OREGON DEPARTMENT OF ENVIRONMENTAL … · OREGON TITLE V OPERATING PERMIT Northwest Region ... SERP...

Issued Permit Number: 26-2777-TV-01Expiration Date: 01/02/2023

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^y.

DEQStete of OregonDepartment ofEnvironmentalQuality

OREGON DEPARTMENT OF ENVIRONMENTAL QUALITYOREGON TITLE V OPERATING PERMIT

Northwest Region700 NE Multnomah St., Suite 600

Portland, OR 97232

Issued in accordance with the provisions of ORS 468A.040and based on the land use compatibility fmdings mcluded in the permit record.

ISSUED TO:

Graphic Packaging International, Inc.P.O. Box 17128Portland, OR 97217-0128

^FORMATION RELIED UPON:

Application Number:

Received:

02732705/13/2013

PLANT SITE LOCATION:

3400 North Marine DrivePortland, OR 97208

LAND USE COMPATIBILITY STATEMENT:

From: City of PortlandDated: 04/11/1991

ISSUED BY THE DEPARTMENT OF ENVIRONMENTAL QUALITY

Keith Johnson^-^ichael R Orman, P.E., Northwest Region AQ Manager

Nature of Business:

Flexible Packaging/Coated Products

SIC2671

NAICS323111

RESPONSIBLE OFFICIAL

Title: Facility Manager

FACILITY CONTACT PERSON

Name: Nathan. PhelanTitle: Environmental ManagerPhone: 503-286-1690

Issued Pennit Number: 26-2777-TV-01Expiration Date: 01/02/2023

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TABLE OF CONTENTS

LIST OF ABBREVIATIONS THAT MAY BE USED FN THIS PERMIT.....................-.........................................^

PERMITTED ACTIVITIES...............,..........................................................................................................................^

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

EMISSION LIMITS AND STANDARDS ...................................................................................................................5

PLANT SITE ENflSSION LIMITS........................................................................................................................... 10

EMISSION FEES................................................................................................................................

TESTING REQUIREMENTS..................................................................................................................................

MONITORmG REQUIREMENTS............................................................................................................................11

RECORDKEEPINGREQUIREMENTS...............................................................................................................^

NON-APPLICABLE REQUIREMENTS...................................................................................................................24

GE^ffiRAL CONDITIONS.....................................................................................................................................


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LIST OF ABBREVIATIONS THAT MAY BE USED IN TfflS PERMIT

ACDP Air Contaminant Discharge PermitacJ&n actual cubic foot per minuteAQMA Air quality management areaASTM American Society of Testing and

MaterialsBtu British thermal unitCFR Code of federal regulationsC02 Carbon dioxideCO Carbon monoxideCPMS Continuous parameter monitoring

systemDEQ/ODEQ Oregon Department of

Environmental Qualitydscf dry standard cubic footEF emission factorEPA US Environmental Protection

AgencyEU Emissions unitPCAA Federal Clean Air Actft3 cubic feetGHG greenhouse gasgr/dscf gram per dry standard cubic footHAP Hazardous Air Pollutant as defined

by OAR 340-244-0040HCFC Halogenated Chloro-Fluoro-

CarbonsID Identification numberI&M Inspection and maintenanceLPG Liquefied petroleum gasMACT IVIaxmium Achievable Control

TechnologyMB Material balancemg/1 milligrams per literMiunit Thousand units, unit = {Ibs, Btu,

ft3, etc.)MM^unit Million units, unit - {Ibs, Btu, ft3,

etc.)Mgal Thousand gallons

MMBtuMMscfNGNOx02OARORSO&MPbPCDPMPMio

PM2.5

ppmppmvPSELpsiapsigPACT

RICE

RTOscfSDSSERSERPSIPSNAPS02STULSDVEVMTvoc

unitsMillion standard cubic feetNatural gasOxides of nitrogenOxygenOregon Administrative RulesOregon Revised StatutesOperation and maintenanceLeadPollution control deviceParticulate matterPartlculate mater less than 10microns m sizeParticulate matter less than 2.5microns m sizePart per miUionPart per million by volumePlant Site Emission Limitpounds per square inch, absolutepounds per square inch, gaugeReasonably Available ControlTedmologyReciprocating Internal CombustionEngineRegenerative Thermal OxidizerStandard cubic footSafety Data SheetSignificant Emission RateSource Emission Reduction PlanState Implementation PlanSignificant New Alternative PolicySulfur dioxideSource testUltra-low sulfur dleselVisible emissionsVehicle miles traveledVolatile organic compound


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PERMITTED ACTIVITIES

1. Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge aircontaminants from those processes and activities directly related to or associated with air contaminantsource(s) m accordance with the requirements, limitations, and conditions of this permit. [OAR 340-218-0010 and 340-218-0120(2)]

2. All conditions in this permit are federally enforceable, meaning that they are enforceable by DEQ, EPA,and citizens under the Clean Air Act, except Conditions, 7, 8, 35, G5, and G9 (OAR 340-248-0005 through340-248-0180) are only enforceable by the state. [OAR 340-218-0060]

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)]:

4.

Emissions Unit Description

Flexographic prmtmg activities

Extrusion process

All VOC emitting activities including FLEXO, EXTR,but excluding fuel burning equipment

Paper coater

Two Kewanee Boilers, each with a rated capacity of8.37xl06 Btu/hr, natural gas fired

Dryers, Space heaters, and RTO with a combinedcapacity of 45.32 x 106 Btu/hr, natural gas fired

Emergency Generator (RICE)

All paper trimmers and slitters

EUIDFLEXO

EXTR

EUvoc

PCBOILERS

DRYERS

RICETRIMS

PoUution Control Device

Regenerative ThermalOxidizer (RTO)

PCDEXTR - Coalescing Filteron # 2 and #3 Extruder

RTO on FLEXO

None

None

None

None

Cyclone (CYC)

The permittee is allowed to instaU and/or modify the emissions unit and pollution control device identifiedbelow: [OAR 340-218-0190 and 340-210-0240]

EUIDTRIMS

PCDIDBH

Description of Modification/ConstructioD.Installation ofBaghouse to control PM/PMio emissions from the paper trimmingoperations

4.a. Thepermittee shall notify the department within 30 days of completing the installation of the BHidentified above.

4.b. The notice shall include:4.b.i. the date of completion of modification or construction;4.b.ii. the date the device was or will be put into operation; and4.b.iii. the Notice of Completion form pursuant to OAR 340-210-0240(3).


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EMISSION LIMITS AND STANDARDS

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

Facility-Wide Requirements

ApplicableRequirement

340-208-0210(1)

340-206-0050

340-208-0300

340-208-0450

40 CFR Part68

ConditionNumber

5

6

7

8

9

Pollutant/Parameter

Fugitive emissions

Alert, Warning orEmergency

Air contaminants

PM >250^

Risk management

Limit/Standard

Minimize

SERP

No nuisance

No fallout

Risk managementplan

Monitoring Requirement

Fugitive Dust Control Plan

VE periodic Monitoring

Complaint investigation

Recordkeeping



NA

MomtormgCondition

33

3534

35

35

NA

5. The permittee must not aUow or permit any materials to be handled, transported, or stored; or a building, itsappurtenances, or a road to be used, constructed, altered, repaired or demolished; or any equipment to beoperated, without taking reasonable precautions to prevent particulate matter from becoming airborne.[OAR 340-208-0210(1)]5.a. Such reasonable precautions include, but are not be limited to the following: [OAR 340-208-

0210(1)]5.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 theclearing of land;

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

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

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

5.a.v. Adequate containment during sandblasting or other similar operations; and5.a.vi. Covering, at all times when in motion, open bodied trucks transporting materials likely to

become airborne.

5,a.vii. Prompt removal jfrom paved streets of earth or other material that does or may becomeairborne.


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6. In the event an Air Pollution Alert, Warning, or Emergency Episode is declared in the Portland area byDEQ, the permittee must take the action appropriate to the episode condition as described in the SourceReduction Plan (SERP) on file with DEQ. If no SERP is on file, the permittee must follow the actionsspecified in OAR Chapter 340, Division 206. The permittee must take such action when the permittee firstbecomes aware of such a declaration whether through news media, direct contact with DEQ, or from othersources. [OAR 340-206-0050]

Nuisance Conditions

7. The permittee must not cause or allow air contaminants from any source to cause a nuisance. Nuisanceconditions will be verified by DEQ personnel. [OAR 340-208-0300] This condition is enforceable only bythe State.

8. The permittee must not cause or permit the emission of any particulate matter larger than 250 microns msize at sufficient duration or quantity, as to create an observable deposition upon the real property ofanother person. [OAR 340-208-0450] This condition is enforceable only by the State.

Accidental Release Prevention

9. Should this stationary source become subject to the accidental release prevention regulations in 40 CFRPart 68, then the permittee must submit a risk management plan (RMP) by the date specified in 40 CFR68.10 and comply with the plan and all other applicable Part 68 requirements. [40 CFR Part 68]

Emissions Unit Specific Limits and Standards

EU/PCD ID

BOILER &DRYERS

BOILER

BOILER

TRIMS &EXTRTRIMS &EXTRFLEXO/RTO

PAPERCOATER

Applicable Requirements

OAR

340-208-0110(2)340-208-0110(4)

340-228-0210(2)(b)

340-228-0200

n/a

340-208-0110(2)340-208-0110(4)

340-226-0210(2)(b)

340-232-0230

340-208-0550340-232-0230(1 )(c)(B)340-232-0160

ConditionNumber

10

11

12

13

14

16

17

18

19

Pollutant/

Parameter

visibleemissions

PM/PM;o

S02

Not subject toarea sourceboiler MACT,subpart JJJJJFJ

visibleemissions

PM/PMio

voc

Odor, 60%VOC Contr.

voc

Limit/

Standard

<20%0pacity

O.Mgr/dscf

Use only natural gas andno. 2 fuel oil, max 0.5% S

Use only natural gas exceptduring gas curtailment, gassupply interruption,startups, or periodic testingon liquid fael

< 20% Opacity

0,14gr/dscf

complying coating or 60%control

1400°F & 0.5 sec. 90%control

2.9 Ib/ga!

Monitoring Requirements

Method

VE periodicmonitoring


%S analysis &Recordkeepmg

Recordkeeping

VE periodicmonitormg


ST and MB-Recordkeeping

Temp. monitor

Recordkeeping

ConditionNumber

37

37

44

36

38,39

38,39

29,40, 41

40

42


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BOILERS/DRYERS

10. The permittee limit visible emission limits from emissions units BOILER and DRYER, constmcted after1970to less than 20 percent opacify. Monitor in accordance with Condition 37 [OAR 340-208-0110(4)]

U. The permittee may not emit partlculate matter from any discharge stack of emissions unit BOILER orDR.YER in excess of 0.14 grain per standard cubic foot, corrected to 12% COi or 50% excess air. Monitorin accordance with Condition 37. [OAR 340-228-0210(2)(b)(B)]

12. The permittee must bum only natural gas and no. 2 fuel oil in BOILERS. No. 2 fuel oil may not exceed asulfur content of 0.5 percent by weight. [OAR 340-228-0200]

Monitor in accordance with Condition 44.

13. The pennittee must operate BOILERS on natural gas at all times, except that BOILERS may be operatedon liquid fuel only as follows: [Not subject to area source Boiler MACT subpart JJJJJJ, per 40 CFR63.11195(e)]

13.a. Liquid fuel may be used only during periods of gas curtailment, gas supply interruption, startups,or periodic testing on liquid fuel.

13. K Periodic testing with liquid fiiel may not exceed a combined total of 48 hours during any calendaryear.

Monitor m accordance with Condition 36.

TRIMS and EXTR

14. The permittee must limit visible emissions from emissions units TRIMS and EXTR constructed after 1970to less than 20 percent opacity. Monitor in accordance with Condition 38 and 39. [OAR 340-208-0110(4)]

15. <previous condition deleted, rule has been repealed>

16. The permittee may not emit partlculate matter from TRIMS or EXTR stack in excess of 0.14 grain perstandard cubic foot. Monitor in accordance with conditions 38 and 39. [OAR 340-226-0210(2)(b)(B)]

FLEXQ_RACT

17. The permittee must comply with the following volatile organic compound (VOC) limits for theflexographic prmting Hne (FLEXO): [OAR 340-232-0230]17.a. In operating scenario No.1 (OS#1), for non-compliant inks:

17.a.i. The permittee must operate the regenerative thermal oxldizer (RTO) to control VOCemissions from FLEXO, with a minimum destruction efficiency of 90% of the non-methane VOCs. [OAR340-232-0230(l)(c)(C)]

IV.a.ii. The permittee must operate a capture system in conjunction with the RTO and mustprovide for a control efficiency of at least 60%. [OAR 340-232-0230(2)(c)]

17.a.ui. The permittee must demonstrate compliance accordmg to Conditions 18, 29 and 40.

17.b. In operating scenario No.2 (OS#2), when using complying inks identified in Conditions 17.b.iand17.b.ii, the permittee must use the method specified in Condition 41.c to determine compliancewith the RACT limits. The requirements of permit Conditions 18 and 40 are not mandatoryrequirements under OS#2.


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17.b.i. The volatile fraction of ink, as it is applied to the substrate, must contain no more than 25percent by volume of organic solvent and at least 75 percent by volume of water. [OAR340"232-0230(l)(a)]

17.b.ii. The ink less water, as it is applied to the substrate, must contain at least 60 percent byvolume ofnonvolatile materials. [OAR 340-232-0230(l)(b)]

17.c. The permittee is allowed operate in more than one operating scenario simultaneously; and changesbetween operating scenarios can be made at any time. The permittee is not required to submitrecord of changes of operating scenarios, but shall record the changes in a log at the permittedfacility and make the record available when requested by the Department.

17.d. Monitor in accordance with conditions 40 and 4Lb,

18. The permittee must operate the RTO with a minimum chamber temperature of 1,400°F with the residencetime of 0.5 seconds or more, whenever the RTO is required to be operated under Operating Scenario #1. Ifa source test is conducted, a new RTO temperature limit that demonstrates 90% destruction efficiency maybe used upon DEQ approval. Monitor in accordance with Condition 40. [OAR 340-232-0230(1 )(c)(B),340-208-0550]

PAPER COATDsfG RACT

19. The permittee must not operate any paper coating line which emits more than 2.9 Ibs. VOC per gallon ofcoating applied, excluding water and any exempt solvents, on a daily average basis. Monitor in accordancewith Condition 42. [OAR 340-232-0160(1) and (5)]

Insignificant Activities Emissions Limits and Standards

20. DEQ acknowledges that msignificant emissions units (EEUs) identified by rule as either categoricallyinsignificant activities or aggregate insignificant emissions as defined in OAR 340-200-0020 exist atfacilities required to obtain an Oregon Title V Operating Permit. lEUs must comply with all applicablerequirements, tn general, the requirements that could apply to lEUs are incorporated as follows:

20.a. OAR 340-208-0110 (20% opacity)20.b. OAR 340-228-0210 (0.14 gr/dscf corrected to 12% C02 or 50% excess air for fuel burning

equipment installed constructed or modified on or after June 1, 1970 but prior to April 15,2015)20.c. OAR 340-228-0210 (0.10 gr/dscf corrected to 12% 002 or 50% excess air for fuel burning

equipment installed constructed or modified after April 15, 2015)20.d. OAR 340-226-0210 (0.14 gr/dscf for non-fugitive, non-fuel burning equipment instaUed

constmcted or modified on or after June 1, 1970 but prior to April 15,2015)20.e. OAR 340-226-0210 (0.10 gr/dscf for non-fugitive, non-fuel burning equipment installed

constructed or modified after April 15,2015)20.f. OAR 340-226-0310 (process weight limit for non-fugitive, non-fuel burning process equipment).

21. The permittee must operate the parts/tools cleanmg equipment and dip tanks at the permitted facility inaccordance with OAR 340-232-0180. Non-VOC solvents as defined in OAR 340-200-0020 are exemptjfrom the requirements of this condition: [OAR 340-232-0180]

21 .a. Each sink must be equipped with a cover that is readily opened and closed; and21 .b. Cover must be closed during idle periods if the sink contains any free standing solvents.

22. <previous condition deleted (spray paint rules), rule has been repealed>


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Unless otherwise specified m this permit or an applicable requirement, DEQ is not requiring any testing, monitoring,recordkeeping, or reporting for the applicable emissions lunits and standards that apply to IBUs. However, if testingwere performed for compliance purposes, the permittee would be required to use the test methods identified m andperform the testing m accordance with DEQ's Source Sampling Manual.

Emergency Reciprocatmg Internal Combustion Engines (RICE)

23. Emergency stationary reciprocating internal combustion engines (RICE) are subject to the followingrequirements: [40 63.6640(f)]23.a. For each emergency stationary RICE, the permittee must:

23.a.i. Change oil and filter every 500 hours of operation or annually, whichever comes first;[40 CFR 63. 6603(a), table 2d(4)(a)]

23.a.ii. Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first; [40CFR 63. 6603 (a), table 2d(4)(b)]

23.a.iii. Inspect all hoses and belts every 500 hours of operation or annually, whichever comesfirst, and replace as necessary; [40 CFR 63. 6603(a), table 2d(4)(c)]

23.a.iv. During periods of startup, minimize the engme's time spent at idle and mmimize theengine's startup time at startup to a period needed for appropriate and safe loading of theengine, not to exceed 30 minutes, after which time the non-startup emission limitationsapply; and [40 CFR 63. 6603(a), table 2d]

23 .b. The permittee must install a non-resettable hour meter on each emergency stationary RICE, if oneis not already installed. [40 CFR 63.6625(f)]

23.c. The pennittee must operate and maintain the stationary RICE according to the manufacturer'semission related operation and maintenance instmctions [40 CFR 63.6640(a), Table 6(9)]

23.d. Operating conditions: [40 CFR63.6640(f)(2)]23.d.i. There is no time limit on the use of emergency stationary RICE m emergency situations.23.d-.ii. Emergency stationary RICE may be operated for the purpose of maintenance checks and

readiness testing, provided that the tests are recommended by the manufacturer, thevendor, or the insurance company associated with the engine. Required testing of suchunits should be minimized, but there is no time limit on the use of emergency stationaryRICE in emergency situations and for routine testing and maintenance.

23 .d.iii. Emergency stationary RICE may be operated for an additional 50 hours per year in non-emergency situations. The 50 hours per year for non-emergency situations cannot beused for peak shaving or to generate income for a facility to supply power to an electricgrid or otherwise supply power as part of a financial arrangement with another utility.

23 .e. The pennittee must keep records of the hours of operation of each emergency stationary RICE thatis recorded through the non-resettable hour meter. The permittee must document how many hoursare spent for emergency operation, including what classified the operation as emergency and howmany hours are spent for non-emergency operation. If the engines are used for demand responseoperation, the permittee must keep records of the notification of the emergency situation, and thetime the engine was operated as part of demand response. [40 CFR- 63.6655(f)]


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PLANT SITE EMISSION LIMITS

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

25.

Pollutant

PM/PMioPM2.5

S02NOxco

vocGHG

Plant SiteEmissionLimit *

tons/year

2121

39 :f:*

3^ **

^ *!{:

35074,000 **

NettingBasis *

tons/year

14141323

5519

8JOO

UnassignedEmissions

tons/year

00000

1690

EmissionReduction

Creditstons/year

0000000

* All Plant Site Emission Limits except for GHG include 1 ton per year for Aggregate InsignificantActivities; the GHG Plant Site Emission Limit includes 2,756 tons per year for Aggregate InsignificantActivities** Plant Site Emission Limits have been set at the Generic level for S02, NOx, CO and GHG. [OAR 340-222-0041(1)]

PSEL monitoring is specified in Conditions 41 through 44. [OAR 340-222-0020 and 340-222-0040]

In lieu of the VOC SER defined in OAR 340-200-0020, the permittee becomes subject to New SourceReview as outlined in OAR 340-224-0010 through 340-224-0110 when accumulative VOC PSEL increasesexceed 26.2 tons/yr above the VOC baseline emission rate of 519 tons/yr. This requirement is establishedpursuant to OAR 340-222-0090, Combining and Splitting Sources, part (2), and is the result of splitting theoriginal facility into 2 separate facilities. [OAR 340-222-0090]

EMISSION FEES

26. Emission fees will be based on the Plant Site Emissions Limits, unless the permittee elects to report actualemissions for one or more permitted processes/pollutants. [OAR 340-220-0090]

HAP LIMITS FOR SYNTHETIC MINOR STATUS

27. The permittee must not cause or allow emissions of Hazardous Air Pollutants (HAPs) to exceed thefollowmg limits in any 12 consecutive calendar month period:

27.a. 9 tons of any single HAP; and27.b. 24 tons of any combination of HAPs.


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TESTING REQUIREMENTS

28. Unless otherwise specified m this permit, the permittee must conduct all testing m accordance with DEQ'sSource Sampling Manual. [OAR 340-212-0120]28.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 inaccordance with the Source Sampling Manual and address any planned variations or alternativesto prescribed test methods. The permittee should be aware that if significant variations arerequested, it may require more than 30 days for DEQ to grant approval and may require EPAapproval in addition to approval by DEQ.

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

28.c. Unless otherwise specified by permit condition or DEQ approved source test plan, all compliancesource tests must be performed as follows:28.C.L At Jeast 90% of the design capacity for new or modified equipment;28.c.ii. At least 90% of the maximum operating rate for existing equipment; or28.c.iii. At 90 to 1 10% of the normal maximum operating rate for existing equipment. For

purposes of this permit, the normal maximum operating rate is defined as the 90thpercentile of the average hourly operating rates during a 12 month period immediatelypreceding the source test. Data supporting the normal maximum operating rate must beincluded with the source test report.

28.d. Each source test must consist of at least three (3) test runs and the emissions results must bereported as the arithmetic average of all valid test runs. If for reasons beyond the control of thepermittee a test run is invalid, DEQ may accept two (2) test runs for demonstratmg compliancewith the emission limit or standard.

28.e. Source test reports prepared in accordance with DEQls Source Sampling Manual must besubmitted to DEQ withiu 45 days of completing any required source test, unless a different timeperiod is approved m the source test plan submitted prior to the source test.

29. If the facility's 12 month rolling average VOC emissions exceed 99 tons per year, the permittee mustconduct a source test to determine VOC destruction efficiency in the RTO, using the following procedures:29.a. Source testing must be conducted for VOC, with sampling before and after the control device to

demonstrate the system's VOC destruction efficiency, using EPA Method 25A.29.b. The combustion chamber temperature must be monitored continuously during the test runs and the

average must be less than or equal to the temperature setpoint specified in Condition I 8, unless thetest protocol intent is to establish a new setpoint,

29.c. The source test must be completed within 12 months of the 12 month rolliug average VOCemissions exceeding 99 tons/year.

29.d. Source testing must be performed in accordance with Condition 28.

MONITORING REQUIREMENTS

The monitoring conditions in this section are based on OAR 340-218-0050(3)(a); unless otherwise specified.

General Monitoring Requirements

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


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31. The permittee must use the same methods to determine compliance as those used to determine actualemissions for fee purposes and can be no less rigorous than the requirements of OAR 340-218-0080. [OAR340-218-0050(3)(a)(F)]

32. The permittee must comply with the monitoring requirements on the date of permit issuance unlessotherwise specified in the permit or an applicable requirement [OAR 340-218-0050(3)(a)(G)]

Facility-wide monitoring:

33. At least once eachmonfhforaminimumperiodof 30 minutes, the permittee must visually survey the plantfor any sources of excess fugitive emissions. For the purpose of this survey, excess fugitive emissions areconsidered to be any visible emissions that leave the plant site boundaries for more than 18 seconds in asix-minute period. The person coiLductmg the observation must follow the procedures ofEPA Method 22.If sources of visible emissions are identified, the pennittee must:

33.a. Immediately take corrective action to minimize the fugitive emissions, mcluding but not limited tothose actions identified in Condition 5; or

33.b. Develop a DEQ approved fugitive emission control plan upon request by DEQ and implement theplan whenever fugitive emissions leave the property for more than 18 seconds in a six-minuteperiod,

34. The permittee must mamtain a log summarizing actions taken during an applicable air pollution episode,pursuant to Condition 6.

3 5. The permittee must maintain a log of each nuisance complaint received by the permittee during theoperation of the facility. Documentation must include date of contact, time of observed nuisance condition,description of nuisance condition, location ofreceptor, status of plant operation during the observed period,and time of response to complainant. A plant representative must immediately investigate the conditionfollowmg the receipt of the nuisance complaint and a plant representative must provide a response to thecomplainant within 24 hours, if possible. This condition is only enforceable by the state. [OAR 340-21 8-0050(3)(a)].

Emissious unit specific monitoring:

BOILERS and DRYERS

36. The permittee must keep records of all fuels used in BOILERS:

36.a. The amount of natural gas used per month; and36.b. When fuel oil is used:

36.b.i. The date and time that use of fuel oil begins;36.b.ii. The date and time that use of fuel oil ends;36.b.ui. The reason for use for fuel oil, such as natural gas curtailment, or maintenance and

readiness testing;36.b.iv. The total hours of fuel oil usage in each calendar year for maintenance and readiness

testing; and36.b.v. The total amount of fuel oil used per month.


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37. Except as provided iti Condition 37.a, the permittee must conduct visible emissions survey at each of themonitoring points of emissions unit BOILERS orDRYERS in accordance with the following proceduresand frequencies:37.a. At any time that the permittee is burning natural gas m emission units BOILERS and DRYERS,

the permittee is not required to conduct any visible emissions or particulate matter momtormgbecause it is extremely unlikely fhat these standards could be violated while burning natural gas.The permittee must mamtam records of the type of fuels being burned on an hourly basis. Ifvisible emissions are to be measured for any reason, the visible emissions must be measured inaccordance withDEQ's Source Sampling Manual.

37.b. The permittee may utilize the (PSEL) fuel monitoring specified in. Condition 41.d.i, and no extramonitormg is required for the purpose of this verification.

37.c. If the permittee switches fuel usage from natural gas to no. 2 fuel oil, the permittee must monitorvisible emissions from the stacks of BOILER and DRYER by conducting an EPA Method 9 test.The visible emissions standard in this condition is based on the average of 24 consecutiveobservations recorded at 15-second intervals, or more frequently as allowed under Condition37.C.U, which comprise a six-minute block. Six-minute blocks need not be consecutive in time andm no case may two blocks overlap. For each set of 24 observations, the six-mmute block averageis calculated by summing the opacity of the 24 observations and dividing the sum by 24. Six-minute block averages are measured by:37.C.L EPA Method 9;37.C.U. A continuous opacity monitoring system (COM'S) installed and operated m accordance

with the DEQ Continuous Monitoring Manual or 40 CFR part 60; or37.c.iii. An alternative monitoring method approved by DEQ that is equivalent to EPA Method 9.37-c.iv. The EPA Method 9 tests must be conducted at least once each day while bummg no. 2

fuel oil, excluding weekends and holidays, on the Boiler and Dryer stacks.37.C.V. If 10 consecutive days of EPA Method 9 test results are less than the standard m

Condition 10, the test frequency may be weekly, while burning no. 2 fuel oil.

TmMS

38. The permittee must conduct visible emissions surveys at each of the TRIMS discharge points in accordancewith the followmg procedures and frequencies:

38.a. At a nunimum of once each semi-annual period (January-June and July-December), the permitteemust conduct a six (6) minute visible emission survey using the procedures outlined in EPAMethod 22. Monitoring shall be conducted at approximately 6-month intervals.

38.b. All visible emissions observations must be conducted during operating conditions that have thepotential to create visible emissions (e.g. during loading and/or unloadmg activities).

38.c. If visible emissions, from an individual momtoring point are detected for more than 5% (18seconds) of the survey time, check the equipment for malfunction and correct the problem. Thenre-check for visible emissions as soon as possible. If visible emissions persist for more than 5%(18 seconds) of the survey time durmg the re-evaluation, an EPA Method 9 test must be conductedon that monitoring point m accordance with the Department's Source Sampling Manual.


Pagel4of32

38.d. If the observer is unable to conduct the survey and/or EPA Method 9 tests due to visualinterference caused by other visible emissions sources (e.g., fugitive emissions during high windconditions) or due to weather conditions such as fog, heavy ram, or snow, the observer must notesuch conditions on the data observation sheet ss.d make at least three attempts in same day toconduct the surveys and7or tests at approximately 2 hours intervals throughout the day. If noobservations are made for that day, the observer must continue to attempt to conduct the surveyand/or EPA Method 9 daily until a valid observation is made.

38.e. If the opacify exceedance is noted, within 24 hours of the noted exceedance, the permittee mustfollow up with an investigation and determine the cause of the problem, and take correctiveactions as necessary to resolve the problem.

EXTR

39. The permittee must conduct visible emissions surveys at each of the EXTR discharge points in accordancewith the following procedures and frequencies

39.a. At a minimum of once each semi-annual period (January-June and July-December), the permitteemust conduct a six (6) minute visible emission survey using the procedures outlined in EPAMethod 22. Monitoring shall be conducted at approximately 6-month intervals.

39.b. All visible emissions observations must be conducted during operating conditions that have thepotential to create visible emissions (e.g. during loading aad/or unloading activities).

39.c. If visible emissions, from an individual monitoring point are detected for more than 5% (18seconds) of the survey time, check the equipment for malfunction and correct the problem. Thenre-check for visible emissions as soon as possible. If visible emissions persist for more than 5%(18 seconds) of the survey time during the re-evaluation, an EPA Method 9 test must be conductedon that monitoring point in accordance with the DEQ's Source Sampling Manual.

39.d. If the observer is unable to conduct the survey and/or EPA Method 9 tests due to visualinterference caused by other visible emissions sources (e.g., fugitive emissions during high windconditions) or due to weather conditions such as fog, heavy rain, or snow, the observer must notesuch conditions on the data observation sheet and make at least three.attempts in same day toconduct the surveys and/or tests at approximately 2 hours intervals throughout the day. If noobservations are made for that day, the observer must continue to attempt to conduct the surveyand/or EPA Method 9 daily until a valid observation is made.

39.e. If the opacity exceedance is noted, within 24 hours of the noted exceedance, the permittee mustfollow up with an investigation and determine the cause of the problem, and take correctiveactions as necessary to resolve the problem.

FLEXO/RTO

40. The pennittee must monitor and record the RTO's operatmg temperature when non-compliant solvent(VOC) based coatings are applied at the (FLEXO) coating lines. [OAR 340-232-0230(3)(d)(A) and 340-212-0250]

40.a. Record the temperature on a strip/circular chart or in electronic files, and check and compare thetemperature readings to the 1,400°F mmimum set forth in Condition 18. Record in a log anyexceedances noted, and corresponding dates, if any.


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40.b. The permittee must keep a log of any maintenance and/or service performed that would affectsystem performance.

Plant Site Emissions Monitoring and the VOC Coating Limit Monitoring:

41. The permittee must determine compliance with the Plant Site Emissions Limits specified in Condition 24by conducting monitoring in accordance with the following procedures and frequencies:

41 .a. Plant site emissions must be calculated on a rolling 12 calendar month basis using the proceduresspecified in this condition. Emissions calculations must be updated no more than 30 days after theend of each calendar month.

41 .b. VOC emissions from EUvoc must be monitored and calculated as follows:

41 .b.i. The permittee must monitor and maintain daily (where required), monthly and annualrecords of the foUowmg operating parameters, as well as all background data andcalculations, related to EUvoc:


Page16of32

OPERATING PARAMETERAll solvent-based materials and solvents used at theFLEXO process excluding compliant materialsdefined in Conditions 17.b.i and 17.b.il.

The VOC content of SMi

The HAP content of SM;

Over-all capture and destruction efficiency rate ofthe FLEXO/RTO system

Daily paper coating usage for any day that a papercoating is used on the paper coater emission unitthat contained greater than 2.9 Ib/ga! VOC

All solvent containing paper coatings appliedmonthly

The VOC content ofPCi (for any day tfaat a papercoating is used on the paper coater emission unitthat contained greater than 2.9 Ib/gal VOC) or PCM;

The HAP content ofPCi (for any day that a papercoating is used on the paper coater emission unitthat contained HAP(s))

All miscellaneous materials/inks and solvents usedat the plant, including compliant coatings (see H.b.iand 17.b.ii) and cleanup solvent, but excluding SMi,PCi, and materials used in routine maintenaace.

The VOC content ofMMi

The HAP content ofMMi

Polyethylene resin processed (EXTR)

The VOC emission factor for Pr

Total reclaimed solvents sold or shipped off-site aswaste.

Average VOC content of W;

SM;

VOCi

HAPi

0.61

PC,

PCMi

VOCP;

HAPPi

MMi

VOCM,

HAPMi

Pr

170.6

Wi

VOCW;

UNITIbs/month

wt. fraction

wt. fraction

dunensionless

gal/day

gal/mo

Ib/gal

Ib/gal

Ibs/mo

weightfraction

weightfraction

106Ibs/mo

lbs/1061bsPr

Ibs/mo

weightfraction

METHODMass balance on materials by inkfamily and Recordkeeping.

From Product data sheets, MSDS,or analysis. MSDS database orelectronic files of ink suppliers usedto compute ink family average.

From Product data sheets, MSDS,or analysis. MSDS database orelectronic files of ink suppliers usedto compute ink family average.

The capture efficiency tested at 70%(10/95), and the destructionefficiency tested at 97.8% (7/97).

Recordkeeping

Recordkeeping

Recordkeeping

Recordkeepmg

Recordkeeping

Product data sheets or MSDS

Product data sheets or MSDS

Recordkeeping

Recordkeepmg/RCRA manifest bytype ofHW

Periodic testing


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41.b.ii. Use the following material balance formula to calculate the monthly (EVOC,MO, Ibs/mo)and 12 rolling calendar month (EVOC,YR, tons/yr) process VOC emissions:

41 .b.ii.A. PCMi = monthly paper coating usage, gal/month

4Lb.u.B. EVOC,MO= 0.39!f!Z(VOCi x SMi)+S(VOCPi x PCMi) + S(VOCMi x MM;) +(170.6 * Pr)-(VOCWi^Wi)

41.b.ii.C. EVOC.YR = [SEvoc,Mo]/2,000

41.c. The penmttee must monitor and maintain records of one ofthefollowmg compliant coating (seeConditions 17.b.i and 17.b.ii) parameters, and update the information as the coating formulationchanges:

Compliant Ink Parameters

volume fraction ofVOC

volume fraction of water

volume fraction of solids

Unit

fraction or percentage



Method

Product data sheets, SDS, or

analysis. SDS database or

electronic files ofmk suppliers usedto compute ink family average

41 .d. The pennittee must monitor and calculate emissions from BOILERS, DRYERS, TRIMS, andEXTR as follows:

41.d.i. The permittee must monitor and mamtain monthly and annual records of the followingoperating parameters:

EMISSIONS UNIT

BOILERS

DRYERSTRIMSEXTRBOILERS

OPERATING PARAMETER

Fuel oil burned

NG burned

NG burned

Paper processed

Resin processed

Percent Suliur

Pl

P2

Ps

P4

Pi

%s

UNFT

103 gallons

10s ft3

10f'ft3

MMlbsMMlbs%

METHOD

from meter reading orpurchase/usage records.

recordkeeping

recordkeeping

see Condition 44

41.d.h. Use the followmg formula and the emissions factors provided to calculate the monthlyand annual emissions from BOH.ERS and DR.YERS:

E, - S (P; EFy) / K = [ (Pi EFij) + (P2 EF2j) + (?3 EF3j) ] / K

where: Ej = pollutant emissions; Ibs/month or tons/year.Pi = operatmg parameter identified in Condition 41.b.i.K = conversion factor; 2,000 Ibs/ton or 1 Ib/lb.EFi ,j = emission factor for each combustion unit and pollutant identified below:


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41.cl.ui. Use the following formula and the emissions factors provided to calculate the monthlyand amiual emissions ofPMio and VOC from TRIMS and EXTR:

Ej - S (Pi EFy) / K = [ (P4 EF4j) + (P5 EF5,) ] / K

where: E, =- pollutant emissions; Ibs/month or tons/year.Pi =: operating parameter identified in Condition 41.b.i.K == conversion factor; 2,000 Ibs/ton or Ib/lb.EF; j ^ emission factor for each process unit and pollutant identified below:

EFy for emissions units identified

EUID

BOILERS

DRYERSTRIMSEXTR

FEED

fuel oil

natural gas

natural gas

paper prod.

resin usage

PM^o

3.3

2.5 <2)

2.5 W

110263.3

so^w

142(%S)2.6

2.6

NOx

20

100100

co

58484

voc

0.34

5.5

5.5

170.6 ^

UNITlbs/1000 gal

lbs/106ft3

lbs/106 ft3

lbs/1061bs

lbs/106 Ibs(1) The S02 EF is a function ofsulfur content (%S) when fuel oil is burned, in which %S is obtained from Condition 44.(2) All EFs are based on AP42 data, except PMio EF for NO combustion is DEQ EF based on ST. See forms AQ-EF05 & AQ-EF04.(3) The VOC EF for EXTR listed in table for reference only. The EXTR VOC emissions are calculated in Condition 41.b.

42. Any day that a paper coating is used OIL the paper coatmg emission unit that contains VOC greater than 2.9Ib/gal, the permittee must determine daily compliance with the Paper Coating RACT limit in Condition 19using the equation below and the monitoring parameters identified in Condition 41.b.i:

Daily average Ib/gal VOC emitted = [2: (VOCPi x PC;) ] / [ S PC, ]

43. Plant site RAP emissions must be calculated on a rollmg 12 calendar month basis using the proceduresspecified m. this condition. Emissions calculations shall be updated no more than 30 days after the end ofeach calendar month.

43.a. Use the following formulas and the emissions factors provided to calculate the monthly and 12rolling calendar month RAP emissions from BOILERS and DRYERS:

43.a.i. CHAP.MO = [ (Pi;l:7.63E-03 lb/mmBtu:l!150mmBtu/kgal) + (P2 + Ps )(7.57E-04 Ib/mmBtu* 1050 mmBtu/mmcf) ] / K

43.a.ii. CHAP,YR = [ T. CHAP,MO ] / 2,000

where: C]..IAP,MO and CHAP.YR^ combustion RA.P emissions; Ibs/month or tons/year.Pi = operatmg parameter identified m Condition 41 .d.i.K ^ conversion factor; 2,000 Ibs/ton or 1 Ib/lbmmBtu = million Btukgal = thousand gallonsmmcf^ million cubic feet.

(For origin of HAP emission factors, see Combustion HAP emission factor table, page 31 .)


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43 .b. Use the following material balance formula to calculate the monthly (EHAP,MO, Ibs/mo) and 12rolling calendar month (EHAP.YR, tons/yr) process HAP emissions:

43.b.i. EHAP,MO:= 0.39 * S(HAPi x SMi) +1: (HAPPi x PCMQ + SCHAPM, x MMQ

43.b.ii. EHAP.YR = [ S BHAP.MO ]/2,000

43 .c. Total HAP emissions for the preceding 12 months is the sum of CHAP,YR and EHAP,YR .

44. The permittee must monitor the sulfur content (%S) of each batch of fuel oil used in BOILERS, maccordance with the following methods or procedures:

44.a. Obtaining a receipt or other statement that identifies the fuel oil as ULSD; or44.b. If the fuel oil is not ULSD:

44.b.l. Obtaining a sulfar analysis certificate from the vendor for each batch; or44.b.ii. Analyzing or having analyzed by a contract laboratory a composite of representative

samples taken by the pennittee from each batch of fuel oil received. Liquid fuels shall beanalyzed using ASTM D129-64, D1552-83, D4057-81, or equivalent method.

RECORDKEEPING REQUIREMENTS

The recordkeepiag conditions m this section are based on OAR 340-218-0050(3)(b); unless otherwise specified.

General Recordkeeping Requirements

45. The pemiittee must mamtain the following general records of testing and monitoring required by thispermit: [OAR 340-218-0050(3)(b)(A)j

45.a. The date, place as defined in the permit, and tune of sampling or measurements;45.b. The date(s) analyses were performed;45.c. The company or entity that performed the analyses;45.d. The analytical techniques or methods used;45.e. The results of such analyses;45.f. The operatiag conditions as existing at the time of sampling or measurement; and45.g. The records of quality assurance for continuous monitormg systems (including but not limited to

quality control activities, audits, calibration drift checks).

46. Unless otherwise specified by permit condition, the permittee must make every effort to maintam 100percent of the records required by the permit. Ifmformation is not obtained or recorded for legitimatereasons (e.g., the monitor or data acquisition system malfunctions due to a power outage), the missingrecord(s) will not be considered a permit deviation provided the amount of data lost does not exceed 10%of the averaging periods in. a reporting period or 10% of the total operating hours m a reporting period, if noaveraging time is specified. Upon discovering that a required record is missing, the permittee mustdocument the reason for the missing record. In addition, any missing record that can be recovered fromother available information, will not be considered a missing record. [OAR 340-214-0114, 340-214-0110,and340-218-0050(3)(b)]

47. The permittee must comply with the recordkeeping requirements on the date of permit issuance unlessotherwise specified in. the permit or an applicable requirement. [OAR 340-218-0050(3)(b)(C)]


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48. Unless otherwise specified, the permittee must retain records of all required monitoring data and supportinformation for a period of at least five (5) years from the date of the monitoring sample, measurement,report, or application. Support information includes all calibration and maintenance records and all originalstrip-chart recordmgs (or other original data) for continuous monitoring mstmmentation, and copies of allreports required by the permit. All existing records required by the previous Air Contaminant DischargePermit or Oregon Title V Operating Permit must also be retained for five (5) years from the date of themonitoring sample, measurement, report, or application. [OAR 340-218-0050(b)(B)]

Source Specific Recordkeeping Requirements

49. The pennittee must maintain the followmg records ofmonitormg required by Conditions 33 through 44:

49.a. Visual inspection results, and a summary of corrective actions taken, if any;49.b. Complaint log and mvestigation reports;49.c. Opacity readings;49.d. RTO temperature readings;49.e. Rolling 12 calendar month Plant Site emissions calculated each month;49.f. Rolling 12 calendar month HAP emissions calculated each month;49.g. Monthly and annual records ofmaterial/solvent usage and/or waste manifest records specified in

Condition 41.b;49.h. RTO source test results, and any other back-ground data supporting the control efficiency;49.1. Daily paper coating RACT calculations and supporting data for any day that a paper coatmg is

used on the paper coater emission unit that contained greater than 2.9 Ib/gal VOC;49.j. Monthly and annual records of fuel usage specified in Condition 41.d.i;49.k. Fuel oil sulfur analyses certificates, or Data sheet/MSDS obtained per Condition 44;49.1. Hours of operation of emergency RICE; and49.m. Any other physical records and/or operating parameters that can be used to show compliance with

the permit conditions (e.g., RTO design spec. to show compliance with the 0.5 second residencetime requirement specified m Condition 18.

REPORTDTO REQUIREMENTS [OAR 340-218-0050(3)(C)]

The reporting conditions in this section are based on OAR 340-218-0050(3)(c); unless otherwise specified.

General Reporting Requirements

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

50.a. Immediately (as soon as possible but m no case later than the end of the first working dayfollowing the excess emissions period) notify DEQ of an excess emission event by phone, e-mail,or facsimile; and

50.b. Within 15 days of the excess emissions event, submit a written report that contams the followinginformation: [OAR 340-214-0340(1)]

50.b.i. The date and time of the beginning of the excess emissions event and the duration or bestestimate of the time until return to normal operation;

50.b.ii. The date and time the owner or operator notified DEQ of the event;50.b.iii. The equipment involved;50.b.iv. Whether the event occurred during planned startup, planned shutdown, scheduled

maintenance, or as a result of a breakdown, malfunction, or emergency;


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50.b.v. Steps taken to mitigate emissions and corrective action taken, includmg whether theapproved procedures for a planned startup, shutdown, or mamtenance activity werefollowed;

50.b.vi. The magnitude and duration of each occurrence of excess emissions during the course ofan event and the increase over normal rates or concentrations as determined bycontinuous monitoring or best estimate (supported by operating data and calculations);

50-b.vh. The final resolution of the cause of the excess emissions; and

50.b.vui.Wliere applicable, evidence supportmg any claim that emissions in excess oftechnology-based limits were due to any emergency pursuant to OAR 340-214-0360.

50.c, In the event of any excess emissions which are of a nature that could endanger public health andoccur during non-business hours, weekends, or holidays, the permittee must munediately notifyDEQ by calling the Oregon Accident Response System (OARs). The current number is 1-800-452-0311.

50.d. If startups, shutdowns, or scheduled maintenance may result m excess emissions, the permitteemust submit startup, shutdown, or scheduled mamtenance procedures used to minimize excessemissions to DEQ for prior authorization, as required m 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 firstoccurrence of the excess emission event. The permittee must abide by the approved proceduresand have a copy available at all times.

50.e. The permittee must notify DEQ of planned startup/shutdown or scheduled maintenance events.50.f. The permittee must continue to mamtain 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 summarylisting the date, time, and the affected emissions units for each excess emission that occurredduring the reporting period. [OAR 340-218-0050(3)(c)]

51. Permjti^eviation Reporting. The permittee must promptly report deviations from permit requirements thatdo not cause excess emissions, including those attributable to upset conditions, as defined in. the permit, theprobable 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. 50.

52. All required reports must be certified by a responsible official consistent with OAR 340-218-0040(5);[OAR340-218-0050(3)(c)(D)]

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

Semi-AnnuaI and Annual Reports

54. The permittee must submit three (3) copies of reports of any required monitoring at least every 6 months,completed on forms approved by DEQ. Six month periods are January 1 to June 30, and July 1 toDecember 31. One copy of the report must be submitted to the EPA and two copies to the DEQ regionaloffice. 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)]]

54.a. The first semi-amiual report is due on July 30 and must include the semi-annual compliancecertification, OAR 340-218-0080.

54.b. The annual report is due on February 15 and must consist of the following:

54.b.i. The emission fee report [OAR 340-220-0100]54.b.ii. The N0^ and VOC emission statement, if applicable; [OAR 340-214-0220];


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54.b.iii. A summary of the excess emissions upset log; [OAR 340-214-0340]54.b.iv. The second semi-annual compliance certification; [OAR 340-218-0080]54.b.v. The annual certification that the risk management plan is being properly implemented, if

applicable; [OAR 340-244-0230 and OAR 340-218-0080(7)]54.b.vi. A summary of the rolling 12 calendar month VOC emissions, as calculated each month,

from emissions unit EUvoc and associated materials usage and wastes solvent data (seeCondition 41.b).

54.b.vii. A summary of the rolling 12 calendar month emissions of each criteria pollutant PMio,SOa, NOx, CO, and VOC, as calculated each month, from emissions units BOILERS andDRYERS, and correspondmg fuel(s) usage (see Condition 41 .d).

54.b.viu.A summary of the rolling 12 calendar month PMio emissions, as calculated each month,from emissions units TRIMS and EXTR and associated paper production and resin usage(see Condition 41.d).

54.b.ix. A summary of the rolling 12 calendar month HAP emissions, as calculated each month(see Condition 43), and

54.b.x. All exceedances of the minimum 1,400 °F temperature, as determined jfrom Condition 40.

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

55.a. The identification of each term or condition of the permit that is the basis of the certification;55.b. The identification of the method(s) or other means used by the permittee for determming the

compliance status with each term and condition duriag the certification period. Such methods andother 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 issufficient to meet this requirement, except when thepermittee must certify compliance 'with newapplicable conditions incorporated by reference into the permit. When certifying compliance withnew applicable conditions that are notyet in the permit, thepermittee must provide theinformation required by this condition. If necessary, the permittee also must identify any othermaterial information that must be included in the certification to comply with section 113(c)(2) ofthe PCAA, which prohibits knowingly making a false certification or omitting materialinformation;

55.c. The status of compliance with terms and conditions of the permit for the period covered by thecertification, including whether compliance during the period was continuous or intermittent. Thecertification must be based on the method or means designated in Condition 55.b. Thecertification 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 whichcompliance is required and in which an excursion or exceedance, as defined under OAR 340-200-0010, occurred; and

55.d. Such other facts as DEQ may require to determine the compliance status of the source.

56. Greenhouse Gas Registration and Reporting: If the calendar year emission rate of greenhouse gases (CC>2e)is greater than or equal to 2,756 tons (2,500 metric tons), the permittee must register and report itsgreenhouse gas emissions with DEQ in accordance with OAR 340-215. The greenhouse gas report must becertified by the responsible official consistent with OAR 340-218-0040(5) and submitted by March 31 ofeach year.

57. Notwithstanding any other provision contained in any applicable requirement, the permittee may usemonitoring as required under OAR 340-218-0050(3) and incorporated into the permit, in addition to anyspecified compliance methods, for the purpose of submitting compliance certifications. [OAR 340-218-0080(6)(e)]


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

DEQ - Northwest RegionAir Quality Division700 NE Multnomah St., Suite 600Portland, OR 97232-4100

(503) 229-5263

DEQ - Accounting/Revenue(for payments)700 NE Multnomah St, Suite600Portland, OR 97232(503) 229-5359

Air Operating PermitsUS Environmental Protection AgencyMail Stop OAQ-1081200 Sixth AvenueSeattle, WA 98101


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NON-APPLICABLE REQUIREMENTS

59. State and Federal air quality requirements (e.g., mles and regulations) currently determmed not applicableto the permittee are listed below along with the reason for the non-applicability: [OAR 340-218-0110]

Applicable Requirement

OAR Chapter 340Division 202: aU mles

Division 208: 0570

Division 210: 0100 through 0120

Division 214: 0130(2) and (3), 0210 and 0220Division 218: 0050(4), 0090, 0100Division 226: 0300 through 0320, 0400

Division 228: 0100, 0120, 0130, 0200, 0300, 600through 639Division 230Division 232: 0040-0150, 0170-0220Division 234

Division 23 6Division 238: 0060, 0070, 0080, 0100Division 240

Division 242: 0420, 0430, 0440, 0520, 0620 and0630Division 244:

Division 246:Division 254Division 256Division 258Division 260: 0030, 0040

Division 268

40 CFR:Part 55Part 57Part 60, except subparts A, and appendixesPart 61, excep^subpartA, M, and appendicesPart 63, except subpart A and appendicesPart 72 through 76Part77Part78Part 82, except subpart FPart 85 through 89

Summary

Ambient Air Quality Standards and PSDIncrementsVisible Emissions and NuisanceRequirementsStationary Source Notification.RequirementsStationary Source Reporting RequirementsOregon Title V Operating PermitsGeneral Emission Standards

Requirements For Fuel Burning Equipmentand Fuel Sulfur ContentIncinerator RegulationsEmission Standards For VOC Point SourcesEmission Standards For Wood ProductsIndust-iesEmission Standards For Specific IndustriesNew Source Performance StandardsRules For Areas With Unique Air QualityNeedsRules Applicable to the Portland Area

Oregon Federal Hazardous Air PollutantProgramOregon State Air Toxics ProgramRules for Indirect SourcesMotor VehiclesMotor Vehicle Fuel SpecificationsRefrigerant Recycling and Ozone-DepletingSubstance RequirementsEmission Reduction Credits

ReasonCode

I

b

b

h, bb, h, b, b,e,h

f, ^ f, e,

M.eb or cb

bec

;? &) &3 l-/3

b, b or cb,k

i,bbbbb

h

bbbbbbbbbb


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Reason code definitions:

a this pollutant is not emitted by the facilityb the facility is not m this source categoryc the facility is not in a special control/nonattamment aread the facility is not m this countye the facility does not have this emissions unitf the facility does not use this fuel typeg the rule does not apply because no changes have been made at the facility that would trigger these

procedural requu'em.entsh this method/procedure is not used by the facilityi this rule applies only to DEQ and regional authoritiesj. 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 emissionsgreater than 100 tons per year are subject to emissions standards promulgated after November of 1990

k. other

GENERAL CONDITIONS

Gl. General Provision

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

G2. Reference materials

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

a. Source Sampling Manual; April 16,2015 - State Implementation Plan Volume 3, Appendix A4;b. Continuous Monitoring Manual; April 16, 2015 - State Implementation Plan Volume 3, Appendix

A6; andc. All state and federal regulations as in effect on the date of issuance of this pennit.

G3. Applicable Requirements [PAR 340-218-0010C3ybyi

Oregon Title V Operatiug Permits do not replace requirements m Air Contaminant Discharge Pennits(ACDP) issued to the source even if the ACDP(s) have expired. For a source operating under a Title Vpermit, requirements established in an earlier ACDP remain in effect notwithstanding expiration of theACDP or Title V permit, unless a provision expires by its terms or unless a provision is modified orterminated following the procedures used to establish the requirement initially. Source specificrequirements, includmg, but not limited to TACT, RACT, BACT, and LAER requirements, established inan ACDP must be mcorporated mto the Oregon Title V Operating Permit and any revisions to thoserequu'ements must follow the procedures used to establish the requirement initially.

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

a. The permittee must comply with all conditions of this permit. Any permit conditionnoncompliance constitutes a violation of the Federal Clean Air Act and/or state rules and isgrounds for enforcement action; for permit termination, revocation and re-issuance, ormodification; or for denial of a permit renewal application.


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Any noncompliance with a permit condition specifically designated as enforceable only by thestate constitutes a violation of state rules only and is grounds for enforcement action; for permittermiaation, revocation and re-issuance, or modification; or for denial of a permit renewalapplication.

b. Any schedule of compliance for applicable requirements with which the source is not incompliance at the time of permit issuance is supplemental to, and does not sanctionnoncompliance with the applicable requirements on which it is based.

c. For applicable requirements that will become effective duriug the permit term, the source mustmeet such requirements on a timely basis unless a more detailed schedule is expressly required bythe applicable requirement.

G5. Masking Emissions:

The permittee may not install or use any device or other means designed to mask the emission of an aircontaminant that causes or is likely to cause detriment to health, safety, or welfare of any person orotherwise violate any other regulation or requirement. [OAR 340-208-0400] This condition is enforceableonly by the State.

06. Credible Evidence:

Notwithstanding any other provisions contained in any applicable requirement, any credible evidence maybe used for the purpose of establishing whether a person has violated or is in violation of any suchapplicable requirements. [OAR 340-214-0120]

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

Any document submitted to DEQ or EPA pursuant to this permit must contain certification by a responsibleofficial of truth, accuracy and completeness. All certifications must state that based on information andbelief 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 inthese records, reports, plans, or other documents.

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

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

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

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

G10. Stratospheric Ozone and Climate Protection [40 CFR 82 Subpart F, OAR 340-260-0040]

The permittee must comply with the standards for recycling and emissions reduction pursuant to 40 CFRPart 82, Subpart F, Recycling and Emissions Reduction.

Gil. Permit Shield [OAR 340-218-0110]

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

i. Such applicable requirements are included and are specifically identified in the permit, or


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ii. DEQ, in acting on the permit application or revision, determines in writing that otherrequu'em.ents specifically identified are not applicable to the source, and the permitincludes the determination or a concise summary thereof.

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

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

ii. The liability of an owner or operator of a source for any violation of applicablerequirements prior to or at the time of permit issuance;

iii. The applicable requirements of the national acid rain program, consistent with section408(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 of records).

c. Sources are not shielded from applicable requu'ements that are enacted during the permit term,unless such applicable requirements are iucorporated into the permit by admmlstrativeamendment, as provided m OAR 340-218-0150(l)(h), significant permit modification, orreopening for cause by DEQ.

G12. Inspection and Entry [OAR 340-218-0080(3)]

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

a. Enter upon the pennittee's premises where an Oregon Title V Operating Permit program source islocated or emissions-related activity is conducted, or where records must be kept under theconditions of the permit;

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

c. Inspect, at reasonable times, any facilities, equipment (including monitormg and air pollutioncontrol 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 orparameters, for the purposes of assuring compliance with the permit or applicable requirements.

G13. Fee Payment [OAR 340-220-0010, and 340-220-0030 through 340-220-0190]

The permittee must pay an annual base fee and an annual emission fee for particulates, sulfur dioxide,nitrogen oxides, aad volatile organic compounds. The permittee must submit payment to the Departmentof Environmental Quality, Business Office, 700 NE Multnomah St., Suite 600, Portland, OR 97232, within30 days of the date DEQ mails the fee invoice or August 1 of the year following the calendar year forwhich emission fees are paid, whichever is later. Disputes must be submitted m writing to DEQ. Paymentmust be made regardless of the dispute. User-based fees will be charged for specific activities (e.g.,computer modeling review, ambient monitoring review, etc.) requested by the permittee.

G14. Off-Permit Chanees to the Source [OAR 340-218-0 140(2)]

a. The permittee must monitor for, and record, any off-pemiit 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;


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v. does not violate any existing permit term or condition; andvi. May result m emissions of regulated air pollutants subject to an applicable requirement

but not otherwise regulated under this permit or may result in msignificant changes asdefined in OAR 340-200-0020.

b. A contemporaneous notification, if required under OAR 340-218-0140(2)(b), must be submitted toDEQemdtheEPA.

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

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

G15. Section 502^10) Changes to the Source [OAR 340-218-0140(3)]

a. The permittee must monitor for, and record, any section 502(b)(10) change to the source, which isdefined 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 monitormg,

recordkeeping, reporting, or compliance certification requirement; oriii. Be a Title I modification.

b. A mmimum 7-day advance notification must be submitted to DEQ and the EPA in accordancewith OAR 340-218-0140(3)(b).

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

G16. Administrative Amendment [OAR 340-218-0150]

Administrative amendments to this permit must be requested and granted m accordance with OAR 340-218-0150. The penmttee must promptly submit an application for the followmg types of administrativeamendments 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 ofOregon, or

b. Sale or exchange of the activity or facility.

G17. Minor Permit Modification [OAR340-218-0170]

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

G18. Significant Permit Modification [OAR 340-218-0180]

The permittee must submit an application for a significant permit modification in accordance with OAR340-218-0180.

G19. Stavins Permit Couditions [OAR 340-218-0050(6)(c)j

Notwithstanding Conditions G16 and G17, the filmg of a request by the permittee for a permitmodification, revocation and re-issuance, or termination, or of a notification of planned changes oranticipated noncompliance does not stay any permit condition.


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

The pennittee must obtain approval from DEQ prior to construction or modification of any stationarysource or air pollution control equipment m accordance with OAR 340-210-0200 through OAR 340-210-0250.

G21. New Source Review Modification [OAR 340-224-001 0]

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

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

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

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

The permittee must furnish to DEQ, within a reasonable time, any information that DEQ may request mwritmg 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 copiesof records required to be retained by the permit or, for infonnation claimed to be confidential, the permitteemay furnish such records to DEQ along with a claim of confidentiality.

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

a. The permit may be modified, revoked, reopened and reissued, or terminated for cause asdetermmed by DEQ.

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

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

G25. Severabilitv Clause [OAR340-218-0050(5)]

Upon. any administrative or judicial challenge, all the emission lumts, specific and general conditions,monitoring, recordkeepmg, and reporting requirements of this permit, except those being challenged,remam valid and must be complied with.

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

a. This permit expires at the end of its term, unless a timely and complete renewal application issubmitted as described below. Permit exph'ation 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 permitrenewal application, DEQ must provide no less than six (6) months for the owner or operator toprepare an application.

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


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

The permit is not transferable to any person except as provided m OAR 340-21 8-0150(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 exclusiveprivileges, nor does it authorize any injury to private property or any invasion of personal rights, nor anymfringement 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 tunes a copy of the Oregon Title V Operating Permitand must provide a copy of the permit to DEQ or an authorized representative upon request.

ALL INQUIRIES SHOULD BE DIRECTED TO:

Northwest Region Air Quality700 NE Multnomah St, Suite 600Portland, OR 97232-4100Telephone: (503) 229-5263

Permit No.: 26-2777Expiration Date: Five years from date of issuance

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Table of Combustion HAP emission factors, taken from the following source:

MEMORANDUMTO: Jim Eddinger, U.S. Environmental Protection Agency, OAQPS (C439-01)FROM: Christy Burlew and Roy Oommen, Eastern Research Group (ERG), MorrisvilleDATE: October, 2002SUBJECT: Development of Average Emission Factors and Baseline Emission Estimates for the Industrial,Commercial, and Institutional Boilers and Process Heaters National Emission Standard for Hazardous Air Pollutants

MAP EF's for boilers inIb/mmBtu heat input

Boiler size:

Emission control

14-Dichlorobenzene

16-PAH

Acetaldehyde

Acrolein

Arsenic

Benzene

Beryllium

Cadmium

Chlorine

Chromium

Dibenzofuran

DibutylphthaiateDioxin

Ethylbenzene

Fonnaldehyde

Hexachlorobenzene

HydrochloricAcidHydrofluoricAcidLeadm-Xylene

Manganese

Mercury

Methyl Chloroform

Methyl Ethyl KetoneMethylene Chloride

Nickel

o-Xylene

Phosphorus

Toluene

XylenesHAP EF = sum ofindividual EFs

gas<10mmBtu/hr

no

1.26E-04

1.86E-04

9.67E-06

1.65E-06

1.50E-06

1.21E-06

1.40E-06

5.99E-12

6.43E-11

6.86E-07

3.30E-04

1.24E-05

2.43E-06

9.14E-07

1.78E-05

2.46E-06

2.01 E-05

1.46E-05

1.21E-06

2.07E-06

2.44E-05

7.57E-04

distil late

<10mmBtu/hr

no

5.19E-05

2.03E-05

9.92E-06

6.03E-07

1.55E-05

2.22E-07

2.22E-07

2.16E-03

7.31 E-07

6.00E-11

2.17E-10

3.23E-07

1.51 E-04

7.10E-05

2.22E-OG

4.20E-06

8.87E-09

1.07E-06

3.01 E-05

1.04E-06

5.00E-07

1.82E-04

6.25E-06

4.53E-06

2.71 E-03

residual<10mmBtu/hr

no

2.14E-05

2.03E-05

9.92E-06

5.38E-06

9.21 E-06

1.12E-06

6.14E-06

2.16E-03

3.14E-05

6.00E-11

2.17E-10

3.23E-07

7.80E-05

7.10E-05

1.63E-05

1.39E-03

8.80E-06

1.07E-06

3.01 E-05

2.06E-03

5.00E-07

1.82E-04

3.95E-05

1.12E-03

7.26E-03

Permit No.: 26-2777Expiration Date: Five years from date of issuance

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Table of Default Assessable Emissions for Fee PurposesEmission

UnitID

FLEXO

EXTR

EUVOC

PC

BOILERS

DRYERS

TRIMS

EmissionUnit

Description

Flexo print

Extruder

Papercoater

Natural gas

No. 2fuei oil

Natural gas

Aggregate Insignificant

PM10

6.06

0.16

0.16

0.02

13.37

1

N Ox

6.38

0.10

8.02

1

502

0.17

0.36

0.21

1

vocMB*

3.92

0.35

0.00

0.44

1

Total assessable emissions: 21 16 2 5.72 + MB

Total default assessable

emissions if Material Balance

for VOCis not used:

* MB means the

material balance

calculation for VOC

emissions from inks.

21 16 350

5.72 is the sum of

VOC emissions from

extruder, boilers,

dryers and aggregate

insignificant.

OREGON DEPARTMENT OF ENVIRONMENTAL … · OREGON TITLE V OPERATING PERMIT Northwest Region ... SERP...

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