Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 1 of 19
Revised 5/19/04
OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY
OREGON TITLE V OPERATING PERMIT
REVIEW REPORT Northwest Region
2020 SW Fourth Avenue, Suite 400
Portland, OR 97201
Source Information:
SIC 2421, 4961 Source Categories (Part and code) B.64
NAICS 321113,
321912,
221330
Compliance and Emissions
Monitoring Requirements:
Unassigned emissions COMS X
Emission credits CEMS
Compliance schedule Ambient monitoring
Source test X
Reporting Requirements:
Annual report (due date) 3/15 Monthly report (due dates)
Emission fee report (due date) 3/15 Excess emissions report X
SACC (due date) 7/30 Other reports X
Quarterly report (due dates)
Air Programs:
NSPS (list subparts) Dc Title V X
NESHAP (list subparts) DDDD ACDP (SIP)
CAM Major HAP source X
Regional Haze (RH) Federal major source X
Synthetic Minor (SM) NSR
Part 68 Risk Management PSD
CFC Acid Rain
RACT Clean Air Mercury Rule (CAMR)
TACT
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 2 of 19
Revised 5/19/04
TABLE OF CONTENTS
PERMITTEE IDENTIFICATION ................................................................................................................................ 6
FACILITY DESCRIPTION .......................................................................................................................................... 6
EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING ......................... 9
PLANT SITE EMISSION LIMITS ............................................................................................................................. 13
HAZARDOUS AIR POLLUTANTS .......................................................................................................................... 14
GENERAL BACKGROUND INFORMATION ......................................................................................................... 15
COMPLIANCE HISTORY ......................................................................................................................................... 15
SOURCE TEST RESULTS ......................................................................................................................................... 16
PUBLIC NOTICE ....................................................................................................................................................... 17
EMISSIONS DETAIL SHEETS ................................................................................................................................. 19
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 3 of 19
Revised 5/19/04
LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT
AQMA Air Quality Management Area
ASTM American Society of Testing and
Materials
BDT bone dry ton
CEMS continuous emissions monitoring
system
CFR Code of Federal Regulations
CMS continuous monitoring system
CO carbon monoxide
COMS continuous opacity monitoring
system
DEQ Oregon Department of
Environmental Quality
dscf dry standard cubic feet
EF emission factor
EPA United State Environmental
Protection Agency
EU emissions unit
FCAA Federal Clean Air Act
gr/dscf grains per dry standard cubic feet
HAP hazardous air pollutant
ID identification code
I&M inspection and maintenance
MB material balance
Mlb 1000 pounds
MM million
NA not applicable
NESHAP National Emission Standard for
Hazardous Air Pollutants
NOx oxides of nitrogen
NSPS New Source Performance Standard
NSR New Source Review
O2 oxygen
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
PSD Prevention of Significant
Deterioration
PSEL Plant Site Emission Limit
SO2 sulfur dioxide
ST source test
VE visible emissions
VMT vehicle mile traveled
VOC volatile organic compound
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 4 of 19
Revised 5/19/04
INTRODUCTION
1. The Department proposes to renew the Title V Air Operating Permit issued to the Weyerhaeuser
Corporation Warrenton Sawmill, in Warrenton, Oregon.
2. In accordance with OAR 340-218-0120(1)(f), this review report is intended to provide the legal and factual
basis for the draft permit conditions. In most cases, the legal basis for a permit condition is included in the
permit by citing the applicable regulation. In addition, the factual basis for the requirement may be the
same as the legal basis. However, when the regulation is not specific and only provides general
requirements, this review report is used to provide a more thorough explanation of the factual basis for the
draft permit conditions.
3. The following changes have been made at the facility during the last permit term:
Date Permit revision or notification Brief explanation
10/23/07 Notice of Construction – Type 1
Application No. 22417
Clean-up conveyor added to planer operation. Deminimus (<
1 tons/yr) emissions. This conveyor improves material
handling in the planer building.
09/23/08 Administrative Amendment
No. 23450
Department initiated modification to the excess emission
reporting rules, and corresponding permit conditions.
12/04/08 Administrative Amendment
No. 23548
Change in Ownership from the Weyerhaeuser Company to
Weyerhaeuser NR.
4. The following is a list of condition-by-condition changes between the previous permit and the proposed
permit:
New Permit
Condition
Number
Old Permit
Condition
Number Description of change Reason for change
Cover Page Cover Page Added NAICS Codes in addition to
SIC Codes
Industry Standard
1 1 No change N/A
2 2 Updated language Template language update
3 3 Updated emission unit descriptions Clarification and better descriptions
4 4 Added fugitive emission control
requirements
Template language update
5 5 Clarified weekly fugitive emission
surveys
Template language update
6 7 No change N/A
7 6 No change N/A
8 8 Updated language Template language update
9 9 Added allowable fuels Template language update
10 10, 19 Updated language Template language update
11 11 No change N/A
12 12, 14 Added emission unit 4-NGB to the
State Opacity requirements.
Clarified that emission unit 4-NGB is
subject to the State opacity
requirements in addition to those in
the NSPS Subpart Dc.
13 13 No change N/A
14 15 No change N/A
15 20 No change N/A
16 14 Separate visible emission monitoring
condition for emission units 1-WH
Clarification for individual emission
units with differing monitoring
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 5 of 19
Revised 5/19/04
New Permit
Condition
Number
Old Permit
Condition
Number Description of change Reason for change
and 6-FUG frequency requirements.
17 14 Separate visible emission monitoring
condition for emission units 2-KLN
and 5-SM
Clarification for individual emission
units with differing monitoring
frequency requirements.
18 21 Deleted reference to cyclones Testing reference not necessary.
19 14, 16, 17 Separate monitoring and operational
requirements for the hog-fuel boiler
(3-HFB)
Clarification for individual emission
unit requirements.
20 17 Separate compliance testing
requirement for the hog-fuel boiler
(3-HFB)
Clarification for individual emission
unit requirements. Increase in
frequency based upon past source
test results.
21 14, 17, 18, 19 Separate monitoring and operational
requirements for the natural gas
boiler (4-NGB). Add condition 21.b.
for NSPS opacity monitoring
requirements.
Clarification for individual emission
unit requirements.
22 17 Separate compliance testing
requirement for the natural gas boiler
(4-NGB).
Clarification for individual emission
unit requirements.
23 14.e No substantive change – reference to
each applicable monitoring condition.
N/A
24 22, 23 Updated language Template language update
25 24 PSEL updated Increases due to correction of
emission factors
26 25 Updated emission factor and added
reference to calculation condition
Source test results indicated increase
in Pm/PM10 3-HFB EF; added
reference for SO2 for 4-NGB.
27 26 Deleted ―Type 1‖ reference Designation not necessary, and
confusing with ASTM Grade 1 and 2
oil.
28 27 Updated emission factor verification
testing requirements for boilers,
deleted reference to kiln (2-KLN)
testing, and changed frequencies.
Increased PM testing frequency
based upon past source test results
for 3-HFB, added VOC testing once
per permit term based upon testing
guidance.
29 -- New condition for emission fees
related to TRAACS data base.
Template language update
30 29 Added reference to NSPS testing
requirements for 4-NGB; clarified
language
Clarified testing requirement
references for federal NSPS rules;
template language update
31 30.a No substantive change N/A - Template language update
32 30.b No substantive change N/A - Template language update
33 30.c No substantive change N/A - Template language update
34 31.a No change N/A
35 31.c No change N/A
36 31.d No change N/A
37 31.e No change N/A
38 31.b. Updated recordkeeping requirements
to match condition changes and
Clarified recordkeeping requirements
with permit changes
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 6 of 19
Revised 5/19/04
New Permit
Condition
Number
Old Permit
Condition
Number Description of change Reason for change
added condition numbers as reference
39 35 and
Administrative
Amendment
No. 23450
Condition No. 1
Excess Emission reporting now
includes written follow-up within 15
days of occurrence.
Rule change
40 36 Notification changed from 7 days to
15 days
Rule change
41 -- Added necessary condition Condition required per rule
42 38, 39 No substantive change Consolidated two conditions into
one.
43 32 Reduced number of copies of reports Consolidation of reporting
44 33 No change N/A
45 37 No change N/A
46 -- Added necessary condition Condition required per rule
47 40 No change N/A
General
Conditions
G1- G29
General
Conditions
G1 – G27
Conditions G3 and G5 are new Departmental Program update
PERMITTEE IDENTIFICATION
5. The permittee is the Weyerhaeuser Corporation Warrenton Sawmill, located at 550 NE Skipanon Drive,
Warrenton, Oregon, 97146.
FACILITY DESCRIPTION
6. The Weyerhaeuser-Warrenton is a sawmill that processes wood logs to make commercial grade lumber.
Site activities include debarking, saw cutting, shipping, planning, and drying the lumber in 7 drying kilns.
The kilns are heated by steam, which is provided by one wood-fired boiler with a supplementary natural
gas burner, and one natural gas-fired boiler that can use number 1 & 2 diesel fuel oil for backup.
EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION
7. The emissions units at this facility are the following:
EU ID Emission Unit Description
1-WH Unpaved roads
2-KLN Dry Kilns
3-HFB Hogged fuel boiler: Boiler 1 - Wellons fuel cell
4-NGB Natural gas boiler: Boiler 2 - Cleaver Brooks,
with #1 or #2 backup fuel oil
5-SM Sawmill and Planer operations:
Baghouses for controlling emissions from wood
residual generating and handling processes.
6-FUG Fugitive emissions from material handling transfers.
7-VOC Volatile organic compound emissions from paints,
coatings, and sealers used for production purposes
8-AGG Aggregate insignificant
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 7 of 19
Revised 5/19/04
1-WH (Wheel Emissions on Unpaved Roads): This emission unit is comprised of fugitive wheel emissions caused
by trucks and equipment. Emissions are total particulate matter (PM) and particulate matter less than 10 microns in
size (PM10).
2-KLN (Dry Kilns): Cut lumber in stacks is loaded into the kilns and dried to reduce moisture content. The kilns
are heated to approximately 190°F using steam generated in the boilers. At this time, the facility dries douglas fir
and hemlock, but is not limited to these wood species. Emissions are volatile organic compounds (VOC), some of
which are Hazardous Air Pollutants (HAPs), and particulate matter (PM/PM10).
3-HFB (Hogged Fuel Boiler): This boiler is a Wellons double cell furnace (fuel cell) boiler equipped with a
multiclone for PM control. It was installed in 1978. It is rated at 40,000 lbs steam/hr or 54 mmbtu/hr. It is also
equipped with a 20 mmbtu/hr natural gas burner in case wet hog fuel or insufficient hog fuel is available for steam
demand. Wood residue (i.e. bark, along with some shavings, chips, sawdust and hogged scrap lumber) generated
from on-site operations is burned in this boiler to generate steam for the wood drying kilns. Incidental quantities of
oil rags, oil booms/absorbents and oily debris from onsite activities are also permitted to be combusted in this boiler.
Emissions are carbon monoxide (CO), sulfur dioxide (SO2), oxides of nitrogen (NOx), VOCs, PM/PM10 and trace
HAPs.
4-NGB (Natural Gas Boiler): This boiler is a Cleaver Brooks boiler rated at 65,000 lbs steam/hr or 62 mmbtu/hr.
The boiler is fired primarily with natural gas, and has the ability to combust distillate oil (ASTM Grades 1 or 2) as
backup fuel in case of a NG curtailment. This boiler configuration supplements steam from the 3-HFB boiler based
upon kiln steam demand. Emissions are CO, SO2, NOx, VOCs, PM/PM10 and trace HAPs.
5-SM (Sawmill Operations): Logs received at the facility undergo a series of woodworking operations, which
compose this emissions unit, including debarking, saw cutting, chipping, and planing. Emissions from this unit are
primarily particulate matter in the form of fugitive wood dust (e.g., sawdust, wood shavings, and sanderdust)
generated as wood residue from woodworking operations. Depending on the woodworking operation, wood dust
may be pneumatically conveyed to a baghouse-controlled cyclone or primary baghouse. Captured wood dust is
either transported to market or burned in the hogged fuel boiler. The emissions from this emissions unit are
PM/PM10. Baghouse 1, (Chips), installed in March 1996, controls emissions from cyclones 1 and 7; baghouse 2,
(Bark Fines), installed April 1996, controls target box (previously considered cyclone 3); and baghouse 3,
(Shavings), installed January 1997, controls two indoor saw centers. Cyclones 2, 4, 5, and 6 have been removed.
6-FUG (Fugitive Emissions from Materials Handling and Transfer): This emissions unit consists of the following
particulate (PM and PM10) fugitive emissions activities and equipment:
a. Bark conveyor
b. Hogged fuel blow pipe to shed
c. Hogged fuel pile front end loader
d. Hogged fuel conveyors
e. Hogged fuel truck unloading
f. Chip conveyors - sawmill
g. Chip surge bins - sawmill
h. Chip shaker - sawmill
i. Planer conveyors
j. Planer chip system
k. Chip barge loading
l. Resaw return conveyor dropout - sawmill
m. Turning chain cleanup conveyor - sawmill
n. Gang/Opt. Board Edger conveyor - sawmill
o. Sawmill conveyors to truck bins - sawmill
p. Sawdust surge bins - sawmill
q. Chip truck loadout bins
r. Hogged fuel and bark truck loadout bins
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 8 of 19
Revised 5/19/04
s. Sawdust truck loadout bins
t. Shavings truck loadout bins
7-VOC (Volatile Organic Compounds for Production Purposes): This emission unit is comprised of the VOC
fraction contained in the paints, coating and sealers used for production purposes, e.g., lumber stenciling and log
marking. The emissions from this emissions unit include a wide range of VOCs (HAP and non-HAP).
8-AGG (Aggregate Insignificant Emissions): A pressure washer is used to wash vehicles and equipment. This
device burns kerosene to produce pressurized steam from water. The emissions resulting from this emission unit are
TSP, PM10, NOX, SO2, CO, VOCs (non-HAP), and trace amounts of HAPs.
8. Categorically insignificant activities include the following:
Constituents of a chemical mixture present at less than 1% by weight of any chemical or compound
regulated under OAR Chapter 340, Divisions 200 through 268, excluding Divisions 248 and 262, or less
than 0.1% by weight of any carcinogen listed in the U.S. Department of Health and Human Service's
Annual Report on Carcinogens when usage of the chemical mixture is less than 100,000 pounds/year
Evaporative and tail pipe emissions from on-site motor vehicle operation
Distillate oil, kerosene, and gasoline fuel burning equipment rated at less than or equal to 0.4 million Btu/hr
Natural gas and propane burning equipment rated at less than or equal to 2.0 million Btu/hr
Office activities
Food service activities
Janitorial activities
Personal care activities
Groundskeeping activities including, but not limited to building painting and road and parking lot
maintenance
On-site laundry activities
On-site recreation facilities
Instrument calibration
Maintenance and repair shop
Automotive repair shops or storage garages
Air cooling or ventilating equipment not designed to remove air contaminants generated by or released
from associated equipment
Refrigeration systems with less than 50 pounds of charge of ozone depleting substances regulated under
Title VI, including pressure tanks used in refrigeration systems but excluding any combustion equipment
associated with such systems
Bench scale laboratory equipment and laboratory equipment used exclusively for chemical and physical
analysis, including associated vacuum producing devices but excluding research and development facilities
Temporary construction activities
Warehouse activities
Accidental fires
Air vents from air compressors
Air purification systems
Continuous emissions monitoring vent lines
Demineralized water tanks
Pre-treatment of municipal water, including use of deionized water purification systems
Electrical charging stations
Fire brigade training
Instrument air dryers and distribution
Process raw water filtration systems
Pharmaceutical packaging
Fire suppression
Blueprint making
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 9 of 19
Revised 5/19/04
Routine maintenance, repair, and replacement such as anticipated activities most often associated with and
performed during regularly scheduled equipment outages to maintain a plant and its equipment in good
operating condition, including but not limited to steam cleaning, abrasive use, and woodworking
Electric motors
Storage tanks, reservoirs, transfer and lubricating equipment used for ASTM grade distillate or residual
fuels, lubricants, and hydraulic fluids
On-site storage tanks not subject to any New Source Performance Standards (NSPS), including
underground storage tanks (UST), storing gasoline or diesel used exclusively for fueling of the facility's
fleet of vehicles
Natural gas, propane, and liquefied petroleum gas (LPG) storage tanks and transfer equipment
Pressurized tanks containing gaseous compounds
Vacuum sheet stacker vents
Emissions from wastewater discharges to publicly owned treatment works (POTW) provided the source is
authorized to discharge to the POTW, not including on-site wastewater treatment and/or holding facilities
Log ponds
Storm water settling basins
Fire suppression and training
Paved roads and paved parking lots within an urban growth boundary
Hazardous air pollutant emissions of fugitive dust from paved and unpaved roads except for those sources
that have processes or activities that contribute to the deposition and entrainment of hazardous air
pollutants from surface soils
Health, safety, and emergency response activities
Emergency generators and pumps used only during loss of primary equipment or utility service due to
circumstances beyond the reasonable control of the owner or operator, or to address a power emergency as
determined by the Department
Non-contact steam vents and leaks and safety and relief valves for boiler steam distribution systems
Non-contact steam condensate flash tanks
Non-contact steam vents on condensate receivers, deaerators and similar equipment
Boiler blowdown tanks
Industrial cooling towers that do not use chromium-based water treatment chemicals
Ash piles maintained in a wetted condition and associated handling systems and activities
Oil/water separators in effluent treatment systems
Combustion source flame safety purging on startup
Broke beaters, pulp and repulping tanks, stock chests and pulp handling equipment, excluding thickening
equipment and repulpers
Stock cleaning and pressurized pulp washing, excluding open stock washing systems
White water storage tanks
EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING
Emission Unit Applicable Requirement Pollutant,
Parameter
Limit/Standard
Facility Wide 340-208-0210(2) Fugitive emissions Minimize
340-208-0300 and 0450 Nuisance No nuisance and/or fallout
340-228-0110(1) #1 distillate oil sulfur
content 0.3% S by weight
340-228-0110(2) #2 distillate oil sulfur
content 0.5% S by weight
1-WH 340-208-0110(2) and (3) Visible emissions 20% opacity
2-KLN 340-208-0110(2) and (3) Visible emissions 20% opacity
3-HFB 340-208-0110(2) and (3) Visible emissions 20% opacity
340-228-0210(1)(b) PM 0.1 gr/dscf corrected to 12% CO2
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 10 of 19
Revised 5/19/04
Emission Unit Applicable Requirement Pollutant,
Parameter
Limit/Standard
340-226-0120(1)(a) Fuels Wood (bark and lumber mill
residue), natural gas, and incidental
amounts of oil rags, oil
booms/absorbents, and oily debris
4-NGB 340-238-0060 and 40 CFR
Part 60 §60.43c( c)
Visible emissions 20% opacity six minute average
27% opacity one six minute period
per hour
340-208-0110(2) and (3) Visible emissions 20% opacity
340-228-0210(1)(b) PM 0.1 gr/dscf corrected to 12% CO2
340-238-0060 and 40 CFR
Part 60 §60.42c(c )
Sulfur content of oil
fuels
0.5 weight percent sulfur
5-SM 340-208-0110(2) and (3) Visible emissions 20% opacity
340-226-0210(1)(b) PM 0.1 gr/dscf
6-FUG 340-208-0110(2) and (3) Visible emissions 20% opacity
Insignificant
activities
340-208-0110 Visible emissions 20% opacity
340-228-0210(b) PM 0.1 gr/dscf (corrected to 12% CO2
for fuel burning equipment
340-226-0210 PM 0.1 gr/dscf
340-226-0310 PM Process weight limit for non-
fugitive, non-fuel burning
equipment
Plant site 340-222-0020 and 0041 PM, PM10, CO, NOX,
SO2, VOC
Annual plant site emission limits
9. Fugitive Emissions - Permit Condition 4: OAR 340-208-0210(2) is a requirement to take reasonable
precautions to minimize fugitive particulate emissions.
a. Testing Requirements: By definition, it is not possible to perform source emission tests on
fugitive emission sources. Therefore, the permit does not include any testing requirements or
compliance test methods.
b. Monitoring requirements - Permit Conditions 5, 16 and 23: Monitoring for this standard consists
of weekly inspections for the presence of fugitive emissions and documenting that reasonable
precautions are being taken to prevent fugitive emissions from occurring.
10. Nuisance - Permit Conditions 6, 7 and 8: These requirements prohibit nuisances (OAR 340-208-0300) and
particulate fallout (OAR 340-208-0450). These requirements are not part of the State Implementation Plan
(SIP) so they are only enforceable by the State. Nuisance conditions must be verified by the Department.
In order to determine whether a nuisance condition may exist, the permittee is required to keep a log of any
complaints (Permit Condition 8). The permittee is also required to respond to the complainant within a
reasonable amount of time and conduct an investigation as to whether any operations under their control
may have caused a nuisance condition.
11. Sulfur Content of Fuel Oil - Permit Conditions 9 and 21.c: OAR 340-228-0110 is a sulfur content limit for
distillate fuel. NSPS Subpart Dc, specifically 40 CFR 60.42c(g) limits sulfur content of any backup oil
combusted in emission unit 4-NGB (the natural gas boiler) to less than 0.5% sulfur by weight. The
permittee only burns distillate oil at the facility so the sulfur limits for other types of liquid fuels are not
included in the permit.
a. Testing Requirements: This is a statewide requirement that applies to fuel users as well as fuel
suppliers, so it should not be possible for the permittee to purchase any fuel containing more sulfur
than specified by the rule. Therefore, the permittee is not required to test the fuel, but they are
required to obtain a certificate from the supplier stating that the fuel meets the specifications. If
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 11 of 19
Revised 5/19/04
they cannot get a certificate, then the permittee would have to analyze a sample of the fuel to show
that it meets the specifications.
b. Monitoring requirements - Permit Conditions 10 and 27: The permittee is required to maintain
records of the sulfur content of the fuel used at the facility, and the quantity combusted in
emission unit 4-NGB.
12. Fugitive road dust, storage piles and material handling requirements (emission units 1-WH and 6-FUG):
The visible emissions standards in OAR 340-208-0110(2) apply to this source of emissions, but the grain
loading standards in OAR 340-229-0210(1) do not apply because the emissions are fugitive.
a. Testing Requirements: Fugitive emission sources cannot be tested, so the permit does not require
any testing.
b. Monitoring Requirements; The Department is requiring a visible emissions survey once a week.
This monitoring consists of a weekly visual survey of the plant. If there are no visible emissions,
then nothing is required. However, if fugitive emissions are detected the permittee must apply
water as required in Condition 4 in the permit, or conduct a modified Method 9 reading within 24
hours, but in any case, take corrective action.
13. Kiln requirements (emission unit 2-KLN): Steam heated lumber drying kilns emit volatile organic
compounds and a small amount of particulate matter. There are no standards for VOC, other than the
PSEL, which is addressed separately. For particulate matter, the general visible emissions standards in
OAR 340-208-0110(2) apply, but the grain loading standards in OAR 340-229-0210(1), do not apply
because the emissions are fugitive.
a. Testing Requirements: Generally, kiln emissions are considered to be fugitive, and fugitive
emission sources cannot be tested, so the permit does not require any testing. However, pilot
study tests have shown that particulate matter emissions from kilns are considerably less than the
grain loading limits, so there is no real concern about compliance. In this case, there is no
evidence to suggest a compliance problem so the permittee is not being required to test the kilns.
b. Monitoring Requirements: The kilns do not have any add-on emission controls so the Compliance
Assurance Monitoring rules do not apply and the general periodic monitoring requirements of
OAR 340-218-0050(3) apply instead. There really is no way for an excess emission to occur, so
the Department is only requiring a visible emissions survey once each week, with the opportunity
to reduce frequency based upon previous, routine compliant readings. This monitoring consists of
surveying the units for visible emissions. If there are no visible emissions, then no further testing
is required. However, if visible emissions are observed for more than 18 seconds during the 6-
minute observation period, then a modified EPA Method 9 test is required to measure the visible
emissions.
14. Sawmill and planer operation requirements (emission unit 5-SM): The baghouses are subject to the 20%
opacity limit in OAR 340-208-0110(2) and the 0.1 gr/dscf emissions limit (OAR 340-226-0210(1)(b)).
a. Testing Requirements: Typically, baghouse emissions are less than the grain loading limits.
According to the Department‘s monitoring guidance, the Department does not require source
testing of equipment that emit less than 5 tons of particulate matter; unless there is a concern about
the compliance status of the equipment. In this case, there is no evidence to suggest a compliance
problem so the permittee is not being required to test the baghouses.
b. Monitoring Requirements: The general periodic monitoring requirements of OAR 340-218-
0050(3) apply instead. Excess emissions from baghouses are typically caused by plugging,
structural damage to the system (i.e., holes in the duct work or bag), or an improper size for the
type and amount of material being handled. As such, a routine inspection program can be useful
in preventing emissions and a routine visible emission survey can be used to verify that the
preventive maintenance is effective. Therefore, the permittee is being required to inspect the
baghouse at least once every other month and perform any necessary maintenance. In addition,
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 12 of 19
Revised 5/19/04
the permittee is required to perform visible emissions monitoring survey once each week, with the
opportunity to reduce frequency based upon previous, routine compliant readings. This
monitoring consists of surveying the units for visible emissions. If there are no visible emissions,
then no further testing is required. However, if visible emissions are observed for more than 18
seconds during the 6-minute observation period, then a modified EPA Method 9 test is required to
measure the visible emissions.
15. Hog-fueled Boiler requirements (emission unit 3-HFB): The applicable requirements are OAR 340-208-
0110(2) and 340-208-0110(3)(a) (20% opacity). The grain loading standard for this boiler is 0.1 gr/dscf at
12% CO2 (340-228-0210(1)(b)).
a. Testing Requirements: This permit renewal requires a source test of this boiler for particulate
matter for compliance and emission factor verification purposes. This compliance testing is
required in the first and fifth year of the permit term. Increased testing frequency is being
required, as past testing has indicated a need to limit steaming rate in order to maintain compliance
with the grain loading standard. Testing is also required for NOx, CO and VOC for emission
factor verification purposes once during the permit term.
b. Monitoring Requirements: The permittee is required to perform visible emissions monitoring
survey once each week using modified EPA Method 9, with the opportunity to reduce frequency
based upon previous, routine compliant readings. If there are no visible emissions, then no further
testing or actions are required. However, if visible emissions are observed for more than 18
seconds during the 6-minute observation period, then corrective actions to correct the problem
causing the opacity exceedance are required. The permittee will monitor boiler residual oxygen
and multiclone pressure drop. Furnace O2 will be monitored/displayed per minute and hourly
averages recorded. Corrective action will be taken as soon as possible when the boilers O2 are
operating outside the allowable operating range of 4 to 15 %. Furnace O2 monitoring ensures that
the boilers are operating within a combustion range which promotes good combustion and
minimizes the inlet loading on the multiclone. The multiclone must be inspected annually and
necessary repairs made.
16. Natural Gas Boiler requirements (emission unit 4-NGB): The applicable state requirements are OAR 340-
208-0110(2) and 340-208-0110(3)(a) (20% opacity). The grain loading standard for this boiler is 0.1
gr/dscf at 12% CO2 (340-228-0210(1)(b)). This boiler is subject to the NSPS Subpart Dc regulations,
which include an opacity limit of 20 % opacity (6-minute average), except for one 6-minute period per hour
of not more than 27 % opacity, [40CFR60.43c(c)]. The NSPS also requires a limit on sulfur content of
distillate fuel oil of less than 0.5% by weight. [40CFR60.42c(d)].
a. Testing Requirements: This permit renewal requires a source test of this boiler for particulate
matter for compliance and emission factor verification purposes if the boiler operates on oil
greater than 5% of the operating time annually. If operated only on natural gas or operated with
fuel oil less than 5% of the annual operating time, no PM testing is required. Testing is also
required for NOx and CO for emission factor verification purposes once during the permit term.
b. Monitoring Requirements: The permittee is required to perform visible emissions monitoring
survey once each week using modified EPA Method 9 if this boiler operates on ASTM Grade 1 or
2 fuel oil, with the opportunity to reduce frequency based upon previous, routine compliant
readings for the state opacity requirements. The permittee is required to conduct annual 3-hour
Method 9 tests while operating on oil, with the possibility of more frequent tests based upon
previous readings for the NSPS requirements. The permittee is also required to obtain supplier
certifications for sulfur content in the fuel oil per 40CFR60.42c(h)(1) and 40CFR60.48c(f).
17. National Emission Standards for Hazardous Air Pollutants (NESHAP) – this facility is classified as a major
source of HAPs .
a. 40 CFR Part 63 Subpart DDDD, Plywood and Composite Wood Products, does apply because the
facility is an affected source, i.e. ―lumber kilns located at any facility‖, (40CFR63.2231(a)), and is
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 13 of 19
Revised 5/19/04
a major HAP source (40CFR63.2231(b)), however none of the standards apply to the dry kilns (2-
KLN). Weyerhaeuser did submit an initial notification on January 13, 2005, per the requirements
in §63.9(b),
b. 40 CFR Part 63 Subpart DDDDD, Industrial, Commercial and Institutional Boilers and Process
Heaters, will apply to the facility. It is anticipated that this rule will be promulgated by the EPA
during the permit term, and will be incorporated by appropriate permitting methods upon
applicability.
18. As identified earlier in this Review Report, this facility has insignificant emissions units (IEUs) that include
categorically insignificant activities and aggregate insignificant emissions, as defined in OAR 340-200-
0020. For the most part, the standards that apply to IEUs are for opacity (20% limit) and particulate matter
(0.1 gr/dscf limit). The Department does not consider it likely that IEUs could exceed an applicable
emissions limit or standard because IEUs are generally equipment or activities that do not have any
emission controls (e.g., small natural gas fired space heaters) and do not typically have visible emissions.
Since there are no controls, no visible emissions, and the emissions are less than one ton per year, the
Department does not believe that monitoring, recordkeeping, or reporting is necessary for assuring
compliance with the standards.
PLANT SITE EMISSION LIMITS
19. Provided below is a summary of the baseline emissions rate, netting basis, plant site emission limits, and
emissions capacity.
Pollutant
Baseline
Emission
Rate
(tons/yr)
Netting Basis
Plant Site Emission Limit (PSEL)
Previous
PSEL
(tons/yr)
Proposed
PSEL
(tons/yr)
PSEL
Increase
(tons/yr)
Previous
(tons/yr)
Proposed
(tons/yr)
PM 195 174 195 167 195 28
PM10 153 132 153 121 153 32
CO 59 59 59 134 134 0
NOx 44 44 44 114 114 0
SO2 3 3 3 39 39 0
VOC 28 78 78 111 111 0
a. The baseline emission rate was updated to reflect changes in emission factors, and not baseline
production rates from 1978. This update was done under the previous permit renewal issued in
2004, under application number 017015, as well as this permit renewal. The emission factor for
PM/PM10 for the hog fueled boiler was corrected to reflect actual emissions, and this increases
both PM and PM10 by 20.9 tons/yr. The baseline year emissions are detailed by emission unit in
item 20, below.
b. The netting basis was changed consistent with the changes to the baseline emission rate. There are
no reductions required by rule, reductions in unassigned emissions or emission reduction credits
transferred off site that would cause a reduction in the netting basis as compared to the baseline
emission rate. The only increase approved under New Source Review was for VOC and so that is
the only pollutant for which the netting basis was increased as compared to the baseline emission
rate. Therefore, the baseline emission rate and netting basis are equal for all pollutants other than
VOC.
c. The PSEL increases are a result of correction to emission factors for PM and PM10 for the Hog
Fueled Boiler, Emission Unit 3-HFB, and include these increases plus previous unassigned
emissions, as detailed below:
Pollutant Previous
Unassigned
Increase due to
EF correction
Total Increase
PM 7 21 28
PM10 11 21 32
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 14 of 19
Revised 5/19/04
This is a change to the PSEL solely due to the availability of better emission information, and is
exempt from being considered an increase. These emission increases are due solely to increased
use of equipment that existed during the baseline period, and the increased use was possible
during the baseline period under the baseline configuration. The increase is not due to a physical
change or change in operation. [OAR 340-200-0020(66)(b)(B)]. See the plant site emission
detail sheets for basis.
20. The baseline year emissions have changed to reflect corrected emission factors and changes for this
renewal are bolded. These changes are explained in detail in the Baseline Emissions Detail Sheet, May
2009 Revision, attached:
Emission Unit PM PM10 SO2 NOx CO VOC
1-WH 16.1 6.0 NA NA NA NA
2-KLN 0.5 0.5 NA NA NA 10.4
3-HFB 67.3 67.3 1.6 42.9 58 15.1
4-NGB* NA NA NA NA NA NA
5-SM 62.3 46.7 NA NA NA NA
6-FUG 47.4 31.4 NA NA NA NA
7-VOC NA NA NA NA NA 1
8-AGG 1 1 1 1 1 1
Total 195 153 3 44 59 28
* 4-NGB did not exist at baseline
SIGNIFICANT EMISSION RATE
21. The proposed PSEL is not greater than the previous netting basis as shown below.
Pollutant SER
Requested increase over
netting basis
Increase due to utilizing
capacity that existed in the
baseline period
Increase due to physical changes
or changes in the method of
operation
PM 25 0 28 0
PM10 15 0 32 0
CO 100 751 30 45
NOx 40 701 22 48
SO2 40 36 Generic PSEL
OAR 340-222-0040
Generic PSEL
OAR 340-222-0040
VOC 40 331 23 10
1These values previously were part of an ambient air quality analysis approved by the Department on June 30, 2004.
See permit file for details.
HAZARDOUS AIR POLLUTANTS
HAP EMISSION UNIT TOTAL
2-KLN 3-HFB 4-NGB CHEMICALS
Acetaldehyde 22.43 0.37 0 0 22.79
Acrolein 0.31 1.63 0 0 1.94
Arsenic 0 0.004 7.5E-05 0 0.004
Benzene 0 1.19 7.9E-04 0 1.19
Beryllium 0 3.1E-04 4.5E-06 0 3.2E-04
Bis-phthalate 0 1.3E-05 0 0 1.3E-05
Cadmium 0 1.9E-03 4.1E-04 0 2.3E-03
Carbon tetrachloride 0 0.013 0 0 0.013
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 15 of 19
Revised 5/19/04
HAP EMISSION UNIT TOTAL
2-KLN 3-HFB 4-NGB CHEMICALS
Chlorine 0 0.22 0 0 0.22
Chlorobenzene 0 0.009 0 0 0.009
Chloroform 0 0.008 0 0 0.008
Chromium, total 0 0.012 5.3E-04 0 0.013
Cobalt 0 1.8E-03 3.16E-05 0 0.0019
Dichlorobenzene 0 0 4.5E-04 0 4.5E-04
2,4-Dinitrophenal 0 5.1E-05 0 0 5.1E-05
Ethyl benzene 0 0.009 3.6E-03 0.016 0.029
Formaldehyde 2.24 1.25 0.0282 0 3.52
Hexane 0 0 0.678 0 0.678
Hydrogen chloride 0 0.22 0 0 0.22
Lead 0 0.02 1.9E-04 0 0.02
Manganese 0 2.102 1.43E-04 0 2.103
Mercury 0 8.2E-04 9.8E-05 0 9.2E-04
Methanol 36.23 0.36 0 0.34 36.93
Methyl isobutyl ketone 0 0 0 0.03 0.03
Naphthalene 0 0.027 2.3E-04 0 0.028
Nickel 0 0.0169 7.9E-04 0 0.0177
4-nitrophenol 0 3.1E-05 0 0 3.1E-05
Pentachlorophenol 0 1.4E-05 0 0 1.4E-05
Phenol 0 0.022 0 0 0.022
Polycyclic organic matter 0 5.7E-03 3.4E-05 0 0.006
Propionaldehyde 0.16 0.017 0 0 0.173
Selenium 0 1.3E-03 9.0E-06 0 0.0013
Styrene 0 0.53 0 0 0.53
TCDB-p-dioxin 0 1.3E-07 0 0 1.3E-07
Toluene 0 7.0E-04 1.4E-03 0.15 0.16
Vinyl chloride 0 0 5.1E-03 0 5.1E-03
Xylene 0 0 0.01 0.09 0.1
o-xylene 0 0.007 0 0 0.007
Total 61.37 8.05 0.754 0.626 70.8
GENERAL BACKGROUND INFORMATION
22. Air quality in the Warrenton area meets the National Ambient Air Quality Standards (NAAQS) established
by the US Environmental Protection Agency (EPA) to protect public health. DEQ has determined that the
air emissions from the Weyerhaeuser mill will not result in a violation of those standards.
COMPLIANCE HISTORY
23. There have been no enforcement actions against this permittee since issuance of the current permit on
September 9, 2004.
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 16 of 19
Revised 5/19/04
SOURCE TEST RESULTS
Summarized below are the results of source testing performed during the last permit term:
24. Source Test Summary for the hogged-fuel boiler (3-HFB):
Pollutant/Operating
Parameter
Average Test Values
Test Date July 21, 2004
(Horizon
Engineering)
October 27,
2005
(Horizon
Engineering)
June 1, 2006
(Horizon
Engineering)
June 2, 2006
(Horizon
Engineering)
August 3, 2006
(Horizon
Engineering)
Steam production
rate, lb/hr
36,300 33,000 45,200 39,100 37,800
PM, gr/dscf @ 12%
CO2
0.14 (limit
0.1)
Not tested 0.18 (limit 0.1) 0.20 (limit 0.1) 0.13 (limit 0.1)
PM, lb/Mlb steam 0.45 (permit
EF 0.3)
Not tested 0.51 (permit
EF 0.4)
0.57 (permit
EF 0.4)
0.41 (permit EF
0.4)
Opacity, % 15.4 Not tested Not tested Not tested 7
NOx, lb/Mlb steam 0.32 (permit
EF 0.31)
Not tested Not tested Not tested Not tested
CO, lb/Mlb steam 0.49 (permit
EF 1.0)
Not tested Not tested Not tested Not tested
VOC as CH4, lb/Mlb
steam
VOC total not
tested
H2CO - 0.017
lbs/hr
Not tested Not tested Not tested Not tested
Antimony,
lbs/mmbtu
Not tested 2.7E-06 Not tested Not tested Not tested
Arsenic, lbs/mmbtu Not tested 8.0E-06 Not tested Not tested Not tested
Barium, lbs/mmbtu Not tested 5.2E-05 Not tested Not tested Not tested
Beryllium,
lbs/mmbtu
Not tested 6.0E-06 Not tested Not tested Not tested
Cadmium,
lbs/mmbtu
Not tested 4.1E-06 Not tested Not tested Not tested
Chromium,
lbs/mmbtu
Not tested 1.7E-05 Not tested Not tested Not tested
Cobalt, lbs/mmbtu Not tested 5.9E-06 Not tested Not tested Not tested
Copper, lbs/mmbtu Not tested 9.4E-05 Not tested Not tested Not tested
Lead, lbs/mmbtu Not tested 4.0E-05 Not tested Not tested Not tested
Manganese,
lbs/mmbtu
Not tested 3.1E-03 3.8E-03 Same as 6/1/06 Not tested
Nickel, lbs/mmbtu Not tested 8.4E-06 Not tested Not tested Not tested
Phosphorus,
lbs/mmbtu
Not tested 7.8E-04 Not tested Not tested Not tested
Selenium, lbs/mmbtu Not tested 4.7E-06 Not tested Not tested Not tested
Silver, lbs/mmbtu Not tested 3.4E-07 Not tested Not tested Not tested
Thallium, lbs/mmbtu Not tested 1.6E-06 Not tested Not tested Not tested
Zinc, lbs/mmbtu Not tested 5.7E-04 Not tested Not tested Not tested
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 17 of 19
Revised 5/19/04
25. Source Test Summary for the natural gas boiler (4-NGB)
Pollutant/Operating
Parameter
Average Test Values
Test Date July 22, 2004
(Horizon Engineering)
December 9, 2004
(Horizon Engineering)
Steam production rate, lb/hr 60,500 60,000
NOx, lb/1000 lb steam 0.12 (permit EF 0.206) 0.131(permit EF 0.206)
CO, lb/1000 lb steam 1.12 *(permit EF 0.187) 0.047 (permit EF 0.2)
*The CO emission factor from the July 2004 test was significantly above the emission factor assumed by the permit.
Weyerhaeuser chose to readjust their boiler and retest, which occurred in Dec. 2004. The follow up test showed that
CO emissions were significantly reduced to approximately 20% of the permitted emission factor. Weyerhaeuser
installed a combustion control system on this boiler to ensure that excess oxygen remains close to necessary levels and
CO levels remain below permitted levels and the emission factor.
PUBLIC NOTICE
26. This permit was put out on public notice from May 8, 2009 to June 15, 2009. The only comments that
were received were from Weyerhaeuser NR, and are included in item 28, below. The Department‘s
responses to the company‘s comments are included in item 29, below. The Department requested an
expedited review of 5 day, as there were no substantive or adverse comments during the comment period.
27. A letter from EPA was received June 25, 2009, granting the permit eligibility for issuance.
If the EPA does not object in writing, any person may petition the EPA within 60 days after the expiration
of EPA's 45-day (or 5-day, if granted) review period to make such objection. Any such petition must be
based only on objections to the permit that were raised with reasonable specificity during the public
comment period provided for in OAR 340-218-0210, unless the petitioner demonstrates that it was
impracticable to raise such objections within such period, or unless the grounds for such objection arose
after such period.
28. Weyerhaeuser NR submitted the following comments on the draft permit and review report:
1. Condition 19.c.ii requires that the mill take ―immediate‖ corrective action. Immediate is defined as no
longer than 1 hour. Unless we are misreading the rules, the actually word used in the rules is
―expeditious‖. If you concur, we propose changing ―immediate‖ to ―expeditious‖ for this condition.
2. Condition 19.c.iii does not make complete sense as it seems that the second sentence requires the operator
to average the values recorded, but the condition only requires that one value per shift be recorded. We
think this language would be clearer: ―Excess oxygen must be recorded at least once per shift, at the end of
each shift (e.g., every eight hours). All values recorded during a shift must be averaged to compare against
the action level.‖
3. As an unfortunate sign of the times, we propose that you consider adding a new condition 20.d: ―In the
event the boiler has not operated more than 4,000 hours in the year that testing is due, the source test can be
deferred to the next calendar year in which the boiler operates for more than 1,440 hours. The subsequent
source test would then be due two years after the deferred source test.‖
4. We propose a change to Condition 29 as follows to include the underlined language: ―Emission fees will
be based on Plant Site Emission Limits, unless the permittee elects to report actual emissions for one or
more permitted processes/pollutants or the permittee qualifies for a reduced activity fee payment alternative
under OAR 340-220-0070. If the permittee reports actual emissions or pays reduced fees under OAR 340-
220-0070 for one or more permitted processes/pollutants…‖
5. We propose a change to Condition 39.e as follows to include the underlined language: ―The permittee
must notify the Department of excess emissions resulting from planned startup/shutdown or scheduled
maintenance events in accordance with Condition 39.a.‖
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 18 of 19
Revised 5/19/04
6. Condition 43.b.iv requires an ―unplanned excess emissions event record‖, but condition 39.f says that you
need a brief summary of all excess emissions. We think that 39.f accurately captures the current
requirement and 43.b.iv should be revised to read: ―the excess emissions event summary.‖
7. Based on some research we did we believe that Condition 44.b contains language from an old version of
the permit template that Mark Fisher has acknowledged misstates the requirements. Here is the language
Mark has agreed should be used:
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, and whether such methods or other means
provide continuous or intermittent data. Such methods and other means shall include, at a minimum, the methods
and means required under OAR 340-218-0050(3). ). Note: Certification of compliance with the monitoring
conditions in the permit is sufficient to meet this requirement, except when the permittee must certify compliance
with new applicable conditions that are incorporated by reference. When certifying compliance with new
applicable conditions that are incorporated by reference, the permittee must provide the information required by
this condition. If necessary, the owner or operator also shall 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;
8. Condition 45.b requires that the NSPS reports be submitted on January 30th and July 30th. The NSPS
rules allow DEQ the authority to set those submittals to be due the same date as the semi-annual Title V
reports—an approach that is much less prone to failure. We hope this would be acceptable to you.
9. As you will recall, we have a conversation about baseline and netting basis and as I recall we both were a
bit confused on the best way to handle the changes from the HFB EF update. We ask Tom Wood to review
this and he felt we definitely needed to make some changes. We are providing a redlined version of the RR
to address this issue.
29. The Department‘s responses to Weyerhaeuser‘s comments are below in corresponding order and number:
1. Condition 19.c.i. and 19.c.ii.: The rule referenced in this condition(OAR 340-226-0120(2)(a)(A))
requires ―corrective action as expeditiously as practical….‖. Therefore, the references to
‗immediate‖ are changed to ―expeditious‖; both in sub-conditions 19.c.i. and 19.c.ii., in
accordance with the rule referenced by this condition.
2. Condition 19.c.iii.: The original condition 19.c.iii. was deleted, as the hog-fueled boiler (3-HFB)
has a continuous chart recorder for excess oxygen, and the condition required recording readings
at least once per shift. However, as a result of this comment, condition 21.c.i., for the natural gas
boiler (4-NGB), was modified to clarify the language for recording oxygen readings at least once
per shift.
3. Condition 20: The PM compliance source testing requirement for the hog-fueled boiler (3-HFB)
was changed from first, third, fifth years to the first and fifth year of the permit term, rather than
tie the testing to hours of operation, as was requested by the company. Two tests per permit term
are sufficient to demonstrate compliance with the grain loading and opacity standards for this
boiler.
4. Condition 29: Added reference to reduced activity fee alternatives granted by rule for permit
emission fee payment.
5. Condition 39.e.: Added clarifying language that the Department must be notified of planned
startup/shutdown or scheduled maintenance events only if those events result in excess emissions.
6. Condition 43.b.iv.: Clarified the requirement for annual report submittals regarding unplanned
excess emissions events is only a summary, as required and explained in condition 39.f., rather
than an ―event record‖.
7. Condition 44.b.: The permit template language has been revised to reflect the changes noted by
the company in their comments, and these language changes have been incorporated into this
condition, and better reflect the requirements of determining compliance status with each term and
condition in the permit.
8. Condition 45.b.: The company‘s semi-annual compliance certification is due on August 15th
each
year, and their annual report is due on March 15th
every year. The company is subject to New
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 19 of 19
Revised 5/19/04
Source Performance Standard, Subpart Dc for their natural gas boiler (4-NGB), and this NSPS
requires semi-annual reports that must be postmarked on the 30th
day following the reporting
periods, which are Jan. 1 – June 30, and July 1 – Dec. 31., making the submission dates July 30th
and Jan 30th
, respectively. The NSPS General Provisions, Subpart A, in section 60.19(d), allows
DEQ to change the dates by which periodic NSPS reports are submitted, (without changing the
frequency of reporting) to be consistent with DEQ‘s reporting schedule by mutual agreement
between the company and the DEQ. This request is permitted.
9. Review Report item 19.b.: The Netting Basis was changed consistent with the changes to the
baseline emission rate. There are no reductions required by rule, reductions in unassigned
emissions or emission reduction credits transferred off site that would cause a reduction in the
netting basis as compared to the baseline emission rate. The only increase approved under New
Source Review was for VOC and so that is the only pollutant for which the netting basis was
increases as compared to the baseline emission rate. Therefore, the baseline emission rate and
netting basis are equal for all pollutants other than VOC.
EMISSION DETAIL SHEETS
See Plant Site Emission Detail Sheets and Baseline Emission Detail Sheets.
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 1 of 2
OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY
OREGON TITLE V OPERATING PERMIT
REVIEW REPORT
ADDENDUM NO. 1
ADMINISTRATIVE AMENDMENT
Northwest Region
2020 SW Fourth Avenue, Suite 400
Portland, OR 97201
Mailing Address Plant Site Address
Hampton Lumber Mills, Inc. Hampton Warrenton Lumber Mill
9600 SW Barnes Road, Suite 200 550 NE Skipanon Drive
Portland, OR 97225 Warrenton, OR 97146
Source Information:
SIC 2421, 4961 Source Categories (Part and code) B.64
NAICS 321113,
321912,
221330
Compliance and Emissions
Monitoring Requirements:
Unassigned emissions COMS X
Emission credits CEMS
Compliance schedule Ambient monitoring
Source test X
Reporting Requirements:
Annual report (due date) 3/15 Monthly report (due dates)
Emission fee report (due date) 3/15 Excess emissions report X
SACC (due date) 7/30 Other reports X
Quarterly report (due dates)
Air Programs:
NSPS (list subparts) Dc Title V X
NESHAP (list subparts) DDDD ACDP (SIP)
CAM Major HAP source X
Regional Haze (RH) Federal major source X
Synthetic Minor (SM) NSR
Part 68 Risk Management PSD
CFC Acid Rain
RACT Clean Air Mercury Rule (CAMR)
TACT
Review Report/Permit No.: 04-0041-TV-02
Application number: 023009
Page 2 of 2
PERMIT MODIFICATION REQUEST:
1. On February 4, 2010, Weyerhaeuser NR Company submitted an Administrative
Amendment (MD904), which is assigned Application No. 23977, requesting a change of
ownership for the Warrenton Sawmill from Weyerhaeuser NR Company (Weyerhaeuser)
to Hampton Lumber Mills, Inc. (Hampton).
DEPARTMENT EVALUATION:
2. Per OAR 340-218-0150(1)(d), an administrative amendment is a permit revision that
allows for a change in the ownership or operational control of a source where the
Department determines that no other change in the permit is necessary, provided that a
written agreement containing a specific date for transfer of permit responsibility,
coverage, and liability between the current and new permittee has been submitted to the
Department. By execution of a letter dated January 27, 2010, Hampton and
Weyerhaeuser agreed that Hampton has assumed coverage, responsibility and liability for
the Title V Permit 04-0041, as issued by the Department and signed on June 26, 2009.
Hampton indicated in this letter that they are not proposing to make changes to the
operation of the Warrenton Mill, therefore no changes have been made to the permit
other than the cover page indicating the new ownership.
PUBLIC NOTICE
3. Public Notice is not required for administrative amendments to Oregon Title V Operating
Permits.