October 7, 2011

Ellen Porter Roseburg Forest Products

– Missoula Particleboard

P.O. Box 4007 Missoula, MT 59806

RE: Administrative Amendment Title V Operating Permit #OP 2303

- 0 6

Dear Ms. Porter :

The Department of Environmental Quality has prepare d the enclosed Final Operating Permit #OP 2303

- 06 , for Roseburg Forest Products , located in Missoula , Montana. Please review the cover page of the attached permit for information pertaining to the action taking place on Permit #OP 2303

- 06

.

If you have any questions, please contact Vickie Walsh , the permit writer, at (406) 444

- 9741 or by email

at Viwalsh@mt.gov

.

Sincerely,

Vickie Walsh Air Permitting Program Supervisor Air Resources Management Bureau (406) 444

- 9741

VW:

Enclosure

Cc: Christopher Ajayi, US EPA Region VIII 8P

- AR

Carson Coat , US EPA Region VIII, Montana OfficeOP2303

- 06 i Decision: 09/06/2011

Final: 10/07/2011 STATE OF MONTANA Department of Environmental Quality Helena, Montana 59620

AIR QUALITY OPERATING PERMIT OP 2303

- 06

Issued to: Roseburg Forest Products

Missoula Particleboard

P.O. Box 1088 Roseburg, OR 97470

Final Date: 10/07/2011 Expiration Date: 07/07/2013

Effective Date: 10/07/2011

Date of Decision: 09/06/2011

Application Deemed Technically Complete: 08/08/2011 Ap plication Deemed Administratively Complete: 08/08/2011

Administrative Amendment Application Received: 07/22/2011

AFS Number: 030

- 063

- 0002 A

Permit Issuance and Appeal Processes: In accordance with Montana Code Annotated (MCA) Sections

75

- 2

- 217 and 218 and the Administrative Rules of Montana (ARM), ARM Title 17, Chapter 8, Subchapter 12, Operating Permit Program, this operating permit is hereby issued by the Department of Environmental Quality (Department) as effective and final on October 7, 2011 . This pe rmit must be kept

on

- site at the above named facility.OP2303

- 06 ii Decision: 09/06/2011

Final: 10/07/2011 Montana Air Quality Operating Permit Department of Environmental Quality

SECTION I. GENERAL INFORMATION

................................ ................................ .......................... 1

SECTION II. SUMMARY OF EMISSION UNITS

................................ ................................ .......... 2

SECTION III. PERMIT CONDITIONS

................................ ................................ ............................. 3

A. F ACILITY

- W IDE

................................ ................................ ................................ .................... 3

B. EU001: P LANT

- W IDE

................................ ................................ ................................ ........... 6

C. EU002: #1 D RYER L INE 1 WITH N ATURAL G AS B ACK

- U P B URNER (DRY 100)

............... 12

EU003: #2 D RYER L INE 1 WITH N ATURAL G AS B ACK

- U P B URNER (DRY 101)

............... 12

EU004: #3 D RYER L INE 1 WITH N ATURAL G AS B ACK

- U P B URNER (DRY 102)

............... 12

EU005: #4 D RYER L INE 1 W ITH N ATURAL G AS B ACK

- U P B URNER (DRY 103)

............... 12

D. EU006: #5 D RYER L INE 2 WITH N ATURAL G AS B ACK

- U P B URNER (DRY 200)

............... 16

EU007: #6 D RYER L INE 2 WITH N ATURAL G AS B ACK

- U P B URNER (DRY 201)

............... 16

E. EU008: P REDRYER (DRY 500)

................................ ................................ ........................... 19

F. EU010: O UTSIDE T RUCK D UMP (BH 50)

................................ ................................ ........... 22

G. EU011: M ILLING AND D RYING (BH 55)

................................ ................................ ............. 24

H. EU012: R EJECT S YSTEM L INE 1 (BH 1 00)

................................ ................................ ......... 26

I. EU013: R EJECT S YSTEM R ELAY L INE 1 (BH 101)

................................ ............................. 2 8

EU046: P REDRY (BH 60)

................................ ................................ ................................ .... 28

J. EU014: 5 X 25 B OARD T RIMSAWS S YSTEM L INE 1 (BH 102)

................................ ............ 30

EU015: 5 X 16 B OARD T RIMSAWS S YSTEM (BH 103)

................................ ....................... 30

K. EU016: C ORE A IR S YSTEM L INE 2 (BH 201)

................................ ................................ ..... 33

EU017: F ACE A IR S YSTEM L INE 2 (BH 200)

................................ ................................ ...... 33

L. EU018: M AT T RIM S YSTEM L INE 2 (BH 202)

................................ ................................ .... 35

EU019: B OARD T RIM S YSTEM L INE 2 (BH 203)

................................ ................................ 35

M. EU020: B OARD & T RIM S YSTEM L INE 2 R ELAY (BH 204)

................................ ................ 38

N. EU021: S IX H EAD S ANDER (BH 300A & BH 300B)

................................ .......................... 40

O. EU023: S IX H EAD AND R EMAN F LATLINE R ELAY (BH 301)

................................ ............. 42

P. EU024: E IGHT H EAD S ANDER (BH 302 & BH 303)

................................ ........................... 44 Q. EU026: E IGHT H EAD S ANDER R ELAY (BH 304)

................................ ................................ 46

R. EU027: R EMAN F LAT L INE S ANDER R ELAY (BH 400)

................................ ...................... 48

S. EU028: S CHILLING & B ULLNOSE S AW & E DGE B ANDER L INE (BH 401)

......................... 50

T. EU029: S CHILLING AND B ULLNOSE S YSTEM R ELAY & E DGE B ANDER L INE (BH 404)

.... 52

U. EU055: M ELAMINE B AGHOUSE (BH500)

................................ ................................ ........... 54

V. EU030: P RESS V ENTS 1, 2, 3, 4 L INE 1 (PRESS 100)

................................ ......................... 56

W. EU0031: P RESS V ENTS 1, 2, 3, & 4 L INE 2 (PRESS 200)

................................ ................... 59

X. EU032: B OILER #1 (BOILER 1)

................................ ................................ ......................... 61

Y. EU033: R OEMMC B URNER (ROEMMC)

................................ ................................ ............ 64

Z. EU047: S OLAGEN B URNER (SOLAGEN)

................................ ................................ ........... 67

AA. EU035: L INE 2 O IL H EAT ER (GEKA)

................................ ................................ ................. 70

BB. EU056: R EGENERATIVE T HERMAL O XIDIZER

................................ ................................ .... 72

CC. EU036: O UTSIDE T RUCK D UMP (FUG 50)

................................ ................................ ......... 74

EU037: P ILE R ECLAIM (FUG 51)

................................ ................................ ....................... 74

EU0 38: R ADIAL S TACKER (FUG 52)

................................ ................................ .................. 74

DD. R EMANUFACTURING F ACILITY

................................ ................................ ........................... 76

EU050: B ULLNOSE F UGITIVES (FUG 400)

................................ ................................ ......... 76

EU051: P AINTLINE F UGITIVES (FUG 401)

................................ ................................ ......... 76

EE. EU048: L INE 1 B OARD C OOLER V ENTS 1, 2, AND 3

................................ ........................... 78

EU049: L INE 2 B OARD C OOLER V ENTS 1 AND 2

................................ ................................ 78OP2303

- 06 iii Decision: 09/06/2011

Final: 10/07/2011 SECTION IV. NON

- APPLICABLE REQUIREME NTS

................................ ................................ 80

A. F ACILITY

- W IDE

................................ ................................ ................................ .................. 80

B. E MISSION U NITS

................................ ................................ ................................ ................. 80

SECTION V. GENERAL PERMIT CONDI TIONS

................................ ................................ ....... 81

A. C OMPLIANCE R EQUIREMENTS

................................ ................................ ............................ 81

B. C ERTIFICATION R EQUIREMENTS

................................ ................................ ........................ 81

C. P ERMIT S HIELD

................................ ................................ ................................ ................... 82

D. M ONITORING

, R ECORDKEEPING

, AND R EPORTING R EQUIREMENTS

................................ .. 83

E. P ROMPT D EVIATION R EPORTING

................................ ................................ ........................ 84

F. E MERGENCY P ROVISIONS

................................ ................................ ................................ ... 84

G. I NSPECTION AND E NTRY

................................ ................................ ................................ ..... 85

H. F EE P AYMENT

................................ ................................ ................................ ..................... 85

I. M INOR P ERMIT M ODIFICATIONS

................................ ................................ ........................ 86

J. C HANGES N OT R EQUIRING P ERMIT R EVISION

................................ ................................ ... 86

K. S IGNIFICANT P ERMIT M ODIFICATIONS

................................ ................................ ............... 87

L. R EOPENING FOR C AUSE

................................ ................................ ................................ ...... 87

M. P ERMIT E XPIRATION AND R ENEWAL

................................ ................................ .................. 88

N. S EVERABILITY C LAUSE

................................ ................................ ................................ ...... 88

O. T RANSFER OR A SSIGNMENT OF O WNERSHIP

................................ ................................ ...... 88

P. E MISSIONS T RADING

, M ARKETABLE P ERMITS

, E CONOMIC I NCENTIVES

........................... 89 Q. N O P ROPERTY R IGHTS C ONVEYED

................................ ................................ ..................... 89

R. T ESTING R EQUIREMENTS

................................ ................................ ................................ ... 89

S. S OURCE T ESTING P ROTOCOL

................................ ................................ ............................. 89

T. M ALFUNCTIONS

................................ ................................ ................................ .................. 89

U. C IRCUMVENTION

................................ ................................ ................................ ................ 89

V. M OTOR V EHICLES

................................ ................................ ................................ .............. 89

W. A NNUAL E MI SSIONS I NVENTORY

................................ ................................ ....................... 89

X. O PEN B URNING

................................ ................................ ................................ ................... 89

Y. M ONTANA A IR Q UALITY P ERMITS

................................ ................................ ..................... 90

Z. N ATIONAL E MISSION S TANDARD FOR A SBESTOS

................................ .............................. 90

AA. A SBESTOS

................................ ................................ ................................ ........................... 90

BB. S TRATOSPHERIC O ZONE P ROTECTION

– S ERVICING OF M OTOR V EHICLE A IR
C ONDITIONERS

................................ ................................ ................................ ................... 91

CC. S TRATOSPHERIC O ZONE P ROTECTION

– R ECYCLING AND E MISSION R EDUCTIONS

.......... 91

DD. E MERGENCY E PISODE P LAN

................................ ................................ ............................... 91

EE. D EFINITIONS

................................ ................................ ................................ ....................... 91

APPENDIX A INSIGNIFICANT EMISSI ON UNITS

................................ ................................ ... A

- 1

APPENDIX B DEFINITIONS AND ABBR EVIATIONS

................................ .............................. B

- 1

APPENDIX C NOTIFICATION ADDRESS ES

................................ ................................ ............. C

- 1

APPENDIX D AIR QUALITY INSPECTO R INFORMATION

................................ .................. D

- 1

APPENDIX E COMPLIANCE ASSURANCE MONITORING (CAM)

................................ ..... E

- 1

APPENDIX F ROUTINE CON TROL DEVICE MAINTENA NCE EXEMPTION

................... F

- 1OP2303

- 06 1 Decis ion: 09/06/2011

Final: 10/07/2011 Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this permit have the meaning assigned to them in the referenced regulations.

SECTION I. GE NERAL INFORMATION

The following general information is provided pursuant to ARM 17.8.1210(1).

Company Name: Roseburg Forest Products

Mailing Address: P.O. Box 4007

City: Missoula State: MT Zip: 59806

Plant Name: Roseburg Missoula Particlebo ard

Plant Location: The facility is located at 3300 Raser Road, in Missoula, Montana. The legal description of the facility is Section 8, Township 13 North, Range 19 West, Missoula County, Montana.

Responsible Official (s) : Chuck Ulik Phone : (541 ) 6 79

- 3311 Grady Mulbery (541) 679

- 331

Mark Allen (406) 782

- 3910

Facility Contact Person: Ellen Porter Phone: (541) 679

- 2130

Primary SIC Code: 2493

Nature of Business: Particleboard Manufacturing

Description of Process: The facility p rocesses raw wood fiber into particleboard by refining the fiber, adding resin, and pressing the mat into boards. The raw material, primarily wood shavings from the planning process in sawmills, is transported to the facility by truck. The material is un loaded at the plant and moved by conveyor to the dryers and the press line, or out to the storage pile. The material is retrieved from the pile by front

- end loader and conveyed to the dryers and the press line. Approximately 50% of the plant production i s stored in this pile during the year. The wood fiber is then dried, blended with a resin, and introduced to the press line for particleboard production. Many baghouses and cyclones are used in the wood fiber handling systems. Sawdust and sander dust is used as fuel for the boiler and sander dust burners. This plant also contains a remanufacturing (reman) section, which processes the particleboard into finished wood that is used in furniture production. The reman section includes an edge banding line t hat utilizes an adhesive product to bind tape to the edge of the particleboard. In addition, this facility applies melamine to its manufactured particleboard. Melamine application involves placing a sheet of melamine paper on the top and bottom surfaces of a particleboard mat and pressing the paper and particleboard in a hot press. The melamine paper that overhangs the particleboard is then trimmed with a

saw.OP2303

- 06 2 Decis ion: 09/06/2011

Final: 10/07/2011 SECTION II. SUMMARY OF EMISSION UNITS

The emission units regulated by this permit are the fol lowing (ARM 17.8.1211):

Emissions

Unit ID Description Pollution Control Device/Practice

EU001 Plant

- Wide N/A

EU002 #1 Dryer Line 1 (DRY 100) Multiclone

EU003 #2 Dryer Line 1 (DRY 101) Multiclone

EU004 #3 Dryer Line 1 (DRY 102) Multiclone

EU005 #4 Dry er Line 1 (DRY 103) Multiclone

EU006 #5 Dryer Line 2 (DRY 200) Multiclone

EU007 #6 Dryer Line 2 (DRY 201) Multiclone

EU008 Predryer (DRY 500) Medium Efficiency Cyclone, WESP, and

RTO

EU010 Outside Truck Dump (BH 50) Baghouse

EU011 Milling and Drying ( BH 55) Baghouse

EU046 Predryer Storage Silo (BH 60) Baghouse

EU012 Reject System Line 1 (BH 100) Baghouse

EU013 Reject System Relay Line 1 (BH 101) Baghouse

EU014 5 X 25 Board Trimsaws System (BH 102) Baghouse

EU015 5 X 16 Board Trimsaws System (BH 103) Baghouse

EU016 Core Air System Line 2 (BH 201) Baghouse

EU017 Face Air System Line 2 (BH 200) Baghouse

EU018 Mat Trim System Line 2 (BH 202) Baghouse

EU019 Board Trim System Line 2 (BH 203) Baghouse

EU020 Board Trim System Line 2 Relay (BH 204) B aghouse

EU021 Six Head Sander System (BH 300A & BH 300B) Two Baghouses

EU023 Six Head and Reman Flatline Relay (BH 301) Baghouse

EU024 Eight Head Sander System (BH 302 & BH 303) Two Baghouses

EU026 Eight Head Sander Relay (BH 304) Baghouse

EU027 Reman Flat Line Sander Relay (BH 400) Baghouse

EU028 Schilling & Bullnose Saw and Edge Bander Line (BH 401) Baghouse

EU029 Schilling & Bullnose System Relay and Edge Bander Line (BH 404) Baghouse

EU055 Melamine Baghouse (BH 500) Baghouse

EU030 Press Vents 1 , 2, 3, & 4 Line 1 (PRESS 100) Biofilter

EU048 Line 1 Board Cooler Vents 1, 2, & 3 (L1BCV1, L1BCV2, & L1BCV3) None

EU031 Press Vents 1, 2, 3, & 4 Line 2 (PRESS 200) Biofilter

EU049 Line 2 Board Cooler Vents 1 & 2 (L2BCV1 & L2BCV2) None

EU032 Boiler #1 (BOILER #1) Multiclone

EU033 Roemmc Burner (ROEMMC) Multiclone

EU047 Solagen Burner (SOLAGEN) Medium Efficiency Cyclone and WESP

EU035 Line 2 Oil Heater (GEKA 200) None

EU056 Regenerative Thermal Oxidizer (RTO) None

EU036 Outside Truck Dump (FUG 50) C over
EU037 Pile Reclaim (FUG 51) None

EU038 Radial Stacker (FUG 52) None

EU050 Bullnose Fugitives (FUG 400) None

EU051 Paintline Fugitives (FUG 401) NoneOP2303

- 06 3 Decis ion: 09/06/2011

Final: 10/07/2011 SECTION III. PERMIT CONDITIONS

The following requirements and conditions are applicable to the facility or to specific emission units located at the facility (ARM 17.8.1211, 1212, and 1213).

A. Facility

- Wide

Conditions Rule Citation Rule Description Pollutant/Parameter Limit

A.1 ARM 17.8.105 Testing Requirements Testing Requirements

------- A.2 ARM 17.8.304(1) Visible Air Contaminants Opacity 40%

A.3 ARM 17.8.304(2) Visible Air Contaminants Opacity 20%

A.4 ARM 17.8.308(1) Particulate Matter, Airborne Fugitive Opacity 20%

A.5 ARM 17.8.308(2) Particulate Matter, Airborne Reasonable Precautions

---- ---

A.6 ARM 17.8.308 Particulate Matter, Airborne Reasonable Precaution,

Construction 20%

A.7 ARM 17.8.309 Particulate Matter, Fuel Burning Equipment Particulate Matter E= 0.882 * H
- 0.1664 Or

E= 1.026 * H
- 0.233

A.8 ARM 17.8.310 Particulate Matter, Indu strial

Processes Particulate Matter E= 4.10 * P 0.67 or E= 55 * P 0.11

- 40

A.9 ARM 17.8.322(4) Sulfur Oxide Emissions, Sulfur in

Fuel Sulfur in Fuel (liquid or solid fuels) 1 lb/MMBtu fired

A.10 ARM 17.8.322(5) Sulfur Oxide Emissions, Sulfur in

Fuel Sulfur in Fuel (gaseous) 50 gr/100 CF

A.11 ARM 17.8.324(3) Hydrocarbon Emissions,

Petroleum Products Gasoline Storage Tanks

-------

A.12 ARM 17.8.342 NESHAPs General Provisions SSM Plans Submittal

A.13 Chapter 32 of the

State of Montana Air Quality

Control

Im plementation Plan (Chapter 4 of the Missoula City

County Air

Pollution Control Program) Missoula County’s Emergency

Episode Plan Emergency Episodes Reduce emissions in

accordance with each stage of the emergency episode avoidance plan

A.1 4 ARM 17.8.749 Co nditions for Issuance of Permit Recordkeeping

----- A.15 ARM 17.8.1212 Reporting Requirements Compliance Monitoring

------- A.16 ARM 17.8.1207 Reporting Requirements Annual Certification

-------

Conditions

A.1. Pursuant to ARM 17.8.105, any person or perso ns responsible for the emission of any air contaminant into the outdoor atmosphere shall, upon written request of the Department, provide the facilities and necessary equipment (including instruments and sensing devices) and shall

conduct test s , emission o r ambient, for such periods of time as may be necessary using methods approved by the Department.

Compliance demonstration frequencies that list “as required by the Department” refer to ARM 17.8.105. In addition, for such sources, compliance with limits and conditions listing “as required by the Department” as the frequency, is verified annually using emission factors and engineering calculations by the Department’s compliance inspectors during the annual emission inventory review; in the case of Method 9 tests, compliance is monitored during the regular inspection by the compliance inspector.

A.2. Pursuant to ARM 17.8.304(1), Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source installed on or before Nov ember 23, 1968, that exhibit an opacity of 40% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit.OP2303

- 06 4 Decis ion: 09/06/2011

Final: 10/07/2011 A.3. Pursuant to ARM 17.8.304(2), Roseburg shall not cause or authorize emissions to be discharged

into the outd oor atmosphere from any source installed after November 23, 1968, that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit.

A.4. Pursuant to ARM 17.8.308(1), Roseburg shall not cause or authorize the production, handling, transportation, or storage of any material unless reasonable precautions to control emissions of particulate matter are taken. Such emissions of airborne particulate matter from any stationary

source shall not exhibit an opacity of 20% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit.

A.5. Pursuant to ARM 17.8.308(2), Roseburg shall not cause or authorize the use of any street, road or parking lot without taking reasonable precautions to control emissions of airborne particulate matter, unless otherwise specified by rule or in this permit.

A.6. Pursuant to ARM 17.8.308, Roseburg shall not operate a construction site or demolition project unless reasonable precautions are taken to control emissions of airborne particulate matter. Such emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit.

A.7. Pursuant to ARM 17.8.309, unless otherwise specified by rule or in this permit, Roseburg shall not cause or authorize particulate matter caused by the combustion of fuel to be discharged from any stack or chimney into the outdoor atmosphere in ex cess of the maximum allowable emissions of particulate matter for existing fuel burning equipment and new fuel burning equipment calculated using the following equations:

For existing fuel burning equipment (installed before November 23, 1968):

E =0.882 * H
- 0.1664

For new fuel burning equipment (installed on or after November 23, 1968):

E =1.026 * H
- 0.233

Where H is the heat input capacity in million BTU (MMBtu) per hour and E is the maximum allowable particulate emissions rate in pounds per MMBtu.

A.8. Pur suant to ARM 17.8.310, unless otherwise specified by rule or in this permit, Roseburg shall not cause or authorize particulate matter to be discharged from any operation, process, or activity into the outdoor atmosphere in excess of the maximum hourly allo wable emissions of particulate matter calculated using the following equations:

For process weight rates up to 30 tons per hour: E = 4.10 * P 0.67
For process weight rates in excess of 30 tons per hour: E = 55.0 * P 0.11

– 40

Where E = rate of emissions i n pounds per hour and p = process weight rate in tons per hour.

A.9. Pursuant to ARM 17.8.322(4), Roseburg shall not burn liquid or solid fuels containing sulfur in excess of 1 pound per million BTU fired, unless otherwise specified by rule or in this permit.

A.10. Pursuant to ARM 17.8.322(5), Roseburg shall not burn any gaseous fuel containing sulfur compounds in excess of 50 grains per 100 cubic feet of gaseous fuel, calculated as hydrogen sulfide at standard conditions, unless otherwise specified by rule or in th is permit.OP2303

- 06 5 Decis ion: 09/06/2011

Final: 10/07/2011 A.11. Pursuant to ARM 17.8.324(3), Roseburg shall not load or permit the loading of gasoline into any stationary tank with a capacity of 250 gallons or more from any tank truck or trailer, except through a permanent submerged fill pipe, unless such t ank is equipped with a vapor loss control device or is a pressure tank as described in ARM 17.8.324(1), unless otherwise specified by rule or in this permit.

A.12. Pursuant to ARM 17.8.342 and 40 CFR 63.6, Roseburg shall submit to the Department a copy of

any s tartup, shutdown, and malfunction (SSM) plan required under 40 CFR 63.6(e)(3) within 30 days of the effective date of this operating permit (if not previously submitted), within 30 days of the compliance date (or approved compliance extension date) of any new National Emission Standard for Hazardous Air Pollutants (NESHAPs) or Maximum Achievable Control Technology (MACT) standard, and within 30 days of the revision of any such SSM plan, when applicable. The Department requests submittal of such plans in el ectronic form, when possible.

A.13. Roseburg shall comply with the requirements contained in Chapter 4 of the Missoula City

- County Air Pollution Control Program (Chapter 32 of the State of Montana Air Quality Control Implementation Plan) with regard to emergenc y episodes.

A.14. All records compiled in accordance with this permit must be maintained by Roseburg as a permanent business record for at least 5 years following the date of measurement. The records must be available at the plant site for inspection by the De partment and must be submitted to the Department upon request (ARM 17.8.1212).

A.15. On or before February 15 and August 15 of each year, Roseburg shall submit to the Department the compliance monitoring reports required by Section V.D. These reports must cont ain all information required by Section V.D, as well as the information required by each individual emissions unit. For the reports due by February 15 of each year, Roseburg may submit a single report, provided that it contains all the information require d by Section V.B & V.D. Per ARM 17.8.1207,

any application form, report, or compliance certification submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including semiannual monitoring reports), shall contain certification by a responsible off

icial of truth, accuracy and completeness. This certification and any other certification required under ARM Title 17, Chapter 8, Subchapter 12, shall state that, “based on information and belief formed after reasonable inquiry, the statements and informa tion in the document are true, accurate and complete.”

A.16. By February 15 of each year, Roseburg shall submit to the Department the compliance certification required by Section V.B. The annual certification required by Section V.B must

include a statement of compliance based on the information available which identifies any observed, documented or otherwise known instance of noncompliance for each applicable requirement. Per ARM 17.8.1207,

any application form, report, or compliance certification submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12 (including annual certifications), shall contain certification by a responsible official of truth, accuracy and completeness. This certification and any other certification required under ARM Title 17, Ch apter 8, Subchapter 12, shall state that, “based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete.”OP2303

- 06 6 Decis ion: 09/06/2011

Final: 10/07/2011 B. EU001: Plant

- Wide

Condition(s) Pollutant/Parameter Permit Limit Co mpliance Demonstration Method Frequency Reporting Requirements

B.1, B.1 6

, B.30,
B.31, B.34, B.35, B.36 Opacity 20% Visual Surveys Weekly Semiannual

Method 9 Semiannual (if

visual surveys

are not
conducted as specified) Semiannual

B.2, B.1 7

, B .32, B.35, B.36 Line 1 Hours of Operation 8

, 500 Hours During any Rolling 12

- Month Period Recordkeeping Ongoing Semiannual

B.3, B.1 8

, B.32, B.35, B.36 Line 2 Production 75 MMft 2 of 3⁄4”

Particle Board During any Rolling

12

- Month Period Recordkeeping Ongoing Semiannual

B.4, B. 19

, B.32, B.35, B.36 Control Equipment Install, Operate, and

Maintain Recordkeeping Month l y Semiannual

B.5, B.2 0

, B.32, B.35, B.36 Sander Dust Handling Systems Enclosed and

Equipped with a Baghouse Recordkeeping Monthly Semiannual

B. 6

, B. 21

, B.32, B.35, B.36 Fugitive Emissions Apply Paving or Dust Suppressant Recordkeeping Monthly Semiannual

B. 7 , B.2 2

, B.32, B.35, B.36 Contaminated Floor Sweepings Not Stored Outside ;

Material stored in

contaminated floor sweepings building

limited to 5 0 units (370 cubic yards) Recordkeeping Monthly Semiannual

B. 8 , B.2 3

, B.32, B.35, B.36 Fugitive Emissions Plant and Maintain Vegetation on

Earthen Berm Recordkeeping Monthly Semiannual

B. 9 , B.2 4

, B.32, B.35, B.36 Total Particulate

Emissions from the Raw Materials Storage Pile 928 lb/day and 30 ton/yr Calculate

Using Equation Daily and

Semiannual Semiannual

B.1 0 , B.2 4

, B.32, B.35, B.36 PM 10 Emissions from the

Raw Materials Storage

Pile 334 lb/day and 9.9 ton/yr Calculate

Using Equation Daily and

Semiannua l Semiannual

B.1 1 , B.2 5

, B.32, B.35, B.36 Raw Material Received

and Operation of Truck Dump(s) Keep Daily Records

of Total Bone

- Dry

Tons of Raw

Material Received and Records of Any Days When Either Truck Dump is Not Operating Recordkeeping Daily Semiannua l

B.1 2 , B.2 6

, B.32, B.35, B.36 Fugitive Emissions Install and Maintain

Enclosures with Curtained Openings

on the Line 2 Fire Dump and the Line 2 Reject Dump Recordkeeping Monthly Semiannual

B.1 3 , B.2 7

, B.32, B.35, B.36 Collection Efficiency of

the Truck Dump Baghouse Install and Maintain a

Cover Over the Lift

Portion of the Outside Truck Dump Recordkeeping Monthly Semiannual

B.1 4 , B.2 8, B.32, B.35, B.36 Fugitive Dust Emissions Install and Maintain a

Cover Over the Reclaim Hopper Recordkeeping Monthly Sem iannual

B.15, B.29, B.33, B.35, B.36 Hazardous Air Pollutants 40 CFR 63, Subparts

A and DDDD 40 CFR 63,

Subparts A and

DDDD 40 CFR 63,

Subparts A and

DDDD SemiannualOP2303

- 06 7 Decis ion: 09/06/2011

Final: 10/07/2011 Conditions

B.1. Roseburg shall not cause or authorize emissions to be discharged into the ou tdoor atmosphere, from any stack or vent, that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)).

B.2. Line 1 shall be limited to a total of 8,500 hours of operation during any rolling 12

- month period (ARM 17.8.749).

B.3. L ine 2 production shall be limited to 75

- million square feet (MMft 2 ) of 3⁄4

- inch particleboard during any rolling 12

- month period (ARM 17.8.749).

B.4. Roseburg shall install, operate, and maintain control equipment as specified in the application for

Montana Air Quality Permit (MAQP) #2303

- 07 (ARM 17.8.749).

B.5. All sander dust

- handling systems are to be enclosed and equipped with baghouse control. No outside storage of sander dust shall be allowed (ARM 17.8.749).

B.6. Paving or a dust suppressant shall be applied to al l routinely used haul roads within the plant area. If a dust suppressant is used, it shall be reapplied at least once per year. Additional applications of dust suppressant may be required if fugitive dust exceeds 20% opacity at any time (ARM 17.8.308).

B.7. Contaminated floor sweepings may not be stored outside. Material stored in the contaminated floor sweepings building shall be limited to no more than 50 units (370 cubic yards (yd 3 ) ) (ARM 17.8.749).

B.8. Roseburg shall plant and maintain vegetation on the sid es and trees along the top of the earthen berm constructed around the raw material pile to reduce dust emissions. Sufficient dust control measures shall be applied to the storage pile to ensure that the visible emissions from the storage pile do not exhib it an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.749).

B.9. Fugitive particulate emissions from the raw material storage pile, including unloading, conveying to the pile, and transfer back to the mill, shall not exceed 928

- pounds p er day ( lb/day ) daily

maximum and 30 tons per year ( TPY ) for total particulate emissions (PM) (ARM 17.8.749).

B.10. Fugitive particulate emissions from the raw material storage pile, including unloading, conveying to the pile, and transfer back to the mill, sha ll not exceed 334

- lb/day daily maximum and 9.9 TPY

for particulate matter with an aerodynamic diameter of 10 microns or less ( PM 10 ) (ARM 17.8.749)

.

B.11. Roseburg shall keep daily records of the total bone

- dry tons (BDT) of raw material received at the

Missoula plant. Roseburg shall also keep records of any days when either truck dump is not operating for any reason (ARM 17.8.749).

B.12. Roseburg shall install and maintain enclosures with curtained openings on the Line 2 Fire Dump and the Line 2 Reject Dump to redu ce fugitive emissions (ARM 17.8.749).

B.13. Roseburg shall install and maintain a cover over the lift portion of the outside truck dump to increase the collection efficiency of the truck dump baghouse (ARM 17.8.749).

B.14. Roseburg shall install and maintain a cover over the reclaim hopper to reduce fugitive dust emissions (ARM 17.8.749).OP2303

- 06 8 Decis ion: 09/06/2011

Final: 10/07/2011 B.15. By October 1, 2008, Roseburg shall comply with all applicable standards and limitations, and the reporting, recordkeeping

, monitoring, and notification requirements of 40 CFR 63, S ubpart A, General Provisions, and Subpart DDDD, National Emissions Standards for Hazardous Air

Pollutants : Plywood and Composite Wood Products (ARM 17.8.342 and 40 CFR 63, Subparts A and DDDD).

Compliance Demonstration

B.16. Once per calendar week during dayli ght hours, Roseburg shall visually survey emissions from the Emitting Unit for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity. The

perso n conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of excessive emissions ar e identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance . The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual su rveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible emissions from the affected unit. Method 9 source tests must be performed in accordanc e with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observ ation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

B.17. Roseburg shall document, by month, the hours of operation of Line 1 . B y the 25 t h day of each month, Roseburg shall total the hours of operation of Line 1 during the previous month. The monthly information will be used to verify compliance with the rolling 12

- month limitation

contained in Section III.B.2. The information for each of the previous months shall be submitted along with the annual emission inventory (ARM 17.8.749 and ARM 17.8.1213 ).

B.18. Roseburg shall document, by month, the production of 3⁄4

- inch particleboard from Line 2 . B y the

25 th day of each month, Roseburg shall total the production of 3⁄4

- inch particleboard from Line 2 during the previous month. The monthly information will be used to verify compliance with the rolling 12

- month limitation contained in Section III.B.3. The information for each of the previous months sha ll be submitted along with the annual emission inventory (ARM 17.8.749 and

ARM 17.8.1213 ).

B.19. Roseburg shall monitor compliance with Section III.B.4 by documenting, monthly, that the control equipment specified in the application for MAQP #2303

- 07 is install ed, operated, and

maintained . The records shall include all repair and maintenance activity to the control equipment . The records must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance (ARM 17.8.1213).

B.20. Roseb urg shall monitor compliance with Section III.B.5 by documenting any instance in which

any of the sander dust

- handling systems were not enclosed or equipped with a baghouse and any

instance in which sander dust was stored outside. Records must include the date and

circumstance (ARM 17.8.1213).OP2303

- 06 9 Decis ion: 09/06/2011

Final: 10/07/2011 B.21. Roseburg shall monitor compliance with Section III.B.6 by documenting, monthly, all paving and dust suppressant applications conducted within the plant area, including the date actions were

taken (ARM 17.8.1213).

B.22. Roseburg shall monitor compliance with Section III.B.7 by documenting, monthly, any instance

in which contaminated floor sweepings were stored outside and any instance in which the amount of material stored in the contaminated floor sweepings building exce ed ed 370 yd 3 at any one time (ARM 17.8.1213).

B.23. Roseburg shall monitor compliance with Section III.B.8 by documenting, monthly, that vegetation has been planted and is being maintained along the earthen berm to reduce fugitive

dust. The records shall inclu de all maintenance activities performed, including the date of any

actions taken. Furthermore, Roseburg shall document, monthly, all dust control measures that

have b een applied to the storage pile, including the date of application (ARM 17.8.1213).

B.24. Rose burg shall monitor compliance with Section s III.B. 9 and III.B.1 0 by using the following equation (ARM 17.8.749):

E = 0.50 (I) (e) (0.33[1

- n td ] + 0.33[1

- n rs ] + 0.33[1

- n rp ])

Where: E = Total fugitive emissions from the raw material pile in pounds (lb);

I = Total raw material delivered to plant in BDT;

e = PM 10 emission factor of 0.36 pound per ton (lb/ton), or a PM emission factor of 1.0 lb/ton;

n td = Control efficiency at the outdoor truck dump expressed as a ratio (i.e. 99% = 0.99);

n rs = Control efficienc y at the radial stacker expressed as a ratio; and

n rp = Control efficiency at the pile reclaim expressed as a ratio.

Notes :

a. The control efficiencies, as revised in MAQP #2303

- 07 , are as follows:

Control Description Efficiency Controls

Outdoor t ruck dump 99% Covered surge bin and trailer lift with baghouse system

Pile reclaim 50% Covered hopper and earthen berm

Radial stacker 50% Reduced drop height and berm

b. The 0.33 is utilized to account for different control efficiencies at each emission po int within the process, assuming that 1/3 of the emissions originate from the truck dump, 1/3 of the emissions originate from the pile reclaim, and 1/3 of the emissions originate from the radial stacker. The constant of 0.50 at the beginning of the equati on is utilized because approximately 50% of the raw material passes through the outside truck dump and the outdoor pile.

c. If the inside truck dump is shut down, or not otherwise used for an entire day, the constant of 0.50 shall be replaced with a constant of 1.00 to determine compliance for that day.

d. If the inside truck dump is shut down, or otherwise not used for one or more entire days, compliance with the annual average limitation shall be determined as follows:

i. Calculate the allowable emissions for th e days when the inside truck dump is shut down using the associated raw material deliver y data and the constant of
1.00;OP2303

- 06 10 Decis ion: 09/06/2011

Final: 10/07/2011 ii. Calculate the allowable emissions for the days when the inside truck dump is operated using the associated raw material delivery data and the constant of 0.50 ; and

iii. Add (i) and (ii) above.

B.25. Roseburg shall monitor compliance with Section III.B.11 through recordkeeping as described in

Section III.B.11 (ARM 17.8.121 3 ).

B.26. Roseburg shall monitor compliance with Section III.B.12 by documenting, monthly, that the enclosures with curtained openings have been installed and maintained on the Line 2 Fire Dump and the Line 2 Reject Dump . The Records shall include all maintenance activity conducted on the Line 2 Fire Dump and the Line 2 Reject Dump

. The records must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance (ARM 17.8.121 3 ).

B.27. Roseburg shall monitor compliance with Section III.B.13 by documenting, monthly, that the cover over the lift portion of the outside truck dump has been installed and maintained to increase the collection efficiency of the truck dump baghouse . The records shall contain all maintenance

activities conducted on the cover over the lift portion of the outside truck dump

. The record s must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance (ARM 17.8.121 3 ).

B.28. Roseburg shall monitor compliance with Section III.B.14 by documenting, monthly, that the cover over the reclaim hopper has been instal led and maintained to reduce the fugitive dust

emissions . The records shall contain all maintenance activities conducted on the cover over the reclaim hopper

. The records must include, but are not limited to, the date, time, and action(s) taken for repai r and maintenance (ARM 17.8.1213).

B.29. Roseburg shall monitor comp liance with Section III.B.15 as required by 40 CFR 63, Subpart A, General Provisions, and Subpart DDDD, National Emissions Standards for Hazardous Air

Pollutants : Plywood and Composite Wood Pro ducts (ARM 17.8.342 and 40 CFR 63, Subparts A and DDDD).

Recordkeeping

B.30. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log sh all include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

B.31. All compliance source test recordkeeping shall be performed in accordance with the test method

used and the Montana Source Test Protoc ol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

B.32. Roseburg shall maintain the records required by Section III.B.11 and III.B.17

– III.B.28 on site and submit the information to the Department upon request (ARM 17. 8.1212).

B.33. Roseburg shall maintain all applicable recordkeeping requirements as required by 40 CFR 63, Subpart A, General Provisions, and Subpart DDDD, National Emissions Standards for Hazardous

Air Pollutants : Plywood and Composite Wood Products (ARM 17.8. 342 and 40 CFR Part 63, Subparts A and DDDD).OP2303

- 06 11 Decis ion: 09/06/2011

Final: 10/07/2011 Reporting

B.34. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

B.35. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

B.36. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted during the la st reporting period;

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log;

c. Reports of any required monitoring performed during the reporting period, with all instance s of deviations from any permit requirements identified; and

d. Certification of compliance with 40 CFR 63, Subparts A and DDDD.OP2303

- 06 12 Decis ion: 09/06/2011

Final: 10/07/2011 C. EU002: #1 Dryer Line 1 with Natural Gas Back

- Up Burner (DRY 100) EU003: #2 Dryer Line 1 with Natural Gas Back

- Up Burner (DRY 101 ) EU004: #3 Dryer Line 1 with Natural Gas Back

- Up Burner (DRY 102) EU005: #4 Dryer Line 1 with Natural Gas Back

- Up Burner (DRY 103)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

C .1, C. 10

, C.1 6 , C.1 7

, C. 20

, C. 21

, C. 22 Opacity 20% Visual Surveys Weekly Semiannual

Method 9 Semiannual (if

visual surveys

are not
conducted as specified) Semiannual

C.2, C.3, C.11

, C.1 7 , C. 20

, C. 21 , C. 22 Total Particulate Matter

DRY 100 4.9 lb/hr

Met hod 5 Every 5 Years Semiannual Total Particulate Matter

DRY 101 4.7 lb/hr

Total Particulate Matter

DRY 102 4.9 lb/hr

Total Particulate Matter

DRY 103 4.9 lb/hr

C.4, C.5, C. 1 2

, C.1 7 , C. 20

, C. 21 , C. 22 PM 10 - DRY 100 4.9 lb/hr

Method 201A Ever y 5 Years Semiannual

PM 10 - DRY 101 4.7 lb/hr

PM 10 - DRY 102 4.9 lb/hr

PM 10 - DRY 103 4.9 lb/hr

C. 6

, C.13,
C.18, C.21,

C.22 Furnish Inlet M o isture

C ontent 24

- hour block

average of less than or equal to 30% (by weight, dry basis) 40 CFR 63

,

Subpart DDDD 40 CFR 63,

Subpart DDDD Semiannual

C. 7

, C.13, C.18, C.21,

C.22 Inlet D ryer Temperature 24

- hour block average of less than or equal to 600  ̊F 40 CFR 63,

Subpart DDDD 40 CFR 63,

Subpart DDDD Semiannual

C. 8 , C.1 4

, C.1 9 , C

. 21

, C. 22 Particulate Emissions Operate and

Maintain

Multiclones Recordkeeping Monthly Semiannual

C. 9 , C.1 5

, C.19 , C. 21,

C.22 Temperature Sensors with

Remote Readout and

Audible Alarm Install and Operate Recordkeeping Monthly Semiannual

Conditions

C.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.752).

C.2. Emissions of total particulate matter from DRY100, DRY102, and DRY103 shall e ach be limited

to a maximum of 4.9 pounds per hour ( lb/hr ) (ARM 17.8.749).

C.3. Emissions of total particulate matter from DRY 101 shall be limited to a maximum of 4.7 lb/hr (ARM 17.8.749).

C.4. Emissions of PM 10 from DRY100, DRY102, and DRY103 shall each be limit ed to a maximum of 4.9 lb/hr (ARM 17.8.749).

C.5. Emissions of PM 10 from DRY101 shall be limited to a maximum of 4.7 lb/hr (ARM 17.8.749).OP2303

- 06 13 Decis ion: 09/06/2011

Final: 10/07/2011 C.6. Roseburg must process furnish with a 24

- hour block average inlet moisture content of less than or equal to 30% (by weight , dry basis) (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

C.7. Roseburg shall operate the dry rotary dryers with a 24

- hour block average inlet dryer temperature of less than or equal to 600  ̊ F (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

C.8. Each dryer shall be equ ipped with multiclone control that is operated and maintained to meet the appropriate emission limit as specified in Sections III.C.2, III.C.3, III.C.4, and III.C.5 (ARM 17.8.752).

C.9. Roseburg shall install and operate temperature sensors at the inlet of the dryers . The temperature sensors shall have a remote readout and audible alarm. The alarm system shall be audible to the dryer operator and the operator(s) of all three combustion units. The alarm system shall become activated when exhaust gas exceeds 1 ,100 degrees Fahrenheit ( oF ) . Data from the temperature sensors shall be maintained for a period of at least 5 years and shall be available to the Department upon request (ARM 17.8.749).

Compliance Demonstration

C.10. Once per calendar week during daylight ho urs, Roseburg shall visually survey emissions from the

combined stack emissions ( which vents DRY100, DRY101, DRY102, and DRY103, and may

vent BH200 and BH201 ) for any sources of excessive emissions. For the purpose of this survey,

excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then R oseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not reliev e Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emiss ions from the combined stack. Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 mi nutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213)

.

C.11. Roseburg shall m onitor compliance with Sections III.C.2 and III.C.3 by conduct ing EPA Method 5 source testing on the combined stack emissions of DRY100, DRY101, DRY102, and DR Y103 ( and BH200 and BH201 if Roseburg chooses to vent the baghouses through th e combined stack ) to determine the total particulate matter emissions from the stack. The test results shall be used to monitor compliance with the sum total particulate matter mass emission limits of all of the operating sources vented to the stack at th e time of the compliance source test. The testing and compliance monitoring of the combined stack emissions shall take place at least once every 5 years, or according to another testing/monitoring schedule as may be approved by the Department.

Source tes ting that is conducted without all sources vented to the combined stack will not relieve Roseburg of complying with the source testing frequency for each of those individual units not venting to the combined stack during the time of the test. The source t ests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).OP2303

- 06 14 Decis ion: 09/06/2011

Final: 10/07/2011 C.12. Roseburg shall monitor compliance with Sections III.C.4 and III.C.5 by conduct ing EPA Method

2 01A source testing on the combined stack emissions of DRY100, DRY101, DRY102, and

DRY103 ( and BH200 and BH201 if Roseburg chooses to vent the baghouses through the

combined stack ) to determine the PM 10 emissions from the stack. Method 5 results may be use d as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The test results shall be used to monitor compliance with the sum total PM 10 mass emission limits of all of the operating sources vented to the stack at the time of the complian ce source test. The testing and compliance monitoring of the combined stack emissions shall take place at least once every 5 years, or according to another testing/monitoring schedule as may be approved by the Department. Source testing that is conducted without all sources vented to the combined stack will not relieve Roseburg of complying with the source testing frequency for each of those individual units not venting to the combined stack during the time of the test. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

C.13. Roseburg shall monitor compliance with Section III. C.6 and III.C.7 as required by 40 CFR 63, Subpart DDDD, National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

C.14. Roseburg shall monitor compliance with Section III.C. 8 by documenting, monthly, that the multiclones are operated and maintai ned on each dryer to meet the emission limits as specified in Section III.C.2, III.C.3, III.C.4, and III.C.5 . The records shall include all repair and maintenance activity to the multiclones. The records must include, but are not limited to, the date, ti me, and action(s) taken for repair and maintenance (ARM 17.8.1213).

C.15. Roseburg shall monitor compliance with Section III.C. 9 by documenting, monthly, that the temperature sensors are installed and operated at the inlet of the dryers, that the temperature

se nsors have a remote readout and audible alarm that is audible to the dryer operator and the operator(s) of all three combustion units , and that the alarm system is operational and programmed to activate if the dryer inlet temperature exceeds 1,100 oF. The records shall include all repair and maintenance activity to the system. The records must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance (ARM 17.8.1213).

Recordkeeping

C.16. If weekly visual surveys are perform ed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

C.17. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

C.18. Roseburg shall m aintain all applicable recordkeeping requirements as required by 40 CFR 63, Subpart DDDD, National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

C.19. Roseburg shall maintain the records required by Sections III.C. 1 4 and III.C. 1 5 on site and submit the information to the Department upon request (ARM 17.8.1212).OP2303

- 06 15 Decis ion: 09/06/2011

Final: 10/07/2011 Reporting

C.20. Any compliance source test reports must be submitted in accordance with the Montana Source

Test Protocol an d Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

C.21. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

C.22. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted during the last reporting period;

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log;

c. Reports of any required monitoring performed during the reporting period, with all instances of deviations from any permit requirements identified ; and

d. Certification of compliance with 40 CFR 63, Subpart DDDD.OP2303

- 06 16 Decis ion: 09/06/2011

Final: 10/07/2011 D. EU006: #5 Dryer Line 2 with Natural Gas Back

- Up Burner (DRY 200) EU007: #6 Dryer Line 2 with Natural Gas Back

- Up Burner (DRY 201)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

D.1 , D.9, D.16,
D.17, D .20

, D. 21 , D. 22 Opacity 20 % Visual Surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

D. 2, D. 10

, D.1 7 , D

. 20

, D. 21 , D. 22 Total Particulate Matter 6.0 lb/hr Method 5 Every 5 Years Semiannual

D.3 , D. 11

, D. 1 7 , D

. 20

, D. 21 , D. 22 PM 10 6 .0 lb/hr Method 201A Every 5 Years Semiannual

D.4, D.12,
D.18, D.21,

D.22 Furnish Inlet Moisture

Content 24

- hour block

average of less than or equal to 30% (by weight, dry basis) 40 CFR 63,

Subpart DDDD 40 CFR 63,

Subpart DDDD Semiannual

D.5, D.12,

D.18 , D.21,

D.22 Inlet Dryer Temperature 24

- hour block average of less than or equal to 600  ̊F 40 CFR 63,

Subpart DDDD 40 CFR 63,

Subpart DDDD Semiannual

D. 6 , D.1 3

, D.1 9 , D

. 21

, D. 22 Particulate Emissions Operate and

Maintain

Multiclones Recordkeeping Monthly Semiannual

D. 7 , D.1 4

, D.1 9 , D. 21

, D. 22 Temperature Sensors with

Remote Readout and

Audible Alarm Install and Operate Recordkeeping Monthly Semiannual

D. 8 , D.1 5

, D.1 9 , D. 21

, D. 22 Combined Production 168,000 BDT per Rolling 12

- Month

Period Recordkeeping Monthly Semiannual

Conditions

D.1. Rosebu rg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.752).

D.2. Emissions of total particulate matter from the Line 2 dry ers shall each be limited to a maximum of 6.0 lb/hr (ARM 17.8.749).

D.3. Emissions of PM 10 from the Line 2 dryers shall each be limited to a maximum of 6.0 lb/hr (ARM 17.8.749).

D.4. Roseburg must process furnish with a 24

- hour block average inlet moisture content of less than or equal to 30% (by weight, dry basis) (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

D.5. Roseburg shall operate the dry rotary dryers with a 24

- hour block average inlet dryer temperature of less than or equal to 600  ̊ F (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

D.6. Each dryer shall be equipped with multiclone control that is operated and maintained to meet the emission limits specified in Section III.D.2 and III.D.3 (ARM 17.8.752).OP2303

- 06 17 Decis ion: 09/06/2011

Final: 10/07/2011 D.7. Roseburg shall install and operate a temperature sensor at the inlet of each dryer . The temperature sensors shall have a remote readout and audible alarm. The alarm system shall be audible to the Line 2 Dryer operators. The alarm system shall become activated when exhaust gas exceeds 1,100 oF. Data from the temperature sensors shall be maintained for a period of at least 5 years and shall be available to the Department upon request (ARM 17.8.749).

D.8. The combined production from the two line 2 dryers shall not exceed 168,000 BDT per rolling 1 2

- month period (ARM 17.8.749).

Compliance Demonstration

D.9. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack s of each of the Line 2 dryers for any sources of excessive emissions. For the purpose of this

s urvey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or

minimize the source of emissions. If corre ctive actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 so urce test for the visible emissions from each of the Line 2 dryer stacks. Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter per iod of time (ARM 17.8.106 and ARM 17.8.1213).

D.10. Roseburg shall monitor compliance with Section III.D.2 by conduct ing EPA Method 5 source testing on the stack emissions of each Line 2 dryer to determine the total particulate matter

emissions from the stack s

. The testing and compliance monitoring of emissions from each stack shall take place at least once every 5 years, or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

D.11. Roseburg shall monitor compliance with Section III.D.3 by conduct ing EPA Method 201A source testing on the stack emissions of each Line 2 dryer to determine the PM 10 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from each stack shall take place

at l east once every 5 years, or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require ad ditional testing (ARM 17.8.1213).

D.12. Roseburg shall monitor compliance with Section III. D .4 and III. D .5 as required by 40 CFR 63, Subpart DDDD, National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).OP2303

- 06 18 Decis ion: 09/06/2011

Final: 10/07/2011 D.13. Roseburg shall monitor compliance with Section III.D. 6 by documenting, monthly, that the multiclones are operated and maintained on each dryer to meet the emission limits as specified in

Section III. D .2 and III. D

. 3. The records sha ll include all repair and maintenance activity to the multiclones. The records must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance (ARM 17.8.1213).

D.14. Roseburg shall monitor compliance with Section III.D. 7 by documenting, monthly, that the temperature sensors are installed and operated at the inlet of the dryers, that the temperature sensors have a remote readout and audible alarm that is audible to the dryer operator and the operator(s) of all three combustio n units , and that the alarm system is operational and programmed to activate if the dryer inlet temperature exceeds 1,100 oF. The records shall include all repair and maintenance activity to the system. The records must include, but are not limited to, th e date, time, and action(s) taken for repair and maintenance (ARM 17.8.1213).

D.15. Roseburg shall document, by month, the production of the two Line 2 dryers. By the 25 th day of each month, Roseburg shall total the hours of operation of the two Line 2 dryers during the previous month. The monthly information will be used to verify compliance with the rolling 12

- month limitation contained in Section III.D. 8 . The information for each of the previous months shall be submitted along with the annual emission inve ntory (ARM 17.8.749 and ARM 17.8.1213).

Recordkeeping

D.16. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the

r equired information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

D.17. All compliance source test recordkeeping shall be performed in accordance with the test method

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

D.18. Roseburg shall maintain all applicable recordkeeping requirements as required by 40 CFR 63, Subpart DDDD, National Emission Standards for Hazardous Air Pollutants: Plywood and Comp osite Wood Products (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

D.19. Roseburg shall maintain the records required by Section III.D. 13 , III.D.1 4 , and III.D.1 5 on site and submit the information to the Department upon request (ARM 17.8.1212).

Reporting

D.20. Any com

pliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

D.21. The annual compliance certification required by Section V.B must contain a certification

statement fo r the above applicable requirements (ARM 17.8.1212).

D.22. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted during the last reporting period;

b. If weekly visual surveys are performed durin g the reporting period, a summary of the results

contained in the wee kly visual observations log;OP2303

- 06 19 Decis ion: 09/06/2011

Final: 10/07/2011 c. Reports of any required monitoring performed during the reporting period, with all instances of deviations from any permit requirements identified ; and,

d. Cert ification of compliance with 40 CFR 63, Subpart DDDD.

E. EU00 8: Predryer (DRY 500)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

E.1, E. 8 , E.1 5

, E.1 6 , E. 1 9

, E. 20 , E. 21 Opacity 20% Vis ual Surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)
E.2, E. 9 , E. 16

, E. 19 , E. 20

, E. 21 Total Particulate Matter 6.21 lb/hr Method 5 Every 5 years Semiannual

E.3, E. 10 , E.1 6

, E. 1 9 , E. 20

, E. 21 PM 10 6.21 l b/hr Method 201A Every 5 years Semiannual

E.4, E.1 1 , E.1 7

, E. 20 , E. 21 Particulate Emissions Operate and

Maintain Medium Efficiency Cyclone

and WESP Recordkeeping Monthly Semiannual

E.5, E.1 2 , E.1 7

, E. 20 , E. 21 Temperature Sensors with

Remote Readout and

A udible Alarm Install and Operate Recordkeeping Monthly Semiannual

E.6, E.1 3 , E.1 7

, E. 20 , E. 21 Production 200,000 BDT per Rolling 12

- Month

Period Recordkeeping Monthly Semiannual

E.7, E.14, E.18,
E.20, E.21 PM 10 CAM Plan CAM Plan Appendix E CAM Plan

Appen dix E Ongoing Semiannual

Conditions

E.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.752).

E.2. Emissions of total particulate matter from the predryer shall be limited to a maximum of 6. 21 lb/hr (ARM 17.8.749).

E.3. Emissions of PM 10 from the predryer shall be limited to a maximum of 6. 21 lb/hr (ARM 17.8.749).

E.4. The predryer shall be equipped with a medium efficienc y cyclone and a wet electrostatic precipitator (WESP) that is operated and maintained to meet the emission limits specified in Section III.E.1, III.E.2 and III.E.3 (ARM 17.8.752).

E.5. Roseburg shall install and operate a temperature sensor at the inlet of the predryer . The temperature sensor shall have a remote readout and audible alarm. The alarm system shall be audible to the dryer operator and the operator(s) of all three combustion units. The alarm system shall become activated when exhaust gas exceeds 1,100oF. Data from the temperature sensors shall be maintained for a period of at least 5 years and shall be available to the Department upon request (ARM 17.8.749).OP2303

- 06 20 Decis ion: 09/06/2011

Final: 10/07/2011 E.6. P roduction from the predryer shall not exceed 200,000 BDT per any rolling 12

- month time p eriod (ARM 17.8.749).

E.7. Roseburg shall provide a reasonable assurance of compliance with the emission limitations or standards for the operation of the emitting unit by following the Compliance Assurance Monitoring (CAM) plan contained in Appendix E of this permit (ARM 17.8.1504).

Compliance Demonstration

E.8. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

RTO stack ( See Section III.BB for requirements specific to the RTO ) for any sources of excessive

emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective

action to contain or minimize the sour ce of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any

corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perfor m a semiannual Method 9 source test for the visible

emissions from the RTO ( See Section III.BB for requirements specific to the RTO )

. Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

E.9. Roseburg shall m onitor compliance with Section III.E.2 by conduct ing EPA Method 5 source testing on the stack emissions of the predryer to determine the total particulate matter emissions

from the stack s . The testing and compliance monitoring of emissions from each stack shall take place at least once every 5 years, or according to another testing/monitoring schedule as may be approved by the Departme nt. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

E.10. Roseburg shall monitor compliance with Section III.E.3 by conduct ing EPA Met hod 201A source testing on the stack emissions of the predryer to determine the PM 10 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from each stack shall take place at least once every 5 years, or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source

Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

E.11. Roseburg shall monitor compliance with Section III.E.4 by documenting, monthly, that the medium efficiency cyclone is operated and maintained on the predryer to meet the e mission limits as specified in Section III.E.2 and III.E.3. The records shall include all repair and maintenance activity to the cyclone. The records must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance (AR M 17.8.1213).OP2303

- 06 21 Decis ion: 09/06/2011

Final: 10/07/2011 E.12. Roseburg shall monitor compliance with Section III.E.5 by documenting, monthly, that the

temperature sensor is installed and operated at the inlet of the predryer, that the temperature sensor

ha s a remote readout and audible alarm that is aud ible to the dryer operator and the operator(s) of

all three combustion units , and that the alarm system is operational and programmed to activate if

the pre dryer inlet temperature exceeds 1,100 oF. The records shall include all repair and

maintenance activ ity to the system. The records must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance (ARM 17.8.1213).

E.13. Roseburg shall document, by month, the production of the predryer. B y the 25 th day of each month, Rosebu rg shall total the production of the predryer during the previous month. The monthly information will be used to verify compliance with the rolling 12

- month limitation contained in Section III.E.6. The information for each of the previous months shall be submitted along with the annual emission inventory ( ARM 17.8.749 and ARM 17.8.1213).

E.14. Roseburg shall monitor compliance with Section III.E.4 and III.E.7 by monitoring emissions according to the CAM Plan contained in Appendix E of this permit (ARM 17.8.150 3 and ARM 17.8.1213).

Recordkeeping

E.15. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required informatio n, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

E.16. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

E.17. Roseburg shall maintain the records required by Section III. E .1 1 , III. E .1 2 and III. E .1 3 on site and submit the information to the Department upon request (ARM 17.8.1212).

E.18. Roseburg shall maintain CA M applicable records in accordance with 40 CFR Part 64 and the CAM Plan contained in Appendix E of this permit (ARM 17.8.1212 and 40 CFR 64).

Reporting

E.19. Any compliance source test reports must be submitted in accordance with the Montana Source

Test Protoc ol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

E.20. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

E.21. The semiannual monitoring report shall pr ovide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations lo g; and

c. Reports of any required monitoring performed during the reporting period, with all instances of deviations from any permit requirements identified

.OP2303

- 06 22 Decis ion: 09/06/2011

Final: 10/07/2011 F. EU010: Outside Truck Dump (BH 50)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonst ration Method Frequency Reporting Requirements

F.1, F.5, F.9, F.10, F.11, F.12, F.13 Opacity 20% Visual Surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

F.2, F.6, F.10, F.11, F.12,

F.13 Total P articulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

F.3, F.7, F.10, F.11, F.12,

F.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

F.4, F.8, F.10,
F.11, F.12,

F.13 F low Rate 27,470 d cfm Method 2 As Required by the Department

and Section

III.A.1 Semiannual

Conditions

F.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

F.2. Emissions of Total Particulate from the outside truck dump baghouse shall not exceed 0.005 grains per dry standard cubic foot (gr/dscf) of exhaust gas (ARM 17.8.749).

F.3. Emissions of PM 10 from the outs ide truck dump baghouse shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

F.4. The flowrate through BH50 shall not exceed 27

, 470 dry cubic feet per minute ( d cfm) (ARM 17.8.749).

Compliance Demonstration

F.5. Once per calendar week during daylight hour s, Roseburg shall visually survey emissions from the

stack of the outside truck dump for any sources of excessive emissions. For the purpose of this

survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity

. The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emis sions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor co mpliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.OP2303

- 06 23 Decis ion: 09/06/2011

Final: 10/07/2011 If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible emissions from the outside truck dump stack. Method 9 source tests must be pe rformed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable li mit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

F.6. Roseburg shall monitor compliance with Section III.F.2 by co nduct ing EPA Method 5 source testing on the stack emissions of the outside truck dump to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may re quire additional testing (ARM 17.8.1213).

F.7. Roseburg shall monitor compliance with Section III.F.3 by conduct ing EPA Method 201A source testing on the stack emissions of the outside truck dump to determine the PM 10 emissions from the

stack. Method 5 result s may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing /monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

F.8. Roseburg shall monito r compliance with Section III.F.4 by conduct ing EPA Method 2 Source Testing on the stack of the outside truck dump to determine the flowrate through the baghouse. The testing and compliance monitoring of emissions from the stack shall take place as requir ed by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Departme nt may require additional testing (ARM 17.8.1213).

Recordkeeping

F.9. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall in clude the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

F.10. All compliance source test recordkeeping shall be performed in accordance with the test method

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

F.11. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212 ).

F.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2303

- 06 24 Decis ion: 09/06/2011

Final: 10/07/2011 F.13. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log.

G. EU011: Milling and Drying (BH 55)

Condition(s) P ollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

G.1, G.6, G.11,
G.12, G.14, G.15, G.16 Opacity 20% Visual Surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as

sp ecified)

G.2, G.7, G.12, G.14, G.15,

G.16 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

G.3, G.8, G.12, G.14, G.15,

G.16 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III .A.1 Semiannual

G.4, G.9, G.12, G.14, G.15,

G.16 Flow Rate 32,000 d cfm Method 2 As Required by the Department

and Section

III.A.1 Semiannual

G.5, G.10, G.13, G.15,

G.16 Baghouse Install, operate, and

maintain Recordkeeping Monthly Semiannual

Conditions

G.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

G.2. Emissions of Total Particulate from BH 55 shal l not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

G.3. Emissions of PM 10 from BH 55 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

G.4. The flowrate through BH 55 shall not exceed 32,000 d cfm (ARM 17.8.749).

G.5. Roseburg shall install, operate, and maintain a baghouse to control emissions from the three dryer loop vents and the coarse refiner loop vent in Milling and Drying (ARM 17.8.749).

Compliance Demonstration

G.6. Once per calendar week during daylight hours, Roseburg shall visually survey emi ssions from the

stack of BH 55 for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shallOP2303

- 06 25 Decis ion: 09/06/2011

Final: 10/07/2011 immediately condu ct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey sha ll record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9. If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible emissions from the milling and drying stack. Method 9 source tests must be performed in

accordance with the Montana Source Test Proto col and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be

a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

G.7. Roseburg shall monitor compliance with Section III.G.2 by conduct ing EPA Method 5 source testing on the stack emissi ons of BH 55 to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitori ng schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

G.8. Roseburg shall monitor complia nce with Section III.G.3 by conduct ing EPA Method 201A source testing on the stack emissions of BH 55 to determine the PM 10 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

G.9. Roseburg shall monitor compliance with Section III.G.4 by conduct ing EPA Method 2 Source Testing on the stack o f BH 55 to determine the flowrate through the baghouse. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department

and Section III.A.1 , or according to another testing/monitoring schedule as may be app roved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

G.10. Roseburg shall monitor compliance with Section III.G.5 by documenting, monthly, that the baghouse was operated and maintained on the three dryer loop vents and the coarse refiner loop vent in Milling and Drying . The records shall include all repair and maintenance activity to the baghouse. The records must i nclude, but are not limited to, the date, time, and action(s) taken for repair and maintenance (ARM 17.8.1213).

Recordkeeping

G.11. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring com pliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

G.12. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).OP2303

- 06 26 Decis ion: 09/06/2011

Final: 10/07/2011 G.13. Roseburg shall maintain the records required by Section III. G .10 on site and submit the

information to the D epartment upon request (ARM 17.8.1212).

Reporting

G.14. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

G.15. The annual compliance certification requir ed by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

G.16. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last repo rting period;

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log; and

c. Reports of any required monitoring performed during the reporting period, with all instances

o f deviations from any permit requirements identified

.

H. EU012: Reject System Line 1 (BH 100)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

H.1, H.5, H.9, H.10, H.11, H.12, H.13 Opaci ty 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

H.2, H.6, H.10,
H.11 H.12,

H.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

H.3, H.7, H.10, H.11 H.12,

H.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

H.4, H.8, H.10, H.11 H.12,

H.13 Flow Rate 40,000 d cfm Method 2 As Required by the Department

and Section

III.A.1 Semiannual

Condition s

H .1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

H .2. Emissions of Total Particulate from BH100 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

H .3. Emissions of PM 10 from BH100 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

H .4. The flowrate through BH100 shall not exceed 40

, 000 d cfm (ARM 17.8.749).OP2303

- 06 27 Decis ion: 09/06/2011

Final: 10/07/2011 Compliance D emonstration

H .5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack of BH 100 for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the

visual surve y being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately co nduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability fo r a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the BH 100 stack. Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading

m eets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

H .6. Roseburg shall monitor compliance with Section III.H.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 100 to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take pl ace as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

H .7. Roseburg shall monitor compliance with Section III.H.3 by conduct ing EPA Method 201A source testing on the stack emissions of BH 100 to determine the PM 10 emissions from the stack. Meth od 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to anot her testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

H.8. Roseb urg shall monitor compliance with Section III.H.4 by conduct ing EPA Method 2 Source Testing on the stack of BH 100 to determine the flowrate through the baghouse. The testing and compliance monitoring of emissions from the stack shall take place as requir ed by the Department

and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Departme nt may require additional testing (ARM 17.8.1213).

Recordkeeping

H.9. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log sha ll include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).OP2303

- 06 28 Decis ion: 09/06/2011

Final: 10/07/2011 H.10. All compliance source test recordkeeping shall be performed in accordance with the test method

used and the Montana Source Test P rotocol and Procedures Manual, and shall be maintained on

s ite (ARM 17.8.106 and ARM 17.8.1212).

Reporting

H.11. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

H.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

H.13. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A s ummary of the results of any compliance test conducted d uring the last reporting period; and

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log.

I. EU013: Reject Syste m Relay Line 1 (BH 101) EU046: Predry (BH 60)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

I.1, I.5, I.9,
I.10, I.11, I.12,

I.13 Opacity 20% Visual surveys Weekly

Semiannual Me thod 9 Semiannual (if

visual surveys

are not
conducted as specified)

I.2, I.6, I.10, I.11 I.12, I.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

I.3, I.7, I.10,
I.11, I.12, I.13 PM 10 0.005 gr/dsc f Method 201A As Required by the Department

and Section

III.A.1 Semiannual

I.4, I.8, I.10, I.11 I.12, I.13 Flow Rate 3,000 d cfm Method 2 As Required by the Department

and Section

III.A.1 SemiannualOP2303

- 06 29 Decis ion: 09/06/2011

Final: 10/07/2011 Conditions

I.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

I.2. Emissions of Total Particulate from BH 10 1 and BH 60 shall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

I.3. Emissions of PM 10 from BH 10 1 and BH 60 shall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

I.4. The flowrate through BH 10 1 and BH 60 shall each not exceed 3, 000 d cfm (ARM 17.8.749).

Complianc e Demonstration

I.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack s of BH 10 1 and BH 60 for any sources of excessive emissions. For the purpose of this

survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of th e visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the BH 10 1 and BH 60 stacks . Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

I. 6. Roseburg shall monitor compliance with Section III.I.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 10 1 and BH 60 to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emi ssions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Te st Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

I.7. Roseburg shall monitor compliance with Section III.I.3 by conduct ing EPA Method 201A source testing on the stack emissions of BH 10 1 and BH 60 to deter mine the PM 10 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack shall take place as required by the Departm ent and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require ad ditional testing (ARM 17.8.1213).OP2303

- 06 30 Decis ion: 09/06/2011

Final: 10/07/2011 I.8. Roseburg shall monitor compliance with Section III.I.4 by conduct ing EPA Method 2 Source Testing on the stack of BH 10 1 and BH 60 to determine the flowrate through the baghouse. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana

So urce Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

I.9. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring comp liance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

I.10. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

I.11. Any compliance source test reports must be submitted in accordance with the Montana So urce Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

I.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

I.13. The semiannua l monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If weekly visual surveys are performed during the reporting period, a summary of the results

contained in t he weekly visual observations log.

J. EU014: 5 X 25 Board Trimsaws System Line 1 (BH 102) EU015: 5 X 16 Board Trimsaws System (BH 103)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

J. 1, J.5, J.9, J.10, J.11, J.12,

J.13 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

J.2, J.6, J.10,
J.11, J.12, J.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Depar tment
and Section

III.A.1 Semiannual

J.3, J.7, J.10, J.11, J.12, J.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

J.4, J.8, J.10, J.11, J.12, J.13 Flow Rate 28,800 d cfm Method 2 As Required by the Departmen t
and Section

III.A.1 SemiannualOP2303

- 06 31 Decis ion: 09/06/2011

Final: 10/07/2011 Conditions

J.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

J.2. Emissions of Total Particulate from BH102 and BH103 shall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

J.3. Emissions of PM 10 from BH102 and BH103 shall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

J.4. The flowra te through BH102 and BH103 shall each not exceed 28

, 800 d cfm (ARM 17.8.749).

Compliance Demonstration

J.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack s of BH 102 and BH 103 for any sources of exce ssive emissions. For the purpose of this

survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the indi vidual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, includin g any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Rose burg shall perform a semiannual Method 9 source test for the visible

emissions from the BH 10 2 and BH 103 stacks . Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior

notifica tion of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be

a minimum of 20 minutes or until a violation of the standard has bee n documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

J.6. Roseburg shall monitor compliance with Section III.J.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 102 and BH 103 to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by t he Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

J.7. Roseburg shall monitor compliance with Section III.J.3 by co nduct ing EPA Method 201A source testing on the stack emissions of BH 102 and BH 103 to determine the PM 10 emissions from the

stack s . Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

half”) is included. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirem ents of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).OP2303

- 06 32 Decis ion: 09/06/2011

Final: 10/07/2011 J.8. Roseburg shall monitor compliance with Section III.J.4 by conduct ing EPA Method 2 Source Testing on the stacks of BH 102 a nd BH 103 to determine the flowrate through each baghouse. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

J.9. If weekly visual surveys are pe rformed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

J.10. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Repor ting

J.11. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

J.12. The annual compliance certification required by Section V.B must contain a c ertification statement for the above applicable requirements (ARM 17.8.1212).

J.13. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log.OP2303

- 06 33 Decis ion: 09/06/2011

Final: 10/07/2011 K. EU016: Core Air System Line 2 (BH 201) EU017: Face Air System Line 2 (BH 200)

Condition(s) Pollutant/Parameter Permit Lim it Compliance Demonstration Method Frequency Reporting Requirements

K.1, K.5, K.9,
K.10, K.11, K.12, K.13 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

K.2, K.6, K.10,

K.1 1, K.12,

K.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

K.3, K.7, K.10, K.11, K.12,

K.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

K.4, K.8, K.1 0, K.11, K.12,

K.13 Flow Rate 26,680 d cfm Method 2 As Required by the Department

and Section

III.A.1 Semiannual

Conditions

K.1 Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

K.2. Emissions of Total Particulate from BH 200 and BH 201 shall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

K.3. Emissions of PM 10 from BH 200 and BH 201 s hall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

K.4. The flowrate through BH200 and BH201 shall each not exceed 26

, 680 d cfm (ARM 17.8.749).

Compliance Demonstration

K.5. Once per calendar week during daylight hours, Roseburg shall visu ally survey emissions from the

stack s of BH 200 and BH 201 for any sources of excessive emissions. For the purpose of this

survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Rose burg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person cond ucting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.OP2303

- 06 34 Decis ion: 09/06/2011

Final: 10/07/2011 If visual surveys are not con ducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the BH 200 and BH 201 stacks . Method 9 source tests must be performed in

accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

K.6. Roseburg shall monitor compliance with Section III.K.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 200 and BH 201 to determine the total particulate matter

emissions from the stack s

. If the source test is conducted while BH200 and BH201 are vented through the combined stack in conjunction with DRY100, DRY101 , DRY102, and DRY103 (see Section III.C), the test results shall be used to monitor compliance with the sum total particulate

mass emission limits of all of the operating sources vented to the stack at the time of the compliance source test. The testing a nd compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requi rements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

K.7. Roseburg shall monitor compliance with Section III.K.3 by conduct ing EPA Method 201A source testing on the stack emissi ons of BH 200 and BH 201 to determine the PM 10 emissions from the

stack s . Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

half”) is included. If the source test is conducted while BH200 and BH201 are vented through th e combined stack in conjunction with DRY100, DRY101, DRY102, and DRY103 (see Section III.C), the test results shall be used to monitor compliance with the sum total particulate mass

emission limits of all of the operating sources vented to the stack at the time of the compliance

source test. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Depa rtment. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

K.8. Roseburg shall monitor compliance with Section III.K.4 by conduct in g EPA Method 2 Source Testing on the stacks of BH 200 and BH 201 to determine the flowrate through each baghouse. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or acc ording to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213 ).

Recordkeeping

K.9. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, t he time, and the initials of the documenting personnel (ARM 17.8.1212).

K.10

. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be main tained on site (ARM 17.8.106 and ARM 17.8.1212).OP2303

- 06 35 Decis ion: 09/06/2011

Final: 10/07/2011 Reporting

K.11

. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

K.12

. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

K.13. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test con ducted d uring the last reporting period;

and

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log.

Alternative Operating Scenario

In any circumstances where Roseburg is unable to demonstrate compliance with the emission limits

identified in Section III .K, Roseburg may, at its discretion, disconnect the combined stack to isolate the individual emission sources and identify the source of the emissions leading to the exc e eda nce. In such circumstances, Roseburg shall correct the problems and re

- attach the stack within no more than 60 days after discovering the exceedance. However, if Roseburg determines, and the Department agrees, that it is

the combined stack itself tha t is causing or contributing to the exceedance, Roseburg shall leave the combined stack unattached, thus venting each source as originally designed. Roseburg will then have 60 days to submit to the Department for approval another alternative to address th is issue. Roseburg will not be required to vent those sources to the combined stack if such venting would result in, or risk resulting in, a violation of any permit term or condition. This alternative operating scenario is meant to allow for Roseburg to isolate any source that may be responsible for an exceedance of a permit condition. This alternative operating scenario does not relieve Roseburg of the liability for a violation of the emission limits identified in Section III.K (ARM 17.8.1212).

L. EU018: Mat Trim System Line 2 (BH 202) EU019: Board Trim System Line 2 (BH 203)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

L.1, L.5, L.9, L.10, L.11, L.12, L.13 Opacity 20% Visual surve ys Weekly Semiannual

Method 9 Semiannual (if

visual surveys

are not
conducted as specified) Semiannual

L.2, L.6, L.10,
L.11 L.12, L.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

L.3, L.7, L.1 0, L.11 L.12, L.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

L.4, L.8, L.10,
L.11 L.12, L.13 Flow Rate 30,000 d cfm Method 2 As Required by the Department

and Section

III.A.1 SemiannualOP2303

- 06 36 Decis ion: 09/06/2011

Final: 10/07/2011 Conditions

L.1. Ro seburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

L.2. Emissions of Total Particulate from BH202 and BH203 shall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

L.3. Emissions of PM 10 from BH202 and BH203 shall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

L.4. The flowrate through BH202 and BH203 shall each not exceed 30

, 00 0 d cfm (ARM 17.8.749).

Compliance Demonstration

L.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack s of BH 202 and BH 203 for any sources of excessive emissions. For the purpose of this

survey, exce ssive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or

minimize the source of emissions. If corrective actio ns are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual su rvey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test f or the visible

emissions from the BH 2 0 2 and BH 203 stacks . Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation pe riod must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (A RM 17.8.106 and ARM 17.8.1213).

L.6. Roseburg shall monitor compliance with Section III.L.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 202 and BH 203 to determine the total particulate matter

emissions from the stack s . The tes ting and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall

conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

L.7. Roseburg shall monitor compliance with Section III.L.3 by conduct ing EPA Method 201A source testing on the stack emissions of BH 202 and BH 203 to determine the PM 10 emissions from the

stack s . Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

half”) is included. The testing and compliance monitoring of emissions from the stack s sh all take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedur es Manual. The Department may require additional testing (ARM 17.8.1213).OP2303

- 06 37 Decis ion: 09/06/2011

Final: 10/07/2011 L.8. Roseburg shall monitor compliance with Section III.L.4 by conduct ing EPA Method 2 Source Testing on the stacks of BH 202 and BH 203 to determine the flowrate through each bagho use. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall c onform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

L.9. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log inclu ding all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

L.10. All compliance source test rec ordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

L.11 Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

L.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable require ments (ARM 17.8.1212).

L.13. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If weekly visual surveys are performed during the reporting peri od, a summary of the results contained in the weekly visual observations log.OP2303

- 06 38 Decis ion: 09/06/2011

Final: 10/07/2011 M. EU020: Board & Trim System Line 2 Relay (BH 204)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

M.1, M. 5, M.9, M.10, M.11,
M.12, M.13 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

M.2, M.6, M.10, M.11, M.12, M.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

M.3, M.7, M.10, M.11
M.12, M.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

M.4, M.8, M.10, M.11, M.12, M.13 Flow Rate 8,000 d cfm Method 2 As Required by the Department

and S ection

III.A.1 Semiannual

Conditions

M.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

M.2

. Emissions of Total Particulate from BH 204 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

M.3. Emissions of PM 10 from BH 204 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

M.4. The flowrate through BH 204 shall not exceed 8

, 000 d cfm (ARM 17.8.749).

Compliance Demonstration

M.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack of BH 204 for any sources of excessive emissions. For the purpose of this survey, excessive

em issions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However,

the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of

emissions. If corrective actions are t aken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey

doe s not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the v isible

emissions from the BH 2 0 4 stack . Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minim um of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).OP2303

- 06 39 Decis ion: 09/06/2011

Final: 10/07/2011 M.6. Roseburg shall monitor compliance with Section III.M.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 204 to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Sourc e Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

M.7. Roseburg shall monitor compliance with Section III.M.3 by conduct ing EPA Method 201A source testing on the stack emissions of BH 204 to determine t he PM 10 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department an d Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require addition al testing (ARM 17.8.1213).

M.8. Roseburg shall monitor compliance with Section III.M.4 by conduct ing EPA Method 2 Source Testing on the stack of BH 204 to determine the flowrate through the baghouse. The testing and compliance monitoring of emissions fr om the stack shall take place as required by the Department

and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test

Protoc ol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

M.9

. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

M.10. All compliance source test recordkeeping shall be performed in accordance with the test me thod used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

M.11. Any compliance source test reports must be submitted in accordance with the Montana Source

Test Protoc ol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

M.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

M.13. The semiannual monitoring rep ort shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log.OP2303

- 06 40 Decis ion: 09/06/2011

Final: 10/07/2011 N. EU021: Six Head Sander (BH 300A & BH 300B)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

N.1, N.5, N.9, N.10, N.11, N.12, N.13 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

N.2, N.6, N.10, N.11, N.12,

N.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

N.3, N.7, N.10, N.11, N.12,

N.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

N.4, N.8, N.10,
N.11, N.12,

N.13 Flow Rate 26,000 d cfm Method 2 As Required by the Department

and Section

III.A.1 Semiannual

Conditions

N.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

N.2. Emissions of Total Particulate from BH 300A and BH 300B shall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

N.3. Emissions of PM 10 from BH 300A and BH 300B shall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

N.4. The flowrate through BH 300A and BH 300B shall each not exceed 26

, 000 d c fm (ARM 17.8.749).

Compliance Demonstration

N.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack s of BH 300A and BH 300B for any sources of excessive emissions. For the purpose of this

survey, excess ive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer w ithin the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or

minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual surv ey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the BH 300A and BH 300B stacks . Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation pe riod must be a minimum of 6 minutesOP2303

- 06 41 Decis ion: 09/06/2011

Final: 10/07/2011 unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (A RM 17.8.106 and ARM 17.8.1213).

N.6. Roseburg shall monitor compliance with Section III.N.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 300A and BH 300B to determine the total particulate matter

emissions from the stack s . The t esting and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall

conform to t he requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

N.7. Roseburg shall monitor compliance with Section III.N.3 by conduct ing EPA Method 201A source testing on the stac k emissions of BH 300A and BH 300B to determine the PM 10 emissions from

the stack s . Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

half”) is included. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Proc edures Manual. The Department may require additional testing (ARM 17.8.1213).

N.8. Roseburg shall monitor compliance with Section III.N.4 by conduct ing EPA Method 2 Source Testing on the stacks of BH 300A and BH 300B to determine the flowrate through eac h baghouse. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

N.9

. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a lo g including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

N.10

. All compliance source t est recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

N.11

. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

N.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

N.13. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If weekly visual surveys are performed during the report ing period, a summary of the results contained in the weekly visual observations log.OP2303

- 06 42 Decis ion: 09/06/2011

Final: 10/07/2011 O. EU023: Six Head and Reman Flatline Relay (BH 301)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

O.1, O.5, O.9, O.10, O.11, O.12, O.13 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

O.2, O.6, O.10, O.11, O.12,

O.13 Total Particulate 0.005 gr/dscf Method 5 As Required by

the De partment
and Section

III.A.1 Semiannual

O.3, O.7, O.10, O.11, O.12,

O.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

O.4, O.8, O.10,
O.11 O.12,

O.13 Flow Rate 4,000 d cfm Method 2 As Required by the Departme nt
and Section

III.A.1 Semiannual

Conditions

O.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2 ) ).

O.2. Emissions of Total Particulate from BH 301 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

O.3. Emissions of PM 10 from BH 301 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

O.4. The flowrate through BH301 shall not exceed 4

, 000 d cfm (ARM 17.8.749).

Compliance Demonstration

O.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack of BH 301 for any sources of excessive emissions. For the purpose of this survey, exces sive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However,

the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of

emissions. If corrective action s are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual sur vey does not relieve Roseburg of a liability for a violation determined using Method 9. If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the BH 301 stack . Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 an d ARM 17.8.1213).OP2303

- 06 43 Decis ion: 09/06/2011

Final: 10/07/2011 O.6. Roseburg shall monitor compliance with Section III.O.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 301 to determine the total particulate matter emissions from the stack. The testing and compliance monito ring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montan a Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

O.7. Roseburg shall monitor compliance with Section III.O.3 by conduct ing EPA Method 201A source testing on the stack emissions of BH 301 to dete rmine the PM 10 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack shall take place as required by the Depart ment and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require a dditional testing (ARM 17.8.1213).

O.8. Roseburg shall monitor compliance with Section III.O.4 by conduct ing EPA Method 2 Source Testing on the stack of BH 301 to determine the flowrate through the baghouse. The testing and compliance monitoring of emiss ions from the stack shall take place as required by the Department

and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

O.9. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance wi th the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

O.10. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

O.11. Any compliance source test reports must be submitted in accordance with the Montana Source

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

O.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

O.13. The semiannual monitor ing report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log.OP2303

- 06 44 Decis ion: 09/06/2011

Final: 10/07/2011 P. EU024: Eight Head Sander (BH 302 & BH 303)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

P.1, P.5, P.9, P.10, P.11, P.12, P.13 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

P.2, P.6, P.10, P.11, P.12,

P.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

P.3, P.7, P.10, P.11, P.1 2,

P.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

P.4, P.8, P.10,
P.11, P.12,

P.13 Flow Rate 47,000 d cfm Method 2 As Required by the Department

and Section

III.A.1 Semiannual

Conditions

P.1. Roseburg sh all not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

P.2. Emissions of Total Particulate from BH 302 and BH 303 shall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

P.3. Emissions of PM 10 from BH 302 and BH 303 shall each not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

P.4. The flowrate through BH 302 and BH 303 shall each not exceed 47

, 000 d cfm (ARM 17.8.749).

Compliance Demonstration

P.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack s of BH 302 and BH 303 for any sources of excessive emissions. For the purpose of this

survey, excessi ve emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer wi thin the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or

minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual surve y does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the BH 302 and BH 303 stacks . Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation perio d must be a minimum of 6 minutesOP2303

- 06 45 Decis ion: 09/06/2011

Final: 10/07/2011 unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

P.6. Roseburg shall monitor compliance with Section III.P.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 302 and BH 303 to determine the total particulate matter

emissions from the stack s . The testin g and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall

conform to the re quirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

P.7. Roseburg shall monitor compliance with Section III.P.3 by conduct ing EPA Method 201A source testing on the stack emi ssions of BH 302 and BH 303 to determine the PM 10 emissions from the

stack s . Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

half”) is included. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

P.8. Roseburg shall monitor compliance with Section III.P.4 by conduct ing EPA Method 2 Source Testing on the stacks of BH 302 and BH 303 to determine the flowrate through each baghous e. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall con form to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

P.9

. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log includi ng all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

P.10

. All compliance source test recor dkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

P.11

. Any compliance source test reports must be s ubmitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

P.12

. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirem ents (ARM 17.8.1212).

P.13

. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If weekly visual surveys are performed during the reporting perio d, a summary of the results contained in the weekly visual observations log.OP2303

- 06 46 Decis ion: 09/06/2011

Final: 10/07/2011 Q. EU026: Eight Head Sander Relay (BH 304)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

Q.1, Q.5, Q.9, Q. 10, Q.11, Q.12, Q.13 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

Q.2, Q.6, Q.10, Q.11, Q.12, Q.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Secti on III.A.1 Semiannual

Q.3, Q.7, Q.10, Q.11, Q.12, Q.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

Q.4, Q.8, Q.10, Q.11, Q.12, Q.13 Flow Rate 10,000 d cfm Method 2 As Required by the Department

and Section

I II.A.1 Semiannual

Conditions

Q.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

Q.2. Emissi ons of Total Particulate from BH 304 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

Q.3. Emissions of PM 10 from BH 304 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

Q.4. The flowrate through BH 304 shall not exceed 10

, 000 d cfm (ARM 17.8.749).

Compliance Demonstration

Q.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack of BH 304 for any sources of excessive emissions. For the purpose of this survey, excessive

emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the pre vious 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, t hen Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey

does not r elieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the BH 304 stack . Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.12 13).OP2303

- 06 47 Decis ion: 09/06/2011

Final: 10/07/2011 Q.6. Roseburg shall monitor compliance with Section III.Q.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 304 to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emiss ions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Q.7. Roseburg shall monitor compliance with Section III.Q.3 by conduct ing EPA Method 201A source testing on the stack emissions of BH 304 to determine the PM 1 0 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Sect ion III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional tes ting (ARM 17.8.1213).

Q.8. Roseburg shall monitor compliance with Section III.Q.4 by conduct ing EPA Method 2 Source Testing on the stack of BH 304 to determine the flowrate through the baghouse. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department

and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test

Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

Q.9. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

Q.10. All compliance source test recordkeeping shall be performed in accordance with the test method

u sed and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

Q.11. Any compliance source test reports must be submitted in accordance with the Montana Source

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

Q.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

Q.13. The semiannual monitoring report sh all provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual obser vations log.OP2303

- 06 48 Decis ion: 09/06/2011

Final: 10/07/2011 R. EU027: Reman Flat Line Sander Relay (BH 400)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

R.1, R.5, R.9, R.10, R.11, R.12, R.13 Opacity 20% Visual surveys Weekly

Semi annual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

R.2, R.6, R.10, R.11, R.12,

R.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

R.3, R.7, R.10, R.11, R.12,

R.13 PM 1 0 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

R.4, R.8, R.10,
R.11, R.12,

R.13 Flow Rate 20,000 d cfm Method 2 As Required by the Department

and Section

III.A.1 Semiannual

Conditions

R.1. Roseburg shall not cau se or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

R.2. Emissions of Total Particulate from BH 400 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

R.3. Emissions of PM 10 from BH 400 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

R.4 The flowrate through BH 400 shall not exceed 20

, 000 d cfm (ARM 17.8.749).

Compliance Demonstration

R.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack of BH 400 for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or e xceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sour ces of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent

visual s urvey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined us ing Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the BH 400 stack . Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applica ble limit, then the observation period must be a minimum of 20OP2303

- 06 4 9 Decis ion: 09/06/2011

Final: 10/07/2011 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

R.6. Roseburg shall monitor compliance with Section II I.R.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 400 to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place as required by the Depa rtment and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

R.7. Roseburg shall monitor compliance with Section III.R.3 by conduct ing EPA Method 201A source testing on the stack emissions of BH 400 to determine the PM 10 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring sche dule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

R.8. Roseburg shall monitor complianc e with Section III.R.4 by conduct ing EPA Method 2 Source Testing on the stack of BH 400 to determine the flowrate through the baghouse. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department

and Se ction III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional t esting (ARM 17.8.1213).

Recordkeeping

R.9. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required inf

ormation, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

R.10. All compliance source test recordkeeping shall be performed in accordance with the test method

used and the Montana Source Test Protocol and Procedures Manu al, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212). Reporting

R.11. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

R.12. T he annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

R.13. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log.OP2303

- 06 50 Decis ion: 09/06/2011

Final: 10/07/2011 S. EU028: Schilling & Bullnose Saw & Edge Bander L ine (BH 401)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

S.1, S.5, S.9, S.10, S.11,
S.12, S.13 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surv eys

are not
conducted as specified)

S.2, S.6, S.10, S.11 S.12, S.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

S.3, S.7, S.10,
S.11, S.12,

S.13 PM 10 0.005 gr/dscf Method 201A As Required by

the Department

and Section

III.A.1 Semiannual

S.4, S.8, S.10, S.11, S.12,

S.13 Flow Rate 27,000 d cfm Method 2 As Required by the Department

and Section

III.A.1 Semiannual

Conditions

S.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

S.2. Emissions of Total Particulate from BH 401 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

S.3. E missions of PM 10 from BH 401 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

S.4. The flowrate through BH401 shall not exceed 27

, 000 d cfm (ARM 17.8.749).

Compliance Demonstration

S.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

stack of BH 401 for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the s urvey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Rosebu rg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conduc ting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conduc ted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the BH 401 stack . Method 9 source tests must be performed in accordance with

the Montana So urce Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20OP2303

- 06 51 Decis ion: 09/06/2011

Final: 10/07/2011 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

S.6. Roseburg shall monitor compliance with Section III.S.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 401 to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to ano ther testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

S.7. Rose burg shall monitor compliance with Section III.S.3 by conduct ing EPA Method 201A source testing on the stack emissions of BH 401 to determine the PM 10 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

S.8. Roseburg shall monitor compliance with Section III.S.4 by conduct ing EPA Method 2 Source Testing on the stack of BH 401 to determine the flowrate through the baghouse. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department

and Section III.A.1 , or according to another testing/ monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

S.9. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

S.10. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.1 06 and ARM 17.8.1212). Reporting

S.11. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

S.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

S.13. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last repo rting period;

and

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log.OP2303

- 06 52 Decis ion: 09/06/2011

Final: 10/07/2011 T. EU029: Schilling and Bullnose System Relay & Edge Bander Line (BH 404)

Condition(s) Pollutant /Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

T.1, T.5, T.9, T.10, T.11,
T.12, T.13 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

T.2, T.6, T.10, T.11, T.12,

T.13 Total Particulate 0.005 gr/dscf Method 5 As Required by the Department

and Section

III.A.1 Semiannual

T.3, T.7, T.10,
T.11, T.12,

T.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semi annual

T.4, T.8, T.10, T.11, T.12,

T.13 Flow Rate 1,700 d cfm Method 2 As Required by the Department

and Section

III.A.1 Semiannual

Conditions

T.1 Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any sour ce, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).

T.2. Emissions of Total Particulate from BH 404 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

T.3. Emissions of PM 10 from BH 404 shall no t exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

T.4 The flowrate through BH404 shall not exceed 1

, 700 d cfm (ARM 17.8.749).

Compliance Demonstration

T.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from th e stack of BH 404 for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the r eporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the BH 404 stack . Method 9 source tests must be performed in accordance with

the Montana Source Test Protocol and Procedures Manua l, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one readingOP2303

- 06 53 Decis ion: 09/06/2011

Final: 10/07/2011 meets or exceeds the applicable limit, then the observation period must be a minimum of 20

minutes or until a viol ation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

T.6. Roseburg shall monitor compliance with Section III.T.2 by conduct ing EPA Method 5 source testing on the stack emissions of BH 404 to de termine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

T.7. Roseburg shall monitor compliance with Sect ion III.T.3 by conduct ing EPA Method 201A source testing on the stack emissions of BH 404 to determine the PM 10 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requ irements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

T.8. Roseburg shall monitor compliance with Section III.T.4 by conduct ing EPA Method 2 Source Testing on the stack of BH 40 4 to determine the flowrate through the baghouse. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department

and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

T.9. If weekly visual surveys are performed, R oseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM

17.8. 1212).

T.10. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212). Reporting

T.11. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

T.12. The annual compliance certification required by Section V.B must contain a certificatio n statement for the above applicable requirements (ARM 17.8.1212).

T.13. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If weekly visual sur veys are performed during the reporting period, a summary of the results contained in the weekly visual observations log.OP2303

- 06 54 Decis ion: 09/06/2011

Final: 10/07/2011 U. EU055: Melamine Baghouse (BH500)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Rep orting Requirements

U.1, U.5, U.9, U.10, U.11, U.12, U.13 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

U.2, U.6, U.10, U.11, U.12,

U.13 Total Particulate 0.005 gr/dscf Method 5 A s Required by the Department

and Section

III.A.1 Semiannual

U.3, U.7, U.10, U.11, U.12,

U.13 PM 10 0.005 gr/dscf Method 201A As Required by the Department

and Section

III.A.1 Semiannual

U.4, U.8, U.10,
U.11, U.12,

U.13 Flow Rate 21,000 d cfm Method 2 As Re quired by the Department

and Section

III.A.1 Semiannual

Conditions

U.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 consecutive m inutes (ARM 17.8.304(2)).

U.2. Emissions of Total Particulate from BH500 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

U.3. Emissions of PM 10 from BH500 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

U.4. The flowrate thro ugh BH500 shall not exceed 21,000 d cfm (ARM 17.8.749).

Compliance Demonstration

U.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the stack of BH 500 for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However,

the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of

emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Co nducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Me thod 9 source test for the visible emissions from the BH 500 stack. Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observ ation period must be a minimum of 6 minutes unless any one readingOP2303

- 06 55 Decis ion: 09/06/2011

Final: 10/07/2011 meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

U.6. Roseburg shall m onitor compliance with Section III.U.2 by conducting EPA Method 5 source testing on the stack emissions of BH 500 to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1, or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the

requ irements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

U.7. Roseburg shall monitor compliance with Section III.U.3 by conducting EPA Method 201A source testing on the stack emiss ions of BH 500 to determine the PM 10 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1, or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana

Source Test Protocol and Procedures Manual. The De partment may require additional testing (ARM 17.8.1213).

U.8. Roseburg shall monitor compliance with Section III.U.4 by conducting EPA Method 2 Source Testing on the stack of BH 500 to determine the flowrate through the baghouse. The testing and complian ce monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1, or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of t he Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

U.9. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual

observations mo nitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

U.10. All compliance source test recordkeeping shall be performed i n accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

U.11. Any compliance source test reports must be submitted in accordance with t he Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

U.12. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

U.13. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted during the last reporting period;

and

b. If weekly visual surveys are performed during the reporting period, a summary of the results

c ontained in the weekly visual observations log.OP2303

- 06 56 Decis ion: 09/06/2011

Final: 10/07/2011 V. EU030: Press Vents 1, 2, 3, 4 Line 1 (PRESS 100)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

V.1, V. 6 , V. 10

, V.1 1 , V.1 3

, V.1 4 , V .1 5 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

V.2, V. 7 , V.1 1

, V.1 3 , V.1 4

, V.1 5 Total Particulate 8.0 lb/hr for all four

stacks combined Method 5 As Required by the Department

a nd Section

III.A.1 Semiannual

V.3, V. 8 , V.1 1

, V.1 3 , V.1 4

, V.1 5 PM 10 8.0 lb/hr for all four

stacks combined Method 201A As Required by the Department

and Section

III.A.1 Semiannual

V.4, V.9, V.12, V.14, V.15 Emissions from the

particleboard presses Contro lled by a Biofilter, except as

allowed under the approved Routine

Control Device

Maintenance Exemption 40 CFR 63,

Subpart DDDD 40 CFR 63,

Subpart DDDD Semiannual

V.5, V.9, V.12, V.14, V.15 Biofilter Routine Control

Device Maintenance Exemption Maximum of 0.5%

of the press annual operating uptime 40 CFR 63,

Subpart DDDD 40 CFR 63,

Subpart DDDD Semiannual

Conditions

V.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 co nsecutive minutes (ARM 17.8.304( 2 ) ).

V.2. Press Vents 1

, 2

, 3 , and 4 on Line 1 shall be limited to 8.0 lb/hr of total particulate emissions for

all four stacks combined (ARM 17.8.749).

V.3. Press Vents 1

, 2

, 3 , and 4 on Line 1 shall be limited to 8.0 lb/hr of PM 10 emissions for all four

stacks combined (ARM 17.8.749).

V.4. Emissions from the particleboard pr esses shall be controlled by a B iofilter, except as allowed under the approved Routine Control Device Maintenance Ex emption specified in Appendix F (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

V. 5

. Roseburg’s Routine Control Device Maintenance Exemption, as specified in Appendix F, shall not exceed 0.5 percent of the press annual operating uptime (ARM 17.8.342 and 40 CF R 63, Subpart DDDD).

Compliance Demonstration

V.6

. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

Bio filter for any sources of excessive emissions. For the purpose of this survey, excessive

emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of theOP2303

- 06 57 Decis ion: 09/06/2011

Final: 10/07/2011 visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then R oseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey

does not reliev e Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emiss ions from the Biofilter

. Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

V. 7

. Roseburg shall monitor compliance with Section III.V.2 by conduct ing EPA Method 5 source testing on the press vents to determine the total particulate matter emissions from the stack s . The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana

Source Test Protocol and Proced ures Manual. The Department may require additional testing (ARM 17.8.1213).

V.8

. Roseburg shall monitor compliance with Section III.V.3 by conduct ing EPA Method 201A source testing on the press vents to determine the PM 10 emissions from the stack s . Meth od 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to ano ther testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

V. 9

. Rose burg shall monitor compliance with Section III.V.4 and III .V.5 as required by 40 CFR 63, Subpart DDDD, National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

Recordkeeping

V. 10

. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

V.11

. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site ( ARM 17.8.106 and ARM 17.8.1212).

V.1 2

. Roseburg shall maintain all applicable recordkeeping requirements as required by 40 CFR 63, Subpart DDDD, National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products (ARM 17.8.342 an d 40 CFR 63, Subpart DDDD).OP2303

- 06 58 Decis ion: 09/06/2011

Final: 10/07/2011 Reporting

V.1 3

. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

V.14

. The annual compliance certification requir ed by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

V.15

. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the las t reporting period;

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log;

c. Certification of compliance with 40 CFR 63, Subpart DDDD.OP2303

- 06 59 Decis ion: 09/06/2011

Final: 10/07/2011 W. EU0031: Press Vents 1, 2, 3, & 4 Line 2 (PRESS 200)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

W.1, W.6

, W. 10 , W.1 1

, W.1 3 , W.1 4

, W.1 5 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

vi sual surveys

are not
conducted as specified)

W.2, W. 7

, W.1 1 , W.1 3

, W.1 4 , W.1 5 Total Particulate 6.5 lb/hr for all four

stacks combined Method 5 As Required by the Department

and Section

III.A.1 Semiannual

W.3, W. 8

, W.1 1 , W.1 3

, W.1 4 , W.1 5 PM 10 6.5 lb/hr for all four

stacks combined Method 201A As Required by the Department

and Section

III.A.1 Semiannual

W .4, W. 9,

W .12, W .14,

W .15 Emissions from the

particleboard presses Controlled by a Biofilter, except as

allowed under the approved Routine

Control Devic e Maintenance Exemption 40 CFR 63,

Subpart DDDD 40 CFR 63,

Subpart DDDD Semiannual

W.5, W.9,
W.12, W.14,

W.15 Biofilter Routine Control

Device Maintenance Exemption Maximum of 0.5%

of the press annual operating uptime 40 CFR 63,

Subpart DDDD 40 CFR 63,

Su bpart DDDD Semiannual

Conditions

W.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 co nsecutive minutes (ARM 17.8.304( 2 ) ).

W.2. Pr ess Vents 1

, 2

, 3

, and 4 on Line 2 shall be limited to 6.5 lb/hr of total particulate emissions for

all four stacks combined (ARM 17.8.749).

W.3. Press Vents 1

, 2

, 3

, and 4 on Line 2 shall be limited to 6.5 lb/hr of PM 10 emissions for all four

stacks comb ined (ARM 17.8.749).

W.4

. Emissions from the particleboard presses shall be controlled by a Biofilter, except as allowed under the approved Routine Control Device Maintenance Exemption specified in Appendix F (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

W .5

. Roseburg’s Routine Control Device Maintenance Exemption, as specified in Appendix F, shall not exceed 0.5 percent of the press annual operating uptime (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

Compliance Demonstration

W. 6

. Once per calendar week du ring daylight hours, Roseburg shall visually survey emissions from the

Bio filter for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of theOP2303

- 06 60 Decis ion: 09/06/2011

Final: 10/07/2011 visual survey being performed. If sources of visible emission s are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compli ance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visua l surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the Biofilter

. Method 9 source tests must be performed in accordanc e with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observ ation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

W. 7

. Roseburg shall monitor compliance with Section III.W.2 by conduct ing EPA Me thod 5 source testing on the press vents to determine the total particulate matter emissions from the stack s . The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or accordi ng to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

W. 8

. Roseburg shall monitor compliance with Section III.W.3 by conduct ing EPA Method 201A source testing on the press vents to determine the PM 10 emissions from the stack s . Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“ba ck

- half”) is included. The testing and compliance monitoring of emissions from the stack s shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The so urce tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

W. 9

. Roseburg shall monitor compliance with Section III.W.4 and III.W.5 as required by 40 CFR 63, Subpart DDDD, National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

Recordkeeping

W. 10

. If weekly visual surveys are performed, Roseburg shall maintain, on

- si te, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

W.1 1

. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

W.1 2

. Roseburg shall maintain all applicable recordkeeping requirements as required by 40 CFR 63, Subpart DDDD, National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).OP2303

- 06 61 Decis ion: 09/06/2011

Final: 10/07/2011 Reporting

W.1 3

. Any compliance source test repo rts must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

W.1 4

. The annual compliance certification required by Section V.B must contain a certification statement for the above applic able requirements (ARM 17.8.1212).

W.1 5

. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

b. If weekly visual surveys are performed during the report ing period, a summary of the results contained in the weekly visual observations log;

c. Certification of compliance with 40 CFR 63, Subpart DDDD.

X. EU032: Boiler #1 (BOILER 1)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

Method Frequency Reporting Requirements

X.1, X.6, X.11, X.12, X.14, X.15, X.16 Opacity 20% Visual Surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

X.2, X.7, X.12, X.14, X.15,

X.16 Total Particulate 19.8 lb/hr Method 5 As Required by the Department

and Section

III.A.1 Semiannual

X.3, X.8, X.12, X.14, X.15,

X.16 PM 10 19.8 lb/hr Method 201A As Required by the Department

and Section

III.A.1 Semiannual

X.4, X.9, X.13, X.15, X.16 Electric Eye Monitor Installe d in Ash Separator Junction

of the Sander Dust

Boiler Stack Recordkeeping Monthly Semiannual

X.5, X.10, X.13, X.15,

X.16 Opacity Monitor Install and Operate (as required) Recordkeeping

(if required to install) Monthly Semiannual

Conditions

X.1. Rosebur g shall not cause or authorize to be discharged into the outdoor atmosphere, from the sander dust abort stack, any visible emissions that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)).

X.2. Particulate emission s from the sander dust boiler shall not exceed 19.8 lb/hr of total particulate when venting from the sander dust boiler abort stack (ARM 17.8.749).

X.3. Particulate emissions from the sander dust boiler shall not exceed 19.8 lb/hr of PM 10 when venting

fro m the sander dust boiler abort stack (ARM 17.8.749).OP2303

- 06 62 Decis ion: 09/06/2011

Final: 10/07/2011 X.4. An electric eye monitor, similar to those used in incinerators, shall be installed in the ash separator junction of the sander dust boiler stack. This location may not be a direct indicator of sta ck opacity, but shall be used to alert the boiler operator to possible upset conditions. The monitor shall have a remote readout visible or audible to the operator of the boiler. Roseburg shall immediately initiate corrective action whenever emissions to atmosphere in excess of 20% opacity

are observed from the sander dust boiler stack. Data from the monitor need not be recorded and digitized unless the Department has reason to believe a violation of the opacity standard exists and requests that Roseburg record and maintain the data (ARM 17.8.749).

X.5. The Department reserves the right to require opacity monitors at the sander dust boiler abort stack. The decision to require this monitoring shall be based upon whether or not the Department has

reason t o believe a violation of the opacity standard exists. If excess emissions exist or may exist at these locations, further opacity monitoring may be required (ARM 17.8.749).

Compliance Demonstration

X.6. Once per calendar week during daylight hours, Roseb urg shall visually survey emissions from the

boiler for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg sh all immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted o nce per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the boiler . Method 9 source tests must be performed in accordance with the

Montana Source Test P rotocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum o f 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

X.7. Roseburg shall monitor compliance with Section III.X.2 by conduct ing EPA Method 5 source testing on the boi ler to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedu le as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

X.8. Roseburg shall monitor compliance with Section III.X.3 by conduct ing EPA Method 201A source testing on the boiler to determine the PM 10 emissions from the stack. Method 5 results may be used as a surrogate for PM 10 if the impinger analysis (“back

- half”) is included. The testing and compl iance monitoring of emissions from the stack shall take place as required by the Department

and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements o f the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).OP2303

- 06 63 Decis ion: 09/06/2011

Final: 10/07/2011 X.9. Roseburg shall monitor compliance with Section III.X.4 by documenting, monthly, that the electric eye monitor is installed in the ash separator junction of the sander dust boiler stack, that the monitor has a remote readout visible or audible to the operator of the boiler, and that corrective action was immediately taken whenever emissions to atmosphere exceeding 20% opacity are

obs erved from the sander dust boiler stack. The records must include , but are not limited to, the date and time of any corrective actions taken (ARM 17.8.1213).

X.10. If opacity monitors are required by the Department at the sander dust boiler abort stack, Roseburg shall document, monthly, that the opacity monitors were installed and operating to monitor compliance with Section III.X.5 (ARM 17.8.1213).

Recordkeeping

X.11. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log inclu ding all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

X.12. All compliance source test rec ordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

X.13. Roseburg shall maintain the records required by Secti on III. X

. 9 , and III. X .1 0 on site and submit the information to the Department upon request (ARM 17.8.1212).

Reporting

X.14. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (AR M 17.8.106 and ARM 17.8.1212).

X.15. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

X.16. The semiannual monitoring report shall provide (ARM 17.8. 1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log; and

c. Reports of any required monitoring performed during the reporting period, with all instances of deviations from any permit requirements identified

.OP2303

- 06 64 Decis ion: 09/06/2011

Final: 10/07/2011 Y. EU033: Roemmc Burner (ROEMMC)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

Method Frequency Reporting Requirements

Y.1, Y.8, Y.14, Y.15, Y.17, Y.18, Y.19 Opacity 20% Visual Surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

Y.2, Y.9, Y.15, Y.17, Y.18,

Y.19 Particulate From Fuel

Comb ustion E = 1.026*

H - 0.233 Method 5 As Required by the Department

and Section

III.A.1 Semiannual

Y.3, Y.10, Y.16, Y.18,

Y.19 Sander Dust Combustion 23,000 Tons per Rolling 12

- Month

Period Recordkeeping Monthly Semiannual

Y.4, Y.11, Y.15, Y.17,
Y.18, Y.19 NO

x 115.0 lb/hr Method 7E Every 5 Years Semiannual

Y.5, Y.11, Y.15, Y.17, Y.18, Y.19 CO 100.0 lb/hr Method 10 Every 5 Years Semiannual

Y.6, Y.12, Y.15, Y.17, Y.18, Y.19 VOC 0.35 lb/hr Method 18, Method 25, or Method 25A (as determined by the Department) As Required by

the Department

and Section

III.A.1 Semiannual

Y.7, Y.13, Y.16, Y.18,

Y.19 Opacity Monitor Install and Operate (as required) Recordkeeping

(if required to install) Monthly Semiannual

Conditions

Y.1. Roseburg shall not cause or authorize e missions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304 ( 2 ) ).

Y.2. Roseburg shall not cause or authorize particulate matter caused by the combustion of fuel to be discharged from any stack or chimney into the outdoor atmosphere in excess of E = 1.026 * H

- 0.233

for new fuel

- burning equipment, where H is the heat input capacity in MMBtu/hr and E is the maximum allowable emission rate in lb/MMBtu (ARM 17. 8.309).

Y.3. Roseburg shall not combust more than 23

, 000 tons of sander dust in the Roemmc Burner during any rolling 12

- month time period (ARM 17.8.749).

Y.4. Emissions of NO

x from the Roemmc Burner shall not exceed 115.0 lb/hr (ARM 17.8.749 and

ARM 17.8 .752).

Y.5. Emissions of CO from the Roemmc Burner shall not exceed 100.0 lb/hr (ARM 17.8.749 and ARM 17.8.752).

Y.6. Emissions of VOCs from the Roemmc Burner shall not exceed 0.35 lb/hr (ARM 17.8.749 and ARM 17.8.752).OP2303

- 06 65 Decis ion: 09/06/2011

Final: 10/07/2011 Y.7. The Department reserves the right to require opacity monitors at the Roemmc sander dust burner abort stack. The decision to require this monitoring shall be based upon whether or not the Department has reason to believe a violation of the opacity standard exists. If excess emission s exist or may exist at these locations, further opacity monitoring may be required (ARM 17.8. 7 49).

Compliance Demonstration

Y.8. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

burner for any sources of ex cessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the

in dividual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain o r minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, includ ing any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Ro seburg shall perform a semiannual Method 9 source test for the visible

emissions from the burner . Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, wh ichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

Y.9. Roseburg shall monitor compliance with Section III.Y.2 by conduct ing EPA Method 5 source testing on the burner to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Y.10. Roseburg shall document, by month, the amount of sander dust combusted in the Roemmc Burner.

B y the 25 th day of each month, Roseburg shall total the amount of sander dust combusted in the

Roemmc Burner during the previous month. The monthly information will be used to verify compliance with the rolling 12

- month limitation contained in Section III.Y.3. The i nformation for each of the previous months shall be submitted along with the annual emission inventory (ARM

17.8.749 and ARM 17.8.1213 ).

Y.11. Roseburg shall monitor compliance with Sections III.Y.4 and III.Y.5 by conducting EPA Method s 7E and 10 s ource t est ing on the Roemmc Burner emissions for NO

x and CO, concurrently. The testing and compliance monitoring of emissions from the stack shall take place at least once every 5 years for each unit , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual, and the Department may require a dditional testing (ARM 17.8.105, ARM 17.8.749 , and ARM 17.8.1213 ).OP2303

- 06 66 Decis ion: 09/06/2011

Final: 10/07/2011 Y.12. Roseburg shall monitor compliance with Section III.Y.6 by conducting EPA Method s 18, 25, or 25A (as determined by the Department) s ource t est ing on the Roemmc Burner emissions for

VOCs. The testing and compliance monitoring of emissions from the stack shall take p lace as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Y.13. If opacity monitors are required by the Department at the Roemmc Burner abort stack , Roseburg shall document, monthly, that the opacity monitors were installed and operating to monitor compliance with Section III. Y

. 7 (ARM 17.8.1213).

Recordkeeping

Y.14. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log sha ll include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

Y.15. All compliance source test recordkeeping shall be performed in accordance with the test method

used and the Montana Source Test P rotocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Y.16. Roseburg shall maintain the records required by Section III. Y

. 10 , and III. Y

. 13 on site and submit the information to the Department upon request (ARM 17 .8.1212).

Reporting

Y.17. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

Y.18. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

Y.19. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period ;

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log; and

c. Reports of any required monitoring performed during the reporting period, with all instances

of deviations from any permit requirements identified.OP2303

- 06 67 Decis ion: 09/06/2011

Final: 10/07/2011 Z. EU0 47 : Solagen Burner (SOLAGEN)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

Z.1, Z.9, Z.16, Z.17, Z.19, Z.20, Z.21 Opacity 20% Visual Su rveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

Z.2, Z.10, Z.17, Z.19, Z.20,

Z.21 Particulate From Fuel

Combustion E = 1.026*

H - 0.233 Method 5 As Required by the Department

and Section

III.A.1 Semiannual

Z.3, Z.11, Z.18, Z.20, Z.21 Sander Dust Combustion 26,280 Tons per Rolling 12

- Month

Period Recordkeeping Monthly Semiannual

Z.4, Z.12, Z.18, Z.20, Z.21 Natural Gas Combustion 352.1 MMscf per Rolling 12

- Month

Period Recordkeeping Monthly Semiannual

Z.5, Z.13, Z.17, Z.19, Z.20,

Z.21 NO

x 31.5 lb/hr Method 7E Every 2 Years Semiannual

Z.6, Z.13, Z.17, Z.19, Z.20,

Z.21 CO 15.6 lb/hr Method 10 Every 2 Years Semiannual

Z.7, Z.14, Z.17,
Z.19, Z.20,

Z.21 VOC 0.09 lb/hr Method 18, Method 25, or Method 25A (as

de termined by the Department) As Required by

the Department

and Section

III.A.1 Semiannual

Z.8, Z.15, Z.18, Z.20, Z.21 Opacity Monitor Install and Operate (as required) Recordkeeping

(if required to install) Monthly Semiannual

Conditions

Z.1. Roseburg sh all not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304 ( 2 ) ).

Z.2. Roseburg shall not cause or authorize particulate matt er caused by the combustion of fuel to be discharged from any stack or chimney into the outdoor atmosphere in excess of E = 1.026 * H

- 0.233

for new fuel

- burning equipment, where H is the heat input capacity in MMBtu/hr and E is the

maximum allowable emissi on rate in lb/MMBtu (ARM 17.8.309).

Z.3. Roseburg shall not combust more than 26

, 280 tons of sander dust in the Solagen Burner during any rolling 12

- month time period (ARM 17.8.749).

Z.4. Roseburg shall not combust more than 352.1 million standard cubic feet (MMscf) of natural gas in

the Solagen Burner during any rolling 12

- month time period (ARM 17.8.749).

Z.5. Emissions of NO

x from the Solagen Burner shall not exceed 31.5 lb/hr (ARM 17.8.749).

Z.6. Emissions of CO from the Solagen Burner shall not exc eed 15.6 lb/hr (ARM 17.8.749).

Z.7. Emissions of VOCs from the Solagen Burner shall not exceed 0. 09 lb/hr (ARM 17.8.749).OP2303

- 06 68 Decis ion: 09/06/2011

Final: 10/07/2011 Z.8. The Department reserves the right to require opacity monitors at the Solagen B urner abort stack. The decision to require this m onitoring shall be based upon whether or not the Department has reason to believe a violation of the opacity standard exists. If excess emissions exist or may exist at these locations, further opacity monitoring may be required (ARM 17.8. 7 49).

Compliance Demonstration

Z.9. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

burner for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissi ons, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a vio lation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the burner . Method 9 sou rce tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading

meets or excee ds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

Z.10. Roseburg shall monitor compliance with Section III.Z.2 by conduct ing EPA Method 5 source testing on the burner to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place as required by the Departme nt and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require add itional testing (ARM 17.8.1213).

Z.11. Roseburg shall document, by month, the amount of sander dust combusted in the Solagen Burner.

B y the 25 th day of each month, Roseburg shall total the amount of sander dust combusted in the Solagen Burner during the previous month. The monthly information will be used to verify compliance with the rolling 12

- month limitation contained in Section III.Z.3. The information for each of the previous months shall be submitted along with the annual emission inventory (ARM

17.8.749 and ARM 17.8.1213 ).

Z.12. Roseburg shall document, by month, the amount of natural gas combusted in the Solagen Burner.

B y the 25 th day of each month, Roseburg shall total the amount of natural gas combusted in the Solagen Burner during the previ ous month. The monthly information will be used to verify compliance with the rolling 12

- month limitation contained in Section III.Z.4. The information for each of the previous months shall be submitted along with the annual emission inventory (ARM

17.8. 749 and ARM 17.8.1213 ).

Z.13. Roseburg shall monitor compliance with Sections III.Z.5 and III.Z.6 by conducting EPA Method s 7E and 10 s ource t est ing on the Solagen Burner emissions for NO

x and CO, concurrently. The testing and compliance monitoring of em issions from the stack shall take place every two years , or according to another testing/monitoring schedule as may be approved by the Department. TheOP2303

- 06 69 Decis ion: 09/06/2011

Final: 10/07/2011 source testing shall occur while Roseburg is using sander dust as the fuel for the Solagen Burner

unless otherwise approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual, and the Department may require

a dditional testing (ARM 17.8.105, ARM 17.8.749 , and ARM 17.8.1213 ).

Z.14. Roseburg shall monitor compliance with Section III.Z.7 by conducting EPA Method s 18, 25, or 25A (as determined by the Department) s ource t est ing on the Solagen Burner emissions for VOCs. The testing and compliance monitoring of emissions from the stack sh all take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana

Source Test Protocol and Procedur es Manual. The Department may require additional testing (ARM 17.8.1213).

Z.15. If opacity monitors are required by the Department at the Solagen Burner abort stack , Roseburg shall document, monthly, that the opacity monitors were installed and operating to monitor compliance with Section III. Z

. 8 (ARM 17.8.1213).

Recordkeeping

Z.16. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

Z.17. All compliance source test recordkeeping shall be performed in accordance with the test method

used and the Montana So urce Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Z.18. Roseburg shall maintain the records required by Section III. Z

. 11 , III. Z

. 12, and III.Z.15 on site and submit the information to the Department upon request (ARM 17.8.1212).

Reporting

Z.19. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

Z.20. The annual compliance certification req uired by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

Z.21. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log; and

c. Reports of any required monitoring performed during the reporting period, with all in stances of deviations from any permit requirements identified.OP2303

- 06 70 Decis ion: 09/06/2011

Final: 10/07/2011 AA. EU035: Line 2 Oil Heater (GEKA)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

AA.1, AA.5, AA.9, AA.10, AA.12, AA.13,

AA.14 Opacity 20% Visual Surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

AA.2, AA.6, AA.10, AA.12, AA.13, AA.14 Particulate From Fuel

Combustion E = 1.026 * H
- 0.233 Method 5 As Required by the Departme nt
and Section

III.A.1 Semiannual

AA.3, AA.7, AA.11, AA.13,

AA.14 Natural Gas Combustion 166.9 MMscf During any Rolling

12

- Month Period Recordkeeping Monthly Semiannual

AA.4, AA.8, AA.11, AA.13,

AA.14 Opacity Monitor Install and Operate (as required) Rec ordkeeping

(if required to install) Monthly Semiannual

Conditions

AA.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 co nsecutive m inutes (ARM 17.8.304(2) ).

AA.2. Roseburg shall not cause or authorize particulate matter caused by the combustion of fuel to be discharged from any stack or chimney into the outdoor atmosphere in excess of E = 1.026 * H

- 0.233

for new fuel

- burning equipmen t, where H is the heat input capacity in MMBtu/hr and E is the maximum allowable emission rate in lb/MMBtu (ARM 17.8.309).

AA.3. Roseburg shall not combust more than 166.9 MMscf of natural gas in the oil heater during any rolling 12

- month time period (ARM 17.8.749).

AA.4. The Department reserves the right to require opacity monitors at the hot oil heater stack. The decision to require this monitoring shall be based upon whether or not the Department has reason to believe a violation of the opacity standa rd exists. If excess emissions exist or may exist at these locations, further opacity monitoring may be required (ARM 17.8. 749 ).

Compliance Demonstration

AA.5. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from t he

hot oil heater for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.OP2303

- 06 71 Decis ion: 09/06/2011

Final: 10/07/2011 If visual surveys are not conducted once per calendar week during the r eporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the hot oil heater . Method 9 source tests must be performed in accordance with

the Montana Source Test Protocol and Procedures Man ual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20

minutes or until a vi olation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

AA.6. Roseburg shall monitor compliance with Section III.AA.2 by conduct ing EPA Method 5 source testing on the hot oil heater to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be

app roved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

AA.7. Roseburg shall document, by month, the amount of natural gas combusted in the hot oil heater.

B y the 25 th day of each month, Roseburg shall total the amount of natural gas combusted in the hot

oil heater during the previous month. The monthly information will be used to verify compliance

with the rolli ng 12

- month limitation contained in Section III.AA.3. The information for each of the previous months shall be submitted along with the annual emission inventory (ARM 17.8.749

and ARM 17.8.1213 ).

AA.8. If opacity monitors are required by the Department a t the hot oil heater stack , Roseburg shall document, monthly, that the opacity monitors were installed and operating to monitor compliance

with Section III. AA

. 4 (ARM 17.8.1213).

Recordkeeping

AA.9. If weekly visual surveys are performed, Roseburg shall m aintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

AA.10. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

AA.11. Roseburg shall maintai n the records required by Section III. AA

. 7 and III.AA.8 on site and submit the information to the Department upon request (ARM 17.8.1212).

Reporting

AA.12. Any compliance source test reports must be submitted in accordance with the Montana Source

Test Pr otocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

AA.13. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).OP2303

- 06 72 Decis ion: 09/06/2011

Final: 10/07/2011 AA.14. The semiannual monito ring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly vi sual observations log; and

c. Reports of any required monitoring performed during the reporting period, with all instances of deviations from any permit requirements identified

.

BB. EU056: Regenerative Thermal Oxidizer

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

B B .1, BB. 6

, BB.1 1 , BB.1 2

, BB.1 5 , BB. 16

, BB. 17 Opacity 10% Visual Surveys Weekly

Semiannual Method 9 Within 180 days

of actual start

up; Semiannual

BB. 2 , BB. 7

, BB. 13 , BB

. 16

, BB. 17 RTO Install, Operate, and

Maintain Recordkeeping Monthly Semiannual

BB. 3 , BB. 8

, BB. 12 , BB. 15

, BB. 16 , BB. 17 Particulate Matter 0.10 gr/ d scf Method 5 Within 180 days

of actual start

up; Thereafter, As Required by the Department

and Section

III.A .1 Semiannual

BB. 4 , BB. 9

, BB. 13 , BB. 16

, BB. 17 Opacity Monitor Install and Operate (if required) Recordkeeping

(if required to install) Monthly Semiannual

BB. 5 , BB.1 0

, BB.1 4 , BB. 16

, BB. 17 RTO Routine Control

Device Maintenance Exemption Maximum of 3% of

t he green dryer annual operating uptime 40 CFR 63,

Subpart DDDD 40 CFR 63,

Subpart DDDD Semiannual

Conditions

BB.1. Roseburg shall not cause or authorize to be discharged into the atmosphere from the RTO any visible emissions that exhibit an opacity of 10% or greater averaged over 6 consecutive minutes (ARM 17.8.752).

BB.2. Roseburg shall install, operate, and maintai n a Regenerative Thermal Oxidizer ( RTO ) to control

VHAP emissions from the wood

- fired green furnish predryer (ARM 17.8.749).

BB. 3

. Roseb urg shall not cause or authorize to be discharged into the atmosphere from the RTO any particulate matter emissions in excess of 0.10 gr/ d scf (ARM 17.8.752).

BB. 4

. The Department reserves the right to require opacity monitors at the RTO abort stack. The decision to require this monitoring shall be based upon whether or not the Department has reason to believe a violation of the opacity standard exists. If excess emissions exist or may exist at this location, further opacity monitoring may be required (AR M 17.8.749).

BB. 5

. Roseburg’s Routine Control Device Maintenance Exemption, as specified in Appendix F, shall not exceed 3 percent of the green dryer annual operating uptime (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).OP2303

- 06 73 Decis ion: 09/06/2011

Final: 10/07/2011 Compliance Demonstration

BB. 6

. Rose burg shall perform a Method 9 source test on the RTO within 180 days of initial start up to

demonstrate compliance with the limitation contained in III.BB.1.

Thereafter, once per calendar week during daylight hours, Roseburg shall visually survey

emissi ons from the RTO for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 5% opacity

. The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 o r take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall

record the r esults of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the rep orting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible emissions from the hot oil heater. Method 9 source tests must be performed in accordance with

the Montana Source Test Protocol and Procedures Manua l, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20

minutes or until a viol ation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

BB. 7

. Roseburg shall monitor compliance with Section III.BB.2 by documenting, monthly, that the RTO has been installed, operated, and mainta ined. The records shall include all repair and maintenance activity to the RTO. The records must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance (ARM 17.8.1213).

BB. 8

. Roseburg shall monitor compliance wit h Section III.BB.3 by conduct ing EPA Method 5 source testing on the RTO to determine the total particulate matter emissions from the stack. The testing and compliance monitoring of emissions from the stack shall take place within 180 days of initial

start up and thereafter, as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall conform to the requirements of the Montana Source Test Protocol and Pro cedures Manual. The Department may require additional testing (ARM 17.8.1213).

BB. 9

. If opacity monitors are required by the Department at the RTO stack , Roseburg shall document, monthly, that the opacity monitors were installed and operating to monitor compliance with

Section III. BB

. 4 (ARM 17.8.1213).

BB.1 0

. Roseburg shall monitor compliance with Section III.BB. 5 as required by 40 CFR 63, Subpart DDDD, National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products (ARM 17. 8.342 and 40 CFR 63, Subpart DDDD).

Recordkeeping

BB

. 1 1

. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement . The log shall include th e required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).OP2303

- 06 74 Decis ion: 09/06/2011

Final: 10/07/2011 BB.1 2

. All compliance source test recordkeeping shall be performed in accordance with the test method

used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

BB.1 3

. Roseburg shall maintain the records required by Section III. BB

. 7 and III.BB. 9 on site and submit the information to the Department upon request (ARM 17.8.1212).

B B.1 4. Roseburg shall maintain all applicable recordkeeping requirements as required by 40 CFR 63, Subpart DDDD, National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products (ARM 17.8.342 and 40 CFR 63, Subpart DDDD).

Repor ting

BB.1 5

. Any compliance source test reports must be submitted in accordance with the Montana Source

Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

BB. 16

. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

BB. 17

. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

b. If weekly vi sual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log;

c. Reports of any required monitoring performed during the reporting period, with all instances of deviations from any permit re quirements identified ; and

d. Certification of compliance with 40 CFR 63, Subpart DDDD.

CC. EU036: Outside Truck Dump (FUG 50) EU037: Pile Reclaim (FUG 51) EU038: Radial Stacker (FUG 52)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

Me thod Frequency Reporting Requirements

CC.1, CC.2, CC.3, CC.4, CC.5, CC.6,

CC.7 Opacity 20% Visual Surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

Conditions

CC.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 cons ecutive minutes (ARM 17.8.304(2) ).OP2303

- 06 75 Decis ion: 09/06/2011

Final: 10/07/2011 Compliance Demonstration

CC.2. Once per calendar week during daylight h ours, Roseburg shall visually survey emissions from the outside truck dump, pile reclaim, and radial stacker for any sources of excessive emissions. For the purpose of this survey, excessive emissions are considered to be any visible emissions, which

meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent vis ual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual survey does not relieve Roseburg of a liability for a

violation determin ed using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the emitting units . Method 9 source tes ts must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must be a minimum of 6 minutes unless any one reading

meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

Recordkeeping

CC.3. If weekly visual surveys a re performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting perso nnel (ARM 17.8.1212).

CC.4. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

CC.5. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

CC.6. The annual compliance certification required by Section V.B must contai n a certification statement for the above applicable requirements (ARM 17.8.1212).

CC.7. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period;

and

b. If we ekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log; andOP2303

- 06 76 Decis ion: 09/06/2011

Final: 10/07/2011 DD. Remanufacturing Facility EU050: Bullnose Fugitives (FUG 400) EU051: Paintline Fugitives (FUG 401)

Condition(s) Po llutant/Parameter Permit Limit Compliance Demonstration Method Frequency Reporting Requirements

DD.1, DD.5

, DD. 9 , DD.1 0

, DD. 13, DD.14,

DD.15 Opacity 20% Visual Surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)
DD.2, DD. 6

, DD.1 1

, DD.1 4,

DD.15 Production of Painted

Material from Bullnose #2 14.7 Million Linear Feet per Rolling 12

- Month Period Recordkeeping Monthly Semiannual

DD.3, DD. 7

, DD.11 , DD.1 4,

DD. 15 Paints (VOCs) Water

- Based Paints

and U.V. Curable

Fillers Recordkeeping Monthly Semiannual

DD.4, DD. 8

, DD.1 2

, DD.14,

DD.15 Remanufacturing Facility 40 CFR 63, Subparts A and JJ 40 CFR 63,

Subparts A and

JJ 40 CFR 63,

Subparts A and

JJ Semiannual

Conditions

DD.1. Roseburg shall not cause or au thorize emissions to be discharged into the outdoor atmosphere from any source, that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304 (2) ).

DD.2. The production of painted material from Bullnose #2 shall not exceed 14. 7 million linear feet per rolling 12

- month period (ARM 17.8.749).

DD.3. Paints used on Roseburg’s paintline shall be water

- based and fillers shall be ultra violet ( U.V. ) curable (ARM 17.8.749).

DD.4. Roseburg shall comply with all applicable standards an d limitations, and the reporting, recordkeeping, and notification requirements of 40 CFR 63, Subpart A, General Provisions, and Subpart JJ, National Emission Standards for Hazardous Air Pollutants for Wood Furniture Manufacturing Operations (ARM 17.8.342 a nd 40 CFR 63, Subparts A and JJ).

Compliance Demonstration

DD. 5

. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the emitting units for any sources of excessive emissions. For the purpose of this survey, exces sive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However,

the individual must have been certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or minimize the source of

emissions. If corrective action s are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective action taken. Conducting a visual sur vey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test fo r the visible

emissions from the emitting units . Method 9 source tests must be performed in accordance withOP2303

- 06 77 Decis ion: 09/06/2011

Final: 10/07/2011 the Montana Source Test Protocol and Procedures Manual, except that prior notification of the test is not required. Each observation period must b e a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).

DD. 6

. Roseburg shall document, by month, the production of painted material from Bullnose #2 . B y the

25 th day of each month, Roseburg shall total the production of painted material from Bullnose #2 during the previous month. The mon thly information will be used to verify compliance with the rolling 12

- month limitation contained in Section III.DD.2. The information for each of the previous months shall be submitted along with the annual emission inventory (ARM 17.8.749 and

ARM 17.8.1 213 ).

DD. 7

. Roseburg shall monitor compliance with Section III. DD

. 3 by documenting, monthly, any instance

in which the paints used on Roseburg’s paintline were not water

- based and fillers were not U.V.

curable (ARM 17.8.1213).

DD. 8

. Roseburg shall monito r compliance with Section III.DD.4 as required by 40 CFR 63, Subpart A, General Provisions, and Subpart JJ, National Emission Standards for Hazardous Air Pollutants for Wood Furniture Manufacturing Operations (ARM 17.8.342 and 40 CFR 63, Subparts A and JJ)

.

Recordkeeping

DD. 9

. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log including all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, t he time, and the initials of the documenting personnel (ARM 17.8.1212).

DD. 10

. All compliance source test recordkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be main tained on site (ARM 17.8.106 and ARM 17.8.1212).

DD.1 1

. Roseburg shall maintain the records required by Section III. DD

. 6 and III.DD. 7 on site and submit the information to the Department upon request (ARM 17.8.1212).

DD.1 2

. Roseburg shall maintain all ap plicable recordkeeping requirements as required by 40 CFR 63, Subpart A, General Provisions, and Subpart JJ, National Emission Standards for Hazardous Air

Pollutants for Wood Furniture Manufacturing Operations (ARM 17.8.342 and 40 CFR Part 63, Subparts A a nd JJ).

Reporting

DD.1 3

. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

DD.1 4

. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable requirements (ARM 17.8.1212).

DD.15

. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of the results of any compliance test conducted d uring the last reporting period ;

b. If weekly visual surveys are performed during the reporting period, a summary of the results contained in the weekly visual observations log;OP2303

- 06 78 Decis ion: 09/06/2011

Final: 10/07/2011 c. Reports of any required monitoring performed during the reporting period, with all instances

of deviations fro m any permit requirements identified ; and

d. Certification of compliance with 40 CFR 63, Subparts A and JJ.

EE. EU048: Line 1 Board Cooler Vents 1, 2, and 3

EU049: Line 2 Board Cooler Vents 1 and 2

Condition(s) Pollutant/Parameter Permit Limit Compliance Dem onstration Method Frequency Reporting Requirements

EE.1, EE.3, EE.5, EE.6,
EE.7, EE.8,

EE.9 Opacity 20% Visual surveys Weekly

Semiannual Method 9 Semiannual (if

visual surveys

are not
conducted as specified)

EE.2, EE.4,
EE.6, EE.7, EE.8, EE. 9 Particulate Matter,

Industrial Process E= 55 * P 0.11

- 40 Method 5 As Required by the Department

and Section

III.A.1 Semiannual

Conditions

EE.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor atmosphere from any sourc e, that exhibit an opacity of 20% or greater averaged over 6 con secutive minutes (ARM 17.8.304(2 )).

EE.2. The particulate emissions from process weight shall not exceed the value calculated by E = 55.0 *

P 0.11

- 40, where E is the emissions in pounds per hour and P is the process weight in tons per hour (ARM 17.8.310).

Compliance Demonstration

EE.3. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

board cooler vents for any sources of excessive emissions. F or the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet or exceed 15% opacity . The person conducting the survey does not have to be an EPA Method 9 certified observer. However, the individual must have be en certified as a Method 9 observer within the previous 2 years of the visual survey being performed. If sources of visible emissions are identified, Roseburg shall immediately conduct a Method 9 or take corrective action to contain or

minimize the source of emissions. If corrective actions are taken, then Roseburg shall immediately conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey shall record the results of the survey in a log, including any corrective ac tion taken. Conducting a visual survey does not relieve Roseburg of a liability for a violation determined using Method 9.

If visual surveys are not conducted once per calendar week during the reporting period, as specified above, Roseburg shall perform a semiannual Method 9 source test for the visible

emissions from the board cooler vents . Method 9 source tests must be performed in accordance with the Montana Source Test Protocol and Procedures Manual, except that prior notification of

the test is not r equired. Each observation period must be a minimum of 6 minutes unless any one reading meets or exceeds the applicable limit, then the observation period must be a minimum of 20 minutes or until a violation of the standard has been documented, whichever i s a shorter period of time (ARM 17.8.106 and ARM 17.8.1213).OP2303

- 06 79 Decis ion: 09/06/2011

Final: 10/07/2011 EE.4. Roseburg shall monitor compliance with Section III.EE.2 by conduct ing EPA Method 5 source testing on the board cooler vents to determine the total particulate matter emissions from the ven ts

. The testing and compliance monitoring of emissions from the vents shall take place as required by the Department and Section III.A.1 , or according to another testing/monitoring schedule as may be approved by the Department. The source tests shall con form to the requirements of the Montana Source Test Protocol and Procedures Manual. The Department may require additional testing (ARM 17.8.1213).

Recordkeeping

EE.5. If weekly visual surveys are performed, Roseburg shall maintain, on

- site, a log includ ing all visual observations monitoring compliance with the visual survey requirement. The log shall include the required information, the date, the time, and the initials of the documenting personnel (ARM 17.8.1212).

EE.6. All compliance source test reco rdkeeping shall be performed in accordance with the test method used and the Montana Source Test Protocol and Procedures Manual, and shall be maintained on site (ARM 17.8.106 and ARM 17.8.1212).

Reporting

EE.7. Any compliance source test reports must be submitted in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212).

EE.8. The annual compliance certification required by Section V.B must contain a certification statement for the above applicable require ments (ARM 17.8.1212).

EE.9. The semiannual monitoring report shall provide (ARM 17.8.1212):

a. A summary of results of the last source testing that was performed; and

b. If weekly visual surveys are performed during the reporting period, a summary of the res ults contained in the weekly visual observations log.OP2303

- 06 80 Decis ion: 09/06/2011

Final: 10/07/2011 SECTION IV. NON

- APPLICABLE REQUIREMENTS

Air Quality Administrative Rules of Montana (ARM) and Federal Regulations identified as not applicable to the facility or to a specific emissions unit at the ti me of the permit issuance are listed below (ARM 17.8.1214). The following list was submitted as part of previous permit applications. The following list does not preclude the need to comply with any new requirements that may become applicable during the permit term.

A. Facility

- Wide

The following table contains non

- applicable requirements which are administrated by the Air Resources Management Bureau of the Department of Environmental Quality.

Rule Citation Reason State Federal

ARM 17.8.321

ARM 17.8.32 3

ARM 17.8 331

ARM 17.8.332

ARM 17.8.333

ARM 17.8.334 These rules are not applicable because the facility is not listed in the source category cited in the rules.

ARM 17.8.316 These rules are not applicable because the facility does not have the specifi c emission unit cited in the rules or is

excluded by rule.

40 CFR 57

40 CFR 60

40 CFR 62

40 CFR 72

40 CFR 73

40 CFR 75

40 CFR 76

40 CFR 77

40 CFR 82 These requirements are not applicable because the facility is

not an affected source as defined in these regulations.

B. Emission Units

The permit application identified applicable requirements: non

- applicable requirements for individual or specific emission units were not listed. The Department has listed all non

- applicable requirements (submitted in previo us applications) in Section IV.A, these requirements relate to each specific unit, as well as facility wide.OP2303

- 06 81 Decis ion: 09/06/2011

Final: 10/07/2011 SECTION V. GENERAL PERMIT CONDITIONS

A. Compliance Requirements ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(a)

- (c)&(e), §1206(6)(c)&( b)

1. The permittee must comply with all conditions of the permit. Any noncompliance with the terms or conditions of the permit constitutes a violation of the Montana Clean Air Act, and may result in enforcement action, permit modification, revocation and r eissuance, or termination, or denial of a permit renewal application under ARM Title 17, Chapter 8, Subchapter 12.

2. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of plann ed changes or anticipated noncompliance does not stay any permit condition.

3. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. If appropriate, this factor may be considered as a mitigating factor in assessing a penalty for noncompliance with an applicable requirement if the source demonstrates that both the health, safety or environmental impacts of halting or reducing operations would be more serious than the impacts of continuing operations, and that such health, safety or environmental impacts were unforeseeable and could not have otherwise been

avoided.

4. The permittee shall furnish to the Departme nt, within a reasonable time set by the Department (not to be less than 15 days), any information that the Department may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit, or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Department copies of those records that are required to be kept pursuant to the terms of the permit. This subsection does not impair or otherwise limit the right of the

pe rmittee to assert the confidentiality of the information requested by the Department, as provided in 75

- 2

- 105, MCA.

5. Any schedule of compliance for applicable requirements with which the source is not in compliance with at the time of permit issuance shall be supplemental to, and shall not sanction noncompliance with, the applicable requirements on which it was based.

6. For applicable requirements that will become effective during the permit term, the source shall meet such requirements on a timely basis unl ess a more detailed plan or schedule is required by the applicable requirement or the Department.

B. Certification Requirements ARM 17.8, Subchapter 12, Operating Permit Program §1207 and §1213(7)(a)&(c)

- (d)

1. Any application form, report, or compliance certi fication submitted pursuant to ARM Title 17, Chapter 8, Subchapter 12, shall contain certification by a responsible official of truth, accuracy and completeness. This certification and any other certification required under ARM Title 17, Chapter 8, Subcha pter 12, shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate and complete.

2. Compliance certifications shall be submitted by February 15 of each year, or more f requently if otherwise specified in an applicable requirement or elsewhere in the permit. Each certification must include the required information for the previous calendar year (i.e., January 1

– December 31).OP2303

- 06 82 Decis ion: 09/06/2011

Final: 10/07/2011 3. Compliance certifications shall include the following:

a. The identification of each term or condition of the permit that is the basis of the certification;

b. The identification of the method(s) or other means used by the owner or operator for determining the status of compliance with each term and co ndition during the certification period, consistent with ARM 17.8.1212;

c. The status of compliance with each term and condition for the period covered by the certification, including whether compliance during the period was continuous or

intermittent (based on the method or means identified in ARM 17.8.1213(7)(c)(ii), as described above); and

d. Such other facts the Department may require to determine the compliance status of the

source.

4. All compliance certifications must be submitted to the Environmental Pro tection Agency, as well as to the Department, at the addresses listed in the Notification Addresses Appendix of this permit.

C. Permit Shield ARM 17.8, Subchapter 12, Operating Permit Program §1214(1)

- (4)

1. The applicable requirements and non

- federally enforc eable requirements are included and specifically identified in this permit and the permit includes a precise summary of the requirements not applicable to the source. Compliance with the conditions of the permit shall be deemed compliance with any applica ble requirements and any non

- federally enforceable requirements as of the date of permit issuance.

2. The permit shield described in 1 above shall remain in effect during the appeal of any permit action (renewal, revision, reopening, or revocation and reissu ance) to the Board of Environmental Review (Board), until such time as the Board renders its final decision.

3. Nothing in this permit alters or affects the following:

a. The provisions of Section 7603 of the FCAA, including the authority of the administrator under that section;

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

c. The applicable requirements of the Acid Rain Program, consistent with Section 7651g(a) of

the F CAA;

d. The ability of the administrator to obtain information from a source pursuant to Section 7414 of the FCAA;

e. The ability of the Department to obtain information from a source pursuant to the Montana Clean Air Act, Title 75, Chapter 2, MCA;

f. The emerge ncy powers of the Department under the Montana Clean Air Act, Title 75, Chapter 2, MCA; andOP2303

- 06 83 Decis ion: 09/06/2011

Final: 10/07/2011 g. The ability of the Department to establish or revise requirements for the use of R easonably

A vailable C ontrol T echnology (RACT) as defined in ARM Title 17, Chapter 8. However, if the inclusion of a RACT into the permit pursuant to ARM Title 17, Chapter 8, Subchapter 12, is appealed to the Board, the permit shield, as it applies to the source’s existing permit, shall remain in effect until such time as the Board has rendered its final

decision.

4. Nothing in this permit alters or affects the ability of the Department to take enforcement action for a violation of an applicable requirement or permit term demonstrated pursuant to ARM 17.8.106, Source Testing Protocol.

5. Pu rsuant to ARM 17.8.132, for the purpose of submitting a compliance certification, nothing in these rules shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance . However, when compliance or noncompliance is demonstrated by a test or procedure provided by permit or other applicable requirements, the source shall then be presumed to be in compliance or noncompliance unless that presumption is overcome by other rel evant credible evidence.

6. The permit shield will not extend to minor permit modifications or changes not requiring a permit revision (see Sections I & J).

7. The permit shield will extend to significant permit modifications and transfer or assignment of

owne rship (see Sections K & O ).

D. Monitoring, Recordkeeping, and Reporting Requirements ARM 17.8, Subchapter 12, Operating Permit Program §1212(2)&(3)

1. Unless otherwise provided in this permit, the permittee shall maintain compliance monitoring

records that inc lude the following information:

a. The date, place as defined in the permit, and time of sampling or measurement;

b. The date(s) analyses were performed;

c. The company or entity that performed the analyses;

d. The analytical techniques or methods used;

e. The resul ts of such analyses; and

f. The operating conditions at the time of sampling or measurement.

2. The permittee shall retain records of all required monitoring data and support information for a period of at least 5 years from the date of the monitoring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all original strip

- chart recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. All monitoring data, support information, and required reports and summaries may be maintained in computerized form at the plant site if the information is made available to Department personnel upon request, which may be for either hard copies or computerized format. S trip

- charts must be maintained in their original form at the plant site and shall be made available to Department personnel upon request.OP2303

- 06 84 Decis ion: 09/06/2011

Final: 10/07/2011 3. The permittee shall submit to the Department, at the addresses located in the Notification Addresses Appendix of this permit, reports of any required monitoring by February 15 and August 15 of each year, or more frequently if otherwise specified in an applicable requirement or elsewhere in the permit. The monitoring report submitted on February 15 of each year must

incl ude the required monitoring information for the period of July 1 through December 31 of the previous year. The monitoring report submitted on August 15 of each year must include the required monitoring information for the period of January 1 through June 30 of the current year. All instances of deviations from the permit requirements must be clearly identified in such reports. All required reports must be certified by a responsible official, consistent with ARM

17.8.1207.

E. Prompt Deviation Reporting

ARM 17.8, Subchapter 12, Operating Permit Program §1212(3)(c)

The permittee shall promptly report deviations from permit requirements, including those attributable to upset conditions as defined in the permit, the probable cause of such deviations, and any co rrective actions or preventive measures taken. To be considered prompt, deviations shall be reported to the Department within the following timeframes (unless otherwise specified in an applicable requirement):

1. For deviations which result in emissions pot entially in violation of permit limitations:

a. An initial phone notification (or faxed or electronic notification) describing the incident within 24 hours (or the next business day) of discovery; and,

b. A follow

- up written, faxed, or electronic report within 30 days of discovery of the deviation that describes the probable cause of the reported deviation and any corrective actions or preventative measures taken.

2. For deviations attributable to malfunctions, deviations shall be reported to the Department in

ac cordance with the malfunction reporting requirements under ARM 17.8.110; and

3. For all other deviations, deviations shall be reported to the Department vie a written, faxed, of electronic report within 90 days of discovery (as determined through the routin e internal review by the permitte e ).

Prompt deviation reports do not need to be resubmitted with the regular semiannual (or other routine) reports, but may be referenced by the date of submittal.

F. Emergency Provisions ARM 17.8, Subchapter 12, Operating Pe rmit Program §1201 (13) and §1214(5), (6)&(8)

1. An “emergency” means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate

corrective action to restor e normal operation and causes the source to exceed a technology

based emission limitation under this permit due to the unavoidable increases in emissions attributable to the emergency. An emergency shall not include noncompliance to the extent caused by i mproperly designed equipment, lack of reasonable preventive maintenance, careless or improper operation, or operator error.

2. An emergency constitutes an affirmative defense to an action brought for noncompliance with a technology

- based emission limitation if the permittee demonstrates through properly signed, contemporaneous logs, or other relevant evidence, that:

a. An emergency occurred and the permittee can identify the cause(s) of the emergency;OP2303

- 06 85 Decis ion: 09/06/2011

Final: 10/07/2011 b. The permitted facility was at the time being properly opera ted;

c. During the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in the permit; and

d. The permittee submitted notice of the emergency to the Departme nt within 2 working days of the time when emission limitations were exceeded due to the emergency. This notice fulfills the requirements of ARM 17.8.1212(3)(c). This notice must contain a description of the emergency, any steps taken to mitigate emission s, and corrective actions taken.

3. These emergency provisions are in addition to any emergency, malfunction or upset provision contained in any applicable requirement.

G. Inspection and Entry ARM 17.8, Subchapter 12, Operating Permit Program §1213(3)&(4)

1. Upo n presentation of credentials and other requirements as may be required by law, the permittee shall allow the Department, the administrator, or an authorized representative (including an authorized contractor acting as a representative of the Department or the administrator) to perform the following:

a. Enter the premises where a source required to obtain a permit is located or emissions

related activity is conducted, or where records must be kept under the conditions of the permit;

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

c. Inspect at reasonable times any facilities, emission units, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit; and

d. As authorized by the Montana Clean Air Act and rules promulgated thereunder, sample or monitor, at reasonable times, any substances or parameters at any location for the purpose of assuring compliance with the permit or appl icable requirements.

2. The permittee shall inform the inspector of all workplace safety rules or requirements at the time of inspection. This section shall not limit in any manner the Department’s statutory right of entry and inspection as provided for in 75

- 2

- 403, MCA.

H. Fee Payment ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(f) and ARM 17.8, Subchapter 5, Air Quality Permit Application, Operation, and Open Burning Fees §505(3)

- (5) (STATE ONLY)

1. The permittee must pay application and operatin g fees, pursuant to ARM Title 17, Chapter 8, Subchapter 5.

2. Annually, the Department shall provide the permittee with written notice of the amount of the fee and the basis for the fee assessment. The air quality operation fee is due 30 days after receipt of the notice, unless the fee assessment is appealed pursuant to ARM 17.8.511. If any portion of the fee is not appealed, that portion of the fee that is not appealed is due 30 days afterOP2303

- 06 86 Decis ion: 09/06/2011

Final: 10/07/2011 receipt of the notice. Any remaining fee, which may be due after t he completion of an appeal, is due immediately upon issuance of the Board’s decision or upon completion of any judicial

review of the Board’s decision.

3. If the permittee fails to pay the required fee (or any required portion of an appealed fee) within

90 d ays of the due date of the fee, the Department may impose an additional assessment of 15% of the fee (or any required portion of an appealed fee) or $100, whichever is greater, plus interest on the fee (or any required portion of an appealed fee), computed at the interest rate

established under 15

- 31

- 510(3), MCA.

I. Minor Permit Modifications ARM 17.8, Subchapter 12, Operating Permit Program §1226(3)&(11)

1. An application for a minor permit modification need only address in detail those portions of the permit application that require revision, updating, supplementation, or deletion, and may reference any required information that has been previously submitted.

2. The permit shield under ARM 17.8.1214 will not extend to any minor modifications processed

pursuant t o ARM 17.8.1226.

J. Changes Not Requiring Permit Revision ARM 17.8, Subchapter 12, Operating Permit Program §1224(1)

- (3), (5)&(6)

1. The permittee is authorized to make changes within the facility as described below, provided the following conditions are met:

a. The proposed changes do not require the permittee to obtain a Montana Air Quality P ermit under ARM Title 17, Chapter 8, Subchapter 7;

b. The proposed changes are not modifications under Title I of the FCAA, or as defined in ARM Title 17, Chapter 8, Subchapt ers 8, 9, or 10;

c. The emissions resulting from the proposed changes do not exceed the emissions allowable under this permit, whether expressed as a rate of emissions or in total emissions;

d. The proposed changes do not alter permit terms that are necessary to enforce applicable emission limitations on emission units covered by the permit; and

e. The facility provides the administrator and the Department with written notification at least 7 days prior to making the proposed changes.

2. The permittee and the Depar tment shall attach each notice provided pursuant to 1.e above to their respective copies of this permit.

3. Pursuant to the conditions above, the permittee is authorized to make Section 502(b)(10) changes, as defined in ARM 17.8.1201(30), without a permit re vision. For each such change, the written notification required under 1.e above shall include a description of the change within the source, the date on which the change will occur, any change in emissions, and any permit term or condition that is no long er applicable as a result of the change.

4. The permittee may make a change not specifically addressed or prohibited by the permit terms and conditions without requiring a permit revision, provided the following conditions are met:

a. Each proposed change does not weaken the enforceability of any existing permit conditions;OP2303

- 06 87 Decis ion: 09/06/2011

Final: 10/07/2011 b. The Department has not objected to such change;

c. Each proposed change meets all applicable requirements and does not violate any existing permit term or condition; and

d. The permittee provid es contemporaneous written notice to the Department and the administrator of each change that is above the level for insignificant emission units as defined in ARM 17.8.1201(22) and 17.8.1206(3), and the written notice describes each such change, including the date of the change, any change in emissions, pollutants emitted, and any applicable requirement that would apply as a result of the change.

5. The permit shield authorized by ARM 17.8.1214 shall not apply to changes made pursuant to ARM 17.8.1224(3) and (5), but is applicable to terms and conditions that allow for increases and decreases in emissions pursuant to ARM 17.8.1224(4).

K. Significant Permit Modifications ARM 17.8, Subchapter 12, Operating Permit Program §1227(1), (3)&(4)

1. The modification proced ures set forth in 2 below must be used for any application requesting a significant modification of this permit. Significant modifications include the following:

a. Any permit modification that does not qualify as either a minor modification or as an

admini strative permit amendment;

b. Every significant change in existing permit monitoring terms or conditions;

c. Every relaxation of permit reporting or recordkeeping terms or conditions that limit the Department’s ability to determine compliance with any applicab le rule, consistent with the requirements of the rule; or

d. Any other change determined by the Department to be significant.

2. Significant modifications shall meet all requirements of ARM Title 17, Chapter 8, including those for applications, public particip ation, and review by affected states and the administrator, as they apply to permit issuance and renewal, except that an application for a significant permit modification need only address in detail those portions of the permit application that require

rev ision, updating, supplementation or deletion.

3. The permit shield provided for in ARM 17.8.1214 shall extend to significant modifications.

L. Reopening for Cause ARM 17.8, Subchapter 12, Operating Permit Program §1228(1)&(2)

1. This permit may be reopened and r evised under the following circumstances:

a. Additional applicable requirements under the FCAA become applicable to the facility when the permit has a remaining term of 3 or more years. Reopening and revision of the permit shall be completed not later than 18 months after promulgation of the applicable requirement. No reopening is required under ARM 17.8.1228(1)(a) if the effective date of the applicable requirement is later than the date on which the permit is due to expire, unless the original permit or a ny of its terms or conditions have been extended pursuant to ARM 17.8.1220(12) or 17.8.1221(2);

b. Additional requirements (including excess emission requirements) become applicable to an affected source under the Acid Rain Program. Upon approval by the adm inistrator, excess emission offset plans shall be deemed incorporated into the permit;OP2303

- 06 88 Decis ion: 09/06/2011

Final: 10/07/2011 c. The Department or the administrator determines that the permit contains a material mistake or that inaccurate statements were made in establishing the emission standard s or other terms or conditions of the permit; or

d. The administrator or the Department determines that the permit must be revised or revoked and reissued to ensure compliance with the applicable requirements.

M. Permit Expiration and Renewal ARM 17.8, Subchap ter 12, Operating Permit Program §1210(2)(g), §1220(11)&(12), and §1205(2)(d)

1. This permit is issued for a fixed term of 5 years.

2. Renewal of this permit is subject to the same procedural requirements that apply to permit issuance, including those for appl ication, content, public participation, and affected state and

administrator review.

3. Expiration of this permit terminates the permittee’s right to operate unless a timely and administratively complete renewal application has been submitted consistent with ARM 17.8.1221 and 17.8.1205(2)(d). If a timely and administratively complete application has been submitted, all terms and conditions of the permit, including the application shield, remain in effect after the permit expires until the permit renewal has been issued or denied.

4. For renewal, the permittee shall submit a complete air quality operating permit application to the Department not later than 6 months prior to the expiration of this permit, unless otherwise specified. If necessary to ensure that t he terms of the existing permit will not lapse before renewal, the Department may specify, in writing to the permittee, a longer time period for submission of the renewal application. Such written notification must be provided at least 1 year before the r enewal application due date established in the existing permit.

N. Severability Clause ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(i)&(l)

1. The administrative appeal or subsequent judicial review of the issuance by the Department of

an initial permit under this subchapter shall not impair in any manner the underlying applicability of all applicable requirements, and such requirements continue to apply as if a final permit decision had not been reached by the Department.

2. If any provision of a pe rmit is found to be invalid, all valid parts that are severable from the invalid part remain in effect. If a provision of a permit is invalid in one or more of its applications, the provision remains in effect in all valid applications that are severable from the invalid applications.

O. Transfer or Assignment of Ownership ARM 17.8, Subchapter 12, Operating Permit Program §1225(2)&(4)

1. If an administrative permit amendment involves a change in ownership or operational control, the applicant must include in i ts request to the Department a written agreement containing a specific date for the transfer of permit responsibility, coverage and liability between the current and new permittee.

2. The permit shield provided for in ARM17.8.1214 shall not extend to adminis trative permit

amendments.OP2303

- 06 89 Decis ion: 09/06/2011

Final: 10/07/2011 P. Emissions Trading, Marketable Permits, Economic Incentives ARM 17.8, Subchapter 12, Operating Permit Program §1226(2)

Notwithstanding ARM 17.8.1226(1) and (7), minor air quality operating permit modification procedures may be used for permit modifications involving the use of economic incentives, marketable permits, emissions trading, and other similar approaches, to the extent that such minor permit modification procedures are explicitly provided for in the Montana State Imple mentation Plan or in applicable requirements promulgated by the administrator.

Q. No Property Rights Conveyed ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(d)

This permit does not convey any property rights of any sort, or any exclusive privile ge.

R. Testing Requirements ARM 17.8, Subchapter 1, General Provisions §105

The permittee shall comply with ARM 17.8.105.

S. Source Testing Protocol ARM 17.8, Subchapter 1, General Provisions §106

The permittee shall comply with ARM 17.8.106.

T. Malfunctions

A RM 17.8, Subchapter 1, General Provisions §110

The permittee shall comply with ARM 17.8.110.

U. Circumvention ARM 17.8, Subchapter 1, General Provisions §111

The permittee shall comply with ARM 17.8.111.

V. Motor Vehicles ARM 17.8, Subchapter 3, Emission Sta ndards §325

The permittee shall comply with ARM 17.8.325.

W. Annual Emissions Inventory ARM 17.8, Subchapter 5, Air Quality Permit Application, Operation and Open Burning Fees §505 (STATE ONLY)

The permittee shall supply the Department with annual producti on and other information for all emission units necessary to calculate actual or estimated actual amount of air pollutants emitted during each calendar year. Information shall be gathered on a calendar

- year basis and submitted to the Department by the dat e required in the emission inventory request, unless otherwise specified in this permit. Information shall be in the units required by the Department.

X. Open Burning ARM 17.8, Subchapter 6, Open Burning §604, 605 and 606

The permittee shall comply with AR M 17.8.604, 605 and 606.OP2303

- 06 90 Decis ion: 09/06/2011

Final: 10/07/2011 Y. Montana Air Quality Permits ARM 17.8, Subchapter 7, Permit, Construction and Operation of Air Contaminant Sources §745 and

764 (ARM 17.8.745(1) and 764(1)(b) are STATE ENFORCEABLE ONLY until approval by the EPA as part of the SIP)

1. Except as specified, no person shall construct, install, alter or use any air contaminant source or stack associated with any source without first obtaining a permit from the Department or Board. A permit is not required for those sources or stacks as sp ecified by ARM 17.8.744(1)(a)

- (k).

2. The permittee shall comply with ARM 17.8.743, 744, 745, 748, and 764.

3. ARM 17.8.745(1) specifies de minimis changes as construction or changed conditions of operation at a facility holding a Montana Air Quality Permit is sued under Chapter 8 that does not increase the facility’s potential to emit by more than 15 tons per year of any pollutant, except (STATE ENFORCEABLE ONLY until approved by the EPA as part of the SIP):

a. Any construction or changed condition that would vio late any condition in the facility’s existing MAQP or any applicable rule contained in Chapter 8 is prohibited, except as provided in ARM 17.8.745(2);

b. Any construction or changed conditions of operation that would qualify as a major

modification under Sub chapters 8, 9 or 10 of Chapter 8;

c. Any construction or changed condition of operation that would affect the plume rise or dispersion characteristic of emissions that would cause or contribute to a violation of an ambient air quality standard or ambient air increment as defined in ARM 17.8.804;

d. Any construction or improvement project with a potential to emit more than 15 tons per year may not be artificially split into smaller projects to avoid a Montana Air Quality

Permit ting; or

e. Emission reductions obtai ned through offsetting within a facility are not included when determining the potential emission increase from construction or changed conditions of operation, unless such reductions are made federally enforceable.

4. Any facility making a de minimis change pursuant to ARM 17.8.745(1) shall notify the Department if the change would include a change in control equipment, stack height, stack diameter, stack gas temperature, source location or fuel specifications, or would result in an increase in source capaci ty above its permitted operation or the addition of a new emission unit. The notice must be submitted, in writing, 10 days prior to start up or use of the proposed de minimis change, or as soon as reasonably practicable in the event of an unanticipated

ci rcumstance causing the de minimis change, and must include the information requested in ARM 17.8.745(1) (STATE ENFORCEABLE ONLY until approval by the EPA as part of the SIP).

Z. National Emission Standard for Asbestos 40 CFR, Part 61, Subpart M

The permitte e shall not conduct any asbestos abatement activities except in accordance with 40 CFR 61, Subpart M (National Emission Standard for Hazardous Air Pollutants for Asbestos).

AA. Asbestos ARM 17.74, Subchapter 3, General Provisions and Subchapter 4, Fees

The p ermittee shall comply with ARM 17.74.301, et seq ., and ARM 17.74.401, et seq . (State only)OP2303

- 06 91 Decis ion: 09/06/2011

Final: 10/07/2011 BB. Stratospheric Ozone Protection

– Servicing of Motor Vehicle Air Conditioners 40 CFR, Part 82, Subpart B

If the permittee performs a service on motor vehicles and t his service involves ozone

- depleting substance/refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to all the applicable requirements as specified in 40 CFR 82, Subpart B.

CC. Stratospheric Ozone Protection

– Recycling and Emissi on Reductions 40 CFR, Part 82, Subpart F

The permittee shall comply with the standards for recycling and emission reductions in 40 CFR 82, Subpart F, except as provided for MVACs in Subpart B:

1. Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to §82.156;

2. Equipment used during the maintenance, service, repair or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to §82.158;

3. Persons per forming maintenance, service, repair or disposal of appliances must be certified by an approved technical certification program pursuant to §82.161;

4. Persons disposing of small appliances, MVACs and MVAC

- like (as defined at §82.152) appliances must comply with recordkeeping requirements pursuant to §82.166;

5. Persons owning commercial or industrial process refrigeration equipment must comply with the leak repair requirements pursuant to §82.156; and

6. Owners/operators of appliances normally containing 50 or m ore pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to §82.166.

DD. Emergency Episode Plan

The permittee shall comply with the requirements contained in Chapter 9.7 of the State of Montana Air Quality Co ntrol Implementation Plan.

Each major source emitting 100 tons per year located in a Priority I Air Quality Control Region, shall submit to the Department a legally enforceable Emergency Episode Action Plan (EEAP) that details

how the source will curtail emissions during an air pollutant emergency episode. The industrial EEAP shall be in accordance with the Department’s EEAP and shall be submitted according to a timetable developed by the Department, following Priority I reclassification.

EE. Definitions

Te rms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this permit, shall have the meaning assigned to them in the referenced regulations.OP2303

- 06 92 Decis ion: 09/06/2011

Final: 10/07/2011 APPENDICESOP2303

- 06 A

- 1 Decis ion: 09/06/2011

Final: 10/07/2011 Appendix A INSIGNIFICANT EMISSION UNITS

Disclaimer: The information in th is appendix is not State or Federally enforceable, but is presented to assist Roseburg, the permitting authority, inspectors, and the public.

Pursuant to ARM 17.8.1201(22)(a), an insignificant emission unit means any activity or emissions unit

located wit hin a source that: (i) has a potential to emit less than 5 tons per year of any regulated pollutant; (ii) has a potential to emit less than 500 pounds per year of lead; (iii) has a potential to emit less than 500 pounds per year of hazardous air pollutants listed pursuant to S ection 7412 (b) of the FCAA; and (iv) is not regulated by an applicable requirement, other than a generally applicable requirement that applies to all emission units subject to Subchapter 12.

List of Insignificant Activities:

The fol lowing table of insignificant sources and/or activities was provided by Roseburg in previous operating permit applications and/or the current renewal application. Because there are no requirements to update such a list, the emission units and/or activitie s may change from those specified in the table.

Emissions Unit ID Description

IEU01 Auxiliary Diesel Generators (I2)

IEU02 Degreasing (I7)

IEU03 Portable Heaters (I9)

IEU04 Wax Pump (I15)

IEU05 Gas Powered Sump Pump (I2)

IEU06 Fire Pond Dredging (I 120)

IEU07 Diesel Tank (I23)

IEU08 Gasoline Storage Tank (I22)

IEU09 2 Wax Tanks (I22)

IEU10 10 Resin Tanks (I22)

IEU11 1 Day Use Wax Tank (I22)

IEU12 Propane Storage Tanks (I25, I31)

IEU13 General Repair and Maintenance (I34)

IEU14 Machining

– Gen eral Maintenance (I36)

IEU15 2

- 52 Gallon Brine Tanks (I33)

IEU16 Septic System with Lift System (I40)

IEU17 Space Heaters (I43)

IEU18 Steam Cleaning

– General Maintenance (I45)

IEU19 Knife Sharpening Solution (I46)

IEU20 Degreasing (I7)

IEU21 Non Pr ocessing Heaters (NPHEAT)

IEU22 Wax Pump (I15)

IEU23 Gas Powered Sump Pump (I2)

IEU24 Fire Pond Dredging (I120)

IEU25 Diesel Tank (I23)

IEU26 Gasoline Storage Tank (I22)

IEU27 Melamine Press Vents (FUG)

IEU28 Melamine Burner (INTEC)

IEU29 Paint Dry ing Oven #1 (S400)

IEU30 Paint Drying Oven #2 (S401)

IEU31 Paint Drying Oven #3 (S402)OP2303

- 06 B

- 1 Decis ion: 09/06/2011

Final: 10/07/2011 Appendix B DEFINITIONS and ABBREVIATIONS

"Act" means the Clean Air Act, as amended, 42 U.S. 7401, et seq

.

"Administrative permit amendment" means an air quality operating p ermit revision that:

(a) C orrects typographical errors;

(b) I dentifies a change in the name, address or phone number of any person identified in the air quality operating permit, or identifies a similar minor administrative change at the source;

(c) R equires more f

requent monitoring or reporting by Roseburg ;

(d) R equires changes in monitoring or reporting requirements that the Department deems to be no less stringent than current monitoring or reporting requirements;

(e) A llows for a change in ownership or operational con trol of a source if the Department has determined that no other change in the air quality operating permit is necessary, consistent with ARM 17.8.1225; or

(f) I ncorporates any other type of change which the Department has determined to be similar to

those rev isions set forth in (a)

- (e), above.

"Applicable requirement" means all of the following as they apply to emission units in a source requiring an air quality operating permit (including requirements that have been promulgated or approved by the Department or the administrator through rule making at the time of issuance of the air quality operating permit, but have future

- effective compliance dates, provided that such requirements apply to sources covered under the operating permit):

(a) A ny standard, rule, or other requirement, including any requirement contained in a consent decree or judicial or administrative order entered into or issued by the Department, that is contained in the Montana state implementation plan approved or promulgated by the

administrator through rule making under Title I of the FCAA;

(b) A ny federally enforceable term, condition or other requirement of any Montana Air Quality

Permit issued by the Department under S ubchapters 7, 8, 9 and 10 of this chapter, or pursuant to regulations approved or promulgated through rule making under Title I of the FCAA, including P arts C and D;

(c) A ny standard or other requirement under Section 7411 of the FCAA, including Section 7411(d);

(d) A ny standard or other requirement under Section 7412 of the FCAA, includi ng any requirement concerning accident prevention under Section 7412(r)(7), but excluding the contents of any risk management plan required under Section 7412(r);

(e) A ny standard or other requirement of the acid rain program under Title IV of the FCAA or

reg ulations promulgated thereunder;

(f) A ny requirements established pursuant to Section 7661c(b) or Section 7414(a)(3) of the
FCAA;OP2303

- 06 B

- 2 Decis ion: 09/06/2011

Final: 10/07/2011 (g) A ny standard or other requirement governing solid waste incineration, under Section 7429 of the FCAA;

(h) A ny standard or other req uirement for consumer and commercial products, under Section 7511b(e) of the FCAA;

(i) A ny standard or other requirement for tank vessels, under Section 7511b(f) of the FCAA;

(j) A ny standard or other requirement of the regulations promulgated to protect stratos pheric ozone under Title VI of the FCAA, unless the administrator determines that such requirements need not be contained in an air quality operating permit;

(k) A ny national ambient air quality standard or increment or visibility requirement under P art C

of Title I of the FCAA, but only as it would apply to temporary sources permitted pursuant to

Section 7661c(e) of the FCAA; or

(l) A ny federally enforceable term or condition of any air quality open burning permit issued by the Department under S ubchapter 6.

"D epartment" means the Montana Department of Environmental Quality.

“Excess Emissions” means any visible emissions from a stack or source, viewed during the visual surveys, that meets or exceeds 15% opacity (or 30% opacity if associated with a 40% opacity l imit) during normal operating conditions.

"Emissions unit" means any part or activity of a stationary source that emits or has the potential to emit any regulated air pollutant or any pollutant listed under Section 7412(b) of the FCAA. This term is not

m eant to alter or affect the definition of the term "unit" for purposes of Title IV of the FCAA.

"FCAA" means the Federal Clean Air Act, as amended.

"Federally enforceable" means all limitations and conditions which are enforceable by the administrator, i ncluding those requirements developed pursuant to 40 CFR Parts 60 and 61, requirements within the Montana state implementation plan, and any permit requirement established pursuant to 40 CFR 52.21 or under regulations approved pursuant to 40 CFR Part 51, S ubpart I, including operating permits issued under an EPA approved program that is incorporated into the Montana state implementation plan and expressly requires adherence to any permit issued under such program.

"Fugitive emissions" means those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally equivalent opening.

"General air quality operating permit" or "general permit" means an air quality operating permit that meets the requirements of ARM 17.8.1222, cover s multiple sources in a source category, and is issued in lieu of individual permits being issued to each source.

"Hazardous air pollutant" means any air pollutant listed as a hazardous air pollutant pursuant to

S ection 112(b) of the FCAA.

"Non

- federall y enforceable requirement" means the following as they apply to emission units in a source requiring an air quality operating permit:

(a) any standard, rule, or other requirement, including any requirement contained in a consent decree, or judicial or adminis trative order entered into or issued by the Department, that is not contained in the Montana state implementation plan approved or promulgated by the administrator through rule making under Title I of the FCAA;OP2303

- 06 B

- 3 Decis ion: 09/06/2011

Final: 10/07/2011 (b) A ny term, condition or other requirement cont ained in any Montana Air Quality Permit issued by the Department under S ubchapters 7, 8, 9 and 10 of this chapter that is not federally enforceable;

(c) D oes not include any Montana ambient air quality standard contained in Subchapter 2 of this chapter.

"Per mittee" means the owner or operator of any source subject to the permitting requirements of this subchapter, as provided in ARM 17.8.1204, that holds a valid air quality operating permit or has submitted a timely and complete permit application for issuanc e, renewal, amendment, or modification pursuant to this subchapter.

"Regulated air pollutant" means the following:

(a) N itrogen oxides or any volatile organic compounds;

(b) A ny pollutant for which a national ambient air quality standard has been promulgated;

(c) A ny pollutant that is subject to any standard promulgated under Section 7411 of the FCAA;

(d) A ny Class I or II substance subject to a standard promulgated under or established by Title VI of the FCAA; or

(e) A ny pollutant subject to a standard or other requirem ent established or promulgated under

Section 7412 of the FCAA, including but not limited to the following:

(i) A ny pollutant subject to requirements under Section 7412(j) of the FCAA. If the administrator fails to promulgate a standard by the date establishe d in S ection 7412(e) of the FCAA, any pollutant for which a subject source would be major shall be considered to be regulated on the date 18 months after the applicable date established in S ection 7412(e) of the FCAA;

(ii) A ny pollutant for which the requirem ents of S ection 7412(g)(2) of the FCAA have been met but only with respect to the individual source subject to Section 7412(g)(2) requirement.

"Responsible official" means one of the following:

(a) For a corporation: a president, secretary, treasurer, or vic e

- president of the corporation in charge of a principal business function, or any other person who performs similar policy or

decision

- making functions for the corporation, or a duly authorized representative of such person if the representative is respons ible for the overall operation of one or more manufacturing, production, or operating facilities applying for or subject to a permit and

either:

(i) T he facilities employ more than 250 persons or have gross annual sales or expenditures exceeding $25 million ( in second quarter 1980 dollars); or

(ii) T he delegation of authority to such representative is approved in advance by the Department.

(b) For a partnership or sole proprietorship: a general partner or the proprietor, respectively.OP2303

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- 4 Decis ion: 09/06/2011

Final: 10/07/2011 (c) For a municipality, state, fed eral, or other public agency: either a principal executive officer or ranking elected official. For the purposes of this part, a principal executive officer of a federal agency includes the chief executive officer having responsibility for the overall

ope rations of a principal geographic unit of the agency (e.g., a regional administrator of the environmental protection agency).

(d) For affected sources: the designated representative in so far as actions, standards, requirements, or prohibitions under Title IV of the FCAA or the regulations promulgated thereunder are concerned, and the designated representative for any other purposes under this subchapter.OP2303

- 06 B

- 5 Decis ion: 09/06/2011

Final: 10/07/2011 Abbreviations:

ARM Administrative Rules of Montana

ASTM American Society of Testing Materials

BACT Bes t Available Control Technology

BDT bone dry tons

BTU British Thermal Unit

CFR Code of Federal Regulations

CO carbon monoxide DEQ Department of Environmental Quality

dscf dry standard cubic foot

dscfm dry standard cubic foot per minute

EEAP Emergency Episod e Action Plan

EPA U.S. Environmental Protection Agency

EPA Method Test methods contained in 40 CFR 60, Appendix A

EU emissions unit

FCAA Federal Clean Air Act

gr grains

HAP hazardous air pollutant

IEU insignificant emissions unit

Mbdft thousand board feet

Method 5 40 CFR 60, Appendix A, Method 5

Method 9 40 CFR 60, Appendix A, Method 9

MMbdft million board feet

MMBTU million British Thermal Units

NOx oxides of nitrogen

NO 2 nitrogen dioxide

O 2 oxygen Pb lead

PM particulate matter

PM10 particulate matter less than 10 microns in size psi pounds per square inch

scf standard cubic feet

SIC Source Industrial Classification

SO 2 sulfur dioxide

SOx oxides of sulfur

TPY tons per year
U.S.C. United States Code

VE visible emissions

VOC volatile organic compoundOP2303

- 06 C

- 1 Decis ion: 09/06/2011

Final: 10/07/2011 Appendix C NOTIFI CATION ADDRESSES

Compliance Notifications:

Montana Department of Environmental Quality Permitting and Compliance Division Air Resources Management Bureau

P.O. Box 200901 Helena, MT 59620

- 0901

United States EPA Air Program Coordinator Region VIII, Monta na Office

10 W. 15 th Street, Suite 3200 Helena, MT 59626

Permit Modifications:

Montana Department of Environmental Quality Permitting and Compliance Division Air Resources Management Bureau

P.O. Box 200901 Helena, MT 59620

- 0901

Office of Partnerships an d Regulatory Assistance Air and Radiation Program US EPA Region VIII 8P

- AR 1595 Wynkoop St. Denver, CO 80202

- 1129OP2303

- 06 D

- 1 Decis ion: 09/06/2011

Final: 10/07/2011 Appendix D AIR QUALITY INSPECTOR INFORMATION

Disclaimer: The information in this appendix is not State or Federally enforceable, but is presented to

as sist Roseburg , permitting authority, inspectors, and the public.

1. Direction to Plant: The facility is l ocated approximately one mile northwest of the city limits of Missoula, Montana at 3300 Raser Road . The mailing address of the facility is P.O. Box 400 7

, Missoula, Montana 59806.

2. Safety Equipment Required: Hard hat, safety glasses, and hearing protection are required at the facility. In addition to the above

- mentioned items, and at the direction of a representative of the Roseburg, additional PPE may be required.

3. Facility Plot Plan: An updated facility plot plan was submitted as part of the operating permit renewal application submitted on January 8, 2007, and is on file with the Department.OP2303

- 06 E

- 1 Decis ion: 09/06/2011

Final: 10/07/2011 Appendix E COMPLIANCE ASSURANCE MONITORING (CAM)

Emitting Unit: EU 008

– #1 Predryer (DRY 500)

Pollutant: PM 10 Control Device: Wet Electrostatic Precipitator (WESP)

Emission Limit: 6 .21 lb/hr Monitoring Approach: The monitoring approach for this CAM applicable emitting unit is

contained in T able I below.

Table I

A. G eneral Criteria

Indicator WESP Power

Measurement Approach Electrical power input is measured using a voltmeter and an ammeter. The total power (P) input to the WESP is the sum of the products of the secondary voltage (V) and the current (I) in

each fiel d. (P=V 1 I 1 + V 2 I 2 )

Indicator Range Due to the nature of WESP’s, only a lower end value will be established for power input. An excursion occurs if the hourly

average power input drops below its respective hourly average

indicator value. The indicator v alue will be established during a source test (see Stack Test below) . An excursion triggers an inspection/investigation, corrective action, and a reporting requirement.

B. Performance Criteria

Data Representativeness The voltage and current are measur ed using the instrumentation (voltmeter and ammeter) specifically designed and installed on the WESP to measure and control the performance. Verification of Operational Status Continuous monitoring of total W ESP power input (kW)

Quality Assurance/Quali ty Control Validate voltmeter and ammeter output on a semiannual basis in accordance with good engineering practices

. Monitoring Frequency Continuous ( at least every 5 minutes)

Data Collection Procedures Continuous voltage and current readout in the Lin e 1 M & D control room. Every five minutes the computer will record the instantaneous voltage and current for the field for that moment. This methodology will provide 12 recorded power reading s per hour block. The data will be stored in an electronic da tabase and printed out in paper form for a minimum of five years

storage.

Averaging Period An arithmetic average of the data collected for each given hour block will be generated.

Stack Test/Monitoring Initiation After Department approval of the CAM Plan , Roseburg will schedule and conduct Method 201A (or Method 5 if the impinger analysis (“back

- half”) is included) testing to establish

a suitable minimum power indicator value. The indicator value shall be 80% of the lowest average power (kW) applied to t he WESP over the duration of any one run that resulted in emissions less than the emission limit during the afore

mentioned test. The indicator value shall be established as expeditiously as practicable after Department approval ( issuance of the final per mit ), but in no case shall the establishment of the indicator value prevent monitoring from beginning within 180 days after the permit becomes final and

effective (ARM 17.8.1508(4)).OP2303

- 06 F

- 1 Decis ion: 09/06/2011

Final: 10/07/2011 Appendix F Routine Control Device Maintenance Exemption

Presses

Control Device for Which the Exemption is Approved: Biofilter Process Equipment Controlled: Exhaust gas from particleboard presses Duration and Frequency of Maintenance Procedure for Which the Exemption is Approved: See Table 1 (not to exceed 0.5% of the press annual o perating uptime)

Table 1: Biofilter Maintenance Exemption

Maintenance Procedures Duration Frequency Biofilter Nozzle Inspection and Replacement 5 hours Monthly

Biofilter Plumping Inspection and Repair 4 hours Monthly

Biofilter Media Cleaning 40 hours Annually Biofilter Media Changeout 96 hours Approximately every 10 years

Predryer Control Device for Which Exemption is Approved: RTO Process Equipment Controlled: Exhaust gas from particleboard green dryer (predryer) Duration and Frequency of Maintenan ce Procedure for Which the Exemption is Approved: See Table 2 (not to exceed 3% of the green dryer annual operating uptime)

Table 2: RTO Maintenance Exemption

Maintenance Procedures Duration Frequency

RTO Bakeout 12

- 16 hours Quarterly

RTO Washout 72 ho urs Semiannual RTO Media Changeout 5 days Approximately every 3

- 5 years ESP Screen Cleaning 8

- 10 hours Every 2 weeks