oregon title v operating permit review report title v operating permit review report ......

Review Report/Permit No.: 04-0041-TV-02

Application number: 023009

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OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

OREGON TITLE V OPERATING PERMIT

REVIEW REPORT Northwest Region

2020 SW Fourth Avenue, Suite 400

Portland, OR 97201

Source Information:

SIC 2421, 4961 Source Categories (Part and code) B.64

NAICS 321113,

321912,

221330

Compliance and Emissions

Monitoring Requirements:

Unassigned emissions COMS X

Emission credits CEMS

Compliance schedule Ambient monitoring

Source test X

Reporting Requirements:

Annual report (due date) 3/15 Monthly report (due dates)

Emission fee report (due date) 3/15 Excess emissions report X

SACC (due date) 7/30 Other reports X

Quarterly report (due dates)

Air Programs:

NSPS (list subparts) Dc Title V X

NESHAP (list subparts) DDDD ACDP (SIP)

CAM Major HAP source X

Regional Haze (RH) Federal major source X

Synthetic Minor (SM) NSR

Part 68 Risk Management PSD

CFC Acid Rain

RACT Clean Air Mercury Rule (CAMR)

TACT



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TABLE OF CONTENTS

PERMITTEE IDENTIFICATION ................................................................................................................................ 6

FACILITY DESCRIPTION .......................................................................................................................................... 6

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING ......................... 9

PLANT SITE EMISSION LIMITS ............................................................................................................................. 13

HAZARDOUS AIR POLLUTANTS .......................................................................................................................... 14

GENERAL BACKGROUND INFORMATION ......................................................................................................... 15

COMPLIANCE HISTORY ......................................................................................................................................... 15

SOURCE TEST RESULTS ......................................................................................................................................... 16

PUBLIC NOTICE ....................................................................................................................................................... 17

EMISSIONS DETAIL SHEETS ................................................................................................................................. 19



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LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT

AQMA Air Quality Management Area

ASTM American Society of Testing and

Materials

BDT bone dry ton

CEMS continuous emissions monitoring

system

CFR Code of Federal Regulations

CMS continuous monitoring system

CO carbon monoxide

COMS continuous opacity monitoring

system

DEQ Oregon Department of

Environmental Quality

dscf dry standard cubic feet

EF emission factor

EPA United State Environmental

Protection Agency

EU emissions unit

FCAA Federal Clean Air Act

gr/dscf grains per dry standard cubic feet

HAP hazardous air pollutant

ID identification code

I&M inspection and maintenance

MB material balance

Mlb 1000 pounds

MM million

NA not applicable

NESHAP National Emission Standard for

Hazardous Air Pollutants

NOx oxides of nitrogen

NSPS New Source Performance Standard

NSR New Source Review

O2 oxygen

OAR Oregon Administrative Rules

ORS Oregon Revised Statutes

O&M operation and maintenance

Pb lead

PCD pollution control device

PM particulate matter

PM10 particulate matter less than 10

microns in size

PSD Prevention of Significant

Deterioration

PSEL Plant Site Emission Limit

SO2 sulfur dioxide

ST source test

VE visible emissions

VMT vehicle mile traveled

VOC volatile organic compound



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INTRODUCTION

1. The Department proposes to renew the Title V Air Operating Permit issued to the Weyerhaeuser

Corporation Warrenton Sawmill, in Warrenton, Oregon.

2. In accordance with OAR 340-218-0120(1)(f), this review report is intended to provide the legal and factual

basis for the draft permit conditions. In most cases, the legal basis for a permit condition is included in the

permit by citing the applicable regulation. In addition, the factual basis for the requirement may be the

same as the legal basis. However, when the regulation is not specific and only provides general

requirements, this review report is used to provide a more thorough explanation of the factual basis for the

draft permit conditions.

3. The following changes have been made at the facility during the last permit term:

Date Permit revision or notification Brief explanation

10/23/07 Notice of Construction – Type 1

Application No. 22417

Clean-up conveyor added to planer operation. Deminimus (<

1 tons/yr) emissions. This conveyor improves material

handling in the planer building.

09/23/08 Administrative Amendment

No. 23450

Department initiated modification to the excess emission

reporting rules, and corresponding permit conditions.

12/04/08 Administrative Amendment

No. 23548

Change in Ownership from the Weyerhaeuser Company to

Weyerhaeuser NR.

4. The following is a list of condition-by-condition changes between the previous permit and the proposed

permit:

New Permit

Condition

Number

Old Permit

Condition

Number Description of change Reason for change

Cover Page Cover Page Added NAICS Codes in addition to

SIC Codes

Industry Standard

1 1 No change N/A

2 2 Updated language Template language update

3 3 Updated emission unit descriptions Clarification and better descriptions

4 4 Added fugitive emission control

requirements

Template language update

5 5 Clarified weekly fugitive emission

surveys


6 7 No change N/A

7 6 No change N/A

8 8 Updated language Template language update

9 9 Added allowable fuels Template language update

10 10, 19 Updated language Template language update

11 11 No change N/A

12 12, 14 Added emission unit 4-NGB to the

State Opacity requirements.

Clarified that emission unit 4-NGB is

subject to the State opacity

requirements in addition to those in

the NSPS Subpart Dc.

13 13 No change N/A

14 15 No change N/A

15 20 No change N/A

16 14 Separate visible emission monitoring

condition for emission units 1-WH

Clarification for individual emission

units with differing monitoring



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New Permit

Condition

Number

Old Permit

Condition


and 6-FUG frequency requirements.

17 14 Separate visible emission monitoring

condition for emission units 2-KLN

and 5-SM


units with differing monitoring

frequency requirements.

18 21 Deleted reference to cyclones Testing reference not necessary.

19 14, 16, 17 Separate monitoring and operational

requirements for the hog-fuel boiler

(3-HFB)


unit requirements.

20 17 Separate compliance testing

requirement for the hog-fuel boiler

(3-HFB)


unit requirements. Increase in

frequency based upon past source

test results.

21 14, 17, 18, 19 Separate monitoring and operational

requirements for the natural gas

boiler (4-NGB). Add condition 21.b.

for NSPS opacity monitoring

requirements.


unit requirements.

22 17 Separate compliance testing

requirement for the natural gas boiler

(4-NGB).


unit requirements.

23 14.e No substantive change – reference to

each applicable monitoring condition.

N/A

24 22, 23 Updated language Template language update

25 24 PSEL updated Increases due to correction of

emission factors

26 25 Updated emission factor and added

reference to calculation condition

Source test results indicated increase

in Pm/PM10 3-HFB EF; added

reference for SO2 for 4-NGB.

27 26 Deleted ―Type 1‖ reference Designation not necessary, and

confusing with ASTM Grade 1 and 2

oil.

28 27 Updated emission factor verification

testing requirements for boilers,

deleted reference to kiln (2-KLN)

testing, and changed frequencies.

Increased PM testing frequency

based upon past source test results

for 3-HFB, added VOC testing once

per permit term based upon testing

guidance.

29 -- New condition for emission fees

related to TRAACS data base.


30 29 Added reference to NSPS testing

requirements for 4-NGB; clarified

language

Clarified testing requirement

references for federal NSPS rules;

template language update

31 30.a No substantive change N/A - Template language update

32 30.b No substantive change N/A - Template language update

33 30.c No substantive change N/A - Template language update

34 31.a No change N/A

35 31.c No change N/A

36 31.d No change N/A

37 31.e No change N/A

38 31.b. Updated recordkeeping requirements

to match condition changes and

Clarified recordkeeping requirements

with permit changes



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New Permit

Condition

Number

Old Permit

Condition


added condition numbers as reference

39 35 and

Administrative

Amendment

No. 23450

Condition No. 1

Excess Emission reporting now

includes written follow-up within 15

days of occurrence.

Rule change

40 36 Notification changed from 7 days to

15 days

Rule change

41 -- Added necessary condition Condition required per rule

42 38, 39 No substantive change Consolidated two conditions into

one.

43 32 Reduced number of copies of reports Consolidation of reporting

44 33 No change N/A

45 37 No change N/A

46 -- Added necessary condition Condition required per rule

47 40 No change N/A

General

Conditions

G1- G29

General

Conditions

G1 – G27

Conditions G3 and G5 are new Departmental Program update

PERMITTEE IDENTIFICATION

5. The permittee is the Weyerhaeuser Corporation Warrenton Sawmill, located at 550 NE Skipanon Drive,

Warrenton, Oregon, 97146.

FACILITY DESCRIPTION

6. The Weyerhaeuser-Warrenton is a sawmill that processes wood logs to make commercial grade lumber.

Site activities include debarking, saw cutting, shipping, planning, and drying the lumber in 7 drying kilns.

The kilns are heated by steam, which is provided by one wood-fired boiler with a supplementary natural

gas burner, and one natural gas-fired boiler that can use number 1 & 2 diesel fuel oil for backup.

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION

7. The emissions units at this facility are the following:

EU ID Emission Unit Description

1-WH Unpaved roads

2-KLN Dry Kilns

3-HFB Hogged fuel boiler: Boiler 1 - Wellons fuel cell

4-NGB Natural gas boiler: Boiler 2 - Cleaver Brooks,

with #1 or #2 backup fuel oil

5-SM Sawmill and Planer operations:

Baghouses for controlling emissions from wood

residual generating and handling processes.

6-FUG Fugitive emissions from material handling transfers.

7-VOC Volatile organic compound emissions from paints,

coatings, and sealers used for production purposes

8-AGG Aggregate insignificant



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1-WH (Wheel Emissions on Unpaved Roads): This emission unit is comprised of fugitive wheel emissions caused

by trucks and equipment. Emissions are total particulate matter (PM) and particulate matter less than 10 microns in

size (PM10).

2-KLN (Dry Kilns): Cut lumber in stacks is loaded into the kilns and dried to reduce moisture content. The kilns

are heated to approximately 190°F using steam generated in the boilers. At this time, the facility dries douglas fir

and hemlock, but is not limited to these wood species. Emissions are volatile organic compounds (VOC), some of

which are Hazardous Air Pollutants (HAPs), and particulate matter (PM/PM10).

3-HFB (Hogged Fuel Boiler): This boiler is a Wellons double cell furnace (fuel cell) boiler equipped with a

multiclone for PM control. It was installed in 1978. It is rated at 40,000 lbs steam/hr or 54 mmbtu/hr. It is also

equipped with a 20 mmbtu/hr natural gas burner in case wet hog fuel or insufficient hog fuel is available for steam

demand. Wood residue (i.e. bark, along with some shavings, chips, sawdust and hogged scrap lumber) generated

from on-site operations is burned in this boiler to generate steam for the wood drying kilns. Incidental quantities of

oil rags, oil booms/absorbents and oily debris from onsite activities are also permitted to be combusted in this boiler.

Emissions are carbon monoxide (CO), sulfur dioxide (SO2), oxides of nitrogen (NOx), VOCs, PM/PM10 and trace

HAPs.

4-NGB (Natural Gas Boiler): This boiler is a Cleaver Brooks boiler rated at 65,000 lbs steam/hr or 62 mmbtu/hr.

The boiler is fired primarily with natural gas, and has the ability to combust distillate oil (ASTM Grades 1 or 2) as

backup fuel in case of a NG curtailment. This boiler configuration supplements steam from the 3-HFB boiler based

upon kiln steam demand. Emissions are CO, SO2, NOx, VOCs, PM/PM10 and trace HAPs.

5-SM (Sawmill Operations): Logs received at the facility undergo a series of woodworking operations, which

compose this emissions unit, including debarking, saw cutting, chipping, and planing. Emissions from this unit are

primarily particulate matter in the form of fugitive wood dust (e.g., sawdust, wood shavings, and sanderdust)

generated as wood residue from woodworking operations. Depending on the woodworking operation, wood dust

may be pneumatically conveyed to a baghouse-controlled cyclone or primary baghouse. Captured wood dust is

either transported to market or burned in the hogged fuel boiler. The emissions from this emissions unit are

PM/PM10. Baghouse 1, (Chips), installed in March 1996, controls emissions from cyclones 1 and 7; baghouse 2,

(Bark Fines), installed April 1996, controls target box (previously considered cyclone 3); and baghouse 3,

(Shavings), installed January 1997, controls two indoor saw centers. Cyclones 2, 4, 5, and 6 have been removed.

6-FUG (Fugitive Emissions from Materials Handling and Transfer): This emissions unit consists of the following

particulate (PM and PM10) fugitive emissions activities and equipment:

a. Bark conveyor

b. Hogged fuel blow pipe to shed

c. Hogged fuel pile front end loader

d. Hogged fuel conveyors

e. Hogged fuel truck unloading

f. Chip conveyors - sawmill

g. Chip surge bins - sawmill

h. Chip shaker - sawmill

i. Planer conveyors

j. Planer chip system

k. Chip barge loading

l. Resaw return conveyor dropout - sawmill

m. Turning chain cleanup conveyor - sawmill

n. Gang/Opt. Board Edger conveyor - sawmill

o. Sawmill conveyors to truck bins - sawmill

p. Sawdust surge bins - sawmill

q. Chip truck loadout bins

r. Hogged fuel and bark truck loadout bins



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s. Sawdust truck loadout bins

t. Shavings truck loadout bins

7-VOC (Volatile Organic Compounds for Production Purposes): This emission unit is comprised of the VOC

fraction contained in the paints, coating and sealers used for production purposes, e.g., lumber stenciling and log

marking. The emissions from this emissions unit include a wide range of VOCs (HAP and non-HAP).

8-AGG (Aggregate Insignificant Emissions): A pressure washer is used to wash vehicles and equipment. This

device burns kerosene to produce pressurized steam from water. The emissions resulting from this emission unit are

TSP, PM10, NOX, SO2, CO, VOCs (non-HAP), and trace amounts of HAPs.

8. Categorically insignificant activities include the following:

Constituents of a chemical mixture present at less than 1% by weight of any chemical or compound

regulated under OAR Chapter 340, Divisions 200 through 268, excluding Divisions 248 and 262, or less

than 0.1% by weight of any carcinogen listed in the U.S. Department of Health and Human Service's

Annual Report on Carcinogens when usage of the chemical mixture is less than 100,000 pounds/year

Evaporative and tail pipe emissions from on-site motor vehicle operation

Distillate oil, kerosene, and gasoline fuel burning equipment rated at less than or equal to 0.4 million Btu/hr

Natural gas and propane burning equipment rated at less than or equal to 2.0 million Btu/hr

Office activities

Food service activities

Janitorial activities

Personal care activities

Groundskeeping activities including, but not limited to building painting and road and parking lot

maintenance

On-site laundry activities

On-site recreation facilities

Instrument calibration

Maintenance and repair shop

Automotive repair shops or storage garages

Air cooling or ventilating equipment not designed to remove air contaminants generated by or released

from associated equipment

Refrigeration systems with less than 50 pounds of charge of ozone depleting substances regulated under

Title VI, including pressure tanks used in refrigeration systems but excluding any combustion equipment

associated with such systems

Bench scale laboratory equipment and laboratory equipment used exclusively for chemical and physical

analysis, including associated vacuum producing devices but excluding research and development facilities

Temporary construction activities

Warehouse activities

Accidental fires

Air vents from air compressors

Air purification systems

Continuous emissions monitoring vent lines

Demineralized water tanks

Pre-treatment of municipal water, including use of deionized water purification systems

Electrical charging stations

Fire brigade training

Instrument air dryers and distribution

Process raw water filtration systems

Pharmaceutical packaging

Fire suppression

Blueprint making



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Routine maintenance, repair, and replacement such as anticipated activities most often associated with and

performed during regularly scheduled equipment outages to maintain a plant and its equipment in good

operating condition, including but not limited to steam cleaning, abrasive use, and woodworking

Electric motors

Storage tanks, reservoirs, transfer and lubricating equipment used for ASTM grade distillate or residual

fuels, lubricants, and hydraulic fluids

On-site storage tanks not subject to any New Source Performance Standards (NSPS), including

underground storage tanks (UST), storing gasoline or diesel used exclusively for fueling of the facility's

fleet of vehicles

Natural gas, propane, and liquefied petroleum gas (LPG) storage tanks and transfer equipment

Pressurized tanks containing gaseous compounds

Vacuum sheet stacker vents

Emissions from wastewater discharges to publicly owned treatment works (POTW) provided the source is

authorized to discharge to the POTW, not including on-site wastewater treatment and/or holding facilities

Log ponds

Storm water settling basins

Fire suppression and training

Paved roads and paved parking lots within an urban growth boundary

Hazardous air pollutant emissions of fugitive dust from paved and unpaved roads except for those sources

that have processes or activities that contribute to the deposition and entrainment of hazardous air

pollutants from surface soils

Health, safety, and emergency response activities

Emergency generators and pumps used only during loss of primary equipment or utility service due to

circumstances beyond the reasonable control of the owner or operator, or to address a power emergency as

determined by the Department

Non-contact steam vents and leaks and safety and relief valves for boiler steam distribution systems

Non-contact steam condensate flash tanks

Non-contact steam vents on condensate receivers, deaerators and similar equipment

Boiler blowdown tanks

Industrial cooling towers that do not use chromium-based water treatment chemicals

Ash piles maintained in a wetted condition and associated handling systems and activities

Oil/water separators in effluent treatment systems

Combustion source flame safety purging on startup

Broke beaters, pulp and repulping tanks, stock chests and pulp handling equipment, excluding thickening

equipment and repulpers

Stock cleaning and pressurized pulp washing, excluding open stock washing systems

White water storage tanks

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING

Emission Unit Applicable Requirement Pollutant,

Parameter

Limit/Standard

Facility Wide 340-208-0210(2) Fugitive emissions Minimize

340-208-0300 and 0450 Nuisance No nuisance and/or fallout

340-228-0110(1) #1 distillate oil sulfur

content 0.3% S by weight

340-228-0110(2) #2 distillate oil sulfur

content 0.5% S by weight

1-WH 340-208-0110(2) and (3) Visible emissions 20% opacity

2-KLN 340-208-0110(2) and (3) Visible emissions 20% opacity

3-HFB 340-208-0110(2) and (3) Visible emissions 20% opacity

340-228-0210(1)(b) PM 0.1 gr/dscf corrected to 12% CO2



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Emission Unit Applicable Requirement Pollutant,

Parameter

Limit/Standard

340-226-0120(1)(a) Fuels Wood (bark and lumber mill

residue), natural gas, and incidental

amounts of oil rags, oil

booms/absorbents, and oily debris

4-NGB 340-238-0060 and 40 CFR

Part 60 §60.43c( c)

Visible emissions 20% opacity six minute average

27% opacity one six minute period

per hour

340-208-0110(2) and (3) Visible emissions 20% opacity

340-228-0210(1)(b) PM 0.1 gr/dscf corrected to 12% CO2

340-238-0060 and 40 CFR

Part 60 §60.42c(c )

Sulfur content of oil

fuels

0.5 weight percent sulfur

5-SM 340-208-0110(2) and (3) Visible emissions 20% opacity

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

6-FUG 340-208-0110(2) and (3) Visible emissions 20% opacity

Insignificant

activities

340-208-0110 Visible emissions 20% opacity

340-228-0210(b) PM 0.1 gr/dscf (corrected to 12% CO2

for fuel burning equipment

340-226-0210 PM 0.1 gr/dscf

340-226-0310 PM Process weight limit for non-

fugitive, non-fuel burning

equipment

Plant site 340-222-0020 and 0041 PM, PM10, CO, NOX,

SO2, VOC

Annual plant site emission limits

9. Fugitive Emissions - Permit Condition 4: OAR 340-208-0210(2) is a requirement to take reasonable

precautions to minimize fugitive particulate emissions.

a. Testing Requirements: By definition, it is not possible to perform source emission tests on

fugitive emission sources. Therefore, the permit does not include any testing requirements or

compliance test methods.

b. Monitoring requirements - Permit Conditions 5, 16 and 23: Monitoring for this standard consists

of weekly inspections for the presence of fugitive emissions and documenting that reasonable

precautions are being taken to prevent fugitive emissions from occurring.

10. Nuisance - Permit Conditions 6, 7 and 8: These requirements prohibit nuisances (OAR 340-208-0300) and

particulate fallout (OAR 340-208-0450). These requirements are not part of the State Implementation Plan

(SIP) so they are only enforceable by the State. Nuisance conditions must be verified by the Department.

In order to determine whether a nuisance condition may exist, the permittee is required to keep a log of any

complaints (Permit Condition 8). The permittee is also required to respond to the complainant within a

reasonable amount of time and conduct an investigation as to whether any operations under their control

may have caused a nuisance condition.

11. Sulfur Content of Fuel Oil - Permit Conditions 9 and 21.c: OAR 340-228-0110 is a sulfur content limit for

distillate fuel. NSPS Subpart Dc, specifically 40 CFR 60.42c(g) limits sulfur content of any backup oil

combusted in emission unit 4-NGB (the natural gas boiler) to less than 0.5% sulfur by weight. The

permittee only burns distillate oil at the facility so the sulfur limits for other types of liquid fuels are not

included in the permit.

a. Testing Requirements: This is a statewide requirement that applies to fuel users as well as fuel

suppliers, so it should not be possible for the permittee to purchase any fuel containing more sulfur

than specified by the rule. Therefore, the permittee is not required to test the fuel, but they are

required to obtain a certificate from the supplier stating that the fuel meets the specifications. If



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they cannot get a certificate, then the permittee would have to analyze a sample of the fuel to show

that it meets the specifications.

b. Monitoring requirements - Permit Conditions 10 and 27: The permittee is required to maintain

records of the sulfur content of the fuel used at the facility, and the quantity combusted in

emission unit 4-NGB.

12. Fugitive road dust, storage piles and material handling requirements (emission units 1-WH and 6-FUG):

The visible emissions standards in OAR 340-208-0110(2) apply to this source of emissions, but the grain

loading standards in OAR 340-229-0210(1) do not apply because the emissions are fugitive.

a. Testing Requirements: Fugitive emission sources cannot be tested, so the permit does not require

any testing.

b. Monitoring Requirements; The Department is requiring a visible emissions survey once a week.

This monitoring consists of a weekly visual survey of the plant. If there are no visible emissions,

then nothing is required. However, if fugitive emissions are detected the permittee must apply

water as required in Condition 4 in the permit, or conduct a modified Method 9 reading within 24

hours, but in any case, take corrective action.

13. Kiln requirements (emission unit 2-KLN): Steam heated lumber drying kilns emit volatile organic

compounds and a small amount of particulate matter. There are no standards for VOC, other than the

PSEL, which is addressed separately. For particulate matter, the general visible emissions standards in

OAR 340-208-0110(2) apply, but the grain loading standards in OAR 340-229-0210(1), do not apply

because the emissions are fugitive.

a. Testing Requirements: Generally, kiln emissions are considered to be fugitive, and fugitive

emission sources cannot be tested, so the permit does not require any testing. However, pilot

study tests have shown that particulate matter emissions from kilns are considerably less than the

grain loading limits, so there is no real concern about compliance. In this case, there is no

evidence to suggest a compliance problem so the permittee is not being required to test the kilns.

b. Monitoring Requirements: The kilns do not have any add-on emission controls so the Compliance

Assurance Monitoring rules do not apply and the general periodic monitoring requirements of

OAR 340-218-0050(3) apply instead. There really is no way for an excess emission to occur, so

the Department is only requiring a visible emissions survey once each week, with the opportunity

to reduce frequency based upon previous, routine compliant readings. This monitoring consists of

surveying the units for visible emissions. If there are no visible emissions, then no further testing

is required. However, if visible emissions are observed for more than 18 seconds during the 6-

minute observation period, then a modified EPA Method 9 test is required to measure the visible

emissions.

14. Sawmill and planer operation requirements (emission unit 5-SM): The baghouses are subject to the 20%

opacity limit in OAR 340-208-0110(2) and the 0.1 gr/dscf emissions limit (OAR 340-226-0210(1)(b)).

a. Testing Requirements: Typically, baghouse emissions are less than the grain loading limits.

According to the Department‘s monitoring guidance, the Department does not require source

testing of equipment that emit less than 5 tons of particulate matter; unless there is a concern about

the compliance status of the equipment. In this case, there is no evidence to suggest a compliance

problem so the permittee is not being required to test the baghouses.

b. Monitoring Requirements: The general periodic monitoring requirements of OAR 340-218-

0050(3) apply instead. Excess emissions from baghouses are typically caused by plugging,

structural damage to the system (i.e., holes in the duct work or bag), or an improper size for the

type and amount of material being handled. As such, a routine inspection program can be useful

in preventing emissions and a routine visible emission survey can be used to verify that the

preventive maintenance is effective. Therefore, the permittee is being required to inspect the

baghouse at least once every other month and perform any necessary maintenance. In addition,



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the permittee is required to perform visible emissions monitoring survey once each week, with the

opportunity to reduce frequency based upon previous, routine compliant readings. This

monitoring consists of surveying the units for visible emissions. If there are no visible emissions,

then no further testing is required. However, if visible emissions are observed for more than 18

seconds during the 6-minute observation period, then a modified EPA Method 9 test is required to

measure the visible emissions.

15. Hog-fueled Boiler requirements (emission unit 3-HFB): The applicable requirements are OAR 340-208-

0110(2) and 340-208-0110(3)(a) (20% opacity). The grain loading standard for this boiler is 0.1 gr/dscf at

12% CO2 (340-228-0210(1)(b)).

a. Testing Requirements: This permit renewal requires a source test of this boiler for particulate

matter for compliance and emission factor verification purposes. This compliance testing is

required in the first and fifth year of the permit term. Increased testing frequency is being

required, as past testing has indicated a need to limit steaming rate in order to maintain compliance

with the grain loading standard. Testing is also required for NOx, CO and VOC for emission

factor verification purposes once during the permit term.

b. Monitoring Requirements: The permittee is required to perform visible emissions monitoring

survey once each week using modified EPA Method 9, with the opportunity to reduce frequency

based upon previous, routine compliant readings. If there are no visible emissions, then no further

testing or actions are required. However, if visible emissions are observed for more than 18

seconds during the 6-minute observation period, then corrective actions to correct the problem

causing the opacity exceedance are required. The permittee will monitor boiler residual oxygen

and multiclone pressure drop. Furnace O2 will be monitored/displayed per minute and hourly

averages recorded. Corrective action will be taken as soon as possible when the boilers O2 are

operating outside the allowable operating range of 4 to 15 %. Furnace O2 monitoring ensures that

the boilers are operating within a combustion range which promotes good combustion and

minimizes the inlet loading on the multiclone. The multiclone must be inspected annually and

necessary repairs made.

16. Natural Gas Boiler requirements (emission unit 4-NGB): The applicable state requirements are OAR 340-

208-0110(2) and 340-208-0110(3)(a) (20% opacity). The grain loading standard for this boiler is 0.1

gr/dscf at 12% CO2 (340-228-0210(1)(b)). This boiler is subject to the NSPS Subpart Dc regulations,

which include an opacity limit of 20 % opacity (6-minute average), except for one 6-minute period per hour

of not more than 27 % opacity, [40CFR60.43c(c)]. The NSPS also requires a limit on sulfur content of

distillate fuel oil of less than 0.5% by weight. [40CFR60.42c(d)].

a. Testing Requirements: This permit renewal requires a source test of this boiler for particulate

matter for compliance and emission factor verification purposes if the boiler operates on oil

greater than 5% of the operating time annually. If operated only on natural gas or operated with

fuel oil less than 5% of the annual operating time, no PM testing is required. Testing is also

required for NOx and CO for emission factor verification purposes once during the permit term.

b. Monitoring Requirements: The permittee is required to perform visible emissions monitoring

survey once each week using modified EPA Method 9 if this boiler operates on ASTM Grade 1 or

2 fuel oil, with the opportunity to reduce frequency based upon previous, routine compliant

readings for the state opacity requirements. The permittee is required to conduct annual 3-hour

Method 9 tests while operating on oil, with the possibility of more frequent tests based upon

previous readings for the NSPS requirements. The permittee is also required to obtain supplier

certifications for sulfur content in the fuel oil per 40CFR60.42c(h)(1) and 40CFR60.48c(f).

17. National Emission Standards for Hazardous Air Pollutants (NESHAP) – this facility is classified as a major

source of HAPs .

a. 40 CFR Part 63 Subpart DDDD, Plywood and Composite Wood Products, does apply because the

facility is an affected source, i.e. ―lumber kilns located at any facility‖, (40CFR63.2231(a)), and is



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Revised 5/19/04

a major HAP source (40CFR63.2231(b)), however none of the standards apply to the dry kilns (2-

KLN). Weyerhaeuser did submit an initial notification on January 13, 2005, per the requirements

in §63.9(b),

b. 40 CFR Part 63 Subpart DDDDD, Industrial, Commercial and Institutional Boilers and Process

Heaters, will apply to the facility. It is anticipated that this rule will be promulgated by the EPA

during the permit term, and will be incorporated by appropriate permitting methods upon

applicability.

18. As identified earlier in this Review Report, this facility has insignificant emissions units (IEUs) that include

categorically insignificant activities and aggregate insignificant emissions, as defined in OAR 340-200-

0020. For the most part, the standards that apply to IEUs are for opacity (20% limit) and particulate matter

(0.1 gr/dscf limit). The Department does not consider it likely that IEUs could exceed an applicable

emissions limit or standard because IEUs are generally equipment or activities that do not have any

emission controls (e.g., small natural gas fired space heaters) and do not typically have visible emissions.

Since there are no controls, no visible emissions, and the emissions are less than one ton per year, the

Department does not believe that monitoring, recordkeeping, or reporting is necessary for assuring

compliance with the standards.

PLANT SITE EMISSION LIMITS

19. Provided below is a summary of the baseline emissions rate, netting basis, plant site emission limits, and

emissions capacity.

Pollutant

Baseline

Emission

Rate

(tons/yr)

Netting Basis

Plant Site Emission Limit (PSEL)

Previous

PSEL

(tons/yr)

Proposed

PSEL

(tons/yr)

PSEL

Increase

(tons/yr)

Previous

(tons/yr)

Proposed

(tons/yr)

PM 195 174 195 167 195 28

PM10 153 132 153 121 153 32

CO 59 59 59 134 134 0

NOx 44 44 44 114 114 0

SO2 3 3 3 39 39 0

VOC 28 78 78 111 111 0

a. The baseline emission rate was updated to reflect changes in emission factors, and not baseline

production rates from 1978. This update was done under the previous permit renewal issued in

2004, under application number 017015, as well as this permit renewal. The emission factor for

PM/PM10 for the hog fueled boiler was corrected to reflect actual emissions, and this increases

both PM and PM10 by 20.9 tons/yr. The baseline year emissions are detailed by emission unit in

item 20, below.

b. The netting basis was changed consistent with the changes to the baseline emission rate. There are

no reductions required by rule, reductions in unassigned emissions or emission reduction credits

transferred off site that would cause a reduction in the netting basis as compared to the baseline

emission rate. The only increase approved under New Source Review was for VOC and so that is

the only pollutant for which the netting basis was increased as compared to the baseline emission

rate. Therefore, the baseline emission rate and netting basis are equal for all pollutants other than

VOC.

c. The PSEL increases are a result of correction to emission factors for PM and PM10 for the Hog

Fueled Boiler, Emission Unit 3-HFB, and include these increases plus previous unassigned

emissions, as detailed below:

Pollutant Previous

Unassigned

Increase due to

EF correction

Total Increase

PM 7 21 28

PM10 11 21 32



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Revised 5/19/04

This is a change to the PSEL solely due to the availability of better emission information, and is

exempt from being considered an increase. These emission increases are due solely to increased

use of equipment that existed during the baseline period, and the increased use was possible

during the baseline period under the baseline configuration. The increase is not due to a physical

change or change in operation. [OAR 340-200-0020(66)(b)(B)]. See the plant site emission

detail sheets for basis.

20. The baseline year emissions have changed to reflect corrected emission factors and changes for this

renewal are bolded. These changes are explained in detail in the Baseline Emissions Detail Sheet, May

2009 Revision, attached:

Emission Unit PM PM10 SO2 NOx CO VOC

1-WH 16.1 6.0 NA NA NA NA

2-KLN 0.5 0.5 NA NA NA 10.4

3-HFB 67.3 67.3 1.6 42.9 58 15.1

4-NGB* NA NA NA NA NA NA

5-SM 62.3 46.7 NA NA NA NA

6-FUG 47.4 31.4 NA NA NA NA

7-VOC NA NA NA NA NA 1

8-AGG 1 1 1 1 1 1

Total 195 153 3 44 59 28

* 4-NGB did not exist at baseline

SIGNIFICANT EMISSION RATE

21. The proposed PSEL is not greater than the previous netting basis as shown below.

Pollutant SER

Requested increase over

netting basis

Increase due to utilizing

capacity that existed in the

baseline period

Increase due to physical changes

or changes in the method of

operation

PM 25 0 28 0

PM10 15 0 32 0

CO 100 751 30 45

NOx 40 701 22 48

SO2 40 36 Generic PSEL

OAR 340-222-0040

Generic PSEL

OAR 340-222-0040

VOC 40 331 23 10

1These values previously were part of an ambient air quality analysis approved by the Department on June 30, 2004.

See permit file for details.

HAZARDOUS AIR POLLUTANTS

HAP EMISSION UNIT TOTAL

2-KLN 3-HFB 4-NGB CHEMICALS

Acetaldehyde 22.43 0.37 0 0 22.79

Acrolein 0.31 1.63 0 0 1.94

Arsenic 0 0.004 7.5E-05 0 0.004

Benzene 0 1.19 7.9E-04 0 1.19

Beryllium 0 3.1E-04 4.5E-06 0 3.2E-04

Bis-phthalate 0 1.3E-05 0 0 1.3E-05

Cadmium 0 1.9E-03 4.1E-04 0 2.3E-03

Carbon tetrachloride 0 0.013 0 0 0.013



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Revised 5/19/04

HAP EMISSION UNIT TOTAL

2-KLN 3-HFB 4-NGB CHEMICALS

Chlorine 0 0.22 0 0 0.22

Chlorobenzene 0 0.009 0 0 0.009

Chloroform 0 0.008 0 0 0.008

Chromium, total 0 0.012 5.3E-04 0 0.013

Cobalt 0 1.8E-03 3.16E-05 0 0.0019

Dichlorobenzene 0 0 4.5E-04 0 4.5E-04

2,4-Dinitrophenal 0 5.1E-05 0 0 5.1E-05

Ethyl benzene 0 0.009 3.6E-03 0.016 0.029

Formaldehyde 2.24 1.25 0.0282 0 3.52

Hexane 0 0 0.678 0 0.678

Hydrogen chloride 0 0.22 0 0 0.22

Lead 0 0.02 1.9E-04 0 0.02

Manganese 0 2.102 1.43E-04 0 2.103

Mercury 0 8.2E-04 9.8E-05 0 9.2E-04

Methanol 36.23 0.36 0 0.34 36.93

Methyl isobutyl ketone 0 0 0 0.03 0.03

Naphthalene 0 0.027 2.3E-04 0 0.028

Nickel 0 0.0169 7.9E-04 0 0.0177

4-nitrophenol 0 3.1E-05 0 0 3.1E-05

Pentachlorophenol 0 1.4E-05 0 0 1.4E-05

Phenol 0 0.022 0 0 0.022

Polycyclic organic matter 0 5.7E-03 3.4E-05 0 0.006

Propionaldehyde 0.16 0.017 0 0 0.173

Selenium 0 1.3E-03 9.0E-06 0 0.0013

Styrene 0 0.53 0 0 0.53

TCDB-p-dioxin 0 1.3E-07 0 0 1.3E-07

Toluene 0 7.0E-04 1.4E-03 0.15 0.16

Vinyl chloride 0 0 5.1E-03 0 5.1E-03

Xylene 0 0 0.01 0.09 0.1

o-xylene 0 0.007 0 0 0.007

Total 61.37 8.05 0.754 0.626 70.8

GENERAL BACKGROUND INFORMATION

22. Air quality in the Warrenton area meets the National Ambient Air Quality Standards (NAAQS) established

by the US Environmental Protection Agency (EPA) to protect public health. DEQ has determined that the

air emissions from the Weyerhaeuser mill will not result in a violation of those standards.

COMPLIANCE HISTORY

23. There have been no enforcement actions against this permittee since issuance of the current permit on

September 9, 2004.



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Revised 5/19/04

SOURCE TEST RESULTS

Summarized below are the results of source testing performed during the last permit term:

24. Source Test Summary for the hogged-fuel boiler (3-HFB):

Pollutant/Operating

Parameter

Average Test Values

Test Date July 21, 2004

(Horizon

Engineering)

October 27,

2005

(Horizon

Engineering)

June 1, 2006

(Horizon

Engineering)

June 2, 2006

(Horizon

Engineering)

August 3, 2006

(Horizon

Engineering)

Steam production

rate, lb/hr

36,300 33,000 45,200 39,100 37,800

PM, gr/dscf @ 12%

CO2

0.14 (limit

0.1)

Not tested 0.18 (limit 0.1) 0.20 (limit 0.1) 0.13 (limit 0.1)

PM, lb/Mlb steam 0.45 (permit

EF 0.3)

Not tested 0.51 (permit

EF 0.4)

0.57 (permit

EF 0.4)

0.41 (permit EF

0.4)

Opacity, % 15.4 Not tested Not tested Not tested 7

NOx, lb/Mlb steam 0.32 (permit

EF 0.31)

Not tested Not tested Not tested Not tested

CO, lb/Mlb steam 0.49 (permit

EF 1.0)


VOC as CH4, lb/Mlb

steam

VOC total not

tested

H2CO - 0.017

lbs/hr


Antimony,

lbs/mmbtu

Not tested 2.7E-06 Not tested Not tested Not tested

Arsenic, lbs/mmbtu Not tested 8.0E-06 Not tested Not tested Not tested

Barium, lbs/mmbtu Not tested 5.2E-05 Not tested Not tested Not tested

Beryllium,

lbs/mmbtu


Cadmium,

lbs/mmbtu


Chromium,

lbs/mmbtu


Cobalt, lbs/mmbtu Not tested 5.9E-06 Not tested Not tested Not tested

Copper, lbs/mmbtu Not tested 9.4E-05 Not tested Not tested Not tested

Lead, lbs/mmbtu Not tested 4.0E-05 Not tested Not tested Not tested

Manganese,

lbs/mmbtu

Not tested 3.1E-03 3.8E-03 Same as 6/1/06 Not tested

Nickel, lbs/mmbtu Not tested 8.4E-06 Not tested Not tested Not tested

Phosphorus,

lbs/mmbtu


Selenium, lbs/mmbtu Not tested 4.7E-06 Not tested Not tested Not tested

Silver, lbs/mmbtu Not tested 3.4E-07 Not tested Not tested Not tested

Thallium, lbs/mmbtu Not tested 1.6E-06 Not tested Not tested Not tested

Zinc, lbs/mmbtu Not tested 5.7E-04 Not tested Not tested Not tested



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Revised 5/19/04

25. Source Test Summary for the natural gas boiler (4-NGB)

Pollutant/Operating

Parameter

Average Test Values

Test Date July 22, 2004

(Horizon Engineering)

December 9, 2004

(Horizon Engineering)

Steam production rate, lb/hr 60,500 60,000

NOx, lb/1000 lb steam 0.12 (permit EF 0.206) 0.131(permit EF 0.206)

CO, lb/1000 lb steam 1.12 *(permit EF 0.187) 0.047 (permit EF 0.2)

*The CO emission factor from the July 2004 test was significantly above the emission factor assumed by the permit.

Weyerhaeuser chose to readjust their boiler and retest, which occurred in Dec. 2004. The follow up test showed that

CO emissions were significantly reduced to approximately 20% of the permitted emission factor. Weyerhaeuser

installed a combustion control system on this boiler to ensure that excess oxygen remains close to necessary levels and

CO levels remain below permitted levels and the emission factor.

PUBLIC NOTICE

26. This permit was put out on public notice from May 8, 2009 to June 15, 2009. The only comments that

were received were from Weyerhaeuser NR, and are included in item 28, below. The Department‘s

responses to the company‘s comments are included in item 29, below. The Department requested an

expedited review of 5 day, as there were no substantive or adverse comments during the comment period.

27. A letter from EPA was received June 25, 2009, granting the permit eligibility for issuance.

If the EPA does not object in writing, any person may petition the EPA within 60 days after the expiration

of EPA's 45-day (or 5-day, if granted) review period to make such objection. Any such petition must be

based only on objections to the permit that were raised with reasonable specificity during the public

comment period provided for in OAR 340-218-0210, unless the petitioner demonstrates that it was

impracticable to raise such objections within such period, or unless the grounds for such objection arose

after such period.

28. Weyerhaeuser NR submitted the following comments on the draft permit and review report:

1. Condition 19.c.ii requires that the mill take ―immediate‖ corrective action. Immediate is defined as no

longer than 1 hour. Unless we are misreading the rules, the actually word used in the rules is

―expeditious‖. If you concur, we propose changing ―immediate‖ to ―expeditious‖ for this condition.

2. Condition 19.c.iii does not make complete sense as it seems that the second sentence requires the operator

to average the values recorded, but the condition only requires that one value per shift be recorded. We

think this language would be clearer: ―Excess oxygen must be recorded at least once per shift, at the end of

each shift (e.g., every eight hours). All values recorded during a shift must be averaged to compare against

the action level.‖

3. As an unfortunate sign of the times, we propose that you consider adding a new condition 20.d: ―In the

event the boiler has not operated more than 4,000 hours in the year that testing is due, the source test can be

deferred to the next calendar year in which the boiler operates for more than 1,440 hours. The subsequent

source test would then be due two years after the deferred source test.‖

4. We propose a change to Condition 29 as follows to include the underlined language: ―Emission fees will

be based on Plant Site Emission Limits, unless the permittee elects to report actual emissions for one or

more permitted processes/pollutants or the permittee qualifies for a reduced activity fee payment alternative

under OAR 340-220-0070. If the permittee reports actual emissions or pays reduced fees under OAR 340-

220-0070 for one or more permitted processes/pollutants…‖

5. We propose a change to Condition 39.e as follows to include the underlined language: ―The permittee

must notify the Department of excess emissions resulting from planned startup/shutdown or scheduled

maintenance events in accordance with Condition 39.a.‖



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Revised 5/19/04

6. Condition 43.b.iv requires an ―unplanned excess emissions event record‖, but condition 39.f says that you

need a brief summary of all excess emissions. We think that 39.f accurately captures the current

requirement and 43.b.iv should be revised to read: ―the excess emissions event summary.‖

7. Based on some research we did we believe that Condition 44.b contains language from an old version of

the permit template that Mark Fisher has acknowledged misstates the requirements. Here is the language

Mark has agreed should be used:

The identification of the method(s) or other means used by the owner or operator for determining the compliance

status with each term and condition during the certification period, and whether such methods or other means

provide continuous or intermittent data. Such methods and other means shall include, at a minimum, the methods

and means required under OAR 340-218-0050(3). ). Note: Certification of compliance with the monitoring

conditions in the permit is sufficient to meet this requirement, except when the permittee must certify compliance

with new applicable conditions that are incorporated by reference. When certifying compliance with new

applicable conditions that are incorporated by reference, the permittee must provide the information required by

this condition. If necessary, the owner or operator also shall identify any other material information that must be

included in the certification to comply with section 113(c)(2) of the FCAA, which prohibits knowingly making a

false certification or omitting material information;

8. Condition 45.b requires that the NSPS reports be submitted on January 30th and July 30th. The NSPS

rules allow DEQ the authority to set those submittals to be due the same date as the semi-annual Title V

reports—an approach that is much less prone to failure. We hope this would be acceptable to you.

9. As you will recall, we have a conversation about baseline and netting basis and as I recall we both were a

bit confused on the best way to handle the changes from the HFB EF update. We ask Tom Wood to review

this and he felt we definitely needed to make some changes. We are providing a redlined version of the RR

to address this issue.

29. The Department‘s responses to Weyerhaeuser‘s comments are below in corresponding order and number:

1. Condition 19.c.i. and 19.c.ii.: The rule referenced in this condition(OAR 340-226-0120(2)(a)(A))

requires ―corrective action as expeditiously as practical….‖. Therefore, the references to

‗immediate‖ are changed to ―expeditious‖; both in sub-conditions 19.c.i. and 19.c.ii., in

accordance with the rule referenced by this condition.

2. Condition 19.c.iii.: The original condition 19.c.iii. was deleted, as the hog-fueled boiler (3-HFB)

has a continuous chart recorder for excess oxygen, and the condition required recording readings

at least once per shift. However, as a result of this comment, condition 21.c.i., for the natural gas

boiler (4-NGB), was modified to clarify the language for recording oxygen readings at least once

per shift.

3. Condition 20: The PM compliance source testing requirement for the hog-fueled boiler (3-HFB)

was changed from first, third, fifth years to the first and fifth year of the permit term, rather than

tie the testing to hours of operation, as was requested by the company. Two tests per permit term

are sufficient to demonstrate compliance with the grain loading and opacity standards for this

boiler.

4. Condition 29: Added reference to reduced activity fee alternatives granted by rule for permit

emission fee payment.

5. Condition 39.e.: Added clarifying language that the Department must be notified of planned

startup/shutdown or scheduled maintenance events only if those events result in excess emissions.

6. Condition 43.b.iv.: Clarified the requirement for annual report submittals regarding unplanned

excess emissions events is only a summary, as required and explained in condition 39.f., rather

than an ―event record‖.

7. Condition 44.b.: The permit template language has been revised to reflect the changes noted by

the company in their comments, and these language changes have been incorporated into this

condition, and better reflect the requirements of determining compliance status with each term and

condition in the permit.

8. Condition 45.b.: The company‘s semi-annual compliance certification is due on August 15th

each

year, and their annual report is due on March 15th

every year. The company is subject to New



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Revised 5/19/04

Source Performance Standard, Subpart Dc for their natural gas boiler (4-NGB), and this NSPS

requires semi-annual reports that must be postmarked on the 30th

day following the reporting

periods, which are Jan. 1 – June 30, and July 1 – Dec. 31., making the submission dates July 30th

and Jan 30th

, respectively. The NSPS General Provisions, Subpart A, in section 60.19(d), allows

DEQ to change the dates by which periodic NSPS reports are submitted, (without changing the

frequency of reporting) to be consistent with DEQ‘s reporting schedule by mutual agreement

between the company and the DEQ. This request is permitted.

9. Review Report item 19.b.: The Netting Basis was changed consistent with the changes to the

baseline emission rate. There are no reductions required by rule, reductions in unassigned

emissions or emission reduction credits transferred off site that would cause a reduction in the

netting basis as compared to the baseline emission rate. The only increase approved under New

Source Review was for VOC and so that is the only pollutant for which the netting basis was

increases as compared to the baseline emission rate. Therefore, the baseline emission rate and

netting basis are equal for all pollutants other than VOC.

EMISSION DETAIL SHEETS

See Plant Site Emission Detail Sheets and Baseline Emission Detail Sheets.



Page 1 of 2

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

OREGON TITLE V OPERATING PERMIT

REVIEW REPORT

ADDENDUM NO. 1

ADMINISTRATIVE AMENDMENT

Northwest Region

2020 SW Fourth Avenue, Suite 400

Portland, OR 97201

Mailing Address Plant Site Address

Hampton Lumber Mills, Inc. Hampton Warrenton Lumber Mill

9600 SW Barnes Road, Suite 200 550 NE Skipanon Drive

Portland, OR 97225 Warrenton, OR 97146

Source Information:

SIC 2421, 4961 Source Categories (Part and code) B.64

NAICS 321113,

321912,

221330

Compliance and Emissions

Monitoring Requirements:

Unassigned emissions COMS X

Emission credits CEMS

Compliance schedule Ambient monitoring

Source test X

Reporting Requirements:

Annual report (due date) 3/15 Monthly report (due dates)

Emission fee report (due date) 3/15 Excess emissions report X

SACC (due date) 7/30 Other reports X

Quarterly report (due dates)

Air Programs:

NSPS (list subparts) Dc Title V X

NESHAP (list subparts) DDDD ACDP (SIP)

CAM Major HAP source X

Regional Haze (RH) Federal major source X

Synthetic Minor (SM) NSR

Part 68 Risk Management PSD

CFC Acid Rain

RACT Clean Air Mercury Rule (CAMR)

TACT



Page 2 of 2

PERMIT MODIFICATION REQUEST:

1. On February 4, 2010, Weyerhaeuser NR Company submitted an Administrative

Amendment (MD904), which is assigned Application No. 23977, requesting a change of

ownership for the Warrenton Sawmill from Weyerhaeuser NR Company (Weyerhaeuser)

to Hampton Lumber Mills, Inc. (Hampton).

DEPARTMENT EVALUATION:

2. Per OAR 340-218-0150(1)(d), an administrative amendment is a permit revision that

allows for a change in the ownership or operational control of a source where the

Department determines that no other change in the permit is necessary, provided that a

written agreement containing a specific date for transfer of permit responsibility,

coverage, and liability between the current and new permittee has been submitted to the

Department. By execution of a letter dated January 27, 2010, Hampton and

Weyerhaeuser agreed that Hampton has assumed coverage, responsibility and liability for

the Title V Permit 04-0041, as issued by the Department and signed on June 26, 2009.

Hampton indicated in this letter that they are not proposing to make changes to the

operation of the Warrenton Mill, therefore no changes have been made to the permit

other than the cover page indicating the new ownership.

PUBLIC NOTICE

3. Public Notice is not required for administrative amendments to Oregon Title V Operating

Permits.

oregon title v operating permit review report title v operating permit review report ......

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