jun 3 o 2020

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Permit number: 22-3501-TV-01 Expiration date: 07/01/25

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OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY OREGON TITLE V OPERATING PERMIT

State of oreg:,n Department of Environmental Quality

Part 1 of2

Western Region 4026 Fairview Industrial Drive SE

Salem, OR 97302 Telephone (503) 378-8240

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

ISSUED TO:

Cascade Pacific Pulp, LLC P.O. Box400 Halsey, OR 97348

PLANT SITE LOCATION:

Halsey Pulp Mill 3.0480 American Drive Halsey, OR 97348

INFORMATION RELIED UPON:

Application Number: Received: Additional Information:

26904 06/29/12 02/20/19, 04/09/19 04/11/19, 06/28/19 04/17/20

LAND USE COMPATIBILITY STATEMENT:

Issued by: Dated:

Linn County 04/01/93

ISSUED BY THE DEPARTEMENT OF ENVIRONMENTAL QUALITY

Nature of Business:

Bleached Kraft Market Pulp

Fuel Burning Equipment

RESPONSIBLE OFFICIALS

Title:

Title:

Manager of Mill Operations

Technical Manager

Date

SIC

2611

4961

JUN 3 O 2020

NAICS

322110

221330

FACILITY CONTACT PERSON

Name:

Title:

Toby Smith

Enviromnental Manager

Phone: (541) 369-1196

TABLE OF CONTENTS


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LIST OF ABBREVIATIONS USED IN THIS PERMIT ............................................................................................. 3

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

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

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING REQUIREMENTS ........................................................................................................................................................ 8

Facility Wide ............................................................................................................................................................ 8 E1nissions Unit RFEU ............................................................................................................................................. 12 E1nissions Unit LI(EU ............................................................................................................................................. 18 E1nissions Unit SDTEU ........................................................................................................................................... 23 E1nissions Unit DGEU ............................................................................................................................................ 28 Emissions Unit PBlEU ........................................................................................................................................... 28 E1nissions Unit PB2EU ........................................................................................................................................... 30 Emissions Unit OCHEU .......................................................................................................................................... 31 E1nissions Unit NCHEU .......................................................................................................................................... 3 5 E1nissions Unit PDEU ............................................................................................................................................. 33 E1nissions Unit LSTEU ............ ; .............................................................................................................................. 35 E1nissions Unit RECEU .......................................................................................................................................... 39 Emissions Unit PMVEU .......................................................................................................................................... 3 8 E1nissions Units FREU ............................................................................................................................................ 3 8 E1nissions Unit BPEU ............................................................................................................................................. 39 Closed Vent System Requirements ...................................................................................................................... 42 Pulping (L VHC/HVLC) System Requirements .................................................................................................. 45 Pulping Condensate Requirements ...................................................................................................................... 50 Insignificant Activities ........................................................................................................................................... 63

PLANT SITE EMISSION LIMITS ............................................................................................................................. 61

GENERAL TESTING REQUIREMENTS ................................................................................................................. 68

General Title V Testing Requirements ................................................................................................................ 68 General NESHAP Testing Requirements ............................................................................................................ 70 Subpart S Testing Requirements ......................................................................................................................... 73 Subpart MM Testing Requirements .................................................................................................................... 87

GENERAL MONITORING REQUIREMENTS ........................................................................................................ 88

General Title V Monitoring .................................................................................................................................. 88 General NESHAP Monitoring Requirements ..................................................................................................... 88 Subpart S Monitoring Requirements .................................................................................................................. 93 Subpart MM Monitoring Requirements ............................................................................................................. 94

GENERAL RECORDI<EEPING REQUIREMENTS ................................................................................................ 94

Title V Recordkeeping .......................................................................................................................................... 94 Part 63 Subpart A - General Recordkeeping ..................................................................................................... 95 Subpart S - General Recordkeeping .................................................................................................................... 97 Subpart MM - General Recordkeeping ... ........................................................................................................... 97

REPORTING REQUIREMENTS ............................................................................................................................... 98

NESHAP Notifications .......................................................................................................................................... 98

Permit number: 22-3501-TV-0l Expiration date: 07/01/25

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NESHAP -- General Reporting Requirements ................................................................................................. 100 Subpart S Reporting ........................................................................................................................................... 102 Subpart MM Reporting ...................................................................................................................................... 103 Title V Reporting Requirements ........................................................................................................................ 103 Emission Fees ................................................................................................................................................... 10211 Non-Applicable Requirements ........................................................................................................................... 106

GENERAL CONDITIONS ....................................................................................................................................... 113

LIST OF ABBREVIATIONS THAT MAY BE USED IN TIDS PERMIT

ACDP Air Contaminant Discharge Permit HAP Hazardous Air Pollutant as defined ADMT Air Dried Metric Tons by OAR 340-244-0040 ADT Air Dried Tons HCFC Halogenated Chloro-Fluoro-ADTP Air Dried Tons of Pulp Carbons Act Federal Clean Air Act ID Identification label ASTM American Society of Testing and I&M Inspection and maintenance

Materials lb pound BACT Best Available Control Technology kg kilogram BDT Bone Dry Tons M thousand BDU Bone Dry Units MACT Maximum Achievable Control BL Black Liquor Technology BLS Black Liquor Solids MB material balance Btu British thermal unit MDTP Machine dried tons of pulp CAM Compliance Assurance Monitoring Mgal one thousand gallons CEMS Continuous Emissions Monitoring MMBtu one million British thermal units

System MMft3 one million cubic feet CFR Code of Federal Regulations NA Not applicable CMS Continuous Monitoring System NCASI National Council of the Paper CO2e Carbon dioxide equivalent Industry for Air and Stream co Carbon Monoxide Improvement COMS Continuous Opacity Monitoring NCG Non condensable gases

System NOx Nitrogen oxides CPMS Continuous parameter monitoring NSPS New Source Performance

system Standards DEQ Department of Enviromnental NSR New Source Review

Quality 02 Oxygen dscf Dry standard cubic feet ODT Oven dried tons dscfm Dry standard cubic feet per minute OAR Oregon Administrative Rules EF Emission factor ODEQ Oregon Department of EPA US Enviromnental Protection Enviromnental Quality

Agency ODP Oven dried pulp ESP Electrostatic precipitator ORS Oregon Revised Statutes EU Emissions Unit O&M Operation and maintenance FCAA Federal Clean Air Act Pb Lead FSA Fuel sampling and analysis PCD Pollution Control Device ft3 cubic feet PM Particulate matter GHG Greenhouse Gases PM2.s Particulate matter less than 2.5 gpm gallons per minute microns in size g/dscm gram per dry standard cubic meter PM10 Particulate matter less than 10 gr/dscf Grain per dry standard cubic feet (1 microns in size

pound= 7000 grains) ppm Parts per million

PSD

PSEL scf scfin SERP SIC S02

Prevention of Significant Deterioration Plant Site Emission Limit standard cubic foot standard cubic foot per minute Source Emissions Reduction Plan Standard Industrial Code Sulfur dioxide

SSMplan

ST TRS VE VMT voe


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Startup, Shutdown, and Malfunction Plan Source test Total Reduced Sulfur Visible emissions Vehicle miles traveled Volatile organic compounds

PERMITTED ACTIVITIES


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1. Until such time as this permit expires or is modified or revoked, the pennittee 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 they are enforceable by DEQ, EPA, and citizens under the Clean Air Act, except as specified below:

2.a. Conditions 5, 6, 7, 155.g, GS, and G9 (OAR 340-248-0005 tln·ough 0180) are only enforceable by the state. [OAR 340-218-0060]

2.b. Conditions 17, 18, 19, 20, 21, 38, 39, 40, 41, 57, 58, 69 and 70 are currently enforceable only by the state but will become federally enforceable upon EPA approval of the proposed revisions to the Oregon Plan for the Control of Designated Pollutants From Existing Facilities (Section 11 l(d) Plan).

2.c. The TRS (total reduced sulfur) PSEL in Condition 157 is currently enforceable only by the state but will becqme federally enforceable upon the EPA approval of the proposed revisions to the Oregon Plan for the Control of Designated Pollutants from Existing Facilities (Section 111 ( d) Plan).

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)]:

Table 1 Emission Units and Control Devices

Emission Unit Description EUID Pollution Control Device Description PCDID

Aggregate Insignificant Activities AI See Individual Devices in Review NA (PM/PM10/PM2.s, VOC, TRS) Report

Bleach Plant BPEU Bleach Plant Scrubber 431-550 W-Stage Washer 431-500 W-Stage Filtrate Tank 431-509 1st Stage Bleach Tower 431-515 pt Stage Washer 431-120 1st Stage Seal Tank 431-123 2nd Stage Bleach Tower 431-128 2nd Stage Washer 4 31-131 2nd Stage Seal Tank 431-134 3rd Stage Bleach Tower 431-138 3rd Stage Washer 431-141 3rd Stage Seal Tank 431-144 4th Stage Bleach Tower 431-531 4th Stage Washer 431-536 4th Stage Seal Tank 431-540 5th Stage Bleach Tower 431-151 5th Stage Washer 431-154 5th Stage Seal Tank 431-157 White Liquor Day Tank 431-208

Emission Unit Description

Chlorine Dioxide Generation and Storage

ClO2 Generator 441-010 CLO2 Absorption Tower 441-050 ClO2 Tail Vent Scrubber 410-060 Methanol Storage Tank 441-140 ClO2 Storage Tanks 1, 2, and 3 441-160, 441-161, 441-162

Digester and NCG Collection System

Digesters 1, 2, and 3 411-109, 411-119, 411-210 No. 1 Blow Gas Condenser 411-160 No. 1 Blow Tan1c 411-150 Relief Blow Gas Separators 411-159, 411-249 No. 2 Blow Gas Condenser 411-250 Evaporator Hotwell 451-159 Recovery Separator 451-306 Strong Black Liquor Storage Tan1c (West) 461-103 Strong Black Liquor Storage Tank (East) 461-101 NCG Chiller 411-266 NCG Condensate Tan1c451-170 Black Liquor Transfer Tan1c

Facility-Wide voe Material Balance

Fiber Receiving

Truck Unloading # 1 311-105 Truck Unloading #2 311-275 Rail Car/Truck Unloading #3 311-366

Lime Kiln

Lime Storage Tanks

Reburned Lime Crusher Rebmned Lime Conveyor 481-136

New Chip/Sawdust Handling

Pre-steamer Surge Bins 1, 2, and 3 411-101, 411-103, 411-201 Shavings Shredder 311-354

Old Chip/Sawdust Handling

West Chip Conveying Cyclone 311-168 East Chip Conveying Cyclone 311-18 8

Paved Road Fugitives (PM)

Power Boiler #1

Power Boiler #2

Pulp Dryer

EUID

CLO2EU

DGEU

FWEU

FREU

LKEU

LSTEU

NCHEU

OCHEU

PRFEU

PBlEU

PB2EU

PDEU

Permit number: 22-3501-TV-01 Expiration date: 07 /0 l /25

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Pollution Control Device Description PCDID

Bleach Plant Scrubber 431-550

( except for methanol storage tank)

NCG Incineration by RFEU, LKEU, or 461-128 PBlEU 481-130

281-124

None NA

None NA None NA Cover and Baghouse 311-366

Venturi Dust Scrubber 481-141

None Lime Handling System Baghouse 471-397

None NA

None NA

Periodic Cleaning NA

None NA

None NA

None NA

Emission Unit Description

Flakt Dryer 843-200 49er Pulp Press Dry Bale Repulper 842-122 Press Pulper 843-195 Wet and Dry End Flakt Dryer Repulpers 843-140

Pulp Mill Vents

Brownstock Washers 1, 2, and 3 421-112, 421-114, 421-116 Filtrate Tanks 1, 2, 3, and 4 421-118, 421-129,421-135,421-170 Decker 421-168 Oxygen Reactor Blow Tanlc 421-435

Knots Drainer 4 21-107

Noss Knotter 421-220

Johnson Rejects Drainer 421-106

#1 & #2 Wash Presses 421-460, 421-515 #1 & #2 Wash Press Dilution Conveyors 421-4 70, 421-525 #1 & #2 Wash Press Level Tanlcs 421-455, 421-510 # 1 Pressate Tanlc 421-480 Mix Tanlc421-498

Recausticizing & Recovery System

New Dregs Washer & Mix Tank 471-101 Green Liquor Stabilization Tanlc 471-360 Green Liquor Clarifier & Storage Tanlc 471-330 Spare Clarifier 471-259 Lime Mud Washer/Weak Wash Storage Tanlc471-193 Lime Mud Storage Tanlc 481-101 Lime Mud Filter Separator 481-109 Filtrate Sump Tanlc 481-114 White Liquor Clarifier/Storage Tank 4 71-180 White Liquor Oxidizer Tank 421-494 Dust Sump Tanlc 481-121 Weak Black Liquor Storage Tank (North) 451-108 Weak Black Liquor Storage Tank (South) 451-101 50% Black Liquor Storage Tanlc 261-115

Lime Slaker 471-368

Recovery Furnace

Smelt Dissolving Tank

Storage Piles

EUID

PMVEU

RECEU

RFEU

SDTEU

SPED


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Fiber Removal Scrubber & 421-565

Methanol Scrubber 421-566

None

None NA

Lime Slaker Scrubber 471-370

Electrostatic precipitator 461-170

Venturi Packed Bed Scrubber 461-212

None NA

sion Unit Description EUID

East Chip Pile West Chip Pile South Chip Pile Sawdust Pile

Unpaved Road Fugitives (PM) UPRFEU

Wastewater Treatment WWTEU


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None NA

None NA

Aeration and Settling Ponds 131-100 Clarifier 131-110

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

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

Table 2 Summary of Facility Wide emission limits and standards

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

Number

340-208-0210(1) 4 Fugitive emissions Minimize Complaint investigation 7

340-208~0300(1) 5 Air contaminants Not cause a nuisance Complaint investigation 7

340-208-0450 6 Particulate matter No fallout Complaint investigation 7 >250 microns

340-228-0110(1) 8 Distillate fuel oil, .:'. 0.3% Sulfur content Batch certification or lab 11 ASTM Grade 1 test of monthly composite

340-228-0110(2) 9 Distillate fuel oil, .:'. 0.5% Sulfur content Batch certification or lab 11 ASTMGrade2 test of monthly composite

340-228-0100 10 Residual fuel oil and .:'. 1. 75% Sulfur content Batch certification or lab 11 Used Oil test of monthly composite

40 CFR Part 68 12 Accidental toxic Prevention/emergency Annual certification of Risk 236.b.v compound release response Management Plan

40 CFR Part 63 13 HAP Comply with Subpart NA NA A

§63.4 14 HAP Prohibited activities NA NA

§63.453(q) 15 HAP General operation and NA NA maintenance requirements

§63.6(i)(l) 16 HAP Compliance extension NA NA

340-234- 17 TRS Other sources of TRS None NA 0210(l)(e)(A) must not exceed 0.078

kg/metric ton (0.156 lb/ton) unbleached pulp

[ daily arithmetic average]

Fugitive and Nuisance Emissions Requirements


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4. The permittee must not allow or permit any materials to be handled, transported, or stored; or a building, its appurtenances, or a road to be used, constructed, altered, repaired or demolished; or any equipment to be operated, without taking reasonable precautions to prevent particulate matter from becoming airborne. [OAR 340-208-0210(1)]

4.a. Such reasonable precautions must include, but not be limited to, the following:

4.a.i. Use, where possible, of water or chemicals for control of dust in the demolition of existing buildings or structures, construction operations, the grading of roads or the clearing of land;

4.a.ii. Application of water, or other suitable chemicals on unpaved roads, materials stockpiles, and other surfaces which can create airborne dusts;

4.a.iii. Full or partial enclosure of materials stockpiles in cases where application of water or chemicals are not sufficient to prevent particulate matter from becoming airborne;

4.a.iv. Installation and use of hoods, fans, and fabric filters to enclose and vent the handling of dusty materials;

4.a.v. Adequate containment during sandblasting or other similar operations; 4.a.vi. Covering, at all times when in motion, open bodied trucks transporting materials

likely to become airborne; and 4.a.vii. Prompt removal from paved streets of ea1th or other material that does or may

become airborne.

4.6. Upon request by DEQ, the pennittee must develop a fugitive emission control plan for approval by DEQ if the above precautions are not adequate, and implement the plan whenever fugitive emissions leave the propetty for more than 18 seconds in a six-minute period.

5. The permittee must not cause or allow air contaminants from any source to cause a nuisance. Nuisance conditions will be verified by DEQ personnel. [OAR 340-208-0300(1)]. This condition is enforceable only by the State.

6. The pennittee must not cause or permit the emission ofpatticulate 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 enforceable only by the State.

Fugitive and Nuisance Emissions Monitoring

7. The pennittee must provide the DEQ's Western Region-Salem Office with written notification within five days of all fugitive dust, visible emission, and air contaminant nuisance complaints received by the permittee during the operation of the facility, and must maintain a log of each complaint. Documentation must include date of contact, time of observed nuisance condition, description of µuisance condition, location of receptor, status of plant operation during the observed period, and time of response to complainant. A plant representative must immediately investigate the complaint and must provide a response to the complainant within 24 hours, if possible. [OAR 340-218-0050(3)(a)] This condition is enforceable only by the State.

7.a. The permittee must maintain a telephone number capable ofreceiving complaints 24 hours per day and maintain a web site that includes complaint contact information.

7.6. The permittee shall submit a summary of the complaints received each month in the


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semiannual report required by Condition 236, listing each complaint, the date of the complaint, type of complaint, location of the complaint, and other relevant information.

Fuel Oil Sulfur Content Requirements

8. The permittee must not use any ASTM Grade 1 distillate fuel oil containing more than 0.3% sulfur by weight. [OAR 340-228-0110(1)]

9. The pennittee must not use any ASTM Grade 2 distillate fuel oil containing more than 0.5% sulfur by weight. The pennittee is allowed to use on-specification used oil that contains no more than 0.5% sulfur by weight. The permittee must obtain analyses from the marketer or, if generated on site, have the used oil analyzed, so that it can be demonstrated that each shipment of oil does not exceed the used oil specifications contained in 40 CFR Part 279.11, Table 1. [OAR 340-228-0110(2)]

10. The permittee must not use any residual fuel oil containing more than 1.75% sulfur by weight. [OAR 340-228-0100]

Fuel Oil Sulfur Content Monitoring

11. The permittee must monitor and maintain records of the sulfur content of each batch of oil ( used, residual, ASTM Grade 1, or ASTM Grade 2) by:

11.a. Obtaining a sulfur analysis certificate from the vendor for each batch received; or

11.b. Analyzing or having analyzed by a contract laboratory a monthly composite of representative samples taken by the pennittee from each batch of fuel received. Liquid fuels must be analyzed using ASTM D129-64, D1552-83, D4057-81, or equivalent.

Risk Management Plan

12. The pennittee must comply with the risk management plan submitted to EPA and all other applicable Part 68 requirements. [ 40 CFR Part 68]

NESHAP - General Compliance

13. The pennittee shall comply with 40 CFR Part 63 Subpa1t A except those sections designated as nonapplicable in Table 1 to Subpart S of Part 63-General Provisions Applicability to Subpart S and those sections designated as nonapplicable in Table 1 to Subpmt MM of Pait 63-General Provisions Applicability to Subpart MM.

NESHAP -- Prohibited Activities and Circumvention

14. The permittee must comply with the following requirements:

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

Permit number: 22-3501-TV-01 Expiration date: 07/01 /25

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

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

14.c.i. The use of diluents to achieve compliance with a relevant standard based on the concentration of a pollutant in the effluent discharged to the atmosphere;

14.c.ii. The use of gaseous diluents to achieve compliance with a relevant standard for visible emissions; and

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

NESHAP -- General Operation and Maintenance Requirements

15. At all times, including periods of startup, shutdown, and malfunction, the permittee must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution conh·ol practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on information available to DEQ 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 63.453(q)]

15.a. Malfunctions must be corrected as soon as practicable after their occurrence. To the extent that an unexpected event arises during a staitup, shutdown, or malfunction, the permittee must comply by minimizing emissions during such a startup, shutdown, and malfunction event consistent with safety and good air pollution conh·ol practices.

15:b. Operation and maintenance requirements established pursuant to section 112 of the Clean Air Act are enforceable independent of emissions limitations or other requirements in relevant standards.

NESHAP -- Compliance with Emission Standards

16. Until an extension of compliance has been granted by DEQ, the owner or operator of an affected source must comply with all applicable requirements of 40 CFR Part 63. [40 CFR 63.6(i)(l)]

Other TRS Sources

TRS Emission Standard

17. The total emission ofTRS (total reduced sulfur) from other sources must not exceed 0.078 kilogram/metric air-dried ton (0.156 pound/air-dried ton) of unbleached pulp production, as a daily arithmetic average. If it is determined that sewers, drains, and anaerobic lagoons significantly conh'ibute to an odor problem, a program for control shall be required. [OAR 340-234-02 lO(l)(e)(A) and (B)]

17.a. Because previous source tests have indicated minimal emissions from Other Sources, no


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TRS emission testing is required for Other Sources. If testing is conducted, the following methods must be used. The reference method(s) for measuring TRS emissions from "Other TRS Sources" is EPA methods 16, 16A or 16B, 16A/6C hybrid (see Condition 58.c, except as noted in Condition 17). Each EPA method test, including the 16A/6C hybrid, must consist of three separate consecutive runs of one-hour each. [OAR 340-234-0240(l)(c)]

17 .b. "Other Sources" means sources of TRS emissions in a Kraft mill other than recovery furnaces, lime kilns, smelt dissolving tanks, sewers, drains, categorically insignificant activities and wastewater treatment facilities including but not limited to: vents from knotters, brown stock washing systems, evaporators, blow tanks, blow heat accumulators, black liquor storage tanks, black liquor oxidation system, pre-steaming vessels, tall oil recovery operations, and any vent which is shown to contribute to an identified nuisance condition. [OAR 340-234-0010(10)] [State-only enforceable pending EPA approval of Section 11 l(d) Plan]

RECOVERY FURNACE (RFEU)

Table 3 Summary of Requirements for Emissions Unit RFEU

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

340-234-0210(1 )(a)(B) 18 TRS 5 ppt11@8%O2 TRSCEMS 19


340-234-02 l 0(1 )(a)(B) 20 TRS 0.075 kg/metric ton Daily Recordkeeping 21 (0.150 lb/air-dried ton) unbleached pulp


7/24/87 AcDP, 22 Visible emissions 35% opacity COMS 24 Condition 3 [6-minute block [40 CFR 63.864(d)] and

average] [340-234-0240(2)(b )]

340-234-0210(2)(a)(C) 23 Visible emissions 35% opacity <30 COMS 24 minutes/ 180 minutes and/or 60 minutes/ 24 hours

7/24/87 ACDP, 25 PM 0.95 kg/metric ton Daily Recordkeeping 27 Condition 3 (1.91 lb/air-dried ton)

[340-234- unbleached pulp

0210(2)(a)(A) has been monthly average and

streamlined into this 1.38 kg/metric ton

requirement] (2. 77 lb/air-dried ton) daily arithmetic average

340-226-02 l 0(2)(b )(A) 26 PM 0.10 gr/dscf One ST per permit term 31

[ average of 3 test runs-DEQ 5)

§63 .862(a)( 1 )(i)(A) 28 HAP metals (PM) PM< 0.10 g/dscm COMS 24

[340-234- (0.044 gr/dscf)@ 8%

0210(2)(a)(B) has been 02

streamlined into this [average of3 test runs-requirement] --EPA 5]

Applicable Condition Pollutant/Parameter Limit/Standard Requirement Number

§63 .864(k)(2)(i)] 29 HAP metals (PM) Must not exceed 35% opacity for 2% or more of the operating time in any semiannual period

7/24/87 PSD ACDP, 32 so, 180 ppmvd @ 8% O, Condition 3 (BACT) [l-hour arithmetic

average]

340-234-0210(3) 33 so, 300 ppm@8% 0, except when burning oil

[3-hour block average]

7/24/87 PSD ACDP 35 CO,NO,, voe Good combustion (BACT) control and proper

operation of the recovery furnace

340-218-0050(3) 37 NOx Emission factor verification test once per permit term

RFEU -- TRS Emission Standards and Monitoring Requirements

TRS (ppm) Standard


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Monitoring Moni!~rin~ Action/Requirement Co

Take corrective action if 30 the average of I 0 consecutive 6 min avg opacities > 20% [40 CFR 63.864(k)(l)(i)]

Quarterly ST - EPA 31 Method 5 (may be semi-annual) [340-234-0240(2)( c)]

COMS 24 [40 CFR 63.864(d)]

SO, CEMS 34

SO,CEMS 34 [OAR 340-234-0240(3)]

COMS, CO CEMS 24, 36

Test Report 37

18. Emissions of total reduced sulfm (TRS) from emissions unit RFEU must not exceed 5 parts per million corrected to 8 percent oxygen, as a daily arithmetic average. [07/24/87 ACDP 22-3501, Condition 3] [OAR 340-234-0210(1)(a)(A) has been streamlined into this requirement] [State-only enforceable pending EPA approval of Section 111 ( d) Plan]

TRS (ppm) Monitoring

19. The pennittee must monitor total reduced sulfur emissions (TRS), as H2S, from emissions unit RFEU by operating, maintaining, and recording the output of a TRS continuous emissions monitoring system (CEMS) in accordance with DEQ's Continuous Monitoring Manual. [OAR 340-234-0240(1)(a) and (b)] [State-only enforceable pending EPA approval of Section 111 ( d) Plan]

19 .a. Monitoring must be continuous using a daily averaging period. The daily arithmetic average must be calculated from 1-hour corrected arithmetic averages.

19 .b. The permittee must operate, maintain, and record the output of an Oxygen continuous monitoring system in accordance with DEQ's Continuous Monitoring Manual for measuring oxygen emissions from emissions unit RFEU at the same location as the TRS CEMS.

19.b.i. The pennittee must calculate the oxygen concentration as an hourly arithmetic average from the continuous monitoring system data.

19.b.ii. 19.b.iii.

The span of the CMS must be set at 25 percent oxygen.


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The pennittee must calculate and record on a daily basis 24-hour average oxygen concentrations of each operating day for the recovery furnace. These 24-hour averages must correspond to the 24-hour average TRS concentrations measured under Condition 19 .a and must be determined as an arithmetic mean of the appropriate 24 contiguous .1-hour average oxygen concentrations measured by the monitoring system.

TRS (pound/ton pulp) Standard

20. Emissions of total reduced sulfur (TRS) from emissions unit RFEU must not exceed 0.075 kilogram/metric air-dried ton (0.150 pound/air-dried ton) of unbleached pulp production as a daily arithmetic average. [OAR 340-234-02 l 0(1 )(a)(B)] [State-only enforceable pending EPA approval of Section 111 ( d) Plan]

TRS (pound/ton pulp) Monitoring

21. Within 7 days ofthe given day, the pennittee must calculate the amount ofTRS emitted from RFEU each day as follows: [OAR 340-218-0050(3)(a)(C)] [State-only enforceable pending EPA approval of Section 11 l(d) Plan]

21.a. The amount of total reduced sulfur emissions for a given day is determined by the hourly ppm concentrations obtained from the CEMS in Condition 19 not corrected for oxygen, the air flow factor obtained from the source tests used in Condition 27.a, and the daily average equivalent pulp production determined in Condition 21.b.

21.b. The pennittee must calculate average daily equivalent pulp production for each day in accordance with the following:

21.c.

21.b.i.

21.b.ii. 21.b.iii.

Calculate a three-month rolling ADMT production per ton of dry BLS burned by recording the air-dried unbleached pulp production and the amount ofBLS burned on a monthly basis, updating the ratio each month.

Monitor the tons of dry BLS burned per day. Multiply the amount of dry BLS burned per day by the ratio of pulp per ton of dry BLS burned to obtain the average daily equivalent pulp production.

Recordkeeping: The permittee must maintain records of the daily TRS emission calculations and comparison to the emission limit standards specified in Condition 20.

RFEU -- Visible Emission Standards and Monitoring Requirements

Visible Emission Standard

22. Emissions from RFEU must not equal or exceed an opacity of thirty-five percent (35%) in any 6-minute block period, excluding uncombined water and excluding periods when the facility is not operating. [7/24/87 ACDP, Condition 3]

23. The emissions of particulate matter from RFEU must not exceed 35% opacity for a period or periods aggregating more than thirty (30) minutes in any one hundred eighty (180) consecutive minutes or more than sixty minutes in any twenty-four (24) consecutive hours, excluding uncombined water and excluding periods when the facility is not operating. [OAR 340-234-0210(2)(a)(C)]

VE Monitoring


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24. The permittee must continuously monitor visible emissions from RFEU by operating and maintaining a continuous opacity monitoring system (COMS) in accordance with Performance Specification 1 (PS-1) in appendix B to 40 CFR Part 60 and DEQ's Continuous Monitoring Manual, Conditions 16 and 189 through 195, and the following: [40 CFR 63.864(d)] and [OAR 340-234-0240(2)(6)] .

24.a. Each COMS must complete a minimum of one cycle of sampling and analyzing for each successive 10-second period and one cycle of data recording for each successive 6-minute period. [40 CFR 63.8(c)(4)(i) and 63.864(d)(3)]

24.b. All COMS data must be reduced to 6-minute averages calculated from 36 or more data points equally spaced over each 6-minute period. [40 CFR 63.8(g)(2) and 40 CFR 63.864(d)(4)]

24.c. The COMS zero and upscale calibration drift must not exceed 2 percent opacity over a 24-hour period. [40 CFR part 60, appendix B, PS-1]

24.d. The pennittee must calculate and maintain records of the average hourly (clock hour) opacity and the average daily opacity for the purpose of determining the particulate matter emission rate in Condition 27.b. [OAR 340-218-0050(3)(a)(C)]

24.e. The permittee must maintain proper operation of the ESP's automatic voltage control (AVC). [40 CFR 63.864(e)(l)]

24.f. Recordkeeping: The permittee must maintain records in accordance with Condition 190 and the following: [OAR 340-2 l 8-0050(3)(a)(C)]

24.f.i. 24.f.ii.

24.f.iii. 24.f.iv.

Each 6-minute average opacity. All periods when the average often consecutive 6-minute averages result in a

measurement greater than 20 percent opacity and corrective actions taken to return the RFEU and/or associated emission control systems to normal operation.

The percentage of time in each semiannual period when opacity is greater than 35%. The amount of time the opacity exceeds 35% during any 180 consecutive minute

period and during any 24 consecutive hour period.

RFEU -- Particulate Matter Emission Standards and Monitoring Requirements

PM Standards

25. Emissions of particulate matter from emissions unit RFEU must not exceed 0.95 kilogram/metric airdried ton ( 1.91 pounds/air-dried ton) of unbleached pulp production, as a monthly arithmetic average of daily values and 1.38 kilograms/metric air-dried ton (2.77 pounds/air-dried ton) of unbleached pulp production as a daily arithmetic average. [07/24/87 PSD ACDP 22-3501, Condition 3] [OAR 340-234-0210(2)(a)(A) has been streamlined into this requirement]]

26. The permittee must not cause or allow the emission of particulate matter in excess of 0.10 grain per standard cubic foot from emissions unit RFEU. [OAR 340-226-0210(2)(b)(A)]

PM (pound/ton) Monitoring

27. Within 7 days of the given day and by the end of the following month, the permittee must calculate the amount of particulate matter emitted from RFEU each day and month as follows: [OAR 340-218-0050(3)(a)(C)]

27.a. PM and Opacity Correlation: The permittee must develop and maintain a correlation between RFEU particulate matter emissions and opacity by using the grains per dry standard cubic foot


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and the corresponding hourly opacity average results from a minimum of five (5) previous source tests, unless the correlation has an r2 value less than 0.50. If the r2 value is less than 0.50, then the best representative data set must be used. An equation must be developed to define the correlation and must be updated each period a source test is done.

27.b. PM Calculation: Perform the following calculations:

27.b.i. Use the average daily opacity calculated in Condition 24.d with the correlation calculated in Condition 27.a to determine the amount of particulate matter (grains per dry standard cubic foot) emitted from RFEU that day.

27.b.ii. Multiply the flow rate obtained from the correlation required in Condition 27.a and the particulate matter emissions in Condition 27 .b.i to obtain pounds of particulate/day.

27 .b.iii. Divide the pounds of pmticulate/day from Condition 27 .b.ii by the average daily equivalent pulp production calculated in accordance with Condition 21.b to obtain the amount of particulate matter discharged per equivalent unit of pulp production.

27.c. Recordkeeping: The permittee must maintain records of the daily and monthly PM emission calculations and comparison to the emission limit standards specified in Condition 25.

HAP Metals Emission Standards

28. The concentration of particulate matter in the exhaust gases discharged to the atmosphere from emissions unit RFEU must be less than or equal to 0.10 gram/dry standard cubic meter (0.044 grain/dry standard cubic foot) corrected to 8 percent oxygen. [40 CFR 63.862(a)(l)(i)(A)] [OAR 340-234-0210(2)(a)(B) has been streamlined into this requirement]

29. The permittee is in violation of the standards of Condition 28 when opacity is greater than 35 percent for 2 percent or more of the operating time within any semiannual period when spent pulping liquor is fed to RFEU. [40 CFR 63.864(k)(2)(i)]

On-going HAP Metals Compliance Monitoring Provision

30. The permittee is required to implement corrective action when the average often consecutive 6-minute averages result in a measurement greater than 20 percent opacity when spent pulping liquor is fed to emissions unit RFEU .. Corrective action can include completion of transient stmtup and shutdown conditions as expediently as possible. [40 CFR 63.864(k)(l)(i)]

PM Testing

31. Particulate matter source testing must be performed at least quarterly in accordance with the requirements specified in Conditions 161 through 171, 185, and the following requirements; except that testing may be semi-annual when the preceding six (6) source tests for emissions unit RFEU were less than 0.075 gram/dscm (0.033 grain/dsct) corrected to 8% 02. If a semi-annual source test result equals or exceeds 0.075 gram/dscm (0.033 grain/dsct), the testing frequency must revert back to quarterly. [OAR 340-234-0240(2)(c) and 40 CFR 63.865]

3 I.a. EPA Method 5 must be used for measuring particulate matter when demonstrating compliance with the emission standards of Condition 28. For each test: water must be used as the cleanup solvent instead of acetone, and consist of the average of three separate consecutive runs having a minimum sampling time of 60 minutes each, a maximum sampling time of eight hours each, and a minimum sampling volume of 31.8 dscf each. [OAR 340-234-0240(2)(a)]

31.b. At least once per permit term, Oregon Method 5 must be used to determine particulate matter emissions from RFEU for the purpose of verifying compliance with Condition 26 and for


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verification of the emission factor used to calculate particulate matter emissions. The EPA and Oregon Method 5 testing runs may be conducted simultaneously by using one sample train. [OAR 340-2 l 8-0050(3)(a)(C)]

31.c. During each test, the permittee must record the following information: 31.c.i. Black liquor solids flow (gpm), black liquor solids(%), air flow rate (dscfm), and

oxygen concentration. 31.c.ii. Six-minute average opacities as measured by the COMS. 31.c.iii. Average daily equivalent pulp production (ADMT). 31.c.iv. The recovery furnace electrostatic precipitator, PCD 461-170, voltages and currents.

31.d. EPA Method 5 test results must be reported in units of gram/dscm@ 8% 02 and grain/dscf@ 8%02,

31.e. Oregon Method 5 test results must be reported in units of grain/dscf@ 8% 02, lb/hour, and lb/ton BLS.

RFEU -- Sulfur Dioxide (SO2) Emission Standards and Monitoring Requirements

SO2 Emission Standards

32. Emissions of sulfur dioxide from emissions unit RFEU must not exceed 180 parts per million on a dry gas basis corrected to 8 percent oxygen, as a one-hour average. This standard does not apply during periods of startup and shutdown. [07 /24/87 PSD ACDP 22-3501, Condition 3 (BACT)]

33. Emissions of sulfur dioxide from emissions unit RFEU must not exceed 300 parts per million on a dtygas basis corrected to 8 percent oxygen, as a three-hour block average, except when burning fuel oil. The sulfur content of the fuel oil burned must not exceed the sulfur content limitations specified in Conditions 8, 9, and 10 for distillate, residual, and used oils. [OAR 340-234-0210(3)]

SO2 Monitoring Requirements

34. The permittee must monitor the amount of SO2 being emitted from emissions unit RFEU by operating and maintaining a sulfur dioxide continuous emissions monitoring system (CEMS) in accordance with DEQ's Continuous Monitoring Manual. [OAR 340-234-0240(3)]

34.a.

34.b.

The one-hour block and 3-hour block average SO2 concentrations (ppm) must be calculated from the continuous readings and should be based on a clock hour.

Recordkeeping: The permittee must maintain records of all one hour and 3-hour block SO2 concentrations.

RFEU - CO, NOx, and VOC Operational Standard and Monitoring Requirements

Operational Standard

35. Emissions of CO, NOx, and VOC from emissions unit RFEU must be minimized as much as practical using good combustion control and proper operation of the recovery furnace. This standard does not apply during periods of startup and shutdown. [07/24/87 PSD ACDP 22-3501 (BACT)]

Monitoring Requirements

36. The permittee must monitor the amount of CO being emitted from emissions unit RFEU by operating and maintaining a carbon monoxide continuous emissions monitoring system (CEMS) in accordance with DEQ's Continuous Monitoring Manual. [OAR 340-218-0050(3)(a)(C)]

RFEU - Emission Factor Testing for NOx


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3 7. At least once per permit term, a source test for NOx emissions from RFEU must be conducted in accordance with the requirements of Condition 161 for the purposes of emission factor verification. [OAR 340-2 l 8-0050(3)(a)(C)]

LIME KILN (LKEU)

Table 4 Summary of Requirements for Emissions Unit LKEU

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

Activity/Requirement

340-234-021 0(l)(b) 38 TRS 20 ppm@ 10% 02 TRSCEMS 39

[daily arithmetic average] [OAR 340-234-0240(1)]

340-234-0210(1 )(b) 40 TRS 0.05 kg/ADMT (0.10 Daily Recordkeeping 41 lb/ADT) unbleached pulp


340-234-0210(2)(b )(A) 42.a PM 0.50 kg/ADMT (1.00 Scrubber Pressure and 46

and lb/ADT unbleached pulp Liquid Flow Rate CPMS on petroleum coke or oil Semi-Annual ST 340-234-0210(2)( d)(B)(iii) fuels [OAR 340-234-

48

[daily arithmetic average] 0240(2)(d)]

340-234-0210(2)( d)(B)(i) 42.b PM 0.25 kg/ADMT (0.50 Scrubber Pressure and 46 lb/ADT unbleached pulp Liquid Flow Rate CPMS on natural gas fuel Semi-Annual ST [ daily arithmetic average] [OAR 340-234-

48

0240(2)(d)]

340-226-0210(2)(b )(A) 43 PM 0.10 gr/dscf One ST per permit term 48

[ average of 3 test rnns-DEQ5)

§63.862(a)(l )(i)(C) 44 HAP metals (PM) 0.15 g/dscm (0.064 Scrubber Pressure and 46

[340-234-0210(2)(b )(8), gr/dsct)@ 10% 0 2 on Liquid Flow Rate CPMS

340-234-02 l 0(2)( d)(B)(ii), any fuel [40 CFR 63.864(e)(10)]

and 340-234- [ average of 3 test runs--- Take corrective action 47 0210(2)( d)(B)(iv) have EPA5] when 3-hr avg. parameter been streamlined into this value outside range requirement.] [40 CFR 63.864(k)(l)(ii)]

Semi-Annual ST 48 [OAR 340-234-0240(2)(d)]

Resetting parametric 199 monitoring ranges [40 CFR 63.864(j)(2)]

§63 .864(k)(2)(iii) 45 HAP metals (PM) 6 or more parameter value Scrubber Pressure and 46 exceedances within a 6 Liquid Flow Rate CPMS month reporting period is [40 CFR 63.864(e)(10)] a violation of the HAP emission standard.

340-234-02 l 0(2)(b )(C) and 49 Visible emissions 20% opacity, 6-minute Parametric monitoring 50 (4) block average

340-224-0070(2) 51 NO, 112 ppm@ 10% 02 when Annual ST for NOx 52

(BACT) firing natural gas or oil & with the existing (2004) burner. 02 CPMS - corrective 53


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

Activity/Requirement

185 ppm@ 10% 02 when action if.'.c 0.5% the petroleum coke burner is used.

1000 ppm@ 10% 02 ifa different burner system is installed. This limit may be adjusted based on test data collected during the first 12-months of operation.

[3 test run average]

340-218-0050(3) 54 co Emission factor Test Report 54 verification test once per permit term

LKEU -- TRS Standards and Monitoring Requirements

TRS (ppm) Standard

38. Emissions of total reduced sulfur (TRS) from emissions unit LKEU must not exceed 20 parts per million (ppm) corrected to 10% oxygen, as a daily arithmetic average. [OAR 340-234-0210(1)(6)] [State-only enforceable pending EPA approval of Section 11 l(d) Plan]

TRS (ppm) Monitoring and Recordkeeping

39. The pennittee must monitor total reduced sulfur emissions, as H2S, from emissions unit LKEU by calibrating, maintaining, and recording the output of a CEMS in accordance with DEQ's Continuous Monitoring Manual. [OAR 340-234-0240(1)(a) and (b)] [State-only enforceable pending EPA approval of Section 111 ( d) Plan]

39.a. Monitoring must be continuous using a daily averaging period. The daily arithmetic average must be calculated from corrected 1-hour arithmetic averages.

3 9 .b. The permittee must install, calibrate, maintain, and record the output of a continuous monitoring system (CMS) in accordance with DEQ's Continuous Monitoring Manual for measuring the oxygen concentration in emissions unit LKEU at the same location as the TRS CEMS.

39.b.i.

39.b.ii. 39.b.iii.

TRS (pound/ton) Standard

The pennittee must calculate the oxygen concentration as an hourly arithmetic average from the continuous monitoring system data.

The span of the oxygen monitor must be set at 25 percent oxygen. The permittee must calculate and record on a daily basis 24-hour average oxygen concentrations of each operating day for the lime kiln. These 24-hour averages must correspond to the 24-hour average TRS concentrations measured under Condition 39.a and must be determined as an arithmetic mean of the appropriate 24 contiguous 1-hour average oxygen concentrations provided by each continuous monitoring system installed under Condition 39.

40. Emissions of total reduced sulfur from emissions unit LKEU must not exceed of0.05 kilogram/air-dried metric ton (0.10 pound/air-dried ton) of unbleached pulp production, as a daily arithmetic average. [OAR 340-234-021 0(l)(b )] [State-only enforceable pending EPA approval of Section 11 l(d) Plan]


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TRS (pound/ton) Monitoring

41. Within 7 days of the given day, the permittee must monitor total reduced sulfur emissions, as H2S, from emissions unit LKEU by calculating emissions in units of kilograms ofTRS/air-dried metric ton of equivalent unbleached pulp production or pounds of TRS/air-dried ton of equivalent unbleached pulp production using the following procedures. [OAR 340-2 l 8-0050(3)(a)(C)] [State-only enforceable pending BP A approval of Section 111 ( d) Plan]

41.a. The TRS emission value is determined by using the hourly TRS ppm values for the given day obtained from the CEMS in Condition 39 not corrected for oxygen, the air flow rate determined in Condition 41.b, and the average daily equivalent pulp production determined in Condition 41.c.

41.b. The flow rate used in this determination is the average flow rate of the last five patiiculate matter source tests conducted at the LKEU.

41.c. The permittee must calculate average daily equivalent pulp production on a monthly basis in accordance with the following:

41.c.i.

41.c.ii.

41.c.iii. 41.c.iv. 41.c.v.

41.c.vi.

Calculate a three-month rolling pulp production per amount of lime processed through the Slaker by recording the air-dried pulp production and the amount of lime produced by the kiln and purchased by the mill on a monthly basis, updating the ratio each month.

Determine and document the production of unbleached pulp equivalent to the monthly amount of lime processed through the Slaker. Submit a copy of the documentation to DEQ with the monthly reports required by this permit and submit revisions whenever process changes make it appropriate. The documentation must include calculations and/or process rate records used to determine the equivalence.

Monitor the amount of dry lime produced by the lime kiln per month. Monitor the amount of purchased lime added to the process per month. Divide the monthly total lime used by the number of days in the month to obtain daily average lime processed through the Slaker.

Multiply the amount of total average dry lime used per day (41.c.v) by the ratio of pulp production per amount of lime processed through the Slaker (41.c.i) to obtain the average daily equivalent pulp production.

LKEU -- PM Emission Standards and Monitoring Requirements

PM Standards

42. PM emissions from emissions unit LKEU must meet the following:

42.a. Emissions of particulate matter from emissions unit LKEU must not exceed 0.50 kilogram per air-dried metric ton (1.00 pound/air-dried ton) of unbleached pulp production as a daily arithmetic average when burning petroleum coke or oil fuels. [OAR 340-234-0210(2)(b)(A) and 340-234-0210(2)(d)(B)(iii)]

42.b. Emissions of particulate matter from emissions unit LKEU must not exceed 0.25 kilogram per air-dried metric ton (0.50 pound/air-dried ton) ofunbleached pulp production as a daily arithmetic average when burning natural gas fuel. [OAR 340-234-0210(2)(d)(B)(i)]


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43. The permittee must not cause or allow the emission of particulate matter in excess of O .10 grain per standard cubic foot from emissions unit LKEU. [OAR 340-226-0210(2)(b)(A)]

HAP Metal Emission Standards

44. The concentration of particulate matter in the exhaust gases discharged to the atmosphere from emissions unit LKEU must be less than or equal to 0.15 gram/dry standard cubic meter (0.064 grain/dry standard cubic foot), corrected to 10 percent oxygen. [40 CFR Part 63.862(a)(l)(i)(C)] [OAR 340-234-0210(2)(b )(B), 340-234-02 l 0(2)( d)(B)(ii), and 340-234-0210( d)(B)(iv) have been streamlined into this requirement.]

45. The permittee is in violation of the standards specified in Condition 44 when six or more block 3-hour average parameter values within any 6-month reporting period are below the minimum operating limits established in Condition 199 with the exception of pressure drop during periods of startup and shutdown. For the purposes of determining the number of nonopacity monitoring exceedances, no more than one exceedance will be attributed in any given 24-hour period. [40 CFR 63.864(k)(2)(iv) and 63.864(k)(3)]

HAP Metal Emissions Monitoring

46. The permittee must operate and maintain a continuous monitoring system that can be used to determine and record the pressure drop across the wet scrubber (PCD 481-141) and the scrubbing liquid flow rate at least once every successive 15-minute period using the procedures in Condition 191, as well as the following procedures: [40 CFR 63.864(e)(l0)]

46.a. The monitoring device used for the continuous measurement of the pressure drop of the gas stream across the scrubber must be certified by the manufacturer to be accurate to within a gage pressure of ±_5 00 pascals (± 2 inches of water gage pressure); and

46.b. The monitoring device used for continuous measurement of the scrubbing liquid flow rate must be certified by the manufacturer to be accurate within± 5 percent of the design scrubbing liquid flow rate.

On-going HAP Metals Compliance Provisions

47. The permittee is required to implement corrective action when any 3-hour block average parameter value is below the minimum operating limits established in Condition 199 when lime mud is fed to LKEU with the exception of pressure drop during periods of startup and shutdown. Corrective action can include completion of transient startup and shutdown conditions as expediently as possible. [40 CFR 63 .864(k)( 1 )(ii)]

PM Testing

48. Particulate matter source testing must be performed on the LKEU at least semi-annually and according to the following procedures to demonstrate compliance with the'emission standards specified in Conditions 42, 43, and 44. [OAR 340-234-0240(2)(d) and 40 CFR 63.865]

48.a. Particulate matter emissions must be measured using EPA Method 5 and the procedures specified in Conditions 161, 165, 166, and 185. In addition, each test must consist of the average of three separate consecutive runs having a minimum sampling time of 60 minutes each, a maximum sampling time of eight hours each, and a minimum sampling volume of 31.8 dscf each with water used as the cleanup solvent instead of acetone. [OAR 340-234-0240(2)(a)]

48.b. At least once per permit term, Oregon Method 5 must be used to determine particulate matter


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emissions from LKEU for the purpose of verifying compliance with Condition 43 and for verification of the emission factor used to calculate particulate matter emissions. The EPA and Oregon Method 5 testing runs may be conducted simultaneously by using one sample train. [OAR 340-218-0050(3)]

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

48.c.i. Amount of lime produced (tons/hour). 48.c.ii. Oxygen concentration. (% 0 2 -- hourly average) 48.c.iii. Scrubber differential pressure (hourly average) and scrubber liquid flow rate (hourly

average). 48.c.iv. Average daily equivalent pulp production (ADMT) must be calculated in accordance

with Condition 41.c. 48.c.v. Types and amounts (MMBtu) of fuels combusted.

48.d. PM test results must be reported in units of gram/dscm corrected to 10% 02, grain/dscf corrected to 10% 02, pounds/hour, pounds/ton lime produced, and pounds/air-dried ton unbleached pulp and must indicate the test method used in each case to determine the result (i.e., EPA Method 5 or Oregon Method 5).

LKEU -- Visible Emission Standards and Monitoring Requirements


49. Visible emissions from emissions unit LKEU must not exceed an opacity equal to or greater than 20 percent as a six-minute block average. The reference method for measuring opacity from emissions unit LKEU is EPA Method 9. [OAR 340-234-0210(2)(b)(C) and (4)]

Visible Emissions Monitoring

50. The parametric monitoring required in Condition 46 will be used to demonstrate continuous compliance with the opacity standards specified in Condition 49.

LKEU -- NOx Emission Standards and Monitoring Requirements

NOi, (ppm) Emissions Standard

51. Emissions ofNOx from emissions unit LKEU must not exceed the following: [2004 and 2006 PSD ACDPs and OAR 340-224-0070(2) (BACT)]

51.a. 112 ppm @ 10% 02 (average of 3 test runs) when using the natural gas/oil fired existing (March 2004) burner only.

51.b. 185 ppm@ 10% 02 (average of3 test runs) when using the petroleum coke fired burner.

51.c. 1000 ppm@ 10% 0 2 (average of 3 test runs) or the adjusted value as determined by the requirements of Condition 51. d for any new burner system that is installed in the Lime Kiln.

51.d. Within 60 days of the end of the 12-month period following initial startup of any new burner system, the pennittee must submit to DEQ a statistical analysis of the performance test data (minimum of 4 tests) collected during this period. All testing must be done in accordance with Conditions 52 and 161. The analysis shall consist of the average, standard deviation, and other statistical measures, as appropriate. IfDEQ determines based on this analysis that the lime kiln has achieved NOx emission rates lower than 1000 ppm @ 10% 0 2 on a consistent basis with a suitable margin of compliance, then an adjusted NOx emission limit shall be established at the lower emission rate. The adjusted limit will be determined by adding 3 standard deviations to


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the average value of the performance test results. Emission factors for demonstrating compliance with the PSEL will be based on the average of the source test results. Within 60 days ofDEQ's approval, the permittee must submit a permit modification application to DEQ to incorporate the adjusted NOx limit into this permit.

NOx (ppm) Testing

52. Testing for NOx emissions from emissions unit LKEU must be conducted once per calendar year in accordance with Condition 161 and the following requirements for the purposes of demonstrating compliance with the emission limits specified in Condition 51. [OAR 340-2 l 8-0050(3)(a)(C)]

52.a. EPA Method 7 or EPA Method 7E must be used for measuring NOx emissions.

52.b. During each test, the pennittee must record the following information:

52.b.i. 52.b.ii. 52.b.iii. 52.b.iv.

Estimated lime produced (tons /hour). Oxygen concentration. Scrubber differential pressure and scrubber liquid flow rate. Types and amounts of fuels combusted (MMBtu/hour heat input).

52.c. NOx test results must be reported in units of pounds/hour, ppm, ppm @ 10% 02, pounds/ton CaO, and pounds/MMBtu heat input.

02 Monitoring and Recordkeeping

53. To demonstrate compliance with the "Good Combustion Control" BACT, the permittee must operate and maintain a continuous monitoring system for measuring the oxygen content of the LKEU exhaust steam, in accordance with the manufacturer's written instructions and the following requirements. [OAR 340-224-0070(2) (BACT)]

53 .a. The permittee must take corrective action if the I-hour average excess oxygen level is less than or equal to 0.5%.

53 .b. An excess oxygen action level excursion is not necessarily a violation of an emission standard in this permit.

53 .c. Recordkeeping: The permittee must maintain records of I-hour average excess oxygen values, excess oxygen excursions, and corrective actions taken.

LKEU - Emission Factor Testing for CO

54. At least once per permit term, a source test for CO emissions from LKEU must be conducted in accordance with the requirements of Condition 161 for the purposes of emission factor verification. [OAR 340-2 l 8-0050(3)(a)(C)]

5 5. Reserved.

SMELT DISSOLVING TANK (SDTEU)

Table 5 Summary of Requirements for Emissions Unit SDTEU


340-234-0210(1 )(c) 57 TRS 0.0165 g/kg BLS

(0.033 lb/ton BLS)


340-234-02 l 0(2)( d)(C) 59 PM 0.15 kg/metric ton pulp

[7/24/87 ACDP, (0.30 lb/ton) Condition 5 has been [ daily arithmetic average] streamlined into this requirement]

340-226-0210(2)(a)(B) 60 PM 0.15 grain/dscf

[average of 3 test runs]

§63 .862(a)(l )(i)(B) 62 HAP metals (PM) 0.10 kg/Mg BLS

(0.20 lb/ton BLS)

[ average of 3 test runs]

§63.864(k)(2)(iii) and 63 HAP metals (PM) 6 or more parameter value (k)(iii) exceedances within a 6

month reporting period is a violation of the HAP emission standard.

340-234-0210(2)( C )( 66 Visible emissions 20% opacity, 6 minute B) and(4) block average

56. Reserved.

SDTEU -- TRS Emission Standards and Monitoring Requirements

TRS Emission Standards


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Monitoring Activity Monitoring Condition Number

Quarterly ST 58

[EPA Method 16, 16A, 16B, or 16A/6C hybrid]

Quarterly ST 61

[EPA Method 5]

One ST per permit term 61

[Oregon Method 5]

Scrubber pressure drop 65 and scrubber liquid flow rate CPMS

[40 CFR 63.864(e)(10)]

Must take corrective 64 action when 3-hr avg. parameter value outside range

[40 CFR 63. 864(k)( 1 )(ii)]

Scrubber Pressure and 65 Liquid Flow Rate CPMS

Quarterly VE 67

57. Emissions of total reduced sulfur from emissions unit SDTEU must not exceed 0.0165 gram/kilogram (0.033 pound/ton) black liquor solids fired, as a daily arithmetic average. [OAR 340-234-0210(l)(c)] [State-only enforceable pending EPA approval of Section 111 ( d) Plan]

TRS Testing

58. TRS emissions from SDTEU must be measured using EPA Methods 16, 16A, 16B, 16A/6C hybrid (as defined in Condition 58.c), or continuous emissions monitors, and in accordance with Condition 161 and the following requirements. [OAR 340-234-0240(l)(d) and 340-2 l 8-0050(3)(a)(C)] [State-only enforceable pending EPA approval of Section 111 ( d) Plan]

ss·.a. The TRS tests must be conducted at least once per calendar quarter. The testing may be conducted semi-annually when the preceding six (6) source test results were less than 0.0124 gram/kilogram (0.025 pound/ton) black liquor solids fired. If semi-annual source test results equal or exceed 0.0124 gram/kilogram (0.025 pound/ton) black liquor solids fired, the frequency must revert back to quarterly.


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58.b. For Method 16A, a test run consists of three 60-minute samples or one 3-hour sample (three test runs constitute a test) in accordance with §8.3 of Method 16A in Appendix A of 40 CFR Part 60.

58.c. For the Method 16A/6C hybrid, the average emissions must be calculated from three 3-hour test runs.

58.c.i.

58.c.ii.

58.c.iii.

58.c.iv.

58.c.v.

If integrated samples are collected in bags instead of directly analyzed, then the bags must be analyzed within four (4) hours. For calibration purposes, H2S must be used and introduced at the beginning of the sample train. Calibration, initial and final bias checks and calibration drift must meet the requirements of EPA Method 6C. The sampling system must be leak-checked before and after the testing program (before the first run and after the last run). Results of the leak check must be documented in the test report. In the EPA Method 16A sampling train, the temperature of the probe, filter, and connector to the first impinger of the SO2 scrubber must be maintained at a high enough level to prevent condensation and potential loss of TRS prior to the SO2 scrubber. The temperatures of the probe and filter box must be monitored and recorded throughout each test run. Condensation within the sample line between the SO2 scrubber and the oxidizer (tube furnace) must also be prevented. A demonstration of adequate temperature control must be documented in the test report. Prior to the recording of emissions data, the sampling system should be conditioned with exhaust gas for a period equal to or exceeding three (3) times the system response time.

58.d. During each test, the permittee must record the following information:

58.d.i. 58.d.ii. 58.d.iii. 58.d.iv. 58.d.v.

Unbleached pulp production (air-dried metric tons). Black liquor solids flow (gpm). Black liquor solids content(%). Total reduced sulfur emissions (ppm). Smelt dissolving tank scrubber liquid flow rate (gpm) and pressure drop (inches of water).

SDTEU -- Particulate Matter Emission Standards and Monitoring Requirements

PM Standards

59. Emissions of particulate matter from emissions unit SDTEU must not exceed of0.15 kilogram/metric airdried ton (0.30 pound/air dried ton) of unbleached pulp production, as a daily arithmetic average. [OAR 340-234-0210(2)(d)(C)] [07/24/87 PSD ACDP 22-3501, Condition 5 has been streamlined into this condition]

60. The permittee must not cause or allow the emission of particulate matter in excess of O .15 grain per standard cubic foot from emissions unit SDTEU. [OAR 340-226-0210(2)(a)(B)]

PM Testing

61. To demonstrate compliance with the particulate emission standards specified in Conditions 59 and 60, particulate matter source testing of emissions unit SDTEU must be performed in accordance with the requirements specified in Condition 161 and the following requirements: [OAR 340-234-0240(a) and 340-218-0050(3)(a)(C) and 40 CFR 63.865]


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61.a. Testing must be conducted at least once per calendar quarter using EPA Method 5 for demonstrating compliance with the emission standards of Condition 59. The testing may be conducted semi-annually when the preceding six source tests were less than 0.113 kilogram/airdried metric ton (0.225 pound/air-dried ton) of unbleached pulp production. Ifsemi-ammal source test results equal or exceed 0.113 kilogram/air-dried metric ton (0.225 pound/air-dried ton) of unbleached pulp production, the frequency must revert back to quarterly. For each test: water must be used as the cleanup solvent instead of acetone, and consist of the average of three separate consecutive runs having a minimum sampling time of 60 minutes each, a maximum sampling time of eight hours each, and a minimum sampling volume of 31.8 dscf each. [OAR 340-234-0240(2)(a)]

61.b. Testing must be conducted at least once per permit term using Oregon Method 5 to measure particulate matter emissions for demonstrating compliance with the emission standards of Condition 60. The EPA and Oregon Method 5 testing runs may be conducted simultaneously by using one sample train. [OAR 340-218-0050(3)]

61.c. For demonstrating compliance with emission standards specified in Condition 59, the permittee must calculate the emissions of particulate matter in units of kilograms per metric ton of equivalent air-dried unbleached pulp production by using the arithmetic average concentration and the air flow rate obtained from the source test data and the daily average equivalent pulp production determined in Condition 21.b.

61.d. During each test, the permittee must record the following information on an hourly average basis:

61.d.i. 61.d.ii. 61.d.iii.

61.d.iv.

Black liquor solids flow (gpm). Black liquor solids content(%) Smelt dissolving tank scrubber liquid flow rate (gpm) and pressure drop (inches of water).

Unbleached pulp production (hourly).

61.e. Particulate matter test results must be reported in units of grains/dscf, pounds/hour, pounds/ton BLS fired, and pounds/air-dried ton of unbleached pulp produced and must indicate the test method used in each case to determine the result (i.e., EPA Method 5 or Oregon Method 5).

SDTEU -- HAP Metals Emission Standards and Monitoring Requirements

HAP Metals Emission Standards

62. The concentration of particulate matter in the exhaust gases discharge to the atmosphere from emissions unit SDTEU must be less than or equal to 0.10 kilogram/megagram (0.20 pound/ton) of black liquor solids fired. Particulate matter emissions must be measured using the procedures specified in Conditions 161 through 171 and Condition 185. [40 CFR63.862(a)(l)(i)(B)]

63. The permittee is in violation of the standards specified in Condition 62 when six or more 3-hour block average parameter values within any 6-month reporting period are below the minimum operating limits established in Condition 199 with the exception of pressure drop during periods ofstaitup and shutdown. For the purposes of determining the number of nonopacity monitoring exceedances, no more than one exceedance will be attributed in any given 24-hour period. [40 CFR 63.864(k)(2)(iv) and 63.864(k)(3)]

On-going HAP Metal Emissions Compliance Monitoring Provision

64. The permittee is required to implement corrective action when any 3-hour block average parameter value is below the minimum operating limits established in Condition 199 when spent liquor is fed to RFEU


Page27 ofl12

with the exception of pressure drop during periods of startup and shutdown. Corrective action can include completion of transient startup and shutdown conditions as expediently as possible. [40 CFR 63 .864(k)(l )(ii)]

HAP Metals Emissions Monitoring

65. The permittee must operate and maintain a continuous monitoring system that can be used to determine and record the and the pressure drop across the wet scrubber (PCD 461-212) and the scrubbing liquid flow rate at least once every successive 15-minute period using the procedures in Condition 191, as well as the following procedures: [40 CFR 63.864(e)(l0)]

65.a. The monitoring device used for the continuous measurement of the pressure drop of the gas stream across the scrubber must be certified by the manufacturer to be accurate to within a gage pressure of ±_500 pascals(± 2 inches of water gage pressure); and

65.b. The monitoring device used for continuous measurement of the scrubbing liquid flow rate must be certified by the manufacturer to be accurate within± 5 percent of the design scrubbing liquid.

65.c. As an alternative to pressure drop measurement, a monitoring device for measurement of fan amperage may be used for dynamic scrubbers that operate at ambient pressure or for low-energy entrainment scrubbers where the fan speed does not vary.

SDTEU -- Visible Emission Standards and Monitoring Requirements


66. Visible emissions from emissions unit SDTEU must not exceed an opacity equal to or greater than 20 percent as a six-minute block average. [OAR 340-234-02 l 0(2)( c )(B) and ( 4 )]

Visible Emission Monitoring

67. At least once per calendar quarter, the permittee must monitor visible emissions from emissions unit SDTEU by conducting EPA Method 9 tests at the outlet of the wet scrubber (PCD 461-212). [OAR 340-218-050(3)( a)(C)]

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

67 .b. If any test result exceeds the applicable standard specified in Condition 66, the permittee must initiate corrective action as soon as is practicable to bring the smelt dissolving tank into compliance with the applicable standards. Upon completion of the corrective action, a EPA Method 9 test must be conducted as soon as is practicable to demonstrate that the source is in compliance with the applicable standard.

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

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

DIGESTER and NCG COLLECTION SYSTEM (DGEU)

Table 6 Summary of Requirements for Emissions Unit DGEU

Applicable Condition Pollutant/ Limit/Standard Requirement Number Parameter

§60.283(a)(l )(iii) 68 Non-condensible gases Treated by incineration in

[Applies to Digester RFEU, LKEU, orPBlEU

No. 3 only] at 1200°F for 0.5 seconds

340-234-021 0(l)(d) 69 Non-condensible gases Treated by incineration in RFEU, LKEU, or PBlEU

340-234-021 0(l)(d) 70 Non-condensible gases Minimize venting ofNCG to less than one-hour

DGEU --NCG Standards and Monitoring Requirements

NCG Standards


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Recordkeeping 71

Recordkeeping 71

Recordkeeping 71

68. The permittee must com bust the gases from the No. 3 digester ( 411-203) with other waste gases in the lime kiln (LKEU), the power boiler No. 1 (PB lEU), or the recovery furnace (RFEU) at a minimum temperature of 1,200°F for at least 0.5 second. Excess emissions are all periods in excess of 5 minutes and their duration during which the combustion temperature at the point of incineration is less than 1200 °F. [40 CFR 60.283(a)(l)(iii) and 60.284(d)(3)(iii)]

69. Non-condensible gases from emissions unit DGEU must be continuously treated by thermal incineration in emissions units RFEU, LKEU, or PBlEU where the non-condensible gases are subjected to a temperature of not less than 650°C (1,200°F) for not less than 0.3 seconds. [OAR 340-234-0210(1)(d)] [State-only enforceable pending EPA approval of Section 111 ( d) Plan]

70. The venting of non-condensible gases must be minimized, but in no case must the time exceed one hour per changeover. [OAR 340-234-02 lO(l)(d)] [State-only enforceable pending EPA approval of Section 1 ll(d) Plan]

NCG Monitoring

71. The permittee must maintain records of which incineration device is being used and the time interval of use for combustion of non-condensible gases and all periods of non-condensible gas bypass. [OAR 340-218-0050(3)]

POWER BOILER NO. 1 (PBlEU)

Table 7 Summary of Requirements for Emissions Unit PBlEU

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

340-218-0050(3) 72 NOx Emission factor Test Report 72 verification test once per permit term


Applicable Condition Pollutant/ Limit/Standard Requirement Number Parameter

340-228-0210(2)(a)(B) 74 PM 0.15 gr/dscf@ 12% CO2

[3 run test average]

340-208-0110(3)(b) 76 Visible emissions 20% opacity, 6-minute block average

PBl EU - Emission Factor Testing for NOx, and CO


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Weekly VE when on oil 77 for 2 consecutive days or more; no monitoring when on natural gas.

Weekly VE when on oil 77 for 2 consecutive days or more; no monitoring when on natural gas.

72. At least once per permit term, a source test for NOx emissions from PB lEU must be conducted in accordance with the requirements of Condition 161 while using natural gas fuel for the purposes of emission factor verification. [OAR 340-218-0050(3)]

73. At least once per permit term, a source test for CO emissions from PB 1 EU must be conducted in accordance with the requirements of Condition 161 while combusting natural gas for the purposes of emission factor verification. [OAR 340-218-0050(3)]

PBlEU --Particulate Matter Standards and Monitoring Requirements

PM Standard

74. Emissions of particulate matter from emissions unit PBlEU must not exceed 0.15 grain per standard cubic foot, corrected to 12% CO2 or 50% excess air. The reference test method for measuring particulate matter emissions from emissions unit PB lEU is Oregon Method 5 unless otherwise approved in the test plan. [OAR 340-228-0210(2)(a)(B)]

PM Testing

75. Reserved.

PBlEU -- Visible Emission Standards and Monitoring Requirements


76. Visible emissions from emissions unit PB lEU must not exceed an opacity equal to or greater than 20 percent as a six-minute block average. [OAR 340-208-0l 10(3)(b)]


77. The permittee must conduct EPA Method 9 tests at least once per week for visible emissions from emissions unit PB lEU when oil is used as the primary fuel for 2 consecutive days or more. [OAR 340-2 l 8-0050(3)(a)(C)]

77 .a. If any test result exceeds the applicable standard specified in Condition 7 6, the permittee must initiate corrective action as soon as is practicable to bring PB 1 EU into compliance with the applicable standards. Upon completion of the corrective action(s), an EPA Method 9 test must be conducted as soon as is practicable to demonstrate that the source is in compliance with the applicable standard.

77 .b. If the permittee is unable to conduct the EPA Method 9 tests due to visual interference caused by other visible emissions sources (e.g., fugitive emissions during high wind conditions) or due


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to weather conditions such as fog, heavy rain, or snow which impair visibility, the observer must note such conditions on the data observation sheet and make at least three attempts to conduct the surveys and/or tests at approximately 2 hour intervals throughout the day. If the visible emissions test could not be conducted on the regularly scheduled day due to interference, the pennittee must conduct the test on the following day.

77.c. Recordkeeping: Records must be maintained of the number of consecutive days oil is burned in PB lEU and of all visible emissions tests and any corrective actions taken.

POWER BOILER NO. 2 (PB2EU)

Table 8 Summary of Requirements for Emissions Unit PB2EU

Condition Pollutant/ Limit/Standard Monitoring Activity Monitoring Number Parameter

Condition Number

340-218-0050(3) 78 NO,, CO Emission factor Test Report 78 verification test once per permit term

340-228-02 l 0(2)(a)(B) 79 PM 0.15 grain/dscf@ 12% None NA co, [3 run test average]

340-208-0110(3 )(b) 80 Visible emissions 20% opacity, 6-minute None NA block average

7/24/87 ACDP, 81 Fuel restriction Only use natural gas or Annual Recordkeeping 82 Condition 8 propane fuels

PP2EU - Emission Factor Testing for NOx and CO

78. At least once per permit term, a source test for NOx and CO emissions from PB2EU must be conducted in accordance with the requirements of Condition 161 for the purposes of emission factor verification. [OAR 340-218-0050(3)].

PB2EU -- Particulate Matter Standards and Monitoring Requirements

79. Emissions of particulate matter from emissions unit PB2EU must not exceed O .15 grain per standard cubic foot, corrected to 12% CO2 or 50% excess air. The reference test method for measuring particulate matter emissions from emissions unit PB2EU is Oregon Method 5 unless otherwise approved in the test plan. [OAR 340-228-0210(2)(a)(B)]

PB2EU --Visible Emission Standards and Monitoring Requirements

80. Visible emissions from emissions unit PB2EU must not exceed an opacity equal to or greater than 20 percent as a six-minute block average. [OAR 340-208-0l 10(3)(b)]

PB2EU -- Fuel Restriction Requirements

81. The pennittee must not use any fuels other than natural gas or propane in emissions unit PB2EU. [7/24/87 ACDP, Condition 8]

82. Recordkeeping: The permittee must maintain records on a calendar year basis demonstrating that only natural gas or propane are combusted in emissions unit PB2EU. The record must be completed within 30 days of the given year.


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OLD CHIP/SAWDUST HANDLING (OCHEU)

T bl 9 S a e ummar yo fR eqmremen s or ' m1ss10ns t f E . ' Ill ' U 'tOCHEU Applicable Condition Pollutant/Parameter Limit/Standard Monitoring Activity Monitoring Requirement Number Condition Number

340-234-0210(4) 83 Visible emissions 20% opacity, 6-minute Monthly VE survey 84 block average

340-226- 85 PM 0.15 gr/dscf Monthlyl&M 87 0210(2)(a)(B)


340-226-0310 86 PM Process weight Table Monthlyl&M 87

[West and East chip per rule

conveying cyclones] [3 run test average]

OCHEU -- Visible Emission Standards and Monitoring Requirements


83. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere from the west and east chip conveying cyclones of emissions unit OCHEU which is equal to or greater than 20% opacity as a six-minute block average, excluding uncombined water. [OAR 340-234-0210(4)]


84. At least once per month, the permittee must conduct a six-minute visible emission survey at the compliance demonstration point of the west and east chip conveying cyclones in emissions unit OCHEU. [OAR 340-2 l 8-0050(3)(a)(C)]

84.a. The permittee must follow the general procedures outlined in EPA Method 22 when conducting the survey. Condensed water vapor is not considered an emission for the purposes of this survey method. The visible emission surveys will be performed by employees or contractors of the permittee who have been trained in the general procedures for determining the presence of visible emissions.

84.b. If visible emissions are identified for more than 5% of the survey time (18 seconds), the pennittee must do one of the following:

84.c.

84.d.

84.b.i. 84.b.ii.

Take corrective action or, Conduct an EPA Method 9 test as soon as is practicable to determine if the applicable opacity standard is being met.

If the pennittee is unable to conduct the survey and/or EPA Method 9 tests due to visual interference caused by other visible emissions sources (e.g., fugitive emissions during high wind conditions) or due to weather conditions such as fog, heavy rain, or snow which impair visibility, the observer must note such conditions on the data observation sheet and make at least three attempts to conduct the surveys and/or tests at approximately 2 hour intervals throughout the day. If the visible emissions survey and/or test could not be conducted on the regularly scheduled day due to interference, the permittee must conduct the test on the following day.

Recordkeeping: The permittee must maintain records of all visible emissions surveys and/or tests and any corrective actions taken.

OCHEU -- Particulate Matter Standards and Monitoring Requirements

PM Standards


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85. Emissions of particulate matter from the west and east chip conveying cyclones in emissions unit OCHEU must not exceed O .15 grains per dry standard cubic foot. The reference test method for measuring particulate matter emissions from emissions unit OCHEU is Oregon Method 8 unless otherwise approved in the test plan [340-226-0210(2)(a)(B)]

86. The permittee must not cause or allow the emission of particulate matter in any one hour in excess of the amount shown in Table 1, OAR 340-226-8010, for the process weight allocated to that process for the west and east chip conveying cyclones in emissions unit OCHEU. The reference test method for measuring particulate matter emissions from the chip conveying cyclones in emissions unit OCHEU is Oregon Method 8 unless otherwise approved in the test plan. [OAR 340-226-03 l O]

PM Monitoring

87. At least once per month, the pennittee must conduct an external inspection of emissions unit OCHEU and repair, as necessary, all material transfer points, conveyor belts, drag chains, drop points, screws, loaders, chippers, screens, ducts, and cyclones. [OAR 340-2 l 8-0050(3)(a)(C)]

87.a. Recordkeeping: The permittee must maintain records of all inspections, fmdings, and corrective actions taken.

NEW CHIP/SAWDUST HANDLING (NCHEU)

a e T bl 10 s ummary o fR eqmrements or < mISSIOns f E mt C 1 U 'N HEU Applicable Condition Pollutant/Parameter Limit/Standard Requirement Number

340-234-0210(4) 88 Visible emissions 20% opacity, 6-minute block average

340-226- 90 PM 0.15 gr/dscf-0210(2)(a)(B) Presteamer surge bins

340-226- #1 and#2

0210(2)(b)(B)

0.14 gr/dscf-Presteamer surge bin #3


340-226-03 l 0 91 PM Process weight Table

[West and East chip per rule

conveying cyclones] [3 run test average]

NCHEU -- Visible Emission Standards and Monitoring Requirements


Monitoring Activity

Monthly VE survey

MonthlyI&M

MonthlyI&M

Monitoring Condition Number

89

92

92

8 8. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere from the presteamer surge bins # 1-#3 of emissions unit NCHEU which is equal to or greater than 20% opacity as a six-minute block average, excluding uncombined water. [OAR 340-234-0210(4)]


89. At least once per month, the pennittee must conduct a six-minute visible emission survey at the compliance demonstration points of the presteamer surge bins #1-#3 in emissions unit NCHEU. [OAR 340-2 l 8-0050(3)(a)(C)]

89.a. The permittee must follow the general procedures outlined in EPA Method 22 when conducting the survey. Condensed water vapor is not considered an emission for the purposes of this


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survey method. The visible emission surveys will be performed by employees or contractors of the permittee who have been trained in the general procedures for determining the presence of visible emissions.

89.b. If visible emissions are identified for more than 5% of the survey time (18 seconds), the permittee must do one of the following:

89.b.i. 89.b.ii.


89.c. If the pennittee is unable to conduct the survey and/or EPA Method 9 tests due to visual interference caused by other visible emissions sources (e.g., fugitive emissions during high wind conditions) or due to weather conditions such as fog, heavy rain, or snow which impair visibility, the observer must note such conditions on the data observation sheet and make at least three attempts to conduct the surveys and/or tests at approximately 2 hour intervals throughout the day. If the visible emissions survey and/or test could not be conducted on the regularly scheduled day due to interference, the permittee must conduct the test on the following day.

89.d. Recordkeeping: The permittee must maintain records of all visible emissions surveys and/or tests and any corrective actions taken.

NCHEU -- Particulate Matter Standards and Monitoring Requirements

PM Standards

90. Emissions ofpatiiculate matter from the presteamer surge bins #1 and #2 in emissions unit NCHEU must not exceed O .15 grains per dry standard cubic foot. Emissions of particulate matter from the presteamer surge bin #3 in emissions unit NCHEU must not exceed 0.14 grains per dry standard cubic foot The reference test method for measuring particulate matter emissions from emissions unit NCHEU is Oregon Method 8 unless otherwise approved in the test plan [340-226-0210(2)(a)(B)]

91. The permittee must not cause or allow the emission of particulate matter in any one hour in excess of the amount shown in Table 1, OAR 340-226-8010, for the process weight allocated to that process for the presteamer surge bins #1-#3 in emissions unit NCHEU. The reference test method for measuring particulate matter emissions from the presteamer surge bins # 1-#3 in emissions unit N CHEU is Oregon Method 8 unless otherwise approved in the test plan. [OAR 340-226-031 O]

PM Monitoring

92. At least once per month, the permittee must conduct an external inspection of emissions unit NCHEU and repair, as necessary, all material transfer points, conveyor belts, drag chains, drop points, screws, loaders, chippers, screens, ducts, presteamer surge bins #1-#3, and the shavings shredder. [OAR 340-218-0050(3)(a)(C)]

92.a. Recordkeeping: The permittee must maintain records of all inspections, findings, and corrective actions taken.

PULP DRYERS (PDEU)

Table 11 Summary of Requirements for Emissions Unit PDEU

Applicable Requirement

Condition Number

Pollutant/Parameter Limit/Standard Monitoring Activity Monitoring Condition Number


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340-234-0210(4) 93 Visible emissions 20% opacity, 6-minute Quarterly VE survey 94 block average

340-226- 95 PM 0.14 gr/dscf One DEQ MS ST once per 97 0210(2)(b)(B) [3 run test average] permit term

340-226-0310 96 PM Process weight Table One DEQ MS ST once per 97 per rule permit term


PDEU -- Visible Emissions Standards and Monitoring Requirements

Visible Emissions Standard

93. The pennittee must not cause or allow the emissions of any air contaminant into the atmosphere from the Flakt dryer in emissions unit PDEU which is equal to or greater than 20% opacity as a six-minute block average, excluding uncombined water. [OAR 340-234-0210(4)]


94. At least once per calendar quarter, the pennittee must conduct a six-minute visible emission survey at the compliance demonstration point(s) of the Flakt dryer in emissions unit PDEU. [OAR 340-218-0050(3)(a)(C)]

94.a. The pennittee must follow the general procedures outlined in EPA Method 22 when conducting the survey. Condensed water vapor is not considered an emission for the purposes of this survey method. The visible emission surveys will be performed by employees or contractors of the permittee who have been trained in the general procedures for determining the presence of visible emissions.

94.b. If visible emissions are identified for more than 5% of the survey time (18 seconds), the permittee must do one of the following:

94.b.i. 94.b.ii.


94.c. If the permittee is unable to conduct the survey and/or EPA Method 9 tests due to visual interference caused by other visible emissions sources (e.g., fugitive emissions during high wind conditions) or due to weather conditions such as fog, heavy rain, or snow which impair visibility, the observer must note such conditions on the data observation sheet and make at least three attempts to conduct the surveys and/or tests at approximately 2 hour intervals throughout the day. If the visible emissions survey and/or test could not be conducted on the regularly scheduled day due to interference, the pennittee must conduct the test on the following day.

94.d. Recordkeeping: The permittee must maintain records of all visible emissions surveys and/or tests and any corrective actions taken.

PDEU -- Particulate Matter Emission Standards and Monitoring Requirements

PM Standards

95. Emissions of particulate matter from the Flakt dryer in emissions unit PDEU must not exceed 0.14 grains per dry standard cubic foot. [OAR 340-226-0210(2)(b)(B)]


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96. The permittee must not cause or allow the emission of particulate matter in any one hour in excess of the amount shown in Table 1, OAR 340-226-8010, for the process weight allocated to that process for the Flakt dryer in emissions unit PDEU. [OAR 340-226-0310]

PDEU - Emission Factor Testing for PM

97. At least once per permit term, a source test for PM emissions from the Flakt dryer must be conducted in accordance with the requirements of Condition 161 for the purposes of emission factor verification and to verify compliance with Condition 95. [OAR 340-218-0050(3)]

LIME STORAGE TANKS (LSTEU)

Table 12 Summary of Requirements for Emissions Unit LSTEU

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

340-234-02 l 0( 4) 98 Visible emissions 20% opacity, 6-minute Quarterly VE survey 99 block average minutes

340-226- 100 PM 0.14 gr/dscf MonthlyI&M 102 0210(2)(b)(B)

avg. of3 test runs

340-226-0310 101 PM Process weight Table per rule

LSTEU -- Visible Emissions Standards and Monitoring Requirements


Monthlyl&M 102

9 8. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere from the lime handling baghouse in emissions unit LSTEU which is equal to or greater than 20% opacity as a sixminute block average, excluding uncombined water. [OAR 340-234-0210(4)]


99. At least once per calendar quaiter, the permittee must conduct a six-minute visible emission survey at the compliance demonstr!ltion point(s) of the lime handling baghouse in emissions unit LSTEU. [OAR 340-218-0050(3)(a)(C)]

99 .a. The permittee must follow the general procedures outlined in EPA Method 22 when conducting the survey. Condensed water vapor is not considered an emission for the purposes of this survey method. The visible emission surveys will be performed by employees or contractors of the permittee who have been trained in the general procedures for determining the presence of visible emissions.

99.b. The surveys must be done during periods when the emissions unit is active.

99.c. If visible emissions are identified for more than 5% of the survey time (18 seconds), the permittee must do one of the following:

99.c.i. Take corrective action or, 99.c.ii. Conduct an EPA Method 9 test as soon as is practicable to determine if the applicable

opacity standard is being met.

99.d. If the permittee is unable to conduct the survey and/or EPA Method 9 tests due to visual interference caused by other visible emissions sources ( e.g., fugitive emissions during high wind


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conditions) or due to weather conditions such as fog, heavy rain, or snow which impair visibility, the observer must note such conditions on the data observation sheet and make at least tlu·ee attempts to conduct the surveys and/or tests at approximately 2 hour intervals tlu·oughout the day. If the visible emissions survey and/or test could not be conducted on the regularly scheduled day due to interference, the permittee must conduct the test on the following day.

99 .e. Recordkeeping: The permittee must maintain records of all visible emissions surveys . and/or tests and any corrective actions taken.

LSTEU --Particulate Matter Emission Standards and Monitoring Requirements

PM Standards

100. Emissions of particulate matter from the lime handling baghouse in emissions unit LSTEU must not exceed 0.14 grains per dry standard cubic foot. The reference test method for measuring particulate matter emissions from LSTEU is Oregon Method 5 unless otherwise approved in the test plan. [OAR 340-226-02 l 0(2)(b )(B)]

101. The pennittee must not cause or allow the emission of particulate matter in any one hour in excess of the amount shown in Table 1, OAR 340-226-8010, for the process weight allocated to that process for emissions unit LSTEU. The reference test method for measuring particulate matter emissions from LSTEU is Oregon Method 5 unless otherwise approved in the test plan. [OAR 340-226-0310]

PM Monitoring

102. At least once per month, the pennittee must conduct an external physical inspection of the Lime Handling System Baghouse (PCD 471-397) and associated duct work for leaks and structural integrity. [OAR 340-2 l 8-0050(3)(a)(C)]

102.a. Recordkeeping: Records must be maintained of all inspections, findings, and any corrective actions taken.

RECAUSTICIZING & RECOVERY SYSTEM (RECEU)

Table 13 Summary of Requirements for Emissions Unit RECEU


340-234-0210(4) 103 Visible emissions 20% opacity, 6-minute block average minutes

340-226- 105 PM 0.14 gr/dscf 0210(2)(b)(B) avg. of 3 test runs

340-226-0310 106 PM Process weight Table per rule

RECEU -- Visible Emissions Standards and Monitoring Requirements


Monitoring Activity

Quarterly VE survey

Daily scrubber water flow

Daily scrubber water flow

Monitoring Condition Number

104

107

107

103. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere from the lime slaker in emissions unit RECEU which is equal to or greater than 20% opacity as a six-minute block average, excluding uncombined water. [OAR 340-234-0210(4)]



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104. At least once per calendar quarter, the permittee must conduct a six-minute visible emission survey at the compliance demonstration point(s) of the lime slaker scrubber in emissions unit RECEU. [OAR 340-2 l 8-0050(3)(a)(C)]

104.a. The pennittee must follow the general procedures outlined in EPA Method 22 when conducting the survey. Condensed water vapor is not considered an emission for the purposes of this survey method. The visible emission surveys will be performed by employees or contractors of the permittee who have been trained in the general procedures for determining the presence of visible emissions.

104.b. The surveys must be done during periods when the emissions unit is active.

104.c. If visible emissions are identified for more than 5% of the survey time (18 seconds), the permittee must do one of the following:

104.c.i. Take corrective action or, 104.c.ii. Conduct an EPA Method 9 test as soon as is practicable to determine if the applicable

opacity standard is being met.

104.d. If the permittee is unable to conduct the survey and/or EPA Method 9 tests due to visual interference caused by other visible emissions sources ( e.g., fugitive emissions during high wind conditions) or due to weather conditions such as fog, heavy rain, or snow which impair visibility, the observer must note such conditions on the data observation sheet and make at least three attempts to conduct the surveys and/or tests at approximately 2 hour intervals throughout the day. If the visible emissions survey and/or test could not be conducted on the regularly scheduled day due to interference, the pennittee must conduct the test on the following day.

104.e. Recordkeeping: The pennittee must maintain records of all visible emissions surveys and/or tests and any corrective actions taken.

RECEU --Particulate Matter Emission Standards and Monitoring Requirements

PM Standards

105. Emissions ofpmticulate matter from the lime slaker in emissions unit RECEU must not exceed 0.14 grains per dry standard cubic foot. The reference test method for measuring particulate matter emissions from RECEU is Oregon Method 5 unless otherwise approved in the test plan. [OAR 340-226-0210(2)(b )(B)]

106. The permittee must not cause or allow the emission of particulate matter in any one hour in excess of the amount shown in Table 1, OAR 340-226-8010, for the process weight allocated to that process for the lime slaker in emissions unit RECEU. The reference test method for measuring particulate matter emissions from RECEU is Oregon Method 5 unless otherwise approved in the test plan. [OAR 340-226-0310]

PM Monitoring

107. At least once per day, the permittee must verify that the water flow is on for the lime slaker scrubber. [OAR 340-2 l 8-0050(3)(a)(C)]

107.a. Recordkeeping: Records must be maintained of the water flow inspections, findings, and any corrective actions taken.

PULP MILL VENTS (PMVEU)


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Table 14 Summary of Requirements for Emissions Unit PMVEU


63.443(a)(l) 108 Organic HAP Capture and treat CPMS for stack exhaust 109 organic HAP temperature and scrubber

water flow


PMVEU -- Pulp & Paper NESHAP Standards and Monitoring Requirements

NESHAP Emission Standard

108. The permittee must capture and treat the organic HAP emissions from emissions unit PMVED in accordance with the requirements of Conditions 131 through 135 [ 40 CFR 63 .443(a)(l)]

NESHAP Emission Monitoring

109. The permittee must continuously monitor the stack effluent gas temperature and the amount of water flow to the Methanol Scrubber (421-566) in accordance with the requirements of Conditions 189 through 198. [40 CFR 63.8 and 63.453]

PMVEU - Emission Factor Testing for CO

110. At least once per permit term, a source test for CO emissions from the Oxygen Reactor Blow Tank must be conducted in accordance with the requirements of Condition 161 for the purposes of emission factor verification. [OAR 340-218-0050(3)]

FIBER RECEIVING (FREU)

Table 15 Summary of Requirements for Emissions Unit FREU

Applicable Condition Pollutant/Parameter Limit/Standard Monitoring Activity Monitoring ~ nt Number Condition Number

340-234-0210(4) 111 Visible emissions 20% opacity, 6 minute Complaint Investigation 113 block average

340-226- 112 PM 0.15 gr/dscf Complaint Investigation 113 0210(2)(a)(B)

avg. of 3 test runs

FREU - Visible Emissions Standards

111. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere from the #3 unloading baghouse in emissions unit FRED which is equal to or greater than 20% opacity as a sixminute block average, excluding uncombined water. [OAR 340-234-0210(4)]

FREU - Particulate Matter Emissions Standards

112. Emissions of particulate matter from the #3 unloading baghouse in emissions unit FRED must not exceed O .15 grains per dry standard cubic foot. The reference test method for measuring particulate


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matter emissions is Oregon Method 5 unless otherwise approved in the test plan. [OAR 340-226-0210(2)(a)(B)]

FREU - Visible Emissions and Particulate Matter Emissions Monitoring Requirements

113. The permittee must investigate air contaminant complaints related to emissions units FREU in accordance with the requirements specified in Condition 7. [OAR 340-2 l 8-0050(3)(a)(C)]

BLEACH PLANT (BPEU)

Table 16 Summary of Requirements for Emissions Unit BPEU


340-234-0210(4) 114 Visible emissions 20% opacity, 6 minute Complaint investigation 116 block average

340-226- 115 PM 0.15 gr/dscf Complaint investigation 116 0210(2)(a)(B) avg. of 3 test runs

§63.445(a)(2) 117 Chlorinated HAP Equipment subject to NA NA standard

§63.445(b) 118 Chlorinated HAP Capture and control Closed vent system 127 bleach plant HAPs requirements [§63.450]

§63.445(c) 119 Chlorinated HAP 99% Reduction Annual Source Test 121

or Continuous parameter 122

Cb:s,)0ppm monitoring

[3-hour average] [§63.453(a)]

or Operate Bleach Plant 123 Scrubber within parameter

Ch :S. 0.002 lb/ton ODP ranges [§63.453(c)] [3-hour average]

Optional Cl CEM 124 [§63.453(d)]

Recordkeeping 204

§63.445(d)(2) 120 Hypochlorite and Use prohibited Certification 122.f.iv Chlorine


340-218-0050(3) 126 voe Emission factor Test Report 126 verification test once per permit term

BPEU -- Visible Emissions Standard

114. The permittee must not cause or allow the emissions of any air contaminant into the atmosphere from the bleach plant scrubber in emissions units BPEU which is equal to or greater than 20% opacity as a six minute block average, excluding uncombined water. The reference test method for measuring opacity from emissions unit BPEU is EPA Method 9. [OAR 340-234-0210(4)]

BPEU - Particulate Matter Emissions Standards

115. Emissions of particulate matter from the bleach plant scrubber in emissions unit BPEU must not exceed 0.15 grains per dry standard cubic foot. [OAR 340-228-0210(2)(a)(B)]


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BPEU - Visible Emissions and Particulate Matter Emissions Monitoring Requirements

116. The permittee must investigate air contaminant complaints related to emissions units BPEU in accordance with the requirements specified in Condition 7. [OAR 340-2 l 8-0050(3)(a)(C)]

BPEU -- Chlorinated HAP Emission Standards and Monitoring Requirements

117. The site specific bleach plant equipment that is subject to the requirements specified in Conditions 118 through 124 is shown in the following listing. [40 CFR 63.445(a)(2)]

Bleach Plant Equipment

■ W-Stage (431-500)

■ W-Stage Filtrate Tank (431-509)

■ 1st Bleach Tower ( 431-515)

■ pt Stage Washer (431-120)

■ pt Stage Seal Tan1c (431-123)

■ yd Stage Bleach Tower (431-138)

■ 3rd Stage Washer (431-141)

■ 3rd Stage Seal Tank ( 431-144)

■ 5th Stage Bleach Tower (431-151)

■ 5th Stage Washer ( 431-154)

■ 5th Stage Seal Tank ( 431-157)

■ White Liquor Day Tank (431-208)

Chlorinated HAP Standards

118. Each bleaching stage where chlorinated bleaching compounds are introduced must be enclosed and vented into a closed-vent system that meets the requirements specified in Condition 127 and routed to a control device that meets the requirements specified in Condition 119. [ 40 CFR 63 .445(b )]

119. The control device used to reduce chlorinated HAP emissions (not including chloroform) from the equipment specified in Condition 117 must: [40 CFR 63.445(c)]

119.a. Reduce the total chlorinated HAP mass in the vent stream entering the control device by 99 percent or more by weight; or

119 .b. Achieve a treatment device outlet concentration of 10 parts per million or less by volume of total HAP (as defined in Condition 178); or

119.c. Achieve a treatment device outlet mass emission rate of0.001 kg of total chlorinated HAP mass per megagram (0.002 pounds/ton) of oven dried pulp.

120. The permittee must use no hypochlorite or chlorine for bleaching in the bleaching system. The presence of small amounts of hypochlorite or chlorine that are by-products or residues of chlorine dioxide production or use does not constitute a violation of this condition. [40 CFR 63.445(d)(2)]

Chlorinated HAP Testing


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121. The permittee must conduct source tests of the Bleach Plant Scrubber (431-550) gas effluent in accordance with the following: [OAR 340-218-0050(3)(a)(C)]

121.a. The permittee must conduct at least one source test per calendar year.

121.b. In the event that changes are made to the bleach plant that require submittal of a construction notice (i.e., a Notice of Approval application), a source test must be conducted within 60 days of the change.

121.c. The source tests must be conducted according to the procedures specified in Conditions 165 through 172 and Condition 178.

Chlorinated HAP Monitoring

122. The permittee must operate and maintain a CMS (including a continuous recorder) in accordance with the requirements specified in Conditions 191 to measure each of the gas scrubber operating parameters as specified below: [40 CFR 63.453(a) and (c)]

122.a. The pH or the oxidation/reduction potential of the gas scrubber effluent.

122.b. The scrubber fan motor status (on or off).

122.c. The gas scrubber liquid influent flow rate.

122.d. The gas scrubber vent gas inlet flow rate.

122.e. Acceptable parameter ranges as determined in Condition 123 must be prominently displayed on the monitoring data screen.

122.f. Recordkeeping: The permittee must maintain records of the following: [OAR 340-218-0050(3)(b)] and [40 CFR 63.454(a)]

122.f.i. 122.f.ii. 122.f.iii. 122.f.iv.

Each 3-hour block average parameter reading. All periods of operation outside of allowed parameter ranges. Operating parameter ranges and the dates on which the ranges were established. The permittee must retain a copy of the certification that certified that no hypochlorite or chlorine, other than small amounts ofhypochlorite or chlorine that are by-products or residues of chlorine dioxide production, will be introduced into the bleaching system on and after April 16, 2001.

123. The Bleach Plant Scrubber must be operated in accordance with the following requirements. [ 40 CFR 63.453(c), (m), and (n)]

123 .a. If an operating parameter is outside the established operating range, the permittee must take corrective action in accordance with the startup, shutdown, and malfunction plan required by Condition Error! Reference source not found ..

123 .b. The permittee may voluntarily re-establish the operating parameter range for the Bleach Plant Scrubber by following the procedure in Condition 123 .c. The revised operating parameter range will be effective retroactively from the date of the source test used to establish the operating parameter range.

123.c. The operating parameter ranges must be re-established as follows:

Permit number: 22-3501-TV-0l Expiration date: 07 /0 l /25

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123.c.i. The operating parameter ranges must be established from parameter monitoring results obtained during source tests that return compliant results, and must conform to the following:

123.c.i.A. The scrubber liquid effluent pH must not be lower than the lowest scrubber effluent pH or the oxidation/reduction potential higher than the highest oxidation/reduction potential monitored during a source test, as a 3-hour block average.

123.c.i.B. The scrubber fan motor must be operating.

123.c.i.C. The gas scrubber liquid influent flow rate must not be lower than the lowest flow rate monitored during a source test, as a 3-hour block average.

123.c.ii. Relevant source tests include:

123 .c.ii.A. All performance and/or source tests required by this permit, and

123.c.ii.B. All voluntary source tests conducted at any time that substantially comply with the source testing requirements in this permit, provided that the permittee can demonstrate to DEQ's satisfaction that the source test(s) were conducted during periods ofrepresentative source operation.

Optional Ch CEM Monitoring

124. As an option to the requirements specified in Condition 122, the pennittee may operate a CMS to measure the chlorine outlet concentration of each gas scrubber used to comply with bleaching system outlet concentration specified in Condition 119.b. [40 CFR 63.453(d)]

BPEU - Emission Factor Testing for CO and VOC

125. At least once per permit term, a source test for CO emissions from the bleach plant scrubber in emissions unit BPEU must be conducted in accordance with the requirements of Condition 161 for the purposes of emission factor verification.• [OAR 340-218-0050(3)(a)(C)]

126. At least once per permit term, a source test for VOC emissions from the bleach pant scrubber in emissions unit BPEU must be conducted in accordance with the requirements of Condition 161 for the purposes of emission factor verification. [OAR 340-2 l 8-0050(3)(a)(C)]

CLOSED VENT SYSTEM REQUIREMENTS

Table 17 Summary of Closed Vent System Requirements

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

§63.450 127 Organic HAP Capture and transport Monthly and annual 128 HAP containing vent l&M streams. For enclosures or hood opening that If inspections show 129 operate under negative a problem, take pressure, maintain the corrective action negative pressure. If within 5 days and positive system, no complete within 15 detectable leaks?: 500 days ppm. Maintain flow

indicator on computer controlled bypass valves. Maintain seals or locks on non- computer controlled bypass valves to ensure they remain closed.

Closed Vent System Standards and Monitoring Requirements

Closed Vent System Standards


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Recordkeeping 130

127. Each enclosure and closed-vent system listed in Table CV-1 for capturing and transporting vent streams that contain HAP must meet the following requirements: [40 CFR 63.450(a)]

TABLE CV-1

HVLC closed-vent system

L VHC closed-vent system

Bleach plant scrubber closed-vent system

Closed-vent systems and condensate storage tanks associated with the pulping condensates closed collection system

127.a. Each enclosure must maintain negative pressure at each enclosure or hood opening as demonsh·ated by the procedures specified in Condition 175 Each enclosure or hood opening closed during the performance test must be maintained in the same closed and sealed position as during the performance test at all times except when necessary to use the opening for sampling, inspection, maintenance, or repairs. [40 CFR 63.450(b)]

127.b. Each component of the closed-vent system used to comply with Condition 132 that is operated at positive pressure and located prior to a conh·ol device must be designed for and operated with no detectable leaks as indicated by an insh'Ulnent reading ofless than 500 parts per million by volume above background, as measured by the procedures specified in Condition 174. [40 CFR 63.450(c)]

127.c. Each bypass line in the closed-vent system that could divert vent sh·eams containing HAP to the atmosphere without meeting the emission limitations in 40 CFR 63.443 (pulping system) or 40 CFR 63.445 (bleaching system) must comply with either of the following requirements: [40 CFR 63.450(d)]

127.c.i. On each bypass line, the permittee must install, calibrate, maintain, and operate according to manufactmer's specifications a flow indicator that provides a record of the presence of gas stream flow in the bypass line at least once every 15 minutes. The flow indicator must be installed in the bypass line in such a way as to indicate flow in the bypass line; or [40 CFR 63.450(d)(l) and 63.454(a) and (e)]

[NOTE: The EPA guidance document "Questions and Answers for the Pulp and Paper NESHAP Second Volume", dated March 31, 2000, states that monitoring the position ( open or closed) of the bypass valve satisfies the requirement for a flow indicator. Also, the duration of the bypass event (i.e., the valve opening) is counted against the period of excess emissions in Condition 134.]

127 .c.ii. For bypass line valves that are not computer conh·olled, the permittee must maintain the bypass line valve in the closed position with a car seal or a seal placed on the valve or closure mechanism in such a way that valve or closure mechanism cannot


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be opened without breaking the seal. [ 40 CFR 63 .450( d)(2)]

Closed Vent System Monitoring

128. Each enclosure and closed vent system used to comply with Condition 127 must comply with the following requirements. [40 CFR 63.453(k)]

Monthly Monitoring

128.a. The following inspections of enclosures and closed-vent systems listed in Table CV-1 are required at least once every 30 days and at other times as requested by DEQ:

128.a.i. For each enclosure opening, a visual inspection eve1y 30 days of the closure mechanism specified in Condition 127.a must be performed to ensure the opening is maintained in the closed position and sealed. [40 CFR 453(k)(l)]

128.a.ii. Each closed-vent system must be visually inspected every 30 days and at other times as requested by DEQ. The visual inspection must include inspection of ductwork, piping, enclosures, and connections to covers for visible evidence of defects. [ 40 CFR 453(k)(2)]

128.a.iii. The valve or closure mechanism specified in Condition 127.c.ii must be visually inspected every 30 days and at other times as requested by DEQ to ensure that the valve is maintained in the closed position and the emission point gas stream is not diverted through the bypass line. [ 40 CFR 453(k)(5)]

Annual Monitoring

128.b. The following inspections of enclosures and closed-vent systems are required to be conducted annually:

128.b.i. For positive pressure closed-vent systems or portions of closed-vent systems, including condensate collection tanks, demonstrate no detectable leaks as specified in Condition 127 .b and measured by the procedures in Condition 174. [40 CFR 453(k)(3)]

128.b.ii. For negative closed-vent systems or portions of closed vent systems, demonstrate that each enclosure opening is maintained at negative pressure as specified in Condition 175. [40 CFR 453(k)(4)]

C01Tective Action Timeline

129. If an inspection required by Condition 128 identifies visible defects in ductwork, piping, enclosures or connections to covers in the closed-vent systems listed in Table CV-1, or if an instrument reading of 500 parts per million by volume or greater above background is measured, or if enclosure openings are not maintained at negative pressure, then the following corrective actions must be taken as soon as practicable. [40 CFR 63.453(k)(6)]

129.a. A first effort to repair or correct the closed-vent system must be made as soon as practicable but no later than 5 calendar days after the problem is identified.

129.b. The repair or corrective action must be completed no later than 15 calendar days after the problem is identified. Delay ofrepair or corrective action is allowed if the repair or corrective action is technically infeasible without a process unit shutdown or if the pennittee determines that the emissions resulting from immediate repair would be equal to or greater than the emissions likely to result from delay or repair. Repair of such equipment must be completed by the end of the next process unit shutdown.


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130. Recordkeeping: For each applicable enclosure opening, closed-vent system, and closed collection system, the permittee must maintain a site-specific inspection plan including a drawing or schematic of the components of applicable affected equipment and must record the following information for each inspection: [40 CFR 63.454(a) and (b)]

130.a. Date of inspection;

130.b. The equipment type and identification;

130.c. Results of negative pressure tests for enclosures;

130.d. Results of leak detection tests;

130.e. The nature of the defect or leak and the method of detection (i.e., visual inspection or instrument detection);

13 0 .f. The date the defect or leak was detected and the date of each attempt to repair the defect or leak;

130.g. Repair methods applied in each attempt to repair the defect or leak;

130.h. The reason for the delay if the defect or leak is not repaired within 15 days after discovery;

130.i. The expected date of successful repair of the defect or leak if the repair is not completed within 15 days;

13 0 .j. The date of successful repair of the defect or leak;

130.k. The position and duration of opening of bypass line valves and the condition of any valve seals; and

130.1. The duration of the use of bypass valves on computer controlled valves.

PULPING SYSTEM REQUIREMENTS (LVHC/HVLC SYSTEMS)

Table 18 Summary of Pulping System Requirements

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

Number

§63.443(a)((l) 131 Organic HAP Must control L VHC and HVLC Operate CMS and 196 through pulping systems as specified in operate within 198 Conditions 13232 and 13333. established parameter

ranges

Recordkeeping 204

§63.443(c) 132 Organic HAP Pulping systems must be enclosed Operate CMS and 196 through and vented into a closed-vent operate within 198 system meeting the requirements established parameter of Condition 1277 and routed to a ranges control device meeting the requirements of Condition 13333.

Recordkeep ing 204

§63.443(d) 133 Organic HAP Control device must reduce total Operate CMS and 196 through HAP emissions: ooerate within 198

Applicable Condition Pollutant/ Limit/ Standard

Permit number: 22-3501-TV-0l Expiration date: 07/01 /25

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Monitoring Monitoring Requirement Number Parameter Requirement Condition

Number

(a) 98% or more by weight; established parameter or ranges (b) concentration ~20 ppm @ 10% 0 2 from a thermal oxidizer;

Record keeping 204 or

( c) use a thermal oxidizer at 1600 °F for 0.75 sec.; or (d) use a boiler, lime kiln, or recovery furnace with HAP emission stream introduced with primary fuel or into flame zone.

§63.443(e) 134 Organic HAP Excess emissions not a violation Recordkeeping 205 if time does not exceed: (a) 1 % for LVHC systems; and (b) 4 % for HVLC systems; and (c) 4% for both LVHC and HVLC systems.

§63.447 135 Organic HAP Clean Condensate Alternative Operate CMS and 196 through requirements operate within 198

established parameter ranges

Recordkeeping 204

Pulping Systems Standards and Monitoring Requirements

Pulping Systems Standards

131. The permittee must control the total HAP emissions from the following equipment systems, as specified in Conditions 132 and 133, unless the pehnittee complies with the clean condensate alternative requirements of Condition 135. [40 CFR 63.443(a)(l)]

131.a. Each LVHC system (clean condensate alternative is not applicable to the LVHC system);

131.b. Each knotter or screen system with total HAP mass emission rates equal to or greater than or equal to the rates specified in paragraphs i or ii, below, or the combined rate specified in paragraph iii, below:

131.b.i. Each knotter system with emissions of 0.05 kilograms or more of total HAP per megagram of ODP (0.1 pounds per ton).

131.b.ii. Each screen system with emissions of 0.10 kilograms or more of total HAP per megagram ofODP (0.2 pounds per ton).

131.b.iii. Each knotter and screen system with emissions of 0.15 kilograms or more of total HAP per megagram of ODP (0.3 pounds per ton).

131.c. Each pulp washing system;

131.d. Each decker system that:

131.d.i. 131.d.ii.

Uses any process water other than fresh water or paper machine white water; or Uses any process water with a total HAP concentration equal to or greater than 400 patis per million by weight; and

131.e. Each oxygen delignification system.

L VHC and HVLC Equipment List


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131.f. The following is a list of mill specific LVHC and HVLC equipment systems that are subject to the requirements of 40 CFR Part 63, Subpart S.

/ LVHC Equipment I ■ #1 Digester (411-109)

■ #2 Digester ( 411-119)

■ #3 Digester ( 411-210)

"■ No. 1 Blow Tank (411-150)

■ Relief Blow Gas Separators # 1 & #2 ( 411-159 and 411-249)

■ No. 1 Blow Gas Condenser (411-160)

■ No. 2 Blow Gas Condenser (411-250)

■ NCG Chiller (411-266)

■ Evaporator Hot Well (451-159)

■ Black Liquor Transfer Tank ( 451-169)

■ NCG Condensate Tank ( 451-170)

■ Strong Black Liquor Tank 9West) (461-103)

■ Strong Black Liquor Tank (East) (461-101)

■ Noss Knotter (421-220)

• Johnson Rejects Drainer (421-106)

The Collection System for this equipment consists of the following:

• Recovery Separator (451-306)

■ Separator

■ NCG West Fan (451-163)

• NCG East Fan (451-161)

• Kiln Fan (481-223)

• Kiln NCG Mist Separator (481-133)

j LVHC Main Vents I • Filter Plant Vent

■ Recovery Vent

• NCG Condensate Tanlc Vent

j HVLC Equipment I • Brownstock Washer #1 (421-112)

• Brownstock Washer #2 (421-114)

• Brownstock Washer #3 (421-116)

■ Filtrate Tank #1 (421-118)

■

■

■

■

■

■

■

■

■

Filtrate Tank #2 (421-129)

Filtrate Tank #3 ( 421-135)

Filtrate Tank #4 ( 421-170)

Decker ( 421-168)

Knots Drainer ( 4 21-107)

Oxygen Reactor Blow Tank (421-435)

HVLC Bypass Vents

Press Vent Fan (421-465)

Oxygen Delignification Blow Tank Vent


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132. Equipment systems listed in Condition 131 must be enclosed and vented into a closed-vent system and routed to a control device that meets the requirements specified in Condition 133. The enclosures and closed-vent system must meet the requirements specified in Condition 127. [40 CFR 63.443(c)]

133. The control device used to reduce total HAP emissions from each equipment system listed in Condition 131 must: [40 CFR63.443(d)]

133.a. Reduce total HAP emissions by 98 percent or more by weight; or [40 CFR 63.443(d)(l)]

13 3. b. Reduce the total HAP concentration at the outlet of the thermal oxidizer by 20 parts per million or less by volume, corrected to 10 percent oxygen on a dry basis; or [40 CFR 63.443(d)(2)]

133.c. Reduce total HAP emission using a thermal oxidizer designed and operated at a minimum temperature of871 °C (1600 °F) and a minimum residence time of0.75 seconds; or [40 CFR 63.443(d)(3)]

133.d. Reduce total HAP emissions using a boiler, lime kiln, or recovery furnace by introducing the HAP emission stream with the primary fuel or into the flame zone; or use a boiler or recovery furnace with a heat input capacity greater than or equal to 44 megawatts (150 million Btu per hour) by introducing the HAP emission stream with the combustion air. [40 CFR 63.443(d)(4)]

Pulping Systems Excess Emissions Standard

134. Periods of excess emissions are not a violation of Conditions 131 through 133 provided that the time of excess emissions divided by the total process operating time in a semi-annual reporting period does not exceed the following levels: [40 CFR 63.443(e)]

134.a. One percent for control devices used to reduce the total HAP emissions from the LVHC system; and

134.b. Four percent for control devices used to reduce the total HAP emissions from the HVLC system; and

134.c. Four percent for control devices used to reduce the total HAP emissions from both the LVHC and HVLC systems.

134.d. Periods of excess emissions include the periods described below, except as noted:


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134.d.i. All periods during which any equipment included in the LVHC and HVLC systems is operating and

134.d.i.A. 134.d.i.B.

134.d.i.C.

A control device is not in use; or A control device is in use but is functioning outside the parameter range; or One or more L VHC and/or HVLC main vent valves is/are open.

134.d.i.C. l Concml'ent periods of time when multiple main vent valves are open will be counted as a single "venting time".

134.d.i.C.2 "Main vent valve" means any valve that, when open, will allow all L VHC and/or HVLC gases to bypass the control device(s) and be emitted directly to atmosphere without treatment. The main vent valves are listed in Condition 13 l.f.

134.d.ii. Typically closed emergency valves, including but not limited to pressure-vacuumrelief (PVR) valves, water seals, rupture discs, sample valves, drain valves, etc., must not be included in the determination of excess emissions.

Clean Condensate Alternative

135. As an alternative to the requirements specified in Conditions 131.b through 131.e for the control of HAP emissions from pulping systems using the Kraft process, the pennittee may demonstrate to the satisfaction of DEQ, by meeting all the requirements of 40 CFR 63 .44 7, that the total HAP emissions reductions achieved by the clean condensate alternative technology are equal to or greater than the total HAP emission reductions that would have been achieved by compliance with Conditions 131.b through 131.e. The clean condensate alternative is not applicable to the L VHC system. [ 40 CFR 63 .44 7]

PULPING PROCESS CONDENSATE STREAM REQUIREMENTS

Table 19 Summary of Pulping Condensate Requirements

Applicable Condition Pollutant/ Limit/ Requirement Number Parameter Standard

§63.446(a) and (b) 136 Organic HAP Listed pulping process condensate streams must meet treatment requirements.

§63.446(c) 137 Organic HAP Must treat:

All listed condensate streams;

-or-

HVLC collection systems and L VHC collection systems plus 65% of remaining streams;

-or-

Collect at least 11.1 lb HAP/ton ODP from listed streams.

§63.446(d) 138 Organic HAP Condensates must be conveyed in a closed collection system that meets hard-piping, control device, and closed vent system requirements. Condensate tanks must have no detectable leaks and openings maintained in a closed, seal position.

§63.453(e) 139 Organic HAP Must treat condensate in accordance with one of the following options:

( 1) Recycle condensate to pulping systems that are collected and controlled.

(2) Discharge condensate below the liquid surface of a biological treatment system that reduces HAP by 92% or more.

(3) Treat in a control device that destroys 92% or more of the total HAP.

(4) Remove 10.2 lb HAP/ ton ODP or meet 330 ppm at control device outlet.

§63.453(f) 140 Organic HAP HAP emissions must be controlled in accordance with Condition 133 if the condensate is treated by any means other than hard-piping.

§63.446(g) 141 Organic HAP For control devices used to meet the requirements of Conditions 139.c or 139.d periods of excess emissions are not a violation of the standards provided the total time of excess emissions does not exceed 10% of the total process operating time in a semi-annual


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Monitoring Monitoring Requirement Condition

Recordkeeping 130

Operate CMS 144

Monthly collection 145, 146 inspection

Recordkeeping 130

Monthlyl&M 149

Start repairs within 5 152 days and complete within 15.

Annual Condensate 151 Tank inspection for leaks

Recordkeeping 130

Daily parameter 147 monitoring

Monthly! & M 149

Start repairs within 5 152 days and complete within 15.

Quarterly 148 perfonnance test

Parameter excursion 153 test

Recordkeeping 154

None NA

Recordkeeping 205

Applicable Condition Pollutant/ Limit/


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Monitoring Monitoring Requirement Number Parameter Standard Requirement Condition

period.

§63.446(h) 142 Organic HAP Evaluate new or modified pulping Recordkeeping process condensates or changes in bleaching

§63.446(i) 143 Organic HAP Mill may meet prorated mass Recordkeeping standard if both bleached and unbleached products are produced

Pulping Process Condensates Standards

136. The pulping process condensates from the following equipment systems must be treated to meet the requirements specified in Conditions 137, 138, and 139. [40 CFR 63.446 (a) and (b)]:

136.a. Each digester system;

136.b. Each tmpentine recovery system;

136.c. Each evaporator system condensate from:

136.c.i. The vapors from each stage where weak liquor is introduced (feed stages); and 136.c.ii. Each evaporator vacuum system for each stage where weak liquor is introduced (feed

stages).

136.d. Each HVLC collection system; and

136.e. Each LVHC collection system.

136.f. The following is a list of the mill-specific pulping condensate streams that are subject to the 40 CFR Pait 63, Subpatt S requirements in this permit.

j Condensate Streams I ■ No. 1 Blow Gas Condenser ■ No. 2 Blow Gas Condenser ■ NCG Chiller ■ NCG Condensates at Recovery ■ Combined Evaporator Condensates ■ NCO Condensates at Kiln

Note: The No. 1 Blow Gas Condenser, No. 2 Blow Gas Condenser, NCG Chiller, and the NCO Condensates from Recovery go to a NCO condensate tank for collection and then to the hard pipe sewer system.

Note: The Combined Evaporator Condensates are directly piped to the hard pipe sewer system.

Note: The NCG Condensates at Kiln come from the NCG mist separator (431-133) at the kiln and are directly piped to the hard pipe sewer system.

137. One of the following combinations of HAP-containing pulping process condensates generated, produced, or associated with the equipment systems listed in Condition 1366 must be subject to the requirements of Conditions 138 and 139: [40 CFR 63.446(c)]


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137.a. All pulping process condensates from the equipment systems specified in Conditions 136.a through 136.e. [40 CFR 63.446(c)(l)]

137.b. The combined pulping process condensates from the equipment systems specified in Conditions 136.d and 136.e, plus pulping process condensate stream(s) that in total contain at least 65% of the total HAP mass from the pulping process condensates from equipment systems listed in Condition 136.a through 136.c. [40 CFR 63.446(c)(2)]

137.c. The pulping process condensates from equipment systems listed in Conditions 136.a through 136.e that in total contain a total HAP mass of 5.5 kilograms per megagram (11.1 pounds per ton) ofoven dried pulp. [ 40 CFR 63 .446( c )(3 )]

138. The pulping process condensates from the equipment systems listed in Condition 136 must be conveyed in a closed collection system that is designed and operated to meet the following requirements: [40 CFR 63.446(d)]

13 8.a. Each closed collection system must meet the individual drain system requirements specified in 40 CFR 63.960, 961, and 962, except closed vent systems must be designed and operated in accordance with Condition 127 and control devices must be designed an operated in accordance with Condition 133. [40 CFR 63.446(d)(l)]

138.b. The pennittee must control air emissions from the individual drain system using one or a combination of the following: [40 CFR 63.962(a)]

138.b.i.

138.b.ii. 138.b.iii.

Covers, water seals, and other air emission control equipment as specified in Condition 13 8.c.ii. Hard-piping. Venting of the individual drain system through a closed vent system to a control device and the individual drain system is designed and operated such that an internal pressure in the vapor headspace in the system is maintained at a level less than atmospheric pressure when the control device is operating.

13 8 .c. If air emissions from an individual drain system are being controlled in accordance with Condition 138.b.i, the pennittee must meet the following requirements: [40 CFR 63.962(b)]

138.c.i.

138.c.ii.

The individual drain system must be designed to segregate the organic vapors from regulated material managed in the controlled individual drain system from entering any other individual drain system that is not controlled for air emissions in accordance with the standards specified in this permit. Drain control requirements. Each drain must be equipped with either a water seal or a closure device in accordance with the following requirements:

138.c.ii.A. When a water seal is used, the water seal must be designed such that either:

13 8 .c.ii.A. l The outlet to the pipe discharging the regulated material extends below the liquid surface in the water seal of the drain; or

138.c.ii.A.2 A flexible shield or other device is installed which restricts wind motion across the open space between the outlet of the pipe discharging the regulated material and the drain.

138.c.ii.B. When a closure device is used (e.g., securing a cap or plug on a drain


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that is not receiving regulated material), the closure device must be designed to operate such that when the closure device is secured in the closed position there are no visible cracks, holes, gaps, or other open spaces in the closure device or between the perimeter of the drain opening and the closure device.

138.c.iii. Junction box control requirements. Each junction box must be equipped with controls as follows:

138.c.iii.A. The junction box must be equipped with a closure device (e.g., manhole cover, access hatch) that is designed to operate such that when the closure device is secured in the closed position there are no visible cracks, holes, gaps, or other open spaces in the closure device or between the perimeter of the junction box opening and the closure device.

138.c.iii.B. If the junction box is vented, the junction box must be vented in accordance with the following requirements:

138.c.iii.B. l The junction box must be vented through a closed vent system to a conh·ol device in accordance with the requirements of Condition 138.a.

138.c.iii.B.2 As an alternative to Condition 138.c.iii.B, the pennittee may vent the junction box directly to the atmosphere when all of the following conditions are met:

138.c.iii.B.2. l The junction box is filled and emptied by gravity flow (i.e., there is not pump) or is operated with no more than slight fluctuations in the liquid level. Large changes in the size of the junction box vapor headspace created by using a pump to repeatedly empty and then refill the junction box do not meet this condition.

138.c.iii.B.2.2 The vent pipe installed on the junction box must be at least 90 centimeters in length and no greater than 10 centimeters in nominal inside diameter.

138.c.iii.B.2.3 Water seals are installed at the liquid entrances(s) to or exit from the junction box to restrict ventilation in the individual drain system and between components in the individual drain system. The permittee must demonsh·ate (e.g., by visual inspection or smoke test) upon request by DEQ that the junction box water seal is properly designed and resh·icts ventilation.

138.c.iv. Sewer line control requirements. Each sewer line must not be open to the atmosphere and must be covered or closed in a manner such that there are no visible cracks, holes,

138.c.v.


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gaps, or other open spaces in the sewer line joints, seals, or other emission interfaces.

Operating requirements. The permittee must operate the air emission controls required by Conditions 138.c.ii through 138.c.iv in accordance with the following requirements:

138.c.v.A. Each closure device must be maintained in a closed position whenever regulated material is in the individual drain system except when it is necessary to remove or open the closure device for sampling or removing material in the individual drain system, or for equipment inspection, maintenance, or repair.

138.c.v.B. Each drain equipped with a water seal and open to the atmosphere must be operated to ensure that the liquid in the water seal is maintained at the appropriate level. Examples of acceptable means for complying with this provision include but are not limited to using a flow-monitoring device indicating positive flow from a main to a branch water line supplying a trap; continuously dripping water into the trap using a hose; or regular visual observations.

13 8 .d. If a condensate tank is used in the closed collection system, the tank must meet the following requirements: [40 CFR 63.446(d)(2)]

138.d.i. The fixed roof and all openings (e.g., access hatches, sampling ports, gauge wells) must be designed and operated with no detectable leaks as indicated by an instrument reading of less than 500 parts per million above background, and vented into a closed-vent system that meets the requirements in Condition 127 and routed to a control device that meets the requirements in Condition 133.

138.d.ii. Each opening must be maintained in a closed, sealed position (e.g., covered by a lid that is gasketed and latched) at all times that the tank contains regulated pulping process condensates or any HAP removed from a pulping process condensate stream except when it is necessary to use the opening for sampling, removal, or for equipment inspection, maintenance, or repair.

139. Each pulping process condensate specified in Conditions 136.a through 136.e must be treated according to one of the following options: [40 CFR 63.446(e)]

139.a. Recycle the pulping process condensate to an equipment system specified in Condition 131 meeting the requirements specified in Conditions 132 and 133; or [40 CFR 63.446(e)(l)]

139.b. Discharge the pulping process condensate below the liquid surface of a biological treatment system and treat the pulping condensates to meet the requirements specified in Conditions 139.c tlu·ough 139.d, and total HAP must be measured as specified in Condition 177; or [40 CFR 63.446(e)(2)]

139.c. Treat the pulping process condensates to reduce or destroy the total HAP by 92 percent or more by weight; or [40 CFR 63.446(e)(3)]

139.d. At mills that do not perform bleaching, treat the pulping process condensates to remove 3.3 kilograms or more of total HAP per megagram (6.6 pounds/ton) of oven dried pulp or achieve a total HAP concentration of 210 parts per million or less by weight at outlet of the control device; or [40 CFR 63.446(e)(4)]

139.e. At mills that perform bleaching, treat the pulping process condensates to remove 5.1


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kilograms or more of total HAP per megagram (10.2 pounds per ton) of ODP, or achieve a total HAP concentration of330 parts per million or less by weight at the outlet of the control device. [40 CFR 63.446(e)(5)]

140. Each HAP removed from a pulping process condensate stream during treatment and handling under Conditions 13 8 and 139, except for those treated according to Condition 139.b, must be controlled as specified in Conditions 132 and _133. [40 CFR 63.446(£)]

141. For each control device used to treat pulping process condensates to comply with the requirements specified in Conditions 138.c or 138.d, periods of excess emissions shall not be a violation ofthe standards provided that the time of excess emissions divided by the total process operating time in a semi-annual reporting period does not exceed 10 percent. The 10 percent excess emissions allowance does not apply to treatment of pulping process condensates where the pulping process condensates are discharged below the liquid surface of a biological treatment system. [ 40 CFR 63 .446(g)]

142. The permittee must evaluate all new or modified pulping process condensates or changes in the annual bleached or non-bleached oven dried pulp used to comply with Condition 143, to determine if they meet the applicable requirements. [ 40 CFR 63 .446(h)]

143. For the purposes of meeting the requirements in Conditions 137.b or 137.c or Conditions 139.d or 139.e at mills producing both bleached and unbleached pulp products, the permittee may meet a prorated mass standard that is calculated by prorating the applicable mass standards (kilograms of total HAP per megagram ofODP) for bleached and unbleached mills specified in Conditions 137.b or 137.c or Conditions 139.d or 139.e by the ratio of annual megagrams of bleached and unbleached oven dried pulp. [40 CFR 63.446(i)]

Pulping Condensate Monitoring Requirements

CMS Operation

144. A continuous monitoring system (CMS) must be operated in accordance with Condition 191 to measure the appropriate parameters determined according to the procedures specified in Condition 197 to comply with the condensate applicability requirements specified in Condition 137. [40 CFR 63.453(a) and (i)]

Inspection Procedures

145. The permittee must maintain a written inspection procedure which will be used to demonstrate compliance with the pulping condensate collection requirement. [OAR 340-218-0050(3)(a)(C)]

145.a. The inspection procedure must include, at a minimum, the following:

145.a.i. 145 .a.ii.

145 .a.iii.

145.a.iv.

A list and description of all condensate streams that are to be collected; A list of all valves that can divert condensate streams away from the condensate treatment system;

The valve list must include the proper position, setting, etc. of each valve that will ensure that the condensate stream is directed to the treatment system;

A diagram showing the locations of all condensate streams which are to be collected;

145.a.v. The diagram must also show the locations of all valves that can divert condensate streams away from the condensate treatment system.

(Note: For the purpose of this condition, the term valve includes valves and all other devices that can divert the flow of a condensate stream from one location to another.)


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145.b. The pennittee must revise and update the inspection procedure whenever changes are made to the condensate collection system.

145.c. Recordkeeping The inspection procedures must be maintained on file and made available to inspectors upon request.

Monthly Collection Inspection

146. At least once each calendar month the permittee must demonstrate compliance with the pulping condensate collection requirement by completing an inspection of the pulping condensate collection system and verifying that all required streams are being collected. [OAR 340-218-0050(3)(a)(C)]

146.a. Recordkeeping: Records of the inspection results must be maintained on site and made available to inspectors upon request.

Daily Monitoring

14 7. On a daily basis, the permittee must perform the monitoring procedures specified below for each open biological treatment system. [40 CFR 63.453G)]

147.a. If the Inlet and Outlet Concentration Measurement Procedure (Procedure 3) in appendix C of 40 CFR Part 63 is used to determine the fraction of HAP compounds degraded in the biological treahnents system as specified in Condition 182, then the pennittee must obtain daily inlet and outlet grab samples from each biological h·eatment unit to have HAP data available to perform the quarterly performance tests specified in Condition 148 and the compliance test specified in Condition 153. [40 CFR 63.453G)(l)(ii)]

147.b. The permittee has received approval to monitor alternate parameters, and must conduct daily monitoring of the site-specific parameters established according to the procedures specified in Condition 197. [40 CFR 63.4530)(2) and (n)]

147.c. Recordkeeping: The permittee must record the following:

Quarterly Testing

147.c.i. 14 7 .c.ii.

14 7 .c.iii.

The value(s) of the approved operating parameter(s); The dates of any parameter out-of-range excursion, and the results of the performance test if one is performed; and

Any maintenance or changes made to the process or conh·ol device after the beginning ofa parameter excursion that would influence the results of the determination.

148. The permittee must conduct a perfonnance test as specified in Condition 182 within 45 days after the beginning of each quarter and meet the applicable emission limit in Condition 139.b. [40 CFR 63.4530)(3)]

148.a. The performance test conducted in the first quarter (annually) must be performed for total HAP as specified in Condition 177 and meet the percent reduction or mass removal emission limit specified in Condition 139.b.

148.b. The remaining quarterly performance tests must be performed as specified in Condition 148.a, except the permittee may use the applicable methanol procedure in Condition 182.a or Condition 182. b and the value of r determined during the first quarter test instead of measuring the additional HAP to determine a new value of r.


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Monthly and Annual Condensate Collection Monitoring

149. Each pulping process condensate closed collection system used to comply with Condition 138 must comply with the requirements specified in Conditions 150 through 152. [40 CFR 63.453(1)]

150. Each pulping process condensate closed collection system must be visually inspected at least once every 30 days and must comply with the following requirements: [40 CFR 63.453(1)(1) and 63.964]

150.a. The individual drain system must be visually inspected as follows to check for defects that could l'esult in air emissions to the atmosphere. [40 CFR 63.964(a)(l)]

150.a.i. The permittee must visually inspect each drain as follows: [40 CFR 63.964(a)(l)(i)]

150.a.i.A. When the drain is using a water seal to control air emissions, the permittee must verify appropriate liquid levels are being maintained and identify any other defects that could reduce water seal control effectiveness.

150.a.i.B. When the drain is using a closure device to control air emissions, the permittee must visually inspect each drain to verify that the closure device is in place and there are no defects. Defects include, but are not limited to, visible cracks, holes, or gaps in the closure devices; broken, cracked, or otherwise damaged seals or gaskets on closure devices; and broken or missing plugs, caps, or other closure devices.

150.a.ii. The pennittee must visually inspect each junction box to verify that closure devices are in place and there are no defects. Defects include, but are not limited to, visible cracks, holes, or gaps in the closure devices; broken, cracked, or otherwise damaged seals or gaskets on closure devices; and broken or missing hatches, access covers, caps, or other closure devices. [40 CFR 63.964(a)(l)(ii)]

150.a.iii. The permittee must visually inspect the unburied portion of each sewer line to verify that all closure devices are in place and there are no defects. Defects include, but are not limited to, visible cracks, holes, gaps, or other open spaces in the sewer line joints, seals, or other emission interfaces. [40 CFR 63.964(a)(l)(iii)]

150.a.iv. In the event that a defect is detected, the permittee must repair the defect in accordance with Condition 152. [40 CFR 63.964(a)(l)(v)]

150.b. Recordkeeping: The permittee must comply with the recordkeeping requirements of 40 CFR 63 .454 instead of the requirements specified in 40 CFR 63 .964(a)(l)(vi) and (b)(3). [40 CFR 63.453(l)(l)(i)]

150.c. The pennittee must comply with the inspection and monitoring requirements for closed vent systems as specified in Condition 127 and control devices as specified in Condition 133 instead of the requirements specified in 40 CFR 63.964(a)(2). [40 CFR 63.453(l)(l)(ii)]

150.d. The permittee must prepare and maintain the following records: [40 CFR 63.965(a)(l) and (2)]

150.d.i.

150.d.ii.

A written site-specific individual drain system inspection plan that includes a drawing or schematic of the individual drain system and identifies each drain, junction box, and sewer line location. A record of the date that each inspection required by Condition 149 is performed.

151. Each condensate tank used in the closed collection system must be operated with no detectable leaks as specified in Condition 138.c measured annually by the procedures specified in Condition 174.

[40 CFR 63.453(1)(2)]


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152. If an inspection identifies visible defects in the closed collection system, or if an instrument reading of 500 ppm or equal to or greater than above background is measured, the following corrective actions must be taken: [40 CFR 63.453(1)(3)] and [40 CFR 63.964(b)]

152.a. The permittee must make first efforts at repair of the defect no later than 5 calendar days after detection and repair must be completed as soon as possible but not later than 15 calendar days after detection except as provided in Condition 152.b. [40 CFR 63.964(b)(l)]

152.b. Repair of a defect may be delayed beyond 15 calendar days if the permittee determines that repair of the defect requires emptying or temporary removal from service of the individual drain system .and no alternative capacity is available at the facility site to accept the wastewater normally managed in the individual drain system. In this case, the pennittee must repair the defect at the next time the process or unit that is generating the wastewater managed in individual drain system stops operation. Repair of the defect must be completed before the process or unit resumes operation. [40 CFR 63.964(b)(2)]

Operating Parameter Excursion Testing

153. The procedures of this condition apply to each pennittee of an open biological treatment system complying with Condition 147 whenever a monitoring parameter excursion occurs, and the permittee chooses to conduct a performance test to demonstrate compliance with the applicable emission limit. A monitoring parameter excursion occurs whenever the monitoring parameters specified in Condition 14 7 are below minimum operating parameter values or above maximum operating values established in accordance with Condition 197. [40 CFR 63.453(p)]

153.a. As soon as practical after the beginning of the monitoring parameter excursion, the following requirements must be met: [40 CFR 63.453(p)(l)]

153.a.i. Before the steps in Conditions 153.a.ii or 153.a.iii are performed, all sampling and measurements necessary to meet the performance test requirements in Condition 153.b must be conducted.

153 .a.ii. Steps must be taken to repair or adjust the operation of the process to end the parameter excursion period.

153 .a.iii. Steps must be taken to minimize total HAP emissions to the atmosphere during the parameter excursion period.

153.b. A parameter excursion is not a violation of the applicable emission standard if the results of the performance test conducted using the following procedures demonstrate compliance with the applicable emission limit in Condition 139.b. [40 CFR 63.453(p)(2)]

153.b.i. Conduct a performance test as specified in Conditions 172 through 184 using the monitoring data specified in Condition 14 7 that coincides with the time of the parameter excursion. No maintenance or changes must be made to the open biological treatment system after the beginning of a parameter excursion that would influence the results of the performance test. [40 CFR63.453(p)(2)(i)]

153.b.ii. If the results of the performance test specified in Condition 153.b.i demonstrate compliance with the applicable emission limit in Condition 139.b, then the parameter excursion is not a violation of the applicable emission limit. [40 CFR 63.453(p)(2)(ii)]

153.b.iii. If the results of the performance test specified in Condition 153.b.i do not demonstrate compliance with the applicable emission limit in Condition 139.b


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because the total HAP mass entering the open biological treatment system is below the level needed to demonstrate compliance with the applicable emission limit in Condition 139.b, then the permittee must perform the following comparisons: [40 CFR 63.453(p)(2)(iii)]

153 .b.iii.A. If the fbio (MeOH) determined during the performance test is within the range of values established during the initial and subsequent performance tests approved by DEQ, then parameter excursion is not a violation of the applicable standard.

153.b.iii.B. If the fbio (MeOH) determined during the performance test is not within the range of values established during the initial and subsequent performance tests approved by DEQ, then parameter excursion is a violation of the applicable standard.

153.b.iv. Recordkeeping: The results of the performance test specified in Condition 153.b.i must be recorded as specified in Condition 154. [40 CFR 63.453(p)(2)(iv)]

Unsafe sampling conditions procedure

153.c. If the permittee determines that performing the required procedures under Condition 153.b for a nonthoroughly mixed open biological system would expose a worker to dangerous, hazardous, or otherwise unsafe sampling conditions, all of the following procedures must be performed: [40 CFR 63.453(p)(3)]

Recordkeeping

153.c.i. Calculate the mass removal or percent reduction value using the procedures specified in Condition 182 except the value for fbio (MeOH) must be detennined using the procedures in appendix E to 40 CFR Part 63. [ 40 CFR 63.453(p)(3)(i)]

153 .c.ii. Repeat the procedures in Condition 153 .c.i for every day until the unsafe conditions have passed. [40 CFR 63.453(p)(3)(ii)]

153 .c.iii. A parameter excursion is a violation of the standard if the percent reduction or mass removal determined in Condition 153 .c.i is less than the percent reduction or mass removal standards specified in Condition 139.b, as appropriate, unless the value of fbio (MeOH) determined using the procedures in appendix E to 40 CFR Pati 63, as specified in Condition 153.c.i, is within the range offbio (MeOH) established during the initial and subsequent performance tests previously approved by DEQ. [40 CFR 63 .453(p )(3)(iii)]

15 3 .c.iv. The determination that there is a condition that exposes a worker to dangerous, hazardous, or otherwise unsafe conditions must be documented and repmied in accordance with Condition 230. [40 CFR 63.453(p)(3)(iv)]

153.c.v. The requirements of Conditions 153.a and 153.b must be performed and met as soon as practical but no later than 24 hours after the conditions have passed that exposed a worker to dangerous, hazardous, or otherwise unsafe conditions. [40 CFR 63.453(p)(3)(v)]

154. The permittee of an open biological treatment system complying with Condition 153 must prepare a written record specifying the results of the performance test specified in Condition 153.b. [40 CFR 63.454(a) and (f)]

Insignificant Activities Emission Limits and Standards

155. DEQ acknowledges that insignificant emissions units (IEUs) identified by rule as either categorically insignificant activities or aggregate insignificant emissions as defined in OAR 340-200-0020 exist at facilities required to obtain an Oregon Title V Operating Permit. IEUs must comply with all applicable


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requirements. In general, the requirements that could apply to IEUs are incorporated as follows:

155.a. OAR 340-208-0110 (20% opacity).

155.b. OAR 340-228-0210 (gr/dscf corrected to 12% CO2 or 50% excess air for fuel burning equipment).

155.c. OAR 340-226-0210 (gr/dscffor non-fugitive, non-fuel burning equipment).

155.d. OAR 340-226-0310 (process weight limit for non-fugitive, non-fuel burning process equipment).

155.e. Reciprocating Internal Combustion Engine (RICE) NESHAP and NSPS

155.e.i. The permittee must comply with the provisions of 40 CFR Part 63 Subpart ZZZZ using the following work practices for the emergency fire pump and chlorine dioxide generators. There is no time limit on emergency operation of the emergency generators.

155 .e.ii.

155.e.i.A.

155.e.i.B.

155.e.i.C.

155.e.i.D. 155.e.i.E.

155.e.i.F.

155.e.i.G.

155.e.i.H

155.e.i.I.

155.e.i.J.

155e.i.K.

Change oil/filter annually or every 500 hours of operation; whichever comes first or use an oil analysis program to extend the interval for oil changes. [40 CFR 63.6602, 63.6640(a) Table 2c(l), and 63.6625(i)] Inspect hoses/belts annually or every 500 hours of

· operation; whichever comes first and replace as necessary. [40 CFR 63.6602 and 63.6640(a) Table 2c(l)]

Inspect air cleaner annually or every 1,000 hours; whichever comes first. [40 CFR 63.6602 and 63.6640(a) Table 2c(l)] Install non-resettable hour meter. [ 40 CFR 63 .6625(£)] Maintain engine in accordance with manufacturer's emissions-related written instructions or develop sitespecific maintenance plan. [40 CFR 63.6625(e)(2)] Minimize engine idle time and limit start up time to less than 30 minutes. [40 CFR 63.6625(11) and Table 2c] Non-emergency operation cannot exceed 50 hours per year. [40 CFR 63.6640(£)(3)] Maintenance and testing hours are limited to less than 100 hours per year. [40 CFR 63.6640(f)(2)(i)] Operate consistent with good air pollution practices to minimize emissions as practicable per Table 6.9. [40 CFR 63.6605(a) and (b) and 63.6640(a)] Record hours of emergency and non-emergency operation. [40 CFR 63.6655(d)-(f)] Maintain records for 5 years in readable available format. [40 CFR 63.6660a-c]

The pennittee must comply with the provisions of 40 CFR Part 60 Subpart JJJJ using the following work practices for the emergency lime kiln auxiliary generator. There is no time limit on emergency operation of the emergency generator.

155.e.ii.A.

155.e.ii.B.

Comply with 40 CFR 63.6590(c) and 40 CFR 60.4320(a)(2) and follow manufacturer's instructions. Manufacturer standards for emissions at 40 CFR Part 1054 apply for the life of the engine per 40 CFR 60.4232 and certified by 40 CFR 60.423 8.

155.e.ii.C.

155.e.ii.D. 155.e.ii.E.

155.e.ii.F.

155.e.ii.G

155.e.ii.H. 155.e.ii.I.


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Use only gasoline meeting the sulfur limit of 40 CFR 80.195. Operate non-resettable hour meter. [40 CFR 60.4237(c)] Maintain engine and control device in accordance with manufacturer's written instructions to meet 40 CFR Part 1068, subparts A-D requirements. [40 CFR 60.4243(a)(l)] Non-emergency operation cannot exceed 50 hours per year. [40 CFR 60.4243(d)(3)] Maintenance and testing hours are limited to less than 100 hours per year. [40 CFR 60.4243(d)(2)] Record hours of emergency and non-emergency operation. Keep maintenance and other records for 5 years in readable available format. [40 CFR 60.4243(a)(l)]

State NESHAP Replacement for the Gasoline Dispensing Facility NESHAP

155.f. The pennittee must not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for extended periods of time. Measures to be taken include, but are not limited to the following: [40 CFR 63.1 l l 16(a), (b), (d) and OAR 340-244-0240, federally enforceable]

155.f.i. Minimize gasoline spills; 155.f.ii. Clean up spills as expeditiously as practicable; 155.f.iii. Cover all open gasoline containers and all gasoline storage tank fill-pipes with a

gasketed seal when not in use; 155.f.iv. Minimize gasoline sent to open waste collection systems that collect and transport

gasoline to reclamation and recycling devices, such as oil/water separators. 155 .f.v. The permittee is not required to submit the notifications or reports as specified in 40

CFR 63.11124 and 63.11126, or subpart A, by the permit must have records available within 24 hours of a request by DEQ to document gasoline throughput.

155.f.vi. Portable gasoline containers that meet the requirements of 40 CFR Part 59, subpart F, are considered acceptable for compliance with Condition 155.f.iii.

155.g. In addition to the measures specified in Condition 155.f, the permittee must take the following measures to minimize vapor releases: [OAR 340-244-0240, state only enforceable]

155.g.i. Do not top off or overfill vehicle tanks. Ifa person can confirm that a vehicle tank is not full after the nozzle clicks off (such as by checking the vehicle's fuel tank gauge), the person may continue to dispense fuel using best judgment and caution to prevent a spill;

155.g.ii. Post a sign at the gasoline dispensing facility (GDF) instructing a person filling up a motor vehicle to not top off the vehicle tank;

155.g.iii. Ensure that cargo tanks unloading at the GDF comply with Conditions 155.f.i through 155.f.iii, 155.g.i, and 155.g.ii.

155.g.iv. The permittee must only load gasoline into storage tanks at the facility by utilizing submerged filling, as defined in OAR 340-244-0030. The submerged fill pipe must be no more than 12 inches from the bottom of the storage tank.

156. Testing, Monitoring, and Recordkeeping Requirements: 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 and perform the testing in accordance with DEQ's Source Sampling Manual.

PLANT SITE EMISSION LIMITS


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

Plant Site Emission Limit Unassigned Emissions Pollutant (tons/year) (tons/year)

PM 370 25

PM10 248 15

PM2.s 196 10

SO2 610 40

NOx 558 0

co 1163 100

voe 372 0

TRS 36 7

H2SO4 17 0

GHG (CO2e) 839,800 0

157.a. The permittee may only use Unassigned Emissions after any necessary construction (OAR 340-218-0190) and permit revision applications (OAR 340-218-0120 through 340-218-0180) have been approved by DEQ.

Plant Site Emission Limit Monitoring

158. The pennittee must determine compliance with the Plant Site Emission Limits established in Condition 157 of this permit by conducting monitoring in accordance with the following procedures: [OAR 340-218-0050(3)(a)]

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

Process Parameters Units Frequency

black liquor solids Tons monthly and annual

fuel oil usage Mgal monthly and annual

lime production Tons monthly and annual

brown pulp production Air dried tons unbleached pulp monthly and annual

pulp production Oven dried tons unbleached pulp monthly and annual

pulp production Air dried meh·ic tons unbleached monthly and annual pulp

pulp productiona ir dried tons bleached pulp monthly and annual

natural gas fuel usage MMft3 monthly and annual

purchased lime Tons monthly and annual

wood chips/sawdust Bone dry units monthly and annual

wood fines Bone dry units monthly and annual

facility wide usage ofVOC Gallons or pounds monthly and annual containing substances

non-condensible gases Hours monthly and annual


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15 8. b. The emission factors for calculating pollutant emissions are as follows:

EUID Process/Device Pollutant Annual EF Units

RFEU All fuels co See Condition 158.h Tons

All fuels so, See Condition 158.f Tons

All fuels TRS See Condition 158.g Tons

All fuels H,SO4 0,02 lb/ pound SO,

(461-128) BLS & NCO combustion NO, 0.90 lb/ton BLS

Oil combustion NO, 47 lb/Mgal oil

Natural Gas Combustion NO, 280 lb/MM ft3 nat. gas

BLS & NCO combustion PM/PM10 0.416 lb/ton BLS

BLS & NCO combustion PM,.s 0.374 lb/ton BLS

Oil combustion PM/PM10 0.21/0.15 lb/Mgal oil

Oil combustion PM,.s 0.12 lb/Mgal oil

Natural Gas Combustion PM/PM10/ 2.5 lb/MM ft3 nat. gas

PM2.s

BLS & NCO combustion voe 0.0238 lb/ton BLS

Oil combustion voe 0.76 lb/Mgal oil

Natural Gas Combustion voe 5.5 lb/MM ft3 nat. gas

LKEU All fuels co I.OS lb/tonCaO

(481-130) All fuels NO, 0.694 lb/ton Cao

All fuels PM 0.698 lb/ton Cao

All fuels PM10 0.663 lb/ton Cao

All fuels PM2.s 0.650 lb/tonCaO

Natural Gas Combustion so, 0.013 lb/ton Cao

Oil Combustion so, 1.44 lb/Mgal

NCO Combustion so, 15.6 lb/hour

All fuels TRS See Condition 158.e tons

All fuels voe 0.038 lb/ ton Cao

Oil combustion voe 0.76 lb/Mgal oil

Natural Gas Combustion voe 5.5 lb/MM ft3 nat. gas

NCO Combustion H2SO4 91.8 lbs/ton SO,

Oil combustion H,SO4 0.021 lb/ton CaO

SDTEU Black liquor solids processed through RFEU NO, 0.033 lb/ton BLS

(461-132) Black liquor solids processed through RFEU PM 0.10 lb/tonBLS

Black liquor solids processed through RFEU PM10 0.095 lb/ton BLS

Black liquor solids processed through RFEU PM2.s 0.086 lb/ton BLS

Black liquor solids processed through RFEU so, 0.00023 lb/ton BLS

Black liquor solids processed through RFEU TRS 0.018 lb/ton BLS

Black liquor solids processed through RFEU voe 0.019 lb/ton BLS

Black liquor solids processed through RFEU co 0.008 lb/ton BLS

RECEU Dregs Mix Tank & Washer (471-101) voe 9.96E-02 lb/ton CaO processed by slaker

Lime Slaker (471-368) voe 5.70E-02 lb/ton CaO processed by slaker

TRS 4.38E-04 kg/ADMT unbleached pulp

PM/PM10/ 0.004 lb/ton CaO processed by slaker

PM2.s Green Liquor Clarifier (471-330) voe 6.20E-03 lb/ton Cao processed by slaker

Green Liquor Stabilization Tank (471-360) voe 1.40E-03 lb/ton CaO processed by slaker

Lime Mud Washer (471-193) voe 8.36E-02 lb/ton CaO processed by slaker

Spare Clarifier (471-260) voe 1.90E-02 lb/ton CaO processed by slaker

Lime Mud Storage (481-101) voe 8.36E-02 lb/ton CaO processed by slaker

Lime Mud Filter Separator ( 481-109) voe 8.36E-02 lb/ton CaO processed by slaker

EUID Process/Device

Filtrate Sump Tank (481-114)

Dust Sump Tank (481-121)

White Liquor Storage (471-180)

White Liquor Oxidation Tank 421-494

Weak Black Liquor Storage-North (451-108)

Weak Black Liquor Storage-South (451-101)

50% Black Liquor Storage Tank

BPEU 1st-5th Stage Bleach Washers, I &.5th Stage Bleach Towers, pt _5 th Stage Seal Tanks 431-120, 431-123, 431-128, 431-131, 431-134, 431-138, 431-141, 431-144, 431-151, 431-154, 431-157, 431-

515, 431-531, 431-536, 431-540, W Stage Washer 431-500, W. Stage Filtrate Tank 431-509

I st-5 th Stage Bleach Washers, 1 &-5 th Stage Bleach Towers

l''-S th Stage Seal Tanks 431-120, 431-123, 431-128, 431-131, 431-134, 431-138, 431-141, 431-144,431-151,431-154,431-157,431-515,431-531, 431-536, 431-540, W. Stage Washer431-

500, W. Stage Filtrate Tank 431-509 l't-s th Stage Bleach Washers, )&.5th Stage Bleach Towers, l't -5th Stage Seal Tanks 431-120, 431-123,431-128,431-131,43!-134,431-138,431-141, 431-144, 431-151, 431-154, 431-157, 431-

515, 431-531, 431-536, 431-540, W. Stage Washer 431-500, W. Stage Filtrate Tank 431-509

PMVEU Oxygen Reactor Blow Tank 421-43 5

Knots Drainer 421-107

Brown Stock Washer #1 421-112



Filtrate Tank# I 421-118

Filtrate Tank#2 421-129

Filtrate Tank #3 421-135


Decker 421-168

#1 Wash Press Level Tank 421-455

#1 Wash Press 421-460

#1 Wash Press Dilution conveyor421-470

#2 Wash Press Level Tank421-510

#2 Wash Press 421-515

#2 Wash Press Dilution Conveyor 421-525

Oxygen Delignification Reactor Blow Tank 421-435

# 1 Pressate Tank 4 21-480

Mix Tank 421-498

Knots Drainer 421-107

BrownStockWasher#l 421-112



Filtrate Tank# 1 421-118




Pollutant

voe

voe

voe

voe

voe

voe

TRS

co

voe

TRS

co

voe

voe

voe

voe

TRS


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Annual EF Units

8.36E-02 lb/ton CaO processed by slaker

8.36E-02 lb/ton Cao processed by slaker

l.90E-02 lb/ton CaO processed by slaker

l.75E-02 lb/ODT unbleached pulp into the Oxygen Delignification System

0.535 lb/hour

0.535 lb/hour

l.19E-03 kg/ADMT unbleached pulp

1.375 lb/ODT unbleached pulp

0.03 lb/ADMT unbleached pulp

5.!SE-03 kg/ADMT unbleached pulp

0.140 lb/ODT unbleached pulp

0.028 lb/ADMT unbleached pulp out of the digesters



0.014 lb/ADMT unbleached pulp into

0.014 the Oxygen Delignification

0.0036 System

0.0025

0.0025

0.0025

0.0329

0.006

0.0036

8.83E-03 kg/ADMT unbleached pulp out of the digesters

EUID Process/Device Pollutant

PDEU Flakt Dryer 843-200 PM PM10 PM2.5 voe

Repulpers 843-122, 843-195, 843-140 voe

PBIEU Oil Combustion co Oil Combustion NO, Oil Combustion PM Oil Combustion PM10 Oil Combustion PM2.5 Oil Combustion SO2 Oil Combustion voe Oil Combustion H2SO4

Natural Gas Combustion co Natural Gas Combustion NO, Natural Gas Combustion PM/PM10/

PM2_5 Natural Gas Combustion SO2 Natural Gas Combustion voe

NCO Combustion SO2 NCO Combustion voe

NCO Combustion PM

NCO Combustion PM10

NCO Combustion PM2,5

NCO Combustion co

NCO Combustion NO,

SO2 Emissions from NCO Combustion H2SO4

PB2EU Natural Gas Combustion co Natural Gas Combustion NO, Natural Gas Combustion PM/PM10/

PM2,5 Natural Gas Combustion SO2 Natural Gas Combustion voe

LSTEU Reburned Lime Conveyor (481-136) PM PM10 PM2,5

Rebumed Lime Crusher PM PM10 PM2.s

NCHEU Presteamer Surge Bins (411-101, PM 411-103, 411-201)

PM10/PM2,5 Shavings Shredder PM/PM10

(311-354) PM2.5

OCHEU West and East Chip Conveying Cyclones PM (311-168, 311-188)


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Annual EF Units

0.255 lb/ADT unbleached pulp 0.191 0.191 0.02 lb/ADMT bleached pulp 2.8E-03 lb/ADMT bleachedpulp

5 lb/M gallons oil 47 lb/M gallons oil 43.4 lb/M gallons oil 41.6 lb/M gallons oil 31.6 lb/M gallons oil See Condition 158.d tons 0.76 lb/M gallons oil 0.0122 lb/M gallons oil 84 lb/MM ft3 nat. gas 282 lb/MM ft3 nat. gas 2.5 lb/MM ft3 nat. gas

1.7 lb/MM ft3 nat. gas 5.5 lb/MM ft3 nat. gas 111 lbs/hour 0.012 lb/ADMT unbleached pulp for

NCO combustion 0.17 lb/ADMT unbleached pulp for





NCO combustion 91.8 lb/ton SO2

84 lb/MM ft3 nat. gas 286 lb/MM ft3 nat. gas 2,5 lb/MM ft3 nat. gas

1.7 lb/MM ft3 nat. gas 5,5 lb/MM ft3 nat. gas

0.11 lb/ton reburned CaO 0.055 lb/ton rebumed CaO 0,028 lb/ton rebumed CaO 0.017 lb/ton rebumed CaO 0,0085 lb/ton rebumed CaO 0.0043 lb/ton rebumed Cao

0,02 lb/BOU chips/sawdust

0,01 lb/BOU chips/sawdust 0,05 lb/BOU shredded

0.025 lb/BOU shredded

0.097 lb/BOU chips/sawdust


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EUID Process/Device Pollutant Annual EF Units

PM10 0,048 lb/BDU chips/sawdust

PM2.s 0.024 lb/BDU chips/sawdust

SPEU Storage Piles PM 0.012 lb/BDU chips/sawdust

PM10 0,006 lb/BDU chips/sawdust

PM2.s 0,0009 lb/BDU chips/sawdust voe 0.4 lb/BDT chips voe 0.55 lb/BDT sawdust

FREU Truck Unloading# I (311-105), Truck Unloading PM 0,036 lb/BDU chips/sawdust #2 (311-275), Rail Car/Truck Unloading #3 (311-

366)

PM10 0.018 lb/BDU chips/sawdust

PM2.s 0,009 lb/BDU chips/sawdust

PRFEU Paved Roads PM 0.553 lb/ADMT bleached pulp

PM10 0.1107 lb/ADMT bleached pulp

PM2.s 0.0277 lb/ADMT bleached pulp

UPRFEU Unpaved Roads PM 0.442 lb/ADMT bleached pulp PM10 0.126 lb/ADMT bleached pulp

PM2.s 0,013 lb/ADMT bleached pulp

WWTEU Waste Water Treatment (131-100) TRS 0,089 lb/ADT unbleached pulp voe 0.95 lb/ADT unbleached pulp

Total Emissions Calculations

158.c. The permittee must determine compliance with the annual PSELs by using the following formula to determine the total emissions discharged for each pollutant other than GHG. The calculations and comparisons to the PSELs must be performed by the end of the following month for each 12 consecutive calendar month period.

E = [I: (Peu X EFeu) / 2000] +AI+ ERF-S02 + ELK-TRS + ERF-TRS + ERF-CO + EFw-voc

where:

E = Emissions (tons/year) Peu = Process parameter for each emissions unit (units/year) as monitored per Condition 158.a .. EFeu = Emission factor for each emissions unit (pounds/units) as shown in Condition 158.b .. AI = 1.0 tons for aggregate insignificant activities, as applicable for PM, PM10, PM2.s, VOC, and TRS. ELK-TRS = Lime Kiln TRS emissions derived per Condition 158.e, as applicable ERF-so2 = Recovery Furnace SO2 emissions derived per Condition 158.f, as applicable. ERF-TRs = Recovery Furnace TRS emissions derived per Condition 158.g, as applicable. ERF-CO = Recovery Furnace CO emissions derived per Condition 158.h, as applicable. EFw-voc = Facility wide VOC emission derived per Condition 158.i, as applicable.

SO2 Emission Factors for Oil Combustion

158.d. To determine the emission factor for calculating SO2 emissions from the combustion of fuel oil, one of the following formulas must be used depending on the grade of the fuel oil used.

158.d.i. When distillate oil (Grades #1 or #2) is combusted use the following equation to determine the emission factor for calculating SO2 emissions:

EFD = 141 x S

158.d.ii.

Where,


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EF n = SO2 emission Factor (pounds SO2/l 000 gallons oil) S = Sulfur content of oil ( e.g., 0.5% sulfur content= 0.5)

When residual oil (Grades #3, #4, #5, or #6) is combusted use the following equation to determine the emission factor for calculating SO2 emissions:

EFR = 157 x S

Where, EFR = SO2 emission Factor (pounds SOz/1000 gallons oil) S = Sulfur content of oil (e.g., 1.75% sulfur content= 1.75)

Lime Kiln TRS Emissions

158.e. The amount ofTRS emissions from the emissions units LKEU must be determined by using the measured data from the Lime Kiln TRS Continuous Emission Monitoring System. The uncorrected hourly measured ppm concentration must be converted to a mass weight basis by using the average flow rate as determined from the last five particulate matter source test conducted for the Lime Kiln. The amount of TRS emitted for a given annual period is determined by summing the measured amounts ofTRS for each month in the 12-month period. The amount of TRS emitted each month is determined by summing the measured amounts of TRS emitted each day during the given month. The amount of TRS emitted each day is determined by summing the amounts ofTRS emitted for each hour during the given day.

158.e.i. Recordkeeping: Hourly, daily, monthly, and annual records of Lime Kiln TRS emissions must be maintained.

Recovery Furnace SO2 Emissions

15 8 .f. The amount of SO2 emissions from emissions unit RFEU must be determined by using the measured data from the Recove1y Furnace SO2 Continuous Emission Monitoring System. The uncorrected hourly measured ppm concentration must be converted to a mass weight basis by using the average flow rate as determined in accordance with Condition 27.a. The amount of SO2 emitted for a given annual period is determined by summing the measured amounts of SO2 for each month in the 12-month period. The amount of SO2 emitted each month is determined by summing the measured amounts of SO2 emitted each day during the given month. The amount of SO2 emitted each day is determined by summing the amounts of SO2 emitted for each hour during the given day.

158.f.i. Recordkeeping: Hourly, daily, monthly, and annual records of Recovery Furnace SO2

emissions must be maintained.

Recovery Furnace TRS Emissions

158.g. The annual TRS emissions from the emissions unit RFEU must be determined by using the measured data from the Recove1y Furnace TRS Continuous Emission Monitoring System. The uncorrected hourly measured ppm concentration must be converted to a mass weight basis by using the average flow rate as determined in accordance with Condition 27.a. The amount of TRS emitted for a given annual period is determined by summing the measured amounts of TRS for each month in the 12-month period. The amount ofTRS emitted each month is determined by summing the measured amounts ofTRS emitted each day during the given month. The amount of TRS emitted each day is determined by summing the amounts of TRS emitted for each hour during the given day.

158 .g.i. Recordkeeping: Hourly, daily, monthly, and annual records of Recovery Fmnace TRS

emissions must be maintained.


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Recovery Furnace CO Emissions

158.h. The annual CO emissions from the emissions unit RFEU must be determined by using the measured data from the Recovery Furnace CO Continuous Emission Monitoring System. The uncorrected hourly measured ppm concentration must be converted to a mass weight basis by using the average flow rate as determined in accordance with Condition 27 .a. The amount of CO emitted for a given annual period is determined by summing the measured amounts of CO for each month in the 12-month period. The amount of CO emitted each month is determined by summing the measured amounts of CO emitted each day during the given month. The amount of CO emitted each day is determined by summing the amounts of CO emitted for each hour during the given day.

158.h.i: Recordkeeping: Hourly, daily, monthly, and annual records of Recovery Furnace CO emissions must be maintained.

Facility wide voe emissions

158.i. The annual VOC emissions from emissions unit FWEU must be determined as follows:

158.i.i. The permittee must maintain records of the amount ofVOC emitting materials used in emissions unit FWEU for each month.

158.i.ii. The VOC content of the materials must be determined from material safety data sheets or equivalent documents. If a range of VOC content is given, the middle of the range must be used to calculate emissions.

158.i.iii. VOC emissions from emissions unit FWEU must be determined using the following equation:

V=%VuxMuxp where: V

p

volatile organic compounds emissions, lbs/month; weight fraction ofVOC in material used in the process, wt/wt; material used in the process, gallons/month; and density of material used in process, lb/ gallon.

159. The emissions factors listed in Condition 158.b are not enforceable limits unless otherwise specified in this permit. Compliance with the PSELs must only be determined by the calculations and procedures contained in Condition 15 8 of this permit.

160. Recordkeeping: The permittee must maintain records of all calculations and comparisons to the PSELs for each 12 consecutive calendar month period.

GENERAL TESTING REQUIREMENTS

General Title V Testing Requirements:

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

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


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approval in addition to approval by DEQ.

161.b. Only regular operating staff may adjust the processes or emission control device parameters during a compliance source test and within two (2) hours prior to the tests. Any operating adjustments made during a compliance source test, which are a result of consultation during the tests with source testing persom1el, equipment vendors, or consultants, may render the source test invalid.

161.c. Unless otherwise specified by permit condition or DEQ approved source test plan, all compliance source tests must be performed as follows:

161.c.i. 161.c.ii. 161.c.iii.

at least 90% of the design capacity for new or modified equipment; at least 90% of the maximum operating rate for existing equipment; or at 90 to 110% of the normal maximum operating rate for existing equipment. For purposes of this permit, the normal maximum operating rate is defined as the 90th percentile of the average hourly operating rates during a 12 month period immediately preceding the source test. Data suppmting the normal maximum operating rate must be included with the source test report.

161.d. Each source test must consist of at least three (3) test runs and the emissions results must be repmted 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.

161.e. Source test reports must be prepared in accordance with DEQ's Source Sampling Manual and must be submitted to DEQ within 60 days of completing any required source test unless specified otherwise in a relevant standard or as approved otherwise in writing by DEQ. A performance test is "completed" when field sample collection is terminated. The reports must contain the following: [OAR 340-218-0050(3)(c)(A), 40 CFR 63.7(g)(l), and 63.10(d)(2)]

161.e.i. Emissions unit and monitoring point identification; 161.e.ii. Emission results in units that are consistent with the emissions limits on the emissions

unit(s) being tested (e.g., gr/dscf, lb/hour, lb per unit throughput, etc.); 161.e.iii.Process parameters during the test (e.g., material throughput, types and amounts of

fuels used, heat input, etc.); 161.e.iv. The results of performance test including analysis of samples, determination of

emissions, and raw data; and 161.e.v. Control device operating parameters, if applicable.

162. For the purpose of establishing or revising operating parameter ranges, the following are allowed: [OAR 340-2 l 8-0050(3)(a)(C)]

162.a. The permittee may perform pretest runs at any time prior to the compliance source test or emission factor verification test, subject to the following conditions:

162.a.i. Pretest run results are intended only to help predetermine operating parameter values to be used during the actual compliance source testing or emission factor verification testing, but may not be used themselves to establish operating parameter ranges required elsewhere in this permit.

162 .a.ii. Pretest runs may be of any duration. 162.a.iii. Pretest run results may not be used as part of the compliance demonsh·ation or

emission factor verification.

162.b. Pretest runs must be completed prior to begim1ing the compliance source testing or emission


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factor verification testing, and no pretest runs may be conducted between individual compliance source tests or emission factor verification test runs.

162.c. The permittee may operate outside the applicable parameter range(s) during pretest runs and during the compliance source test or emission factor verification test for the purpose ofrevising or expanded the allowed operating parameter ranges.

162.d. This condition does not authorize non-compliance with any applicable standard or limitation. Noncompliance with an applicable standard or limitation that occurs as a result of operation outside established operating parameter range(s) must be rep01ied as an excess emission.

General NESHAP Testing Requirements

Performance Test Dates

163. Except as provided in Condition 159, if required to do performance testing by a relevant standard, the permittee of an affected source must perform such tests within 180 days of the compliance date for such source. DEQ may require the permittee to conduct performance tests at the affected source at any other time when the action is authorized by section 114 of the Clean Air Act. [40 CFR 63.7(a)(2) and (3)]

164. If a force majeure is about to occur, occurs, or has occurred for which the permittee intends to assert a claim of force majeure: [40 CFR 63.7(a)(4)]

164.a. The permittee must notify DEQ in writing as soon as practicable following the date the permittee first knew or through due diligence should have known that the event may cause or caused a delay in testing beyond the regulatory deadline specified in this condition, but the notification must occur before the performance test deadline unless the initial force majeure or a subsequent force majeure event delays the notice, and in such cases, the notification must occur as soon as practicable.

164.b. The pennittee must provide to DEQ a written description of the force majeure event and a rationale for attributing the delay in testing beyond the regulatory deadline to the force majeure; describe the measures taken or to be taken to minimize the delay; and identify a date by which the owner or operator proposes to conduct the performance test. The performance test must be conducted as soon as practicable after the force majeure occurs.

164.c. The decision as to whether or not to grant an extension to the performance test deadline is solely within the discretion ofDEQ. DEQ will notify the permittee in writing of approval or disapproval of the request for an extension as soon as practicable.

164.d. Until an extension of the perfonnance deadline has been approved by the Department, the pennittee remains strictly subject to the provisions of this permit.

Notifications

165. The permittee must notify DEQ in writing of his or her intention to conduct a performance test at least 60 calendar days before the performance test is initially scheduled to begin to allow DEQ, upon request, to review and approve the site-specific test plan and to have an observer present during the test. In the event the permittee is unable to conduct the performance test on the date specified above due to unforeseeable circumstances beyond his or her control, the permittee must notify DEQ as soon as practicable and without delay prior to the scheduled performance test date and specify when the performance test is rescheduled. This notification of delay in conducting the performance test does not relieve the permittee of legal responsibility for compliance with any other applicable provisions of 40 CFR Pati 63 or with any other applicable Federal, State, or local requirement, nor will it prevent DEQ from implementing or enforcing 40 CFR Part 63 or taking any other action under the Clean Air Act.

[40 CFR 63.7(b) and 63.9(e)]

Quality Assurance Program


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166. The results of the quality assurance program required in this condition will be considered by DEQ when determining the validity of a performance test. [ 40 CFR 63. 7 ( c )( 1)]

Submission of site-specific test plan

166.a. Before conducting a required performance test, the permittee must develop and submit a sitespecific test plan to DEQ for approval. The test plan must include a test program summary, the test schedule, data quality objectives, and both an internal and external quality assurance (QA) program. Data quality objectives are the pretest expectations of precision, accuracy, and completeness of data. [40 CFR 63.7(c)(2)(i) thru (v)]

Approval of site-specific test plan

166.b. DEQ will notify the permittee of approval or intentio1;1 to deny approval of the site-specific test plan (ifreview of the site-specific test plan is requested) within 30 calendar days after receipt of the original plan and within 30 calendar days after receipt of any supplementary information that is submitted under Condition 166.b.ii. Before disapproving any site-specific test plan, DEQ will notify the applicant ofDEQ's intention to disapprove the plan together with: [40 CFR 63.7(c)(3)(i)]

166.b.i. Notice of the information and findings on which the intended disapproval is based; and

166.b.ii. Notice of oppo1tunity for the permittee to present, within 30 calendar days after he/she is notified of the intended disapproval, additional information to DEQ before final action on the plan.

166.c. In the event that DEQ fails to approve or disapprove the site-specific test plan within the time period specified in Condition 166.b, the following conditions must apply: [40 CFR 63.7(c)(3)(ii)]

166.c.i. If intending to demonstrate compliance using the test method(s) specified in the relevant standard or with only minor changes to those tests methods (see 40 CFR 63.7(e)(2)(i)), the permittee must conduct the performance test within the time specified in this section using the specified method(s);

166.c.ii. If intending to demonstrate compliance by using an alternative to any test method specified in the relevant standard, the permittee is authorized to conduct the performance test using an alternative test method after DEQ approves the use of the alternative method when DEQ approves the site-specific test plan (if review of the site-specific test plan is requested) or after the alternative method is approved (see 40 CFR 63.7(f)). However, the pennittee is authorized to conduct the performance test using an alternative method in the absence of notification of approval 45 days after submission of the site-specific test plan or request to use an alternative method. The permittee is authorized to conduct the performance test within 60 .calendar days after he/she is authorized to demonstrate compliance using an alternative test method. Notwithstanding the requirements in the preceding tlu·ee sentences, the permittee may proceed to conduct the performance test as required in 40 CFR 63.7 (without DEQ's prior approval of the site-specific test plan) if he/she subsequently chooses to use the specified testing and monitoring methods instead of an alternative.

166.c.iii. Neither the submission ofa site-specific test plan for approval, nor DEQ's approval or disapproval of a plan, nor DEQ's failure to approve or disapprove a plan in a timely manner shall:


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166.c.iii.A. Relieve the permittee oflegal responsibility for compliance with any applicable provisions of 40 CFR Part 63 or with any other applicable Federal, State, or local requirement; or

Performance Testing Facilities

166.c.iii.B. Prevent DEQ from implementing or enforcing 40 CFR Pait 63 or taking any other action under the Act.

167. If required to do performance testing, the permittee must provide performance testing facilities as follows: [40 CFR 63.7(d)]

167.a. Sampling ports adequate for test methods applicable to such source. This includes:

167.a.i. Constructing the air pollution control system such that volumetric flow rates and pollutant emission rates can be accurately determined by applicable test methods and procedures; and

167 .a.ii. Providing a stack or duct free of cyclonic flow during performance tests, as demonstrated by applicable test methods and procedures;

167.b. Safe sampling platfonn(s);

167.c. Safe access to sampling platform(s);

167.d. Utilities for sampling and testing equipment; and

167 .e. Any other facilities that DEQ deems necessary for safe and adequate testing of a source.

Conduct of Perfonnance Tests

168. Performance tests must be conducted under such conditions as DEQ specifies to the pennittee based on representative performance (i.e., performance based on normal operating conditions) of the affected source for the period being tested. Representative conditions exclude periods of stmtup and shutdown. The permittee may not conduct performance tests during periods of malfunction. The pennittee must record the process information that is necessary to document operating conditions during the test and include in such record an explanation to support that such conditions represent normal operation. Upon request the permittee shall make available to DEQ such records as may be necessary to determine the conditions of performance tests. [40 CFR 63.457(0) and 63.865]

168.a. Performance tests must be conducted and data must be reduced in accordance with the test methods and procedures set forth in this permit, in each relevant standard, and, if required, in applicable appendices of parts 51, 60, 61, and 63 of 40 CFR unless DEQ or the EPA Administrator:

168.a.i. Specifies or approves, in specific cases, the use of a test method with minor changes in methodology (see definition in §63.90(a)). Such changes may be approved in conjunction with the site-specific test plan; or

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

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

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


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168.b. Unless otherwise specified in a relevant standard or test method, each performance test must consist of three separate runs using the applicable test method. Each run must be conducted for the time and under the conditions specified in the relevant standard. For the purpose of determining compliance with a relevant standard, the arithmetic mean of the result of the tlu·ee runs shall apply. Upon receiving approval from DEQ, results of a test run may be replaced with results of an additional test run in the event that --

168 .b.i. A sample is accidentally lost after the testing team leaves the site; or 168.b.ii. Conditions occur in which one of the three runs must be discontinued because of

forced shutdown; or 168.b.iii. Extreme meteorological conditions occur; or 168.b.iv. Other circumstances occur that are beyond the pennittee's control.

Use of an Alternative Test Method

169. Until authorized to use an intermediate or major change or alternative to a test method by the EPA Administrator, the permittee remains subject to the testing requirements specified in this permit and the relevant standard. The pennittee of an affected source required to do performance testing by a relevant standard may use an alternative test method from that specified in the standard provided that the permittee complies with requirements in 40 CFR 63.7(±)(2)-(6). [40 CFR 63.7(f)]

Performance Test Recordkeeping

170. Unless otherwise specified in a relevant standard or test method, or as otherwise approved by DEQ in writing, results of performance tests must include the analysis of samples, determination of emissions, and raw data. A performance test is "completed" when field sample collection is terminated. The pennittee must report the results of the performance test to DEQ before the close of business on the 60th

day following the completion of the performance test, unless specified otherwise in a relevant standard or as approved otherwise in writing by DEQ (see Condition 214). The results of the performance test must be submitted as part of the notification of compliance status required under Condition 213. For a minimum of 5 years after a performance test is conducted, the permittee must retain and make available, upon request, for inspection by DEQ the records or results of such performance test and other data needed to determine emissions from an affected source. [40 CFR 63.7(g)(l) and (3)]

Waiver of Performance Test

171. Until a waiver of performance testing requirement has been granted by DEQ pursuant to the provisions of 40 CFR 63.7(h), the permittee remains subject to the requirements of 40 CFR 63.7. [40 CFR 63.7(h)]

Subpart S Testing Requirements

Vent Sampling Port Locations and Gas Stream Properties

172. For purposes of selecting vent sampling port locations and determining vent gas stream properties; the permittee must comply with the following applicable procedures. [40 CFR 63.457(b)]

172.a. Method 1 or IA of part 60, appendix A-1, as appropriate, shall be used for selection of the sampling site as follows: [40 CFR 63.457(b)(l)]

172.a.i. To sample for vent gas concentrations and volumetric flow rates, the sampling site shall be located prior to dilution of the vent gas stream and prior to release to the atmosphere;

172.a.ii. For determining compliance with percent reduction requirements, sampling sites shall be located prior to the inlet of the control device and at the outlet of the control device; measurements shall be performed simultaneously at the two sampling sites; and

172.a.iii. For determining compliance with concentration limits or mass emission rate limits,


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the sampling site shall be located at the outlet of the control device.

172.b. No traverse site selection method is needed for vents smaller than 0.10 meter (4.0 inches) in diameter. [40 CFR 63.457(b)(2)]

172.c. The vent gas volumetric flow rate shall be determined using Method 2, 2A, 2C, or 2D of part 60, appendix A-1, as appropriate. [40 CFR 63.457(b)(3)]

172.d. The moisture content of the vent gas shall be measured using Method 4 of part 60, appendix A-3. [40 CFR 63.457(b)(4)]

172.e. To determine vent gas concentrations, the permittee shall conduct a minimum of three test runs that are representative of normal conditions and average the resulting pollutant concentrations using the procedures in 40 CFR 63.457(b)(5)(i)(A) and (B). [40 CFR 63.457(b)(5)]

172.e.i. Except for the modifications specified in Conditions 172.e.i.A through 172.e.i.K, Method 26A of 40 CFR part 60, appendix A-8 shall be used to determine chlorine concentration in the vent stream.

172.e.i.A. Probe/Sampling Line. A separate probe is not required. The sampling line shall be an appropriate length of0.64 cm (0.25 in) OD Teflon® tubing. The sample inlet end of the sampling line shall be inserted into the stack in such a way as to not entrain liquid condensation from the vent gases. The other end shall be connected to the impingers. The length of the tubing may vary from one sampling site to another, but shall be as shmt as possible in each situation. If sampling is conducted in sunlight, opaque tubing shall be used. Alternatively, if transparent tubing is used, it shall be covered with opaque tape.

172.e.i.B. Impinger Train. Three 30 milliliter (ml) capacity midget impingers shall be connected in series to the sampling line. The impingers shall have regular tapered stems. Silica gel shall be placed in the third impinger as a desiccant. All impinger train connectors shall be glass and/or Teflon®.

172.e.i.C. Critical orifice. The critical orifice shall have a flow rate of200 to 250 ml/min and shall be followed by a vacuum pump capable of providing a vacuum of 640 millimeters of mercury (1mn Hg). A 45 millimeter diameter in-line Teflon 0.8 micrometer filter shall follow the impingers to protect the critical orifice and vacuum pump.

172.e.i.D. The following are necessary for the analysis apparatus:

172.e.i.D. l Wash bottle filled with deionized water;

172.e.i.D.225 or 50 ml graduated burette and stand;

l 72.e.i.D.3Magnetic stirring apparatus and stir bar;

172.e.i.D.4Calibrated pH Meter;

l 72.e.i.D.5150-250 ml beaker or flask; and

171.e.i.D.6A 5 ml pipette.

172.e.i.E.


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The following procedures must be used to prepare the reagents.

172.e.i.E.1

172.e.i.E.2

172.e.i.E.3

172.e.i.E.4

172.e.i.E.5

To prepare the 1 molarity (M) potassium dihydrogen phosphate solution, dissolve 13 .61 grams (g) of potassium dihydrogen phosphate in water and dilute to 100 ml.

To prepare the 1 M sodium hydroxide solution (NaOH), . dissolve 4.0 g of sodium hydroxide in water and dilute to 100 ml.

To prepare the buffered 2 percent potassium iodide solution, dissolve 20 g of potassium iodide in 900 ml water. Add 50 ml of the 1 M potassium dihydrogen phosphate solution and 30 ml of the 1 M sodium hydroxide solution. While stirring solution, measure the pH of solution electrometrically and add the 1 M sodium hydroxide solution to bring pH to between 6.95 and 7.05.

To prepare the 0.1 normality (N) sodium thiosulfate solution, dissolve 25 g of sodium thiosulfate, pentahydrate, in 800 ml of freshly boiled and cooled distilled water in a 1-liter volumetric flask. Dilute to volume. To prepare the 0.01 N sodium thiosulfate solution, add 10.0 ml standardized 0.1 N sodium thiosulfate solution to a 100 ml volumetric flask, and dilute to volume with water.

To standardize the 0.1 N sodium thiosulfate solution, dissolve 3.249 g of anhydrous potassium bi-iodate, primary standard quality, or 3.567 g potassium iodate dried at 103 =/-2 degrees Centigrade for 1 hour, in distilled water and dilute to 1000 ml to yield a O .1000 N solution. Store in a glass-stoppered bottle. To 80 ml distilled water, add, with constant stirring, 1 ml concentrated sulfuric acid, 10.00 ml 0.1000 N anhydrous potassium bi-iodate, and 1 g potassium iodide. Titrate iimnediately with 0.1 n sodium thiosulfate titrant until the yellow color of the liberated iodine is almost discharged. Add 1 ml starch indicator solution and continue titrating until the blue color disappears. The normality of the sodium thiosulfate solution is inversely proportional to the ml of sodium thiosulfate solution consumed:

Normality of 1 =---------------

SodiumThiosuljate ml Sodium Thiosulfate Consumed

172.e.i.E.6 To prepare the starch indicator solution, add a small amount of cold water to 5 g starch and grind in a motiar to obtain a thin paste. Pour paste into 1 L of boiling

172.e.i.F.

172.e.i.E.7


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distilled water, stir, and let settle overnight. Use clear supernate for starch indicator solution.

To prepare the 10 percent sulfuric acid solution, add 10 ml of concentrated sulfuric acid to 80 ml water in a 100 ml volumetric flask. Dilute to volume.

The following procedures must be used to perform the sampling.

172.e.i.F .1

172.e.i.F.2

172.e.i.F.3

172.e.i.F.4

Preparation of Collection Train. Measure 20 ml buffered potassium iodide solution into each of the first two impingers and connect probe, impingers, filter, critical orifice, and pump. The sampling line and the impingers shall be shielded from sunlight.

Leak and Flow Check Procedure. Plug sampling line inlet tip and turn on pump. If a flow of bubbles is visible in either of the liquid impingers, tighten fittings and adjust connections and impingers. A leakage rate not in excess of2 percent of the sampling rate is acceptable. Carefully remove the plug from the end of the probe. Check the flow rate at the probe inlet with a bubble tube flow meter. The flow should be comparable or slightly less than the flow rate of the critical orifice with the impingers off-line. Record the flow and turn off the pump.

Sample Collection. Inse1t the sampling line into the stack and secure it with the tip slightly lower than the pmt height. Start the pump, recording the time. End the sampling after 60 minutes, or after yellow color is observed in the second in-line impinger. Record time and remove the tubing from the vent. Recheck flow rate at sampling line inlet and turn off pump. If the flow rate has changed significantly, redo sampling with fresh capture solution. A slight variation (less than 5 percent) in flow may be averaged. With the inlet end of the line elevated above the impingers, add about 5 ml water into the inlet tip to rinse the line into the first impinger.

Sample Analysis. Fill the burette with 0.01 N sodium thiosulfate solution to the zero mark. Combine the contents of the impingers in the beaker or flask. Stir the solution and titrate with thiosulfate until the solution is colorless. Record the volume of the first endpoint (TN, ml). Add 5 ml of the 10 percent sulfuric acid solution, and continue the titration until the contents of the flask are again colorless. Record the total volume oftitrant required to go through the first and to the second endpoint (TA, ml). If the volume of neutral titer is less than 0.5 ml, repeat the testing for a longer period of time. It is important that sufficient lighting be present to clearly see the endpoints, which are determined when

172.e.i.F.5


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the solution turns from pale yellow to colorless. A lighted stirring plate and a white background are useful for this purpose.

Inte1ferences. Known interfering agents of this method are sulfur dioxide and hydrogen peroxide. Sulfur dioxide, which is used to reduce oxidant residuals in some bleaching systems, reduces formed iodine to iodide in the capture solution. It is therefore a negative interference for chlorine, and in some cases could result in erroneous negative chlorine concentrations. Any agent capable of reducing iodine to iodide could interfere in this manner. A chromium trioxide impregnated filter will capture sulfur dioxide and pass chlorine and chlorine dioxide. Hydrogen peroxide, which is cmmnonly used as a bleaching agent in modern bleaching systems, reacts with iodide to form iodine and thus can cause a positive interference in the chlorine measmement. Due to the chemistry involved, the precision of the chlorine analysis will decrease as the ratio of chlorine dioxide to chlorine increases. Slightly negative calculated concentrations of chlorine may occur when sampling a vent gas with high concentrations of chlorine dioxide and very low concentrations of chlorine.

172.e.i.G. The following calculation must be performed to determine the corrected sampling flow rate:

(BP-PW]( 293 l Sa= Su 760 273 +t

Where:

Sc=Corrected (dry standard) sampling flow rate, liters per minute;

Su=Uncorrected sampling flow rate, L/min;

BP=Barometric pressure at time of sampling;

PW=Saturated partial pressure of water vapor, 111111 Hg at temperature; and

t=Ambient temperature, °C.

172.e.i.H. The following calculation must be performed to determine the moles of chlorine in the sample:

Where:

TN=Volume neutral titer, ml;

TA=Volume acid titer (total), ml; and

172.e.i.I.

172.e.i.J.


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NThio=Normality of sodium thiosulfate titrant.

The following calculation must be performed to determine the concentration of chlorine in the sample:

Where:

Sc=Corrected (dry standard) sampling flow rate, liters per minute;

ts=Time sampled, minutes;

TN=Volume neutral titer, ml;

TA=Volume acid titer (total), ml; and

NThio=Nonnality of sodium thiosulfate titrant.

The following calculation must be performed to determine the moles of chlorine dioxide in the sample:

Where:

TA=Volume acid titer (total), ml;

TN=Volume neutral titer, ml; and

NThio=Normality of sodium thiosulfate titrant.

172.e.i.K. The following calculation shall be performed to determine the concentration of chlorine dioxide in the sample:

Where:

Sc=Corrected ( dry standard) sampling flow rate, liters per minute;

ts=Time sampled, minutes;

TA=Volume acid titer (total), ml;

TN=Volume neutral titer, ml; and

NThio=Nonnality of sodimn thiosulfate titrant.

172.e.ii. Any other method that measures the total HAP or methanol concentration that has been demonstrated to the Administrator's satisfaction.

172.f. The minimum sampling time for each of the three test runs must be 1 hour in which either an


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integrated sample or four grab samples shall be taken. If grab sampling is used, then the samples must be taken at approximately equal intervals in time, such as 15 minute intervals during the test run. [40 CFR63.457(b)(6)]

Liquid Sampling Locations and Properties

173. For purposes of selecting liquid sampling locations and for detennining properties of liquid streams such as wastewaters, process waters, and condensates, the permittee must comply with the following procedures: [40 CFR 63.457(c)]

173.a. Samples must be collected using the sampling procedures of the test method listed in Condition 173.c selected to determine liquid stream HAP concentrations; [ 40 CFR 63 .457( c )(1 )]

173.b.

173.c.

173 .a.i. Where feasible, samples shall be taken from an enclosed pipe prior to the liquid stream being exposed to the atmosphere; and

173 .a.ii. When sampling from an enclosed pipe is not feasible, samples must be collected in a manner to minimize exposure of the sample to the atmosphere and loss of HAP compounds prior to sampling.

The volumetric flow rate of the entering and exiting liquid streams must be determined using the inlet and outlet flow meters or other methods demonstrated to DEQ's satisfaction. The volumetric flow rate measurements to determine actual mass removal must be taken at the same time as the concentration measurements. [40 CFR 63.457(c)(2)]

The permittee shall conduct a minimum of three test runs that are representative of normal conditions and average the resulting pollutant concentrations. The minimum sampling time for each test run shall be 1 hour and the grab or composite samples shall be taken at approximately equally spaced intervals over the I-hour test run period. The permittee shall use one of the following procedures to determine total HAP or methanol concentration: [40 CFR 63.457(c)(3)]

173.c.i. Method 305 in Appendix A of 40 CFR Part 63, adjusted using the following equation:

11.

c = 2.Pd ffflj i-1

Where:

C =Pollutant concentration for the liquid stream, parts per million by weight.

Ci=Measured concentration of pollutant i in the liquid stream sample determined using Method 305, parts per million by weight.

fin;=Pollutant-specific constant that adjusts concentration measured by Method 305 to actual liquid concentration; the fin for methanol is 0.85. Additional pollutant fin values can be found in table 34, subpart G of 40 CFR Pait 63.

n=Number of individual pollutants, i, summed to calculate total HAP.

173.c.ii. For determining methanol concentrations, NCASI Method DI/MEOH-94.03. This test method is incorporated by reference in §63.14(f)(l) ofsubpmt A of 40 CFR Part 63.

173 .c.iii. Any other method that measures total HAP concentration that has been demonstrated to the Administrator's satisfaction.

173 .d. To determine soluble BODs in the effluent stream from an open biological treatment unit used


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to comply with Conditions 139.b and 147, the permittee must use EPA Method 405.1 of 40 CFR Pait 136 with the following modifications: [40 CFR 63.457(c)(4)]

173 .d.i. Filter the sample through the filter paper, into an Erlenmeyer flask by applying a vacuum to the flask sidearm. Minimize the time for which vacuum is applied to prevent stripping of volatile organics from the sample. Replace filter paper as often as needed in order to maintain filter times ofless than approximately 30 seconds per filter paper. No rinsing of sample container or filter bowl into the Erlenmeyer flask is allowed.

173 .d.ii. Perform Method 405.1 on the filtrate obtained in Condition 173 .d.i .. Dilution water shall be seeded with 1 milliliter of final effluent per liter of dilution water. Dilution ratios may require adjustment to reflect the lower oxygen demand of the filtered sample in comparison to the total BODs. Three BOD bottles and different dilutions must be used for each sample.

173.e. If the test method used to determine HAP concentration indicates that a specific HAP is not detectable, the value determined as the minimum measurement level (MML) of the selected test method for the specific HAP must be used in the compliance demonstration calculations. To determine the MML for a specific HAP using one of the test methods specified in Condition 173.c, one of the procedures specified below must be performed. The MML for a particular HAP must be determined only if the HAP is not detected in the normal working range of the method. [40 CFR 63.457(c)(5)]

173 .e.i. To determine the MML for a specific HAP, the following procedures shall be performed each time the method is set up. Set up is defined as the first time the analytical apparatus is placed in operation, after any shut down of 6 months or more, or any time a major component of the analytical apparatus is replaced.

173 .e.i.A. Select a concentration value for the specific HAP in question to represent the MML. The value of the MML selected shall not be below the calibration standard of the selected test method.

173.e.i.B. Measure the concentration of the specific HAP in a minimum of three replicate samples using the selected test method. All replicate samples shall be run through the entire analytical procedure. The samples must contain the specific HAP at the selected MML concentration and should be representative of the liquid streams to be analyzed in the compliance demonstration. Spildng of the liquid samples with a known concentration of the target HAP may be necessary to ensure that the HAP concentration in the three replicate samples is at the selected MML. The concentration of the HAP in the spilced sample must be within 50 percent of the proposed MML for the demonstration to be valid. As an alternative to spiking, a field sample above the MML may be diluted to produce a HAP concentration at the MML. To be a valid demonstration, the diluted sample must have a HAP concentration within 20 percent of the proposed MML, and the field sample must not be diluted by more than a factor of five.

173.e.i.C. Calculate the relative standard deviation (RSD) and the upper confidence limit at the 95 percent confidence level using the measured HAP concentrations determined in Condition 173 .e.i.B. If the upper confidence limit of the RSD is less than 30 percent, then the selected MML is acceptable. If the upper confidence limit of the RSD is greater than or equal to 30 percent, then the selected MML is too low, and the procedures specified in Conditions 173 .e.i.A through C must be repeated.


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173.e.ii. Provide for DEQ's approval the selected value of the MML for a specific HAP and the rationale for selecting the MML including all data and calculations used to determine the MML. The approved MML must be used in all applicable compliance demonstration calculations.

173 .f. When using the MML determined using the procedures in Condition 173 .e.i or when using the MML determined using the procedures in Condition 173 .e.ii, except during set up, the analytical laboratory conducting the analysis must perform and meet the following quality assurance procedures each time a set of samples is analyzed to determine compliance. [40 CFR 63.457(c)(6)]

173.f.i. Using the selected test method, analyze in triplicate the concentration of the specific HAP in a representative sample. The sample must contain the specific HAP at a concentration that is within a factor of two of the MML. If there are no samples in the set being analyzed that contain the specific HAP at an appropriate concentration, then a sample below the MML may be spiked to produce the appropriate concentration, or a sample at a higher level may be diluted. After spiking, the sample must contain the specific HAP within 50 percent of the MML. If dilution is used instead, the diluted sample must contain the specific HAP within 20 percent of the MML and must not be diluted by more than a factor of five.

173 .f.ii. Calculate the RSD using the measured HAP concentrations determined in Condition 173.f.i. If the RSD is less than 20 percent, then the laboratory is performing acceptably.

Detectable Leak Procedures

174. To measure detectable leaks for closed-vent systems as specified in Condition 127 or for pulping process wastewater collection systems as specified in Condition 138.d.i, the permittee must comply with the following: [40 CFR 63.457(d)]

174.a. Method 21, ofpart60, appendixA-7; and

174.b. The instrument specified in Method 21 must be calibrated before use according to the procedures specified in Method 21 on each day that leak checks are performed. The following calibration gases must be used:

174.b.i. Zero air (less than 10 parts per million by volume of hydrocarbon in air); and 174.b.ii. A mixture of methane or n-hexane and air at a concentration of approximately, but

less than, 10,000 parts per million by volume methane or n-hexane.

Negative Pressure Procedures

175. To demonstrate negative pressure at process equipment enclosure openings as specified in Condition 127.a,, the permittee must use one of the following procedures: [40 CFR 63.457(e)]

175.a. An anemometer to demonstrate flow into the enclosure opening;

175.b. Measure the static pressure across the opening;

175.c. Smoke tubes to demonstrate flow into the enclosure opening; or

175.d. Any other industrial ventilation test method demonstrated to the Administrator's satisfaction.

HAP Concentration Measurements


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176. The permittee must measure the total HAP concentration as one of the following: [40 CFR 63.457(±)]

176.a. As the sum of all individual HAPs; or

176.b. As methanol.

Condensate HAP Concentration Measurement

177. For purposes of complying with the kraft pulping condensate requirements, the permittee must measure the total HAP concentration as methanol. For biological treatment systems complying with Condition 139.b, the permittee must measure total HAP as acetaldehyde, methanol, methyl ethyl ketone, and propionaldehyde and follow the procedures in Conditions 182.a or 182.b. [40 CFR 63.457(g)]

Bleaching HAP Concentration Measurement

178. For purposes of complying with the bleaching system requirements, the permittee must measure the total HAP concentration as the sum of all individual chlorinated HAPs or as chlorine. [40 CFR 63.457(h)]

Vent Gas Stream Calculations

179. To demonstrate compliance with the mass emission rate, mass emission rate per megagram of oven dried pulp, and percent reduction requirements for vent gas streams the permittee must use the following: [40 CFR 63.457(i)]

179.a. The total HAP mass emission rate must be calculated using the following equation: [40 CFR 63.457(i)(l)]

Where:

E=Mass emission rate of total HAP from the sampled vent, kilograms per hour.

K2=Constant, 2.494x10-6 (parts per million by volumef1 (gram-mole per standard cubic meter) (kilogram/gram) (minutes/hour), where standard temperature for (gram-mole per standard cubic meter) is 20 °C.

CrConcentration on a dry basis ofpollutantj in parts per million by volume as measured by the test methods specified in Condition 172.

MrMolecular weight ofpollutantj, gram/gram-mole.

Qs=Vent gas stream flow rate (dry standard cubic meter per minute) at a temperature of20 °C as indicated in Condition 172.

n=Number of individual pollutants, i, summed to calculate total HAP.

179 .b. The total HAP mass emission rate per megagram of ODP shall be calculated using the following equation: [ 40 CFR 63 .457(i)(2)]

E F=-p

Where:


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F=Mass emission rate of total HAP from the sampled vent, in kilograms per megagram of ODP.

E=Mass emission rate of total HAP from the sampled vent, in kilograms per hour determined as specified in Condition 180.a.

P=The production rate of pulp during the sampling period, in megagrams of ODP per hour.

179.c. The total HAP percent reduction shall be calculated using the following equation: [ 40 CFR 63 .457(i)(3)]

Where:

R =Efficiency of control device, percent.

Ei=Inlet mass emission rate of total HAP from the sampled vent, in kilograms of pollutant per hour, determined as specified in Condition 180.a.

E0=Outlet mass emission rate of total HAP from the sampled vent, in kilograms of pollutant per hour, determined as specified in Condition 180.a.

Liquid Stream Calculations

180. To demonstrate compliance with the mass flow rate, mass per mega gram of ODP, and percent reduction requirements for liquid streams, the pennittee must use the following: [40 CFR 63.457(i)]

180.a. The mass flow rates of total HAP or methanol entering and exiting the treatment process must be calculated using the following equations: [40 CFR 63.457(i)(l)]

Where:

Eb=Mass flow rate of total HAP or methanol in the liquid stream entering the treatment process, kilograms per hour.

Ea=Mass flow rate of total HAP or methanol in the liquid exiting the treatment process, kilograms per hour.

K=Density of the liquid stream, kilograms per cubic meter.

V bi=Volumetric flow rate of liquid stream entering the treatment process during each run i, cubic meters per hour, determined as specified in Condition 173.

Vai=Volumetric flow rate of liquid stream exiting the treatment process during each run i, cubic meters per hour, determined as specified in Condition 173.


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Cb1=Concentration of total HAP or methanol in the stream entering the treatment process during each run i, parts per million by weight, determined as specified in Condition 173.

c.1=Concentration of total HAP or methanol in the stream exiting the treatment process during each run i, parts per million by weight, determined as specified in Condition 173.

n=Number of runs.

180.b. The mass of total HAP or methanol per megagram ODP must be calculated using the following equation: [40 CFR 63.457(j)(2)]

F = Ea. p

Where:

F=Mass loading of total HAP or methanol in the sample, in kilograms per mega gram of ODP.

E.=Mass flow rate of total HAP or methanol in the wastewater stream in kilograms per hour as determined using the procedures in Condition 185 .b.

P=The production rate of pulp during the sampling period in megagrams ofODP per hour.

180.c. The percent reduction of total HAP across the applicable treatment process must be calculated using the following equation: [40 CFR 63.457(j)(3)]

Where:

R=Control efficiency of the treatment process, percent.

Eb=Mass flow rate of total HAP in the stream entering the treatment process, kilograms per hour, as determined in Condition 182.a.

E.=Mass flow rate of total HAP in the stream exiting the treatment process, kilograms per hour, as determined in Condition 182.a.

180.d. Compounds that meet the following requirements are not required to be included in the mass flow rate, mass per megagram ofODP, or the mass percent reduction determinations. [40 CFR 63.457(j)(4)]

180.d.i. Compounds with concentrations at the point of determination that are below 1 part per million by weight; or

180.d.ii. Compounds with concentrations at the point of determination that are below the lower detection limit where the lower detection limit is greater than 1 part per million by weight.

Oxygen Concentration Correction Procedures

181. To demonstrate compliance with the total HAP concentration limit of20 ppmv in Condition 133.b, the concentration measured using the methods specified in Condition 172.e shall be corrected to 10 percent oxygen using the following procedures: [40 CFR 63.457(k)]


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181.a. The emission rate correction factor and excess air integrated sampling and analysis procedures of Methods 3A or 3B of part 60, appendix A-2 shall be used to determine the oxygen concentration. The samples shall be taken at the same time that the HAP samples are taken. As an alternative to Method 3B, ASME PTC 19.10-1981 [Part 10] may be used. [40 CFR 63.457(k)(l)]

181.b. The concentration corrected to IO percent oxygen shall be computed using the following equation: [40 CFR 63.457(k)(2)]

C = C [ 10.9 l c m 20.9-¾Ou

Where:

Cc=Concentration of total HAP corrected to 10 percent oxygen, dry basis, parts per million by volume.

Cm=Concentration of total HAP d1y basis, parts per million by volume, as specified in Condition 172.

%02ct=Concentration of oxygen, d1y basis, percent by volume.

Biological Treatment System Percent Reduction and Mass Removal Calculations

182. To demonstrate compliance with the condensate treatment standards specified in Condition 139.b and the monitoring requirements specified in Condition 148 using a biological treatment system, the permittee must use one of the following procedures. A permittee using a nonthoroughly mixed open biological treatment system must also comply with Condition 182.c. [40 CFR 63.457(1)]

Percent reduction methanol procedure

182.a. For the purposes of complying with the condensatetreatment requirements specified in 40 CFR 63.446(e)(2) and (3), the methanol percent reduction must be calculated using the following equations: [40 CFR 63.457(1)(1)]

R = fob (MeOH) * 100 ( 1 + 1. 0 87 (r))

F'c.w11.111£1.h{l}l,of.) r=-----

F'c,11/£1.h/1}/.of.)

Where:

R = Percent destruction.

fbio(MeOH) = The fraction of methanol removed in the biological treatment system. The sitespecific biorate constants shall be determined using the appropriate procedures specified in appendix C of 40 CFR Part 63.

r = Ratio of the sum of acetaldehyde, methyl ethyl ketone, and propionaldehyde mass to methanol mass.

F(nonmethanol) = The sum of acetaldehyde and propionaldehyde mass flow rates (kg/Mg ODP) entering the biological treatment system determined using the procedures in Condition 180.b.


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F(methanol) = The mass flow rate (kg/Mg ODP) of methanol entering the system determined using the procedures in Condition 180.b.

Mass removal methanol procedure

182.b. For the purposes of complying with the condensate treatment requirements specified in Conditions 139.b and 139.d, the methanol mass removal must be calculated using the following equation: [ 40 CFR 63 .457(1)(2)]

Where:

F = Methanol mass removal (kg/Mg ODP).

Fb = Inlet mass flow rate of methanol (kg/Mg ODP) determined using the procedures in Condition 180.b.

fbio(MeOH) = The fraction of methanol removed in the biological treatment system. The sitespecific biorate constants shall be determined using the appropriate procedures specified in Appendix C of 40 CFR Part 63.

r = Ratio of the sum of acetaldehyde, methyl ethyl ketone, and propionaldehyde mass to methanol mass determined using the procedures in Condition 182.a.

182.c. A pennittee of a nonthoroughly mixed open biological treatment system using the monitoring requirements specified in Condition 153.c must follow the procedures specified in section III.B.1 of Appendix E of 40 CFR Part 63 to determine the borate constant, Ks, and characterize the open biological treatment system during the initial and any subsequent performance tests. [40 CFR 63.457(1)(3)]

Condensate Segregation Procedures

183. The following procedures must be used to demonstrate compliance with the condensate segregation requirements specified in Condition 137. [40 CFR 63.457(111)]

183.a. To demonstrate compliance with the percent mass requirements specified in Condition 137.b, the following procedures must be performed. [40 CFR 63.457(111)(1)]

183 .a.i. Determine the total HAP mass of all condensates from each equipment system listed in Conditions 136.a, 136.b, and 136.c using the procedures specified in Conditions 173 and 180.

183.a.ii. Multiply the total HAP mass determined in Condition 183.a.i by 0.65 to determine the target HAP mass for the high-HAP fraction condensate stream or streams.

183.a.iii. Compliance with the segregation requirements specified in Condition 137.b is demonstrated if the condensate stream or streams from each equipment system listed in Conditions 136.a, 136.b, and 136.c being treated as specified in Condition 139 contain at least as much total HAP mass as the target total HAP mass determined in Condition 183 .a.ii.

183.b. To demonstrate compliance with the percent mass requirements specified in Condition 137.c, the following procedures must be performed. [40 CFR 63.457(111)(2)]

183.b.i. Determine the total HAP mass contained in the high-HAP fraction condensates from each equipment system listed in Conditions 136.a, 136.b, and 136.cand the total


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condensates streams from the equipment systems listed in Conditions 136.d and 136.e, using the procedures specified in Conditions 173 and 180.

183 .b.ii. Compliance with the segregation requirements specified in Condition 13 7 .c is demonstrated if the total HAP mass determined in Condition 183.b.i is equal to or greater than the appropriate mass requirements specified Condition 13 7 .c ..

Open Biological Treatment System Monitoring Sampling Storage

184. The inlet and outlet grab samples required to be collected in Condition 14 7 .a shall be stored at 4 °C ( 40 °F) to minimize the biodegradation of the organic compounds in the samples. [40 CFR 63.457(n)]

Subpart MM Testing Requirements

185. The permittee must use the following procedures for determining compliance with Conditions 28, 44, and 62: [40 CFR 63.865(b)]

185 .a. Method 5 in appendix A-3 of 40 CFR Part 60 or Method 29 in appendix A-8 of 40 CFR Part 60 must be used, except that Method 17 in appendix A-6 of 40 CFR Part 60 may be used in lieu of Method 5 or Method 29 if a constant value of 0.009 g/dscm (0.004 gr/dscf) is added to the results of Method 17, and the stack temperature is no greater than 205 degrees C (400 degrrs F). For Methods 5, 29, and 17, the sampling time and sample volume for each run must be at least 60 minutes and 0.90 dscm (31.8 dscf), and water must be used as the cleanup solvent instead of acetone in the sample recovery procedure.

185.b. The PM concentration must be corrected to the appropriate oxygen concentration using the following equation: [40 CFR 63.865(b)(2)]

Ccorr = Cmeas X [(20.9 - X) / (20.9-Y)]

Where: Ccorr = the measured concentration corrected for oxygen, g/dscm (gr/dscf).

Cineas = the measured concentration uncorrected for oxygen, g/dscm (gr/dscf).

X = the corrected volumetric oxygen concentration (8 % for recovery furnaces and 10% for lime kilns.

Y = the measured average volumetric oxygen concentration.

185 .c. Methods 3A or 3B in appendix A-2 of 40 CFR part 60 must be used to determine the oxygen concentration. The voluntary consensus standard ANSI/ ASME PTC 1910 -- 1981 - Part 10 (incorporate by reference - see 40 CFR 63 .14) may be used as an alternative to using Method 3B. The gas sample must be taken at the same time and the same traverse points as the particulate sample. [40 CFR 63.865(b)(3)]

185.d. For purposes of selecting sampling port location and number of traverse points, Method 1 or IA in appendix A-lof 40 CFR part 60 must be used. For purposes of determining stack gas velocity and volumetric flow rate, Method 2, 2A, 2C, 2D, or 2F in appendix A-1 or Method 2G in appendix A-2 of 40 CFR part 60 must be used. For purposes of conducting gas analysis, and determining moisture content of stack gas, Method 3, 3A, or 3B in appendix A-2 of 40 CFR part 60 must be used. The voluntary consensus standard ANSI/ASME PTC 19.10 - 1981-Part 10 (incorporate by reference - see 40 CFR 63 .14) may be used as an alternative to using Method 3B. For purposes of determining moisture content of stack gas, Method 4 in appendix A-3 of 40 CFR part 60 must be used. [40 CFR 63.865(b)(5)]


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185.e. Process data measured during the performance test must be used to determine the black liquor solids firing rate on a dry basis and the CaO production rate. [40 CFR 63.865(b)(6)]

GENERAL MONITORING REQUIREMENTS

General Title V Monitoring Requirements

186. The permittee must not knowingly render inaccurate any required monitoring device or method. [OAR 340-2 l 8-0050(3)(a)(E)]

187. The permittee must use the same methods to determine compliance as those used to determine actual emissions for fee purposes and can be no less rigorous than the requirements of OAR 340-218-0080. [OAR 340-2 l 8-0050(3)(a)(F)]

188. The permittee must comply with the monitoring requirements on the date ofpennit issuance unless otherwise specified in the permit or an applicable requirement. [OAR 340-2 l 8-0050(3)(a)(G)]

General NESHAP Monitoring Requirements

Applicability

189. For the purposes of 40 CFR Part 63, all continuous monitoring systems (CMS) required under relevant standards shall be subject to the provisions 40 CFR 63.8 upon promulgation ofperfonnance specifications for CMS as specified in the relevant standard or otherwise by the EPA Administrator. [40 CFR 63.8(a)(2)]

Conduct of Monitoring

190. Monitoring must be conducted as set forth in this condition and the relevant standards(s) unless DEQ specifies or approves the use of minor changes in methodology for the specified monitoring requirements and procedures; or the EPA Administrator approves the use of an intermediate or major change or alternative to any monitoring requirements or procedures. [40 CFR 63.8(b)]

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

190.b. If the relevant standard is a mass emission standard and the emissions from one affected source are released to the atmosphere through more than one point, the permittee must install an applicable CMS at each emission point unless the installation of fewer systems is--

190.b.i. 190.b.ii.

Approved by DEQ; or Provided for in a relevant standard (e.g., instead ofrequiring that a CMS installed at each emission point before the effluents from those points are channeled to a co1mnon control device, the standard specifies that only one CMS is required to be installed at the vent of the control device).

190.c. When more than one CMS is used to measure the emissions from one affected source (e.g.,


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multiple breechings, multiple outlets), the permittee must report the results as required for each CMS. However, when one CMS is used as a backup to another CMS, the permittee must report the results from the CMS used to meet the monitoring requirements. If both CMS are used during a particular reporting period to meet the monitoring requirements, then the permittee must report the results from each CMS for the relevant compliance period.

Operation and Maintenance of Continuous Monitoring Systems

191. The permittee must maintain and operate each CMS as specified in this condition, or in the relevant standard, and in a manner consistent with good air pollution control practices. [40 CFR 63.S(c)]

191.a. The permittee must maintain and operate each CMS as specified in Condition 15 and must keep the necessaty patts for routine repairs of the affected CMS equipment readily available. [40 CFR 63.S(c)(l)]

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

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

191.d. Except for system breakdowns, out-of-control periods, repairs, maintenance periods, calibration checks, and zero (low-level) and high-level calibration drift adjustments, all CMS, including COMS and CEMS, must be in continuous operation and must meet minimum frequency of operation requirements as follows: [40 CFR 63.8(c)(4]

191.d.i. All COMS must complete a minimum ofone cycle of sampling and analyzing for each successive 10-second period and one cycle of data recording for each successive 6-minute period.

191.d.ii. All CEMS for measuring emissions other than opacity must complete a minimum of one cycle of operation (sampling, analyzing, and data recording) for each successive 15-minute period.

191.e. Unless otherwise approved by DEQ, minimum procedures for COMS must include a method for producing a simulated zero opacity and an upscale (high level) opacity condition using a certified neutral density filter or other related technique to produce a lmown obscuration of the light beam. Such procedures must provide a system check of all the analyzer's internal optical surfaces and all electronic circuitry, including the lamp and photodetector assembly normally used in the measurement of opacity. [40 CFR 63.8(c)(5)]

191.f. The permittee must comply with the following CMS requirements: [40 CFR 63.8(c)(6)]

191.f.i. For a continuous monitoring system (CMS) that is not a continuous parameter monitoring system (CPMS), the zero (low-level) and high level calibration drifts


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must be checked at least once daily in accordance with the written procedure specified in the performance evaluation plan developed in accordance with Conditions 193 .b and 193 .b.i. The zero (low-level) and high-level calibrations drifts must be adjusted, at a minimum, whenever the 24-hour zero (low-level) drift exceeds two times the limits of the applicable performance specification(s). The system must allow the amount of excess zero (low-level) and high-level drift measured at the 24-hour interval checks to be recorded and quantified whenever specified.

191.f.ii. For COMS, all optical and instrumental surfaces exposed to the effluent gases must be cleaned prior to performing the zero (low-level) and high-level drift adjustments. The optical surfaces and instrumental surfaces must be cleaned when the cumulative automatic zero compensation, if applicable, exceeds 4 percent opacity.

191.f.iii. The CPMS must be calibrated prior to use for the purposes of complying with 40 CFR 63. 8 and the CPMS must be checked daily for indication that the system is responding. If the CPMS system includes an internal system check, results must be recorded and checked daily for proper operation.

191.g. A CMS is out of control if: [ 40 CFR 63 .8(c)(7)(i)]

191.g.i. The zero (low-level), mid-level (if applicable), or high level calibration drift exceeds two times the applicable calibration drift specification in the applicable performance standard or relevant standard; or

191.g.ii. The CMS fails a performance test audit ( e.g., cylinder gas audit), relative accuracy audit, relative accuracy test audit, or linearity test audit; or

191.g.iii. The COMS calibration drift exceeds two times the limit in the applicable performance specification in the relevant standard.

191.h. When a CMS is out of control, the permittee must take the necessary corrective action and must repeat all necessary tests which indicate that the system is out of control. In addition --[ 40 CFR 63.8(c)(7)(ii)]

191.h.i. The permittee must take corrective action and conduct retesting until the performance requirements are below the applicable limits.

191.h.ii. The beginning of the out-of-control period is the hour the pennittee conducts a performance check (e.g., calibration drift) that indicates an exceedance of the performance requirements.

191.h.iii. The end of the out-of-control period is the hour following completion of corrective action and successful demonstration that the system is within the allowable limits.

191.h.iv. During the period the CMS is out of control, recorded data shall not be used in data averages and calculations, or to meet any data availability requirement.

191.i. The pennittee of a CMS that is out of control as defmed in Condition 191.g must submit all information concerning out-of-control periods, including start and end dates and hours and descriptions of c01Tective actions taken, in the excess emissions and continuous monitoring system performance report required in Condition 225. [40 CFR 63.8(c)(8)]

CMS Quality Control Program

192. The results of the quality control program required in this condition will be considered by DEQ when it determines the validity of monitoring data. [40 CFR 63.8(d)(l)]

192.a. The permittee of an affected source that is required to use a CMS must develop and implement a CMS quality control program. As part of the quality control program, the permittee must develop and submit to DEQ for approval upon request a site-specific performance evaluation test plan for the CMS performance evaluation required in Condition 193, according to the procedures specified in Condition 193. In addition, each quality control program must include,


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at a minimum, a written protocol that describes procedures for each of the following operations: [40 CFR 63.8(d)(2)]

192.a.i. Initial and any subsequent calibration of the CMS; 192.a.ii. Determination and adjustment of the calibration drift of the CMS; 192.a.iii. Preventive maintenance of the CMS, including spare paits inventory; 192.a.iv. Data recording, calculations, and repmting; 192.a.v. Accuracy audit procedures, including sampling and ·analysis methods; and 192.a.vi. A program of corrective action for a malfunctioning CMS.

192.b. The permittee must keep these written procedures on record for the life of the affected source or until the affected source is no longer subject to the provisions of 40 CFR Part 63, to be made available for inspection, upon request, by DEQ. If the performance evaluation plan is revised, the permittee must keep previous (i.e., superseded) versions of the performance evaluation plan on record to be made available for inspection, upon request by DEQ, for a period of 5 years after each revision to the plan. [40 CFR 63.8(d)(3)]

CMS Performance Evaluation

193. When required by a relevant standard, and at any other time DEQ may require under section 114 of the Clean Air Act, the permittee of an affected source being monitored must conduct a performance evaluation of the CMS according to the applicc:1ble specifications and procedures described in this condition or in the relevant standard. [40 CFR 63.8(e)(l)]

Notification of performance evaluation

193.a. The permittee must notify DEQ in writing of the date of the performance evaluation simultaneously with the notification of the performance test date required by Condition 165 or at least 60 days prior to the date the perfonnance evaluation is scheduled to begin if no performance test is required. [40 CFR 63.8(e)(2)]

Submission of site-specific performance evaluation test plan

193.b. Before conducting a required CMS performance evaluation, the permittee must develop and submit a site-specific pe1formance evaluation test plan to DEQ for approval upon request. The performance evaluation test plan must include the evaluation program objectives, an evaluation program summary, the performance evaluation schedule, data quality objectives, and both an internal and external QA program. Data quality objectives are the pre-evaluation expectations of precision, accuracy, and completeness of data. [40 CFR 63.8(e)(3)]

193 .b.i. The internal QA program must include, at a minimum, the activities planned by routine operators and analysts to provide an assessment of CMS performance. The· external QA program must include, at a minimum, systems audits that include the opp01tunity for on-site evaluation by DEQ of insh·ument calibration, data validation, sample logging, and documentation of quality conh·ol data and field maintenance activities.

193 .b.ii. The permittee must submit the site-specific performance evaluation test plan to DEQ (ifrequested) at least 60 days before the performance test or performance evaluation is scheduled to begin, or on a mumally agreed upon date, and review and approval of the performance evaluation test plan by DEQ will occur with the review and approval of the site-specific test plan (ifreview of the site-specific test plan is requested).

193.b.iii. DEQ may request additional relevant information after the submittal ofa site-specific performance evaluation test plan.

193.b.iv. In the event that DEQ fails to approve or disapprove the site-specific performance evaluation test plan within the time period specified in Condition 166.b, the following conditions apply.

193.b.v.


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193.b.iv.A. If intending to demonstrate compliance using the monitoring method(s) specified in the relevant standard, the permittee must conduct the performance evaluation within the time specified in the NESHAP using the specified method(s);

193 .b.iv.B. If intending to demonstrate compliance by using an alternative to a monitoring method specified in the relevant standard, the permittee must refrain from conducting the performance evaluation until the EPA Administrator approves the use of the alternative method. If the EPA Administrator does not approve the use of the alternative method within 30 days before the performance evaluation is scheduled to begin, the performance evaluation deadlines specified .in Condition 193 .cmay be extended such that the permittee must conduct the performance evaluation within 60 calendar days after the EPA Administrator approves the use of the alternative method. Notwithstanding the requirements in the preceding two sentences, the permittee may proceed to conduct the performance evaluation as required in this section (without the EPA Administrator's prior approval of the site-specific performance evaluation test plan) if he/she subsequently chooses to use the specified monitoring method(s) instead of an alternative.

Neither the submission of a site-specific performance evaluation test plan for approval, nor DEQ's approval or disapproval of a plan, nor DEQ's failure to approve or disapprove a plan in a timely manner shall:

193.b.v.A.

193.b.v.B.

Relieve the permittee of legal responsibility for compliance with any applicable provisions of 40 CFR Part 63 or with any other applicable Federal, State, or local requirement; or Prevent DEQ from implementing or enforcing 40 CFR Part 63 or taking any other action under the Clean Air Act.

Conduct of performance evaluation and performance evaluation dates

193 .c. The permittee must conduct a performance evaluation of a required CMS during any performance test required under 40 CFR 63.7 in accordance with the applicable performance specification as specified in the relevant standard. Notwithstanding the requirement in the previous sentence, if the permittee elects to submit COMS data for compliance with a relevant opacity emission standard, the permittee shall conduct a performance evaluation of the COMS as specified in the relevant standard, before the performance test is conducted in time to submit the results of the performance evaluation. If a performance test is not required, or the requirement for a performance test has been waived under 40 CFR 63 .7(h), the permittee must conduct the performance evaluation not later than 180 days after the appropriate compliance date for the affected somce. [40 CFR 63.8(e)(4)]

Use of an Alternate Monitoring Method

194. Until permission to use an alternative monitoring procedure (minor, intermediate, or major changes; see defmition in 40 CFR63.90(a)) has been granted pursuant to the provisions of 40 CFR 63.8(f), the permittee of an affected source remains subject to the requirements of 40 CFR 63.8 and the relevant standard. [40 CFR 63.8(f)]

Reduction of Monitoring Data

195. For each CMS, the permittee must reduce the monitoring data as specified in Conditions 195.a through195.d. [40 CFR 63.8(g)]


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195.a. The data from each COMS must be reduced to 6-minute averages calculated from 36 or more data points equally spaced over each 6-minute period. Data from CEMS for measurement other than opacity, unless otherwise specified in the relevant standard, must be reduced to 1-hour averages computed from four or more data points equally spaced over each I-hour period, except during periods when calibration, quality assurance, or maintenance activities pursuant to the provisions of 40 CFR Pait 63 are being performed. During these periods, a valid hourly average shall consist of at least two data points with each representing a 15-minute period. Alternatively, an arithmetic or integrated 1-hour average of CEMS data may be used. Time periods for averaging are defined in 40 CFR 63.2. [40 CFR 63.8(g)(2)]

195.b. The data may be recorded in reduced or nonreduced form (e.g., ppm pollutant and percent 02 or ng/J of pollutant). [40 CFR 63.8(g)(3]

195.c. All emission data must be converted into units of the relevant standard for reporting purposes using the conversion procedures specified in that standard. After conversion into units of the relevant standard, the data may be rounded to the same number of significant digits as used in that standard to specify the emission limit ( e.g., rounded to the nearest 1 percent opacity). [40 CFR 63.8(g)(4)]

195.d. Monitoring data recorded during periods ofunavoidable CMS breakdowns, out-of-control periods, repairs, maintenance periods, calibration checks, and zero (low-level) and high-level adjustments must not be included in any data average computed under 40 CFR Pait 63. If complying with the requirements of 40 CFR 63.10(b)(2)(vii)(A) or (B), data averages must include any data recorded during periods of monitor breakdown or malfunction. [40 CFR 63.8(g)(5)]

Subpart S Monitoring Requirements

Using Alternate Control Devices or Techniques

196. lfthe permittee uses a control device, technique or an alternative parameter other than those specified 40 CFR 63.453(b) through (1), then he must install a CMS and establish appropriate operating parameters to be monitored that demonstrate, to DEQ's satisfaction, continuous compliance with the applicable control requirements. [40 CFR 63.453(111)]

Establishing or Reestablishing Parameter Values

197. The permittee must use the following procedures to establish or reestablish the value for each operating parameter: [40 CFR 63.453(11)]

197 .a. During the initial performance test or any subsequent performance test, continuously record the operating parameter;

197.b. Determinations must be based on the control performance and parameter data monitored during the performance test, supplemented if necessary by engineering assessments and the manufacturer's recommendations;

197.c. The permittee must provide for DEQ's approval the rationale for selecting the monitoring parameters necessary to comply with paragraphs (t), (i), and (m) of 40 CFR 63.453; and

197.d. Provide for DEQ's approval the rationale for the selected operating parameter value, and monitoring frequency, and averaging time. Include all data and calculations used to develop the value and a description of why the value, monitoring frequency, and averaging time demonstrate continuous compliance with the applicable emission standard.

Operating Outside of Parameter Ranges


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198. The permittee must operate the control devices subject to the monitoring provisions in this permit that pertain to the Pulp and Paper NESHAP ( 40 CFR Part 63, Subpart S) in a manner consistent with the minimum or maximum (as appropriate) operating parameter value or procedure required to be monitored under 40 CFR 453(a) through (n) and established in accordance with Condition 197. Except as provided in Conditions 134 or 153, operation of the control device below minimum operating parameter values or above maximum operating parameter values established in this permit or failure to perform procedures required by this permit will constitute a violation of the applicable emission standard and must be reported as a period of excess emissions. [40 CFR 63.453( o)]

Subpart MM Monitoring Requirements

Determination of Operating Ranges

199. During the initial or periodic performance tests required in Conditions 48 and 61, the permittee must establish operating limits for the monitoring parameters in Conditions 46 and 65. [40 CFR 63.8640)(1)]

199.a. The permittee may base operating limits on values recorded during previous performance tests or conduct additional performance tests for the specific purpose of establishing operating limits, provided that data used to establish the operating limits are or have been obtained during testing that used the test methods and procedures required in this permit. The permittee must certify that all control techniques and processes have not been modified subsequent to the testing upon which the data used to establish the operating parameter limits were obtained. [40 CFR 63 .864G)(2)]

199.b. The permittee may establish expanded or replacement operating limits for the monitoring parameters determined in this condition during subsequent performance tests using the test methods in Condition 185. [40 CFR 63.8640)(3)]

199.c. The permittee must continuously monitor each parameter and determine the arithmetic average value of each pararrieter during each performance test run. Multiple performance tests may be conducted to establish a range of parameter values. Operating outside a previously established parameter limit during a performance test to expand the operating limit range does not constitute a monitoring exceedance. Operating limits must be confirmed or reestablished during performance tests. [40 CFR 63.864(i)(4)]

For an affected source or process unit that uses a wet scrubber, the permittee must set a minimum scrubber pressure drop operating limit as the lowest of the 1-hour average pressure drop values associated with each test run demonstrating compliance with the applicable emission limit. For a smelt dissolving tank dynamic wet scrubber operating at ambient pressure or for low-energy entrainment scrubbers where fan speed does not vary, the minimum fan amperage operating limit must be set as the lowest of the I-hour average fan amperage values associated with each test run demonstrating compliance with the applicable emission limit. [40 CFR63.864(i)(5)]

GENERAL RECORDKEEPING REQUIREMENTS

Title V Recordkeeping Requirements

200. The permittee must maintain the following general records of testing and monitoring required by this permit: [OAR 340-218-0050(3)(b )(A)]

200.a. The date, place as defined in the permit, and time of sampling or measurements.

200.b. The date(s) analyses were performed.

200.c. The company or entity that performed the analyses.

200.d. The analytical techniques or methods used.

200.e. The results of such analyses.


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200.f. The operating conditions as existing at the time of sampling or measurement.

200.g. The records of quality assurance for continuous monitoring systems (including but not limited to quality control activities, audits, calibration drift checks).

201. 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) will not be considered a permit deviation provided the amount of data lost does not exceed 10% of the operating time of the device being monitored on an annual basis. Upon discovering that a required record is missing, the pennittee must document the reason for the missing record. In addition, any missing record that can be recovered from other available information will not be considered a missing record. [OAR 340-214-0110, 340-214-0114, and 340-218-0050(3)(b)]

201.a. Recordkeeping: The permittee must maintain records of annual operating times and percent valid data availability for each pollution parameter monitoring system.

201.b. Missing CEM Data: For purposes of calculating actual emissions for comparison to the PSEL, the permittee must use the average of the last valid hourly value prior to the missing data period and the first valid hourly value after the missing data period as the value of each missing hour.

202. Recordkeeping requirements must co1mnence on the date of permit issuance unless otherwise specified in the permit or an applicable requirement. [OAR 340-2 l 8-0050(3)(b )(C)]

203. Unless otherwise specified, the permittee must retain records of all required monitoring data and support information for a period ofat least five (5) years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. All existing records required by the previous Air Contaminant Discharge Permit or Oregon Title V Operating Permit must also be retained for the five (5) years from the date of the monitoring sample, measurement, report, or application. [OAR 340-218-0050(b)(B)]

Part 63 Subpart A - General Recordkeeping Requirements

204. The permittee must maintain files of all information (including all reports and notifications) required by this permit 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, on computer floppy disks, on magnetic tape disks, or on microfiche. [40 CFR 63.lO(b)(l)]


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205. For each affected source and for each affected source required to install a CMS by a relevant standard, the permittee must maintain records of: [ 40 CFR 63 .1 0(b )(2) and 63 .10( c )]

205.a. All required maintenance performed on the air pollution control and monitoring equipment. [40 CFR 63 .1 0(b )(2)(iii)]

205.b. Each period during which a CMS is malfunctioning or inoperative (including out of control periods). [40 CFR 63 .1 0(b )(2)(vi)]

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

205.c.i. This sub-condition applies to permittees required to install a continuous emissions monitoring system (CEMS) where the CEMS installed is automated, and where the calculated data averages do not exclude periods of CEMS breakdown or malfunction. An automated CEMS records and reduces the measured data to the form of the pollutant emission standard through the use of a computerized data acquisition system. In lieu of maintaining a file of all CEMS subhourly measurements as required under Condition 205.g, the pennittee must retain the most recent consecutive three averaging periods of subhourly measurements and a file that contains a hard copy of the data acquisition system algorithm used to reduc~ the measured data into the reportable form of the standard.

205.c.ii. This sub-condition applies to permittees required to install a CEMS where the measured data is manually reduced to obtain the reportable form of the standard, and where calculated averages do not exclude periods of CEMS breakdown or malfunction. In lieu of maintaining a file of all CEMS subhourly measmements as required under Condition 205.g, the permittee must retain all subhourly measurements for the most recent reporting period. The subhourly measurements must be retained for 120 days from the date of the most recent smmnary or excess emissions report submitted to DEQ.

205.c.iii. DEQ, upon notification to the source, may require the permittee to maintain all measurements as required by Condition 205.g, ifDEQ determines these records are required to more accurately assess the compliance status of the affected source.

205.d. All results of performance tests, CMS performance evaluations, and opacity and visible emission observations. [40 CFR 10(b)(2)(viii)]

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

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

205 .g. All adjustments and maintenance performed on CMS. [ 40 CFR 63.1 0(b )(2)(xi)]

205 .h. All documentation supporting initial notifications and notifications of compliance status under 40 CFR63.9. [40 CFR63.10(b)(2)(xiv)]

205.i. All required CMS measurements (including monitoring data recorded during unavoidable CMS breakdowns and out-of-control periods). [40 CFR 63.l0(c)(l)]


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205.j. The date and time identifying each period during which the CMS was inoperative except for zero (low-level) and high-level checks. [40 CFR 63.10(c)(5)]

205 .k. The date and time identifying each period during which the CMS was out of control, as defined in Condition 191.g. [40 CFR 63.10(c)(6)]

205.1. The date and time of commencement and completion of each period of excess emissions and parameter monitoring exceedances that occurs during startup, shutdown or malfunction of the affected source. [40 CFR 63.10(c)(7)]

205 .m. The date and time of c01mnencement and completion of each period of excess emissions and parameter monitoring exceedances that occurs during periods other than startup, shutdown or malfunction of the affected source. [40 CFR 63.l0(c)(S)]

205.n. The nature and cause of any malfunction (if known). [40 CFR 63.1 0(c)(l0)]

205.o. The corrective action taken or preventive measures adopted. [ 40 CFR 63 .10( c)(l l )]

205.p. The nature of the repairs or adjustments to the CMS that was inoperative or out of control. [40 CFR 63.10(c)(l2)]

205.q. The total process operating time of each affected unit during the repmiing period. [40 CFR63.10(c)(l3)]

205.r. All procedures that are part ofa quality control program developed and implemented for CMS in accordance with Condition 192. [40 CFR63.10(c)(l4)]

Subpart S - General Recordkeeping Requirements

206. The permittee must record the CMS parameters specified in 40 CFR 63.453 and meet the requirements specified in 40 CFR 63 .454(a) for any new affected process equipment or pulping process condensate stream that becomes subject to the standards in Subpart S of 40 CFR Part 63 due to a process change or modification. [40 CFR 63.454(d)]

207. The permittee must maintain the following records of malfunctions: [40 CFR 63.454(g)]

207 .a. Records of the occurrence and duration of each malfunction of operation (i.e., process equipment) or the air pollution control and monitoring equipment.

207.b. Records of actions taken during periods of malfunction to minimize emissions, including corrective actions to restore malfunctioning process and air pollution control and monitoring equipment to its normal .or usual manner of operation.

Subpart MM - General Recordkeeping Requirements

208. The permittee must maintain records of any occurrence when corrective action is required under Conditions 30, 47, and 64 and when a violation is noted under Conditions 29, 45, and 63. [40 CFR 63.866(b)]

209. In addition to the general records required by Condition 204, the permittee must maintain the following records: [40 CFR 63.866(c) and (d)]


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209 .a. Records of black liquor solids firing rates in units of megagrams/day or tons/day for all recovery furnaces.

209.b. Records ofCaO production rates in units ofmegagrams/day or tons/day for all lime kilns.

209.c. Records of parameter monitoring data required under Conditions 24, 46, and 65 including any period when the operating parameter levels were inconsistent with the established levels, with a brief explanation of the cause of the monitoring exceedance, the time the monitoring exceedance occurred, the time corrective action was initiated and completed, and the corrective action taken.

209 .d. Records and documentation of supporting calculations for compliance determinations made under Condition 185.

209.e. Records of monitoring parameter operating limits established for each affected source or process unit.

209.f. Records ce1tifying that an NDCE recovery furnace equipped with a dry ESP system is used to comply with the gaseous organic HAP standard.

209.g. Records demonstrating compliance with the requirement to maintain proper operation of an ESP's A VC.

209.h. In the event that an affected unit fails to meet an applicable standard, including any emission limit or an opacity or CPMS operating limit, record the number of failures. For each failure record the date, start time, and duration of each failure.

209.i. For each failure to meet an applicable standard, record and retain a list of the affected sources or equipment and the following information:

209.j.

209.i.(A) For any failure to meet an emission limit, record an estimate of the quantity of each regulated pollutant emitted over the emission limit and a description of the method used to estimate the emissions.

209.i.(B) For each failure to meet an operating limit, maintain sufficient information to estimate the quantity of each regulated pollutant emitted over the emission limit. This information must be sufficient to provide a reliable emissions estimate ifrequested by DEQ.

Record actions taken to minimize emissions and any corrective actions taken to return the affected unit to its normal or usual manner of operation.

REPORTING REQUIREMENTS

NESHAP Notifications

Initial Notifications

210. The permittee of an affected source that has an initial startup before the effective date of a relevant standard must notify DEQ in writing that the source is subject to the relevant standard. The notification must be submitted not later than 120 calendar days after the effective date of the relevant standard ( or within 120 calendar days after the source becomes subject to the relevant standard) and must provide the following information: [40 CFR 63.9(b)(2)]

210.a. The name and address of the permittee;


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210.b. The address (i.e., physical location) of the affected source;

210.c. An identification of the relevant standard, or other requirement, that is the basis of the notification and the source's compliance date;

210 .d. A brief description of the nature, size, design, and method of operation of the source and an identification of the types of emission points within the affected source subject to the relevant standard and types of hazardous afrpollutants emitted; and

210.e. A statement of whether the affected source is a major source or an area source.

Request for Extension of Compliance

211. If the permittee cannot comply with a relevant standard by the applicable compliance date for that source, or if the pennittee has installed BACT or technology to meet LAER consistent with 40 CFR 63.6(i)(5), the permittee may submit to DEQ a request for an extension of compliance as specified in 40 CFR 63.6(i)(4) through 40 CFR 63.6(i)(6). [40 CFR 63.9(c)]

Additional Notification Requirements for Sources with Continuous Monitoring Systems

212. The permittee, if required to use a CMS by a relevant standard, must furnish DEQ written notification as follows: [40 CFR 63.9(g)]

212.a.

212.b.

212.c.

A notification of the date the CMS performance evaluation under Condition 193 is scheduled to begin, submitted simultaneously with the notification of the performance test date required under Condition 165. Ifno performance test is required, or if the requirement to conduct a performance test has been waived for an affected source under 40 CFR 63.7(h), the permittee must notify DEQ in writing of the date of the performance evaluation at least 60 calendar days before the evaluation is scheduled to begin;

A notification that COMS data results will be used to determine compliance with the applicable opacity emission standard during a performance test required by 40 CFR 63. 7 in lieu of Method 9 or other opacity emissions test method data as allowed by 40 CFR 63.6(h)(&)(ii), if compliance with an opacity standard is required for the source by a relevant standard. The notification shall be submitted at least 60 calendar days before the performance test is scheduled to begin; and

A notification that the criterion necessary to continue use of an alternative to relative accuracy testing, as provided by 40 CFR 63.8(±)(6), has been exceeded. The notification must be delivered or postmarked not later than 10 days after the occurrence of such exceedance, and it must include a description of the nature and cause of the increased emissions.

Notification of Compliance Status

213. The permittee must comply with all requirements for compliance status reports contained in this permit and as required by 40 CFR Part 63. Each time a notification of compliance status is required under 40 CFR Part 63, the permittee must submit the notification of compliance status to DEQ following completion of the relevant compliance demonstration activity specified in the relevant standard. If the permittee submits estimates or preliminary information in the application for approval of construction or reconstruction in place of the actual emissions data or control efficiencies required in paragraphs (d)(l )(ii)(H) and (d)(2) of 40 CFR 63 .5, the pennittee must submit the actual emissions data and other correct information as soon as available but no later than with the initial notification of compliance status required in this condition. [40 CFR63.9(h)(3) and (5)]

Adjustment to Time Periods or Postmark Deadlines for Submittal and Review of Required Communications


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214. Until an adjustment of a time period or postmark deadline has been approved by DEQ in accordance with the requirements in 40 CFR 63 .9(i), the permittee reinains strictly subject to the requirements of 40 CFR Part 63. [40 CFR 63.9(i)]

Change in Information Ah-eady Provided

215. Any change in the information already provided in accordance with Conditions 210 through 213 must be provided to DEQ in writing within 15 calendar days after the change. [40 CFR 63.9G)]

General NESHAP Reporting Requirements

Reporting Dates

216. The semiannual reports must be submitted by the same dates as the annual and semiannual reports required in the pennittee's Title V permit. [40 CFR 63.10(a)(5)]

General Reporting Requirement

217. The pennittee must submit repmts to DEQ in accordance with the repmting requirements in the relevant standard(s). [40 CFR63.10(d)(l)]

218. The permittee must report the results of a required performance test to DEQ before the close of business on the 60tl1 day following the completion of the performance test, unless specified otherwise in a relevant standard or as approved in writing by DEQ. The results of the performance test shall be submitted as part of the notification of compliance status required under 40 CFR 63.9(h). [40 CFR 63. l0(d)(2)]

Repmting Results of Opacity or Visible Emission Observations

219. If required to conduct opacity or visible emission observations by a relevant standard, the permittee must report the opacity or visible emissions results (produced using EPA Test Method 9 or EPA Test Method 22, or an alternative to these test methods) along with the results of the performance test required under 40 CFR 63. 7. If no performance test is required, or if visibility or other conditions prevent the opacity or visible emission observations from being conducted concurrently with the performance test required under 40 CFR 63 .7, the permittee must report the opacity or visible emission results before the close of business on the 30th day following completion of the opacity or visible emission observations. [40 CFR 63.10(d)(3)]

Compliance Extension Progress Reports

220. If the permittee is required to submit progress reports as a condition of receiving an extension of compliance, then such reports must be submitted to DEQ by the dates specified in the written extension of compliance. [40 CFR63.10(d)(4)]

221. Reserved.

222. Reserved

General Reporting Requirement for Sources with CMS

223. When more than one CEMS is used to measure the emissions from one affected source (e.g., multiple breechings, multiple outlets), the permittee must report the results as required for each CEMS. [40 CFR 63.l0(e)(l)]

Reporting Results of CMS Performance Evaluations

224. The pennittee must furnish DEQ a copy of a written report of the results of the CMS performance


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evaluation, as required in Condition 193, simultaneously with the results of the performance test required under 40 CFR 63. 7, unless otherwise specified in the relevant standard. If a COMS is used to determine opacity compliance during any performance test required under 40 CFR 63.7, the permittee must furnish DEQ two copies of a written report of the results of the COMS performance evaluation. The copies must be furnished at least 15 calendar days before the performance test required under 40 CFR 63. 7 is conducted. [40 CFR 63.10(e)(2).

CMS and Excess Emissions Reports

225. The pennittee must submit the semiannual Summary Reports and (if required) Excess Emissions and Continuous Monitoring System Performance Reports in accordance with the following unless more frequent reporting is specifically required by a relevant standard or DEQ determines that more frequent reporting is necessary to accurately assess the compliance status of the source. If more frequent reporting is required the pennittee may reduce the frequency of rep01ting for that standard to semiannual if the conditions in 40 CFR 63 .10( e)(3)(ii) through (iv) are met: [40 CFR 63.10( e)(3)(i) and (ii)]

225 .a. Written reports of excess emissions, exceedances of process or control system parameters, monitoring system performance rep01ts, and all smrunary reports, ifrequired, must be delivered or postmarked by the 30th day following the end of each calendar semiannual period, as appropriate must include all of the information required in Conditions 191.g through 191.i and Conditions 205.n through 205.u, and the relevant standard, and they must include the name, title, and signature of the responsible official who is certifying the accuracy of the rep01t. When no excess emissions or exceedances of a parameter have occurred, or a CMS has not been inoperative, out of control, repaired, or adjusted, such information must be stated in the report. [40 CFR 63.10(e)(3)(v)]

225.b. The Smmnary Rep01t must be entitled "Smrunary Report Gaseous and Opacity Excess Emission and Continuous Monitoring System Performance" and must contain the information specified below: [ 40 CFR 63 .10( e)(3)(vi)]

225.b.i. The company name and address of the affected source; 225 .b.ii. An identification of each hazardous air pollutant monitored at the affected source; 225.b.iii. The beginning and ending dates of the reporting period; 225.b.iv. A brief description of the process units; 225.b.v. The emission and operating parameter limitations specified in the relevant

standard(s ); 225.b.vi. The monitoring equipment manufacturer(s) and model number(s); 225.b.vii. The date of the latest CMS certification or audit; 225.b.viii.The total operating time of the affected source during the repo1ting period; 225.b.ix. An emission data smmnary (or similar summary if the permittee monitors control

system parameters), including the total duration of excess emissions during the rep01ting period (recorded in minutes for opacity and hours for gases), 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 startup/shutdown, control equipment problems, process problems, other known causes, and other unknown causes;

225.b.x. A CMS performance summary (or similar summary if the pennittee monitors control system parameters), including the total CMS downtime during the reporting period (recorded in minutes for opacity and hours for gases), the total duration of CMS downtime expressed as a percent of the total source operating time during that reporting period, and a breakdown of the total CMS downtime during the reporting period into periods that are due to monitoring equipment malfunctions, nonmonitoring equipment malfunctions, quality assurance/quality control calibrations, other known causes, and other unknown causes;


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225.b.xi. A description of any changes in CMS, processes, or controls since the last reporting period;

225.b.xii. The name, title, and signature of the responsible official who is certifying the accuracy of the report; and

225.b.xiii.The date of the report.

225 .c. If the total duration of excess emissions or process or control system parameter exceedances for the reporting period is less than 1 percent of the total operating time for the reporting period, and CMS downtime for the reporting period is less than 5 percent of the total operating time for the reporting period, only the Summary Report must be submitted, and the full Excess Emissions and Continuous Monitoring System Performance Report need not be submitted unless required by DEQ. [40 CFR 63.10(e)(3)(vii)]

225 .d. If the total duration of excess emissions of process or control system parameter exceedances for the reporting period is 1 percent or greater than of the total operating time for the reporting period, or the total CMS downtime for the reporting period is 5 percent or greater than of the total operating time for the reporting period, both the Summary Report and the Excess Emissions and Continuous Monitoring System Performance Report must be submitted. [40 CFR 63.10(e)(3)(viii)]

225.e. If required to use a COMS, the permittee must record the monitoring data produced during a performance test required under 40 CFR 63.7 and must furnish DEQ a written report of the monitoring results. The repmt of COMS data must be submitted simultaneously with the repo1t of the performance test results required by 40 CFR 63.10(d)(2). [40 CFR 63.10(e)(4)]

Waiver ofRecordkeeping or Reporting Requirements

226. Until a waiver of a recordkeeping or repo1ting requirement has been granted by DEQ in accordance with 40 CFR 63. l0(f), the permittee remains subject to the requirements of 40 CFR 63.10. Recordkeeping or reporting requirements may be waived upon written application to DEQ if, in DEQ's judgement, the permittee is achieving the relevant standard(s), or the source is operating under an extension of compliance, or the pennittee has requested an extension of compliance and DEQ is still considering the request. [ 40 CFR 63. l0(f)(l) and (2)]

Subpart S Reporting Requirements

22 7. The permittee must comply with the reporting requirements specified in Conditions 210 through 226 and Conditions 228 through 230. [40 CFR 63.455(a)]

228. The permittee must meet the requirements specified in Condition 227 upon startup of any new affected ptocess equipment or pulping process condensate stream that becomes subject to subpart S of 40 CFR Part 63 due to a process change or modification. [40 CFR 63.455(d)]

229. If the permittee uses the results of the performance test required in 40 CFR 63.453(p)(2) to revise the approved values or ranges of the monitoring parameters specified in 40 CFR 63.453U)(l) or (2), the permittee must submit an initial notification of the subsequent performance test to DEQ as soon as practicable, but no later than 15 days, before the performance test required in 40 CFR 63.453(p)(2) is scheduled to be conducted. The pennittee must notify DEQ as soon as practicable, but no later than 24 hours, before the performance test is scheduled to be conducted to confirm the exact date and time of the performance test. [40 CFR 63.455(e)]

230. To comply with the open biological treatment system monitoring provisions of 40 CFR 63.453(p)(3), the


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permittee must notify DEQ as soon as practicable of the onset of the dangerous, hazardous, or otherwise unsafe conditions that did not allow a compliance determination to be conducted using the sampling and test procedures in 40 CFR 63 .457(1). The notification must occur no later than 24 hours after the onset of the dangerous, hazardous, or otherwise unsafe conditions and must include the specific reason(s) that the sampling and test procedures in 40 CFR 63.457(1) could not be performed. [40 CFR 63.455(£)]

231. If a malfunction occurred during a reporting period, the pennittee must submit a report which must include the number, duration and a brief description of 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 the permittee during a malfunction of an affected source to minimize emissions, including actions taken to correct a malfunction. [40 CFR 63.455(g)]

232. The permittee must report the results of a performance test before the close of business on the 60 th day following the completion of the performance test, unless otherwise approved in writing by DEQ, utilizing the procedures and requirements in 40 CFR 63.455(h)(l) through (4). [40 CFR 63.455(h)]

Subpart MM Reporting Requirements

Notifications

233. The permittee must submit the applicable notifications from 40 CFR Part 63, Subpart A, as specified in Table 1 of subpart MM for any affected source or process unit. [40 CFR 63.867(a)(l)]

Subpart MM Excess Emissions Report

234. The pennittee must report by the end of the following month for each semiannual period that measured parameters meet any of the conditions specified in paragraph (k)(l) or (k)(2) of Part 63 .864 (i.e., Conditions 29, 30, 45, 47, 63, and 64) according to the procedures in 40 CFR 63.867(c)(l) through (4). [40 CFR 63.867(c)]

234.a. If the affected source or process units are subject to the requirements of subpart MM and subpart S of Part 63, the permittee may combine excess emissions and/or summary reports for the mill. [40 CFR 63.867(c)(5)]

23 5. Within 60 days after the date of completing each performance test, the permittee must submit the results of the performance test following the procedures specified in 40 CFR 63.867(d). [40 CFR 63.867(d)]

Title V Reporting Requirements

Semi-annual and Annual Reports

236. The pennittee must submit three (3) copies ofreports of any required monitoring at least every 6 months, completed on forms approved by DEQ. One copy of the report must be submitted to the EPA and two copies to the DEQ's Western Region - Salem office. 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)] and [40 CFR 63.10(a)(3) and (4)(ii)]

236.a. The first semi-annual reports for the reporting period of January 1 through June 30 are due on or before August 15, unless otherwise approved in writing by DEQ and must include the following:


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236.a.i. The first semi-annual Title V compliance certification repo1t (Forms Rl002 R1003, as applicable). [OAR 340-218-0080]

236.a.ii. The first semi-annual NESHAP-Subpart A Excess Emissions and/or Parameter Excursion Report in accordance with the requirements specified in Condition 225.a.

236.a.iii. The first semi-annual NESHAP-Subpart A Continuous Monitoring Systems (CMS) and Excess Emissions Report in accordance with the requirements specified in Conditions 225.b tlu·ough 225.d.

236.a.iv. The first semi-annual NESHAP-Subpait MM Excess Emissions Report in accordance with the requirements specified in Condition 234, if applicable.

236.a.v. A summary of excess emission events in accordance with Condition 238.f.

236.b. The second semi-annual reports for the reporting period of July 1 through December 31 and annual reports for the prior calendar year are due on or before March 15 and must include the following:

236.b.i. The annual Title V emission fee rep01t (Fonns Fl 101- Fl 106, as applicable). [OAR 340-220-0100].

236.b.ii. The annual emission inventory rep01t (Form Rl00l). [40 CFR part 51]

236.b.iii. The second Title V semi-annual compliance certification report (Forms R1002 -Rl003, as applicable). [OAR 340-218-0080]

236.b.iv. A summary of excess emission events in accordance with Condition 238.f.

236.b.v. The annual certification that the risk management plan is being properly implemented. [OAR 340-218-0080(7) and 340-244-0230]

236.b.vi. The second semi-annual NESHAP-Subpait A Excess Emissions and/or Parameter Excursion Report in accordance with the requirements specified in Condition 225.a.

236.b.vii. The second semi-annual NESHAP-Subpart A Continuous Monitoring Systems (CMS) and Excess Emissions Rep01t in accordance with the requirements specified in by Conditions 225.b through 225.d.

236.b.viii. The second semi-annual Subpmt MM Excess Emissions Rep01t in accordance with the requirements specified in Condition 234, if applicable. ·

237. The Title V semi-annual compliance certification must include the following (provided that the identification of applicable information may cross-reference the permit or previous rep01ts, as applicable): [OAR 340-218-0080(6)( c )]

23 7 .a. The identification of each term or condition of the permit that is the basis of the certification;

237.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, and whether such methods or other means provide continuous or intermittent data. Such methods and other means must include, at a minimum, the methods and means required under OAR 340-218-0050(3 ). Note: Certification of compliance with the monitoring conditions in the permit is sufficient to meet this requirement, except when the permittee must certify compliance with new applicable requirements that are incorporated by reference in the permit. When certifying compliance with new applicable requirements that are not yet in the permit, 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 l 13(c)(2) of the FCAA, which prohibits knowingly making a false certification or omitting material information;

238.


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23 7 .c. The status of compliance with terms and conditions of the permit for the period covered by the certification, based on the method or means designated in Condition 237.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, occurred; and

237.d. Such other facts as DEQ may require to determine the compliance status of the source.

237.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)]

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

238.a. Immediately (within 1 hour of the event) notify DEQ ofan excess emission event by phone, email, or facsimile; and

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

238.b.i. The date and time of the beginning of the excess emissions event and the duration or

238.b.ii. 23 8 .b.iii. 238.b.iv.

238.b.v.

best estimate of the time until return to normal operation; The date and time the owner or operator notified the Department of the event; The equipment involved; Whether the event occurred during planned startup, planned shutdown, scheduled maintenance, or as a result of a breakdown, malfunction, or emergency; Steps taken to mitigate emissions and corrective action taken, including whether the approved procedures for a planned stmtup, shutdown, or maintenance activity were followed;

23 8. b. vi. The magnitude and duration of each occurrence of excess emissions during the course of an event and the increase over normal rate.s or concentrations as determined by continuous monitoring or best estimate (supported by operating data and calculations);

238.b.vii. The final resolution of the cause of the excess emissions; and 238.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.

23 8.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 pennittee must immediately notify DEQ by calling the Oregon Emergency Response System (OERS). The current number is 1-800-452-0311.

238.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.

23 8 .e. 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


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summary listing the date, time, and the affected emissions units for each excess emission that occurred dming the reporting period. [OAR 340-218-0050(3)(c)]

238.f. Notwithstanding the immediate reporting requirement specified above, the permittee must make an initial notification of an excess emissions event no later than one hour after the start of first working day (i.e. 8 AM of the following day) following the excess emissions event.

Chronic Upset Conditions

239. IfDEQ determines that an upset condition is chronic and correctable by installing new or modified process or control procedures or equipment, a program and schedule to effectively eliminate the deficiencies causing the upset conditions must be submitted. Such reoccurring upset conditions causing emissions in excess of applicable limits may be subject to civil penalty or other appropriate action. [OAR 340-234-0270]

Permit Deviations

240. 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 238. [OAR 340-218-0050(3)(c)(B)]

Other Reporting Requirements

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

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

Greenhouse Gas Registration and Reporting

243. If the calendar year emission rate of greenhouse gases (CO2e) is greater than or equal to 2,756 tons (2500 metric tons), the permittee must register and report its greenhouse gas emissions with DEQ in accordance with OAR 340-215. The greenhouse gas repo1t must be ce1tified by the responsible official consistent with OAR 340-218-0040(5).

Addresses ofregulatory agencies are the following, unless otherwise instructed:

DEQ- Western Region 4026 Fairview Industrial Drive SE Salem, OR 97302 (503) 378-8240

EMISSION FEES

DEQ - Air Quality Division 700 NE Multnomah St., Suite 600 Portland, OR 97232 (503) 229-5359

Air Operating Permits US Enviromnental Protection Agency Mail Stop OAQ-108 1200 Sixth Avenue Seattle, WA 98101

244. Emission fees will be based on the Plant Site Emissions Limits, unless the permittee elects to report actual emissions for one or more permitted processes/pollutants. [OAR 340-220-0090]

NON-APPLICABLE REQUIREMENTS

245. State and Federal air quality requirements (e.g., rules and regulations) currently determined not


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applicable to the permittee are listed below along with the reason for the non-applicability: [OAR 340-218-0110]

Non-Agglicable Reason Non-Agglicable Reason Non-Agglicable Reason Non-Agglicable Reguirement Code Reguirement Code Reguirement Code Reguirement

OAR Chapter 340: 0045 through 0060 C Division 242 Division 264

Division 202 0245 through 0260 C all rules C all rules

all rules Division 225 Division 244 40 CFR

Division 204 0045 C 0242 h Part 55

all rules Division 226 8990 through 9090 b Part 57

Division 206 0400 h Division 248 Part 60, except

0050 C Division 228 0210-0230 b subparts A, BB (40 CFR

0060 0120 through 0130 f Division 250 60.283(a)(l )(iii)

Division 208 0200 e all rules only), JJJJ, and

0500 through 0610 d 0300 through 0678 b Division 252 appendices

Part 61, except Division 210 Division 230 all rules subparts A, M, and 0100 through 0120 b all rules e Division 254 appendices

Division 214 Division 232 all rules e Part 63, except

0200 through 0220 C all rules C Division 256 subparts A, S, MM, RR,ZZZZ,

Division 218 Division 234 all rules b DODOO, and

0050(4) b 0100 through O 140 e Divisiort 257 appendices

0050(8) h 0500 through 0540 b all rules e Parts 72 through 78

0090 b Division 236 Division 258 Part 82, except subpart F

0100 b all rules b all rules b Parts 85 through 89 Division 222 Division 238 Division 260

0042 h 0100 e all rules b

0060 h Division 240 Division 262

Division 224 all rules C all rules b

Reason code definitions:

a this pollutant is not emitted by the facility b the facility is not in this source category c the facility is not in a special control/nonattainment area d the facility is not in this county e the facility does not have this emissions unit f the facility does not use this fuel type g the rule does not apply because no changes have been made at the facility that would trigger these

procedural requirements h this method/procedure is not used by the facility

this rule applies only to DEQ and regional authorities

Reason Code

h

b

b

b

b

b

b

b

b

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

GENERAL CONDITIONS

G 1. General Provision

Pennit number: 22-3501-TV-01 Expiration date: 07/01 /25

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

02. 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; November 15, 2018; b. Continuous Monitoring Manual; April 16, 2015 - 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.

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

04.

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.

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 reissuance, 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.

05. Masking Emissions:

The permittee must 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.

06. Credible Evidence:

07.

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]

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


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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.

GS. 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]

Gl0.

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.

Stratospheric Ozone and Climate Protection [40 CFR 82 Subpait F, OAR 340-260-0040]

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

Gl 1. Permit Shield [OAR 340-218-011 0]

a. Compliance with the conditions of the permit is deemed compliance with any applicable requirements as of the date ofpennit 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 smmnaiy 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 depa1tment);

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 ofDEQ to obtain information from a source pursuant to ORS 468.095 (investigatory authority, entry on premises, status ofrecords).

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(l)(h), significant permit modification, or reopening for cause by DEQ.

G 12. 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, or an authorized representative (including an authorized contractor acting as a representative of the EPA Administrator), to perform the following:

Gl3.

014.

015.


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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

parameter~, for the purposes of assuring compliance with the permit or applicable requirements.

Fee Payment [OAR 340-220-0010, and 340-220-0030 through 340-220-0190]

The pennittee must pay an annual base fee and an annual emission fee for particulates, sulfur dioxide, nitrogen oxides, and volatile organic compounds. The permittee must submit payment to the Department of Environmental Quality, Financial Services, 700 Multnomah St., Suite 600, Portland, OR 97232, 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. Payment must be made regardless of the dispute. User-based fees will be charged for specific activities (e.g., computer modeling review, ambient monitoring review, etc.) requested by the permittee.

Off-Permit Changes to the Source [OAR 340-218-0140(2)]

a. The pennittee 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 ofregulated air pollutants subject to an Qpplicable 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 G 11 does not extend to off-permit changes.

Section 502(b)(l 0) Changes to the Source [OAR 340-218-0140(3)]

a. The permittee must monitor for, and record, any section 502(b)(l0) change to the source, which is defmed as a change that would contravene an express permit term but would not:

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

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

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

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


of 112

016. 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.

Gl 7. Minor Permit Modification [OAR 340-218-0170]

018.

019.

020.

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

Significant Permit Modification [OAR 340-218-0180]

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

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

Notwithstanding conditions O 16 and O 17, 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.

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.

021. 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.

022. Need to Halt or Reduce Activity Not a Defense [OAR 340-2 l 8-0050(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.

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

The pennittee 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.

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

G25.

G26.


of 112

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

b. A permit must be reopened and revised under any of the circumstances listed in OAR 340-2 l 8-0200(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.

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.

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

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

b. Applications for renewal must be submitted at least 12 months before the expiration of this permit, unless 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 pennittee submits a timely and complete renewal application, this permit will remain in effect until final action has been taken on the renewal application to issue or deny the permit.

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

The permit is not transferable to any person except as provided in OAR 340-218-0150(l)(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 Western Region 4026 Fairview Industrial Drive SE Salem, OR 97302 503-378-8240

~.

Permit No.: 22-3501-TV-0l Expiration Date: 07/01/25

Page 1 of 11 Pages

rt.: 1 ,1 =<•1 OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

OREGON TITLE V OPERATING PERMIT State of Oregon Department of Environmental Quality

PART 2 of2

Western Region 4026 Fairview Industrial Drive SE

Salem, OR 97302 Telephone: 503-378-8240

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:

Cascade Pacific Pulp, LLC P.O. Box 400 Halsey, OR 97348

PLANT SITE LOCATION:

Halsey Pulp Mill 30480 American Drive Halsey, OR 97348

INFORMATION RELIED UPON:

See Part 1 of permit

LAND USE COMPATIBILITY STATEMENT:

Issued By: Dated:

Linn County 04/01/93

ISSUED BY THE DEPARTMENT OF ENVIRONMENTAL QUALITY

I JUN 3 0 2020 rn Region Air Quality Manager Date

Nature of Business:

Primary SIC: Supporting SIC:

RESPONSIBLE OFFICIALS:



See Part 1 of permit See Part 1 of permit

FACILITY CONTACT PERSON:


Permit No.: 22-3501-TV-01 Expiration Date: 07/01/25

Page 3 of 11 Pages

4.a.i The pennittee must meet each work practice standard in Table 3 that applies to the boiler or process heater, for each boiler or process heater at the source. [ 40 CFR 63.7500(a)(l)]

4.a.ii At all times, the pennittee must operate and maintain any affected source (as defined in 40 CFR 63.7490), including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. Determination of whether such operation and maintenance procedures are being used will be based on available information that 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 63.7500(a)(3)]

4.b As provided in 40 CFR 63.6(g), EPA may approve use of an alternative to the work practice standards. [40 CFR 63.7500(b)]

4.c Limited-use boilers and process heaters must complete a tune-up every 5 years as specified in Condition 10. They are not subject to the emission limits in Tables 1 and 2 or 11 through 13, the annual tune-up, or the energy assessment requirements in Table 3, or the operating limits in Table 4. [40 CFR 63.7500(c)]

4.d Boilers and process heaters with a heat input capacity of less than or equal to 5 million Btu per hour in the units designed to burn gas 2 ( other) fuels subcategory, or units designed to burn light liquid fuels subcategory must complete a tune-up every 5 years as specified in Condition 10. [40 CFR 63.7500(d)]

4.e Boilers and process heaters in the units designed to burn gas 1 fuels subcategory with a heat input capacity of less than or equal to 5 million Btu per hour must complete a tune-up every 5 years as specified in Condition 10. Boilers and process heaters in the units designed to burn gas 1 fuels subcategory with a heat input capacity greater than 5 million Btu per hour and less than 10 million Btu per hour must complete a tune-up every 2 years as specified in Condition 10. Boilers and process heaters in the units designed to burn gas 1 fuels subcategory are not subject to the emission limits in Tables 1 and 2 or 11 through 13, or the operating limits in Table 4. [40 CFR 63.7500(e)]

4.f These standards apply at all times the affected unit is operating, except during periods of startup and shutdown during which time the permittee must comply only with Table 3. [ 40 CFR 63.7500(£)]

5. Reserved.

Initial Compliance Requirements

6. Initial compliance requirements and deadlines. [40 CFR 63.7510]

6.a The permittee must complete an initial tune-up by following the procedures described in Conditions 1 0.a.i.( 1) through 10 .a.i.( 6) no later than the compliance date specified in Condition 3. The permittee must complete the one-time energy assessment specified in Table 3 no later than the compliance date specified in Condition 3. [40 CFR 63.7(a)(2) and 63.7510(e)]

7. Conducting subsequent tune-ups. [40 CFR 63.7515]

7 .a If required to meet an applicable tune-up work practice standard, the permittee must conduct an annual, biennial, or 5-year performance tune-up according to Condition 10.a.i, 1 0.a.ii, or

Permit No.: 22-3501-TV-01 Expiration Date: 07/01/25

Page 5 of 11 Pages

any time prior to tune-up or delay the burner inspection until the next scheduled or unscheduled unit shutdown). At units where entry into a piece of process equipment or into a storage vessel is required to complete the tune-up inspections, inspections are required only during planned entries into the storage vessel or process equipment; [ 40 CFR 63. 7540(a)(l 0)(i)]

1 0.a.i.(2) Inspect the flame pattern, as applicable, and adjust the burner as necessaty to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available; [ 40 CFR 63. 7540(a)(IO)(ii)]

1 0.a.i.(3) Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (the permittee may delay the inspection until the next scheduled unit shutdown). [40 CFR 63.7540(a)(10)(iii)]

1 0.a.i.( 4) Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any NOx requirement to which the unit is subject; [40 CFR 63.7540(a)(I0)(iv)]

10.a.i.(5) Measure the concentrations in the effluent stream of CO in pmis per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dty or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer; and [ 40 CFR 63. 7540(a)(l 0)(v)]

1 0.a.i.( 6) Maintain on-site and submit, if requested by DEQ, a report containing the following informi:ition: [40 CFR 63.7540(a)(l0)(vi)]

1 0.a.i.(6)(a) The concentrations of CO in the effluent stream in parts per million by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler or process heater; [ 40 CFR 63 .7540(a)(l 0)(vi)(A))

10 .a.i.( 6)(6) A description of any corrective actions taken as a part of the tune-up; and [40 CFR 63.7540(a)(l0)(vi)(B)]

10.a.i.(6)(c) The type and amount of fuel used over the 12 months prior to the tune-up, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel used by each unit. [40 CFR 63.7540(a)(10)(vi)(C))

10 .a.ii If the boiler or process heater has a heat input capacity of less than 10 MMBtu per hour ( except as specified in Condition 10 .a.iii), the permittee must conduct a biennial tune-up of the boiler or process heater as specified in Conditions 10 .a.i.( 1) through 10.a.i.(6) to demonstrate continuous compliance. [40 CFR 63.7540(a)(l 1)]

10 .a.iii If the boiler or process heater has a continuous oxygen trim system that maintains an optimum air to fuel ratio, or a heat input capacity of less than 5 MMBtu per hour, and the unit is in the units designed to burn gas 1; units designed to burn gas 2 ( other); or units designed to burn light liquid subcategories, or meets the definition of limited-use boiler or process heater in 40 CFR 63.7575, the permittee must conduct a tune-up of the boiler or process heater every 5 years as specified in

12.

Permit No.: 22-3501-TV-01 Expiration Date: 07/01 /25

Page 7 of 11 Pages

11.b.iv.(1) "This facility completed the required initial tune-up for all of the boilers and process heaters covered by 40 CPR 63 Subpart DDDDD at this site according to the procedures in 40 CPR 63 .7540(a)(10)(i) through (vi)." [40 CPR 63.7545(e)(8)(i)]

11.b.iv.(2) 'This facility has had an energy assessment performed according to 40 CPR 63.7540(e)." [40 CPR 63.7545(e)(8)(ii)]

11.b.iv.(3) Except for units that burn only natural gas, refinery gas, or other gas 1 fuel, or units that qualify for a statutory exemption as provided in section 129(g)(l) of the Clean Air Act, include the following: "No secondary materials that are solid waste were combusted in any affected unit." [ 40 CPR 63.7545(e)(8)(iii)]

11.c If operating a unit designed to burn natural gas, refinery gas, or other gas 1 fuels that is subject to the NESHAP, and intending to use a fuel other than natural gas, refinery gas, gaseous fuel subject to another subpart of 40 CPR pati 60, 61, 63, or 65, or other gas 1 fuel to fire the affected unit during a period of natural gas cmtailment or supply interruption, as defined in 40 CPR 63.7575, the permittee must submit a notification of alternative fuel use within 48 hours of the declaration of each period of natural gas curtailment or supply interruption, as defined in 40 CPR 63.7575. The notification must include the following information: [40 CPR 63.7545(:f)]

11.c.i Company name and address. [40 CPR 63.7545(:f)(l)]

1 Le.ii Identification of the affected unit. [40 CPR 63.7545(£)(2)]

11.c.iii Reason the pennittee is unable to use natural gas or equivalent fuel, including the date when the natural gas curtailment was declared or the natural gas supply interruption began. [40 CPR 63.7545(£)(3)]

11.c.iv Type of alternative fuel that the permittee intends to use. [ 40 CPR 63. 7545(:f)( 4)]

11.c.v Dates when the alternative fuel use is expected to begin and end. [ 40 CPR 63.7545(£)(5)]

11.d If the permittee has switched fuels or made a physical change to the boiler or process heater and the fuel switch or physical change resulted in the applicability of a different subcategory, the pennittee must provide notice of the date upon which the permittee switched fuels or made the physical change within 30 days of the switch/change. The notification must identify: [40 CPR 63.7545(11)]

11.d.i The name of the owner or operator of the affected source, as defined in 40 CPR 63.7490, the location of the source, the boiler(s) and process heater(s) that have switched fuels, were physically changed, and the date of the notice. [40 CPR 63.7545(h)(l)]

11.d.ii The currently applicable subcategory under the NESHAP. [40 CPR 63.7545(h)(2)]

11.d.iii The date upon which the fuel switch or physical change occurred. [ 40 CPR 63 .7545(h)(3)]

11.e Change in information already provided. Any change in the information already provided under this section must be provided to the Administrator in writing within 15 calendar days after the change. [40 CPR 63.9(i)]

Reporting. [40 CPR 63.7550]

12.a Compliance Report. Unless DEQ has approved a different schedule for submission of reports under 40 CPR 63 .1 0(a), the permittee must submit each report as follows. For units that are


Page 9 of 11 Pages

burner inspection if it was not done annually, biennially, or on a 5-year period and was delayed until the next scheduled or unscheduled unit shutdown. [ 40 CFR 63. 7550( c )(5)(xiv)]

12.b.vii Statement by a responsible official with that official's name, title, and signature, certifying the truth, accuracy, and completeness of the content of the report. [40 CFR 63.7550(c)(5)(xvii)]

12.c The permittee must submit all reports required by Table 9 of 40 CFR Part 63 Subpart DDDDD electronically to the EPA via the CEDRI. (CEDRI can be accessed through the EPA's CDX.) The permittee must use the appropriate electronic report in CED RI for this subpart. Instead of using the electronic report in CED RI for this subpart, the permittee may submit an alternate electronic file consistent with the XML schema listed on the CEDRI website (https://www.epa.gov/chieD, once the XML schema is available. If the reporting form specific to this subpaii is not available in CEDRI at the time that the rep01i is due, the permittee must submit the rep01i to DEQ at the appropriate address listed in the permit. The permittee must begin submitting repmis via CEDRI no later than 90 days after the form becomes available in CEDRI. [40 CFR 63.7550(11)(3)]

13. Recordkeeping. [40 CFR 63.7555]

13.a The permittee must keep the following records: [40 CFR 63.7555(a)]

13 .a.i A copy of each notification and rep01i that was submitted to comply with the NESHAP, including all documentation supporting any Initial Notification or Notification of Compliance Status or semiannual compliance rep01i that the permittee submitted. [40 CFR 63.10(b)(2)(xiv) and 63.7555(a)(l)]

13 .a.ii The occurrence and duration of each startup, shutdown, or malfunction of operation (i.e., process equipment); [ 40 CFR 63 .1 0(b )(2)(i)]

13 .a.iii All required maintenance performed on the air pollution control and monitoring equipment; [ 40 CFR 63 .1 0(b )(2)(iii)]

13.b If operating a unit in the unit designed to burn gas 1 subcategory that is subject to the NESHAP, and using an alternative fuel other than natural gas, refinery gas, gaseous fuel subject to another subpati under 40 CFR part 60, 61, 63, or 65, or other gas 1 fuel, the permittee must keep records of the total hours per calendar year that alternative fuel is burned and the total hours per calendar year that the unit operated during periods of gas curtailment or gas supply emergencies. [40 CFR 63.7555(h)]

14. Form and how duration of recordkeeping. [40 CFR 63.7560]

14.a Records must be in a form suitable and readily available for expeditious review. [40 CFR 63.7560(a)]

14.b The permittee must keep each record for 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. [ 40 CFR 63. 7560(b )]

14.c The permittee must keep each record on site, or they must be accessible from on-site (for example, through a computer network), for at least 2 years after the date of each occurrence, measurement, maintenance, corrective action, repoti, or record. The pennittee can keep the records off site for the remaining 3 years. [ 40 CFR 63. 7560( c )]


Page 11 of 11 Pages

c. An inventory of major energy use systems consuming energy from affected boilers and process heaters and which are under the control of the boiler/process heater owner/operator. d. A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage. e. A review of the facility's energy management practices and provide recommendations for improvements consistent with the definition of energy management practices, if identified. f. A list of cost-effective energy conservation measures that are within the facility's control. g. A list of the energy savings potential of the energy conservation measures identified. h. A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments.

Table 10 in 40 CFR Part 63 Subpart DDDDD lists the General Provisions from 40 CFR Part 63 that are applicable to Subpart DDDDD and is incorporated by reference. The permittee must comply with any applicable General Provisions as shown in Table 10.

jun 3 o 2020

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