October 7, 2011

Ellen Porter

Roseburg Forest Products – Missoula Particleboard

P.O. Box 4007

Missoula, MT 59806

RE: Administrative Amendment Title V Operating Permit #OP2303-06

Dear Ms. Porter:

The Department of Environmental Quality has prepared the enclosed Final Operating Permit #OP2303-

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 #OP2303-06. 

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 Office
OP2303-06 i Decision: 09/06/2011

Final: 10/07/2011

STATE OF MONTANA

Department of Environmental Quality

Helena, Montana 59620

AIR QUALITY OPERATING PERMIT OP2303-06

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

Application Deemed Administratively Complete: 08/08/2011

Administrative Amendment Application Received: 07/22/2011

AFS Number: 030-063-0002A

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 permit 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. FACILITY-WIDE ....................................................................................................................3

B. EU001: PLANT-WIDE ...........................................................................................................6

C. EU002: #1 DRYER LINE 1 WITH NATURAL GAS BACK-UP BURNER (DRY 100) ...............12

EU003: #2 DRYER LINE 1 WITH NATURAL GAS BACK-UP BURNER (DRY 101) ...............12

EU004: #3 DRYER LINE 1 WITH NATURAL GAS BACK-UP BURNER (DRY 102) ...............12

EU005: #4 DRYER LINE 1 WITH NATURAL GAS BACK-UP BURNER (DRY 103) ...............12

D. EU006: #5 DRYER LINE 2 WITH NATURAL GAS BACK-UP BURNER (DRY 200) ...............16

EU007: #6 DRYER LINE 2 WITH NATURAL GAS BACK-UP BURNER (DRY 201) ...............16

E. EU008: PREDRYER (DRY 500)...........................................................................................19

F. EU010: OUTSIDE TRUCK DUMP (BH 50) ...........................................................................22

G. EU011: MILLING AND DRYING (BH 55).............................................................................24

H. EU012: REJECT SYSTEM LINE 1 (BH 100) .........................................................................26

I. EU013: REJECT SYSTEM RELAY LINE 1 (BH 101).............................................................28

EU046: PREDRY (BH 60)....................................................................................................28

J. EU014: 5 X 25 BOARD TRIMSAWS SYSTEM LINE 1 (BH 102)............................................30

EU015: 5 X 16 BOARD TRIMSAWS SYSTEM (BH 103) .......................................................30

K. EU016: CORE AIR SYSTEM LINE 2 (BH 201) .....................................................................33

EU017: FACE AIR SYSTEM LINE 2 (BH 200)......................................................................33

L. EU018: MAT TRIM SYSTEM LINE 2 (BH 202)....................................................................35

EU019: BOARD TRIM SYSTEM LINE 2 (BH 203)................................................................35

M. EU020: BOARD & TRIM SYSTEM LINE 2 RELAY (BH 204)................................................38

N. EU021: SIX HEAD SANDER (BH 300A & BH 300B)..........................................................40

O. EU023: SIX HEAD AND REMAN FLATLINE RELAY (BH 301).............................................42

P. EU024: EIGHT HEAD SANDER (BH 302 & BH 303)...........................................................44

Q. EU026: EIGHT HEAD SANDER RELAY (BH 304)................................................................46

R. EU027: REMAN FLAT LINE SANDER RELAY (BH 400) ......................................................48

S. EU028: SCHILLING & BULLNOSE SAW & EDGE BANDER LINE (BH 401) .........................50

T. EU029: SCHILLING AND BULLNOSE SYSTEM RELAY & EDGE BANDER LINE (BH 404)....52

U. EU055: MELAMINE BAGHOUSE (BH500)...........................................................................54

V. EU030: PRESS VENTS 1, 2, 3, 4 LINE 1 (PRESS 100) .........................................................56

W. EU0031: PRESS VENTS 1, 2, 3, & 4 LINE 2 (PRESS 200) ...................................................59

X. EU032: BOILER #1 (BOILER 1).........................................................................................61

Y. EU033: ROEMMC BURNER (ROEMMC)............................................................................64

Z. EU047: SOLAGEN BURNER (SOLAGEN)...........................................................................67

AA. EU035: LINE 2 OIL HEATER (GEKA).................................................................................70

BB. EU056: REGENERATIVE THERMAL OXIDIZER....................................................................72

CC. EU036: OUTSIDE TRUCK DUMP (FUG 50).........................................................................74

EU037: PILE RECLAIM (FUG 51) .......................................................................................74

EU038: RADIAL STACKER (FUG 52)..................................................................................74

DD. REMANUFACTURING FACILITY...........................................................................................76

EU050: BULLNOSE FUGITIVES (FUG 400).........................................................................76

EU051: PAINTLINE FUGITIVES (FUG 401).........................................................................76

EE. EU048: LINE 1 BOARD COOLER VENTS 1, 2, AND 3...........................................................78

EU049: LINE 2 BOARD COOLER VENTS 1 AND 2................................................................78
OP2303-06 iii Decision: 09/06/2011

Final: 10/07/2011

SECTION IV. NON-APPLICABLE REQUIREMENTS ................................................................80

A. FACILITY-WIDE ..................................................................................................................80

B. EMISSION UNITS .................................................................................................................80

SECTION V. GENERAL PERMIT CONDITIONS.......................................................................81

A. COMPLIANCE REQUIREMENTS............................................................................................81

B. CERTIFICATION REQUIREMENTS ........................................................................................81

C. PERMIT SHIELD...................................................................................................................82

D. MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS..................................83

E. PROMPT DEVIATION REPORTING........................................................................................84

F. EMERGENCY PROVISIONS...................................................................................................84

G. INSPECTION AND ENTRY.....................................................................................................85

H. FEE PAYMENT.....................................................................................................................85

I. MINOR PERMIT MODIFICATIONS ........................................................................................86

J. CHANGES NOT REQUIRING PERMIT REVISION ...................................................................86

K. SIGNIFICANT PERMIT MODIFICATIONS...............................................................................87

L. REOPENING FOR CAUSE......................................................................................................87

M. PERMIT EXPIRATION AND RENEWAL..................................................................................88

N. SEVERABILITY CLAUSE ......................................................................................................88

O. TRANSFER OR ASSIGNMENT OF OWNERSHIP......................................................................88

P. EMISSIONS TRADING, MARKETABLE PERMITS, ECONOMIC INCENTIVES...........................89

Q. NO PROPERTY RIGHTS CONVEYED.....................................................................................89

R. TESTING REQUIREMENTS ...................................................................................................89

S. SOURCE TESTING PROTOCOL .............................................................................................89

T. MALFUNCTIONS..................................................................................................................89

U. CIRCUMVENTION ................................................................................................................89

V. MOTOR VEHICLES ..............................................................................................................89

W. ANNUAL EMISSIONS INVENTORY .......................................................................................89

X. OPEN BURNING...................................................................................................................89

Y. MONTANA AIR QUALITY PERMITS.....................................................................................90

Z. NATIONAL EMISSION STANDARD FOR ASBESTOS ..............................................................90

AA. ASBESTOS ...........................................................................................................................90

BB. STRATOSPHERIC OZONE PROTECTION – SERVICING OF MOTOR VEHICLE AIR 

 CONDITIONERS ...................................................................................................................91

CC. STRATOSPHERIC OZONE PROTECTION – RECYCLING AND EMISSION REDUCTIONS ..........91

DD. EMERGENCY EPISODE PLAN...............................................................................................91

EE. DEFINITIONS .......................................................................................................................91

APPENDIX A INSIGNIFICANT EMISSION UNITS...................................................................A-1

APPENDIX B DEFINITIONS AND ABBREVIATIONS..............................................................B-1

APPENDIX C NOTIFICATION ADDRESSES .............................................................................C-1

APPENDIX D AIR QUALITY INSPECTOR INFORMATION ..................................................D-1

APPENDIX E COMPLIANCE ASSURANCE MONITORING (CAM) .....................................E-1

APPENDIX F ROUTINE CONTROL DEVICE MAINTENANCE EXEMPTION................... F-1
OP2303-06 1 Decision: 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. GENERAL 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 Particleboard

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) 679-3311

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 processes 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 unloaded 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 is 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 that 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 Decision: 09/06/2011

Final: 10/07/2011

SECTION II. SUMMARY OF EMISSION UNITS

The emission units regulated by this permit are the following (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 Dryer 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) Baghouse

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) Cover

EU037 Pile Reclaim (FUG 51) None

EU038 Radial Stacker (FUG 52) None

EU050 Bullnose Fugitives (FUG 400) None

EU051 Paintline Fugitives (FUG 401) None
OP2303-06 3 Decision: 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 OrE= 1.026 * H-0.233

A.8 ARM 17.8.310 Particulate Matter, Industrial 

Processes Particulate Matter E= 4.10 * P0.67 orE= 55 * P0.11- 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 

Implementation 

Plan (Chapter 4 of 

the Missoula CityCounty 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.14 ARM 17.8.749 Conditions 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 persons 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 tests, emission or 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 November 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 Decision: 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 outdoor 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 excess 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. Pursuant 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 allowable emissions of particulate 

matter calculated using the following equations:

For process weight rates up to 30 tons per hour: E = 4.10 * P0.67

For process weight rates in excess of 30 tons per hour: E = 55.0 * P0.11– 40

Where E = rate of emissions in 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 this permit.
OP2303-06 5 Decision: 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 tank 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 startup, 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 electronic 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 emergency 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 Department 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 contain 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 required 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 official 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 information 

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, Chapter 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 Decision: 09/06/2011

Final: 10/07/2011

B. EU001: Plant-Wide

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

B.1, B.16, 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.17, 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.18, B.32, 

B.35, B.36 Line 2 Production

75 MMft2of 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 Monthly Semiannual

B.5, B.20, 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.22, B.32, 

B.35, B.36

Contaminated Floor 

Sweepings

Not Stored Outside; 

Material stored in 

contaminated floor 

sweepings building 

limited to 50 units 

(370 cubic yards)

Recordkeeping Monthly Semiannual

B.8, B.23, B.32, 

B.35, B.36 Fugitive Emissions

Plant and Maintain 

Vegetation on 

Earthen Berm

Recordkeeping Monthly Semiannual

B.9, B.24, 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.10, B.24,

B.32, B.35, B.36

PM10 Emissions from the 

Raw Materials Storage 

Pile

334 lb/day and 9.9 

ton/yr

Calculate 

Using Equation

Daily and 

Semiannual

Semiannual

B.11, B.25, 

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 Semiannual

B.12, B.26, 

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.13, B.27, 

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.14, B.28, 

B.32, B.35, B.36 Fugitive Dust Emissions

Install and Maintain a 

Cover Over the 

Reclaim Hopper

Recordkeeping Monthly Semiannual

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

Semiannual
OP2303-06 7 Decision: 09/06/2011

Final: 10/07/2011

Conditions

B.1. Roseburg shall not cause or authorize emissions to be discharged into the outdoor 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. Line 2 production shall be limited to 75-million square feet (MMft2) 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 all 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 (yd3)) (ARM 

17.8.749).

B.8. Roseburg shall plant and maintain vegetation on the sides 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 exhibit 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 per 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, shall not exceed 334-lb/day daily maximum and 9.9 TPY

for particulate matter with an aerodynamic diameter of 10 microns or less (PM10) (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 reduce 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 Decision: 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, 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 63, Subparts A 

and DDDD).

Compliance Demonstration

B.16. Once per calendar week during daylight 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 

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 excessive 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 affected unit. 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).

B.17. Roseburg shall document, by month, the hours of operation of Line 1. By the 25thday 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. By the 

25th 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 shall 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 installed, 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. Roseburg 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 Decision: 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 exceeded 370 yd3at 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 include all maintenance activities performed, including the date of any 

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

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

B.24. Roseburg shall monitor compliance with Sections III.B.9 and III.B.10 by using the following 

equation (ARM 17.8.749):

E = 0.50 (I) (e) (0.33[1-ntd] + 0.33[1-nrs] + 0.33[1-nrp])

Where:

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

I = Total raw material delivered to plant in BDT;

e = PM10 emission factor of 0.36 pound per ton (lb/ton), or a PM emission factor of 1.0 

lb/ton;

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

nrs = Control efficiency at the radial stacker expressed as a ratio; and

nrp = 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 truck 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 point 

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 

equation 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 the days when the inside truck dump is 

shut down using the associated raw material delivery data and the constant of 

1.00;
OP2303-06 10 Decision: 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 17.8.1213).

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 17.8.1213).

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 records 

must include, but are not limited to, the date, time, and action(s) taken for repair and maintenance

(ARM 17.8.1213).

B.28. Roseburg shall monitor compliance with Section III.B.14 by documenting, monthly, that the 

cover over the reclaim hopper has been installed 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 repair and maintenance (ARM 17.8.1213).

B.29. Roseburg shall monitor compliance 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 Products (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 shall 

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 Protocol 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 Decision: 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 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, Subparts A and DDDD.
OP2303-06 12 Decision: 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.16, C.17, 

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.17, C.20, 

C.21, C.22

Total Particulate MatterDRY 1004.9 lb/hr

Method 5 Every 5 Years Semiannual

Total Particulate MatterDRY 1014.7 lb/hr

Total Particulate MatterDRY 1024.9 lb/hr

Total Particulate MatterDRY 1034.9 lb/hr

C.4, C.5, C.12, 

C.17, C.20, 

C.21, C.22

PM10 - DRY 100 4.9 lb/hr

Method 201A Every 5 Years Semiannual

PM10 - DRY 101 4.7 lb/hr

PM10 - DRY 102 4.9 lb/hr

PM10 - DRY 103 4.9 lb/hr

C.6, C.13, 

C.18, C.21, 

C.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

C.7, C.13, 

C.18, C.21, 

C.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

C.8, C.14, 

C.19, C.21, 

C.22

Particulate Emissions

Operate and 

Maintain 

Multiclones

Recordkeeping Monthly Semiannual

C.9, C.15, 

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 each 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 PM10 from DRY100, DRY102, and DRY103 shall each be limited to a maximum of 

4.9 lb/hr (ARM 17.8.749).

C.5. Emissions of PM10 from DRY101 shall be limited to a maximum of 4.7 lb/hr (ARM 17.8.749).
OP2303-06 13 Decision: 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 equipped 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 hours, 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 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 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 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).

C.11. Roseburg shall monitor compliance with Sections III.C.2 and III.C.3 by conducting EPA Method 

5 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 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 the 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 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).
OP2303-06 14 Decision: 09/06/2011

Final: 10/07/2011

C.12. Roseburg shall monitor compliance with Sections III.C.4 and III.C.5 by conducting EPA Method 

201A 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 PM10 emissions from the stack. Method 5 results may be used 

as a surrogate for PM10 if the impinger analysis (“back-half”) is included. The test results shall be 

used to monitor compliance with the sum total PM10 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 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 maintained 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, time, 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 

sensors 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 1,100oF. 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 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).

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 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).

C.19. Roseburg shall maintain the records required by Sections III.C.14 and III.C.15 on site and submit 

the information to the Department upon request (ARM 17.8.1212).
OP2303-06 15 Decision: 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 and 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 Decision: 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.17, D.20, 

D.21, D.22

Total Particulate Matter 6.0 lb/hr Method 5 Every 5 Years Semiannual

D.3, D.11, 

D.17, D.20, 

D.21, D.22

PM10 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.13, 

D.19, D.21, 

D.22

Particulate Emissions

Operate and 

Maintain 

Multiclones

Recordkeeping Monthly Semiannual

D.7, D.14, 

D.19, D.21, 

D.22

Temperature Sensors with 

Remote Readout and 

Audible Alarm

Install and Operate Recordkeeping Monthly Semiannual

D.8, D.15, 

D.19, D.21, 

D.22

Combined Production

168,000 BDT per 

Rolling 12-Month 

Period

Recordkeeping Monthly Semiannual

Conditions

D.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).

D.2. Emissions of total particulate matter from the Line 2 dryers shall each be limited to a maximum of 

6.0 lb/hr (ARM 17.8.749).

D.3. Emissions of PM10 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 Decision: 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 

1,100oF. 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).

D.8. The combined production from the two line 2 dryers shall not exceed 168,000 BDT per rolling 12-

month period (ARM 17.8.749).

Compliance Demonstration

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

stacks of each of the Line 2 dryers 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 reporting period, as 

specified above, Roseburg shall perform a semiannual Method 9 source 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 period of time (ARM 17.8.106 and ARM 17.8.1213).

D.10. Roseburg shall monitor compliance with Section III.D.2 by conducting EPA Method 5 source 

testing on the stack emissions of each Line 2 dryer to determine the total particulate matter 

emissions from the stacks. 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 conducting EPA Method 201A source 

testing on the stack emissions of each Line 2 dryer to determine the PM10 emissions from the 

stack. Method 5 results may be used as a surrogate for PM10 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).

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 Decision: 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 shall 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 combustion units, and that the alarm system is operational and programmed 

to activate if the dryer inlet temperature exceeds 1,100oF. 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).

D.15. Roseburg shall document, by month, the production of the two Line 2 dryers. By the 25th 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 inventory (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 

required 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 

Composite 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.14, and III.D.15 on site 

and submit the information to the Department upon request (ARM 17.8.1212).

Reporting

D.20. 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).

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

statement for 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 during the reporting period, a summary of the results 

contained in the weekly visual observations log;
OP2303-06 19 Decision: 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. Certification of compliance with 40 CFR 63, Subpart DDDD.

E. EU008: Predryer (DRY 500)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

E.1, E.8, E.15, 

E.16, E.19, 

E.20, E.21

Opacity 20%

Visual 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.16, 

E.19, E.20, 

E.21

PM10 6.21 lb/hr Method 201A Every 5 years Semiannual

E.4, E.11, E.17, 

E.20, E.21 Particulate Emissions

Operate and 

Maintain Medium 

Efficiency Cyclone 

and WESP

Recordkeeping Monthly Semiannual

E.5, E.12, E.17, 

E.20, E.21

Temperature Sensors with 

Remote Readout and 

Audible Alarm

Install and Operate Recordkeeping Monthly Semiannual

E.6, E.13, E.17, 

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 PM10 CAM Plan CAM Plan Appendix E

CAM Plan 

Appendix 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 PM10 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 efficiency 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 Decision: 09/06/2011

Final: 10/07/2011

E.6. Production from the predryer shall not exceed 200,000 BDT per any rolling 12-month time period 

(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 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 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 monitor compliance with Section III.E.2 by conducting EPA Method 5 source 

testing on the stack emissions of the predryer to determine the total particulate matter emissions 

from the stacks. 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.10. Roseburg shall monitor compliance with Section III.E.3 by conducting EPA Method 201A source 

testing on the stack emissions of the predryer to determine the PM10 emissions from the stack. 

Method 5 results may be used as a surrogate for PM10 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 emission 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 (ARM 17.8.1213).
OP2303-06 21 Decision: 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 

has 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 predryer inlet temperature exceeds 1,100oF. 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).

E.13. Roseburg shall document, by month, the production of the predryer. By the 25th day of each 

month, Roseburg 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 17.8.1503 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 information, 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.11, III.E.12 and III.E.13 on site and 

submit the information to the Department upon request (ARM 17.8.1212).

E.18. Roseburg shall maintain CAM 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 Protocol 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 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; 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 Decision: 09/06/2011

Final: 10/07/2011

F. EU010: Outside Truck Dump (BH 50)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

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 Particulate 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

PM10 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

Flow Rate 27,470 dcfm 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 consecutive 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 PM10 from the outside 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 (dcfm) (ARM 

17.8.749).

Compliance Demonstration

F.5. Once per calendar week during daylight hours, 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 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 23 Decision: 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 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).

F.6. Roseburg shall monitor compliance with Section III.F.2 by conducting 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 require additional testing (ARM 17.8.1213).

F.7. Roseburg shall monitor compliance with Section III.F.3 by conducting EPA Method 201A source 

testing on the stack emissions of the outside truck dump to determine the PM10 emissions from the 

stack. Method 5 results may be used as a surrogate for PM10 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 monitor compliance with Section III.F.4 by conducting 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 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

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 include 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 Decision: 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 during 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) Pollutant/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 

specified)

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

PM10 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 dcfm 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 consecutive minutes 

(ARM 17.8.304(2)).

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

17.8.749).

G.3. Emissions of PM10 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 dcfm (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 emissions 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 shall 
OP2303-06 25 Decision: 09/06/2011

Final: 10/07/2011

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 milling and drying 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 17.8.1213).

G.7. Roseburg shall monitor compliance with Section III.G.2 by conducting EPA Method 5 source 

testing on the stack emissions 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/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.8. Roseburg shall monitor compliance with Section III.G.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 55 to determine the PM10 emissions from the stack. Method 

5 results may be used as a surrogate for PM10 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 conducting EPA Method 2 Source 

Testing on the stack of 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 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.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 include, 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 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).

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 Decision: 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 Department 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 required 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 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; and

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

of 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

Opacity 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

PM10 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 dcfm Method 2

As Required by 

the Department 

and Section 

III.A.1

Semiannual

Conditions

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 consecutive 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 PM10 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 dcfm (ARM 17.8.749).
OP2303-06 27 Decision: 09/06/2011

Final: 10/07/2011

Compliance Demonstration

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 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 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 

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).

H.6. Roseburg shall monitor compliance with Section III.H.2 by conducting 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 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).

H.7. Roseburg shall monitor compliance with Section III.H.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 100 to determine the PM10 emissions from the stack. Method 

5 results may be used as a surrogate for PM10 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).

H.8. Roseburg shall monitor compliance with Section III.H.4 by conducting 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 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

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 shall include the 

required information, the date, the time, and the initials of the documenting personnel (ARM 

17.8.1212).
OP2303-06 28 Decision: 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 Protocol and Procedures Manual, and shall be maintained on 

site (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 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 

contained in the weekly visual observations log.

I. EU013: Reject System 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 Method 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 PM10 0.005 gr/dscf 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 dcfm Method 2

As Required by 

the Department 

and Section 

III.A.1

Semiannual
OP2303-06 29 Decision: 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 consecutive minutes 

(ARM 17.8.304(2)).

I.2. Emissions of Total Particulate from BH 101 and BH 60 shall each not exceed 0.005 gr/dscf of 

exhaust gas (ARM 17.8.749).

I.3. Emissions of PM10 from BH 101 and BH 60 shall each not exceed 0.005 gr/dscf of exhaust gas 

(ARM 17.8.749).

I.4. The flowrate through BH 101 and BH 60 shall each not exceed 3,000 dcfm (ARM 17.8.749).

Compliance Demonstration

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

stacks of BH 101 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 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 reporting period, as 

specified above, Roseburg shall perform a semiannual Method 9 source test for the visible 

emissions from the BH 101 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 conducting EPA Method 5 source 

testing on the stack emissions of BH 101 and BH 60 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).

I.7. Roseburg shall monitor compliance with Section III.I.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 101 and BH 60 to determine the PM10 emissions from the 

stack. Method 5 results may be used as a surrogate for PM10 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).
OP2303-06 30 Decision: 09/06/2011

Final: 10/07/2011

I.8. Roseburg shall monitor compliance with Section III.I.4 by conducting EPA Method 2 Source 

Testing on the stack of BH 101 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 

Source 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 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).

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 Source 

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 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 

contained in the 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 Department 

and Section 

III.A.1

Semiannual

J.3, J.7, J.10, 

J.11, J.12, J.13 PM10 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 dcfm Method 2

As Required by 

the Department 

and Section 

III.A.1

Semiannual
OP2303-06 31 Decision: 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 consecutive 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 PM10 from BH102 and BH103 shall each not exceed 0.005 gr/dscf of exhaust gas 

(ARM 17.8.749).

J.4. The flowrate through BH102 and BH103 shall each not exceed 28,800 dcfm (ARM 17.8.749).

Compliance Demonstration

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

stacks of BH 102 and BH 103 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 reporting period, as 

specified above, Roseburg shall perform a semiannual Method 9 source test for the visible 

emissions from the BH 102 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 

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).

J.6. Roseburg shall monitor compliance with Section III.J.2 by conducting 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 stacks

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).

J.7. Roseburg shall monitor compliance with Section III.J.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 102 and BH 103 to determine the PM10 emissions from the 

stacks. Method 5 results may be used as a surrogate for PM10 if the impinger analysis (“backhalf”) is included. The testing and compliance monitoring of emissions from the stacks 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).
OP2303-06 32 Decision: 09/06/2011

Final: 10/07/2011

J.8. Roseburg shall monitor compliance with Section III.J.4 by conducting EPA Method 2 Source 

Testing on the stacks of BH 102 and BH 103 to determine the flowrate through each baghouse. 

The testing and compliance monitoring of emissions from the stacks 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 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).

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).

Reporting

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 certification 

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 during 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 Decision: 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 Limit 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.11, 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

PM10 0.005 gr/dscf Method 201A

As Required by 

the Department 

and Section 

III.A.1

Semiannual

K.4, K.8, K.10, 

K.11, K.12, 

K.13

Flow Rate 26,680 dcfm 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 consecutive 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 PM10 from BH 200 and BH 201 shall 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 dcfm (ARM 17.8.749).

Compliance Demonstration

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

stacks 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, 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 34 Decision: 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 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 conducting EPA Method 5 source 

testing on the stack emissions of BH 200 and BH 201 to determine the total particulate matter 

emissions from the stacks. 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 and compliance monitoring of emissions from the stacks 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).

K.7. Roseburg shall monitor compliance with Section III.K.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 200 and BH 201 to determine the PM10 emissions from the 

stacks. Method 5 results may be used as a surrogate for PM10 if the impinger analysis (“backhalf”) is included. 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 and compliance monitoring of emissions from the stacks 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).

K.8. Roseburg shall monitor compliance with Section III.K.4 by conducting 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 stacks 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

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, the 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 maintained on 

site (ARM 17.8.106 and ARM 17.8.1212).
OP2303-06 35 Decision: 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 conducted during 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 exceedance. 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 that 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 this 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 surveys 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.10, 

L.11 L.12, L.13 PM10 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 dcfm Method 2

As Required by 

the Department 

and Section 

III.A.1

Semiannual
OP2303-06 36 Decision: 09/06/2011

Final: 10/07/2011

Conditions

L.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 17.8.304(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 PM10 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 30,000 dcfm (ARM 17.8.749).

Compliance Demonstration

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

stacks of BH 202 and BH 203 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 reporting period, as 

specified above, Roseburg shall perform a semiannual Method 9 source test for the visible 

emissions from the BH 202 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 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).

L.6. Roseburg shall monitor compliance with Section III.L.2 by conducting EPA Method 5 source 

testing on the stack emissions of BH 202 and BH 203 to determine the total particulate matter 

emissions from the stacks. The testing and compliance monitoring of emissions from the stacks

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 conducting EPA Method 201A source 

testing on the stack emissions of BH 202 and BH 203 to determine the PM10 emissions from the 

stacks. Method 5 results may be used as a surrogate for PM10 if the impinger analysis (“backhalf”) is included. The testing and compliance monitoring of emissions from the stacks 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).
OP2303-06 37 Decision: 09/06/2011

Final: 10/07/2011

L.8. Roseburg shall monitor compliance with Section III.L.4 by conducting EPA Method 2 Source 

Testing on the stacks of BH 202 and BH 203 to determine the flowrate through each baghouse. 

The testing and compliance monitoring of emissions from the stacks 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

L.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).

L.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

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 requirements (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 during 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 38 Decision: 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

PM10 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 dcfm Method 2

As Required by 

the Department 

and Section 

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 consecutive 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 PM10 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 dcfm (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 

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 reporting period, as 

specified above, Roseburg shall perform a semiannual Method 9 source test for the visible 

emissions from the BH 204 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 17.8.1213).
OP2303-06 39 Decision: 09/06/2011

Final: 10/07/2011

M.6. Roseburg shall monitor compliance with Section III.M.2 by conducting 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 Source 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 conducting EPA Method 201A source 

testing on the stack emissions of BH 204 to determine the PM10 emissions from the stack. Method 

5 results may be used as a surrogate for PM10 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).

M.8. Roseburg shall monitor compliance with Section III.M.4 by conducting 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 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

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 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

M.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).

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 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 

contained in the weekly visual observations log.
OP2303-06 40 Decision: 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

PM10 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 dcfm 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 consecutive 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 PM10 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 dcfm (ARM 17.8.749).

Compliance Demonstration

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

stacks of BH 300A and BH 300B 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 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 period must be a minimum of 6 minutes 
OP2303-06 41 Decision: 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).

N.6. Roseburg shall monitor compliance with Section III.N.2 by conducting EPA Method 5 source 

testing on the stack emissions of BH 300A and BH 300B to determine the total particulate matter 

emissions from the stacks. The testing and compliance monitoring of emissions from the stacks

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).

N.7. Roseburg shall monitor compliance with Section III.N.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 300A and BH 300B to determine the PM10 emissions from 

the stacks. Method 5 results may be used as a surrogate for PM10 if the impinger analysis (“backhalf”) is included. The testing and compliance monitoring of emissions from the stacks 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).

N.8. Roseburg shall monitor compliance with Section III.N.4 by conducting EPA Method 2 Source 

Testing on the stacks of BH 300A and BH 300B to determine the flowrate through each baghouse. 

The testing and compliance monitoring of emissions from the stacks 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 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).

N.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

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 during 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 42 Decision: 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 Department 

and Section 

III.A.1

Semiannual

O.3, O.7, O.10, 

O.11, O.12, 

O.13

PM10 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 dcfm Method 2

As Required by 

the Department 

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 consecutive 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 PM10 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 dcfm (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, 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 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 and ARM 17.8.1213).
OP2303-06 43 Decision: 09/06/2011

Final: 10/07/2011

O.6. Roseburg shall monitor compliance with Section III.O.2 by conducting 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 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).

O.7. Roseburg shall monitor compliance with Section III.O.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 301 to determine the PM10 emissions from the stack. Method 

5 results may be used as a surrogate for PM10 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).

O.8. Roseburg shall monitor compliance with Section III.O.4 by conducting EPA Method 2 Source 

Testing on the stack of BH 301 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

O.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).

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 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 

contained in the weekly visual observations log.
OP2303-06 44 Decision: 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.12, 

P.13

PM10 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 dcfm Method 2

As Required by 

the Department 

and Section 

III.A.1

Semiannual

Conditions

P.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 17.8.304(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 PM10 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 dcfm (ARM 17.8.749).

Compliance Demonstration

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

stacks of BH 302 and BH 303 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 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 period must be a minimum of 6 minutes 
OP2303-06 45 Decision: 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 conducting EPA Method 5 source 

testing on the stack emissions of BH 302 and BH 303 to determine the total particulate matter 

emissions from the stacks. The testing and compliance monitoring of emissions from the stacks

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.7. Roseburg shall monitor compliance with Section III.P.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 302 and BH 303 to determine the PM10 emissions from the 

stacks. Method 5 results may be used as a surrogate for PM10 if the impinger analysis (“backhalf”) is included. The testing and compliance monitoring of emissions from the stacks 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 conducting EPA Method 2 Source 

Testing on the stacks of BH 302 and BH 303 to determine the flowrate through each baghouse. 

The testing and compliance monitoring of emissions from the stacks 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

P.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).

P.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

P.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).

P.12. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (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 during 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 46 Decision: 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 Section 

III.A.1

Semiannual

Q.3, Q.7, Q.10, 

Q.11, Q.12, 

Q.13

PM10 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 dcfm Method 2

As Required by 

the Department 

and Section 

III.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 consecutive minutes 

(ARM 17.8.304(2)).

Q.2. Emissions of Total Particulate from BH 304 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 

17.8.749).

Q.3. Emissions of PM10 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 dcfm (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 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 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 17.8.1213).
OP2303-06 47 Decision: 09/06/2011

Final: 10/07/2011

Q.6. Roseburg shall monitor compliance with Section III.Q.2 by conducting 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 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).

Q.7. Roseburg shall monitor compliance with Section III.Q.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 304 to determine the PM10 emissions from the stack. Method 

5 results may be used as a surrogate for PM10 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).

Q.8. Roseburg shall monitor compliance with Section III.Q.4 by conducting 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 

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

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 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 

contained in the weekly visual observations log.
OP2303-06 48 Decision: 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

Semiannual

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

PM10 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 dcfm Method 2

As Required by 

the Department 

and Section 

III.A.1

Semiannual

Conditions

R.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 17.8.304(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 PM10 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 dcfm (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 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 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 applicable limit, then the observation period must be a minimum of 20 
OP2303-06 49 Decision: 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 III.R.2 by conducting 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 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).

R.7. Roseburg shall monitor compliance with Section III.R.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 400 to determine the PM10 emissions from the stack. Method 

5 results may be used as a surrogate for PM10 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).

R.8. Roseburg shall monitor compliance with Section III.R.4 by conducting 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 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

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 information, 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 Manual, 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. The 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 during 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 Decision: 09/06/2011

Final: 10/07/2011

S. EU028: Schilling & Bullnose Saw & Edge Bander Line (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 surveys 

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

PM10 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 dcfm 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 consecutive 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. Emissions of PM10 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 dcfm (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 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 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 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 
OP2303-06 51 Decision: 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 conducting 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 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.7. Roseburg shall monitor compliance with Section III.S.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 401 to determine the PM10 emissions from the stack. Method 

5 results may be used as a surrogate for PM10 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 conducting 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 17.8.106 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 during 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 52 Decision: 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

PM10 0.005 gr/dscf Method 201A

As Required by 

the Department 

and Section 

III.A.1

Semiannual

T.4, T.8, T.10, 

T.11, T.12, 

T.13

Flow Rate 1,700 dcfm 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 source, that exhibit an opacity of 20% or greater averaged over 6 consecutive 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 PM10 from BH 404 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

T.4 The flowrate through BH404 shall not exceed 1,700 dcfm (ARM 17.8.749).

Compliance Demonstration

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

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 reporting 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 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 
OP2303-06 53 Decision: 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).

T.6. Roseburg shall monitor compliance with Section III.T.2 by conducting EPA Method 5 source 

testing on the stack emissions of BH 404 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).

T.7. Roseburg shall monitor compliance with Section III.T.3 by conducting EPA Method 201A source 

testing on the stack emissions of BH 404 to determine the PM10 emissions from the stack. Method 

5 results may be used as a surrogate for PM10 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).

T.8. Roseburg shall monitor compliance with Section III.T.4 by conducting EPA Method 2 Source 

Testing on the stack of BH 404 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, 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).

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 certification 

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 during 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 54 Decision: 09/06/2011

Final: 10/07/2011

U. EU055: Melamine Baghouse (BH500)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

Method Frequency

Reporting 

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

As Required by 

the Department 

and Section 

III.A.1

Semiannual

U.3, U.7, U.10, 

U.11, U.12, 

U.13

PM10 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 dcfm Method 2

As Required 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 minutes 

(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 PM10 from BH500 shall not exceed 0.005 gr/dscf of exhaust gas (ARM 17.8.749).

U.4. The flowrate through BH500 shall not exceed 21,000 dcfm (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. 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 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 observation period must be a minimum of 6 minutes unless any one reading 
OP2303-06 55 Decision: 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 monitor 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 

requirements 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 emissions of BH 500 to determine the PM10 emissions from the stack. Method 

5 results may be used as a surrogate for PM10 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).

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 

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

U.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).

U.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

U.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).

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 

contained in the weekly visual observations log.
OP2303-06 56 Decision: 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.11, V.13, 

V.14, V.15

Opacity 20%

Visual surveys Weekly

Semiannual

Method 9

Semiannual (if 

visual surveys 

are not 

conducted as 

specified)

V.2, V.7, V.11, 

V.13, V.14, 

V.15

Total Particulate 8.0 lb/hr for all four 

stacks combined Method 5

As Required by 

the Department 

and Section 

III.A.1

Semiannual

V.3, V.8, V.11, 

V.13, V.14, 

V.15

PM10

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

Controlled 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 consecutive 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 PM10 emissions for all four 

stacks combined (ARM 17.8.749).

V.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).

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 CFR 63, Subpart 

DDDD).

Compliance Demonstration

V.6. Once per calendar week during daylight hours, Roseburg shall visually survey emissions from the

Biofilter 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 
OP2303-06 57 Decision: 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 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 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 conducting EPA Method 5 source 

testing on the press vents to determine the total particulate matter emissions from the stacks. The 

testing and compliance monitoring of emissions from the stacks 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).

V.8. Roseburg shall monitor compliance with Section III.V.3 by conducting EPA Method 201A source 

testing on the press vents to determine the PM10 emissions from the stacks. Method 5 results may 

be used as a surrogate for PM10 if the impinger analysis (“back-half”) is included. The testing and 

compliance monitoring of emissions from the stacks 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).

V.9. Roseburg 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.12. 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 58 Decision: 09/06/2011

Final: 10/07/2011

Reporting

V.13. 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 required 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 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. Certification of compliance with 40 CFR 63, Subpart DDDD.
OP2303-06 59 Decision: 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.11, 

W.13, W.14, 

W.15

Opacity 20%

Visual surveys Weekly

Semiannual

Method 9

Semiannual (if 

visual surveys 

are not 

conducted as 

specified)

W.2, W.7, 

W.11, W.13, 

W.14, W.15

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.11, W.13, 

W.14, W.15

PM10

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 Device 

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, 

Subpart 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 consecutive minutes 

(ARM 17.8.304(2)).

W.2. Press 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 PM10 emissions for all four 

stacks combined (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 during daylight hours, Roseburg shall visually survey emissions from the 

Biofilter 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 
OP2303-06 60 Decision: 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 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 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).

W.7. Roseburg shall monitor compliance with Section III.W.2 by conducting EPA Method 5 source 

testing on the press vents to determine the total particulate matter emissions from the stacks. The 

testing and compliance monitoring of emissions from the stacks 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).

W.8. Roseburg shall monitor compliance with Section III.W.3 by conducting EPA Method 201A source 

testing on the press vents to determine the PM10 emissions from the stacks. Method 5 results may 

be used as a surrogate for PM10 if the impinger analysis (“back-half”) is included. The testing and 

compliance monitoring of emissions from the stacks 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).

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-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).

W.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).

W.12. 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 Decision: 09/06/2011

Final: 10/07/2011

Reporting

W.13. 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).

W.14. The annual compliance certification required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212).

W.15. 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. 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

PM10 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

Installed 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. Roseburg 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 emissions 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 PM10 when venting 

from the sander dust boiler abort stack (ARM 17.8.749).
OP2303-06 62 Decision: 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 stack 

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 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 17.8.749).

Compliance Demonstration

X.6. Once per calendar week during daylight hours, Roseburg 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 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 boiler. 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).

X.7. Roseburg shall monitor compliance with Section III.X.2 by conducting EPA Method 5 source 

testing on the boiler 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).

X.8. Roseburg shall monitor compliance with Section III.X.3 by conducting EPA Method 201A source 

testing on the boiler to determine the PM10 emissions from the stack. Method 5 results may be 

used as a surrogate for PM10 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).
OP2303-06 63 Decision: 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 

observed 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 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).

X.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).

X.13. Roseburg shall maintain the records required by Section III.X.9, and III.X.10 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 (ARM 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 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; 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 Decision: 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 

Combustion

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

NOx 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 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)).

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 NOx 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 Decision: 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 emissions 

exist or may exist at these locations, further opacity monitoring may be required (ARM 17.8.749).

Compliance Demonstration

Y.8. 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 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 reporting period, as 

specified above, Roseburg 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, whichever 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 conducting 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. 

By the 25th 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 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).

Y.11. Roseburg shall monitor compliance with Sections III.Y.4 and III.Y.5 by conducting EPA Methods

7E and 10 source testing on the Roemmc Burner emissions for NOx 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 additional testing (ARM 

17.8.105, ARM 17.8.749, and ARM 17.8.1213).
OP2303-06 66 Decision: 09/06/2011

Final: 10/07/2011

Y.12. Roseburg shall monitor compliance with Section III.Y.6 by conducting EPA Methods 18, 25, or 

25A (as determined by the Department) source testing on the Roemmc Burner emissions for 

VOCs. 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.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 shall 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 Protocol 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 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; 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 Decision: 09/06/2011

Final: 10/07/2011

Z. EU047: 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 Surveys 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

NOx 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 

determined 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 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 17.8.304(2)).

Z.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).

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 NOx 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 exceed 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 Decision: 09/06/2011

Final: 10/07/2011

Z.8. The Department reserves the right to require opacity monitors at the Solagen 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 emissions exist or may exist 

at these locations, further opacity monitoring may be required (ARM 17.8.749).

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 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 reporting period, as 

specified above, Roseburg 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, 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 conducting 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).

Z.11. Roseburg shall document, by month, the amount of sander dust combusted in the Solagen Burner. 

By the 25th 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. 

By the 25th day of each month, Roseburg shall total the amount of natural gas 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.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 Methods

7E and 10 source testing on the Solagen Burner emissions for NOx and CO, concurrently. The 

testing and compliance monitoring of emissions from the stack shall take place every two years, or 

according to another testing/monitoring schedule as may be approved by the Department. The 
OP2303-06 69 Decision: 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 

additional 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 Methods 18, 25, or 

25A (as determined by the Department) source testing on the Solagen Burner emissions for VOCs. 

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).

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 Source 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 required 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 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; and

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

of deviations from any permit requirements identified.
OP2303-06 70 Decision: 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 Department 

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)

Recordkeeping 

(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 consecutive minutes 

(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 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).

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 standard 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 the 

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 Decision: 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 hot oil heater. 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).

AA.6. Roseburg shall monitor compliance with Section III.AA.2 by conducting 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 

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).

AA.7. Roseburg shall document, by month, the amount of natural gas combusted in the hot oil heater. 

By the 25th 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 rolling 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 at 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 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).

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 maintain 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 Protocol 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 Decision: 09/06/2011

Final: 10/07/2011

AA.14.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; 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

BB.1, BB.6, 

BB.11, BB.12, 

BB.15, BB.16, 

BB.17

Opacity 10%

Visual Surveys Weekly

Semiannual

Method 9

Within 180 days 

of actual startup; 

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/dscf Method 5

Within 180 days 

of actual startup; 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.10, 

BB.14, BB.16, 

BB.17

RTO Routine Control 

Device Maintenance 

Exemption

Maximum of 3% of 

the 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 maintain a Regenerative Thermal Oxidizer (RTO) to control 

VHAP emissions from the wood-fired green furnish predryer (ARM 17.8.749).

BB.3. Roseburg shall not cause or authorize to be discharged into the atmosphere from the RTO any 

particulate matter emissions in excess of 0.10 gr/dscf (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 (ARM 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 Decision: 09/06/2011

Final: 10/07/2011

Compliance Demonstration

BB.6. Roseburg 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 

emissions 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 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 hot oil heater. 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).

BB.7. Roseburg shall monitor compliance with Section III.BB.2 by documenting, monthly, that the RTO 

has been installed, operated, and maintained. 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 with Section III.BB.3 by conducting 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 Procedures 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.10.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.11.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).
OP2303-06 74 Decision: 09/06/2011

Final: 10/07/2011

BB.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).

BB.13.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).

BB.14.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).

Reporting

BB.15.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 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.

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

Method 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 consecutive minutes 

(ARM 17.8.304(2)).
OP2303-06 75 Decision: 09/06/2011

Final: 10/07/2011

Compliance Demonstration

CC.2. Once per calendar week during daylight hours, 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 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 emitting units. 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).

Recordkeeping

CC.3. 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).

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 contain 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 during 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; and
OP2303-06 76 Decision: 09/06/2011

Final: 10/07/2011

DD. Remanufacturing Facility

EU050: Bullnose Fugitives (FUG 400)

EU051: Paintline Fugitives (FUG 401)

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration

Method Frequency

Reporting 

Requirements

DD.1, DD.5, 

DD.9, DD.10, 

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.11, DD.14, 

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.14, 

DD.15

Paints (VOCs)

Water-Based Paints 

and U.V. Curable 

Fillers

Recordkeeping Monthly Semiannual

DD.4, DD.8, 

DD.12, 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 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)).

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 and 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 and 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, 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 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 tests must be performed in accordance with 
OP2303-06 77 Decision: 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 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).

DD.6. Roseburg shall document, by month, the production of painted material from Bullnose #2. By the 

25th day of each month, Roseburg shall total the production of painted material from Bullnose #2 

during the previous month. The monthly 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 17.8.1213).

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 monitor 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, the 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 maintained on 

site (ARM 17.8.106 and ARM 17.8.1212).

DD.11.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.12.Roseburg shall maintain all applicable 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 and JJ).

Reporting

DD.13.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.14.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 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;
OP2303-06 78 Decision: 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. 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 Demonstration

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 * P0.11

- 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 source, that exhibit an opacity of 20% or greater averaged over 6 consecutive 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. 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 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 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).
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EE.4. Roseburg shall monitor compliance with Section III.EE.2 by conducting EPA Method 5 source 

testing on the board cooler vents to determine the total particulate matter emissions from the vents. 

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 conform 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 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).

EE.6. 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

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 requirements (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 results 

contained in the weekly visual observations log.
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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 time 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 17.8.323

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 specific 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 previous applications) in Section IV.A, these requirements relate to each specific unit, as 

well as facility wide.
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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 reissuance, 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 planned 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 Department, 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 

permittee 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 unless 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 certification 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, 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.

2. Compliance certifications shall be submitted by February 15 of each year, or more frequently 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).
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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 condition 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 Protection 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 enforceable 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 applicable 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 reissuance) 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 FCAA;

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 emergency powers of the Department under the Montana Clean Air Act, Title 75, 

Chapter 2, MCA; and
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g. The ability of the Department to establish or revise requirements for the use of Reasonably 

Available Control Technology (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. Pursuant 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 relevant 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 

ownership (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 include 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 results 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. Strip-charts must be maintained in their original form at the plant site 

and shall be made available to Department personnel upon request.
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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 

include 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 corrective 

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 potentially 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 

accordance 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 routine internal review 

by the permittee).

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 Permit 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 restore normal operation and causes the source to exceed a technologybased 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 improperly 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;
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b. The permitted facility was at the time being properly operated;

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 Department 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 emissions, 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. Upon 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 emissionsrelated 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 applicable 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 operating 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 after 
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Final: 10/07/2011

receipt of the notice. Any remaining fee, which may be due after the 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 days 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 to 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 Permit 

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, Subchapters 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 Department 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 revision. 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 longer 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;
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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 provides 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 procedures 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 

administrative 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 applicable 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 participation, 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 

revision, 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 revised 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 any 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 administrator, excess 

emission offset plans shall be deemed incorporated into the permit;
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c. The Department or the administrator determines that the permit contains a material mistake 

or that inaccurate statements were made in establishing the emission standards 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, Subchapter 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 application, 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 the 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 renewal 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 permit 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 its 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 administrative permit 

amendments.
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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 Implementation 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 privilege.

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

ARM 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 Standards §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 production 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 date 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 ARM 17.8.604, 605 and 606.
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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 specified 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 issued 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 violate 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 Subchapters 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 

Permitting; or

e. Emission reductions obtained 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 capacity 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 

circumstance 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 permittee 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 permittee shall comply with ARM 17.74.301, et seq., and ARM 17.74.401, et seq. (State only)
OP2303-06 91 Decision: 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 this 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 Emission 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 performing 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 more 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 Control 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

Terms 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 Decision: 09/06/2011

Final: 10/07/2011

APPENDICES
OP2303-06 A-1 Decision: 09/06/2011

Final: 10/07/2011

Appendix A INSIGNIFICANT EMISSION UNITS

Disclaimer: The information in this 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 within 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 Section 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 following 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 activities 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 (I120)

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 – General 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 Processing 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 Drying Oven #1 (S400)

IEU30 Paint Drying Oven #2 (S401)

IEU31 Paint Drying Oven #3 (S402)
OP2303-06 B-1 Decision: 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 permit revision that:

(a) Corrects typographical errors;

(b) Identifies 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) Requires more frequent monitoring or reporting by Roseburg;

(d) Requires changes in monitoring or reporting requirements that the Department deems to be 

no less stringent than current monitoring or reporting requirements;

(e) Allows for a change in ownership or operational control 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) Incorporates any other type of change which the Department has determined to be similar to 

those revisions 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) Any 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) Any federally enforceable term, condition or other requirement of any Montana Air Quality 

Permit issued by the Department under Subchapters 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 Parts C and D;

(c) Any standard or other requirement under Section 7411 of the FCAA, including Section

7411(d);

(d) Any standard or other requirement under Section 7412 of the FCAA, including 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) Any standard or other requirement of the acid rain program under Title IV of the FCAA or 

regulations promulgated thereunder;

(f) Any requirements established pursuant to Section 7661c(b) or Section 7414(a)(3) of the 

FCAA;
OP2303-06 B-2 Decision: 09/06/2011

Final: 10/07/2011

(g) Any standard or other requirement governing solid waste incineration, under Section 7429 of 

the FCAA;

(h) Any standard or other requirement for consumer and commercial products, under Section

7511b(e) of the FCAA;

(i) Any standard or other requirement for tank vessels, under Section 7511b(f) of the FCAA;

(j) Any standard or other requirement of the regulations promulgated to protect stratospheric 

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) Any national ambient air quality standard or increment or visibility requirement under Part 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) Any federally enforceable term or condition of any air quality open burning permit issued by 

the Department under Subchapter 6.

"Department" 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 limit) 

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 

meant 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, including 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, Subpart 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, covers 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 

Section 112(b) of the FCAA. 

"Non-federally 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 administrative 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 Decision: 09/06/2011

Final: 10/07/2011

(b) Any term, condition or other requirement contained in any Montana Air Quality Permit

issued by the Department under Subchapters 7, 8, 9 and 10 of this chapter that is not federally 

enforceable;

(c) Does not include any Montana ambient air quality standard contained in Subchapter 2 of this 

chapter.

"Permittee" 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 issuance, renewal, amendment, or modification 

pursuant to this subchapter.

"Regulated air pollutant" means the following:

(a) Nitrogen oxides or any volatile organic compounds;

(b) Any pollutant for which a national ambient air quality standard has been promulgated;

(c) Any pollutant that is subject to any standard promulgated under Section 7411 of the FCAA;

(d) Any Class I or II substance subject to a standard promulgated under or established by Title VI 

of the FCAA; or

(e) Any pollutant subject to a standard or other requirement established or promulgated under 

Section 7412 of the FCAA, including but not limited to the following:

(i) Any pollutant subject to requirements under Section 7412(j) of the FCAA. If the 

administrator fails to promulgate a standard by the date established in Section 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 Section 

7412(e) of the FCAA; 

(ii) Any pollutant for which the requirements of Section 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 vice-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 responsible for the overall operation of one or more 

manufacturing, production, or operating facilities applying for or subject to a permit and 

either:

(i) The facilities employ more than 250 persons or have gross annual sales or expenditures 

exceeding $25 million (in second quarter 1980 dollars); or 

(ii) The 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.
OP2303-06 B-4 Decision: 09/06/2011

Final: 10/07/2011

(c) For a municipality, state, federal, 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 

operations 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 Decision: 09/06/2011

Final: 10/07/2011

Abbreviations:

ARM Administrative Rules of Montana

ASTM American Society of Testing Materials

BACT Best 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 Episode 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

NO2 nitrogen dioxide

O2 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

SO2 sulfur dioxide

SOx oxides of sulfur

TPY tons per year

U.S.C. United States Code

VE visible emissions

VOC volatile organic compound
OP2303-06 C-1 Decision: 09/06/2011

Final: 10/07/2011

Appendix C NOTIFICATION 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, Montana Office

10 W. 15th 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 and Regulatory Assistance

Air and Radiation Program

US EPA Region VIII 8P-AR

1595 Wynkoop St.

Denver, CO 80202-1129
OP2303-06 D-1 Decision: 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 

assist Roseburg, permitting authority, inspectors, and the public.

1. Direction to Plant: The facility is located 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 4007, 

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 Decision: 09/06/2011

Final: 10/07/2011

Appendix E COMPLIANCE ASSURANCE MONITORING (CAM)

Emitting Unit: EU008 – #1 Predryer (DRY 500)

Pollutant: PM10

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 Table I below. 

Table I

A. General 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 field. (P=V1I1 + V2I2)

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 value 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 measured 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 WESP power input (kW)

Quality Assurance/Quality 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 Line 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 readings per 

hour block. The data will be stored in an electronic database 

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 the 

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 permit), 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 Decision: 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 operating 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 Maintenance 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 hours Semiannual

RTO Media Changeout 5 days Approximately every 3-5 years

ESP Screen Cleaning 8-10 hours Every 2 weeks