in Condition 16 apply during tank operation as defined in 40 CFR 63.41, and

during periods of startup and shutdown as these are routine occurrences for affected sources subject to 40

CFR Part 63, Subpart N. In response to an action to enforce the standards set forth in this subpart, the

owner or operator may assert a defense to a claim for civil penalties for violations of such standards that are

caused by a malfunction, as defined in 40 CFR 63.2. Appropriate penalties may be assessed, however, if

the owner or operator fails to meet the burden of proving all the requirements in the affirmative defense.

The affirmative defense shall not be available for claims for injunctive relief. [40 CFR §63.342(b)(1)]



Page 10 of 67

15.a. To establish the affirmative defense in any action to enforce such a standard, the owner or operator

must timely meet the reporting requirements of Condition 15.b, and must prove by a

preponderance of evidence that:

15.a.i. The violation was caused by a sudden, infrequent and unavoidable failure of air

pollution control equipment, process equipment, or a process to operate in a normal

and usual manner; and could not have been prevented through careful planning,

proper design or better operation and maintenance practices; and did not stem from

any activity or event that could have been foreseen and avoided, or planned for; and

was not part of a recurring pattern indicative of inadequate design, operation or

maintenance; and

15.a.ii. Repairs were made as expeditiously as possible when exceeded violation occurred.

Off-shift and overtime labor were used, to the extent practicable to make these

repairs; and

15.a.iii. The frequency, amount and duration of the violation (including any bypass) were

minimized to the maximum extent practicable; and

15.a.iv. If the violation resulted from a bypass of control equipment or a process, then the

bypass was unavoidable to prevent loss of life, personal injury, or severe property

damage; and

15.a.v. All possible steps were taken to minimize the impact of the violation on ambient air

quality, the environment, and human health; and

15.a.vi. All emissions monitoring and control systems were kept in operation if at all possible,

consistent with safety and good air pollution control practices; and

15.a.vii. All of the actions in response to the violation were documented by properly signed,

contemporaneous operating logs; and

15.a.viii. At all times, the affected sources were operated in a manner consistent with good

practices for minimizing emissions; and

15.a.ix. A written root cause analysis was prepared, the purpose of which is to determine,

correct and eliminate the primary causes of the malfunction and the excess emissions

resulting from the malfunction event at issue. The analysis shall also specify, using

the best monitoring methods and engineering judgment, the amount of excess

emissions that were the result of the malfunction.

15.b. Report. The owner or operator seeking to assert an affirmative defense shall submit a written

report to the Administrator with all necessary supporting documentation, that it has met the

requirements set forth in Condition 15.a. This affirmative defense report shall be included in the

first periodic compliance, deviation report or excess emission report otherwise required after the

initial occurrence of the violation of the relevant standard (which may be the end of any applicable

averaging period). If such compliance, deviation report or excess emission report is due less than

45 days after the initial occurrence of the violation, the affirmation defense report may be included

in the second compliance, deviation report or excess emission report due after the initial

occurrence of the violation of the relevant standard.

16. Standard. During tank operation, the permittee must control chromium emissions discharged to the

atmosphere from emissions unit CP by not allowing the concentration of total chromium in the exhaust gas

stream discharged to the atmosphere to exceed 0.015 milligrams of total chromium per dry standard cubic

meter (mg/dscm) of ventilation air (6.6 x 10-6

grains per dry standard cubic foot [gr/dscf]). [40 CFR

§63.342(c)(1)(ii)] (also see Condition 72.b)

17. Work practice standards. The work practice standards of this condition address operation and maintenance

practices. [40 CFR §63.342(f)]



Page 11 of 67

17.a. Startup, shutdown and malfunctions.

17.a.i. At all times, including periods of startup, shutdown and malfunction, the permittee

must operate and maintain emissions unit CP, including associated air pollution

control devices and monitoring equipment, in a manner consistent with good air

pollution control practices, consistent with the operation and maintenance plan

required by Condition 17.c.

17.a.ii. Malfunctions must be corrected as soon as practicable after their occurrence in

accordance with the operation and maintenance plan required by Condition 17.c.

17.a.iii. Operation and maintenance requirements established pursuant to Section 112 of the

FCAA are enforceable independent of emissions limitations or other requirements in

relevant standards.

17.b. Operation and maintenance procedures.

17.b.i. Determination of whether acceptable operation and maintenance procedures are being

used will be based on information available to the Administrator, which may include,

but is not limited to, monitoring results; review of the operation and maintenance

plan, procedures, and records; and inspection of the source.

17.b.ii. Based on the results of a determination made under Condition 17.b.i, the

Administrator may require that the permittee make changes to the operation and

maintenance plan required by Condition 17.c. Revisions may be required if the

Administrator finds that the plan:

17.b.ii.A. Does not address a malfunction that has occurred;

17.b.ii.B. Fails to provide for the operation of the affected source, the air

pollution control techniques, or the control system and process

monitoring equipment during a malfunction in a manner consistent

with good air pollution control practices; or

17.b.ii.C. Does not provide adequate procedures for correcting

malfunctioning process equipment, air pollution control techniques,

or monitoring equipment as quickly as practicable.

17.c. Operation and maintenance plan. The permittee must maintain an operation and maintenance

plan. The plan is incorporated by reference into this permit. The plan must include the following

elements:

17.c.i. The plan must specify the operation and maintenance criteria for the affected source,

the add-on air pollution control device, and the process and control system monitoring

equipment, and must include a standardized checklist to document the operation and

maintenance of this equipment;

17.c.ii. The plan must incorporate the following work practice standards for the composite

mesh pad system (pollution control device ME1):

Work Practice Standards Frequency

Visually inspect device to ensure there is proper drainage, no chromic acid buildup on the pads,

and no evidence of chemical attack on the structural integrity of the device. 1/Quarter

Visually inspect back portion of the mesh pad closest to the fan to ensure there is no breakthrough

of chromic acid mist. 1/Quarter

Visually inspect ductwork from tank or tanks to the control device to ensure there are no leaks. 1/Quarter

Perform washdown of the composite mesh-pads in accordance with manufacturers

recommendations. Per Manufacturer

17.c.iii. The plan must specify procedures to be followed to ensure that equipment or process

malfunctions due to poor maintenance or other preventable conditions do not occur;

and



Page 12 of 67

17.c.iv. The plan must include a systematic procedure for identifying malfunctions of process

equipment, add-on air pollution control devices, and process and control system

monitoring equipment and for implementing corrective actions to address such

malfunctions.

17.c.v. The plan shall include housekeeping procedures, as specified in the following table.

[40 CFR 63.342(f)(3)(i)(F)] The owner or operator shall implement the housekeeping

procedures after March 19, 2013. [40 CFR 63.343(a)(8)]

For You Must: At this Minimum Frequency

1. Any substance used in an

affected chromium

electroplating or chromium

anodizing tank that contains

hexavalent chromium.

(a) Store the substance in a closed container

in an enclosed storage area or building;

AND

At all times, except when

transferring the substance to and

from the container.

(b) Use a closed container when

transporting the substance from the

enclosed storage area.

Whenever transporting

substance, except when

transferring the substance to and

from the container.

2. Each affected tank, to

minimize spills of bath solution

that result from dragout. Note:

this measure does not require the

return of contaminated bath

solution to the tank. This

requirement applies only as the

parts are removed from the tank.

Once away from the tank area,

any spilled solution must be

handled in accordance with Item

4 of these housekeeping

measures.

(a) Install drip trays that collect and return

to the tank any bath solution that drips or

drains from parts as the parts are removed

from the tank; OR

Prior to operating the tank.

(b) Contain and return to the tank any bath

solution that drains or drips from parts as

the parts are removed from the tank; OR

Whenever removing parts from

an affected tank.

(c) Collect and treat in an onsite wastewater

treatment plant any bath solution that drains

or drips from parts as the parts are removed

from the tank.

Whenever removing parts from

an affected tank.

3. Each spraying operation for

removing excess chromic acid

from parts removed from, and

occurring over, an affected tank.

Install a splash guard to minimize

overspray during spraying operations and to

ensure that any hexavalent chromium laden

liquid captured by the splash guard is

returned to the affected chromium

electroplating or anodizing tank.

Prior to any such spraying

operation.

4. Each operation that involves

the handling or use of any

substance used in an affected

chromium electroplating or

chromium anodizing tank that

contains hexavalent chromium.

Begin clean up, or otherwise contain all

spills of the substance. Note: substances

that fall or flow into drip trays, pans,

sumps, or other containment areas are not

considered spills.

Within 1 hour of the spill.

5. Surfaces within the enclosed

storage area, open floor area,

walkways around affected tanks

contaminated with hexavalent

chromium from an affected


chromium anodizing tank.

(a) Clean the surfaces using one or more of

the following methods: HEPA vacuuming;

Hand-wiping with a damp cloth; Wet

mopping; Hose down or rinse with potable

water that is collected in a wastewater

collection system; Other cleaning method

approved by the permitting authority; OR

At least once every 7 days if one

or more chromium electroplating

or chromium anodizing tanks

were used, or at least after every

40 hours of operating time of

one or more affected chromium

electroplating or chromium

anodizing tank, whichever is

later.

(b) Apply a non-toxic chemical dust

suppressant to the surfaces.

According to manufacturer’s

recommendations.



Page 13 of 67

For You Must: At this Minimum Frequency

6. All buffing, grinding, or

polishing operations that are

located in the same room as


chromium anodizing operations.

Separate the operation from any affected

electroplating or anodizing operation by

installing a physical barrier; the barrier may

take the form of plastic strip curtains.

Prior to beginning the buffing,

grinding, or polishing operation.

7. All chromium or chromium-

containing wastes generated

from housekeeping activities.

Store, dispose, recover, or recycle the

wastes using practices that do not lead to

fugitive dust and in accordance with

hazardous waste requirements.

At all times.

17.d. If the operation and maintenance plan fails to address or inadequately addresses an event that

meets the characteristics of a malfunction at the time the plan is initially developed, the permittee

must revise the operation and maintenance plan within 45 days after such an event occurs. The

revised plan must include procedures for operating and maintaining the process equipment, add-on

air pollution control device, or monitoring equipment during similar malfunction events, and a

program for corrective action for such events.

17.e. Recordkeeping associated with the operation and maintenance plan is identified in Condition 88.a.

Reporting associated with the operation and maintenance plan is identified in Condition 104.c.

17.f. If actions taken by the permittee during periods of malfunction are inconsistent with the

procedures specified in the operation and maintenance plan required by Condition 17.c, 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. A letter must follow this

report within 7 working days after the end of the event, unless the permittee makes alternative

reporting arrangements, in advance, with the Administrator.

17.g. The permittee must keep the written operation and maintenance plan on record after it is

developed to be made available for inspection, upon request, by the Administrator for the life of

the affected source or until the source is no longer subject to the provisions of 40 CFR Part 63,

Subpart N. In addition, if the operation and maintenance plan is revised, the permittee must keep

previous (i.e., superseded) versions of the operation and maintenance plan on record to be made

available for inspection, upon request, by the Administrator for a period of 5 years after each

revision to the plan.

17.h. To satisfy the requirements of Condition 17.c, the permittee may use applicable standard operating

procedure (SOP) manuals, Occupational Safety and Health Administration (OSHA) plans, or other

existing plans, provided the alternative plans meet the requirements of this section.

Surface Coating of Miscellaneous Metal Parts and Products NESHAP (Subpart MMMM):

18. The affected source is the collection of all of the items listed in 18.a through 18.d that are used for surface

coating of miscellaneous metal parts and products within each subcategory. [40 CFR 63.3882(b)

18.a. All coating operations as defined in 40 CFR 63.3981;

18.b. All storage containers and mixing vessels in which coatings, thinners and/or other additives, and

cleaning materials are stored or mixed;

18.c. All manual and automated equipment and containers used for conveying coatings, thinners and/or

other additives, and cleaning materials; and

18.d. All storage containers and all manual and automated equipment and containers used for conveying

waste materials generated by a coating operation.

19. The permittee must limit organic HAP emissions to the atmosphere from the affected source to the

applicable limit specified in the following table during each 12-month compliance period: [40 CFR

63.3890(b)]



Page 14 of 67

Coating Operation Organic HAP Limit

(lb/gal coating solids) 40 CFR Citation

General Use Coating 2.6 63.3890(b)(1)

High Performance Coating 27.5 63.3890(b)(2)

Magnet Wire Coating 1.0 63.3890(b)(3)

Rubber-to-Metal Coating 37.7 63.3890(b)(4)

Extreme Performance Fluoropolymer Coating 12.4 63.3890(b)(5)

20. The permittee must include all coatings (as defined in 40 CFR 63.3981), thinners, and/or other additives,

and cleaning materials used in the affected source when determining whether the organic HAP emission

rate is equal to or less than the applicable limit in Condition 19. To make this determination, the permittee

must demonstrate that the organic HAP content of each coating used in the coating operation(s) is less than

or equal to the applicable emission limit in Condition 19, and that each thinner and/or other additives, and

cleaning materials used contain no organic HAP. [40 CFR 63.3891(a)]

21. The permittee must be in compliance with the emission limitations in Condition 19 at all times. [40 CFR

63.3900(a)(1)]

22. The permittee must always operate and maintain the affected source, including all air pollution control and

monitoring equipment used for purposes of complying with the limits in Condition 19 according to the

provisions in 40 CFR 63.6(e)(1)(i).

23. Attachment 2 shows which parts of the NESHAP General Provisions (40 CFR Part 63, Subpart A) apply to

surface coating of miscellaneous metal parts and products. [40 CFR 63.3901]

24. The permittee must submit the notifications in 63.7(b) and (c), 63.8(f)(4), and 63.9(b) through (e) and (h)

that apply to the affected source by the dates specified in those sections. [40 CFR 63.3910(a)]

25. The permittee must use the compliant material option for each individual coating operation. The permittee

must conduct a separate initial compliance demonstration for each general use, high performance, magnet

wire, rubber-to-metal, and extreme performance fluoropolymer coating operation. The permittee must

meet all of the requirements in this condition. The permittee must use the procedures in this condition on

each coating, thinner and/or other additive, and cleaning material in the condition it is in when it is received

from its manufacturer or supplier and prior to any alteration. The permittee does not need to re-determine

the organic HAP content of coatings, thinners and/or other additives, and cleaning materials that are

reclaimed on-site (or reclaimed off-site if the permittee has documentation showing that the permittee

received back the exact same material that were sent off-site) and reused in the coating operation for which

the permittee uses the compliant material option, provided these materials in their condition as received

were demonstrated to comply with the compliance material option. [paraphrased from 40 CFR 63.3941

because the permittee will only use the compliant material option for complying with the NESHAP]

25.a. The permittee must determine the mass fraction of organic HAP for each coating, thinner and/or

other additives, and cleaning material used during the compliance period by using one of the

following options: [40 CFR 63.3941(a)]

25.a.i. The permittee may use Method 311 for determining the mass fraction of organic

HAP. Use the following procedures when performing a Method 311 test:

25.a.i.A. Count each organic HAP that is measured to be present at 0.1

percent by mass or more for Occupational Safety and Health

Administration (OSHA) defined carcinogens as specified in 20 CFR

1910.1200(d)(4) and at 1.0 percent by mass or more for other

compounds. For example, if toluene (not an OSHA carcinogen) is



Page 15 of 67

measured to be 0.5 percent of the material by mass, the permittee

does not have to count it. Express the mass fraction of each organic

HAP you count as a value truncated to four places after the decimal

(e.g., 0.3791)

25.a.i.B. Calculate the total mass fraction of organic HAP in the test material

by adding up the individual organic HAP mass fractions and

truncating the result to three places after the decimal (e.g., 0.763).

25.a.ii. For coatings, the permittee may use Method 24 to determine the mass fraction of

nonaqueous volatile matter and use that value as a substitute for mass fraction of

organic HAP. For reactive adhesives in which some of the HAP react to form solids

and are not emitted to the atmosphere, the permittee may use the alternative method

contained in Appendix A to Subpart PPPP for 40 CFR Part 63, rather than Method 24.

The permittee may use the volatile fraction that is emitted, as measured by the

alternative method in Appendix A to Subpart PPPP of 40 CFR Part 63, as a substitute

for the mass fraction of organic HAP.

25.a.iii. The permittee may use an alternative test method for determining the mass fraction of

organic HAP once EPA has approved it. The permittee must follow the procedure in

40 CFR 63.7(f) to submit an alternative test method for approval.

25.a.iv. The permittee may rely on information other than that generated by the test methods

specified in Conditions 25.a.i through 25.a.iii, such as manufacturer’s formulation

data. If it represents each organic HAP that is present at 0.1 percent by mass or more

for OSHA defined carcinogens as specified in 29 CFR 1910.1200(d)(4) and at 1.0

percent by mass or more other compounds. For example, if toluene (not an OSHA

defined carcinogen) is 0.5 percent of the material by mass, the permittee does not

have to count it. For reactive adhesives in which some of the HAP react to form

solids and are not emitted to the atmosphere, the permittee may rely on

manufacturer’s data that expressly states the organic HAP or volatile matter mass

fraction emitted. If there is disagreement between such information and results of a

test conducted according to Conditions 25.a.i through 25.a.iii, then the test method

results will take precedence unless, after consultation, the permittee demonstrates to

the satisfaction of the enforcement agency that the formulation data are correct.

25.a.v. Solvent blends may be listed as single components for some materials in data

provided by manufacturers or suppliers. Solvent blends may contain organic HAP

which must be counted toward the total organic HAP mass fraction of the materials.

When test data and manufacturer’s data for solvent blends are not available, the

permittee may use the default values for the mass fraction of organic HAP in these

solvent blends listed in the following tables (A and B). If the permittee uses the

tables, the permittee must use the values in Table A for all solvent blends that match

Table A, and the permittee may use Table B only if the solvent blends in the materials

the permittee uses do not match any of the solvent blends in Table A and the

permittee knows only whether the blend is aliphatic or aromatic. However, if the

results of a Method 311 (Appendix A to 40 CFR Part 63) test indicate higher values

than those listed in Tables A or B, the Method 311 results will take precedence

unless, after consultation, the permittee demonstrates to the satisfaction of the

enforcement agency that the formulation data are correct.

25.b. The permittee must determine the volume fraction of coating solids (gallon of coating solids per

gallon of coating) for each coating used during the compliance period by a test, by information

provided by the supplier or the manufacturer of the material, or by calculation, as specified in

Conditions 25.b.i through 25.b.iv. If test results obtained according to Condition 25.b.i do not

agree with the information obtained under Conditions 25.b.ii through 25.b.iv, the test results will

take precedence unless, the permittee demonstrates to the satisfaction of the enforcement agency

that the formulation data are correct. [40 CFR 63.3941(b)]



Page 16 of 67

25.b.i. The permittee may use ASTM Method D2697-86 (re-approved 1998), “Standard Test

Method for Volume Nonvolatile Matter in Clear or Pigmented Coatings”

(incorporated by reference, see 40 CFR 63.14) or ASTM Method D6093-97 (re-

approved 2003), “Standard Test Method for Percent Volume Nonvolatile Matter in

Clear or Pigmented Coatings Using a Helium Gas Pycnometer” (incorporated by

reference, see 40 CFR 63.14), to determine the volume fraction of coating solids for

each coating. Divide the nonvolatile volume percent obtained with the methods by

100 to calculate volume fraction of coating solids.

25.b.ii. The permittee may use an alternative test method for determining the solids content of

each coating once EPA has approved it. The permittee must follow the procedure in


25.b.iii. The permittee may obtain volume fraction of coating solids for each coating from the

supplier or manufacturer.

25.b.iv. The permittee may determine the volume fraction of coating solids using the

following equation:

Where:

Vs = Volume fraction of coating solids, gallon coating solids per gallon

coating

mvolatiles = Total volatile matter content of the coating, including HAP, volatile

organic compounds (VOC), water, and exempt compounds, determined

according to Method 24 in Appendix A of 40 CFR Part 60, grams

volatile matter per liter coating.

Davg = Average density of volatile matter in the coating, grams volatile matter

per liter volatile matter, determined from test results using ASTM

Method D1475-98, “Standard Test Method for Density of Liquid

Coatings, Inks, and Related Products” (incorporated by reference, see

40 CFR 63.14), information from the supplier or manufacturer of the

material, or reference sources providing density or specific gravity data

for pure materials. If there is disagreement between ASTM Method

D1475-98 test results and other information sources, the test results

will take precedence unless, after consultation the permittee

demonstrates to the satisfaction of the enforcement agency that the

formulation data are correct.

25.c. Determine the density of each coating used during the compliance period from test results using

ASTM Method D1475-98, “Standard Test Method for Density of Liquid Coatings, Inks, and

Related Products” (incorporated by reference, see 40 CFR 63.14), information from the supplier or

manufacturer of the material, or specific gravity data for pure materials. If there is disagreement

between ASTM Method D1475-98 test results and the supplier’s or manufacturer’s information,

the test results will take precedence unless, after consultation the permittee demonstrates to the

satisfaction of the enforcement agency that the formulation data are correct. [40 CFR 63.3941(c)]

25.d. Calculate the organic HAP content, lb of organic HAP emitted per gallon coating solids used, of

each coating used during the compliance period using the following equation: [40 CFR

63.3941(d)]

avg

volatiless

D

mV 1

s

ccc

V

WDH

))((



Page 17 of 67

Where:

Hc = Organic HAP content of the coating, lb organic HAP per gallon coating

solids used.

Dc = Density of coating, lb per gallon coating, determined according to

Condition 25.c.

Wc = Mass fraction of organic HAP in the coating, lb organic HAP per lb

coating, determined according to Condition 25.a.


coating, determined according to Condition 25.b.

25.e. The calculated organic HAP content for each coating used during the initial compliance period

must be less than or equal to the applicable emission limit in Condition 19; and each thinner

and/or other additive, and cleaning material used during the initial compliance period must contain

no organic HAP, determined according to Condition 25.a. The permittee must keep all records

required by Conditions 89 and 90. As part of the notification of compliance status, the permittee

must identify the coating operation(s) for which the permittee used the compliant material option

and submit a statement that the coating operation(s) was (were) in compliance with the emission

limitations during the initial compliance period because the permittee used no coatings for which

the organic HAP content exceeded the applicable emission limit in Condition 19, and the

permittee used no thinners and/or other additives, and cleaning materials that contained organic

HAP, determined according to the procedures in Condition 25.a. [40 CFR 63.3941(e)]

26. The permittee must demonstrate continuous compliance as follows: [40 CFR 63.3942]

26.a. For each compliance period to demonstrate continuous compliance, the permittee must use no

coating for which the organic HAP content (determined using the equation in Condition 25.d and

use no thinner and/or other additive, or cleaning material that contains organic HAP, determined

according to Condition 25.a. A compliance period consists of 12 months. Each month, after the

end of the initial compliance period, is the end of a compliance period consisting of that month

and the preceding 11 months.

26.b. If the permittee chooses to comply with the emission limitations by using the compliant material

option, the use of any coating, thinner and/or other additive, or cleaning material that does not

meet the criteria specified in 26.a is a deviation from the emission limitations that must be

reported as specified in Conditions 24 and 105.

26.c. As part of each semiannual compliance report required by Condition 105, the permittee must

identify the coating operation(s) for which the permittee used the compliance material option. If

there were no deviations from the applicable emission limit in Condition 19, submit a statement

that the coating operation(s) was (were) in compliance during the reporting period because you

used no coatings for which the organic HAP content exceeded the applicable emission limit in

Condition 19, and the permittee used no thinner and/or other additive, or cleaning material that

contained organic HAP, determined according to Condition 25.a.

26.d. The permittee must maintain records as specified in Conditions 89 and 90.

Surface Coating of Wood Building Products NESHAP (Subpart QQQQ):

27. The affected source is the collection of all of the items listed in 27.a through 27.d that are used for surface

coating of wood building products within each subcategory. [40 CFR 63.4682(b)

27.a. All coating operations as defined in 40 CFR 63.4781;

27.b. All storage containers and mixing vessels in which coatings, thinners and cleaning materials are

stored or mixed;

27.c. All manual and automated equipment and containers used for conveying coatings, thinners and

cleaning materials; and

27.d. All storage containers and all manual and automated equipment and containers used for conveying

waste materials generated by a coating operation.



Page 18 of 67

28. The permittee must limit organic HAP emissions to the atmosphere from the affected source to the

applicable limit specified in the following table during each 12-month compliance period: [40 CFR

63.4690(b)]

Coating Products Subcategory Organic HAP Limit (lb/gal solids) JELD-WEN Operation

1. Exterior siding and primed doorskins 0.6 WFD-O

2. Flooring 0.78

3. Interior wall paneling or tileboard 1.53

4. Other interior panels 0.17

5. Doors, windows and miscellaneous 1.93 MM-KF, MS

29. The permittee must include all coatings, thinners and cleaning materials used in the affected source when

determining whether the organic HAP emission rate is equal to or less than the applicable limit in

Condition 28. To make this determination, the permittee must demonstrate that the organic HAP content of

each coating used in the coating operation(s) is less than or equal to the applicable emission limit in

Condition 28, and that each thinner and cleaning materials used contain no organic HAP. [paraphrased

from 40 CFR 63.4691 and 63.4691(a) for compliant material option]

30. The permittee must be in compliance with the emission limitations in Condition 28 at all times. [40 CFR

63.4700(a)(1)]

31. The permittee must always operate and maintain the affected source, including all air pollution control and

monitoring equipment used for purposes of complying with the limits in Condition 28 according to the

provisions in 40 CFR 63.6(e)(1)(i). [40 CFR 63.4700(b)]

32. Attachment 2 shows which parts of the NESHAP General Provisions (40 CFR Part 63, Subpart A) apply to

surface coating of miscellaneous metal parts and products. [40 CFR 63.4701]

33. The permittee must submit the notifications in 63.7(b) and (c), 63.8(f)(4), and 63.9(b) through (e) and (h)

that apply to the affected source by the dates specified in those sections. [40 CFR 63.4710(a)]

34. The permittee must use the compliant material option for each individual coating operation. The permittee

must meet all of the requirements in this condition. To demonstrate initial compliance using the compliant

material option, the coating operation or group of coating operations must use no coating with an organic

HAP content that exceeds the applicable emission limit in Condition 28 and must use no thinner or cleaning

material that contains organic HAP as determined according this condition. Any coating operation for

which the permittee uses the compliance material option is not required to meet the operating limits or

work practice standards required in 40 CFR 63.4692 and 63.4693, respectively. To demonstrate initial

compliance with the emission limitations using the compliant material option, the permittee must meet all

the requirements of this condition for the coating operations using this option. Use the procedures in this

condition on each coating, thinner and cleaning material in the condition it is in when it is received from its

manufacturer or supplier and prior to any alteration. The permittee does not need to re-determine the

organic HAP content of coatings, thinners and cleaning materials that are reclaimed on-site and reused in

the coating operation(s) for which the permittee uses the compliant material option, provided these

materials in their condition as received were demonstrated to comply with the compliant material option. If

the mass fraction of organic HAP of a coating equals zero, determined according to Condition 34.a, and the

permittee uses the compliant material option, the permittee is not required to comply with Conditions 34.b

and 34.c for that coating. [paraphrased from 40 CFR 63.4741 because the permittee will only use the

compliance material option for complying with the NESHAP]



Page 19 of 67

34.a. The permittee must determine the mass fraction of organic HAP for each coating, thinner and

cleaning material used during the compliance period by using one of the following options: [40

CFR 63.4741(a)]

34.a.i. The permittee may use Method 311 for determining the mass fraction of organic

HAP. Use the following procedures when performing a Method 311 test. If these

values cannot be determined using Method 311, the permittee must submit an

alternative technique for determining the values for approval by the EPA.

34.a.i.A. Count each organic HAP that is measured to be present at 0.1

percent by mass or more for Occupational Safety and Health

Administration (OSHA) defined carcinogens as specified in 20 CFR

1910.1200(d)(4) and at 1.0 percent by mass or more for other

compounds. For example, if toluene (not an OSHA carcinogen) is

measured to be 0.5 percent of the material by mass, the permittee

does not have to count it. Express the mass fraction of each organic

HAP you count as a value truncated to four places after the decimal

(e.g., 0.379178412 truncates to 0.3791)

34.a.i.B. Calculate the total mass fraction of organic HAP in the test material

by adding up the individual organic HAP mass fractions and

truncating the result to three places after the decimal (e.g., 0.763).

34.a.ii. For coatings, the permittee may use Method 24 to determine the mass fraction of

nonaqueous volatile matter and use that value as a substitute for mass fraction of

organic HAP. [Note: Method 24 is not appropriate for those coatings with a water

content that would result in an effective detection limit greater than the applicable

emission limit.]

34.a.iii. The permittee may use an alternative test method for determining the mass fraction of

organic HAP once EPA has approved it. The permittee must follow the procedure in


34.a.iv. The permittee may rely on information other than that generated by the test methods

specified in Conditions 34.a.i through 34.b.ii, such as manufacturer’s formulation

data, if it represents each organic HAP that is present at 0.1 percent by mass or more

for OSHA defined carcinogens as specified in 29 CFR 1910.1200(d)(4) and at 1.0

percent by mass or more for other compounds. For example, if toluene (not an OSHA

defined carcinogen) is 0.5 percent of the material by mass, the permittee does not

have to count it. For reactive adhesives in which some of the HAP react to form

solids and are not emitted to the atmosphere, the permittee may rely on

manufacturer’s data that expressly states the organic HAP or volatile matter mass

fraction emitted. If there is disagreement between such information and results of a

test conducted according to Conditions 34.a.i through 34.b.ii, then the test method

results will take precedence unless, after consultation, the permittee demonstrates to

the satisfaction of the enforcement agency that the formulation data are correct.

34.a.v. Solvent blends may be listed as single components for some materials in data

provided by manufacturers or suppliers. Solvent blends may contain organic HAP

which must be counted toward the total organic HAP mass fraction of the materials.

When test data and manufacturer’s data for solvent blends are not available, the

permittee may use the default values for the mass fraction of organic HAP in these

solvent blends listed in the following tables (A and B). If the permittee uses the

tables, the permittee must use the values in Table A for all solvent blends that match

Table A, and the permittee may use Table B only if the solvent blends in the materials

the permittee uses do not match any of the solvent blends in Table A and the

permittee knows only whether the blend is aliphatic or aromatic. However, if the

results of a Method 311 (Appendix A to 40 CFR Part 63) test indicate higher values

than those listed in Tables A or B, the Method 311 results will take precedence

unless, after consultation, the permittee demonstrates to the satisfaction of the

enforcement agency that the formulation data are correct.



Page 20 of 67

34.b. The permittee must determine the volume fraction of coating solids (gallon of coating solids per

gallon of coating) for each coating used during the compliance period by a test, by one of the

methods specified in Condition 34.b.i through 34.b.ii. [40 CFR 63.4741(b)]

34.b.i. The permittee may use ASTM Method D2697-86 (re-approved 1998), “Standard Test

Method for Volume Nonvolatile Matter in Clear or Pigmented Coatings”

(incorporated by reference, see 40 CFR 63.14) or ASTM Method D6093-97,

“Standard Test Method for Percent Volume Nonvolatile Matter in Clear or Pigmented

Coatings Using a Helium Gas Pycnometer” (incorporated by reference, see 40 CFR

63.14), to determine the volume fraction of coating solids for each coating. Divide

the nonvolatile volume percent obtained with the methods by 100 to calculate volume

fraction of coating solids. If these values cannot be determined using these methods,

the permittee may submit an alternative technique for determining their values for

approval by EPA.

34.b.ii. The permittee may obtain volume fraction of coating solids for each coating from the

supplier or manufacturer.

34.b.iii. If the volume fraction of coating solids cannot be determined using the options in

Conditions 34.b.i or 34.b.ii, the permittee must determine it using the following

equation:

Where:


coating.

mvolatiles = Total volatile matter content of the coating, including HAP, volatile

organic compounds (VOC), water, and exempt compounds, determined

according to Method 24 in Appendix A of 40 CFR Part 60, grams

volatile matter per liter coating.

Davg = Average density of volatile matter in the coating, grams volatile matter

per liter volatile matter, determined from test results using ASTM

method D1475-90, information from the supplier or manufacturer of

the material, or reference sources providing density or specific gravity

data for pure materials. If there is disagreement between ASTM

Method D1475-90 test results and other information sources, the test

results will take precedence.

34.c. Determine the density of each coating used during the compliance period from test results using

ASTM method D1475-90 or information from the supplier or manufacturer of the material. If

there is disagreement between ASTM Method D1475-90 test results and the supplier’s or

manufacturer’s information, the test results will take precedence. [40 CFR 63.4741(c)]

34.d. Calculate the organic HAP content, lb of organic HAP per gallon coating solids, of each coating

used during the compliance period using the following equation: [40 CFR 63.4741(d)]

Where:

Hc = Organic HAP content of the coating, lb organic HAP per gallon coating

solids used.

Dc = Density of coating, lb per gallon coating, determined according to

Condition 34.c.

avg

volatiless

D

mV 1

s

ccc

V

WDH

))((



Page 21 of 67

Wc = Mass fraction of organic HAP in the coating, lb organic HAP per pound

coating, determined according to Condition 34.a.


coating, determined according to Condition 34.b.

34.e. The organic HAP content for each coating used during the initial compliance period, determined

using the equation in Condition 34.d, must be less than or equal to the applicable emission limit in

Condition 28; and each thinner and cleaning material used during the initial compliance period

must contain no organic HAP, determined according to Condition 34.a. The permittee must keep

all records required by Conditions 89 and 90. As part of the notification of compliance status, the

permittee must identify the coating operation(s) for which the permittee used the compliant

material option and submit a statement that the coating operation(s) was (were) in compliance with

the emission limitations during the initial compliance period because the permittee used no

coatings for which the organic HAP content exceeded the applicable emission limit in Condition

28, and the permittee used no thinners or cleaning materials that contained organic HAP,

determined according to the procedures in Condition 34.a. [40 CFR 63.4741(e)]

35. The permittee must demonstrate continuous compliance as follows: [40 CFR 63.4742]

35.a. For each compliance period to demonstrate continuous compliance, the permittee must use no

coating for which the organic HAP content determined using the equation in Condition 34.d

exceeds the applicable emission limit in Condition 28 and use no thinner or cleaning material that

contains organic HAP, determined according to Condition 34.a. A compliance period consists of

12 months. Each month, after the end of the initial compliance, is the end of a compliance period

consisting of that month and the preceding 11 months.

35.b. If the permittee chooses to comply with the emission limitations by using the compliant material

option, the use of any coating, thinner or cleaning material that does not meet the criteria specified

in 35.a is a deviation from the emission limitations that must be reported as specified in

Conditions 33 and 105.

35.c. As part of each semiannual compliance report required by Condition 105, the permittee must

identify the coating operation(s) for which the permittee used the compliance material option. If

there were no deviations form the emission limitations in Condition 28, submit a statement that the

coating operation(s) was (were) in compliance with the emission limitations during the reporting

period because the permittee used no coating for which the organic HAP content exceeded the

applicable emission limit in Condition 28, and the permittee used no thinner or cleaning material

that contained organic HAP, determined according to Condition 34.a.

35.d. The permittee must maintain records as specified in Conditions 89 and 90.

Plywood and Composite Wood Products NESHAP (Subpart DDDD)

36. Emission standards and operating requirements:

36.a. Emissions from the fiber dryers (FD) and press vents (PV) must meet one of the following

compliance options using an add-on control system: [40 CFR 63.2240(b)]

36.a.i. Reduce emissions of total HAP, measured as THC (as carbon), by 90 percent; or

36.a.ii. Limit emissions of total HAP, measured as THC (as carbon), to 20 ppmvd; or

36.a.iii. Reduce methanol emissions by 90 percent; or

36.a.iv. Limit methanol emissions to less than or equal to 1 ppmvd if uncontrolled methanol

emissions entering the control device are greater than or equal to 10 ppmvd; or

36.a.v. Reduce formaldehyde emissions by 90 percent; or

36.a.vi. Limit formaldehyde emissions to less than or equal to 1 ppmvd if uncontrolled

formaldehyde emissions entering the control device are greater than or equal to 10

ppmvd.

36.b. If using one of the emission concentration compliance options (Condition 36.a.ii, 36.a.iv or

36.a.vi), there must be a capture device that 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)]



Page 22 of 67

36.c. The 24-hour block biofilter bed temperature must be maintained within the range established in

accordance with Condition 37.j (currently 71 to 102°F based on three performance tests). [40

CFR 63.2240(c)]

36.d. The fiber dryers and press vents must be in compliance with the compliance options, operating

requirements, and the work practice requirements 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 § 63.2251, if applicable.

The compliance options, operating requirements, and work practice requirements do not apply

during times when the process unit(s) subject to the compliance options, operating requirements

and work practice requirements are not operating, or during periods of startup, shutdown and

malfunction. Startup and shutdown periods must not exceed the minimum amount of time

necessary for these events. [40 CFR 63.2250(a)]

36.e. The permittee must always operate and maintain the affected source, including air pollution

control and monitoring equipment, according to the provisions in 40 CFR 63.6(e)(1)(i).

36.f. The permittee must develop a written startup, shutdown and malfunction plan (SSMP) according

to the provisions in 40 CFR 63.6(e)(3).

36.g. The General Provisions of 40 CFR Part 63 are incorporated by reference as specified in Table 10

of Subpart DDDD.

37. Performance testing:

37.a. The biofilter must be tested within 2 years following the previous performance test and within 180

days after each replacement of any portion of the biofilter media or each replacement of more than

50 percent (by volume) of the biofilter media with the same type of media. [40 CFR 63.2271]

37.b. The tests must be conducted using the methods specified in Table 4 of 40 CFR Part 63, Subpart

DDDD. [40 CFR 63. 2262(a)]

37.c. The tests must not be conducted during periods of startup, shutdown or malfunction. [40 CFR

63.2262(b)(1)]

37.d. The tests must be conducted under representative operating conditions as defined in 40 CFR

62.2292. The operating conditions during the test must be described in the performance test report

for the process and control system and explain why they are representative. [40 CFR

63.2262(b)(2)]

37.e. Three separate test runs must be conducted for each performance test. Each test run must last at

least 1 hour except testing of an enclosure conducted using the alternative tracer gas method in

Appendix A of 40 CFR Part 63, requires a minimum of three separate runs of at least 20 minutes

each. [40 CFR 63.2262(c)]

37.f. 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 (defined in

40 CFR 63.2292) and prior to any releases to the atmosphere. For control sequences with wet

control devices (defined in 40 CFR 63.2292) followed by control devices (defined in 40 CFR

63.2292), sampling sites may be located at the inlet and outlet of the control sequence and prior to

any releases to the atmosphere. [40 CFR 63.2262(d)]

37.g. The permittee must collect operating parameter monitoring system or continuous emissions

monitoring system (CEMS) data at least every 15 minutes during the entire performance test and

determine the parameter or concentration value for the operating requirement during the

performance test using the methods specified in Condition 37.b. [40 CFR 63.2262(e)]

37.h. All nondetect data (defined in 40 CFR 63.2292) must be treated as one-half of the method

detection limit when determining total HAP, formaldehyde, methanol or total hydrocarbons (THC)

emission rates. [40 CFR 63.2262(g)(1)]

37.i. When complying with any of the compliance options based on percent reduction across a control

system as part of the performance test, the percent reductions must be calculated using the

following equation: [40 CFR 63.2262(h)]



Page 23 of 67

PR = -100 * CE * (ERin - ERout)/ERin

Where,

PR = Percent reduction (%);

CE = Capture efficiency (%) – determine for reconstituted wood product

presses and board coolers as required in Table 4 of 40 CFR Part 63,

Subpart DDDD;

ERin = Emission rate of total HAP (calculated as the sum of the emission rate

of acetaldehyde, acrolein, formaldehyde, methanol, phenol and

proprionaldehyde), THC, formaldehyde, or methanol in the inlet vent

stream of the control device (lbs/hr);

ERout = Emission rate of total HAP (calculated as the sum of the emission rate

of acetaldehyde, acrolein, formaldehyde, methanol, phenol and

proprionaldehyde), THC, formaldehyde, or methanol in the outlet vent

stream of the control device (lbs/hr)

37.j. During the performance test, the permittee must continuously monitor the biofilter bed

temperature during each of the required 1-hour test runs. To monitor biofilter bed temperature, the

permittee may use multiple thermocouples in representative locations throughout the biofilter bed

and calculate the average biofilter bed temperature across these thermocouples prior to reducing

the temperature data to 15-minute averages for purposes of establishing biofilter bed temperature

limits. The biofilter bed temperature range must be established as the minimum and maximum

15-minute biofilter bed temperatures monitored during the three test runs. The permittee may base

the biofilter bed temperature range on values recorded during previous performance tests provided

that the data used to establish the temperature ranges have been obtained using the test methods

required in this condition. If using data from previous performance tests, the permittee must

certify that the biofilter and associated process unit(s) have not been modified subsequent to the

date of the performance tests. Replacement of the biofilter media with the same type of material is

not considered a modification of the biofilter for purposes of this sub-condition. The permittee

may expand the biofilter bed temperature operating range by submitting the notification specified

in Condition 38.c.v and conducting a repeat performance test that demonstrates compliance with

the applicable compliance options of this subpart. [40 CFR 63.2262(m)(1) and (2)]

38. Monitoring, recordkeeping and reporting:

38.a. Compliance monitoring:

38.a.i. The permittee must install, operate and maintain a continuous parameter monitoring

system (CPMS) for measuring the biofilter bed temperature. [Table 4 of 40 CFR Part

63, Subpart DDDD, 40 CFR 63.2269(a), and 63.2270(a)]

38.a.ii. 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)]

38.a.iii. 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)]

38.a.iv. The permittee must record the results of each inspection, calibration and validation

check. [40 CFR 63.2269(a)(3)]

38.a.v. The temperature sensor must be located in a position that provides a representative

temperature of the biofilter bed. [40 CFR 63.2269(b)]

38.a.vi. The temperature sensor must have a minimum accuracy of 4F or 0.75 percent of the

temperature value, whichever is larger. [40 CFR 63.2269(b)(2)]

38.a.vii. If a chart recorder is used, it must have a sensitivity with minor divisions not more

than 20F. [40 CFR 63.2269(b)(3)]



Page 24 of 67

38.a.viii. The permittee must 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 30F of the process temperature

sensor’s reading. [40 CFR 63.2269(b)(4)]

38.a.ix. The permittee must conduct calibration and validation checks any time the sensor

exceeds the manufacturer’s specified maximum operating temperature range or install

a new temperature sensor. [40 CFR 63.2269(b)(5)]

38.a.x. At least quarterly, the permittee must inspect all components for integrity and all

electrical connections for continuity, oxidation and galvanic corrosion. [40 CFR

63.2269(b)(6)] 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)]

38.a.xi. 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 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 of the control system. [40 CFR 63.2270(c)]

38.a.xii. The permittee must determine the 24-hour block average of all recorded temperature

readings, calculated after every 24 hours of operation as the average of the evenly

spaced recorded readings in the previous 24 operating hours, excluding periods

described in Conditions 38.a.x and 38.a.xi. [40 CFR 63.2270(e)]

38.a.xiii. To calculate the data averages for each 24-hour averaging period, the permittee must

have at least 75 percent of the required recorded readings for that period using only

recorded readings that are based on valid data (i.e., not from periods described in

Conditions 38.a.x and 38.a.xi). [40 CFR 63.2270(f)]

38.b. Recordkeeping:

38.b.i. The permittee must keep the following records: [40 CFR 63.2282(a)]

38.b.i.A. A copy of each notification and report submitted to comply with 40

CFR Part 63, Subpart DDDD, including all documentation

supporting any Initial Notification or Notification of Compliance

Status that was submitted, according to the requirements in 40 CFR

63.10(b)(2)(xiv).

38.b.i.B. The records in 40 CFR 63.6(e)(3)(iii) through (v) related to startup,

shutdown and malfunction.

38.b.i.C. Documentation of the approved routine control device maintenance

exemption, if such an exemption is requested under 40 CFR

63.2251.

38.b.i.D. Records of performance tests and performance evaluations as

required in 40 CFR 63.10(b)(2)(viii).



Page 25 of 67

38.b.ii. The permittee must keep the records of the biofilter bed temperature required to show

continuous compliance with the biofilter operating requirement. [40 CFR 63.2282(b)]

38.c. Reporting requirements:

38.c.i. The permittee must report each instance in which the permittee did not meet each

compliance option, operating requirement and work practice requirement in Condition

36. This includes periods of startup, shutdown and malfunction and periods of

control device maintenance specified in paragraphs (b)(1) through (3) of this

condition. These instances are deviations from the compliance options, operating

requirements and work practice requirements in this subpart. These deviations must

be reported according to the requirements in 38.c.ii. [40 CFR 63.2271(b)]

38.c.i.A. Consistent with 40 CFR 63.6(e) and 63.7(e)(1), deviations that

occur during a period of startup, shutdown or malfunction are not

violations if you demonstrate to the DEQ’s satisfaction that you

were operating in accordance with 40 CFR 63.6(e)(1). DEQ will

determine whether deviations that occur during a period of startup,

shutdown or malfunction are violations, according to the provisions

in 40 CFR 63.6(e).

38.c.i.B. Deviations that occur during periods of control device maintenance

covered by any approved routine control device maintenance

exemption are not violations if you demonstrate to DEQ’s

satisfaction that you were operating in accordance with the

approved routine control device maintenance exemption.

38.c.ii. The permittee must submit a compliance report semi-annually along with the semi-

annual compliance certification report required by Condition 96. The compliance

report must include the following information: [40 CFR 63.2281(a), (b)(5), and (c)]

38.c.ii.A. Company name and address.

38.c.ii.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.

38.c.ii.C. Date of report and beginning and ending dates of the reporting

period.

38.c.ii.D. If there were startups, shutdowns or malfunctions during the

reporting period and the operator took actions consistent with the

SSMP, the compliance report must include the information

specified in 40 CFR 63.10(d)(5)(i).

38.c.ii.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

following information:

(i) The date and time when the control device was shut down

and restarted.

(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.

(iii) A statement of whether or not the control device

maintenance was included in your approved routine control

device maintenance exemption developed pursuant to 40 CFR

63.2251. If the control device maintenance was included in

your approved routine control device maintenance exemption,

then you must report the following information:

(A) The total amount of time that each process unit

controlled by the control device operated during the

semiannual compliance period and during the

previous semiannual compliance period.



Page 26 of 67

(B) The amount of time 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.

(C) Based on the information recorded under (A) and

(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 the following equation:

RM = (DTp + DTc)/(PUp PUc)

Where:

RM = Annual percentage of process unit uptime during which

control device is down for routine control device maintenance;

DTp = Control device downtime claimed under the routine control

device maintenance exemption for the previous semiannual

compliance period;

DTc = Control device downtime claimed under the routine control

device maintenance exemption for the current semiannual

compliance period.

PUp = Process unit uptime for the previous semiannual compliance

period;

PUc = Process unit uptime for the current semiannual compliance

period;

38.c.ii.F. The results of any performance tests conducted during the

semiannual reporting period.

38.c.ii.G. If there are no deviations from any applicable compliance option or

operating requirement, a statement that there were no deviations

from the compliance options or operating requirements during the

reporting period.

38.c.ii.H. If there were no periods during which the continuous monitoring

system (CMS) was out-of-control as specified in 40 CFR 63.8(c)(7),

a statement that there were no periods during which the CMS was

out-of-control during the reporting period.

38.c.iii. The permittee must report all deviations as defined in this subpart in the semiannual

monitoring report required by Condition 96. If the permittee submits a compliance

report pursuant to this condition along with, or as part of, the semiannual monitoring

report required by Condition 96, and the compliance report includes all required

information concerning deviations from any compliance option, operating

requirement or work practice requirement in this condition, submission of the

compliance report shall be deemed to satisfy any obligation to report the same

deviations in the semiannual monitoring report. However, submission of a

compliance report shall not otherwise affect any obligation the affected source may

have to report deviations from permit requirements to the permitting authority.

38.c.iv. For each deviation from a compliance option or operating requirement occurring at an

affected source where the permittee is using a CMS to comply with the compliance

options and operating requirements, the permittee must include the following

information in the semi-annual compliance report. This includes periods of startup,

shutdown and malfunction and routine control device maintenance. [40 CFR 63.6(e)]



Page 27 of 67

38.c.iv.A. The date and time that each malfunction started and stopped.

38.c.iv.B. The date and time that each CMS was inoperative, except for zero

(low-level) and high-level checks.

38.c.iv.C. The date, time and duration that each CMS was out-of-control,

including the information in 40 CFR 63.8(c)(8).

38.c.iv.D. 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 your approved routine control device

maintenance exemption; or during another period.

38.c.iv.E. 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.

38.c.iv.F. 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.

38.c.iv.G. A summary of the total duration of CMS 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.

38.c.iv.H. A brief description of the process units.

38.c.iv.I. A brief description of the CMS.

38.c.iv.J. The date of the latest CMS certification or audit.

38.c.iv.K. A description of any changes in CMS, processes or controls since

the last reporting period.

38.c.v. The permittee must notify DEQ within 30 days before taking either of the following

actions: [40 CFR 63.6280(g)]

38.c.v.A. Modifying or replacing the control system for any process unit

subject to the compliance options and operating requirements in

Condition 36; or

38.c.v.B. Changing a continuous monitoring parameter or the value or range

of values of a continuous monitoring parameter for any process unit

or control device.

Boiler Area Source MACT (40 CFR Part 63, Subpart JJJJJJ):

39. The permittee may only burn biomass in Boiler G (BLRG). Biomass means any biomass-based solid fuel

that is not a solid waste as defined in 40 CFR 241.3. This includes, but is not limited to:

39.a. Wood residue and wood products, including trees, tree stumps, tree limbs, bark, lumber, sawdust,

sander dust, chips, scraps, slabs, millings and shavings;

39.b. Animal manure, including litter and other bedding materials; and

39.c. Vegetative agricultural and silvicultural materials, including logging residues (slash), nut and

grain hulls and chaff , bagasse, orchard prunings, corn stalks, coffee bean hulls and grounds.

40. No later than March 21, 20121, the permittee must conduct a performance tune-up of Boiler G and every

two years thereafter as follows: [40 CFR 63.11196(a)(1), 63.11201(b), 63.11214(b) and 63.11223]

1On March 13, 2012, EPA issued a “no action assurance” for the Area Source Boiler Rule, stating that EPA would

not enforce the requirement to conduct an initial tune-up by March 21, 2012. On July 18, 2012, EPA issued an

extension for the “no action assurance” to either (1) December 31, 2012, or (2) the effective date of a final rule

addressing the proposed reconsideration of the Area Source Boiler Rule.



Page 28 of 67

40.a. Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure it is correctly

calibrated and functioning properly;

40.b. Measure the exhaust concentration of carbon monoxide (ppmv) and oxygen (%), before and after

the adjustments are made. Measurements may be made either on a dry or wet basis, as long as it is

the same basis before and after any adjustments are made;

40.c. Optimize the total emissions of carbon monoxide. This optimization must be consistent with the

manufacturer’s specifications, if available.

40.d. If the boiler is not operating on the required date for the tune-up, the tune-up must be conducted

within one week of startup; and

40.e. Each biennial tune-up must be conducted no more than 25 months after the previous tune-up.

41. The permittee must maintain biennial reports containing the tune-up information as required in Condition

40, specifically: [40 CFR 63. 11223(b)(6) (i) through (iii) and 63.11225(c)(2) (i) and (ii)]

41.a. Identification of the boiler, date of tune up, the procedures followed for the tune-up, and the

manufacturer’s specifications to which the boiler was tuned.

41.b. The CO concentrations in the exhaust in ppmv, and oxygen %, measured before and after the tune-

up, as detailed in Condition 40.b.

41.c. A description of any corrective actions taken as part of the tune-up.

41.d. The type and amount of fuel used each month over the 12 months prior to the biennial tune-up.

41.e. These records must be maintained onsite, in a form suitable for inspection and/or submittal upon

request.

42. No later than July 19, 20121, the permittee must submit the Notification of Compliance Status including the

statement, signed by the responsible official, which states: “This facility complies with the requirements in

40 CFR 63.11214 to conduct an initial tune-up of the boiler.” [40 CFR 63.11225(a)(4)(i)]

43. No later than March 21, 2014, the permittee must conduct an energy assessment of the boiler and its energy

use systems. [40 CFR 63.11214(c), 63.11237 and Table 2 to Subpart JJJJJJ of 40 CFR Part 63]

43.a. The energy assessment must be conducted as follows dependent on the annual heat input to the

facility:

43.a.i. For facilities with affected boilers using less than 300,000 MMbtu (0.3 trillion btu)

per year total heat input, the energy assessment must be one day in length maximum.

The boiler system and energy use system accounting for at least 50 percent of the

affected boiler(s) energy output must be evaluated to identify energy savings

opportunities.

43.a.ii. For facilities with affected boilers and process heaters using greater than 300,000

MMbtu (0.3 trillion btu), but less than 1,000,000 MMbtu (1 trillion btu) per year total

heat input, the energy assessment must be three days in length maximum. The boiler

system and energy use system accounting for at least 33 percent of the affected

boiler(s) energy output must be evaluated to identify energy savings opportunities.

43.a.iii. For facilities with affected boilers and process heaters using more than 1,000,000

MMbtu (1 trillion btu) per year total heat input. The boiler system and energy use

system accounting for at least 20 percent of the affected boiler(s) energy output must

be evaluated to identify energy savings opportunities.

43.b. The energy assessment must include:

43.b.i. A visual inspection of the boiler system;

43.b.ii. An evaluation of operating characteristics of the facility, specifications of energy use

systems, operating and maintenance procedures, and unusual operating constraints;

Energy use systems include, but are not limited to process heating, compressed

air systems, machine drive (pumps, motors, fans), process cooling, facility

heating, ventilation and air conditioning (HVAC) systems, hot heater systems,

building envelope, and lighting.



Page 29 of 67

43.b.iii. An inventory of major systems consuming energy from each affected boiler(s);

43.b.iv. A review of available architectural and engineering plans, facility operation and

maintenance procedures and logs, and fuel usage;

43.b.v. A list of major energy conservation measures;

43.b.vi. A list of energy savings potential of the energy conservation measure identified; and

43.b.vii. A comprehensive report detailing the ways to improve efficiency, the cost of specific

improvements, benefits, and the time frame for recouping those investments.

44. No later than July 19, 2014, the permittee must submit the Notification of Compliance Status including the

statement, signed by the responsible official, which states: “This facility has had an energy assessment

performed according to 40 CFR 63.11214(c).” This energy assessment report must be submitted upon

request. [40 CFR 63.11225(a)(4)(ii)]

45. The permittee must comply with the following, as applicable:

45.a. The permittee must prepare a biennial compliance report and include it with the annual report

specified in Condition 96.b. The report must include the following: [40 CFR 63.11225(b)]

45.a.i. Company name and address;

45.a.ii. Statement by a responsible office, with the official’s name, title, phone number, e-

mail address, and signature, certifying the truth accuracy and completeness of the

notification and a statement of whether the source has complied with all of the

relevant standards and other requirements of 40 CFR Part 63, Subpart JJJJJJ.

45.a.iii. If the source experiences any deviations from the applicable requirements during the

reporting period, include a description of the deviations, the time periods during

which the deviations occurred, and the corrective action taken.

45.b. Notification 30 days prior to commencing combustion of solid waste including the following

information: [40 CFR 63.11225(f)]

45.b.i. The name of the owner or operator of the affected source, the location of the source,

the boilers(s) that will commence burning solid waste, and the date of the notice;

45.b.ii. The currently applicable subcategory under 40 CFR Part 63, Subpart JJJJJJ;

45.b.iii. The date on which the boilers became subject to the currently applicable emission

limits; and

45.b.iv. The date upon which combusting solid waste will commence.

45.c. Notification 30 days prior to switching to a fuel(s) that may result in the applicability of a different

subcategory or a switch out of 40 CFR Part 63, Subpart JJJJJJ due to a switch to 100 percent

natural gas, including the following information: [40 CFR 63.11225(g)]

45.c.i. The name of the owner or operator of the affected source, the location of the source,

the boiler(s) that will switch fuels, and the date of the notice;

45.c.ii. The currently applicable subcategory under 40 CFR Part 63, Subpart JJJJJJ;

45.c.iii. The date on which the boilers became subject to the currently applicable emission

limits; and

45.c.iv. The date upon which the fuel switch will commence.

45.d. The General Provisions of 40 CFR Part 63 are incorporated by reference in accordance with Table

8 of Subpart JJJJJJ. [40 CFR 63.11235]

SIP Standards

46. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere from

Boiler G (BLRG), Natural Gas Combustion Devices (NGCD), paint drying ovens (O), fiber dryres

(FD)/press vents (PV)/biofilter, cyclones (CF, CT1 and CT2), kilns (K), and Baghouses (BH1) 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. [OAR 340-208-0110(2) and 340-208-0110(3)(a)] Visible emissions

must be measured in accordance with Condition 74 for CF, CT1, CT2, V, O, FD/PV/Biofilter, and K;

Conditions 75 and 76 for BH1, Conditions 77 and 79 for boiler G; and Condition 80 for NGCD.



Page 30 of 67

47. The permittee may not cause or allow the emissions of any air contaminant into the atmosphere from

material handling activities (MHF and MHT), sawing and debarking (S&D), storage piles (SP), and

unpaved roads (UPR) 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. [OAR 340-208-0110(2) and 340-208-

0110(3)(a)] Visible emissions must be measured in accordance with Conditions 69 and 70.

48. The permittee may not cause or allow the emissions of particulate matter from Natural Gas Combustion

Devices (NGCD) in excess of 0.1 grains per dry standard cubic foot, corrected to 50% excess air. [OAR

340-228-0210(1)(b)] If testing is required, particulate matter emissions must be measured in accordance

with Condition 64. Particulate matter must be monitored in accordance with Condition 80.

49. The permittee may not cause or allow the emissions of particulate matter from Boiler G (BLRG) in excess

of 0.07 grains per dry standard cubic foot, corrected to 12% CO2. [1989 ACDP Condition 3 and OAR 340-

228-0210(1)(b)] Particulate matter emissions must be measured in accordance with Condition 63. Visible

emissions as a surrogate for particulate matter must be monitored in accordance with Conditions 77 and 79.

50. The permittee may not cause or allow the emissions of particulate matter from the paint drying ovens (O) in

excess of 0.1 grains per dry standard cubic foot. [OAR 340-226-0210(1)(b)] If testing is required,

particulate matter emissions must be measured in accordance with Condition 64. Visible emissions as a

surrogate for particulate matter must be monitored in accordance with Condition 74.

51. The permittee may not cause or allow the emissions of particulate matter from the FD and PV

baghouses/biofilter in excess of 0.1 grains per dry standard cubic foot. [OAR 340-226-0210(1)(b)] If

testing is required, particulate matter emissions must be measured in accordance with Condition 64.

Visible emissions as a surrogate for particulate matter must be monitored in accordance with Condition 74.

52. The permittee may not cause or allow the emission of particulate matter from the cyclones CT1 in excess of

0.2 grains per dry standard cubic foot. [OAR 340-226-0210(1)(a)] If testing is required, particulate matter

emissions must be measured in accordance with Condition 64. Visible emissions as a surrogate for

particulate matter must be monitored in accordance with Condition 74.

53. The permittee may not cause or allow the emission of particulate matter from the baghouses (BH1), and

cyclones (CF and CT2) in excess of 0.1 grains per dry standard cubic foot. [OAR 340-226-0210(1)(b)] If

testing is required, particulate matter emissions must be measured in accordance with Condition 64.

Visible emissions as a surrogate for particulate matter must be monitored in accordance with Condition 75.

54. The permittee may not cause or allow the combined emissions of particulate matter from the baghouses

(BH1), cyclones (CF), paint drying ovens (O), fiber dryers (FD), and press vents (PV) in excess of 29.4

lbs/hr as a 24-hour (daily) average based on the regulatory limit of 1.13 pound per thousand square feet of

finish product and a maximum capacity of 26 thousand square feet per hour. [OAR 340-234-0530(2)(b)(B)

and 340-234-0500(3)] Particulate matter emissions must be measured in accordance with Condition 64.

55. The permittee may not cause or allow the emission of particulate matter from any cyclone included in

emissions units CT1 and CT2 in excess of the amount shown in Table 1 of OAR 340-226-0310 for the

process weight allocated to that process. If testing is required, particulate matter emissions must be

measured in accordance with Condition 64. Visible emissions as a surrogate for particulate matter must be

monitored in accordance with Condition 74.

56. The permittee may not cause or allow the operation of the veneer dryer (V) such that visible air

contaminants emitted from the dryer stacks or emission points exceed:

56.a. An average operating opacity of 10% [OAR 340-234-0510(1)(b)(A)]; or

56.b. A maximum opacity of 20%. [OAR 340-234-0510(1)(b)(B)]



Page 31 of 67

"Average operating opacity” means the opacity of emissions determined using EPA Method 9 on any three

days within a 12-month period which are separated from each other by at least 30 days; a violation of the

average operating opacity limitation is judged to have occurred if the opacity of emissions on each of the

three days is greater than the specified average operating opacity limitation.

"Maximum opacity" means the opacity as determined by EPA Method 9 (average of 24 consecutive

observations). [OAR 340-234-0010]

57. The permittee may not cause or allow the emission of particulate matter from the veneer dryer (V) in

excess of 0.1 grains per dry standard cubic foot. [OAR 340-226-0210(1)(b)] If testing is required,

particulate matter emissions must be measured in accordance with Condition 64. Visible emissions as a

surrogate for particulate matter must be monitored in accordance with Condition 74.

58. The veneer dryer must be maintained and operated at all times such that air contaminant generating

processes and all air contaminant control equipment must be at full efficiency and effectiveness so that the

emission of air contaminants are kept at the lowest practicable levels. [OAR 340-234-0510(1)(e)]

59. The permittee must not willfully cause or permit the installation or use of any means, such as dilution,

which, without resulting in a reduction in the total amount of air contaminants emitted, conceals an

emission from the veneer dryer which would otherwise violate Conditions 56 or 57. [OAR 340-234-

0510(1)(f)]

Insignificant Activities Emission Limits and Standards

60. DEQ acknowledges that insignificant emissions units (IEUs) 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. IEUs must comply with all applicable requirements. In

general, the requirements that could apply to IEUs are incorporated as follows:

60.a. OAR 340-208-0110: 20% opacity

60.b. OAR 340-226-0210: 0.1 gr/dscf for non-fugitive, non-fuel burning equipment

60.c. OAR 340-226-0310: process weight limit for non-fugitive, non-fuel burning process equipment

60.d. OAR 340-228-0210: 0.1 gr/dscf corrected to 12% CO2 or 50% excess air for boilers

60.e. OAR 340-234-0510(1)(a): 1.0 pound of particulate matter per 1000 square feet of veneer

production on a 3/8” finished product equivalent basis for veneer production sources including,

but not limited to, sanding machines, saws, presses, barkers, hogs, chippers, and other material

size reduction equipment, process or space ventilation systems, and truck loading and unloading

facilities. Exempted from this limit are veneer dryers, fuel burning equipment, and refuse burning

equipment.

60.f. Emergency stationary reciprocating internal combustion engines (RICE) are subject to the

following requirements beginning May 3, 2013: [40 CFR 63.6603(a), 63.6625(f), 63.6640(a), and

63.6640(f)(2)]

60.f.i. For each emergency stationary RICE, the permittee must:

60.f.i.A. Change oil and filter every 500 hours of operation or annually,

whichever comes first; [40 CFR 63. 6603(a), Table 2d(4)(a)]

60.f.i.B. Inspect air cleaner every 1,000 hours of operation or annually,

whichever comes first; [40 CFR 63. 6603(a), Table 2d(4)(b)]

60.f.i.C. Inspect all hoses and belts every 500 hours of operation or annually,

whichever comes first, and replace as necessary; [40 CFR 63.

6603(a), Table 2d(4)(c)]

60.f.i.D. During periods of startup, minimize the engine’s time spent at idle

and minimize the engine’s startup time at startup to a period needed

for appropriate and safe loading of the engine, not to exceed 30

minutes, after which time the non-startup emission limitations

apply; and [40 CFR 63. 6603(a), Table 2d]



Page 32 of 67

60.f.ii. The permittee must install a non-resettable hour meter on each emergency stationary

RICE, if one is not already installed. [40 CFR 63.6625(f)]

60.f.iii. The permittee must operate and maintain the stationary RICE according to the

manufacturer’s emission related operation and maintenance instructions. [40 CFR

63.6640(a), Table 6(9)]

60.f.iv. Operating conditions: [40 CFR 63.6640(f)(2)]

60.f.iv.A. There is no time limit on the use of emergency stationary RICE in

emergency situations.

60.f.iv.B. Emergency stationary RICE may be operated for the purpose of

maintenance checks and readiness testing, provided that the tests

are recommended by the manufacturer, the vendor, or the insurance

company associated with the engine. Required testing of such units

should be minimized, but there is no time limit on the use of

emergency stationary RICE in emergency situations and for routine

testing and maintenance.

60.f.iv.C. Emergency stationary RICE may be operated for an additional 50

hours per year in non-emergency situations. The 50 hours per year

for non-emergency situations cannot be used for peak shaving or to

generate income for a facility to supply power to an electric grid or

otherwise supply power as part of a financial arrangement with

another utility.

60.f.v. The permittee must keep records of the hours of operation of each emergency

stationary RICE that is recorded through the non-resettable hour meter. The

permittee must document how many hours are spent for emergency operation,

including what classified the operation as emergency and how many hours are spent

for non-emergency operation. If the engines are used for demand response operation,

the owner or operator must keep records of the notification of the emergency

situation, and the time the engine was operated as part of demand response. [40 CFR

63.6655(f)]

PLANT SITE EMISSION LIMITS

61. The annual plant site emissions (tons/year) for the entire facility must not exceed the following as measured

in accordance with Conditions 81 through 81.e. [OAR 340-028-1010 and 340-028-1020]:

PM PM10 PM2.5 SO2 NOx CO VOC GHG

(CO2e)

Single

HAP

Combined

HAP

48 27 11 39 67 108 295 74,000 9 24

61.a. Unassigned emissions are as follows: [OAR 340-22-0045(2)(a)]

61.a.i. PM = 58 tons

61.a.ii. PM10 = 27 tons

61.a.iii. PM2.5 = 18 tons

61.a.iv. VOC = 172 tons

61.b. At the next permit renewal, the unassigned emissions will be reduced to the significant emission

rate (SER), if the unassigned emissions are not used during the permit term. [OAR 340-2222-

0045]

61.c. In order to use unassigned emissions, the permittee must submit a notice of construction, as well

as an application for a significant permit modification to increase the plant site emission limit(s).

[OAR 340-218-0180 and 340-218-0190]



Page 33 of 67

TESTING REQUIREMENTS

62. Unless otherwise specified in this permit, the permittee must conduct all testing in accordance with DEQ’s

Source Sampling Manual. [OAR 340-212-0120]

62.a. 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.

62.b. Unless otherwise specified by permit condition or DEQ approved source test plan, all compliance

source tests must be performed at maximum operating rates (90 to 110% of device design

capacity).

62.c. 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, DEQ may accept two (2) test runs for demonstrating compliance

with the emission limit or standard.

62.d. Source test reports prepared in accordance with DEQ’s Source Sampling Manual must be

submitted to DEQ within 45 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.

63. Oregon Method 5 must be used for measuring particulate matter emissions from Boiler G (BLRG). Each

test run must be a minimum of 60 minutes long with a minimum sample volume of 31.8 dscf. Test results

must be reported as grains per dry standard cubic feet (gr/dscf), gr/dscf corrected to 12% CO2, lbs/hr, and

lbs/thousand lbs of steam produced.

63.a. Boiler G must be tested no later than January 1, 2015.

63.b. During each test run, the permittee must record the following information:

63.b.i. As fired fuel characteristics including moisture content, approximate percentage of

bark, species, percent by weight less than 1/8 inch, and approximate amount of

recycled hardboard (percent by weigth);

63.b.ii. Visible emissions as measured by the COMS;

63.b.iii. NOx emissions, as measured by EPA Method 7e;

63.b.iv. CO emissions, as measured by EPA Method 10;

63.b.v. Boiler steaming rate (lbs/hr);

63.b.vi. Boiler residual oxygen (%); and

63.b.vii. Control device operating parameters including the pressure drop across the multiclone

and ESP voltage/current.

63.c. Three additional test runs must be conducted for measuring NOx and CO emissions while burning

resinated fuels if resinated fuel was burned for more than 720 total elapsed hours during the period

between the date this permit is issued and the date of the test conducted to satisfy the requirement

of Condition 63.a. The fuel characteristics, steam rate, and residual oxygen must be recorded

during each test run.

64. Unless otherwise specified in this permit or an applicable requirement, DEQ is not requiring any testing,

monitoring, recordkeeping, or reporting for the applicable emissions limits and standards that apply to

IEUs. However, if testing 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 340-208-0010

and perform the testing in accordance with DEQ’s Source Sampling Manual. This condition also applies to

any other emissions unit for which testing is not specifically required by the permit.



Page 34 of 67

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

General Monitoring Requirements

65. The permittee must not knowingly render inaccurate any required monitoring device or method. [OAR

340-218-0050(3)(a)(E)]

66. Methods used to determine actual emissions for fee purposes must also be used for compliance

determination and can be no less rigorous than the requirements of OAR 340-218-0080. [OAR 340-218-

0050(3)(a)(F)]

67. 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)]

Facility-Wide Monitoring Requirements

68. The permittee must maintain a log for recording all complaints received via letter, telephone, in person, or

facsimile by the responsible official or a designated appointee that specifically refer to a complaint of odor

or particulate matter fallout from the permitted facility. The log must also include a record of the

permittee's actions to investigate, make a determination as to the validity of the complaint, and resolve the

problem, if possible, within two working days, but not longer than five working days of receiving the

complaint. The permittee must immediately notify DEQ of any complaints unresolved after 5 days of

receiving the complaint. This condition is only enforceable by the state.

69. At least once during each week for a minimum period of 30 minutes, the permittee must visually survey the

entire facility other than the veneer dryer, hog fuel boilers, cyclones, press vents, and kilns for any sources

of excess fugitive emissions. For the purpose of this survey, excess fugitive emissions are considered to be

any visible emissions that leave the plant site boundaries. The person conducting the survey does not have

to be EPA Method 9 certified. However, the individual should be familiar with the procedures of EPA

Method 9 including using the proper location to observe visible emissions. If sources of excess fugitive

emissions are identified, the permittee must:

69.a. Immediately conduct a Method 9 test at the plant site boundary; or

69.b. Contain the source of emissions (e.g. sweep up the dust), cover the material, or use water or some

other chemical treatment to minimize the fugitive emissions, unless cold weather would make this

activity result in hazardous conditions. If water is used to control the fugitive dust emissions, the

permittee must take precautions to not create a water quality problem from surface water run-off.

69.c. The permittee must record in a logbook the date and time of the surveys, the results of the surveys,

and the corrective action, if performed in accordance with Condition 69.a.

70. The permittee must maintain records of inspection and maintenance activities identified in the fugitive

emissions control plan required by Condition 6.

71. The permittee must maintain records of air pollution episodes and emission reduction actions taken

required by Condition 10.

Chromium NESHAP Monitoring:

72. Monitoring to demonstrate continuous compliance. The permittee must conduct monitoring according to

the type of air pollution control technique that is used to comply with the emission limitation in Condition

16. The monitoring required to demonstrate continuous compliance with the emission limitation is

identified in this section. [40 CFR 63.343(c)(1)]

72.a. During the initial performance test, the permittee must determine the outlet chromium



Page 35 of 67

concentration using the test methods and procedures in Condition 16 and must establish a site-

specific operating parameter value for the pressure drop across the system, setting the value that

corresponds to compliance with the applicable emission limitation, using the procedures in

Condition 73. The permittee may conduct multiple performance tests to establish a range of

compliant pressure drop values, or may set as the compliant value the average pressure drop

measured over the three test runs of one performance test and accept ± 2 inch of water column

from this value as the compliant range.

72.b. On and after the date on which the initial performance test is required to be completed under 40

CFR 63.7, the permittee must monitor and record the pressure drop across the composite mesh-

pad system once each day that any affected source is operating. To be in compliance with the

standards, the composite mesh-pad system must be operated within ± 2 inches of water column of

the pressure drop value established during the initial performance test, or must be operated within

the range of compliant values for pressure drop established during multiple performance tests.

73. Establishing site-specific operating parameter values. The permittee must follow the procedures in this

condition for establishing site-specific operating parameters. [40 CFR 63.344(d)(1) and (2)]

73.a. All monitoring equipment must be installed such that representative measurements of emissions or

process parameters from emissions unit CP are obtained. For monitoring equipment purchased

from a vendor, verification of the operational status of the monitoring equipment must include

execution of the manufacturer's written specifications or recommendations for installation,

operation, and calibration of the system.

73.a.i. Specifications for differential pressure measurement devices used to measure velocity

pressure must be in accordance with Section 2.2 of Method 2 (40 CFR Part 60,

Appendix A).

73.a.ii. Specification for differential pressure measurement devices used to measure pressure

drop across a control system must be in accordance with manufacturer's accuracy

specifications.

73.b. The permittee may establish the pressure drop in accordance with the following guidelines: [40

CFR 63.344(d)(5)]

73.b.i. Pressure taps must be installed at any of the following locations:

73.b.i.A. At the inlet and outlet of the control system. The inlet tap should be

installed in the ductwork just prior to the control device and the

corresponding outlet pressure tap should be installed on the outlet

side of the control device prior to the blower or on the downstream

side of the blower;

73.b.i.B. On each side of the packed bed within the control system or on each

side of each mesh pad within the control system; or

73.b.i.C. On the front side of the first mesh pad and backside of the last mesh

pad within the control system.

73.b.ii. Pressure taps must be sited at locations that are:

73.b.ii.A. Free from pluggage as possible and away from any flow

disturbances such as cyclonic demisters;

73.b.ii.B. Situated such that no air infiltration at the measurement site will

occur that could bias the measurement.

73.b.iii. Pressure taps must be constructed of either polyethylene, polybutylene, or other

nonreactive materials.

73.b.iv. Nonreactive plastic tubing must be used to connect the pressure taps to the device

used to measure pressure drop.

73.b.v. Any of the following pressure gauges can be used to monitor pressure drop: a

magnehelic gauge, an inclined manometer, or a "U" tube manometer.

73.b.vi. Prior to connecting any pressure lines to the pressure gauge(s), each gauge should be

zeroed. No calibration of the pressure gauges is required.

Emissions Unit Monitoring



Page 36 of 67

74. The permittee must monitor visible emissions from the stacks of the cyclones (CF, CT1, CT2), veneer dryer

(V), paint drying ovens (O), fiber dryers (FD)/press vents (PV)/biofilter, and kilns (K) by conducting a

Modified Method 9 test. Each Modified 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 Conditions 46 and 56 is documented, whichever period is shorter.

74.a. Modified EPA Method 9 tests must be conducted at least once each quarter with consecutive tests

conducted at least 30 days apart.

74.a.i. The modified EPA Method 9 tests may be waived provided the permittee conducts a

six minute visible emissions survey using EPA Method 22 and visible emissions,

excluding water vapor, are not detected for more than 5% (18 seconds) of the survey

time.

74.a.ii. If the observer is unable to conduct the tests and/or survey due to visual interferences

caused by other visible emissions sources or due to weather conditions such as fog,

heavy rain, or snow, the observer must note such conditions on the data observation

sheet and make at least three attempts to conduct the tests and/or surveys at

approximately 2-hour intervals throughout the day. The permittee must attempt to

make the observations each production day until a valid observation period is

completed.

74.b. Should a test result exceed the applicable standard, the applicable monitoring frequency must be

once weekly for a minimum of four weeks. If the results of the weekly tests are all less than the

applicable standard, the test frequency may return to quarterly.

74.c. All modified EPA Method 9 or Method 22 tests must be performed during periods that the

emission devices are in operation.

75. The permittee must perform compliance assurance monitoring (CAM) for emissions unit BH1 as follows:

[OAR 340-212-0200 through 340-212-0280 and 340-226-0120]

75.a. The permittee must make visible emissions observations of the Shaker baghouse, Fiber main

baghouse, Fiber south baghouse, line 1 former baghouse, and line 2 former baghouse at least once

during each day of operation and take corrective action if there are any visible emissions, other

than water vapor, observed.

75.b. Visible emissions observations must be performed in accordance with EPA Method 22 for a

minimum period of 6 minutes per baghouse.

75.c. If the observer is unable to conduct the visible emissions observations due to visual interferences

caused by other visible emission sources or due to weather conditions such as fog, heavy rain, or

snow, the observer must note such conditions on the data observation sheet and make at least three

attempts to conduct the observations at approximately 2-hour intervals throughout the day.

75.d. All excursions of the visible emissions action level and the corrective action taken to return the

process/baghouses to highest and best practicable treatment and control must be recorded in a log.

75.e. In the semi-annual monitoring report required by Condition 96, the permittee must provide a

summary of the number and duration of action level excursions and corrective action, if necessary,

that occurred during the reporting period.

75.f. An excursion of the visible emissions action level is not necessarily a violation of the particulate

matter emission standard.

76. The permittee must inspect each baghouse at least quarterly and replace the bags, if necessary. Records of

the inspections and any corrective action must be maintained in an inspection logbook.

77. The permittee must install, calibrate, maintain, operate, and record the output of a continuous opacity

monitoring system (COMS) on the exhaust stack of the ESP on Boiler G (BLRG) in accordance with

DEQ’s Continuous Monitoring Manual.



Page 37 of 67

78. The permittee must install, calibrate, maintain, operate, and record the output of a continuous monitoring

system in accordance with the manufacturers written instructions for measuring the steam production and

residual oxygen of Boiler G (BLRG):

78.a. Real time data must be displayed at least once every minute that the boiler is in operation. Hourly

averages of the data or integrated values must be recorded at the end of each clock hour that the

boiler is in operation.

78.b. Minimum data availability must be 90% for any day, month and year of operation. Monitor

availability must be determined excluding periods of calibrations and routine maintenance.

79. The permittee must perform compliance assurance monitoring (CAM) for Boiler G as follows: [OAR 340-

212-0200 through 340-212-0280 and 340-226-0120]

79.a. Using the COMS required by Condition 77, the permittee must take corrective action any time that

the one-hour average opacity exceeds 10%.

79.b. If corrective action cannot be performed within 3 hours of an excursion or the corrective action is

ineffective, the permittee must notify DEQ.

79.c. All excursions of the opacity action level and the corrective action must be recorded in a boiler

operating log.

79.d. In the semi-annual monitoring report required by Condition 96, the permittee must provide a

summary of the number and duration of action level excursions and corrective action, if necessary,

that occurred during the reporting period.

79.e. An excursion of the opacity action level is not necessarily a violation of the particulate matter

emission standard.

80. The permittee must monitor the type of fuel used in each combustion device.

80.a. As long as Natural Gas Combustion Devices (NGCD) operate on natural gas, monitoring

pertaining to Conditions 46 and 48 (opacity and grain loading requirements) consists of

maintaining records of monthly and annual natural gas usage.

80.b. The permittee must install a natural gas meter for NGCD for measuring the amount of natural gas

burned at the facility each calendar month.

80.c. For Boiler G, the permittee must develop and implement a routine fuel inspection program for

monitoring the amount of resinated fuel burned in the boiler on a monthly basis. These procedures

must be included in the operation and maintenance plan for the boiler.

Plant Site Emission Limits Monitoring

81. The permittee must determine compliance with the Plant Site Emission Limits established in Condition 61 of

this permit by conducting monitoring and calculations for each 12-month period in accordance with the

following procedures, test methods, and frequencies:

81.a. Except for GHG, the permittee must calculate pollutant emissions using the following formula,

process parameters, and emission factors:

E = Peu x EFeu x K

Where:

E = Pollutant emissions in lbs/month and tons/yr.

Peu = Process parameter identified in the table below;

EFeu = Emission factor identified for each emissions unit and pollutant

in the table below;

K = Conversion constant: 1 lb/lb for daily and monthly emissions

calculations; 1 ton/2,000 lbs for annual emissions calculations.



Page 38 of 67

Emission Source

Description

Throughput

Type [Units]

Emission Factors (lb/throughput unit)

PM PM10 PM2.5 SO2 NOX CO VOC

MM-T Boiler G –

non-resinated fuel

Steam [1000

POUNDS] 0.019 0.019 0.017 0.014 0.25 0.4 0.13

MM-T Boiler G –

resinated fuel

Steam [1000

POUNDS] 0.019 0.019 0.017 0.014 0.29 0.4 0.13

MM-T supporting

activities

Lumber [1000

BOARD FEET] 0.33 0.33 0.17 NA NA NA 2.3

MM-T fugitives Lumber [1000

BOARD FEET] 1.8 0.71 0.13 NA NA NA 2.2e-5

WFD-O

supporting

activities

1/8-inch

Hardboard [1000

SQUARE FEET]

0.010 0.008 0.006 NA NA NA 0.47

WFD-O fugitives

1/8-inch

Hardboard [1000

SQUARE FEET]

0.0071 0.0071 0.0036 NA NA NA NA

MM-KF

supporting

activities

Lumber [1000

BOARD FEET] 0.006 0.006 0.006 NA NA NA 1.0

Natural gas

combustion

devices

Natural Gas

[MILLION

CUBIC FEET]

2.5 2.5 2.5 2.6 50 84 5.5

Facility wide

VOC

Material usage

(gallons or

pounds)

NA NA NA NA NA NA Conditions

81.b &

81.c

81.b. The permittee must maintain usage records of all materials that contain VOCs and calculate the

monthly and annual emissions separately for the hardboard line, engineering fabrications, and

millwork line using the following equation:

E = (RMi Di VOCi) K

Where:

E = VOC emissions in tons/month and tons/yr;

RMi = Amount of each type of VOC containing raw material used in gal/month

and gal/yr;

Di = Density of each type of VOC containing raw material used in lb/gal from

MSDS;

VOCi = VOC content of raw material (% by weight from MSDS);

K = Conversion constant = 1 ton/2,000 lbs.

81.c. After the biofilter is put in place, the VOC emissions captured and controlled by the biofilter may

be reduced by the overall efficiency of the biofilter as determined by a source test reviewed and

approved by DEQ.

81.d. For each pollutant other than GHG, the annual emissions must be the sum of all of the emissions

calculated in Conditions 81.a through 81.c. For GHG, the information provided in the report

required by Condition 99 will be used for determining compliance with the PSEL for GHG.

81.e. The emissions factors listed in Condition 81.a are not enforceable limits unless otherwise specified

in this permit. Compliance with PSELs must only be determined by the calculations contained in

Conditions 81.a through 81.d of this permit.



Page 39 of 67

EMISSION FEES

82. Emission fees will be based on the Plant Site Emission Limits, unless the permittee elects to report actual

emissions for one or more permitted processes/pollutants. If the 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]

ES Description Permitted Process

Code [DEQ]

PM10

(tons)

SO2

(tons)

NOX

(tons)

VOC

(tons)

MM-T Boiler G PS-1/P-1 4.1 3.0 53.4 27.8

MM-T supporting activities GS-3/P-1 6.0 0 0 43.7

MM-T fugitives FS-2/P-1 13.4 0 0 0

WFD-O supporting activities GS-1/P-1 4.6 0 0 0

WFD-O fugitives FS-1/P-1 0.7 0 0 0

MM-KF dehumidification kilns GS-4/P-1 0 0 0 3.7

Natural gas burning devices GS-2/P-1 0.7 0.7 13.5 1.5

Facility-wide VOC FS-3/P-1 0 0 0 218.0

RECORDKEEPING REQUIREMENTS

General Recordkeeping Requirements

83. The permittee must maintain the following general records of testing and monitoring required by this

permit: [OAR 340-218-0050(b)(A)]

83.a. The date, place as defined in the permit, and time of sampling or measurements;

83.b. The date(s) analyses were performed;

83.c. The company or entity that performed the analyses;

83.d. The analytical techniques or methods used;

83.e. The results of such analyses;

83.f. The operating conditions as existing at the time of sampling or measurement; and

83.g. The records of quality assurance for continuous monitoring systems (including but not limited to

quality control activities, audits, calibration drift checks).

84. Recordkeeping requirements must commence on the date of permit issuance unless otherwise specified in

the permit or an applicable requirement. [OAR 340-218-0050(3)(b)(C)]

85. Unless 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) may 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 10% of the 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 may not be considered a missing record. [340-212-0160, OAR 340-214-0110,

and 340-218-0050(3)(b)]

86. Unless 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



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permit. All existing records required by the previous Air Contaminant Discharge Permit must also be

retained for five (5) years. [OAR 340-218-0050(b)(B)]

Source Specific Recordkeeping Requirements

87. The permittee must maintain the following specific records of required monitoring:

87.a. Records of emergency RICE maintenance and operating requirements (Condition 60.f);

87.b. Complaint log (Condition 68);

87.c. Weekly facility excess fugitive emissions inspections and corrective action (Condition 69);

87.d. Records of the facility inspection and maintenance activities (Condition 70);

87.e. Records of all air pollution episodes and emission reduction actions (Condition 71);

87.f. Daily pressure drop across the composite mesh pad when the chrome electroplating tank is

operating (Conditions 72 and 73);

87.g. Monthly and/or quarterly visible emissions observation reports and corrective action log for

emissions units PV, CF, CT1, CT2, V, O, and K; (Condition 74);

87.h. Daily visible emissions observations, number and duration of excursions, and corrective action, if

required, for emissions units BH1 and FD; (Condition 75)

87.i. Quarterly baghouse inspection and corrective action log (Condition 76);

87.j. Boiler G opacity as measured by the COMS (Condition 77);

87.k. Hourly records of the steam produced in hog fuel Boiler G while burning non-resinated fuel

(Conditions 78 and 80.c);

87.l. Hourly records of the steam produced in hog fuel Boiler G while burning resinated fuel

(Conditions 78 and 80.c);

87.m. Hourly records of Boiler G residual oxygen (Condition 78);

87.n. Hourly records of Boiler G opacity, number and duration of excursions, and corrective action if

necessary (Condition 79);

87.o. Monthly and annual records of the natural gas combusted in NGCD (Condition 80);

87.p. Weekly records of the type of fuel burned in boiler G (Condition 80);

87.q. Monthly and annual records of material throughput (BDT) for the baghouses (BH1), and Cyclones

(CF, CT1, CT2);

87.r. Monthly and annual records of the following (Condition 81.a):

87.r.i. Steam produced in Boiler G (1000 lbs);

87.r.ii. MM-T lumber production (MBF);

87.r.iii. WFD-O door skin production (MSF – 1/8” basis); and

87.r.iv. Natural gas burned (MMCF)

87.s. Monthly and annual records of VOC containing raw materials (gallons), density of raw material

(lb/gal), and VOC content (% by weight or lbs/gallon);

87.t. Annual emissions as a 12-month rolling total, calculate within 14 days after the end of each month

for the previous 12 months.

87.u. Occurrence and length of downtime for all pollution control devices;

87.v. Source test reports; and

87.w. Excess emissions

Chromium NESHAP Recordkeeping Requirements

88. Unless a waiver from recordkeeping requirements has been granted in accordance with 40 CFR 63.10(f),

the permittee must fulfill all recordkeeping requirements outlined in this section. [40 CFR 63.346]

88.a. The permittee must maintain the following records for such source:

88.a.i. Inspection records for the add-on air pollution control device, if such a device is used,

and monitoring equipment, to document that the inspection and maintenance required

by the work practice standards of Condition 17 have taken place. The record can take

the form of a checklist and should identify the device inspected, the date of



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inspection, a brief description of the working condition of the device during the

inspection, and any actions taken to correct deficiencies found during the inspection.

88.a.ii. Records of all maintenance performed on the affected source, the add-on air pollution

control device, and monitoring equipment, except routine housekeeping practices;

88.a.iii. Records of the occurrence, duration, and cause (if known) of each malfunction of

process, add-on air pollution control, and monitoring equipment;

88.a.iv. Records of actions taken during periods of malfunction to minimize emissions in

accordance with Condition 14, including corrective actions to restore malfunctioning

process and air pollution control and monitoring equipment to its normal or usual

manner of operation;

88.a.v. Other records, which may take the form of checklists, necessary to demonstrate

consistency with the provisions of the operation and maintenance plan required by

Condition 17.c;

88.a.vi. Test reports documenting results of all performance tests;

88.a.vii. All measurements as may be necessary to determine the conditions of performance

tests;

88.a.viii. Records of monitoring data required by Condition 72 that are used to demonstrate

compliance with the standard including the date and time the data are collected;

88.a.ix. The specific identification (i.e., the date and time of commencement and completion)

of each period of excess emissions, as indicated by monitoring data, that occurs

during malfunction of the process, add-on air pollution control, or monitoring

equipment;

88.a.x. The specific identification (i.e., the date and time of commencement and completion)

of each period of excess emissions, as indicated by monitoring data, that occurs

during periods other than malfunction of the process, add-on air pollution control, or

monitoring equipment;

88.a.xi. The total process operating time of the affected source during the reporting period;

88.a.xii. Any information demonstrating whether a source is meeting the requirements for a

waiver of recordkeeping or reporting requirements, if the source has been granted a

waiver under 40 CFR 63.10(f) of Subpart A; and

88.a.xiii. All documentation supporting the notifications and reports required by 40 CFR 63.9

and 40 CFR 63.10 of Subpart A and Condition 100.

88.b. The permittee must maintain all information (including all reports and notifications) required by

40 CFR Part 63 recorded in a form suitable and readily available for expeditious inspection and

review. The files must be retained for at least 5 years following the date of each occurrence,

measurement, maintenance, corrective action, report, or record. At a minimum, the most recent 2

years of data must be retained on site. The remaining 3 years of data may be retained off site.

Such files may be maintained on microfilm, on a computer floppy disk, on magnetic tape disk, or

on microfiche.

Surface Coating of Miscellaneous Metal Parts and Wood Products NESHAP Recordkeeping Requirements

89. The permittee must collect and keep records of the data and information required by this condition. Failure

to collect and keep these records is a deviation from the applicable standard.

89.a. A copy of each notification and report that the permittee submitted to comply with the Surface

Coating of Miscellaneous Metal Parts and Wood Products NESHAPs (40 CFR Part 63, Subpart

MMMM and QQQQ). [40 CFR 63.3930(a) and 63.4730(a)]

89.b. A current copy of information provided by materials suppliers or manufacturers, such as

manufacturer’s formulation data, or test data used to determine the mass fraction of organic HAP

and density for each coating, thinner and/or other additive, and cleaning material, and the volume

fraction of coating solids for each coating. If the permittee conducted testing to determine mass

fraction of organic HAP, density, or volume fraction of coating solids, the permittee must keep a

copy of the complete test report. If the permittee uses the information provided by the



Page 42 of 67

manufacturer or supplier of the material that was based on testing, the permittee must keep the

summary sheet of results provided to the permittee by the manufacturer or supplier. The permittee

is not required to obtain the test report or other supporting documentation from the manufacturer

or supplier. [40 CFR 63.3930(b) and 63.4730(b)]

89.c. For each compliance period, the permittee must keep the following records:

89.c.i. A record of the coating operations on which the permittee used each compliance

option and the time periods (beginning and ending dates and times) for each option

the permittee used. [40 CFR 63.3930(c)(1) and 63.4730(c)(1)]

89.c.ii. For the compliant material option, a record of the calculation of the organic HAP

content for each coating, using Equation 2 of 40 CFR 63.3941. [40 CFR

63.3930(c)(2) and 63.4730(c)(2)]

89.d. A record of the name and volume of each coating, thinner and/or other additive, and cleaning

material used during each compliance period. If the permittee is using the compliance material

option for all coatings at the source, the permittee may maintain purchase records for each material

used rather than a record of the volume used. [40 CFR 63.3930(d) and 63.4730(d)]

89.e. A record of the mass fraction of organic HAP for each coating, thinner and/or other additive, and

cleaning material used during each compliance period unless the material is tracked by weight.

[40 CFR 63.3930(e) and 63.4730(e)]

89.f. A record of the volume fraction of coating solids for each coating used during each compliance

period. [40 CFR 63.3930(f) and 63.4730(f)]

89.g. The permittee must keep records of the date, time and duration of each deviation. [40 CFR

63.3930(j) and 63.4730(j)]

90. The permittee must keep the records identified in Condition 89 as follows: [40 CFR 63.3931 and 63.4731]

90.a. The records must be in a form suitable and readily available for expeditious review, according to

40 CFR 63.10(b)(1). Where appropriate, the records may be maintained as electronic spreadsheets

or as a database.

90.b. As specified in 40 CFR 63.10(b)(1), the permittee must keep each record for 5 years following the

date of each occurrence, measurement, maintenance, corrective action, report or record.

90.c. 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 according to 40 CFR 63.10(b)(1).

The permittee must keep the records off-site for the remaining 3 years.

REPORTING REQUIREMENTS

General Reporting Requirements

91. Excess Emissions Reporting: The permittee must report all excess emissions as follows: [OAR 340-214-

0300 through 340-214-0360]

91.a. Immediately (within 1 hour of the event or by 10:00 am the next business day if the event occurs

outside of normal administrative hours) notify DEQ of an excess emission event by phone, e-mail

or facsimile using form R1006; and

91.b. Within 15 days of the excess emissions event, submit a written report using form R1007 that

contains the following information: [OAR 340-214-0340(1)]

91.b.i. The date and time of the beginning of the excess emissions event and the duration or

best estimate of the time until return to normal operation;

91.b.ii. The date and time the owner or operator notified DEQ of the event;

91.b.iii. The equipment involved;

91.b.iv. Whether the event occurred during planned startup, planned shutdown, scheduled

maintenance, or as a result of a breakdown, malfunction or emergency;

91.b.v. Steps taken to mitigate emissions and corrective action taken, including whether the



Page 43 of 67

approved procedures for a planned startup, shutdown or maintenance activity were

followed;

91.b.vi. The magnitude and duration of each occurrence of excess emissions during the course

of an event and the increase over normal rates or concentrations as determined by

continuous monitoring or best estimate (supported by operating data and

calculations);

91.b.vii. The final resolution of the cause of the excess emissions; and

91.b.viii. Where applicable, evidence supporting any claim that emissions in excess of

technology-based limits were due to any emergency pursuant to OAR 340-214-0360.

91.c. In the event of any excess emissions which are of a nature that could endanger public health and

occur during non-business hours, weekends or holidays, the permittee must immediately notify

DEQ by calling the Oregon Emergency Response System (OERS). The current number is 1-800-

452-0311.

91.d. If startups, shutdowns or scheduled maintenance may result in excess emissions, the permittee

must submit startup, shutdown or scheduled maintenance procedures used to minimize 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 of the excess emission event. The permittee must abide by the approved procedures

and have a copy available at all times.

91.e. The permittee must notify DEQ of planned startup/shutdown or scheduled maintenance events.

91.f. The permittee must continue to maintain a log of all excess emissions in accordance with OAR

340-214-0340(3). However, the permittee is not required to submit the detailed log with the semi-

annual and annual monitoring reports. The permittee is only required to submit a brief summary

listing the date, time, and the affected emissions units for each excess emission that occurred

during the reporting period. [OAR 340-218-0050(3)(c)]

92. Permit Deviations Reporting: The permittee must promptly report deviations from permit requirements

that do not cause excess emissions, including 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 within 15 days of the deviation. Deviations that cause excess emissions, as specified in

OAR 340-214-0300 through 340-214-0360 must be reported in accordance with Condition 91.

93. The permittee must submit any required source test report within 45 days after the source test; unless

otherwise approved in the source test plan. [OAR 340-218-0050(3)(c)(C) and 340-028-1100]

94. All required reports must be certified by a responsible official consistent with OAR 340-218-0040(5);

[OAR 340-218-0050(3)(c)(D)]

95. Reporting requirements must commence on the date of permit issuance unless otherwise specified in the

permit. [OAR 340-218-0050(3)(c)(E)]

Semi-Annual and Annual Reporting Requirements

96. The permittee must submit three (3) copies of reports of any required monitoring at least every 6 months,

completed on forms approved by DEQ. Six month periods are January 1 to June 30, and July 1 to

December 31. Two copies of the report must be submitted to the DEQ regional office and one copy to the

EPA. All instances of deviations from permit requirements must be clearly identified in such reports.

[OAR 340-218-0050(3)(c)(A) and 340-218-0080(6)(d)]

96.a. The first semi-annual report shall be due on July 30 and must include the semi-annual compliance

certification, OAR 340-218-0080 and the information identified in Conditions 38.c, 97.f, 97.g and

97.h.

96.b. The annual report shall be due on March 15 and must consist of the following:



Page 44 of 67

96.b.i. The emission fee report; [OAR 340-220-0100]

96.b.ii. The second semi-annual compliance certification; and [OAR 340-218-0080]

96.b.iii. The information identified in Condition 97.

97. The following information must be included in the annual report:

97.a. Annual records of total steam produced in Boiler G;

97.b. Annual records of fuel combusted in NGCD;

97.c. Annual records of total hardboard pressed on a 1/8” basis;

97.d. Annual records of total raw lumber production;

97.e. Annual records of total amount of VOC containing materials used along with the VOC percent;

97.f. Summary of the number and duration of emissions units BH1 and FD visible emissions excursions

and brief description of corrective action;

97.g. Summary of the number and duration of boiler G opacity excursions and brief description of

corrective action; and

97.h. Summary of all permit deviations that occurred during the reporting period.

98. 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)]

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

98.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

requirements incorporated by reference. When certifying compliance with requirements

incorporated by reference, the permittee must provide 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;

98.c. The status of compliance with the terms and conditions of the permit for the period covered by the

certification, including whether compliance during the period was continuous or intermittent. The

certification must be based on the method or means designated in Condition 98.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 defined under OAR 340-200-

0020 and 40 CFR Part 64 occurred; and

98.d. Such other facts as DEQ may require to determine the compliance status of the source.

98.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:

99. If the calendar year emission rate of greenhouse gases (CO2e) 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 340-218-0040(5).

Chromium NESHAP Reporting Requirements:



Page 45 of 67

100. Unless a waiver from reporting requirements has been granted in accordance with 40 CFR 63.10(f), the

permittee must fulfill all reporting requirements outlined in Conditions 101 through 104 and any reporting

requirements contained in an extension of compliance granted under 40 CFR 63.6(i). These reports must

be made to the Administrator at the appropriate address as identified in 40 CFR 63.13 of Subpart A, or to

the delegated State authority. Reports required by Subpart A of 40 CFR Part 63 and this permit may be

sent by U.S. mail, fax, or by another courier.

100.a. Submittals sent by U.S. mail must be postmarked on or before the specified date.

100.b. Submittals sent by other methods must be received by the Administrator on or before the specified

date.

100.c. If acceptable to both the Administrator and the permittee, reports may be submitted on electronic

media.

101. Notification of performance test. [40 CFR 63.347(d)]

101.a. The permittee must notify the Administrator in writing of his or her intention to conduct a

performance test at least 60 calendar days before the test is scheduled to begin to allow the

Administrator to have an observer present during the test. Observation of the performance test by

the Administrator is optional.

101.b. In the event the permittee is unable to conduct the performance test as scheduled, due to

unforeseeable circumstances beyond his or her control, the permittee must notify the

Administrator within 5 days prior to the scheduled performance test date and specify the date

when the performance test is rescheduled.

102. Notification of compliance status. [40 CFR 63.347(e)]

102.a. A notification of compliance status is required each time that an affected source becomes subject

to the requirements of this subpart.

102.b. If the State in which the source is located has not been delegated the authority to implement the

rule, each time a notification of compliance status is required under this part, the permittee must

submit to DEQ and the Administrator a notification of compliance status, signed by the

responsible official (as defined in 40 CFR 63.2) who must certify its accuracy, attesting to whether

the affected source has complied with 40 CFR Part 63 Subpart N. If the state has been delegated

the authority, the notification of compliance status must be submitted to the appropriate permitting

authority. The notification must list for each affected source:

102.b.i. The applicable emission limitation and the methods that were used to determine

compliance with this limitation;

102.b.ii. If a performance test is required, the test report documenting the results of the

performance test, which contains the elements required by 40 CFR §63.344;

102.b.iii. The type and quantity of hazardous air pollutants emitted by the source reported in

mg/dscm;

102.b.iv. For each monitored parameter for which a compliant value is to be established under

Condition 72, the specific operating parameter value, or range of values, that

corresponds to compliance with the applicable emission limit;

102.b.v. The methods that will be used to determine continuous compliance, including a

description of monitoring and reporting requirements, if methods differ from those

identified in this subpart;

102.b.vi. A description of the air pollution control technique for each emission point;

102.b.vii. A statement that the permittee has completed and has on file the operation and

maintenance plan as required by the work practice standards in Condition 17;

102.b.viii. A statement by the permittee as to whether the source has complied with the

provisions of 40 CFR Part 63 Subpart N.

102.c. The notification of compliance status must be submitted to the Administrator no later than 90



Page 46 of 67

calendar days following completion of the compliance demonstration required by 40 CFR 63.7 of

Subpart A.

103. Reports of performance test results. [40 CFR 63.347(f)]

103.a. If the State in which the source is located has not been delegated the authority to implement the

rule, the permittee must report to DEQ and the Administrator the results of any performance test

conducted as required by 40 CFR 63.7 or Condition 102. If the State has been delegated the

authority, the permittee should report performance test results to DEQ.

103.b. Reports of performance test results must be submitted no later than 90 days following the

completion of the performance test, and must be submitted as part of the notification of

compliance status required by Condition 102.

103.c. Results of performance tests must also be reported in accordance with 40 CFR 63.347(f).

104. Ongoing compliance status reports for major sources. [40 CFR 63.347(g)]

104.a. The permittee must submit a summary report to DEQ and the Administrator to document the

ongoing compliance status of the affected source. The report must contain the information

identified in Condition 104.c, and must be submitted semiannually except when:

104.a.i. The Administrator determines on a case-by-case basis that more frequent reporting is

necessary to accurately assess the compliance status of the source; or

104.a.ii. The monitoring data collected by the permittee in accordance with Condition 72 show

that the emission limit has been exceeded, in which case quarterly reports must be

submitted. Once the permittee reports an exceedance, ongoing compliance status

reports must be submitted quarterly until a request to reduce reporting frequency

under Condition 104.b is approved.

104.b. Request to reduce frequency of ongoing compliance status reports.

104.b.i. The permittee, if required to submit ongoing compliance status reports on a quarterly

(or more frequent basis), may reduce the frequency of reporting to semiannual if all of

the following conditions are met:

104.b.i.A. For 1 full year (e.g., 4 quarterly or 12 monthly reporting periods),

the ongoing compliance status reports demonstrate that the affected

source is in compliance with the relevant emission limit;

104.b.i.B. The permittee continues to comply with all applicable

recordkeeping and monitoring requirements of 40 CFR Part 63

Subpart A and Subpart N; and

104.b.i.C. The Administrator does not object to a reduced reporting frequency

for the affected source, as provided in Conditions 104.b.ii and

104.b.iii.

104.b.ii. The frequency of submitting ongoing compliance status reports may be reduced only

after the permittee notifies the Administrator in writing of his or her intention to make

such a change, and the Administrator does not object to the intended change. In

deciding whether to approve a reduced reporting frequency, the Administrator may

review information concerning the source's entire previous performance history

during the 5-year recordkeeping period prior to the intended change, or the

recordkeeping period since the source's compliance date, whichever is shorter.

Records subject to review may include performance test results, monitoring data, and

evaluations of an owner or operator's conformance with emission limitations and

work practice standards. Such information may be used by the Administrator to make

a judgment about the source's potential for noncompliance in the future. If the

Administrator disapproves the permittee's request to reduce reporting frequency, the

Administrator will notify the permittee in writing within 45 days after receiving

notice of the permittee's intention. The notification from the Administrator to the

permittee will specify the grounds on which the disapproval is based. In the absence



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of a notice of disapproval within 45 days, approval is automatically granted.

104.b.iii. As soon as the monitoring data required by Condition 72 show that the source is not

in compliance with the relevant emission limit, the frequency of reporting must revert

to quarterly, and the permittee must state this exceedance in the ongoing compliance

status report for the next reporting period. After demonstrating ongoing compliance

with the relevant emission limit for another full year, the permittee may again request

approval from the Administrator to reduce the reporting frequency as allowed by

Condition 104.b.

104.c. Contents of ongoing compliance status reports: The permittee must prepare a summary report to

document the ongoing compliance status of the source. The report must contain the following

information:

104.c.i. The company name and address of the affected source;

104.c.ii. An identification of the operating parameter that is monitored for compliance

determination, as required by Condition 72;

104.c.iii. The relevant emission limitation for the affected source, and the operating parameter

value, or range of values, that correspond to compliance with this emission limitation

as specified in the notification of compliance status required by Condition 102;

104.c.iv. The beginning and ending dates of the reporting period;

104.c.v. A description of the type of process performed in the affected source;

104.c.vi. The total operating time of the affected source during the reporting period;

104.c.vii. A summary of operating parameter values, including the total duration of excess

emissions during the reporting period as indicated by those values, the total duration

of excess emissions expressed as a percent of the total source operating time during

that reporting period, and a breakdown of the total duration of excess emissions

during the reporting period into those that are due to process upsets, control

equipment malfunctions, other known causes, and unknown causes;

104.c.viii. A certification by a responsible official, as defined in 40 CFR 63.2 of Subpart A, that

the work practice standards in Condition 17 were followed in accordance with the

operation and maintenance plan for the source;

104.c.ix. If the operation and maintenance plan required by Condition 17.c was not followed,

an explanation of the reasons for not following the provisions, an assessment of

whether any excess emission and/or parameter monitoring exceedances are believed

to have occurred, and a copy of the report(s) required by Condition 17.f documenting

that the operation and maintenance plan was not followed;

104.c.x. A description of any changes in monitoring, processes, or controls since the last

reporting period;

104.c.xi. 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. The report must also include a

description of actions taken by an owner or operator during a malfunction of an

affected source to minimize emissions in accordance with Condition 14, including

actions taken to correct a malfunction.

104.c.xii. The name, title and signature of the responsible official who is certifying the accuracy

of the report; and

104.c.xiii. The date of the report.

Surface Coating of Miscellaneous Metal Parts and Wood Products NESHAPs Reporting Requirements:

105. The permittee must submit semi-annual compliance certification reports required by 40 CFR 63.3920(a)

and 63.4720(a). The permittee may submit the reports along with, or as part of, the semiannual compliance

certification reports required by Condition 96. The following information must be included with the

semiannual report if the permittee submits it as part of the semiannual compliance certification required by

Condition 96: [40 CFR 63.3920(a)]



Page 48 of 67

105.a. If there are no deviations from the emission limitations in Conditions 19 and 28, the semiannual

compliance report must include a statement that there were no deviations from the emission

limitations during the reporting period. [40 CFR 63.3920(a)(4) and 63.4620(a)(4)]

105.b. If there was a deviation from the applicable organic HAP content requirements in Condition 19

and 28, the semiannual compliance report must contain the following information: [40 CFR

63.3920(a)(5) and 63.4620(a)(5)]

105.b.i. Identification of each coating used that deviated from the applicable emission limit,

and each thinner and/or other additive, and cleaning material used that contained

organic HAP, and the dates and time periods each was used;

105.b.ii. The calculation of the organic HAP content (using the equation in Conditions 25.d

and 34.d) for each coating identified in Condition 105.b.i.; the permittee does not

need to submit background data supporting this calculation (e.g., information

provided by coating suppliers or manufacturers, or test reports);

105.b.iii. The determination of mass fraction of organic HAP for each thinner and/or other

additive, and cleaning material identified in Condition 105.b.i. The permittee does

not need to submit background data supporting this calculation (e.g., information

provided by coating suppliers or manufacturers, or test reports); and

105.b.iv. A statement of the cause of each deviation.

Reporting Addresses:

DEQ – Eastern Region


Bend, OR 97702

(541) 388-6146

DEQ – Air Quality Division

811 SW Sixth Avenue

Portland, OR 97204

(503) 229-5359

Air Operating Permits

US Environmental Protection Agency

1200 Sixth Avenue, Suite 900

Seattle, WA 98101

NON-APPLICABLE REQUIREMENTS

106. Requirements specifically identified below are not applicable to the source for the reason(s) stated. [OAR

340-218-0110]

106.a. Surface coating of miscellaneous metal parts and products NESHAP (40 CFR Part 63,

Subpart MMMM): The permittee is an existing source that is using the compliant material

option for complying with 40 CFR Part 63, Subpart MMMM. Therefore, the following

requirements are not applicable to the source:

63.3883(a), (c) and (d)

63.3890(a) and (c)

63.3891(b) and (c)

63.3892

63.3893

63.3900(a)(2) and (c)

63.3910(b) – the initial notification was submitted on November 20, 2006

63.3910(c)(7)(iv)

63.3910(c)(8)(ii) and (iii)

63.3910(c)(9), (10) and (11)

63.3920(a)(6) and (7)

63.3920(b) and (c)

63.3930(c)(3) and (4)

63.3930(g), (h) and (k)

63.3942(a), last sentence

63.3950 through 63.3968 (these compliance options are not used by the permittee)



Page 49 of 67

106.b. Surface coating of wood products NESHAP (40 CFR Part 63, Subpart QQQQ): The

permittee is an existing source that is using the compliant material option for complying with the

40 CFR Part 63, Subpart QQQQ. Therefore, the following requirements are not applicable to the

source:

63.4683(a), (c) and (d)

63.4690(a) and (c)

63.4691(b) and (c)

63.4692 (b) and (c)

63.4693 (b), (c) and (d)

63.4700(a)(2), (c) and (d)

63.4710(b) – the initial notification was submitted on November 20, 2006

63.4710(c)(7)(iv), (c)(8)(ii), (c)(8)(iii), (c)(9), (10) and (11)

63.4720(a)(6) and (7)

63.4720(b) and (c)

63.4730(c)(3) and (4)

63.4730(g), (h) and (k)

63.4750 through 63.4768 (these compliance options are not used by the permittee)

106.c. Unless modified or reconstructed, Boiler G is not subject NSPS Subparts Db and Dc because the

heat input capacity is less than 100 million Btu/hr and construction of the boiler commenced prior

to June 9, 1989. In addition, only the provisions in Subpart Dc that pertain to the combustion of

natural gas apply to Boiler N or its replacement.

106.d. This facility is no longer a major source of hazardous air pollutants (HAPs). Therefore, Boiler G

is not subject to the MACT standards in 40 CFR Part 63, Subpart DDDDD.

GENERAL CONDITIONS

G1. 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 if the 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.



Page 50 of 67

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 and re-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 and re-

issuance, or modification; or for denial of a permit renewal application.

b. Any schedule of compliance for applicable requirements with which the source is not in

compliance at the time 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 timely basis unless a more detailed schedule is expressly required by

the applicable requirement.

G5. Masking Emissions

The permittee may not install or use any device or other means designed to mask the emission of an air

contaminant 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

Notwithstanding any other provisions contained in any applicable requirement, any credible evidence may

be used for the purpose of establishing whether a person has violated or is in 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 DEQ or EPA pursuant to this permit must contain certification by a responsible

official of truth, accuracy and completeness. All certifications must state that based on information and

belief formed after reasonable inquiry, the statements and information in the document are true, accurate

and complete. The permittee must promptly, upon discovery, report to DEQ 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 conducting open burning, 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

conducting any renovation or demolition activities at the facility.

G10. Stratospheric Ozone and Climate Protection [40 CFR 82 Subpart F, OAR 340-260-0040]



Page 51 of 67

The permittee must comply with the standards for recycling and emissions reduction pursuant to 40 CFR

Part 82, Subpart F, Recycling and Emissions Reduction.

G11. Permit Shield [OAR 340-218-0110]

a. Compliance with the conditions of the permit is deemed compliance with any applicable

requirements as of the date of permit issuance provided that:

i. such applicable requirements are included and are specifically identified in the permit, or

ii. DEQ, in acting on the permit application or revision, determines in writing that other

requirements specifically identified are not applicable to the source, and the permit

includes the determination or a concise summary thereof.

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 DEQ);

ii. the liability of an owner or operator of a source 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 DEQ to obtain information from a source pursuant to ORS 468.095

(investigatory authority, entry on premises, status of records).

c. Sources are not shielded from applicable requirements that are enacted during 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 DEQ.

G12. 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

DEQ of Environmental 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 source 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 permit or applicable requirements.

G13. Fee Payment [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 all regulated air pollutants except

for carbon monoxide, any class I or class II substance subject to a standard promulgated under or

established by Title VI of the Federal Clean Air Act, or any pollutant that is a regulated air pollutant solely

because it is subject to a standard or regulation under section 112(r) of the Federal Clean Air Act. The

permittee must submit payment to DEQ of Environmental Quality, Business Office, 811 SW 6th Avenue,

Portland, OR 97204, within 30 days of the date DEQ 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 DEQ of Environmental Quality. Payment must be made regardless of the dispute.



Page 52 of 67

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 Source [OAR 340-218-0140(2)]

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

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

defined in OAR 340-200-0020.

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

DEQ 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 G11 does not extend to off-permit changes.

G15. Section 502(b)(10) Changes to the Source [OAR 340-218-0140(3)]

a. The permittee must monitor for, and record, any section 502(b)(10) change to the source, which is

defined 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 DEQ and the EPA in accordance

with OAR 340-218-0140(3)(b).

c. The permit shield of Condition G11 does not extend to section 502(b)(10) changes.

G16. 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.

G17. 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.

G18. Significant Permit Modification [OAR 340-218-0180]



Page 53 of 67

The permittee must submit an application for a significant permit modification in accordance with OAR

340-218-0180

G19. Staying Permit Conditions [OAR 340-218-0050(6)(c)]

Notwithstanding Conditions G16 and G17, the filing of a request by the permittee for a permit

modification, revocation and re-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]

The permittee must obtain approval from DEQ prior to construction or modification of any stationary

source or air pollution control equipment in accordance with OAR 340-210-0200 through OAR 340-210-

0250.

G21. 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 DEQ 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. Duty to Provide Information [OAR 340-218-0050(6)(e) and OAR 340-214-0110]

The permittee must furnish to DEQ, within a reasonable time, any information that DEQ 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 DEQ copies

of records required to be retained by the permit or, for information claimed to be confidential, the permittee

may furnish such records to DEQ 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 Department.

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 of this 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]



Page 54 of 67

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 DEQ requests an earlier submittal. If more than 12 months is required to process a permit

renewal application, DEQ 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(1)(d)]

The permit is not transferable to any person except as provided in OAR 340-218-0150(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 of federal, 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 of the Oregon Title V Operating Permit

and must provide a copy of the permit to DEQ or an authorized representative upon request.

ALL INQUIRIES SHOULD BE DIRECTED TO:

DEQ - Eastern Region


Bend, OR 97702

(541) 388-6146



Page 55 of 67

ATTACHMENT 1

Cross-reference from New Rule Numbers to Old Rule Numbers (Effective March 24, 2003)

New Rule

Number

Old Rule

Number

208-0110 021-0015

208-0200 021-0055

208-0210 021-0060

214-0300 028-1400

214-0310 028-1410

214-0320 028-1420

214-0330 028-1430

214-0340 028-1440

214-0350 028-1450

214-0360 028-1460

218-0010 028-2100

218-0020 028-2110

218-0040 028-2120

218-0050 028-2130

218-0060 028-2140

218-0070 028-2150

218-0080 028-2160

218-0090 028-2170

218-0100 028-2180

218-0110 028-2190

218-0120 028-2200

218-0130 028-2210

218-0140 028-2220

218-0150 028-2230

New Rule

Number

Old Rule

Number

218-0160 028-2240

218-0170 028-2250

218-0180 028-2260

218-0190 028-2270

218-0200 028-2280

218-0210 028-2290

218-0220 028-2300

218-0230 028-2310

218-0240 028-2320

218-0250 028-1790

220-0010 028-2560

220-0030 028-2580

220-0040 028-2590

220-0050 028-2600

220-0060 028-2610

220-0070 028-2620

220-0080 028-2630

220-0090 028-2640

220-0100 028-2650

220-0110 028-2660

220-0120 028-2670

220-0130 028-2680

220-0140 028-2690

220-0150 028-2700

New Rule

Number

Old Rule

Number

220-0160 028-2710

220-0170 028-2720

220-0180 028-2730

220-0190 028-2740

256-0200 024-0100

256-0300 024-0300

256-0310 024-0306

256-0320 024-0307

256-0330 024-0308

256-0340 024-0309

256-0350 024-0312

256-0360 024-0314

256-0370 024-0318

256-0380 024-0320

256-0390 024-0325

256-0400 024-0330

256-0410 024-0332

256-0420 024-0335

256-0430 024-0337

256-0440 024-0340

256-0450 024-0355

256-0460 024-0357

256-0470 024-0360

264-0010 023-0022

New Rule

Number

Old Rule

Number

264-0020 023-0025

264-0030 023-0030

264-0040 023-0035

264-0050 023-0040

264-0060 023-0042

264-0070 023-0043

264-0080 023-0045

264-0100 023-0055

264-0110 023-0060

264-0120 023-0065

264-0130 023-0070

264-0140 023-0075

264-0150 023-0080

264-0160 023-0085

264-0170 023-0090

264-0180 023-0100

264-0190 023-0105

264-0200 023-0115



Page 56 of 67

ATTACHMENT 2

Emission Factors for Hazardous Air Pollutants

HAP

Boiler G

(lb/1000 lb

steam)

Natural Gas

Combustion

(lb/mmscf)

Fiber

Dryers/Press

Vents/Biofilter

(lb/MSF)

Kilns

(lb/MBF)

Veneer

Dryer

(lb/MSF)

Acenaphthene 1.32E-06 1.80E-06

Acenaphthylene 7.25E-06 1.80E-06

Acetaldehyde 1.20E-03 7.25E-04 1.13E-01 1.50E-03

Acetophenone 4.64E-09

Acrolein 5.80E-03 8.39E-04 1.60E-03

Anthracene 4.35E-06 2.40E-.06

Benzaldehyde 1.23E-06

Benzene 6.09E-03 2.10E-03

Benzo(a)anthracene 9.43E-08 1.80E-06

Benzo(a)pyrene 3.77E-06 1.20E-06

Benzo(a)fluoranthene 1.45E-07 1.80E-06

Benzo(g,h,i)perylene 1.35E-07 1.20E-06

Benzo(k)fluoroanthene 5.22E-08 1.80E-06

Benzoic acid 6.82E-08

bis(2-ethylhexyl)phthalate 6.82E-08

Bromomethane 2.18E-05

Carbazole 2.61E-06

Carbon tetrachloride 6.53E-05

Chlorine 1.15E-03

Chlorobenzene 4.79E-05

Chloroform 4.06E-05

Chloromethane 3.34E-05

3-chloronaphthalene 3.48E-09

2-chlorophenol 3.48E-08

Chrysene 5.51E-08 1.80E-06

Crotonaldehyde 1.44E-05

Decachlorobiphenyl 3.92E-10

Dibenzo(a,h)anthracene 1.32E-08 1.20E-06

1,2-dibromoethene 7.98E-05

Dichlorobenzene

1.20E-06

Dichlorobiphenyl 1.07E-09

1,2 Dichloroethane 4.21E-05

Dichloromethane 4.21E-04

1,2 Dichloropropane 4.79E-05

7,12-demethylbenz(a)anthracene

1.60E-05

2,4 Dinitrophenol 2.61E-07

Dioxin&furans 2.42E-06

Ethylbenzene 4.50E-05

Fluoranthene 2.32E-06

Fluorene 4.93E-06 2.80E-06

Formaldehyde 6.38E-03 7.50E-02 8.82E-04 2.90E-03 3.50E-04

Heptachlorobiphenyl 9.57E-11

Hexachlorobiphenyl 7.98E-10

Hexanal 1.02E-05



Page 57 of 67

HAP

Boiler G

(lb/1000 lb

steam)

Natural Gas

Combustion

(lb/mmscf)

Fiber

Dryers/Press

Vents/Biofilter

(lb/MSF)

Kilns

(lb/MBF)

Veneer

Dryer

(lb/MSF)

Hexane

1.80E+00

Hydrogen chloride 2.76E-02

Indeno(1.2,3,c,d)pyrene 1.26E-07 1.80E-06

Isobutyraldehyde 1.74E-05

MDI

4.99E-03

Methanol

1.55E-03 6.50E-02 2.70E-03

2-methylnaphthalene 2.32E-07 2.40E-03

3-methylchloroanthrene

1.80E-06

Monochlorobiphenyl 3.19E-10

Naphthalene 1.41E-04 6.10E-04

2-nitrophenol 3.48E-07

4-Nitrophenol 1.60E-07

Pentachlorobiphenyl 1.74E-09

Pentachlorophenol 7.40E-08

Perylene 7.54E-10

Phenanthrene 1.02E-05 1.70E-05

Phenol 7.40E-05 1.73E-03

Propionaldehyde 8.85E-05 5.88e-04 1.00E-03

Pyrene 5.37E-06 5.00E-06

Styrene 2.76E-03

Tetrachlorobiphenyl 3.63E-09

Tetrachloroethene 5.51E-05

o-tolualdehyde 1.04E-05

p-tolualdehyde 1.60E-05

Toluene 1.33E-03 3.40E-03

Trichlorobiphenyl 3.77E-09

1,1,1-trichloroethane 4.50E-05

trichloroethene 4.35E-05

Trichlorofluoromethane 5.95E-05

2,4,6-trichlorophenol 3.19E-08

vinyl chloride 2.61E-05

o-xylene 3.63E-05

Antimony 1.15E-05

Arsenic 3.19E-05 2.00E-04

Beryllium 1.60E-06 1.20E-05

Cadmium 5.95E-06 1.10E-03

Chromium 3.05E-05 1.40E-03

Cobalt 9.43E-06 8.40E-05

Lead 6.96E-05 5.00E-04

Manganese 2.32E-03 3.80E-04

Mercury 5.08E-06 2.60E-04

Nickel 4.79E-05 2.10E-03

Selenium 4.06E-06 2.40E-05



Page 58 of 67

ATTACHMENT 3

NESHAP General Provisions Applicability (Table to Subpart N, Table 2 to subpart MMMM, and Table 4 of Subpart QQQQ)

General

Provision

Subpart

N

Subpart

MMMM

Subpart

QQQQ Comment

63.1(a)(1). Yes Yes Yes Additional terms defined in Sec. 63.341; when overlap between Subparts A and N occurs, Subpart N takes

precedence.

63.1(a)(2) Yes Yes Yes


63.1(a)(4) Yes Yes Yes Subpart N clarifies the applicability of each paragraph in Subpart A to sources subject to Subpart N.





63.1(a)(11) Yes Yes Yes Sec. 63.347(a) of Subpart N also allows report submissions via fax and on electronic media.

63.1(a)(12)-(14) Yes Yes Yes

63.1(b)(1) No Yes Yes Sec. 63.340 of Subpart N specifies applicability. Applicability of Subpart MMMM is also specified in 63.3881.

Applicability to Subpart QQQQ is specified in 63.4681.

63.1(b)(2) Yes Yes Yes

63.1(b)(3) No Yes Yes This provision in Subpart A is being deleted. Also, all affected area and major sources are subject to Subpart N;

there are no exemptions.

63.1(c)(1) Yes Yes Yes Subpart N clarifies the applicability of each paragraph in Subpart A to sources subject to Subpart N.

63.1(c)(2) Yes No No Subpart N specifies permit requirements for area sources. Area sources are not subject to Subparts MMMM and

QQQQ.



Page 59 of 67

General

Provision

Subpart

N

Subpart

MMMM

Subpart

QQQQ Comment

63.1(c)(3) No No Area sources are not subject to Subparts MMMM and QQQQ

63.1(c)(4) Yes Yes Yes

63.1(c)(5) No Yes Yes Subpart N clarifies that an area source that becomes a major source is subject to the requirements for major sources.

63.1(e) Yes Yes Yes

63.2 Yes Yes Yes

Additional terms defined in Sec. 63.341; when overlap between Subparts A and N occurs, Subpart N takes

precedence. Additional definitions for Ssubpart MMMM are specified in §63.3981. Additional definitions for

Subpart QQQQ are specified in §63.4781.

63.3 Yes Yes Yes Other units used in Subpart N are defined in that subpart.

63.4 Yes Yes Yes

63.5(a) Yes Yes Yes Except replace the term ``source'' and ``stationary source'' in Sec. 63.5(a)(1) and (2) of Subpart A with `àffected

resources.''


63.5(b)(3) Yes Yes Yes Applies only to major affected sources.

63.5(b)(4) No Yes Yes Subpart N (Sec. 63.345) specifies requirements for the notification of construction or reconstruction for affected

sources that are not major.



63.5(d)(1)(i) No Yes Yes Sec. 63.345(c)(5) of Subpart N specifies when the application or notification shall be submitted.

63.5(d)(1)(ii) Yes Yes Yes Applies to major affected sources that are new or reconstructed.

63.5(d)(1)(iii) Yes Yes Yes Except information should be submitted with the Notification of Compliance Status required by Sec. 63.347(e) of

Subpart N.



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Subpart

N

Subpart

MMMM

Subpart

QQQQ Comment

63.5(d)(2) Yes Yes Yes

Applies to major affected sources that are new or reconstructed except: (1) replace ``source'' in Sec. 63.5(d)(2) of

Subpart A with `àffected source''; and (2) actual control efficiencies are submitted with the Notification of

Compliance Status required by Sec. 63.347(e).

63.5(d)(3)-(4) Yes Yes Yes Applies to major affected sources that are new or reconstructed.

63.5(e) Yes Yes Yes Applies to major affected sources that are new or reconstructed.

63.5(f)(1) Yes Yes Yes Except replace ``source'' in Sec. 63.5(f)(1) of Subpart A with `àffected source.''

63.5(f)(2) No Yes Yes New or reconstructed affected sources shall submit the request for approval of construction or reconstruction under

Sec. 63.5(f) of Subpart A by the deadline specified in Sec. 63.345(c)(5) of Subpart N.

63.6(a) Yes Yes Yes

63.6(b)(1)-(2) Yes Yes Yes Except replace ``source'' in Sec. 63.6(b)(1)-(2) of part A with `àffected source.'' Section 63.3883 specifies the

compliance dates for Subpart MMMM. Section 63.4683 specifies the compliance dates for Subpart QQQQ.

63.6(b)(3)-(4) Yes Yes Yes

63.6(b)(5) Yes Yes Yes Except replace ``source'' in Sec. 63.6(b)(5) of Subpart A with `àffected source.''

63.6(b)(7) No Yes Yes Provisions for new area sources that become major sources are contained in Sec. 63.343(a)(4) of Subpart N.

63.6(c)(1)-(4) Yes Yes Yes Except replace ``source'' in Sec. 63.6(c)(1)-(2) of Subpart A with `àffected source.'' Section 63.3883 specifies the

compliance dates for Subpart MMMM. Section 63.4683 specifies the compliance dates for Subpart QQQQ.

63.6(c)(5) No Yes Yes Compliance provisions for existing area sources that become major sources are contained in Sec. 63.343(a)(3) of

Subpart N.

63.6(e)(1)-(2) No Yes Yes Sec. 63.342(f) of Subpart N contains work practice standards (operation and maintenance requirements) that

override these provisions.

63.6(e)(3) No No JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ standards.

63.6(f)(1) No No No Sec. 63.342(b) of Subpart N specifies when the standards apply. JELD-WEN is not using a control device to comply

with Subpart MMMM and QQQQ standards.



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General

Provision

Subpart

N

Subpart

MMMM

Subpart

QQQQ Comment

63.6(f)(2)(i)-(ii) Yes Yes Yes

63.6(f)(2)(iii) No Yes Yes Sec. 63.344(b) of Subpart N specifies instances in which previous performance test results for existing sources are

acceptable.

63.6(f)(2)(iv) Yes Yes Yes

63.6(f)(2)(v) Yes Yes Yes

63.6(f)(3) Yes Yes Yes

63.6(g) Yes Yes Yes

63.6(h) No No No Subparts N, MMMM and QQQQ do not contain any opacity or visible emission standards.

63.6(i)(1) Yes Yes Yes

63.6(i)(2) Yes Yes Yes Except replace ``source'' in Sec. 63.6(i)(2)(i) and (ii) of Subpart A with `àffected source.''


63.6(i)(4)(i) No Yes Yes Sec. 63.343(a)(6) of Subpart N specifies the procedures for obtaining an extension of compliance and the date by

which such requests must be submitted.

63.6(i)(4)(ii) Yes Yes Yes


63.6(i)(6)(i) Yes Yes Yes This paragraph only references ``paragraph (i)(4) of this section'' for compliance extension provisions. But, Sec.

63.343(a)(6) of Subpart N also contains provisions for requesting a compliance extension.

63.6(i)(6)(ii) Yes Yes Yes


63.6(i)(8) Yes Yes Yes This paragraph only references ``paragraphs (i)(4) through (i)(6) of this section'' for compliance extension

provisions. But, Sec. 63.343(a)(6) of Ssubpart N also contains provisions for requesting a compliance extension.



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General

Provision

Subpart

N

Subpart

MMMM

Subpart

QQQQ Comment


This paragraph only references ``paragraphs (i)(4) through (i)(6) of this section'' and ``paragraphs (i)(4) and (i)(5) of

this section'' for compliance extension provisions. But, Sec. 63.343(a)(6) of Subpart N also contains provisions for

requesting a compliance extension.

63.6(i)(10)(i)-(iv) Yes Yes Yes

63.6(i)(10)(v)(A) Yes Yes Yes This paragraph only references `'paragraph (i)(4)'' for compliance extension provisions. But, Sec. 63.343(a)(6) of

Subpart N also contains provisions for requesting a compliance extension.

63.6(i)(10)(v)(B) Yes Yes Yes


63.6(i)(12)(i) Yes Yes Yes This paragraph only references ``paragraph (i)(4)(i) or (i)(5) of this section'' for compliance extension provisions.

But, Sec. 63.343(a)(6) of Subpart N also contains provisions for requesting a compliance extension.

63.6(i)(12)(ii)-

(iii) Yes Yes Yes




63.6(j) Yes Yes Yes


This applies to all affected sources. Additional requirements for performance testing are specified in 63.3964,

63.3965, and 63.3966 of Subpart MMMM. Additional requirements for performance testing are specified in

63.4764, 63.4765, and 63.4766 of Subpart QQQQ.

63.7(a)(2)(i)-(vi) Yes No No JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ standards.

63.7(a)(2)(ix) Yes No No JELD-WEM is not using a control device to comply with Subpart MMMM and QQQQ standards.




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Subpart

N

Subpart

MMMM

Subpart

QQQQ Comment

63.7(b)(1) No No No

Sec. 63.347(d) of Subpart N requires notification prior to the performance test. Sec. 63.344(a) of Subpart N requires

submission of a site-specific test plan upon request. JELD-WEN is not using a control device to comply with

Subpart MMMM and QQQQ standards.

63.7(b)(2) Yes No No JELD-WEN is not using a control device to comply with Subpart MMMM standards.

63.7(c) No No No

Sec. 63.344(a) of Subpart N specifies what the test plan should contain, but does not require test plan approval or

performance audit samples. JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ

standards.

63.7(d) Yes No No Except replace ``source'' in the first sentence of Sec. 63.7(d) of Subpart A with `àffected source.'' JELD-WEN is

not using a control device to comply with Subpart MMMM and QQQQ standards.

63.7(e) Yes No No Subpart N also contains test methods specific to affected sources covered by that subpart. JELD-WEN is not using a

control device to comply with Subpart MMMM and QQQQ standards.

63.7(f) Yes Yes Yes Sec. 63.344(c)(2) of Subpart N identifies CARB Method 425 as acceptable under certain conditions. For subpart

MMMM and QQQQ, this applies to all test methods except those used to determine capture system efficiency.

63.7(g)(1) No No No

Subpart N identifies the items to be reported in the compliance test [Sec. 63.344(a)] and the timeframe for

submitting the results [Sec. 63.347(f)]. JELD-WEN is not using a control device to comply with Subpart MMMM

and QQQQ standards.

63.7(g)(3) Yes No No JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ standards.

63.7(h)(1)-(2) Yes No No JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ standards.

63.7(h)(3)(i) Yes No No

This paragraph only references ``Sec. 63.6(i)'' for compliance extension provisions. But, Sec. 63.343(a)(6) of

Subpart N also contains provisions for requesting a compliance extension. JELD-WEN is not using a control device

to comply with Subpart MMMM and QQQQ standards.

63.7(h)(3)(ii)-(iii) Yes No No JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ standards.

63.7(h)(4)-(5) Yes No No JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ standards.

63.8(a)(1) Yes No No JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ standards.



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General

Provision

Subpart

N

Subpart

MMMM

Subpart

QQQQ Comment

63.8(a)(2) No No No Work practice standards are contained in Sec. 63.342(f) of Subpart N. JELD-WEN is not using a control device to

comply with Subpart MMMM and QQQQ standards.

63.8(a)(3) No No JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ standards.

63.8(a)(4) No No No Subparts MMMM and QQQQ do not have additional monitoring requirements.


63.8(b)(2) No Yes Yes Sec. 63.344(d) of Subpart N specifies the monitoring location when there are multiple sources.

63.8(b)(3) No Yes Yes Sec. 63.347(g)(4) of Subpart N identifies reporting requirements when multiple monitors are used.

63.8(c)(1)(i) No No No Subpart N requires proper maintenance of monitoring devices expected to be used by sources subject to Subpart N.

JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ standards.

63.8(c)(1)(ii) No No No Sec. 63.342(f)(3)(iv) of Subpart N specifies reporting when the O&M plan is not followed. JELD-WEN is not using

a control device to comply with Subpart MMMM and QQQQ standards.

63.8(c)(1)(iii) No No No Sec. 63.343(f)(2) identifies the criteria for whether O&M procedures are acceptable. JELD-WEN is not using a

control device to comply with Subpart MMMM and QQQQ standards.

63.8(c)(2)-(3) No No No Sec. 63.344(d)(2) requires appropriate use of monitoring devices. JELD-WEN is not using a control device to

comply with Subpart MMMM and QQQQ standards.

63.8(c)(4)-(7) No No No JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ standards and Subpart

MMMM and QQQQ do not have opacity standards.

63.8(c)(8) No No JELD-WEN is not using a control device to comply with Subpart MMMM and QQQQ standards.

63.8(d) No No No Maintenance of monitoring devices is required by Secs. 63.342(f) and 63.344(d)(2) of Subpart N. Subparts MMMM

and QQQQ do not require the use of continuous emissions monitoring systems.

63.8(e) No No No There are no performance evaluation procedures for the monitoring devices expected to be used to comply with

subpart N. Subparts MMMM and QQQQ do not require the use of continuous emissions monitoring systems.




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General

Provision

Subpart

N

Subpart

MMMM

Subpart

QQQQ Comment

63.8(f)(2) No Yes Yes Instances in which the Administrator may approve alternatives to the monitoring methods and procedures of Subpart

N are contained in Sec. 63.343(c)(8) of Subpart N.




63.8(f)(6) No No No Subpart N does not require the use of CEM's. Subparts MMMM and QQQQ do not require the use of continuous

emissions monitoring systems.

63.8(g) No No No

Monitoring data does not need to be reduced for reporting purposes because Subpart N requires measurement

once/day. Section 63.3967 and 63.3968 of Subpart MMMM specify monitoring data reduction. Section 63.4767

and 63.4768 of Subpart QQQQ specify monitoring data reduction.

63.9(a) Yes Yes Yes

63.9(b)(1)(i)-(ii) No Yes Yes Sec. 63.343(a)(3) of Subpart N requires area sources to comply with major source provisions if an increase in HAP

emissions causes them to become major sources.

63.9(b)(1)(iii) No Yes Yes Sec. 63.347(c)(2) of Subpart N specifies initial notification requirements for new or reconstructed affected sources.

63.9(b)(2) No Yes Yes Sec. 63.347(c)(1) of Subpart N specifies the information to be contained in the initial notification.

63.9(b)(3) No Yes Yes Sec. 63.347(c)(2) of Subpart N specifies notification requirements for new or reconstructed sources that are not

major affected sources.

63.9(b)(4) No Yes Yes

63.9(b)(5) No Yes Yes

63.9(c) Yes Yes Yes

This paragraph only references ``Sec. 63.6(i)(4) through Sec. 63.6(i)(6)'' for compliance extension provisions. But,

Sec. 63.343(a)(6) of Subpart N also contains provisions for requesting a compliance extension. Subpart N provides

a different timeframe for submitting the request than Sec. 63.6(i)(4).

63.9(d) Yes Yes Yes This paragraph only references ``the notification dates established in paragraph (g) of this section.'' But, Sec. 63.347

of Subpart N also contains notification dates.



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General

Provision

Subpart

N

Subpart

MMMM

Subpart

QQQQ Comment

63.9(e) No No No Notification of performance test is required by Sec. 63.347(d) of Subpart N. JELD-WEN is not using a control

device to comply with Subpart MMMM and QQQQ standards.

63.9(f) No No No Subparts MMMM and QQQQ do not have opacity or visible emissions standards.

63.9(g) No No No Subpart N does not require a performance evaluation or relative accuracy test for monitoring devices. Subparts

MMMM and QQQQ do not require the use of continuous emissions monitoring systems.

63.9(h)(1)-(3) No Yes Yes Sec. 63.347(e) of Subpart N specifies information to be contained in the notification of compliance status and the

timeframe for submitting this information.

63.9(h)(5) No Yes Yes

Similar language has been incorporated into Sec. 63.347(e)(2)(iii) of Subpart N. Section 63.3910 of Subpart

MMMM specifies the dates for submitting the notification of compliance status. Section 63.4710 of Subpart QQQQ

specifies the dates for submitting the notification of compliance status.

63.9(h)(6) Yes Yes Yes

63.9(i) Yes Yes Yes

63.9(j) Yes Yes Yes

63.10(a) Yes Yes Yes

63.10(b)(1) Yes Yes Yes Additional requirements are specified in 63.3930 and 63.3931 of Subpart MMMM. Additional requirements are

specified in 63.4730 and 63.4731 of Subpart QQQQ.

63.10(b)(2)(i)-(v) No No No Sec. 63.346(b) of Subpart N specifies the records that must be maintained. JELD-WEN is not using a control device

to comply with Subpart MMMM and QQQQ standards.

63.10(b)(2)(vi)-

(xi) Yes Yes

63.10(b)(2)(xii) Yes Yes

63.10(b)(2)(xiii) No No Subparts MMMM and QQQQ do not require the use of continuous emissions monitoring systems.

63.10(b)(2)(xiv) Yes Yes



Page 67 of 67

General

Provision

Subpart

N

Subpart

MMMM

Subpart

QQQQ Comment

63.10(b)(3) No Yes Yes Subpart N applies to major and area sources.

63.10(c)(1)-(6) No Yes Yes Applicable requirements of Sec. 63.10(c) have been incorporated into Sec. 63.346(b) of Subpart N.

63.10(c)(7)-(8) No No For subparts MMMM and QQQQ, the same records are required in 63.3920(a)(7) and 63.4720(a)(7); respectively.

63.10(c)(9)-(15) Yes Yes

63.10(d)(1) Yes Yes Yes For Subpart MMMM, additional requirements are specified in 63.3920. For Subpart QQQQ, additional

requirements are specified in 63.4720.

63.10(d)(2) No Yes Yes

Sec. 63.347(f) of Subpart N specifies the timeframe for reporting performance test results. For Subpart MMMM,

additional requirements are specified in 63.3920(b). For Subpart QQQQ, additional requirements are specified in

63.4720(b).

63.10(d)(3) No No No Subpart N, MMMM and QQQQ do not contain opacity or visible emissions standards.

63.10(d)(4) Yes Yes Yes

63.10(d)(5) No No No Sec. 63.342(f)(3)(iv) and Sec. 63.347(g)(3) of Subpart N specify reporting associated with malfunctions. JELD-

WEN is not using a control device to comply with Subpart MMMM and QQQQ standards.

63.10(e)(1)-(2) No No No

Sec. 63.347(g) and (h) of Subpart N specify the frequency of periodic reports of monitoring data used to establish

compliance. Applicable requirements of Sec. 63.10(e) have been incorporated into Sec. 63.347(g) and (h). Subparts

MMMM and do not require the use of continuous emissions monitoring systems.

63.10(e)(3) No No No Section 63.3920(b) of Subpart MMMM specifies the contents of periodic compliance reports. Section 63.4720(b) of

Subpart QQQQ specifies the contents of periodic compliance reports.

63.10(3)(4) No No No Subparts MMMM and QQQQ do not specify requirements for opacity or COMS.

63.10(f) Yes Yes Yes

63.11 No No No Flares will not be used to comply with the emission limits for Subparts N, MMMM and QQQQ.

63.12-63.15 Yes Yes Yes For Subpart QQQQ, test Methods ANSI/ASME PTC 19.10-1981, Part 10, ASTM D2697-86 (re-approved 1998),

and ASTM D6093-97 (incorporated by reference, see 63.14).

Documents

Oregon Title V Operating Permit Number: 18-0006-TV-01 Expiration Date: 02/01/2018 Page 1 of 67 OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY OREGON TITLE V OPERATING PERMIT Eastern Region