1
Permit Number: 26 . 3025•

Expiration Date: 11/1/B7

Page I of 5 Pages

AIR CONTAMINANT DISCHARGE PERMIT

. De partment of Environmental Quality

522 Southwest Fifth, Portland, OR.97204.

Mailing Address.: ' Sox 1760, Portland, OR 97247

Telephone': (503). 229-5696

Issued in acoOrdan.ce with the provisions of ORS• 468.310

I.SSTJ..D TO INFORMATION RELIE`3 UPON :

Industrial Laundry & Dry Application No. 20 0 2,

Cleaners, Inc.

s;ba Master Cleaners Date Received: 11/5,'80

4245 S.E. Milwaukie Ave.

Portland, Ol 97202

PLANT SITE:

4245 S.E. ,iilw,augie Ave.

ISSUED BY D] PARTMENT OF LWIROPfltEWTAL QUALITY

At. IWILLIAM H. YOUNG ,r rector

kid/

Source (s) Permitted to Discharge Air Contaminants:

Name of Air Contaminant Source Standard Induetru Code as Listed

Dry Cleaning Plant

t;s;isting source not listed on Table A for which an air quelity problem is

identified by the Departnent (low cost).

Permitted Activities

Until such time as this permit. expires or is modified or revoked, the .

pe.rm.it•tee is herewith allowed to discharge exhaust gases containing air

contaminants including emissions from those processes and activities

directly related or associated thereto in accordance with the requirements,

limitations; and conditions of this permit. from the air contarli.nart •

source (s) listed above.

The specific listing of requirements, limitation: and conditions contained

herein does not relieve the permi ttee frill cunpiying with all other rules

and standards of the Department,

fated

DD.; ITsj

2
Page 2 of 5 Pages '

Permit Number: 26-3025

Expiration Date: L1/1/87

Performance Standards and Emission Limits

contaminants are kept at the toisest levels.

2. The pecmittee shall not allow the emission of odorous ;,i. ttet as

msaLused off the permittee's property in excess ot

a, A soestometer no.. 0 odor strength or oTsiosslent dilution tn

sesidential and commercial areas.

b. A scentomQter no. .2 . odor strengUb -or e uivalsnt dilution in a.tl

other land use areas'.

. . .

A violation of Condition 2a or 2b shall have oosurted when two

measurements made by the Department within s period of , ons hour,

separated by at least 15 minutes excoed tin. limits.

Soecial Condition

3. Tho . Hoyt DrYer ReClaiMer Shall be in continuous use to capture at

least 51.5 tons of cleaning fLilid per ysat or 70% of tie' fluid used

if less that 18,720 gallons (65.5 tons. ) are used per year

Oni.SSiOO reduction p '..On

Action. tb bo Tak.on

Prepare to cesse dry cleaning

operations.

Cease dry ol, esning oporations so

that no dry clewing fluid or oslsss

is- teinssod to the atmosphere.

1

s. Continue Warning measures.

2- mirimize emissions by r(,Is:.'ucirl G

he.it and stosm 3ems.ods .to

absolute neosssities '

consistent with preventing

f:croir.mc..It. dan s...3 e

5. The 'permittee shall demonstrate thst the 'soyt Petro Riser is capably

of operating in continuous omplionce . with Condition 3 by- perfor: iog

a test for.. emissions from the : unit by June 1, 1981. 'All. test data

-and results shall be submitted to the Department for review by no

later, than July l 1581. Cmplianoe. shall have been dmonstrace d

1. The permittee• shall at all times Maintain snd operate all air

contaminant generating processes and, all contaminant control equipment

at fell efficiency and effectiveness, such that the emissions of air

Emission Reduction Plan

4. The putmittee s'hsll implonont the' r9 .lluwio9

when so notified by the Deparment:

Notice Cdtdition *so

a.. . . Alt Level

b.. . '7srning Leva

. EseSgency Level

3
Page 3 of 5 Pages

Permit Number: 26-3023 .

Expiration Date: 11:1/87

upon written approval, by the Deperbnent, of the test data and

results. All tests shall be conducted in accordance with the testing

procedures on file (Test Method 34, Material Balance) at the

Department or in conformance with applicable standard methods approved

in advance by the Department.

Mean ing and Reporting

6 The per.mittee shall effectively inspect and monitoe the operation

and maintenance of the plant and associated air. contaminant control

facilities. A record of all such data shall be maintained for a

period of one year.. and be available at the plant •site at al timee

for inspection by the authorizerd representatives of the Department.

At least the following parameters shall be monitored and recorded

at the indicated interval.

Parameter . . l1nimum ::anion:ing :nouerce

a. The-amount of clearing fluid A n nually

purchased.

b. The ai+nouet of cleaning fluid Annually

used.

c. The amount of spent solvent Annually

reclaimed and shipp;d to

reclaimers.

d. Calculated amount of solvent ?tnr:uell1

emitted to the atmosphere.

e A description of many:' As Perior: ed

,ma.inte K nee to the air

nt.aminent control eyetm.

7. The pertnittee shall report to the Deparcnent by Januery 13 of each

year this.. permit is in effect the following information for the

preceding calendar year:

a. •Plant loss of cleaning fluid, substantiated by irnounts listed

above as 6.a, through 6.d.

b. Quantities acid types of fuels used.

Fee Schedule -

8. The- Annual Com pliance Determination Fee for this permit is slue

October 1 of each year this permit is in effect. An invoice

indicating the amoune, as dets:rmined by Department regulations,

be mailed prior to the above date.

4
Permit Humber: 26-3025

Expiration Date: II/1/87

Page 4 of S Pages

General Conditions and Disclaimers

GI. The permittee shall allow Department of Environmental Quality

' representatives access to the plant site and pertinent records at

all reasonable times for the purposes of making inspections,

collecting samples, obtaining data, roviewing end copying air

contaminant emission disdharge records and otherwise conducting all

necessary: functions related to this permit.

G2. .The permittee is prohibited from conducting open burning except as

may 'be allowed by OAR Chapter 340,. Sections 23-025 through 23-050.

G3. The permittee shall;

a. Notify the Department in writing using a Departmental. "Ilotice

Of Construction" fotm,, and

b. Obtain written approval...

before:

a. Constructing or installing any . new :new:cc of air contenrnaat

emissione i inolLiding air pollution control eciui:tent, of

Modifying or altering an exietiag coerce that may eignificentl e

affect the emisSion of air contaminanes.

C4. The permittee shall notify the Department at 1.eact t4 heure in

of any planned shutdown of air pollution control equij.meni: for

scheduled maintenance that may caeae a violation of ppl.iczble

standards.

G The Permi t:tee Y till. notify the Depar bunt by telephone or. in pet-ton

within ore (1) hour of any malfunction of air pollution contre:

equignent or other upset condition that may cause a violation of 1: be

applicable standards. Such notice shall include the nature and

Taantit.y of'the increased emissions that have occurred ind the

expected dueation of the breakdown.

G6. The per.Mittee shall at all times conduct duet suopteesion measurer;

to Meet the requirements set forth in "Fugiti're El-nissions" and

"Nuisance Conditions" in OAR Chapter 340, 'SItions 21-050 theough

21-060.

G7. Application for a modification of this - per:nit :nust be Suleeitted noc

Less than 60 days prior to the source modification. A Filing Fee

and an Application Processing Fee must be suhnitted with an

application for the permit modification

G8. Application for renewal of this permit meet be submitted not lees

than 60 days p.bior to the peemit ex pi=ation date. A Filing Fee and

an Annual Compliance Determination Fee meet be _submitted with the

-application for the peemit renewal.

G9. The issuance ef this permit does not convey , any propetty riahts in

either reel or personal property, or:any exclusive privileges, hr

doee. it ,authorize any injury to private property or, eny invasien of

personal righte, nor any iefringement .f federal, state., or local

laws or ae.gulatione.

5
Page 5 of 5 Pages

Permit Number: 26-3025

Expiration Date; 11/i/37

GIO. This permit is subject to revocation for cause as provided by law.

G11. Notice.proviclion: Section 113(d)(1)() of the Federal Clean Air Act,

as ..amended in 1977, requires that a major stationary source, as

defined in that act, be notified herein that "it will be required

to pay a noncccnpliance pen'alty under Section 120 (of that act) or

by such later date as is set forth in the order (i.e., in this perrnir)

in accordance with Section 120 in the event that such source fails

to achieve final compliance by July 1, 1979."

P26302.5

6
I

Permit Number: " 26-3025

Application No.: 2002

Dater November 6, 1980

{

Department of Environmental Quality

Air Quality Control Division

AIR CONTAMINANa'. DISCHARGE PER.NIT APPLICATION ,RZVIEW REPORT

Industrial Laundry . & Dry Cleaners, Inc.

4245 Southeast Milwaukie Avenue

Portland, OR 97202

Lackgrountl

1. Indu.strial Laundry and Dry Cleaners, Inc., dl Master Cieane a,

operates a dry cleaning business, located at 4245 Southeast Milweekie

Avenue iii Portland.

2. The ahnual. production capacity is approximately 521,000 gourds of

clothes cleaner'..

4. The emission control system will be a- Hoyt Petro hN.ser o].vcnt vapor

recovery unit.

5. The estimated annual rate of ait contaminant- emission i., 65.5 tons

per,. year now, 14 tons per year after the Hoyt unit is installed..

The plant. L.s Operated 8-hours per day-, 5. rays per' week.; and 52 weeks

per year..

7.. H. rura1 gas is burned.. in the. boiler. Estimated annual fuel

consumption consists of 70,000 therms neeur•a.l. , y_is.

Evaluation

3.. The emissions from the plant have been determined to he in compliance

with Department. of Environmental Quality emission limitations,

9. The p lant received Departmental approval April 25, 1980, to install

the Hoyt unit. It is estimated that a_re_duction of 51.5 tone pct.

year of Velatile Organic Compounds will occur. Publishers Pepe r

Company is in the process of buying that reduction, to use as an

offset . (partial) .for their new, hogged-fuel, 300,000 lb/he boiler

at their Newberg' mill. See Publishers' Mt Contaminant t schange

Pexnti t 3660 .11.

?ec'Omme nda t =' cart

1.0. It is recommended that the proposed Permit be approved for issuance

to Industrial Laundry , and Dry Cleaners, "Inc.

P. Basset- men, Nov.' 6; 1900

P2630.2.5R (wn)

3 The plant' 's five dryers consumed 18,720 gallons of Stoddard solvent

in 1979.

7
1 BEFORE THE &NVIRON TAL QUALITY COI iISS ION

2 OF THE STATE OF . OR13 ON

3

4 In the matter of the Transfer by

VANPLY, INC. of a 1C Offset to

5 to Spalding Pulp & t Paper Co.

7 N.s

9 . 1. The purpose of. this Stipulation and Consent Final Order. is to

10 make permanent , and. federally and state enforceable a• certain reduction

11 of emissions of iao1at ,'le .organic compounds ("`VCC") by Vanply, Inc.

12 .(" Vanply " ) which is intended. to. partially offset and. thereby partially

13 allow a certain VCC mission increase proposed by Spaulding Pulp & Paper

14 'Co. ("Spaulding" ), n accordance with applicable federal and state Laws.

15 2. Cn January 3, 1980, the Oregon Department of Environmental Quality

16 ("Department") issued to Spaulding air contaminant discharge Permit No.

17 36_6041 pursuant to permit application No 1557 filed with the Department

18 . on March. 29, 1979. Permit No. 36-6041 authorizes Spaulding to discharge

19 air contaminants from its new wood fired No. 10 boiler at Publishers Paper

20 Mil., Newberg, Oregon. in accordance with the conditions contained in the

21 permit. The permit is scheduled to expire on October 1., 1984.

22 3. Special condition No. 9 of Spaulding's. permit re q uites Spaulding

23 to secure and have in effect emission reductions ("offset") in the amount:

24 of 569 tons per year of VCC prior. to operation of boiler No. 10.

25 4. The offsets referred to in paragraph 3 above were and are

26 r.equi-red. by the p rovisions of the Clean Air Act, as amended, the United .

ge .L-STIPULATION CONS1a" T FINAL O1DER

STIPULATION AND cONS rr

FINAL ORDLR

)

)

)

8
1 States Environmental Protection Agency's ( " EPA") implementing rules,

2 regulations and rulings, and Oregon PAministrative Rules 340-20-192(1),

3 as a prerequisite to Spaulding operating its No. 10 boiler, a "new major

4 source" under those laws. The emissions, reductions were and are required

to be permanent and federally ahd ' state enforceable.: by , the above cited

laws

5. Pri.br. tro S ptcrii^^er 1U . . 197. 9 [date of s le to

Vanply), D: G. shelter Products, a tlcTh.^^.z 4 • [State of

9 in rpor;,tion] corporation, owned' and. operates a flat tam coating facility

10 at Beaverton, Oregon. B.G. Shelter Produc=Ls opereted is Pe a eeton

11 facility and emitted 97 torts pf:r year of VcX therefrom pursuant to air

12 contaminant discharge permit .^'',o. 34-2632 _issued by the a_par°t: ent to D. G.

13 Shelter Products

14 G. •:Effect;ive .3eptember 10 ;15 U. G. Shelter

15 Products sold its Beaverton fecility to Vanply, Inc, ("Vey ply") ,

16 a tieshinuton . [state of• incorporation]. corporation, which cor.;o1e.Eeiy

17 shut c ti'n the . facility and terminated all []"`C emissions therefrom.

i 7. ..:O September 29, 1980, Spaulding a^n^d Vanply agreed to relinquish,

19 transfer and assign to Spaulding any and all right, title and interest

2o ard claim Vanply. may have with respect - to the 97 tons' per year--.reduction

21 of emissior.S resulting iron the closure by Vanply at its above

22 described Beaverton facility in_ order to allow Spaulding to partially

23 satisfy the offset requirement described above in paragraphs 3 and

to execute any other irlr trunents, such as thi ,

to accomplish the purposes of the agreement.

for it offset tcensfer described

5

.26

Vanply also agreed therein

required by the Department

-8. Vanply understands that in order

2--STIi 1LaTIO T CCNSEN1 FINAL ORDER

9
1 in paragraph 7.above to be effective to authorize Spaulding to operate

2 its No. 10 boiler, as was the purpose of Vanply's agreent with Spaulding,

3 Vwnply has.. to commit itself, its successors and assigns to making the

4 enissian reductions permanent and federally and state enforceable and that

5 that is the purpose of this S.tipulation and Consent Final Order. Vanply

5 understands, further that because its offset eca ibnent contained herein

will be permanent and federally. and state enforceable that it therefore

would prevent Vanicaly, its succesors and asignees from starting up or

expanding after September 28 , 1979 [date of shutdown}, the sage or

10 a similar operation with associated emissions at the 'cave ton site,

11 or any other site in Air' Quality Control Region 193 without Vanply, its

12 successors or assigns, obtaining its own offsets not related to ths

13 offset. • ,art ermore, as a conse quence thereof, if Vanply, its sudcesors

14 or assigns, ever makes application with the fYpartanent for an air

15 contaminant discharge permit or preconstruction -authorization to so start

iG up or expand, the C apartment and the Oregon 1:1nvirornlental Quality

17 Commission' ( "Commission") would be required to deny the application until

18 the applicant. obtains its own offset: unrelated to - this offset. Vanply

15 confirm that neither it., its successors nor assi cjrnshas so started up

20 or expanded any such operation. .

21 9. Vanply understands- that this is one of the first offsets that

22 the Department and the Commission have had to deal with and that the- -ef :re

23 the criteria and limitations of offsets have not yet been fully defined

24 . by rules. Vanply also understands that this offset will be regulated- by

25 and will be subject to the limitations contained in future rules, when

26 they are adopted and that the final order container nerln will, then be

3g_ 3-STIPULATION AND 4ONSEl i I '' L ORDER

10
l subject to. amendment by the Commission to ex pressly incorporate, 'interpret

2 and apply those rules. Furthermore, Vanply understands that. it may have3 to execute an additional document or documents in order to achieve the

4 purposes of the agreement and the laws.

5 10. Vanply understands that this ;sti pulation and Consent Final Order

6 is subject to review and approval, or disapproval by the Crmissidn and

CPA. If disapproved by either, Vanply understands that .the...final order

contained herein will be subject to amendment by the CO nission in order

to gain approval' hereof.

11. Vanply recognizes that the commission has the power to issue .

11. federally and state enforceable final enforcent orders and orders

12 pertaining to applications for precionstruction afuthorizations and air

13 contaminant discharge permits. Therefore, Venply wishes to implement its.

14 offset transfer agreement by consenting, purse.: nt to CRS l3 3. 415 (3) , to

15 . the entry by the Commission of a final order or orders im posing certain

limitations and waiving rights to notices,. hearings and judicial. .review

17 thereof.

18 ,OW THE RC, based on the above, Vanply, on behalf or itself, its

1.9 successors and assigns, consents and agrees to the following:..

20 . . A. The :almissian shall enter. the following final. order--

21 (1) The 97 tons per year of 4CC emissions from Vanply`s

2 Beaverton facility (formally Awned by D. G. Shelter Products) is hereby

r i:toved from the emissions inventory and the removal shall be submitted

to f1PA for approval as. a revision to dregon'.,s Clean Air Act State

Implementation Plan (°SIP" ).

25 (2) Vanply, its successors and assigns are herby prohibited

Page 4-STIFt1LATICN NC. ccNS l'r FINAL QP 2. .

23 .

24

.25

11
1 from, on and after September 28 1979, (date Vanply

2 shut down) starting up or expanding the same or any similar operation as

3 described in paragraph 5 above, at the Beaverton site or any other site

4 in Air Quality Control Region 193 without Vanply, its successors or

s assigns, first obtaining its own offsets not related to this offset.

(3) The Ccmmissi.on hereby retains jurisdiction to issue such

supplemental or amended interlocutory or final orders as the Commission

..dears appropriate under ., the circumstances, including

. (a) -Such' as. are necess y. to Obtain the approval -hereof

by CPA;

11 (b) Such as necessary to incorporate and apply any future

Z2 ' Ca-mission rules that may be adopted. regarding offsets.

13 B. Whenever any person makes any application for. an air contaminant

14 discharge permit or for precbnstruction•. approval of any.. activity which

,..__/ 15 would •violate subparagraph . (2) of paragraph A above, the Department and

16 Commission shall issue final. orders denying the application:

17 C. Whenever requested by the Department. or Commission, Vanply its

18 successors and assigms shall execute. any c^oe:aac:nt necessar:e "to achieve

19 the purposes of the above-described laws and offset transfer agreement.

20 D. This Stipulation and Consent Final Order may be submitted to EP

21 for approval as a revision to the SIP for the purpose of. making it

22 federally enforceable.

23

24

25

26

,ge 5- S.TIPSJLATICN AND CONSENT FINAL ORD ER

6

8

12
• 2 IT. IS. SO STIRIIATID. AND AGREED:

3

4 VAN PLY, INC.

5

6. Date: Deer 2.3 , .1980

Narnc: _Don . R -McDonald

(Please print or type)

8.: .

Title: Vice President-Operations

(Please print or type)

1.2' -

13

14 IT IS SO' OMIT= AND APPROVSDI

15 .E VIa 1Jl.`IL'SL;iN AC -Q11 ALL l.V:rE'11,J 1Vl;i

.1.6

17 Date: .3 9

1.8

19

20

.21

22

'2..3

24 .

25

26

Pa 'g 6-STIPULATION- ND CCNSUP' . FINAL ORDER

tfzlliam t.Youi Direct

Department of 'virote:iurital Quality

pursuant to OAR 340-J )-j :36 {]

13
AIR CONTAMINANT DISCHARGE PERMIT

Department of Environmental Quality

522 Southwest Fifth Ague, Portland, OR 97204

Mailing Address: Box 1.760, Portland, OR 97207

Telephone: (503) 229-5696

Issued in accordance with the provisions of ORS 468.310

ISSUED TO:

Weyerhaeuser Company

P Box 325

Sly, OA 97622

PLANT SITE:

ighwa 140

Sly, Oregon

ISSUED BY DEPARTS ENVIRONMENTAL QUACK

Source (s) Permitt

/ Name of Air Contarinan ce

to Discharge Air ontaminant :

Sewmj and Planing Mill - greater than 2421.

25,000 board feet per shift.

lruei Burning Equipment - outside ACM 4961

greater than 30 millie BTU/hr.

Peri to t .vi,ti

until. such time as this permit expires or is modified or revoked, the

permittee herewith allowed to discharge exhaust gases containing air

contaminants including emissions from those processes and activities

directly related or associated thereto in accordance with the requirements,

limitations and conditions of this permit from the air contaminant

source (s) listed above.

The specific listing of requirements, limitations and conditions contained

herein dyes` not relieve the permittee from complying with all other rules

and standards of the Department.

Permit Number:

Expiration Date;

Page 1 c 4 Pages

fEe 3

14
Permit Number: 18-0037

Expiration Dates 5/l/86

Page 2 of 4 Pages

' e permittee shall at all times-maintain and operate all air -

e• taminant generating processes and all contaminant control equipment

at I1 efficiency and effectiveness, such that the emission of air

eortnants are kept at the lowest practicable levels.

Partiou -te emissions from any single air contaminant source except

the Sterl g boiler shall not exceed any of the following:

a.

..0.2 grans per standard cubic foot for sources existing prior

to June , 1970;

0.1 grains per standard cubic; foot for sources installed

constructed, r modified after June 1, 1970; and

An opacity equa to or greater than twenty percent (20%) for

a period aggrega ng more than three (3) minutes in any one

(1) hour.

The permittee shall operat and control the steam generating boiler(s)

in accordance with the folio ng list of boiler operating parameters

and emission limitations:

Seiler

Identification

sterling hogged fuel 20 40,0003

Maximum opacity that shall not be egu led or exceeded for a

period or periods aggregating more than three minutes in any

one hour, excluding uncombined water va

) 'Maximum hourly average steam production ( u' •s per hour)

The permittee shall not operate the boiler with othe. fuels or at

greater steam generating rates than those established uring the

Department approved particulate emiasions source test._

'Particulate emissions from the Sterling boiler shall not exceed

7S metric tons per year (86 short tons per year),

6. Particulate emissions from the Sterling boiler shall not exceed 0.13

grains per standard cubic foot corrected to 12 percent carbon dioxide,

Rein ,oring and Reporting

7. +ermittee shall report to the Department of Environmental Quality

by - ary 15 of each year this permit is in effect at least the

foll.owin information for the preceding calendar year t

a. -Total sa • 1 operating time (hours/year)

Sawmill product'., (board feet/year)

c^ 'Type and amount (tons/y _r) of wood waste burned in each boiler

d. Total boiler operating time rs/year)

Maximum mission Limits

Fuel 0PA It y • Maxom,

.m

a _ ^

Used Ca 2

15
Permit gi mbeL Y 18-0037

Expiration Date: 5/1/86

Page 3 of 4 Pages

Fee o E edu

8. The Annual Compliance Determination Fee for this permit is due April

1st f each year this permit is in effect. An invoice indicating

the a aunt, as determined by Department regulations, will be mailed

prior o the above date.

General Condi ions and Disclaimers _ eaGI. The permit ee shall allow Department of Environmental Quality

representat'ves access to the plant site and pertinent records at

all reasona e times for the purposes of making inspections, surveys,

collecting sr,pies, obtaining data, reviewing and copying air

contaminant em scion discharge records and otherwise conducting all

necessary funot' ons related to this permit.

G2. The permittee is ' rohibited from conducting open burning except as

may be allowed by i Chapter 340, Sections 23-025 through 23 .050.

The permittee shall:

..a. Notify the Departs ent in writing using a Departmental "Notice

of Construction" R rm, and

before:

any new source of air a. Constructing or install ' contaminant

emissions, including air llution control equipment, or

. Modifying or altering an ex sting source that may significantly

affect the emission of air •. taminants.

The permittee shall at all times conduct dust sup

to meet the requirements set forth in "Fugitive e

"Nuisance Conditions" in OAR Chapter 340, Sections

21-060.

Application for a modification of this permit must be sebnitted not

less than 60 days prior to the source modification. A Fi ing Fee

and an Application Processing Fee must be submitted with an

application for the permit modification.

The permittee shall notify the Depa

of any planned shutdown of air poilu

scheduled maintenance that may cause a

standards.

ent at least 24 hours in. advance

on control equipment for

violation of applicableThe permittee shall notify the .Departaten

within one Ol) hour of any malfunction of a r

equipment or other upset condition that may

applicable standards. Such notice shall incl

quantity of the increased emissions that have

expected duration of the breakdown.

telephone or in person

pollution control

ause a violation of the

de the nature and

ccurred and the

16
Permit Number. 8,-0037

Expiration Date. 5/1/86

Page 4 of 4 Pages

GS. A•4lication for renewal of this permit must be submitted not less

the 60. days 'prior to the permit expiration date, A Filinc Fee and

an An. al Compliance Determination Fee must be submitted with the

appliea on for the permit renewal.

-G9. The issuan . of this permit does not convey any property rights in

either real personal property, or any exclusive privileges, nor

does it author any injury to private property or any invasion of

personal rights, •r any infringement of federal, state, or local

laws or regulations.

evocation for cause as provided by law.

Notice revision; Section 1

as amen ed i l97, requires tha

defined in that act, be notified he

to pay a noncompliance penalty under

by such later date as is set forth in the

in accordance with Section 120 in the event

to achieve final compliance by July 1, 1979

(1) (B) of the Federal Clean Air Act,

major stationary source, as

in that "it will be required

tion 120 (of that act) or

rder (i.e., in this permit)

such source fails

- P18003,.7 (a)

17
Permit Number: 36-6041

Expiration Date: 10/1/84 .

Page 1 of . 1 Pages.

I

A.I1 CONTAMINANT DISCHARGE- PERMIT

Department of Environmental Quality

522 SW Fifth, Portland, OR 97204

Mailing Address: Box 1760, Portland, OR 97207

Telephone: (503J 229.-5696

- Issued in accordance with the provisions of ORS 468.310

I ssc TC3 : . REFERENCE. INFORMATION :

Spaulding Pulp and Pa p er Co. Application No. N/A

Box 70 Cate Received:. June 27, 1930

New.berg, oft 97132

PLANT SITE:

Publishers Paper Mill

KyrtooSki Street

Newberg, Oregon

ISSUED BY DEPARTMENT OF VIRONMENTAL QUALIT[ (

1 i i 19,

Gr/ 2 •'i /7. DEC

WILLIAM U. YOi;'Z^ty;b.irector Dated

FiD D F. 2+ T b[ J b f NO. 1 .

In accordance with OAR Chapter 340, Section 14-040, Air Contaminant Discharge

Permit No. 36-6041, Conditions 4 and 9 now read as follows:

4. Annual •emissions fzcm the boiler shall not exceed 240 tons of particulate

and 189 tons. of Volatile Organic Compounds {VOC).

9. The permittee shall secure and have in effect emission reductions (of.`sets)

in the amount of 139 tons/year or more to offset boiler Volatile Org ni

Compound emissions prior to o peration of the boiler. These offsets may be

obtained from any source within the broad vicinity of Newberg but not

outside of Air Quality Control Region 193. Emission offsets shall be

consistent with definitions and guidelines in the Emission Offset

Inter pretative Ruling, a'R Vol.44 No. 11, San 16, 1979.

18
Permit Number: 36-6041

Expiration Date: 10/1/84

Page 2 of 1 Pages

Conditions 16 and 17 are hereby added as follows:

16. The No. 9 wood waste boiler at the Newberg Mill (i3umstead-Woolford) shall

be operated within the_ following constraints to ensure an annual VOC offset

of 12 tons: to be applied to the adjacent No. 10 boiler:

a. The total. neon-fossil fuel quantity burned in the No. 9 boiler shall

not exceed 15.3 million therms per year (equivalent to approximately

95,000 DDT of fuel per year). .

b. Maximum. super-heated steam production (hourly average) . shall not exceed

the following:

1) 145,000 pph during simultaneous operation ,oE No. 9' .and No. 10

boilers : un::ess at least' ? 5 ther is/h'r of fossil fuel is f ited

per 1000 pph steam above 145,000 pph up to a maximum of 160-,000

pph2). 160,000 pph during periods when No. 10 boiler' ie not opetee'i.ng.

c. Records of operating conditions sufficient to document cornplieece

with these :constrein•ts shall be kept on file.

17. The Publishers. Paper Portland Division facility located. at 56.37 SE .00th

Avenue., :PGrt.and., shall be permanently sh.ur_' down. fin the event' the

Publishers ?aper Company or any other operator wishes to restart this

facility,. total offsets for. volatile organic compounds must be secured

and placed into effect before such startup.

P36604. 1., . .(

19
Permit Na'.: 26°3112

Expiration Date: 09-01-97

Page 1 of 2 Pages

AIR CONTAMINANT DISCHARGE PERMIT

Department of Environmental QualitY

Northwest Region

2020 SW Fourth Avenue, Suite 400

' Portland, OR 972014987

Telephone: (503) 229-5263

Issued in accordance with the provisions of ORS• 468A.040 , and based

on the land use ' compatibility fps included in the pest record.

INFORMATION RE UPON

Application No.: 015085

Date Received: 07-20-95

LAND USE COMPATIBILITY STATEMENT:

. City of Portland`

Dated: November 14, 1988

ISSUED BY THE DEPT OF ENVIRONMENTAL QUALITY

Thomas.. Bispham, Northwest .Region ,Administrator

ADDENDUM. NO. 1.

In accordance with OAR 340-14-040, Air Contaminant Discharge Permit No, 26 .3112.,

Condition(s)-15 through 21 are added as follows. All other permit conditions remain

as issued on March 14, 1994.

S THEUC.MINOR CONDiTiON

15. The amount of Volatile Organic Compound (VOC) used in a y= - 11 not

exceed 33.3 tons.

16. The amount of each individual Hazardous ollutant (HAP) used in a

year shall not exceed 9.9 tons.

ISSUED .TO:

Duxes. Industries, -MC.

P.O. Box 10762 '

-.Portland, OR 97210

PLANT IiDCATION:

4466 . NW Yeon . Portland, OR 97210

' SEP . 1 4 1995

Dated

20
21
Permit Cdr: 26-3112

Application No.: 12047

Page 1 of 8 Pages

Departrr n.t of Ert ironrenta.L Quality

Aix Quality Division

AIR 03NTAKNANT .DISC-1MM PET APPLICA.TION REVIEW ART

Dun.. ' Thais tries., Inc

2.0. 'Box .10762

Portland, OR 97210

C'^1S NSR: PSD

MN

SOURCE. TEST'

CAL

:SCQ

SPEC

CgIt

REPORT

AQM.

EXCESS NSS SIZE

Al .A2 Wrd

This permit review it co zcted in LIND parts. Fix t . (1) tom' facility and Its

emissions'' sources are evaluated. The key e.'mssion mts are identified and

the appropriate regulatory std are determined.- The second part (IL)

consists of the alternate RACT cdetermination:,

I. THE FAC1Z1TTREVIEW .

GOAL BACKGROUND INFORMATION .

1. Duna Industries, Inc ..operates a surface coating facility.located. at _66

NW y on, Portland, Oregon, , 97210.. • Du . paints aluminum extrusion $

used zn the construction of c rcialbu:ilrIi rigs,, and the coat ` 5s

app.-lied to. these, extrusion parts are subject to the , high .pe ormance

architectural. coatings (HPA.C) standard (OAR 340-22-170 (j) (E)) of 3.5

lbs VOC per gallon of coating, less water. The coat ' s applied to other

miscellaneous pants are subject to OAR 3.40-22-170 ) (j) (A) :through (D)

.'Tie source is located in a nonattainrrent

source (< 40- tons/yr). of ozone preciir or

(\CC) All other criteria pollutants

insignificant-,amounts.

A Land-. Use Coin atthility St

granted unconditional a

der permits is

Quality for

:genera .or .

2.

'3.

or required by the Department-or Environmental

source include a registration. as a hazardous waste

22
13. The source is required to submit reports to the Depart - M..: .. ^y as

specified in the permit.

14. The source is not subject W. in-media thin. one hour) reporting of

excess emissions, except when.. ; :_ - emiseiot may endanger public health.

15. This s o u rce a s • j ect to federal regulations-for New source

P rfo z anda ds (NSP ) ,.Prevention of Signi:ficaartt Deterioration

rational .i.ssio> Stance for .Hazardous Ai:r Pollutants

ce Review (MR)

II.THEALTERNATE RAC' DE ION

Pursuant. to a.. source-specirfic State Implementation . Plan MEP) revision criteria:

Inc : from meeting the $ i:gh pe ormance architectural coatings (1-3PAC) standard.

(CHAR 340-22-170 (5) (j) (E)) of 3.5 lbs V-per `gallon of crating,. less water, .

and in its place establi.shes the, alterr,stv'e .emission limit. ; The exception to -

the Reasonably Available Control Technology (RAM') standard is proposed in this

permit mainly because (1) high performance architectural coatings are not .

currently available and '(2) the cost of control is considered to be excessive

for this source.

The proposed alternative PACT limit need, not be adopted by, the Oregon

Env ironrr erital :Quality . Cr xru:ss i on, (MC) pr_ for to EPA approval as the provision

is a part of the RAC'I' coating rule. The alternative RACT limit in this permit

is su mi.tted -,rectly to EPA, "and " it will not -became effective until approved

by EPA. The permit issvanc wild. follow the procedural reque errents. of 40 CPR

cited in OAR 340-22-17Q, , this permit proposes to eft pura Industries

?art 51:102, which- cover's the public hearing processes

SAC^ e- fi NFoRMA' 'ION .

16. OREGON - RACE SURFACE COAT]NG- STA ARDS ; The surface coating RACr

standards. (CAR 340-22-170) ' n'Oreggon are - currently divided into 20

categories to cover a wide range of industrial coating applications from

(a) automobile. to (z) zinc coating operations, except the aerospace

coating applications , - The primary ,intent ' cl the .surfaca_ coating

rules is to reduce the pollutants fees the front-end by restr-ieLing the

solvent (VLC) contents in coatings. The concept has corked for the most

part, but in certain coating ` categories such as the architectural.

coatings, the cc rP1i:ant coating rs. sins' unavailable.

' 17: rIHE ARC- ITECI JRAL ODATTh LZMQUE SS: Du_Ya. Industries, Enc. coats

exterior alumieurr panels ' and extrusion parts ,for (hi.ghrise) cc rrercial

buildings. .The paint fi.ni.sh must .meet the Arnica. Architectural

.Manufacturing Association (APPgO. speca ficati on 605..2; which requires

Peet Nor: . 26.-3112

Application No.: 12047

Page 4 of 8 Pages

23
Permit Nur±er: 26-3112

Application No. : 12047

Page 5 of 8 Pages

(with a warranty) the long lasting life expectancy of . 25. plus . years, high

durability-and color retention, and resistance to atmospheric pollutants

- particularly "acid rain" and alkaline deposits . The . only architectural

coating white ' meeta the rigid AhmA standard. contains 6.2 lbs WC per

gallon of coating; less water.

i t o c h e t u : N o r t h A erica,. Inc. , a division of the F r e n c h C an Elf

P taine, is the manufacturer of the resin binder trademarked "KR

. '500"; which is sold Only to sew licerised• paint manufacturers .

including DeSot9 . Inc . ,' The Glidden Company, -PPp :Industries Inc . , . and tho Value Corp : KYNAR S O is Compositionally polyvinylidene fluoride;

which is the key ingredient of the resin binder uniquely suited for

605.2 specifications : KyNAR 5O0 is highly resistant' to UV ,light;, its a

strong water , repellant, and provides the best available protection

against the most general forms of .environmental stress, and the other

characteristics ideal for cemmercial application,.

The availability of reformulation is primarily dictated by the physical .

law of solubility. The coating solid will not dissolve . beyond its

saturation po `e at given teitpera.ture and pressure. The coating solid is

the coating component that dictates the coating -(protective)

characteristics, and solvent (VCC) is a mere . tr parting medium. As

discussed, the amount' of solvent needed to dissolve coating solids and

formulate a gallon of coating is dictated by the physical law of 

.

solubility. The responses from the referenced. paint manufacturers were

essentially univocal: The develop-eat work to formulate a water

reducible coating, which, began as early as in 1960, continues

unsuccessfully 'due to the unresolvable application problems. KY tAR 500

is soluble only in a few selected solvents and at relatively low

concentration, and that successful formulation meeting the RAMP. 605.2

spec ' best -contain at leeet 6.2. lbs VCC per gall_ct of. coating, less water.

of less than 10 years, In. car ari.son, the AAMA spec paints would

certainly benefit the environment over the life (> 25 yr) of the AANA

spec. finish. Also note . that the "surface coating in manufacturi ig" • rules

are tit applicable to the painting activities at the construction site

It is also worth noting, for ' example, the common exterior paints with the

average 3.5 lbs/gad. VCC content generally have the normal life expectancy

n-Attei rrrent . . Pear, . HPAG limit.

Corr-cane/Lome ion Status tons /vr l.bs /cal.

?EFCO, Inc./ Moderate

St. Paul, MT .

and/or for the repair'/maintenance caerks

18 A selective survey was conducted on facilities in various ozone nonatta.inu nt areas which use AANrA. 605..2 spec. HPAC coatings, and their

limits are listed .below:

None none ..

24
Permit Number: 26-31.12

Application No.: 12047

Page 6 of 8 Pages

Aluminum Finishing

Core./Indianapolis

Southern. Aluminum

Fini.shirzg Co . /

Atlanta GA

International Extr.,

Inc. / LA A

Serious

rem .

Mederate 25 Note

®.2

None

after. Coritxol r towed Nov '93

cur rently divided into 4 cla$ses:

Marginal.

19 THE PORTLAND - : OXUS t Thy Portland area is currently

designated as a :nor ttarn rit area for ozone: However, one of

the criteria for reaching the attainment status is to not exceed. t.h

nati< : ambient air c .i:ty. star: - .. for ozone (0.125 ppn) .mere than

once .per year on average over a. three year ,period: For past three years,

Portland has been in ccmoli:a tee with the'EPAStandard: '

; ...# Exceedances Year (Date); Canc : gym)

1991 (7/02) 0.129.

1992

1993

Department will- also neat the deadline (Nove, '93) for .the

submittal of. a plan to maintain corn 1i.ance With the standard.

As. indicated earlier, Data' s Arc ed „PS is 33 . .3 tons/yr. According to

. xa' s emission data, thep ojeczed arc i.tectural coating' usage is less

than 'Q .-tons/Yr, : a . the' rest is for non.-atectural coatings' and

cleanup solvent usage

0.126

There is only one -other s mila ,r architectural coating. facility (Anodizing

c ..) = .ire Portland, but they, are suoj ect, to meet 'the New Source Review

(NSR) r ,i.re pts mod their. VOC.=emissions. **ad. be cdntrolled. The' side -

benefit that will 'result. ftua 'the '1SR control regtiirerre#7ts is t1ia she

coating line emission l.d also tree-t. the "_CT standard of 3.5 - lbs/gal:.

The Depatrrent' a emiF ssiori inventory (1990) indicates the industrial

errassions account • for about 6 percent' of total Portland area .VtjC

'emissions. The excess' t fission cue to the proposed alternative :RACY

ien.t limit (6 : 2. 7 bs/gal) is min' uscul.e, and the .t act on the. - air -

cg lel,i,ty (or Portland ozone : .u nance plan) caused by proposed alternate

PACT limit (source specific pecif 3 c - 'only applies to Lora Inc.) .' Mild be .

insignificant:

The ozone n n-attaiznsnt status

E r 'Serious .

25
20. RACS' compliance can be achieved by :using ccmpli.ant coatings and/or by

adding pollution control devices. Due to the lack of reformulation, the

feasibility of add-on abatement devices was explored. to comply with the

RACr standard, OAR .340-22-.17.0 (5) (j ) (E) .

In choosing the pollution conteol devices, the initial capital investment

cost was the major concern for ^Dura Inc, for several reasons. First of.

all, Dura is a small business ' with. small capital. 3wri addition, ' the . possibility of utilizing a powder coating technolc gy exists in. near

future. There are also uncertainties present in the future market share

due to strong foreign campetitaons (with no VCC regulations) All things

considered,: the initial capital investment cost, and not the annual

operating cost, is the primary factor influencing the selection of a

specific type of coorrOl equipment: .

Of existing abatement devices, a thermal incinerator system without the.

energy recovery is determined to ce the most appropriate (a least initial

capital cost) . technolcgy fpr this source. The other . key pararreters,which

influenced the cost analysis include the business decision to•provide the

.\ incinerator control to only dne stray booth - where all the AAt4A. spec

coatings would be applied.' Refer to attach .nts Al ' through IBS for a

ccaplete cost analysis.

Ln..suamary, the annual cost of \CC control ' to greet the 3.5 lbs/gal - M 'I': .

limit „ is determined to be $50,600., Based on the 10 tons/yr VCC emissions

from the AAM.A.spec ,coating applications, the actr+al emission would P

less, the cost per ton of vow control, is greater than $5,000/ton. The

Beprtaent acknewledges the .: (greater than), ' 5,000/ton/yr control, cost: to

be excessive for PACT, especially Teihen the future market is uncertain,

and therefore' the thermal cine_tetion.control is not required as Rte'.

permit Number: • 26-3112

Application No:: . .12047

Page 7 of 8. Pages,

VCC @missions - 1990 Ozone Season

day Percent 44°a

35,913 ,. 6%-

158,311 26%.

91,-f62 .15%.

87,079. .14%

239,338 39%.

TH FEASIBILITY OF. AJDD-ON tOL•

Thet'^.l..l=NATIVE RACT LIMIT

21. Availability of i-Solvent Coati gs '(compliant architectural 'coatings)

has be•,n discussed, and the feae ility of abatement devices has been

'explored. This permit determine& theposed alternative R.ACT limit for

3ourCe Tv

Stationary Point Sources

Statidnary Area Sources

Biogeriic Sources .

Non-Rd Mobile Sources

On-Road M5bi,le Sources

Total within Portland A.P

'

26
Permit Number: . 26-3112

Application No. : 12047

Page $of 8 Pages

architectural coatings that are' subject to the AAtvrA 605.2 spec is 6.2 Lbs

VCC. per gallon of coating, less water. The EPA cctrvl.iance guideline

dictates the alternative PACT limit. be e aressed on a solid basis,

because when coatings are refaiu&clated to a higher solids .content, a

smaller volume of coating material is required to •a ply the same amount

of solids

The 6.2 lbs /gal.: coating, less meter, meal-Ls 'eke is 6.2 of VCC

in one gallon of coating: Divide by . the average solvent . dezisity of 7.36

lbs/gal, as cited at OAR 340-22-170.(6),. the6,2pounds of in one

gallon of paint mould occupy (6.2/7.36 `=) 0.8424 gallon space'. The rest

(0.1576 gallon) of the gallon wed consist of, coating solids in this

ceee. erefore, the amount of 'Si :C emitted per gal: lon of gating solids,

water, i5:

6.2tbs. , 39.3 Lbs VOC

0.1576 gal gal' coating solids

ADDITTONP:LREQtaRl`i[[ENTS

22. ' Special conditions

permit. include:

the'. form of CoatA'i.ance schedule contained in the .

The surface coating .RACE l m7.ts; and

Require nt toadsrer_ ±: se in the 'paint aux 1/ir►a az ne -continue

to cien ristrate t complying low-solvent coatings are unavailable.

23. . Cr...xrrnliance schedule contained ire he pe ar i s ccndi tional , and a t may ax

may noti.,.be triggered 'pen ' .cu' , EPAw poiival/rlis pr val of the alternate

RACE limit asa determined -In.,th. e posed` permit' If 'A es' of "tom

al gate PACT lam t, the compliance' e' schedule does riet apply, : but if EPA

disapproves., the :grassed after? to RACT limit wz.7:1 be s ^stema t^ c ly

revoked as out]: ed a n :e compliance schedul

PUBLIC... C7T .

hearing c.iss held, _

20, '1993 for the

.24. The proposed Plant Site a.ru.ssi.on. Limit is, same as

C-0Y

'ue:nt ICY '5, :l9*. . ' '-

P 'ETS. ? 61128>.

A

27
Permit No.: 26-3224

Expiration Date: 5-01-97

Page 1 of 3 Pages

AIR CONTACT DISC E PEP'flT

Department of Environmental Quality

811 S.W. Sixth Avenue

Portland, OR '97204-1390

Telephone: (503) ,229-5696

Issued in accordance with the provisions of ORS 468A.040 and based

on the land use compatibility findings included in the permit record.

ISSUED Ta :

Port of Portland

P.O. Box 3529

Portland, Oregon 97208

PLANT SLiE LOCATION:

Ship Repair Yard

5555 North Channel

Portland, Oregon 97217

ISSUED BY THE DEPARTMENT OF ENVIRONMENTAL Qt LrTY

'OCT 0 4 1995

Tom Bispham, Northwest Region Administrator Dated

ADDENDUM NO. 2

In accordance with OAR 340-14-040, Air ContaminantDascharge Permit No. 26-3224,

Conditions 17e shall be amended, and the following Conditions 19 and 20 shall

replace Conditions 19, 20 and 21 of Addendum No. 1, issued May 4, 1995, in

accordance with . OAR 340--22--104, and read as follows:

REPORTING REOUERIIMENTS

17 e. Weekly average . volatile organic compound (VOC) content of coatings used

in the ship painting operations, less water and exempt compounds (weekly

average lb VOC/gal) for each coating category, as listed in Condition

19, Table 1.

SURFACE COATING PERFORMANCE STANDARD

The following condition shall replace Condition 19. of Addendum No. 1, issued ,

May 4, 1995, effective one year after EPA approval of the PACT determination,

and Condition 19. of Addendum No. 1 will remain in effect until the

compliance date for the source specific RACT requirements:

INFORMATION RELIED -UPON:

Department Initiated

PACT Determination

-.i

28
Permit No.: 26-3224

Expiration Date:

Page

,S-01-9t'^

2 of t

19. The perelittee shall not use surface coatings for ship painting operations that

exceed the limits in Table 1 for volatile organic compounds (VOC) per gallon

of coating, as applied, less water and exempt compounds. .These limits are

based on a weekly weighted average of the applied ^tings'in.each. category.

VOC content may be averaged within a coating category, however excess VOC

emissions in one category may not be offset with lowered emissions in another

coating category. Compliance shall be determined by dividing the total VCC

content (Ibis) of the coatings in a category used in one week by the total

number of gallons used in that category in that week (Monday 12:01 am thru

Sunday 12:00 midnite).

Weekly Average Content by Coating at Category Ca

• /'`y ^^ `

l ! L' 1f 1Tr ^^-"^"^g L

USE ..e

sa

Ep ieS

Al nt Ps-awash

Prs

zee: -

Tar" C

,v,^ other

Specialty

Weekly - ' Average 3.5 , 3.7 6.5 5.4 5.5 '

lb VCC per

Gallon

The Department has determined that these limits represent Reasonably Available

Control Technology (PACT) for ship painting. Compliance with these limits

must be demonstrated within one year of approval of the PACT det erm ination by

the U.S. Environmental Protection Agency. Formal - EPA approval will be '

published in the Federal Register. The Department shall notify the perm ttee

of EPA approval.

SOLVENT MANAGEMENT PRACTICES

The following condition shall replace Conditions 20. and 21. of Addendum No.

1, issued May 4, 1995, effective one year after ERA approval of the PACT

detonation, and conditions 20. and 21. of Addendum No. 1 will remain in

effect until the compliance data for the source specific PACT requirements:

20. The permittee shall provide training' and instruction for contractors and

subcontractors working on-site in Best Management Practices far solvent use.

These Practices shall include the following emission control procedures:

A. Use of closed systems for cleaning and flushing paint guns and lines.

Flushing systems shall have only the minim= venting required to

operate. As an alternative, a non-170C solvent cleaning system may be

used.

29
Permit No. : 26-3224

Expiration Date: 5-01-97

Page 3 of 3

B. Distillation or other approved recovery methods for recovery and reuse

of cleaning solvents. All solvents fee ible shall be reclaimed.

C. Use of closed containers for storage and transfer of solvents from bulk

stores to work areas.

D. Use of closed containers for collection of solvent-laden cloths or rags

prior to proper disposal.

E. All personnel working with coatings shall receive at least four hours

training in efficient use of solvents, to prevent waste and minimize

usage. New employee orientation shall include training on solvent

handling and coating record keeping. Existing personnel shall have two

hour minimum refresher courses at least annually. Training records

shall be maintained and be available for inspection by the Department.

ALL ENQUIRIES SHOULD BE DIRECTED TO:

Department of Environmental Quality

Northwest Region

2020 SW Fourth Avenue, Suite 400

Portland, Oregon 97201

Telephone: (503) 229-5263

263224.pmt

30
31
Penult No.: 34-2060

Expiration Date: 8-1-97

Page 1 of 7 Pages

AIR UONTAMZNANT DISCHARGE PERMIT

Department of Enviroruriental Quality

811 SW Sixth Avenue

Portland, OR 97204-1390

Telephone: (503) 229-5696

Issued in accordance with the provisions of ORS 468A.040 and based

on the land use compatibility findings included in the permit record.

ISSUED TO:

White Consolidated Industries, Inc.

dba Schrock Cabinet Co.

., PO Box 547

Hillsboro, Oregon 97123

RACE INFORMATION:

Source Specific PACT Determination,

Submitted 3-22-93

Additional information submitted

7-30-93, and 3-16-94

PLANT 5LL'.E LOCATION:

600 SW Walnut Street

Hillsboro, Oregon 97123

ISSUED BY THE DEPARIMENT OF ENVIRONMENTAL QUALI'T'Y

AU :,1 199 .

Tom Bispham, Northwest Region Administrator Dated

e

ADDaTD(]M NO. 2

As required by OAR 340-22-104, the Department has determined VOC PACT requirements

for this source. These modifications are subject to EPA approval and will be

effective one year after notice of approval is given to the source. In accordance

th OAR 340-14-040, Air Contaminant Discharge Permit No. 34-2060, Conditions

_,6,8,9 and 11 through 16 shall read as follows:

32
.

33
(

Permit Number: 34-2060

RACI' Determination

Page 1 of 5 Pages

Department of 33hvironmente 1 Quality

Air Quality Division

DEPE'T INITIATEE) MODIFICATION

AIR CONTANIIIANT DDISCEARGE PERMIT REVIEW RE OR

White Consolidated Industries, Inc.

ciba Schrock Cabinet Co.

600 SW Walnut Street

Hillsboro, Oregon 97123

GENERAL BACKGROUND INFORMATION

1. White consolidated. Industries, Inc. operates a cabinet manufacturing

facility under the name of Schrock Cabinet Co., located at 600 SW Walnut

Street in Hillsboro. The processes include the construction and

finishing of kitchen cabinets. Schrock Cabinet Co. employs a three-step

process for coating kitchen cabinets. The cabinets receive one coating

of stain or toner, one of sealer, and one of topcoat. The coating

process includes an overhead conveyor line.

2. This is a Department . initiated modification to Air Contaminant Diharge

Permit (ACDP) No. 34-2060, which was issued on 4-13-94 and is scheduled

to expire on 8-01-97. This modification documents the source specific

Reasonably Available Control Technology (RACT) determination that the

Department and the permittee conducted pursuant to Oregon Adtrdnie Le ative

Rules (OAR) 340-22-104 (5) , and under the provisions of OAR 340-20-047.

This modification establishes PACT limits and/or operating conditions for

the processes at the facility which use and emit volatile organic

mounds (VOC) .

Reasonably Available ConLeol Technology (PACT)

Portland Ozone Attainment Status

3. The Portland Metropolitan area is currently designated as a marginal

nonattairn it area for ozone. The Schrock Cabinet Co_ facility. is

located within the nonatta riment area. However, for the years 1991

through 1993, the Portland area airshed met the criteria for an ozone

attainment area. One exceedence of the ozone National Ambient Air Quality

Standard of 0.125 cccurred in 1991 and 1992, while no exceedences

occaxrred in 1993. At this time, the Department is drafting an ozone.

maintenance plan to subu t to the EPA as part of the Oregon State

Iuplementation Plan. Upon approval of the maintenance plan by the EPA,

the Portland area will he considered in attainment with the ozone

standard. The RA= permit conditions will be required in the future as

an element of the pollution prevention efforts to remain in attainment

with the ozone standard.

s:a

34
Permit Number: 34-2060

PACT Determination

Page 2 of 5 Pages

T Determination

This PACT-permit modi ficcation places limits ; on the VCC content of

coatings used in the Ong steps of wood cabinet production and VOC

handling methods used in solvent related cleaning. The implementation of

the permit conditions will resu7 t in lower VCC emissions than previously

pew; ttod through. the use of coatings containing higher concentrations of

solid and utilizing best management practices during solvent cleaning

operations, as listed in Condition 14. of the permit Addendum.

The PACT review of the permittee's operations focused on the coating

processes.

ting Processes

The coating processes contribute to the majority (approx. 90%) of Schrock

Cabinet Co. VOC emissions. PACT determinations for similar coating .

operations in other states were evaluated as well as the effectiveness of

applying control technologies that capture and remove VOC. The following

three areas were included in the coating evaluation:

a. Alternative coatings

b. Increased. transfer efficiency of coating solids to substrate

c. Add-on controls

The PACT analysis and supplements submitted by Schrock Cabinet Co. (March

1993, July 1993, and March 1994) included a comparison of the

requirements of different states for wood products coatings as included

in the PACT/BACT/LAER Clearinghouse. In addition, White Consolidated

Industries is a participant in the wood furniture coating regulatory

negotiation (reg-neg) process. This is the follow-up process to EPA's

draft Control Technique Guideline from October, 1991.

A few of the Clearinghouse entries were potentially comparable to the

Schrock Cabinet Co. facility. These PACT decisions included specific

coating limits (lb VCC/gal), which were found to be comparable to the

coatings already,in use at Schrock Cabinet Co.. An increase in transfer

efficiency was implied for some facilities by the requirement of a

coating application technology, such as Air Assisted Airless (AAA) or

high volume, low pressure (HVLP). The operations at these facilities

were being reviewed for RACT or BACT determinations (best available

control technology). This type of requirement was considered for the

Schrock Cabinet Co. facility along with a coating limit where applicable.

Add-on controls were required only for facilities subject to LAER (lowest

.achievable emission rate) and BACT requirements. Typire l add-on controls

include thermal oxidation and carbon adsorption.

.RACT for the coating processes at Schrock Cabinet Co. was determined to

include the use of high-solids coatings, water based coatings, and the

most efficient transfer of coating using applicator technology. The

35
Permit Number: 34-2060

PACT Determination

Page 3 , of 5 Pages

a)

b)

proposed coating standards are equivalent to those proposed in the regneg process (as compared with the Jan. 9, 1994 straw person draft .

document). Although the coatings in use at the facility are of a similar

VOC content to limits in . otherStates, it was determine) that further VOC

reductions were feasible and reasonable through the use of a water based

topcoat. As determined in the RACT analysis submittal, add--on controls

do not represent RA=T due to the cost of capturing the dilute VOC

airstream follczied by a. control technology. The cost of these systems

exceed $3, 000 per ton VOC rived, with most control devices shading a

cost effectiveness 'of greater than $10,000 per ton VOC removed.

Coating limits were established for :

VOC Limits for Coatings, as app lied, to Wood Products

COATINGS CATEGORY LB VOC/GAL

(approx.

equivalent)'

LB VOC/LB SOLID

Water Based Topcoats (3.0) ' 0.8

Pigmented Coatings 4.5 -----

Aigh Solids Topcoatsb 1.8

Alkyd Amino Vinyl

Topcoats

(5.0) 2.0

High sal „4s Sealers (5.1) 1.9

Alkyd Amino Sealers (5.4) 2.3

Sealers used with water

Based Topcoats

5.6 .

The equivalent as re1culated•using the standard solvent density of 7.36

Jib/gal and the density of the solid.material in typical coatings of the

-category. The lb VOC/gal standard should he used as an estimate: actual

compliance should be based on the lb VOC/lb solid standard where one is

given.

High solids topcoats other than alkyd amino vinyl topcoats.

The coating limits are expressed in' terms of pound VOC/pound solid

applied (lb VCC/lb solid). This is consistent with the units proposed

through the reg-neg process. Where a limit is expressed in terms of lb

11 C/gal, as applied, no limits were proposed in the re-neg pro'ess, and

the equivalent limit was not determined due to insufficient coating -

solids content data.

Transfer Efficiency

36
Permit Nye 34-2060

PACT Determination

Page 4 of 5 Pages

As a special condition, the permittee must use the most efficient spray

application method appropriate for each coating. The water-based topcoat

and high-solids coatings will be applied using conventional air spray.

These methods of application have shown tobe more effective (by White

Consolidated Industrjre) than the HVLP or air-assisted airless (AAA)

equipment the to the physical properties of the water-based formation.

The use of conventional, air spray equipment is allowed for touch-up

operations and for up to 5% of the total anneal gallonage, . The .5%

allowance for use of conventional air spray on coatings other than waterbased or high solids is designed to give Schram some flexibility to

apply cusp coatings for short production runs or spec'el orders.

lvent Cleaning Operations

The solvent cleaning' operations permit conditions are based on the

Alternative Control Techniques Document ndustr-i_al Clean.inci Solvents

(EPA-453/R 94-015) doci rent along' with the measures proposed by the

permittee. The EPA document summarizes nationwide regulations for .

industrial cleaning solvents. The measures in the permit are some of the

typical requirements specified for cleaning equipment from coating

operations when a solvent based cleaning solution is used- The purpose

of the solvent recovery still is to encourage recycling of spent solvent

that is captured during the cleaning operations. The spray equipment

must be cleaned in such away as to capture the cleaning solvent and

minimize evaporative losses. Any cleaned , i pment that holds cleaning

liquid (solvent) must be drained into a sealable container. This measure

is required to prevent the cleaning liquid to be sprayed out of the

equipment onto an exposed surface and evaporated. The final measure is

intended to make all other cleaning operations be conducted uti l i ring

best management pLcodices . This is part of the reg-neg language that

recognizes the futility is specifying conditions for all cleaning .

operations, when good housekeeping and standard pollution prevention

practices are all that is needed to minimize the evaporation of VCC.

ANT SITE EMISSION LIMIT (PS'',

The RACE adjusted Paae, is 213 tpy, based on 105,290 gallons of coatings

and solvents, at ,an average of 4.04 lb VOC/gal:

The PSEL has been adjusted from the previous permit due to the "

establishment of PACT limits. Because of limited data from the baseline

operations, it is difficult to accurately determine the amount of

adjustment based on the RAC' limits. However, this was done

simplistically through a comparison of the average gallon of coating

(finishing material) from baseline and to the average gallon of coating,

post PACT implementation. Within the last few years, Schrock Cabinet Co.

has had an average lb VOC/gal coating of approximately 5.2 to 5.3, which

is the same as the baseline operations. The simplistic comparison

results in an adjusted Pseie

37
Permit Number: 34-2060

PACT Determination

Page. 5 of 5 Pages

Baseline: 5.25 lb VOC/gal average, 105,290 gallons

RACT adjustee: 4.04 lb VOC/gal average

(4.04 . lb VCC/gal) *(105,290 gal./yr) / (2000 lb/ton) = 213 tons/year

a) The PACT adjusted average VOC content was determined by the

pertnittee, replacing current solvent based topcoats with a water

based topcoat. This estimate is based on 1993 coatings usage but

replacing VCC content with those specified in the RACT limits,

resulting in 34, 094 gallons of finishing material producing n7,800

lbs of VOC emissions for an average of 4..04 lb VOC/gal. This

represents a 23% reduction from the baseline emission rate: 276

tpy - 213 tpy = 63 tpy, 63/276 * 100% = 22.8%

9. The Plant Site Emission Limit for normal operation is the same as the

baseline emission rate of 213 tons per year, and 2,560 lbs/day. The

daily VOC emission rate- is based on 213 tons/yr divided by 250 days/yr plus 50t increase to account for highest day usage . f luctuations .

PUBLIC NOTICE

0. The PACE determination is submitted to the EPA as a. source specific

revision to the State Implementation Plan and contains performance

standards and decreases in the emission limits at the facility. Federal

regulations require a notice to the public and a hearing for a State

Implementation Plan submittal. A public hearing was held on January 12,

1995 in Hillsboro to receive oral comments on the proposed permit.

Written continents were accepted until 5:00 pm on January 13, 1995_ Based

on the written and oral cements, minor revisions were made to the

permit.

PJB:GBO: e

July 20, 1995

PERM TS\A342060R

38
( "

39
File:

October 4, 1995 rVe rptn ladoC:

4V

2der

Activity

DEPARTMENT OF

ENVIRONMENTAL

QUALITY

Intel Corporation

Attn.: Bonnie Gariepy

5200 NE Earn Young Parkway

Hillsboro, Oregon 97124

Re: Issuance of Oregon Title V Operating

Permit No. 34-2681

Dear Permittee:

The Department of Environmental Quality has completed processing your Oregon Title V

Operating Permit application and has issued the attached permit. Also enclosed are the revised

reporting and modification forms for Title V sources. Please use these forms for all reports

submitted to the Department and all requests for permit modifications.

The permit will become effective upon the date signed, unless you request a hearing before the

,Environmental Quality Commission or its authorized representative. Any such requests shall

be made in writing within 20 days of the date of this letter, and shall clearly specify which

permit conditions are being challenged and why, including each alleged factual or legal

objection. Permit conditions that are not contested shall be in effect upon the date the permit

was signed (OAR 340-28-2300). Once effective, the Title V Operating Permit will replace

your existing Air Contaminant Discharge Permit.

You are urged to carefully read the permit and take all possible steps to ensure compliance

with the conditions established. If you have any questions regarding the permit, please contact

.George Yuri at (503) 229-6093.

Sincerely,

ohn J. R igno, P.E., M ger

Program Operations Section

Air Quality Division

JJR:JW:j

LTRIAH74 890 . DOC

Attachment

cc: Region

Source File

aF p

w 4

0

:•,,-zi: z.

tiI I SW Si\th Avenue

'-)U I'ortl<ind, O '-1 2[)-4-

003i 22'-1-5o , n h

lL)l) 4Et13)

IIC?-I

40
OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

OREGON TITLE-V OPERATING PERMIT

Northwest Region

2020 'SW 4th, Suite 400

Portland, OR 97201

Telephone: (503) 229-5554

Issued in accordance with the provisions of

ORS 468A.040, 468A.300 and based on the land use compatibility findings included in the permit record.

ISSUED TO: INFORMATION RELIED UPON:

Intel Corporation Application No.: 14659

5200 NE Elam Young Parkway Received: 11/15/94

MIS AL4-91

Hillsboro, Oregon 97124

PLANT SITE LOCATION: LAND USE COMPATIBILITY STATEMENT:

3585 SW 198th Avenue From: Washington County Department

Aloha, Oregon 97007 of Land Use & Transportation

Dated: 9120191

ISSUED BY DEPARTMENT OF ENVIRONMENTAL QUALITY

NATURE OF BUSINESS: PRIMARY SIC:

Semiconductor Manufacturing 3674

RESPONSIBLE OFFICIAL: FACILITY CONTACT PERSON

Name: Sunlin Chou Name: Bonnie Gariepy

Title: Vice President and Director of Title: Sr. Environmental Engineer

Components Technology Development Phone: (503) 642-6592

41
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 2 of 32 Pages

TABLE OF CONTENTS PAGE

List of Abbreviations used in this permit 3

Permitted Activities 4

Emissions Unit and Pollution Control Device Identification 4

Emission Limits and Standards 6

Plant Site Emission Limits 9

Source-Specific Conditions 10'

Reasonably Available Control Technology (RACT) Standards

Pollution Prevention and Pre-approved Changes

Aggregate HAPs Emission Limits

Monitoring Requirements 14

Test Methods and Procedures 19

Recordkeeping Requirements 20

Reporting Requirements 21

Non-Applicable Requirements 23

General Conditions 24

Attachment-1 32

42
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 3 of 32 Pages

LIST OF ABBREVIATIONS USED IN THIS PERMIT

ACDP Air Contaminant Discharge Permit

act. Actual cubic foot

ASTM American Society of Testing and Materials

CCCU Carbon Concentration Condensation Unit

CFR Code of federal regulations

CO Carbon monoxide

DEQ Oregon Department of Environmental Quality

dscf dry standard cubic foot

EF emission factor

EPA US Environmental Protection Agency

EU Emissions unit

FBR Free Board Ratio

FCAA Federal Clean Air Act

gr/dscf grain per dry standard cubic foot

GC/FID Gas chromatograph/Flame ionization detection

HAP Hazardous Air Pollutant as defined by OAR 340-32-130

HCFC Hydro-chloro-fliaoro-carbons

ID Identification number

I&M Inspection and maintenance

LPG Liquified petroleum gas

MB Material balance

MMBtu Million British thermal units

mvac Motor vehicle air conditioner

NG Natural gas

NO, Oxides of nitrogen

02 Oxygen

OAR Oregon Administrative Rules

ORS Oregon Revised Statutes

O&M Operation and maintenance

Pb Lead

PCD Pollution control device

PM Particulate matter

PMio Particulate mater less than 10 microns in size

ppm Part per million

ppmv Part per million by volume

PSEL Plant Site Emission Limit

RACT Reasonably Available Control Technology

scf Standard cubic foot

SERP Source Emission Reduction Plan

SIP State Implementation Plan

SNAP Significant New Alternative Policy

SO2 Sulfur dioxide

ST Source test

VE Visible emissions

VOC Volatile organic compound

43
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 4 of 32 Pages

PERMITTED ACTIVITIES

1. Until such time as this permit expires or is modified or revoked, the permittee is allowed to discharge air

contaminants from those processes and activities directly related or associated with the air contaminant

sources in accordance with the requirements, limitations, and conditions in this permit. [OAR 340-28-

2100 and 340-28-2200(2)]

2. All Conditions in this permit are federally enforceable and state enforceable except as noted below. [OAR

340-28-2140 and 340-28-21501

2.a. Conditions 5.b., 6., 11.b., 15., G21. and associated monitoring requirements are enforceable by

the state only.

2.b. Attachment-1 of this permit provides a cross reference for SIP rules that have been renumbered

in the current Oregon Administrative Rules.

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

3. The emissions units regulated by this permit are the following [OAR 340-28-2120(3)):

3.a. Emissions Unit #1 (EU1)

VOC Emissions Unit

Stationary

Source ID

Pollution Control -

Device .(PCD) PCD ID.

All activities emitting

Volatile Organic

Compounds (VOCs) at

the Aloha campus .

except EU2 and EU3

Boilers.

FAB4 EU 1.1 Wet Scrubber PCD 1

EARS None

D 1 EU 1.2 Carbon Concentration

Condensation Unit

(CCCU)

PCD26

AL3 EU 1.3 None -

AL

44
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 5 of 32 Pages

3.b. Emissions Unit #2 (EU2)

Commercial Boilers

Stationary

Source ID

Capacity

106 btu/hr

FAB4 #1 Boiler EU2.1 3

FAB4 #2 Boiler EU2.2 3

FAB4 #3 Boiler EU2.3 3

FAB5 #1 Boiler EU2.4 6.5

FAB5 #2 Boiler EU2.5 6.5

FAB5 #3 Boiler EU2.6 6,277

FAB5 #4 Boiler EU2.7 5.277

FAB5 #6 Boiler EU2.9 1.255

FAB5 #7 Boiler EU2.10 4.185 .

FAB5 #8 Boiler EU2.11 4.185

ALA #1 Boiler EU2.12 2.929

ALA #2 Boiler EU2.13 2.929

ALA #3 Boiler EU2.14 2.929

3.c. Emissions Unit #3. (EU3)

Industrial Boilers

wl Low N4x Burner

Stationary

Source ID

Capacity

106 btulhr

D 1 # 1 Boiler EU3.1 20.922

D I #2 Boiler EU3 .2 20.922

D 1 #3 Boiler EU3.3 29.4

DI #4 Boiler EU3.4 20.922

D1 #5 Boiler EU3.5 20.922

45
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 6 of 32 Pages

4. The VOC Pollution Control Devices (PCD) regulated by this permit are the following [OAR 340-28-

2120(3)]:

Pollution Control

Device PCD ID

Emission Unit/

Process Controlled

Wet Scrubber PCD1 EU1.1: VOC emissions

from FAB4 building

Carbon Concentration

Condensation Unit (CCCU)

PCD26 EUI.2: VOC emissions

from D1 building

EMISSION LIMITS AND STANDARDS

The following Table-I through Table-III contain summaries of applicable requirements other than the Plant Site

Emission Limit (PSEL), along with the monitoring methods for the emissions units to which those requirements

apply.

Table-I. Facility-wide Emission Limits and Standards

Monitoring Requirements

Applicable

Requirements

Condition

Number

Pollutant!

Parameter

Limit/

Standard

Method

Condition

Number

340-21-060(2) 5.a. Fugitive/dust

No nuisance

Complaint

Investigation &

Recordkeeping

- 20.a.

ACDP Condition #6. 5.b. Odor

340-30-520 6.a. PM 250 microns Inspection &

Recordkeeping 20.b.

340-30-530 6.b. SO2 1000 ppm

ACDP Condition #9.

(340-27-015)

7. Ozone Implementation

of SERP

Recordkeeping 20.c.

40 CFR Part 82,

Subpart E.

8,a. Ozone

depleting

chemicals

Labeling

requirements

Inspection &

Recordkeeping 20.d.

Section 612 of

the FCAA

8.b. SNAP -

alternatives

46
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 7 of 32 Pages

5. The permittee shall comply with the following nuisance-control requirements:

5.a. The permittee shall not cause, suffer, allow, or permit any materials to be handled, transported,

or stored; or a building, its appurtenances, or a road to be used, constructed, altered, repaired or

demolished; of any equipment to be operated, without taking reasonable precautions to prevent

particulate matter from becoming airborne. [OAR 340-2.1.060(2)]

5.b. The permittee shall not allow the emission of odorous matter or other fugitive emissions so as to

create nuisance conditions off the permittee's property. [04119193 ACDP 34-2681, Condition 6]

This condition is only enforceable by the state.

6. The permittee shall comply with the following state-only enforceable conditions:

6.a. Particulate matter which is larger than 250 microns and which may be deposited upon the real

property of another person shall not be emitted. [OAR 340-30-5201

6.b. The peaaittee shall not cause or allow the emission of sulfur dioxide in excess of 1000 ppm from

any air contaminant source, as measured in accordance with Condition 26. of this permit. [OAR

340-30-530]

7. In the event an Air Pollution Alert, Warning, or Emergency Episode is declared in the Portland area by

the Department, the permittee shall take the action appropriate to the episode condition as required by.

Oregon Administrative Rules 340, Division 27 "Air Pollution Emergencies." The permittee shall take such

action when the permittee first becomes aware of such a declaration whether through news media, direct

contact with the Department, or from other sources. The Source Emission Reduction Plan (SERI') shall be

available, on the source premises for inspection by Department personnel. [04/19/93 ACDP 34-2681,

Condition 9]

8. The permittee shall comply with the following federal requirements when using ozone-depleting

substances;

8.a. If the permittee uses class I or class II substances at the plant site, the permittee is subject to all

of the applicable requirements as specified in 40 CFR Part 82, Subpart E; The Labeling of

Products Using Ozone-depleting substances.

8.b. The permittee shall be allowed to switch from any ozone-depleting substance to any alternative

that is listed in the Significant New Alternatives Program (SNAP) promulgated pursuant to

section 612 of the Act without requiring a permit revision.

47
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 8 of 32 Pages

Table-U. Emissions Unit Specific Emission Limits and Standards

EU/PCD

ID

Applicable

Requirements

Condition

Number

Pollutant/

Parameter

Limit/

Standard

Monitoring Requirements

Method

Condition

Number

EU2 &

EU3

340-21-015(2)(b) 9.a. Opacity 20% VE periodic

monitoring &

Recordkeeping

21.a.

340-21-020(1)(b) 9.b. PM I oIPM 0.1 gr/scf

PCD1 340-28-620 10. O&M O&M Recordkeeping 21.b.

9. Particulate emissions from each of the EU2 and EU3 boilers shall not exceed the following limits:

9.a. An opacity equal to or greater than twenty percent (20%), excluding uncombined water vapor,

for a period aggregating more than three (3) minutes in any one (1) hour, as measured in

accordance with Condition 26. of this permit. [OAR 340-21-015(2)(b)]

9.b. 0.1 grains per dry standard cubic foot, corrected to 12% carbon dioxide or 50% excess air, as a

three (3) hour average, as measured in accordance with Condition 26. of this permit. [OAR 340-

21-020(1)(b)].

10. The permittee shall operate the PCD1 in accordance with the following Operation and Maintenance (O&M)

requirements- [OAR 340-28-620]:

10.a. The scrubber water flow rate (gpm) shall be maintained at the flow rate corresponding to the

optimum VOC removal efficiency, which must be verified through source tests specified in

Condition 24.k.

10.b. The scrubber shall be maintained and serviced in accordance with the manufacturer's

recommendation.

Table-M. Emission Limits and Standards Applicable to Insignificant Activities

A ppl icable

Requirements

Condition .

Number

Pollutant/

Parameter

Limit/

Standard

Monitoring Requirements

Condition

Method Number

340-21-030(2) 11.a, PM, o/PM 0.1 gr/scf I&M 22.a.

340-30-500 11. b. Opacity 20 %

Recordkeeping

340-22-930 l l.c. VOC Coating I&M 22.a. & b.

and 1030 Specifications Recordkeeping

48
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 9 of 32 Pages

41. The permittee shall comply with the following requirements applicable to insignificant activities:

11.a. Particulate emissions from any single non-fuel burning and non-fugitive air contaminant source

shall not exceed 0.1 grains per dry standard cubic foot, as measured in accordance with

Condition 26. of this permit. [OAR 340-21-030(2)1

11.b. Visible emissions from any single non-fuel burning air contaminant source shall not exceed an

opacity equal to or greater than twenty percent (20%) for a period aggregating more than thirty

(30) seconds in any one (1) hour, as measured in accordance with Condition 26. of this permit.

[OAR 340-30-500(2)] This condition is only enforceable by the state.

11.e. The per-mitten shall not knowingly use or contract for the use of any noncomplying architectural

coating or spray paint manufactured after July 1, 1996. In addition, all VOC-containing

architectural coatings shall be stored in closed containers when not being accessed, filled,

emptied, maintained, repaired or otherwise used. [OAR 340-22-930 and 340-22-1030]

PLANT SITE EMISSION LIMITS

12. The plant site emissions shall not exceed the following: [OAR 340-28-1010 and 340-28-1020]

12.a. PROCESS (EU1) PSEL

Pollutant Limit Units Monitoring Requirements

VOC 8.0 tons/wk Chemical Mass Balance, parametric monitoring,

and source test as specified in Condition 24.

190 tonslyr

12.b. COMBUSTION SOURCES .(EU2 & EU3) PSEL

Pollutant Limit Units Fuel Usage; Annual and Hourly Units Monitoring Requirements

PMIO 0.8 tons/mo EU2 max capacity = 53x106 btu/hr

EU3 max capacity = I13xI06 btu/hr

Compliance Monitoring with the

monthly PSEL is specified in

Condition 23.b.

6.4 tonslyr (2.01 + 7.98 =) 9.99

million therms n.g.lyr

Compliance Monitoring with the,

annual PSEL is specified in

Condition 23.a.

SO2 0.3 tons/mo same as above same as above

1.3 tonslyr

49
Permit No.: 34-2681

Expiration Date: [0-31-99

Page 10 of 32 Pages

Pollutant Limit Units Fuel Usage; Annual and Hourly Units Monitoring Requirements

CO 3.6 tons/mo same as above same as above

32.0 tonslyr

NO,, tons/mo same as above same as above

21.6 tonslyr

VOC 0.2 tons/mo same as above same as above

tonslyr

12.b.i. The EU2 and EU3 boilers shall only burn natural gas, and use propane (LPG) as back-up.

13. Emissions from the " Aggregate Insignificant Activities" shall not exceed the following aggregate limits, as

specified in OAI 340-28-110(5). The monitoring shall be conducted in accordance with Condition 22.c.

of this permit. [OAR 340-28-1060(2)]

13.a. Particulate emissions shall not exceed LO ton per year.

13.b. , Hazardous Air Pollutants emissions shall not exceed 2.5 tons per year.

SOURCE-SPECIFIC CONDITIONS

REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACY) STANDARDS [OAR 340-22-104 (5)]

14. 14.a. Volatile Organic Compound emissions from EU1, based on a weekly average, shall not exceed

2xl0 pounds (lbs) per square centimeter (cm2) of wafer processed.

14.b. The permittee shall comply with the specifications outlined below when operating solvent

cleaning stations. Non-VOC solvents as defined in OAR 340-22-100 are exempt from the

requirements of this section.

14.b.i. Each sink must operate with a freeboard ratio of at least 0.7, and have a visible fill line.

14.b.ii. Each sink must be equipped with a cover that is readily opened and closed, and a cover

must be closed during idle periods if the sink contains any free standing solvents.

14.c. Reasonably Available Control Technology (RACT) standards identified in Condition 14.a. and

14.b. become effective one year from the date of EPA's approval as a revision to the Oregon

State Implementation Plan (SIP).

50
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 11 of 32 Pages

15. If EPA disapproves the proposed RACT standards identified in Condition 14., the permittee shall provide

the alternative RACT controls for the affected operations according to the schedule outlined below:

15.a. By no later than 90 days after a written notification by the Department, unless otherwise

extended by the Department pursuant to OAR 340-22-104 (6), the permittee shall submit a

complete (alternative) control strategy to the Department for .review and approval.

15.b. .By no later than 365 days after the date of the Department 's written notification of EPA's

approval of the (alternative) control strategy, the permittee shall comply with the approved

RACT standards.

POLLUTION PREVENTION AND PRE-APPROVED CHANGES

16. The permittee shall develop and implement the pollution prevention program in accordance with the

schedule provided and adhere to the conditions specified below [OAR 340-28-6101:

16.a. The pollution prevention program shall be implemented according to the following schedule:.

16.a.i. By no later than 60 days after the issuance of this permit, the permittee shall submit to

the Department the proposed pollution prevention program.

16.a.ii. Within 30 days after submittal, the Department will review the proposed program with

respect to the program elements specified in Condition 16.b., and preliminarily

determine adequacy of the information submitted. By no later than 30 days after the

Department approves the proposed program, the permittee shall prepare the pollution

prevention program in detail and submit to the Department.

16.a.iii. The Department will review and comment on the program within 30 days of submittal.

By no later than 15 days after the Department 's comment, if any, the permittee shall

either incorporate the Department recommendation or provide justification/explanation

for rejecting the Department recommendation.

I6.a.iv. Within 15 days of receipt of the final program submittal, the Department will notify the

permittee of the approval status.

16.a.v. If the Department does not respond within the time line specified, the program submittal

will be deemed approved by the Department.

16.b. The pollution prevention program shall include at minimum the following program elements:

16.b.i. The process to formulate performance goals and objectives to comply with the VOC and

HAP limits through the implementation of pollution prevention.

51
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 12 of 32 Pages

16.b.ii. Develop a partnership/agreement between the permittee and its materials supplier(s) to

reduce HAP and VOC from their raw materials/products to the extent possible.

16.b.iii. Develop a partnership/agreement between the permittee and its equipment vendor(s) to

reduce HAP and VOC emissions to the extent possible by integrating pollution

prevention into equipment design.

16.b.iv. Formulate data collection necessary for the evaluation of pollution prevention

effectiveness.

16.b.v. Develop a employee training program to promote pollution prevention at the permitted

facility.

16.b.vi. Statement of commitment to pollution prevention at the permitted facility.

16.c. • In the event the permittee opts to make a major change in the approved program, the permittee

shall notify the Department in writing at least 30 days prior to making the change. The permittee

shall at minimum demonstrate the need for the modification to the program, and a detailed

description of the modification. The modification procedure shall follow the time-line as

specified in Conditions 16.a.iii through 16.a.v. In the event the permittee makes a minor change

in the approved program, the permittee shall include a description of the change and its

justification in the. annual report submitted pursuant to item 16.d.

16.d. Monitoring and Reporting requirements:

16.d.i. Each March 15 following program approval, the permittee shall prepare a detailed

progress report on an annual basis describing accomplishments made under the approved

program.

16.d.ii. The final report prepared on March 15 of the last year of this permit term shall include

a summary of the activities taken during this permit term, and a self evaluation of the

over-all effectiveness of the program.

16.d.iii. All documents and reports must be kept at the permitted facility and shall be made

available to the Department representatives for inspection at the facility.

16.d.iv. Each April 15 following program approval, the permittee shall submit to the Department

an annual executive summary, or the final executive summary in the last year of this

permit term, describing the over-all efforts and definitive results.

17. Pursuant to the requirements of OAR 340-28-2270, the permittee is approved to make physical changes

and changes in method of operation that would increase the maximum capacity of a stationary source to

emit VOC, provided the following conditions are met:

52
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 13. of 32 Pages

17.a. Such changes are limited to installing new VOC emitting activities and to making physical

changes or changes in the method of operation of existing VOC emitting activities at the

stationary sources comprising EU1.

17.b. No new stationary source shall be added to EU1.

17,c. Increases in maximum capacity to emit of a stationary source at EU1 resulting from changes

approved under this condition shall have been offset by emission reductions at EU1 achieved

through the pollution prevention program outlined in Condition 16. such that the maximum

capacity to emit of EUI does not exceed the weekly VOC Plant Site Emission Limit (PSEL) for

EU1 specified in Condition 12.a.

17.d. The physical changes and changes in method of operation approved under this condition do not

involve changes to the Pollution Control Devices (PCD) as identified in. Condition 4. or cause a

degradation in the performance of any PCD.

17.e. Any new VOC emitting activities and any physical changes or changes in the method of

operation of existing VOC emitting activities must be subject to, and comply with, the RACT

requiretents specified in Conditions 14. and 15.

I7.f. Any new VOC emitting activities and , any physical changes or changes in the method of

operation of existing VOC emitting activities must be subject to, and comply with, the sourcespecific VOC Compliance monitoring requirements specified in Condition 24.

17.g. No new applicable requirement is triggered.

17.h. Monitoring and Reporting requirements:

17.h.i. The permittee shall conduct monitoring related to this pre-approval condition in accordance

with the monitoring protocols identified in Condition 25.

17.h.ii. Notice of Completion: In accordance with OAR 340-28-2270(3)(f), the permittee shall

include in the semi-annual report (submitted per Conditions 30. & 31.) a summary of any

pre-approved changes made to EU1 pursuant to this condition during the 6-month period

covered by the report, if the maximum capacity to emit of any stationary source at the end

of the 6-month period covered by the report is greater than the maximum capacity to emit at

the end of the 6-month period covered by the previous semi-annual report, as determined

from monitoring conducted per Condition 25.b.

18. The pollution prevention (#16) and pre-approval (#17) conditions as outlined above are a one term

experiment which will expire at the completion of the first term of this Oregon Title-V Operating Permit

34-2681, unless otherwise agreed upon by mutual consent to continue, which will be decided at the time of

permit renewal.

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Permit No.: 34-2681

Expiration Date: 10-31-99

Page 14 of 32 Pages

AGGREGATE HAPs EMISSION LIMITS

19. The permittee shall emit organic (VOC) and inorganic (non-VOC) hazardous air pollutants (HAPs),

on a total aggregate plant site basis, within the following annual limits in order to retain the area

source status for HAPs:

19.a. Aggregate organic HAPs emissions, based on a twelve month rolling average, shall be less than.

10 tons per year.

19.b. Aggregate inorganic HAPs emissions, based on a twelve month rolling average, shall be less than

10 tons per year.

MONITORING REOUIREMENTS

20. The permittee shall conduct. monitoring related to the facility-wide emissions limits and standards

established in Conditions 5. through 8. in accordance with the following procedures and frequencies:

20.a. The permittee shall maintain a log recording. all written complaints or complaints received via

telephone or in person by the responsible official or a designated appointee that specifically refer

to a complaint of odor/visible nuisance from the permitted facility. Said log shall also record

permittee 's actions to investigate,' make a determination as to the validity of the complaint, and

resolve the problem within two working days or within such longer time (not to exceed 7 days)

as is reasonably necessary to resolve the problem that led to the complaint.

20.b. Once during each semi-annual reporting period, the permittee shall inspect and determine

whether any air contaminant source could emit particulate matter larger than 250 microns, and

whether it could cause sulfur dioxide emission in excess of 1000 ppm. The permittee shall

record in a log the results of this inspection.

20.c. The permittee shall maintain a log summarizing actions taken during an applicable air pollution

episode, pursuant to Condition 7.

20.d. The permittee shall conduct all monitoring and recordkeeping related to the Labeling of Products

Using Ozone-depleting substances; 40 CFR Part 82, Subpart E. In addition, the permittee shall

keep records of all SNAP alternative compounds used in place of class I or class H ozonedepleting substances.

21. The permittee shall conduct monitoring related to the EU-specific emission limits and standards established

in Conditions 9, and 10. in accordance with the following procedures and frequencies:

21.a. The minimum monitoring requirements for Condition 9. are specified as follow:

21.a.i. As long as the boilers burn natural gas (or propane/LPG as a backup), the permittee is

assumed to be in compliance with the 20% visible standard (9.a.).

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Page 15 of 32 Pages

21.a, ii. As long as the boilers burn natural gas (or propane/LPG as a backup), the permittee is

assumed to be in compliance with the 0.1 grain loading standard (9.b,).

21 .a.iii. The permittee shall monitor the type(s) of fuel used in EU2 and EU3 boilers as required in

Condition 23: The permittee shall notify the Department in writing and get an approval

prior to using, fuels other than natural gas (or propane/LPG as a backup) in the EU2/EU3

boilers, at which time the permittee may become subject to the construction/operation

modifications requirements as specified in OAR 340-28-2270.

21.b. The minimum monitoring requirements for the 'Operation and Maintenance " protocols of

Condition 10. are specified as follow:

21.b.i. If the scrubber water pumping (flow) rate is changed and the FAB4 is in operation, the

permittee shall record the water flow rate and the corresponding pressure drop across

the padking, and the date of the change.

21.b.ii. The permittee shall keep a log of any maintenance and/or service performed that would

affect the system performance.

22. The permittee shall conduct monitoring related to the Emissions limits and standards applicable to

Insignificant Activities established in Conditions 11. and 13. in accordance with the following procedures

and frequencies:

22.a. Once during each semi-annual reporting period, which may coincide with the monitoring

conducted per Condition 20.b., the permittee shall inspect and determine whether the

categorically insignificant activities and the activities included in the aggregate insignificant

emissions are in compliance with all applicable requirements, condition 11. The permittee shall

record in a log the results of this inspection.

22.b. The permittee shall monitor the VOC content of architectural coatings and spray paint by

obtaining written certification from suppliers or contractors that:

22.b.i. architectural coatings provided by the supplier or used by the contractor comply with the

requirements of OAR 340-22-1020; and

22.b.ii, spray paint provided by the supplier or used by the contractor complies. with the

requirements of OAR 340-22-920.

22.c. The minimum monitoring requirements for emission limits established in Condition 13. for

" aggregate insignificant activities " are as follow:

22.c.i. Once during each permit term, the emissions from the activities included under the aggregate

insignificant emissions limits shall be estimated in accordance with OAR 340-28-

2120(3)(c)(E). The emissions estimation may coincide with the permit renewal application.

55
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 16 of 32 Pages22.c.ii. Once during each semi-annual reporting period, which may coincide with the monitoring

conducted per Condition 22.a., the permittee shall inspect and make a determination that the

activities included under the aggregate insignificant emissions limits have not been modified

in such a manner that would increase the emissions above the aggregate insignificant

emissions limit.

22.c.iii. The permittee shall maintain a log for recording the results of the inspections required by

condition 22.c.

23. The permittee shall determine compliance with the Combustion sources PSELs established in Condition

I2.b. in accordance with the formula and procedures specified:

E = EF x P/2,000 where;

E = pollutant emissions, ton/yr

EF = PSEL Emission Factors, see Table below (& see Attachments)

P = annual natural gas usage (10 6 act)

23.a. For each pollutant, the actual annual natural gas usage is multiplied by the EF below to

determine annual emissions:

Emission Factors (lbs110 6 acf)

Pollutant PK0 SO2 NO, CO VOC

EU2 EF 12 2.6 100 21 3.8

EU3 EF 13.7 2.6 31.5 78.8 2.8

23.b. For each pollutant, the actual monthly natural gas usage is multiplied by the EF below to

determine monthly emissions:

Emission Factors (1bs1I06 acf)

Pollutant PM14 SOz NO, CO VOC

EU2 EF 12 3.8 100 21 3.8

EU3 EF 13.7 3.8 31.5 78.8 2.8

23.c. Monitor and record the amount of natural gas (or LPG) used in the EU2 and EU3 boilers on a

monthly basis.

23.d. Monitor and record the amount of natural gas (or LPG) used in EU3 boilers on a daily basis.

23.e. Monitor and record the quantity and type of fuel(s) other than natural gas (or LPG) used in both

EU2 and EU3 boilers.

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Expiration Date: . 10-31-99

Page 1.7 of 32 Pages

24. The permittee shall determine compliance with the "VOC PSELs" established in Condition 12.a.; "RACT

standards " established in Conditions 14. and 15.; and the "Aggregate HAP limits " established in Condition

19. in accordance with the following chemical mass balance procedures. The minimum monitoring

frequency specified below is also the required interval between two consecutive monitoring periods.

Minimum

Parameter Monitoring Frequency

24.a. Quantity of VOCs used. 2 months

24.b. Quantity of hazardous and non- 2 months

hazardous waste shipped off site, which

include solvent recovered by PCD26; and

the representative VOC content of each

(waste) batch as measured by EPA Method

8015M GC/FID" or other equivalent method.

" For solvents which the EPA standard method 8015 does not cover,

the modified method (EPA 8015M GCIFID) or other equivalent methods

shall be used. The permittee shall record in a log all methods used

to determine the VOC content of waste.

24.e. Quantity of VOCs controlled by PCDI. 2 months

24.d. A total aggregate HAP emission; monthly

separate VOC HAPs from non-VOC HAPs

24.e. Total "cmz " of wafer processed Weekly

24.f. The Bi-monthly emission factor (EF) 2 months

derived from items a, b, c, and the sum of e.

EF = (a-b-c)/Eel(e)

24.g. The weekly VOC emission from Weekly

the weekly production e. and the

most recent EF as determined in f.

Weekly emission = EF * (e)

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Expiration Date: 10-31-99

Page 18 of 32 Pages

Minimum

Parameter Monitoring Frequency

24,h. Weekly RACT compliance Weekly

determination.

"lbsVOC /cm2 Wafer " = g I e

24.i. Free Board Ratio (FBR) None required for automatic control. For

manually operated stations, monitor and

record on a monthly basis.

24.j. The permittee is not subject to the monitoring conditions 24.h. and 24.i. associated with the

RACT standards of Condition 14., until the RACT standards become effective as outlined in

Condition I4.c. The RACT monitoring protocol may be revised if alternative RACT is

established pursuant to Condition 15.

24.k. Source testing Requirements .

24.k.i. Within 3 months of permit issuance, the permittee shall conduct source test on PCD1

and establish the VOC removal efficiency (%) of PCD1 utilized in the VOC emissions

calculations (see item 24.c, above).

24.k. ii. A second source (verification) test shall be conducted in the third year of the permit

term.

24.k.iii. Source tests on PCD1 shall be conducted in accordance with the Department's Source

Sampling Manual, unless an alternative (DEQ/EPA approved) method is approved in

writing by the Department.

25, The permittee shall conduct monitoring related to the pre-approval conditions established in Condition 17.

in accordance with the following procedures and frequencies:

25.a. On a weekly basis, the permittee shall determine the maximum capacity to emit of each

stationary source at EU1 by using the latest EP derived from Condition 24.f., and compare the

results to the weekly PSEL established in Condition I2.a.:

"Maximum capacity to emit" = EF * maximum wafer production capacity (cm 2 /week)

58
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 19 of 32 Pages

25.b. At the end of each 6-month reporting period, which may coincide with the monitoring conducted

per Condition 20.b. or 22.a., the permittee shall inspect and determine whether each preapproved change-made to the EU1 stationary sources complies with the criteria set forth in

Conditions 17.a., 17.b., and 17.d. through 17.g.

25.c. At the end of each 6-month reporting period, the permittee shall determine the maximum

capacity to emit of each stationary sources at EU I. The permittee shall then combine the

"Maximum capacity to emit" of all stationary sources at EU1, and compare the sum (EU1's

maximum capacity) to the sum determined as of the end of the previous six month period. As

specified in Condition 17.h.ii., if the current maximum capacity of EU1 is greater than the

maximum capacity of EU1 as of the end of the previous six month period, the permittee shall

submit a Notice of Completion and include at a minimum the following information:

25.c.i. A summary description of the new and/or modified activities that caused the increase in

maximum capacity to emit of EU1.

Date of completion and the date new and/or modified activities commenced or will begin.

25.c.iii. The net increase in capacity of EU1 due to the new and/or modified activities.

25 .c. iv. A brief summary describing how the increases in the capacity of EU1 have been offset by

the pollution prevention program outlined in Condition 16. such that the weekly VOC PSEL

for EU1 specified in Condition 12.a. is not exceeded. A detailed report shall follow in

accordance with the reporting requirements outlined in Condition 16.d.

TEST METHODS AND PROCEDURES [OAR 340-28-2130(1)]

26. Although source testing is not required for the permit conditions listed below, if source testing is

conducted in addition to the monitoring specified in this permit, the permittee shall use the following test

methods and averaging times to measure the pollutant emissions:

Permit

Condition Test Method Averaging time Special conditions

6.6. EPA Method 6 or

6C

average of three onehour test runs

None.

t 1.a. ODEQ Methods 5,

7, or 8

average of three onehour test runs

ODEQ Method 8 is for sources with exhaust gases at essentially

ambient conditions (e.g. material handling cyclones); ODEQ

Method 7 is for direct contact combustion or other heat sources

(e.g. particle and veneer dryers); ODEQ Method 5 is for indirect

contact fuel burning equipment (e.g. boilers) and any other

source.

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Permit No.: 34-2681

Expiration Date: 10-31-99

Page 20 of 32 Pages

Permit

Condition Test Method Averaging time Special conditions

9.a,

EPA. Method 9

aggregate of three (3)

minutes in any 60

minute period

The test duration may be less than 60 minutes if a violation of

the standard is documented before the full 60 minute -

observation period is completed.

t l.b. aggregate of thirty (30)

seconds in any 60

minute period

9.b. ODEQ Method 5 average of three test

runs

The sample time for each test nun shall be no less than one hour

(31.8 dscf) and no longer than eight hours.

All testing shall be conducted in accordance with the Department 's Source Sampling Manual unless

otherwise specified in the special conditions column of the table above.

RECORDKEEPING REOUIREMENTS [OAR 340-28-2130(3)(b)]

27. The permittee shall maintain the following general records of required monitoring information which

include the following:

27.a. semi-annual inspection results of the status of aggregate insignificant activities;

27.b. semi-annual inspection results of the status of the categorically insignificant activities;

27.c. the date, place as defined in the permit, and time of sampling or measurements;

27.d. the date(s) analyses were performed;

27.e. the company or entity that performed the analyses;

27.f, the analytical techniques or methods used;

27.g. the results of such analyses;

27.h. the operating conditions as existing at the time of sampling or measurement; and

27.i. the records of quality assurance for continuous monitoring systems (including but not limited to

quality control activities, audits, calibrations drift checks).

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Permit No.: 34-2681

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Page 21 of 32 Pages

28. The permittee shall maintain the following specific records of required monitoring information which

include the following:

28.a. Complaint log and investigation reports;

28.b. Operation & Maintenance records;

28.c. Inspection/survey records;

28.d. Quantity and type of fuel used in EU2 on a monthly basis;

28.e. Quantity and.type of fuel used in EU3 on a daily basis;

28.f. Weekly productions in total "cmz " of wafer start;

28.g. Records of chemicals used by type, quantity, and VOC/HAP contents;

28.h. Records of waste shipment and analysis results;

28.i. Continuous monitoring charts, if any;

28.j. Records of all calculated PSEL and RACT emissions; and

28.k. Records resulting from monitoring related to Pollution Prevention and Pre-approval Conditions.

29. The permittee shall retain records of all required monitoring data and support information for a, period of

at least five (5) years from the date of the monitoring sample, measurement, report, or application.

Support information includes all calibration and maintenance records and all original strip-chart recordings

for continuous monitoring instrumentation, and copies of all reports required by the permit. All existing

records required by the previous Air Contaminant Discharge Permit shall also be retained for five (5)

years.

REPORTING REQUIREMENTS [OAR 340-28-2130(3)(c) and 340-28-2160]

30. The permittee shall submit four (4) copies of the semi-annual monitoring report. covering the period from

January 1 to June 30, using Department approved forms, by July 30, unless otherwise approved in writing

by the Department. One copy of the report shall be submitted to the Air Quality Division, two copies to

the regional office, and one copy to the EPA. The semi-annual monitoring report shall include the semiannual compliance certification.

31. The permittee shall submit four (4) copies of the annual monitoring report, using Department approved

forms, by February 15, unless otherwise approved in writing by the Department. One copy of the report

shall be submitted to the Air Quality Division, two copies to the regional office, and one copy to the EPA.

61
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Expiration Date: 10-31-99

Page 22 of 32 Pages

32. The annual monitoring report shall consist of:

32.a. The emission fee report.

32.b. The emission statement. [OAR 340-28-1520]

32.c. The excess emissions upset log. [OAR 340-28-1440]

32.d. The second semi-annual compliance certification covering the period from July 1 to December

31. [OAR 340-28-2160]

Source-specific Reporting Requirements

32.e. Quantity of natural gas burned on a monthly and annual basis for EU2 and EU3. Also certify

that no other fuels than natural gas (or propane/LPG) have been used.

32.f. Tabulate the bi-monthly VOC emissions based on actual solvent monitoring as determined from

data collected per Condition 24: a, b, and c.

32.g. Tabulate the bi-monthly VOC emissions based on EF and production as determined from the (2

months) sum of weekly emissions (24.g). Also report the bi-monthly EFs (lbs VOC/cm2 wafer)

used for each hi-monthly monitoring period. Note that the bi-monthly sum of weekly emissions

based on EF does not have to equal the actual emission determined from the actual solvent

monitoring, i.e., results obtained by this condition (32.g.) do not have to equal results obtained

per item 32.f. above.

32.h. A summary of maximum weekly VOC emissions noted during each (2 months) monitoring period

and corresponding weeks from Condition 24.g. Report all exceedances of the weekly PSEL.

32.i. A summary of maximum weekly RACT emissions noted during each 2 month monitoring period

and corresponding dates (weeks) from Condition 24.h., once the RACT standard becomes

effective. Report all exceedances of the source-specific RACT standard of 2x10-0 lbs VOCs/cm'

wafer processed.

32.j. Report all exceedances of the RACT Free Board Ratio limit (Condition 14.b) as determined from

Condition 24.i., once the RACT standard becomes effective.

32.k. A summary of the (monthly) rolling HAP emissions as determined from Condition 24.d.

Addresses of regulatory agencies:

DEQ-Northwest Region DEQ-Air Quality Division Air Compliance . Division

2020 SW 4th', Suite 400 811 SW Sixth Ave, US EPA

Portland, OR 97201 Portland, OR 97204 Mail Stop AT-084

Telephone (503) 229-5554 Telephone (503) 229-5359 1200 Sixth Avenue

Seattle, WA 98101

62
Permit No.: 34-2681

Expiration Date: 10-31-99 .

Page 23 of 32 Pages

NON-APPLICABLE REOUIREMENTS

33. Air Quality Oregon Administrative Rules (OAR) currently determined not applicable to the permittee are

listed below [OAR 340-28-2190]:

33.a. The following OARs are not applicable because the source is not in the source category cited in

the rules:

340-21-027, 210 to 245. ,

340-22-010 to 025, 106, 110 to 175, 190 to 640; except 340-22-405 to 410.

340- Divisions 23; Division 24 except 340.24-005, 035 to 040; Division 25 except 340-25-505, 510,

515, 525, 554.

340-28-500 to 520, 800 to 820, 2170, 2680.

340-30-420, 460, 500.

340-31-010 to 055.

340-32-220, 250, 4500.

33.b. The following OARs are not applicable because the source does not have specific emissions units

cited in-the rules:

340-21-025.

340-22-180, 183, 186.

33.c. The following OARs are not applicable because the source is outside the special control, nonattainment areas or county cited in the rules.

340-27-025.

340-30-012 to 230, 600 to 620.

33.d. The following OARs are not applicable because the method/procedure is not used by the facility.

340-28-1040.

33.e. The following OARs applied in the past and the fees have been paid.

340-28-2400 to 2550', 2570.

34. Federal applicable requirements currently determined not applicable to the permittee are listed below:

40 CFR Parts 55, 57, 60 except Subpart Dc (60.40c), 61, 63 Subpart T, 68, 72, 73, 75, 76, 77, and 78.

40 CFR Part 82 (except subpart F),

40 CFR Parts 85 through 89, .

Section 129 of the FCAA, Solid Waste,

Section 183(e) of the FCAA, Consumer and commercial products,

Section 183(f) of the FCAA, Tank Vessels.

63
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 24 of 32 Pages

GENERAL CONDITIONS

G1. General Provision

Terms not otherwise defined in the permit shall have the meaning assigned to such terms in the

referenced regulation.

G2. Reference materials

Where referenced in this permit, the version of the following materials are effective as of the dates

noted unless otherwise specified in the permit:

a. Source Sampling Manual; January 23, 1992. - State Implementation Plan Volume 3, Appendix A4;

b. Continuous Monitoring Manual; January 23, 1992 - State Implementation Plan Volume 3,

Appendix A6; and

c. All state' and federal regulations as in effect on the date of issuance of this permit.

G3. Compliance [OAR 340-28-2120(3)(n)(C), 340-28-2130(6), and 340-28-2160(4)]

a. The permittee shall comply with all conditions of the federal operating permit. Any permit

condition noncompliance constitutes a violation of the Federal Clean Air Act and/or state rules and

is grounds for enforcement action; for permit termination, revocation and reissuance, or

modification; or for denial of a permit renewal application. Any noncompliance with a permit

condition specifically designated as enforceable only by the state constitutes a violation of state

rules only and is grounds for enforcement action; for permit termination, revocation and

reissuance, or modification; or for denial of a permit renewal application.

b. Any schedule of compliance for applicable requirements with which the source is not in

compliance at the time of permit issuance shall be supplemental to, and shall not sanction

noncompliance with the applicable requirements on which it is based.

c. For applicable requirements that will become effective during the permit term, the source shall

meet such requirements on a timely basis unless a more detailed schedule is expressly required by

the applicable requirement.

G4. Compliance Monitoring and Enforcement [OAR 340-28-300, 340-28-1100, 340-28-1120, 340-28-1130,

340-28-1140, 340-28-2130(3), 340-28-2160, 340-32-2701

For the purpose of submitting semi-annual compliance certification reports, the permittee shall use,

at a minimum, the information obtained from the monitoring requirements of this permit. The

permittee shall not knowingly falsify or render inaccurate any monitoring device or method

required to be maintained or followed by the permit.

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Page 25 of 32 Pages

b. The information obtained from the monitoring required by this permit can be used directly for

enforcement.

G5. Certification [OAR 340-28-300, 340-28-2120(5) and 340-28-2160(2)]

Any document submitted to the Department pursuant to this permit shall contain certification by a

responsible official of truth, accuracy and completeness. All certifications shall state that based on

information and belief formed after reasonable inquiry, the statements and information in the document

are true, accurate, and, complete. The permittee shall promptly, upon discovery, report to the

Department a material error or omission in these records, reports, plans, or other documents.

G6. Excess Emissions Reporting [OAR 340-28-1400 through 340-28-1460]

a. The permittee shall report all excess emissions in accordance with OAR 340-28-1400 through 340-

28-1460. In summary, the permittee shall immediately (i.e., as soon as possible but in no case

more than one hour after the beginning of the excess emission period) notify the Department by

telephone or in person of any excess emission, other than pre-approved startup, shutdown, or

scheduled maintenance. Notification shall, to the extent reasonably ascertainable at the time of

notification, include the source name, nature of the emissions problem, name of the person making

the report, name and telephone number of the contact person for further information, date and

time of the onset of the upset condition, whether or not the incident was planned, the cause of the

excess emission (e.g., startup, shutdown, maintenance, breakdown, or other), equipment involved

in the upset, estimated type and quantity of excess emissions, estimated time of return to normal

operations, efforts made to minimize emissions, and a description of remedial actions to be taken.

Follow-up reporting shall be made in accordance with Department direction and OAR 340-28-

1430(2) and 340-28-1440.

b. Notification shall be made to the appropriate regional office. Current Departmental telephone

numbers are:

Portland 229-5554 Medford 776-6010 Bend 388-6146

Pendleton 276-4063 Salem 378-8240

c. In the event of any excess emissions which are of a nature that could endanger public health and

occur during nonbusiness hours, weekends, or holidays, the permittee shall immediately notify the

Department by calling the Oregon Accident Response System (OARS). The current number is 1-

800-452-0311.

d. If,startups, shutdowns, or scheduled maintenance may result . in excess emissions, the permittee

shall submit startup, shutdown, or scheduled maintenance procedures used to minimize excess

emissions to the Department for prior authorization, as required in OAR 340-28. 1410 and 340-28-

1420. New or modified procedures shall be received by the Department in writing at least 72

hours prior to the first occurrence of the excess emission event. The permittee shall abide by the

approved procedures and have a copy available at all times.

65
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Page 26 of 32 Pages

e. The permittee shall notify the Department of planned startup/shutdown or scheduled maintenance

events only .if required by permit condition or if the source is located in a nonattainment area for a

pollutant which may be emitted in excess of applicable standards.

f. The permittee shall maintain and submit to the Department a log of planned and unplanned excess

emissions, on Department approved forms, in accordance with OAR 340-28-1440.

G7. Permit Deviation Reporting [OAR 340-28-2130(3)(c)(B)]

The permittee shall promptly report, by telephone or in person, any deviations from permit

requirements that do not cause excess emissions, including those attributable to upset conditions, as

defined in the permit, the probable cause of such deviations, and any corrective actions or preventative

measures taken. Deviations are instances when any permit condition is violated. "Prompt" is defined

as within seven (7) days of the deviation.

G8. Open Burning [OAR Chapter 340, Division 23]

The permittee is prohibited from conducting open burning, except as may be allowed by OAR 340-23-

025 through 340-23-115.

G9. Asbestos [40 CFR Part 61, Subpart M (federally enforceable), OAR 340-32-5600 through 340-32-5650

and OAR Chapter 340, Division 33 (state-only enforceable)]

The permittee shall comply with OAR 340-32-5600 through 340-32-5650, OAR Chapter 340 Division

33, and 40 CFR Part 61, Subpart M when conducting any renovation or demolition activities at the

facility.

G10. Stratospheric Ozone and Climate Protection [40 CFR 82 Subpart F, OAR 340-22-420]

The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40

CFR Part 82, Subpart F, Recycling and Emissions Reduction.

G 11. Permit Shield [OAR 340-28-2190]

a. Compliance with this permit shall be deemed compliance with all applicable requirements as of the.

date of permit issuance provided that:

i. such applicable requirements are specifically identified in the permit, or

ii. such applicable requirements are specifically identified in the "Non-Applicable Requirements"

section of this permit.

66
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 27 of 32 Pages.

b. Nothing in this rule or in any federal operating permit shall alter or affect the following:

is the provisions of ORS 468.115 (enforcement in cases of emergency) and ORS 468.035

(function of department);

ii. the liability of an owner or operator of a source for any violation of applicable requirements

prior to or at the time of permit issuance;

iii. the applicable requirements of the national acid rain program, consistent with section 408(a)

of the FCAA; or

iv. the ability of the Department to obtain information from a source pursuant to ORS 468.095

(investigatory authority, entry on premises, status of records).

c. Sources are not shielded from applicable requirements that are enacted during the permit term,

unless such applicable requirements are incorporated into the permit by administrative amendment,

as provided in OAR 340-28-2230(1)(h), or significant permit modification.

G12. Inspection and Entry [OAR 340-28-2160(3)]'

Upon presentation of credentials and other documents as may be required by law, the permittee shall

allow the Department of Environmental Quality, or an authorized representative (including an

authorized contractor acting as a . representative of. the EPA Administrator), to perform the following:

a. enter upon the permittee's premises where an Oregon Title V operating permit program source is

located or emissions-related activity is conducted, or where records must be kept under the

conditions of the permit;

b. have access to and copy, at reasonable times, any records that must be kept under conditions of

the permit;

c. inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution

control equipment), practices, or operations regulated or required under the permit; and

d. as authorized by the FCAA or state rules, sample or monitor, at reasonable times, substances or

parameters, for the purposes of assuring compliance with the permit or applicable requirements.

G13. Fee Payment [OAR 340-28-2560, and 340-28-2580 through 340-28-2740]

The permittee shall pay an annual base fee and an annual emission fee for all regulated air pollutants

except for carbon monoxide, any class I or class II substance subject to a standard promulgated under

or established by Title VI of the Federal Clean Air Act, or any pollutant that is a regulated air pollutant

solely because it is subject to a standard or regulation under section l12(r) of the Federal Clean Air

Act. The permittee shall submit payment to the Department of Environmental Quality, Business Office,

811 SW 6th Avenue, Portland, OR 97204, within 30 days of the date the Department mails the fee

invoice or August 1 of the year following the calendar year for which emission fees are paid,

whichever is later. Disputes shall be submitted in writing to the Department of Environmental Quality.

Payment shall be made regardless of the dispute. User-based fees shall be charged for specific activities

(e.g., computer modeling review, ambient monitoring review, etc.) requested by the permittee.

67
Pennit No.: 34-2681

Expiration Date: 10-31-99

. Page 28 of 32 Pages

G14. Off-Permit Changes to the Source [OAR 340-28-2220(2)]

a. The permittee shall monitor for, and record, any off-permit change to the source that:

i. is not addressed or prohibited by the permit;

ii. is not a Title 1 modification;

iii. is not subject to any requirements under Title IV of the FCAA;

iv, meets all applicable requirements;

v. does not violate any existing permit term or condition; and

vi. may result in emissions of regulated air pollutants subject to an applicable requirement but

not otherwise regulated under this permit or may result in insignificant changes as defined in

OAR 340-28-110.

b. A contemporaneous notification, as required in OAR 340-28-2220(2)(b), shall be submitted to the

Department and the EPA.

c. The permittee shall keep a record describing off permit changes made at the facility that result in

emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise

reguiated'under the permit, and the emissions resulting from those off-permit changes.

d. The permit shield of condition G11 shall not extend to off-permit changes.

G15. Section 502(b)(10) Changes to the Source [OAR 340-282220(3)]

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

defined as a change that would contravene an express permit term but would not:

i. violate an applicable requirement;

ii. contravene a federally enforceable permit term or condition that is a monitoring,

recordkeeping, reporting, or compliance certification requirement; or

iii. be a Title 1 modification.

b. A minimum 7-day advance notification shall be submitted to the Department and the EPA in

accordance with OAR 340-28-2220(3)(b),

c. The permit shield of condition G11 shall not extend to section 502(b)(10) changes.

G16. Administrative Amendment [OAR 340-28-22301

Administrative amendments to this permit shall be requested and granted in accordance with OAR 340-

28-2230. The permittee shall promptly submit an application for the following types of administrative

amendments upon becoming aware of the need for one, but no later than 60 days of such event:

a. legal change of the registered name of the company with the Corporations Division of the State of

Oregon, or

68
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 29 of 32 Pages

b. sale or exchange of the activity or facility.

G17, Minor Permit Modification [OAR 340-28-2250]

The permittee shall submit an application for a minor permit modification in accordance with OAR 340-

28-2250.

G18. Significant Permit Modification [OAR 340-28-2260]

, The permittee shall submit an application for a significant permit modification in accordance with OAR

340-28-2260

G19. Construction/Operation Modification [OAR 340-28-2270]

No permittee shall construct or make modifications required to. be reviewed under OAR 340-28-2270,

the construction/operation modification rule, without receiving a Notice of Approval in accordance with

OAR 340-28-2270. The permittee should allow 60 days for Department review of applications for a

construction/operation modification if public notice is not required, or 180 days if public notice is

required.

G20. New Source Review Modification [OAR 340-28-1900]

No permittee shall construct or make modifications required to be reviewed under New Source Review

(OAR 340-28-1900(1)) without receiving an Air Contaminant Discharge Permit (ACDP) (OAR 340-28-

1700). The permittee should allow 180 days for Department review of an ACDP application for New

Source Review.

G21. Hazardous Air Pollutant Modification for Non-major HAP Sources [OAR 340-32-230 (state-only

enforceable)]

No permittee shall make a physical change in or change in the method of operation of a non-major

HAP source that results in an increase in the potential to emit so that the major source threshold (i.e.,

10 tons of an individual HAP or 25 tons of aggregate HAPs) is exceeded, without first obtaining a

Notice of Approval in accordance with OAR 340-28-2270. The permittee should allow 180 days for

Department review of applications for construction/operation modifications and issuance of a Notice of

Approval.

G22. Need to Halt or Reduce Activity Not a Defense [OAR 340-28-2130(6)(b)]

It shall not be a defense for a pert-Mace in an enforcement action that it would have been necessary to

halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.

69
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 30 of 32 Pages

G23. Duty to Provide Information [OAR 340-28-2130(6)(e) and OAR 340-28-300]

The permittee shall furnish to. the Department, within a reasonable time, 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 records required to be retained by the permit.

G24. Reopening for Cause [OAR 340-28-2130(6)(c) and 340-28-2280]

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

determined by the Department.

b. 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.

c. A permit shall be reopened and revised under any of the circumstances listed in OAR 340-28-

2280(1)(a).

d. Proceedings to reopen and reissue a permit shall follow the same procedures as apply to initial

permit issuance and shall affect only those parts of the permit for which cause to reopen exists.

G25. Severability Clause [OAR 340-28-2130(5)]

Upon any administrative or judicial challenge, all the emission limits, specific and general conditions,

monitoring, recordkeeping, and reporting requirements of this permit, except those being challenged,

remain valid and must be complied with.

G26. Permit Renewal and Expiration [OAR 340-28-2120(l)(a)(D) and 340-28-2210]

a. This permit shall expire at the end of its term. Permit expiration terminates the permittee's right

to operate unless a timely and complete renewal application is submitted as described below.

b. Applications for renewal shall be submitted at least 12 months before the expiration of this permit,

unless the Department requests an earlier submittal. If more than 12 months is required to process

a permit renewal application, the Department shall provide no less than six (6) months for the

owner or operator to prepare an application. Provided the permittee submits a timely and

complete renewal application, this permit shall remain in effect until final action has been taken on

the renewal application to issue or deny the permit.

G27. Permit Transference [OAR 340-28-2230(1)(d)]

The permit is not transferrable to any person except as provided in OAR 340-28-2230(1)(d).

70
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 31 of 32 Pages

G28. Property Rights [OAR 340-28-110(9)(c) and 340-28-2130(6)(4)]

The permit does not convey any property rights in either real or personal property, or any exclusive

privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor

any infringement of federal, state, or local laws or regulations, except as provided in OAR 340-28-

2190.

G29. Permit Availability [OAR 340-28-110(9)(c) and 340-28-2200(2)]

The permittee shall have available at the facility at all times a copy of the Oregon Title V Operating

Permit and shall provide a copy of the permit to the Department or an authorized representative upon

request.

ALL INQUIRIES SHOULD BE DIRECTED TO:

Northwest Region

2020 S.W. 4th Avenue, #400

Portland, OR. 97201-5884

Telephone: (503) 229-5263

T342681

71
Permit No.: 34-2681

Expiration Date: 10-31-99

Page 32 of 32 Pages

ATTACHMENT-1

The following Oregon Administrative Rules have been renumbered from Division 20 to Division 28. The

Division 20 rules are enforceable by the EPA until the proposed State Implementation Plan (SIP) revisions have

been approved by the EPA. At that time, the Division 28 rules will be enforceable by the EPA. Currently, the

Division 28 rules are enforceable by the Department only.

State-only Enforceable Rules Federally Enforceable Rules

340-28-500 340-20-005

340-28-510 340-20-010

340-28-520 340-20-015

340-28-800 340-20-020

340-28-810 340-20-025

340-28-820 340-20-030

340-28-1010 340-20-301

340-28-1020 340-20-310

340-28-1030 340-20-315

340-28-1040 340-20-320

340-28-1100 340-20-035

340-284120 340-20-040

340-28-1130 340-20-045

340-28-1140 340-20-046

340-28-1400 340-20-350

340-28-1410 340-20-360

340-28-1420 340-20-365

340-28-1430(2) through (5) 340-20-370

340-28-1440 340-20-375

340-28-1700 340-20-140

340-28-1900 340-20-220

T342681

72
Review Report: 34-2681

Application No.: 14659

Page 1 of 42 Pages

Department of Environmental Quality

Air Quality Division

OREGON TITLE-V OPERATING PERMIT APPLICATION REVIEW REPORT

Intel Corporation

5200 NE Elam Young Pkway, #AL4-19

Hillsboro, OR 97124-6497

PSEL

CRED

SOURCE

TEST

COMS CEMS AMB

MON

COMPL

SCHED

SPEC

COND A S

REPORT

Q

EXCESS NSPS NSR P5D NESHAPS SIZE

M R N Al A2

©^^ X X

X X X

This permit review report is formatted to accommodate the permit

conditions and thus recommended to be reviewed simultaneously and

in direct reference to the permit line items. This review report

intends to convey all pertinent emission data, rules, policies,

theories and engineering assumptions. used to construct the Oregon

Title-V Operating Permit 34-2681. The primary source of

information used to construct this permit is the referenced

application (No. 14659).

Oregon Title-V Operating Permit 34-2681 focuses on numerous

permitting issues which include a source specific RACT

determination, increase in the boiler PSELs, and the pre-approved

changes and pollution prevention protocols. Applicable

regulatory standards and associated monitoring, recordkeeping,

reporting requirements, along with the applicable conditions from

the existing Air Contaminant Discharge Permit (ACDP are

incorporated into the Oregon Title-V Operating Permit 34-2681 as

outlined:

TABLE OF CONTENTS PAGE

Background Information 2

Facility description

Compliance history

Operating scenario

Permitted Activities 5

Emission Unit & Pollution Control Device Identification

Emission Limits and Standards 9

Plant Site Emission Limits 12.

73
Review Report: 34-2681

Application No.: 14659

Page 2 of 42 Pages

TABLE OF CONTENTS

Source-Specific Conditions:

Source-specific RACT Standards

Pollution Prevention and

Pre-approved Changes

Aggregate HAP Emission Limit

Monitoring Requirements

Test Methods and Procedures

Recordkeeping Requirements

Reporting Requirements

Non-Applicable Requirements

General Conditions

.Summary/Public Notice

Attachments:

PSEL Detail Sheets Al-A6

EU2 Baseline Capacity A7

Fig.l:. VOC Monitoring A8

RACT Emission Data A9-A13

Toxic Substance Usage A14

BACKGROUND INFORMATION

The proposed Oregon Title-V Operating Permit replaces an existing

Air Contaminant Discharge Permit (ACDP) which was issued on.

4/19/93 and was originally scheduled to expire on 11/01/96. The

proposed permit applies to all existing and planned activities at

the Intel Aloha Campus occupying 54.5 acres of properties located

at 3585 Southwest 198th Avenue, Aloha, Oregon, 97007. Mr. Sunlin

Chou is currently identified as the primary responsible official

for the Aloha Campus operations.

Intel submitted a Land Use Compatibility Statement (LUCS) to

Washington County Department of Land Use & Transportation

(WCDLUT), and the Washington County signed and approved the LUCS

on 9/20/91. Other permits issued or required by the Department

for this source include NPDES permit 100917 for non-process

wastewater discharge. The process wastewater is discharged to

PAGE

19

28

. 30

31

39

39

39

40

40

40

74
Review Report: 34-2681

Application No.: 14659

Page 3 of 42 Pages

one of the Unified Sewerage Agency's (USA) wastewater treatment

plants of Washington County. This source is also a registered

large quantity hazardous waste generator; ORD 060591963. The VOC

emission calculations include monitoring of the hazardous waste

streams.

Facility Description.

Intel Corporation operates one of its semiconductor manufacturing

plants in Aloha, Oregon, hereby occasionally referred to as the

Aloha campus. There are five main buildings at the Aloha campus;

AL3, AL4, FAB4, FAB5, and D1. Buildings AL3 and AL4 are

primarily office buildings. Buildings FAE4 and FAB5 are the main

manufacturing facilities. The D1 currently serves as a

technology development facility, for newer generation of

semiconductors, which would gradually be converted to a

manufacturing facility. Besides these five main buildings, there

are several other (relatively small) buildings located on the

west side of - the•Aloha campus which are currently used by

contractors and consultants working for Intel.

The Aloha facility is located in a nonattainment area for ozone

and Carbon Monoxide (CO). The facility is a major (> 100

tons/yr) source of VOCs (ozone precursor), but is a minor (32

tans/yr) source of CO. Intel is also a minor source of Hazardous

Air Pollutants CHAPS).

This source is not subject to federal regulations for Prevention

of Significant Deterioration (PSD), or National Emissions

Standards-for Hazardous Air Pollutants (NEORAPS).

Compliance History

The most recent facility inspections were conducted on 9/21/95,.

9/07/94, and 9/21/93; and the source was found to be in

compliance with all existing ACDP conditions. A file, review also

indicates, ever since the beginning of operation, no public

complaints were received by the Department. The permittee's

unblemished compliance history is one of the factors influencing

the level of compliance demonstration requirements established in

this permit. Item 20.a. of this review report provides a good

example.

Intel's (only) Operating Scenario

Intel has identified one operating scenario covering a broad

spectrum of semiconductor manufacturing operations. The

production steps traditionally include application of

75
Review Report: 34-2681

Application No.: 14659

Page 4 of 42 Pages

photoresist, UV light exposure, developing, etch, deionized water'

rinse, doping, and acid/solvent rinse steps. Under this one

operating scenario, the source operations are divided into three

emission units. Each identified emission unit (EU) is grouped

with respect to common applicable rule requirements, and this

grouping allows each EU to be regulated under uniform compliance

monitoring requirements.

The semiconductor manufacturing processes emit VOCs from

chemicals/materials that they use. In terms of specific

processes, VOCs' are emitted from the photoresist applications

(mainly spin coaters and developers), solvent cleaning stations,

and storage/handling operations. Over 90% of the plant site VOC.

emissions come from the photoresist applications, and the

remaining 10a is mostly generated from the solvent cleaning

stations. These VOC generating processes located throughout the

Aloha campus are grouped under Emission Unit 1 (EU1).

The operating scenario at EU1 covers the plant site VOC

emissions, excluding a small amount of VOCs in the boiler flue

gases. Regulations pertaining to Intel's (non-fuel burning)

process VOC emissions are uniform, and by grouping the VOC

emission sources as one emission unit (EU1) eliminates any

ambiguity associated with- the compliance demonstration with

respect to the PSEL and RACT, or applicability of New Source

Review (NSR) and Prevention of Significant Deterioration (PSD).

This would perhaps become increasingly more apparent as this

permit document is reviewed further.

The operating schedule is proposed at 24 hrs/day x 365 days/yr;

meaning this permit does not directly impose a cap on the

operating hours nor the production rate. Instead the permit

focuses on the actual VOC emissions by strict enforcement of the

VOC PSEL and RACT conditions. As will be discussed in the PSEL

section, the EU1's VOC PSEL essentially represents a cap and it

also serves as the starting point from which to determine the

NSR/PSD applicability. The RACT standards proposed in this

permit are also designed td limit VOC emissions on a unit

production basis. A combination of VOC PSEL and RACT standards

effectively regulates the permittee's actual VOCs emissions.

Boilers are separated into two emission units (EU2 & EU3) based

on the size (industrial or commercial) category in which the predetermined fuel usage is the primary limiting factor for each

unit. Unlike the EU1 process VOC PSEL, the combustion PSELs

established for EU2 and EU3 boilers represent a cap on fuel

usage. All boilers are limited to burn natural gas only as

identified in the Intel's only operating scenario. The hourly

(short term) emissions from the EU2/EU3 boilers are based on each

Emission Unit's maximum capacity, and theoretically this maximum

capacity cannot be exceeded, unless the boiler is physically

76
Review Report: 34-2681

Application No.: 14659

Page 5 of 42 Pages

modified. All EU2/EU3 boilers are operated below their operating

capacity. As discussed, annual operations of the EU2/EU3 boilers

are limited by the allowable natural gas usage, and these limits

are further reflected in the boiler PSELs..

PERMITTED ACTIVITIES

1. Condition 1 basically sets the tone that the permittee is

allowed to discharge regulated air pollutants only in

accordance with the limits and standards established in the

Oregon Title-V Operating Permit 34-2681. The effective date

of this permit is the date of the permit issuance.

2. Condition 2 makes a clear distinction between the state-only

enforceable conditions from those conditions enforceable by.

both state and the U.S. EPA. All conditions in this permit

are enforceable by both the EPA and State, except those

conditions and associated monitoring specifically identified

in item 2.a._as state-only enforceable.

The monitoring. (plus recordkeeping/reporting) requirements

associated with the state-only applicable requirements are

cited in* item 2.a. by reference only, for reason that some

of these monitoring protocols are also used by the federally

enforceable conditions. Specific monitoring is extractable

by its association to specific applicable requirements.

A list of non-applicable rules and the summary of reasons

are provided in the Non-applicable requirements section,

toward the end of this permit.

EMISSION UNIT'AND CONTROL DEVICE IDENTIFICATION

3. Existing air contaminant sources at the facility are grouped

as follow:

3.a. Emission Unit #l (EU1)

Buildings AL3 and AL4 are primarily office buildings with no

measurable emissions (or worth measuring) and they are

listed here for identification purpose only. FAB4 and FAB5

are existing manufacturing facilities, and D1 is currently a

technology development center which may also (gradually)

become a manufacturing facility.

77
Review Report : 34-2681

Application No.: 14659

Page 6 of 42 Pages

Emission Unit #1 (EU1) in a physical sense is the entire

Aloha campus excluding EU2 and EU3 boilers. It includes all

non-fuel burning activities and processes at the Aloha

campus that emit VOCs. These activities/processes are

grouped as one emission unit since they emit the same

regulated air pollutant .(VOCs), trigger the same applicable

requirements, and share the same compliance monitoring

protocols.

As listed in the permit ' item 3.a. (table), EU1 is divided

into three (3) stationary sources; EU1.1, EU1.2, and EU1.3.

FAB4 and FAB5 buildings share a common material flow

(distribution & waste collection) and they are combined to'

comprise a . stationary source EU1.1. The current emission

capacity of EU1.1 is 190 tons per year.. The second

stationary source EU1.2 is the D1 building. It utilizes its

own material flow and employs newer technology. The D1

building (EU1.2) is currently under expansion and its

projected emission capacity is rated at 53 tons per year.

As discussed, a stationary source EU1.3 consists of AL3 and

AL4 office buildings with no rated emission capacity.

3.b./c. Emission Unit #2 (EU2) and Emission Unit #3 (EU3)

Currently there is a total of sixteen (16) boilers, and two

(EU3.4 & EU3.5) more are planned to be installed during the

94/95 calendar year. This permit is for the total capacity

of 18 boilers. The electric boiler (EU2.8) has been omitted

for obvious reason. All (EU3) D1 boilers fall under the

industrial boiler category (10 to 100 million btu/hr) and

the rest (EU2) are commercial type (0.5 to 10 million

btu/hr). All EU2 and EU3 boilers are permitted to burn

natural gas (and propane backup) only. In addition, all EU3

boilers would be operated with the LowNO, control.

EU2 Boiler ID Yr installed. Max. BHP Fuel

EU2.1 FAB4 - #1 1977 66.7 . n.gas

EU2.2 FAB4 - #2 1977 66.7 n.gas

EU2.3 FAB4 - #3 1977 66.7 n.gas

EU2.4 FAB5 - #1 1978 144.4 n.gas

EU2.5 FAB5 - #2 1978 144.4 n.gas

EU2.6 FAB5 - #3 1992 139.5 n.gas

EU2.7 FAB5 - ##4 1992 139.5 n.gas

EU2.9 FAB5 - #6 1993 27.9 n.gas

EU2.10 FAB5 - #7 1993 93.0 n.gas

78
Review Report: 34-2681

Application No.: 14659

Page 7 of 42 Pages

EU2.11 FAB5.- #8 1993 93.0 n.gas

EU2.12 AL4 - #1 1990 65.1 n.gas

EU2.13 AL4 - #2 1990 65.1 n.gas

EU2.14 AL4 - #3 1990 65.1 n.gas

EU3 Boiler ID Yr installed Max.•BHP Fuel_

EU3.1 Dl - #1 1992 465 n.gas

EU3.2 ' D1 - #2 1992 465 n.gas

EU3.3 Dl - #3 1993 653 n.gas

EU3.4 Dl - #4 1994 465 n.gas

EU3.5 Dl - #5 1994 455 n.gas

Baseline Boilers 106 btu/hr (qal/hr)

EU2. 1 (FAB4 -- #I) 3 (22.8)

EU2.2 (FAB4 - #2) 3 (22.8)

EU2.3 (FAB4 - #3) 3 (22.8)

EU2. 4 (FAB5 - #I) 6.5 (49.5)

EU2.5 (FAB5 - #2) 6 . 5 (49.5) . _ .

EU2 Baseline Capacity: .22 .xc 106 btu/hr (167 gal/hr)

Note the boiler capacity and chronological information

contained in this section shall be used to track changes in

the boilers' emission capacity since the baseline and

determine applicability of NSR/PSD when necessary. The

baseline capacity of EU2 is based on the fuel oil-usage of

l. 4-7__milli-on_...gal_lons....per...year,_ A tchment_ A7_ contains

estimation of emissions from EU2 boilers based on their

baseline oil capacity. The EU3 boilers did not exist during

baseline and therefore the baseline capacity of EU3 is set

equal to zero.

This permit review determined the EU3 boilers to be NSPS

boilers, pursuant to 40 CFR (§) Part 60.40c, Subpart Dc,

"Standards of Performance for Small Industrial-CommercialInstitutional Steam Generating Units". Each of the five (5)

EU3 boilers is capable of burning natural gas (or LPG) only.

None of the EU3 boilers generate steam, and they do not heat

any materials that would be used in the heat transfer

operations. However, as noted above (465 BHP ,. 20.9 X 106

btu/hr & 653 BHP 29.4 X 106 btu/hr), each EU3 boiler's

capacity is greater than the subpart-Dc lower size cut-off

(10 X 106 btu/hr), and the EU3 boilers are . indeed used

partially to heat (hot) water used throughout the Aloha

campus, thus triggering one of the subpart-Dc applicability.

79
Review Report: 34-2681

Application No.: 14659

Page 8 of 42 Pages

4. VOCs Pollution Control Devices: Intel operates two pieces

of VOC emission control equipment. A wet scrubber (PCD1)

was installed and went into operation in late 1994. A wet

scrubber controls water miscible VOCs emitted from the FAB4

building. The. scrubber effluent containing water soluble

chemicals is ruted to one of the wastewater treatment

plants operated by Unified Sewerage Agency of Washington

County, and this wastewater discharge is indirectly

regulated by the Department through the pre-treatment

program.

The other VOC control device (PCD26) is the Carbon

Concentration Condensation Unit (CCCU), and it also has been

installed and began operations in 1995. The. PCD26 is

dedicated to controlling VOC emissions arising from

operations conducted in D1 building (EU1.2).

- VOC emission control devices -

Pollution

Control

Device{PCD)

PCD

ID

Emission

Unit/Process

Controlled

Design

Parameters

Design

efficiency

Wet Scrubber

(Spray Tower)

PCD1 VOC emissions

from FAB4

building

(EU1. 1)

Fgu = 6,000 acfm

FN20 = 100-150 gpm

P,^^^^^ = 6.0 in. H2O

> 90%

Carbon

Concentration

Condensation

Unit (CCCU)

PCD26 VOC emissions

from D1

building

(EU1.2)

F,, = 2,000 acfm

.The VOC removal. efficiency is

rated at above 90a but this

efficiency rate (o) is not a

necessary parameter to complete

the VOC CMB, as described in

detail below.

PCD26 The CCCU (PCD26) is designed to treat an air stream

relatively dilute with low concentration of VOCs. The CCCU

utilizes a carbon adsorption/reactivation technology coupled

with a condenser to recover VOCs. The VOC condensate

recovered from PCD26 is directly piped to the solvent waste

storage tank, and this is the reason the PCD26 control

efficiency (normally obtained through source testing) is not

needed to complete the chemical mass balance (CMB), a method

used in this permit as the compliance monitoring protocol

for the plant site VOC emissions.

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The CCCU consists of a carbon adsorption tower, a desorption

tower, and a condenser laid out in series. Process air

stream from EU1.2 relatively dilute with VOCs is directed to

the bottom of the adsorption tower, where the treated air

exits - through the top. The adsorption tower is constructed

with a series of "tilted" sieve trays designed to move

(utilizing gravity force) solid Bead Activated Carbon (BAC)

from top tray to the next one below and so on down to the

bottom. VOC laden air stream moving upwards fluidizes the

BACs, which in turn adsorbs VOCs in the air stream.

Carboni beads (BAC) laden with VOCs exit the adsorption tower

and enter the desorption tower, where a small (manageable)

volume of air laden with the VOC-stripping gas is introduced

to reactivate the BAC by desorbing/stripping VOCs from it.

Reactivated BACs are returned to the adsorption tower, in

which the cycle is continuous. The VOC laden air (with

stripping gas) stream exiting the desorption tower contains

optimum - amount of VOCs and is routed to the condenser for

efficient recovery. -

There are basically two control options available for

(relatively) concentrated solvent laden air exiting the

desorption tower: thermal destruction or condensation. The

condenser control option (unlike thermal control) eliminates

the formation of combustion by-products, and it is the

preferred method, and the method chosen by Intel. The

condenser option also simplifies the VOC monitoring since

the amount of solvent recovered is already an inherent part

of.._the. - _overall ..- che.mical_mass balance. As reflected in the

permit VOC monitoring condition, where PCD1's control

efficiency is needed and must be verified through source

test, the PCD26 control efficiency is not necessary to

complete the CMB. Of minor note, the thermal control

traditionally have been subject to additional monitoring

requirements such as measuring the capture and destruction

efficiency, and monitoring the combustion temperature.

EMISSION LIMITS AND STANDARDS,

This section contains all applicable emission limits and

standards other than the PSEL and the source-specific standard

such as reasonably available control technology (RACT). The

applicable limits and standards of this section are further

divided into three sub-categories as follow: Table-I contains

those limits applicable to the entire facility, and Table-II

contains the specific limits applicable to the emission units and

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pollution control devices identified, and lastly Table-III

summarizes the applicable limits of "insignificant" activities.

Facility-wide Limits and Standards

5. Condition 5.a. reflects OAR 340-21-060(2) and is. applicable

to all sources located inside Special control areas as

defined in OAR 340-21-010, or when ordered by the Department

in other areas. Intel is located inside Washington County,

within the Special control areas defined in the rules.

Condition 5.b. as written establishes a basis for regulating

odor and other unforeseeable nuisance problems that may

arise in the future.

6. Condition 6. includes two state-only enforceable

requirements. The {250 micron) particulate fall out

standard is applicable to all permitted sources located

inside the tri-county area that do not have specific

industrial standards, and thus applicable to Intel. The

1000 ppm SO2 standard is also applicable to all permitted

sources located inside the tri-county area. The tri-county

consists of Clackamas, Multnomah, and Washington Counties.

7. This condition requires the permittee to implement the

appropriate procedures as outlined in their Source Emission

Reduction Plan (SERP) in the event an air pollution alert,

warning, or emergency episode, due to high formation of

ozone, is declared in the Portland area by the Department.

8. Pursuant to 40 CFR Part 82, Subpart E; The Labeling of

Products Using Ozone-depleting substances, Condition 8. is

established because the permittee currently uses the

following ozone depleting chemicals:

Ozone-depleting Replacement

substance Class Chemical

CFC-12 I R-123 or R-134A

HCFC-22 II No plans yet

HCFC-123 II No plans yet

Halon 1211 II No plans yet

Halon 1301 II No plans yet

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Emission Unit Specific Limits and Standards

9. The visible and grain loading standards of this condition

apply to any single air contaminant discharge point to the

atmosphere that originated from the fuel combustion sources.

Which means these standards are applicable to each and every

stack of the EU2 and EU3 boilers.

10 The "Operation & Maintenance" requirements of condition 10.

are applicable only to PCD1; the VOC wet scrubber. This

condition effectively replaces the existing Highest and Best

condition in ACDP, pursuant to OAR 340-28-600 (2)(e) and

340-28-620. This O&M condition focuses on the sourcespecific maintenance and work practice requirements for PCD1

that are deemed appropriate for the Intel specific PCD1

operations.

Operating parameters that influence the (PCD1) scrubber VOC

removal 'efficiency include the air exhaust from FAB4 (air

inlet to PCD1), its (PCD inlet) VOCs concentration, and the

scrubber water flow rate. The PCD1 inlet air flow and its

VOC concentrationare basically dictated by the production,

and these are not the appropriate control parameters to be

regulated as the permit conditions. The water flow rate is

the design control parameter suited for the permit O&M

requirements. The VOC removal efficiency varies with

respect the water flow rate, and the optimum water flow rate

is yet to be determined through source test. The PCD1

design predicts the acetone (to be de-listed) removal rate

of -90 o---or- greater. Th- e --re-mova.l..._rates.. of __other _water soluble

VOCs would be slightly less:

Emission Limits and Standards Applicable to Insignificant

Activities

11. The grain loading standard. established in Condition 11.a.

applies to any single (non-fugitive) air contaminant

discharge. point (stack) to the atmosphere that originated

from non-fuel burning sources which include "categorical"

and non-categorical "aggregate" insignificant activities. -

The 200 opacity limit of Condition ll.b. is applicable to

fugitive emission sources as well as the stack emission

sources identified as the insignificant activities.

Recently adopted the paint spray and architectural coating

rules . (11.c.) are applicable to all permitted sources

located inside the Portland ozone non-attainment area.

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PLANTSITE EMISSION LIMITS

12. 12.a. EU1 (VOC) PSEL

ANNUAL PEEL: The Aloha campus excluding D1 (EU1.2) was

constructed during 1976 through 1978, and the facility was

retroactively assigned an emission limit (PSEL) equal to the

1978 capacity to emit (190 tons VOC per year) in the first

Department issued Air Contaminant Discharge Permit. This

baseline emission rate of 190 tons of VOC per year is also

the permittee's current PSEL. It also serves as the

stationary source EU1.1 (FAB4 & FAB5) maximum capacity to

emit. A stationary source EU1.2 (D1) currently under (ongoing) expansion was recognized under the previously issued

ACDP. The Dl building has the maximum emission capacity of

53 tons/yr, and it is the EU1.2's maximum capacity

recognized in this permit.

The baseline PSEL of 190 tons/yr has been and continues to

comprise'a cap on permittee's plant wide actual emissions,

and it shall be used as the basis for limiting source's VOC

emissions for various physical and operational changes that

are permitted and contemplated by this permit. This means

for the purpose of determining applicability of (major) New

Source Review (NSR) or Prevention of Significant

Deterioration (PSD), OAR 340-28-1900 through 340-28-2000,

the baseline capacity of 190 tons of VOCs per year is the

starting point. Accumulative VOC emission increases/

decreases which result in a net (actual) emission increase

greater than the Significant Emission Rate (40 tons/yr)

would trigger the NSR; and the FACT/LAER review would be

imposed on the stationary source that causes the increase..

Any increases less than SER but above the PSEL of 190

tons/yr, no matter how small, will trigger the permit

modification process.

EU1 Baseline Capacity EU1 Current PSEL 190 tons/yr.

WEEKLY PSEL: Pursuant to OAR 340-28-1020 (2), the short

term PSEL established in this permit is the weekly PSEL.

The weekly limit was determined to be most compatible with

source operations.

Intel normally operates their production lines continuously

for about.5 to 7 days. Chemicals applied at the production

lines have uniform solvent content (o VOC) that does not

fluctuate during the continuous weekly operations. The

level of VOC emission would be proportional to the

production rate. The weekly emission closely reflect the

sum of their daily emissions which are evenly distributed.

In the last ACDP renewal, the weekly VOC PSEL was set at 8.0

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tons/wk. The 8.0 tons weekly PSEL reflects the maximum

weekly production rate extrapolated from the emission

monitoring conducted from 6/28/92 to 8/29/92 (ACDP data);

and it is retained in this permit.

HISTORY OF CHANGE TO VOC (EU1) PSEL: There have been no

Department approved VOC (EU1) PSEL increases or decreases

between . the baseline year (1978) and this permit (1995).

The current EU1 PSEL is set equal to the baseline capacity

of 190 tons/yr.

12.b. Boilers (EU2 & EU3) PSELs

BASELINE PSELs for EU2: The baseline boiler PSELs were

established based on the fuel usage of 399,000 gallons of

diesel. For the purpose of assigning diesel fuel usage

among the baseline EU2. boilers, the capacity ratio of each

boiler was used (see attached detail sheet A6). Note only

the total fuel usage affects the emission calculation.. The

fuel combustion products (criteria pollutants) generated

(tons/yr) based on the fuel usage of 399,000 gallons of

diesel are summarized below:

PMto S02 NO, CO VOC

0.4 14.2 - 4.0 1.0 0.1 .

CURRENT PSEL for EU2: Intel is committed to fueling these

boilers with natural gas only. The short-term PSELs,are

based on EU2's maximum fuel capacity. And based on proposed

_ nat-ural--gas---u-sage-the- e-s-t-im•a•ted----a-nnua-l---EU2---emirs-ions--

(tons/yr) are:

PM10 S 2 NO, CO VOC

1.15 0.25 9.55 2.01 0.36

BASELINE PSEL for EU3: All existing and planned EU3 boilers

were/would be constructed after 1978, and therefore the

baseline PSEL for EU3 is set equal to zero.

CURRENT PSEL for EU3: All EU3 boilers are capable of

burning natural gas only. The short-term PSELs are based on

EU3's maximum fuel capacity. And based on forecasted

natural gas consumption the estimated annual EU3 emissions

(tons/yr) are:

PMia S02 NO, CO VOC

5.21 0.99 11.97 29.94 1.06

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History of chancres to the EU2/EU3 boilers' annual PSEL

The ACDP addendum , l issued on 3/7/89 increased the SO2 PSEL

to 16.4tons/yr from the baseline rate of 14.2 tons/yr. The

EPA AP42 emissions factors for boilers have been updated,

and this permit reflects updated AP42 boiler emission

factors. The EU2 and EU3 boilers' baseline PSELs are

reconstructed to reflect these new AP42 emission factors.

Thirteen additional boilers (not counting the electric EU2.8

boiler) have been installed since the baseline year. In

this permit, Intel forfeited EU2 boilers' capacity to burn

oil and all boilers are now committed to burning natural gas

only.

Since the baseline year, a combined capacity of all EU2 and.

EU3 boilers have increased by almost an eight fold from 22

to 166 million btu/hr. However, using only the natural gas

and retrofitting all D1 boilers with LowNOx burners would

minimize'the over-all increases, and actually reduces the

boiler S02 emissions.

Based on the.. proposed fuel usage (see attachment A6), the

proposed EU2 & EU3 boilers' PSELs are estimated below. The

increase in emission of each pollutant is less than the

Significant Emission Rate •(SER) as defined in OAR 340-20-225

(25). All particulates emitted from the boilers are

regarded as PM1 o for the permitting purpose. Also note the

SO2 PSEL has actually decreased since the baseline while the

capacity went up by almost

expressed in tons per year:

an eight

PSEL

fold. All units are

Pollutant, Baseline Increase SER

PMm 0.4 6.4 6.0 15

S02 14.2 1.3 -12.9 40.

NO, 4 . 0 21.6 17.6 40

CO 1.0 32.0 31.0 100

VOC 0.1 1.5 1.4 40

EU2/EU3 Short-term PSELs

Oregon's PSEL rules indicate the short-term PSEL (averaging

period) be consistent with the ambient standards unless such

practice is incompatible with source operation. The shortterm ambient standards for criteria pollutants are expressed

in term of hourly to 24-hour average.

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Intel operates a total of 18 boilers on natural gas, in a

non-attainment area for ozone and carbon monoxide, and the

combined annual emissions (PSEL) total 1.5 tons of VOCs and.

'32 tons of. CO; which-are considered insignificant.

The EU2/EU3 PSEL is basically a product of natural gas usage

and the AP42 emission factor, in which the gas usage is the

actual limiting factor. The short-term (monthly) PSEL for

the EU2/EU3 boilers is based on the maximum (rated) hourly

capacity multiplied by 24 hrs/day and 31 days/month; the

short-term PSEL in this permit can be expressed in either

monthly or daily form, and they would actually represent the

same limit. It would be theoretically not possible for

boilers to operate beyond their maximum capacity. In actual

practice, each boiler is normally operated well below its

rated capacity.

The gas usage is the only varying parameter used to

determine compliance with the PSEL, and the monthly natural

gas usage is obtained from the natural gas supplier's

monthly billings. Given the size of the boiler emissions,

and considering the fact that short-term limits reflect the

maximum combined capacity of all. boilers, the monthly (PSEL)

averaging is determined to be most compatible for the

EU2/EU3 boilers operations. The monthly PSELs reflecting

the EU2/EU3 boilers' maximum capacities are summarized in

the emissions detail sheets.

13. The aggregate limits for insignificant activities

es_tzblishedin_this Condition reflect OAR 340 . 28-110 (5);

which sets the aggregate Particulate limit at 1 -

0---ton --peryear and the aggregate HAP limit at 2.5 tons per year,

pursuant to OAR 340-28-1060(2). This condition basically

parrots the rule requirements (OAR 340-28-110(5)) that a

total combined emissions from all "aggregate insignificant

activities" cannot exceed the aggregate limits for each of

the regulated pollutants (Particulates & HAPs) identified:

Description of Current

insignificant activities

Regulated Air

Pollutants

Estimated

Emissions

(tons/yr)

Baghouses PCD3 & PCD4 for

wafer grinding operations Particulates 0.2

Natural gas combustion of EU2

& EU3 boilers Organic HAPs < 0.2

Process scrubbers, Implant

sources, etc. Inorganic HAPs 0.6

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This condition does not intend to limit "aggregate

insignificant activities" to only those currently identified

in the permit application. For same reason the permittee is

free to add more categorical insignificant activities to

their existing list (identified in the permit application).

The permittee can add more insignificant activities to their

existing list, even after the permit is issued, provided

that the aggregate limits established in the permit (or

rules) are not exceeded. The monitoring protocol for the

aggregate insignificant activities requires the permittee to

report semi-annually of the changed status. (if any), at

which time the status change-will undergo further Department

scrutiny.

Aggregate Particulate emissions: The only other criteria .

pollutant, other than VOCs, generated from EUI is

particulate and all particulate emissions from EU1 are

included in the "aggregate insignificant emissions". No

silicon crystals are grown at- the Aloha campus. Intel

purchases thinly sliced wafers (size varies) with one side

having a mirror finished surface (chemically etched &

polished). The only silicon"particulate generating process

performed at the facility is grinding unpolished side of

wafer.

There are two baghouses (PCD3 & PCD4, each with 99.9 9,5

control efficiency), located on the south side of FAB4

building, controlling the silicon particulate emissions.

The particulate emitted to the atmosphere from these

baghouses total about 0.02 tons/yr, and these emissions are

included in the "aggregate insignificant emissions".

EU1 PCD ID Yr installed Flow (acfm) Eff. (%)

FAB4 PCD3 1982 2,900 99.9

FAB4 PCD4 1982 2,900 99.9

Aggregate Organic HAP emissions: Organic HAPs emissions

.from the EU2 and EU3 boilers were estimated using the

emission factors published ii the OAQPS document; EPA-450/2-

90-011; second edition, October 1990.

EF CA = 415 of total VOCs (0.04 x 2.8 lbs/10 6 ft3 ng.)

EF CH20 = 88.12 lbs per 10 12 btu heat input for EU2 bailers

EF CH2O = 997 lbs per 10 12 btu heat input for EU3 boilers

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Combined HAPs emissions due to EU2 and EU3 natural gas

combustion total less than 0.2 tons/yr.

E, Benzene (C^H^) - 0.04 tons/yr

E, Formaldehyde (CHZO) 0.09 tons/yr

Aggregate Inorganic HAP emissions: Inorganic HAPs

emissions are summarized in the Table below. Inorganic HAPs

are emitted to atmosphere through process scrubbers (PCDs),

and emissions from these "high efficiency" PCDs are very

small as noted below:

HAPs DESCRIPTION OF ACTIVITIES ESTIMATE

(tons/yr. ) _1

Arsenic

compounds

Doping, parts cleaning trace

.Chromium

compounds

Backside coating, etch trace

Ethyl benzene Negative litho process trace

Ethylene glycol Various dips, cleans & eq. cooling trace

Phosphine Implant source 0.02

-Phosphorus---. _Implant._ s_ourc.e. t

Hydrofluoric

acid

PCD2.1/2.2, PCD5, PCD6, PCD7, PCD8,

PCD9, PCD11, PCD19/20

0.09

Hydrochloric

acid

PCD2.1/2.2, PCD5, PCD6, PCD7, PCD8,

PCD9, PCD11, PCD16, PCD17, PCD19/20

0.40

Chlorine PCD2.1/2.2, PCD7, PCD8, PCD9,

PCD19/20

0..09

Total 0.6

As noted above, controlled emissions of inorganic compounds

.(mostly acids) from numerous high efficiency scrubbers are

small. Most of inorganic HAPs originate from the acid

baths, and vapors from the acid baths are routed to wet

scrubbers (PCDs) as listed in the following Table. Because

acids have strong affinity for water, the dilute acid bath

would not release significant amount of acids to begin with,

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and when such emission is further controlled by wet

scrubbers, the acid emissions to the atmosphere are

virtually eliminated. This partly explains Intel's ability

to remain a minor source of (inorganic) HAPs. The following

Table lists all existing PCDs for non-VOC HAPs and their key

design parameters

- Inorganic HAPs Emission Control Devices -

Design Parameters

Pollution Control PCD ID Year

Equipment(s) Gas Flow Pre. drop Water Flow Installed (acfm) (in. water) (gpm)

Wet Scrubber/ PCD2.1 200 0.25 2.5 1993

Thermal scfm

decomposition units pCD2.2 each 0.25 2.5 1993

(Delatech 857)

Horizontal Wet PCDS 19,050 2.5 120 1974

Scrubbers

PCD6 19,050 2.5 120 1974 (FAB4 SCO #1 - #5)

PCD7 19,050 2.5 120 1974

PCD8 20,OQ0 2.5 120 1988

PCD9 5,OQa 2.5 50 1988

Vertical Acid PCDIO 19,OQ0 < 3 20 1974

Scrubbers

PCD11 " C 3 20 1974 (FAB5 SCO #1 - #4)

PCD12 3 20 1974

PCD13 " < 3 20 1974

HPH Horiz. Scrubber PCD14 34,000 Q.5 30 1993

(FAB5 SCO #5)

PCD15 2 500 1992

D1 Horizontal Wet 60,000

Scrubbers PCD16 scfm 2 586 1993

PCD17 each 2 586 1993

PCD18 2 500 1992

PCD19/

20 X0,000 1.25 100 1992

PCD21 85,00Q 2:6 341 1994

PCD22 85,000 2.6 341 1994

PCD23 29,000 , 2.6 356 1994

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SOURCE-SPECIFIC CONDITIONS

This "Source-specific Conditions" section of this permit is

reserved for special conditions/requirements applicable to the

permittee that are reflective of. the source uniqueness. This

section is further divided into three subsections:

Condition No. Subsection

14. - 15. Source-specific RACT Conditions

16. - 18. Pollution Prevention and Pre-approved changes

1.9. (Synthetic Minor) HAP Emission•Limits

14. REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT)

Applicability: Pursuant to Oregon Administrative Rules

(OAR) 340-22-104 (5), this permit proposes a source-specific

Reasonably Available Control Technology (RACT) standard for

affected operations. at the Intel Aloha campus. The proposed

source-specific RACT standards need not be approved by the

Oregon Environmental Quality Commission (EQC) prior to EPA

approval since this source-specific requirement itself is

inherently apart of the State Implementation Plan -(SIP) VOC

rules.

Procedure: The RACT portion of this permit issuance

-fold.owed_the__procedur-al_._requiremnts__of_ 4.0_CFR_Part_ 51 . 10. 2 L___

which included posting of public notice in the newspaper on

June 8, 1995, followed by conducting a public hearing on

July 13, 1995. In addition, the RACT portion of this permit

was posted on the secretary of state notice to conform with

the (state) source-specific SIP revision, process. The

public notice/hearing process has been completed, and

therefore the proposed RACT standards are being submitted to

EPA (Region X Office) for their review and approval. The

proposed RACT standards in this permit are not final; and

they are subject to change pending EPA action. Once EPA

approves the proposed RACT standards, the permittee has one

year from the date of EPA approval to comply with the

applicable RACT requirements..

General background information: The Oregon SIP VOC Rules

(Division 22) include several categorical RACT standards

applicable to specific categorical sources residing inside

the designated nonattainment area. Division-22 also

includes a provision which requires other non-categorical

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"affected sources * " to comply with the case by, case (source

specific) RACT standard(s) established by the Department.

Intel is the only affected semiconductor manufacturer

currently operating in Oregon that became subject to a

source-specific RACT determination.

Most RACT determinations are based on EPA Control Technology

Guidelines (CTG), but there is no CTG developed for

semiconductor industry. However, similar source-specific

RACT determinations have been made by the other regulatory

agencies (outside Oregon), and this permit. uses some of

their assessments (for comparative purpose only) as a

guideline to assess source-specific RACT standard for

certain Intel operations. Subsequently, the engineering/

technical evaluation coupled with the cost analysis dictated

the RACT standards in this permit.

` "Affected sources" are those stationary sources operating

inside nonattainment areas for which no categorical RACT

requirements exist and which have the potential emissions

before add-on controls over 100 tons of VOC per year.

The Portland.. area attainment status: The Portland ... area is

currently designated as a marginal nonattainment area for

ozone. However, one of the criteria for reaching the

attainment status is to not exceed the national ambient air

quality standard for ozone (0.125 ppm) more than once per

year on average over a three year period. For past three

years, Portland has been in compliance with the EPA

standard:

Year (Date)

1991 (7/02)

1992 (8/17)

1993

The Department has also met the EPA deadline (November '93)

for the submittal of a plan to maintain compliance with the

ambient ozone standard. The (draft) plan does not amend the

existing RACT regulations.

The latest Department's emission inventory taken during the

1990 Ozone season indicates the industrial emissions

accounted for about 6 percent of total Portland area VOC

emissions. The VOC emissions in the following years follow

the same trend and the percentage would be very similar:

# Exceedances Conc. (ppm)

1 0.129

1 0.126

0 < 0.125

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VOC Emissions

Source Type lbs/day percent (%)

Stationary Point Sources 35,913 6

Stationary Area Sources 158,311 26

Biogenic Sources 91,462 15

Non-Road Mobile Sources 87,07,9 14

On -Road Mobile Sources 239,338 3.9

Total within Portland AQMA 612,103

No emission increase is proposed with the RACT assessment.

In fact the proposed RACT standard will (legally) prevent

Intel from increasing the level of pollutant emitted per

unit (wafer) production. This performance specific RACT

standard combined with the emission cap (PSEL) established

in this permit represent one of the most effective

environmental protective measure available, which can only

help maintain the Portland attainment status.

RACT assessment (screening) overview'

Semiconductor manufacturing processes performed at the Aloha

campus were initially divided into four (4) distinct

categories of operations; out of which only two(rl types of

operations are determined to be suitable candidates for

specific RACT assessment in this permit:

• VOC storage, handling, and distribution

• VOC waste collection and disposal

• - Solvent--cleaning--sta-{Ions

Photoresist operations

• VOC storage and handling: Drums (< 55 gal.) and smaller

carboys'are used to deliver organic chemicals to the process

area through a closed fill (hard piped) system, during which

displaced vapors (VOCs) are fed back to the waste bulk

(under-ground) storage tanks. Solvents in drums are pumped.

through hard piping to a process unit where it is

quantitatively dispensed directly to the process equipment.

e VOC Waste collection/disposal: Any excess and/or spent

materials from the process equipment are immediately

captured and drained (piped) to the waste storage tank.

The over-all controls provided in these first two categories

of Intel specific operations exceed RACT; A similar solvent

distribution/collection system (>95% efficiency) was

determined to be BACT by the California Air Resource Board

(CARE). This high degree of collection efficiency provided

by the enclosed solvent distribution/collection system is

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one of the contributing factors that over 90%- of all plant

site VOC emissions come from the photoresist processes, and

most of the remaining (100) portion of VOC emissions is

generated from the solvent cleaning stations. By design,

VOC emissions from these tightly controlled solvent

distribution/collection operations are insignificant. This

is one of the deciding factors not to establish a separate

individual RACT standard for these solvent distribution/

collection operations: The level of control provided

already exceeds what the RACT would require, and a further

technical/economical review would become an academic

exercises at best. Furthermore, these operations are

actually a (supportive) part of the (main) photoresist

activities, and it is more appropriate to regulate these

operations under the photoresist RACT standard.

It must be noted that omission (on paper) of these

solvent/waste distribution/collection operations from the

individual RACT assessment does not mean these operations

are beixig.exempted •from the RACT review. Instead the RACT

standard set forth in this. permit for the (main) photoresist

operation extends to the solvent distribution/collection

operations, because :tY are essentially an auxiliary part

of the main photoresist operations. Of related topic, the

photoresist RACT standard would also_applyto . VOC emissions

from the solvent'cleaningstations, even though a separate

RACT work-performance standard (FBR) is established for the

solvent cleaning stations.

The RACT review in this permit focuses on the latter two (®)

categories of operations where the environment impact would

be the greatest. In addition to the (main) photoresist RACT

standard, the permittee is required to provide an additional

(FBR) performance measure at the solvent cleaning stations.

In summary, the solvent distribution/collection activities

support the photoresist. operations, and these activities are

actually considered a part of the photoresist operations and

it will be regulated as such. Instead of a separate RACT

standard for these auxiliary activities, a universal RACT

standard, applicable to all phase of semiconductor

manufacturing, better serves the Department/permittee from

the enforcement/practical stand point. The FBR control

required at the solvent cleaning stations serves as an

additional layer of environment protection.

► RACT Standard for Solvent Cleaning Stations

Solvent cleaning operations at Intel are executed on a small

scale with open area (top dimension) ranging from 2 to 4

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ft2. Size-wise, Intel's solvent cleaning. /degreasing

stations don't. even come close to industrial size cold

cleaners, open-top vapor degreasers, or conveyorized

degreasers. However, the solvent cleaning operations,

regardless of their size, are functionally similar. They

all use solvents in either vapor or liquid phase to remove

impurities from the product surface. The operational goal

of any cleaner or degreaser is common, and this is the

rationale for applying the CTG developed for "conventional

organic solvent cleaners/degreasers to Intel's "small scale"

solvent cleaning operations.

Recommended CTG standards in general consist of proper

operating procedures, and/or additional control devices.

The CTG document (EPA--450/3-78-120) recommends conveyorized

degreasers smaller than 21.5 ft2 of air/vapor interface; and

open-top vapor degreasers smaller than 10.8 ft2 of open area

be exempted from having to add a major control device such

as refrigeration/condenser. Pursuant to the guidelines set

forth iri"the referenced CTG, the RACT assessment in this

permit is therefore based on proper operational procedures.

The most common and effective operational procedures applied

to the cleaning/degreasing operations include controlled

Freeboard Ratio (FBR) and covers. FBR is defined as the

freeboard height (depth) divided by the width (not length)

of the air/solvent interface area. Higher FBR reduces

diffusional (VOC) losses by lessening the effect of

(ambient) air current on the air/solvent interface zone.

Covers obviously discourage natural draft and reduce solvent

-evaporative- -losses-.----

Approximately 90% control efficiency can be achieved with a

0.7 FBR and covers for the sinks. The test results compiled

in "Air Pollution Engineering Manual (1992, p. 352-357)

further supports the effectiveness of the FBR control.

Table 1 (Attachment A9) lists various control equipments for

cleaners and their control efficiencies taken from the CARE

report. Intel also furnished historical source test data

(Attachments A10 through Ala) to characterize VOC

evaporative losses from their operational area during parts

cleaning operations.

In establishing the RACT'standards for Intel's solvent

cleaning stations, a further observation (of source

uniqueness) is necessary. There are a few solvent cleaning

stations at Intel that are not conventional in a sense that

these stations resemble a typical laboratory (or kitchen)

sink: It consists of a sink and"over-head hood with built95
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in fan, a solvent faucet, and a typical drain system.. The

parts are cleaned in running solvents (from the faucet) and

the waste solvents are immediately drained (piped to the

waste storage vault). If there is no solvent left standing

in the sink, the FBR/cover control requirements simply do

not apply. Therefore the FBR control is applicable only

when parts are cleaned by immersion. The following RACT

performance standards (permit language) are appropriated for

Intel's solvent cleaning operations:

The freeboard ratio must be equal to or greater than

0.7 if parts are cleaned by immersion.

▪ A cover must be provided during idle periods if the

sink contains any free standing solvents.

n The cleaners are exempt from these RACT requirements if.

they use non-VOC solvents as defined in OAR 340-22-100.

• RACT Standard for Photoresist Operations

Reiterating, the photoresist operation is the single largest

source of VOC emissions' at,the Aloha campus, generating

approximately-90 percent of total.-,plant; . site ' VOC emissions.

Traditionally the photoresist processes are categorized into

two sub-categories termed "positive" and "negative" {terms

used. throughout this review report). Both the positive and

negative photoresist processes use solvents in their spin

coater operations, but only the negative photoresist process

uses solvents in the development stage. Historical data

confirms the negative process emits a.significantly greater

amount of VOCs then the positive process.

The (California) . Bay Area Air Quality Management District

(BAAQMD) has designated the positive process as RACT.

Because, in terms of VOC emissions, the positive process

translates to the equivalent of 90%. abatement for the

negative process. In other words, the RACT control for the

negative process is either providing the 90% equivalent

emission control or a conversion of the negative to the

positive system.

The existing photoresist machines at the Aloha campus are

all based on the positive technology, except for one

negative unit. VOC emissions from the negative process are

approximately 11 tons/yr (tpy), and the cost of controlling

this emissions to the level of the positive technology (1.1

tpy) was shown to be beyond the cost acceptable for a RACT

cost increment. The control cost of thermal destruction was

also estimated to run well over $10,000/ton/yr.

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Following the BAAQMD's RACT determination, the alternative

(to thermal control) is the conversion. However, a straight

conversion from negative to positive was also determined to

be not cost effective for Intel. The cost of conversion

would run into well over $10,000/ton/yr (based on a direct

quote from the equipment vendor). The Department generally

acknowledges the control cost greater than $10,000/ton/yr to

be excessive for RACT. From the cost stand point, the

permittee (Intel) is exempt from having to provide the RACT

level (equivalent to., their positive process) control to

their negative system. And since the positive system itself

is considered equivalent to RACT, the source-specific RACT

.assessment for the photoresist operations could prematurely

end at this point. The permit RACT review for Intel went a

step beyond the straight conversion, and the other control

alternatives are explored on a plant wide basis:

First of all, recognize the positive photoresist process

units significantly outnumber "one and only" negative unit

at the Aloha campus. This opens up the possibility of overcontrolling (tweaking, P2, etc.) each and every positive C

units (already considered RACT equivalent) to a degree such

that it. would not be considered cost excessive. Overcontrolling "many" positive units even to a small degree;

beyond what'the-RACT would require, to the extent that is

equal to or greater than the under-controlled level from

"one and only" negative unit; could easily yield the net

result being equal to or greater than the RACT equivalent

control across the entire plant. For instance, providing

numeric value , to a given example, over-controlling VOC

emissions from each and every 100 positive units by 0.1 tons _nee_ n

(total 10 tons) would more than offset the total-Under

..............

controlled amount of 5 tons from one (1) negative unit by 2

to 1

This is accomplished by, in lieu of having separate

standards for the positive and the negative, establishing a

common universal. standard for both the positive and negative

system. This universal RACT standard, which is based on the

(cleaner) positive technology, is also applicable to the

negative process performed at the Aloha campus.

Theoretically, the permittee can only comply with this

universal RACT standard by providing over-control at the

positive units. This basically illustrates the Bubble (OAR

340-28-1030) concept.

In addition to the Bubble concept, the universal RACT

standard serves another purpose. Consider the dynamic

nature of the semiconductor industry. Unlike traditional

smoke stack industries, the semiconductor technology, and

the manufacturing process which it is based on, rapidly

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changes with respect to time. The manufacturing processes

may no longer be based on so-called the positive/negative

photoresist technology. From the enforcement perspective,

it is highly desirable to have a definite regulatory control

over Intel's future operations, as well as their existing

operations.

The universal RACT standard proposed in this permit is

applicable to all existing positive and negative systems, as

well as all future wafer manufacturing processes, regardless

of the technology a new system may rely on. The proposed

RACT standard will encourage Intel to promote the pollution

prevention, such as incorporation of necessary process

equipment design/changes and chemical substitution, during

the research and development stage. Furthermore, this

universal RACT standard eliminates the need to separately

monitor the chemical usage (emissions) of. the positive from

the negative. This greatly simplifies the chemical mass

balance (enforcement tool) needed to determine permittee's

compliance status with respect to the proposed RACT

standard.

Intel's historical ., emissioa and production data were

evaluated and the appropriate time period that accurately

represents Intel specific positive photoresist technology

was identified. The year selected is 1985 because it was

the year the positive process at the Aloha campus

incorporated the (source-specific) EBR and cuprinse steps.

These unique EBR/cuprinse designs significantly reduced the

VOCs emissions from the traditional (those without EBR/cuprinse) positive photoresist process. The positive process

units at the Aloha campus continue to utilize these sourcespecific EBR/cuprinse technologies.

VOC emissions Production

59.97 tons 181,300 normalized

8" (inch) wafers .

Chemical and production specific information are available

at the plant site for Department/EPA inspections. Based on

the above emission data from the Intel' specific positive

system with the EBR/cuprinse design, the - universal source -

specific RACT standard applicable to Intel's entire spectrum

of wafer manufacturing processes is:

2 X 10" lbs VOC per cm2 Wafer Processed

The permittee must achieve real reductions in actual

VOC emissions consistent with the proposed RACT level

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(2X104 lbs VOC/cm2 ) of control. The proposed RACT

standard, directly tied to actual production rate,.

provides an assurance that source cannot utilize nonproduction or equipment downtime credits in their

emission calculations to show compliance with the VOC

PSEL. A proposed RACT is essentially a performance

standard independent of PSEIJ and it directly limits the

amount (lbs) of VOC emitted per specific amount (cm2 )

of wafer production.

® The proposed RACT standard applicable to the current

technology employed by Intel extends to all future

technologies contemplated and adopted by Intel and

utilized at the Aloha campus,

RACT Averaging_Time

The short term PSEL proposed in this permit is weekly and it

was determined to be most compatible with the source

operations, pursuant to OAR 340 . -28-1020(2) . . The RACT

averaging period needs to be consistent with the VOC PSEL

short-term.. monitoring period and is therefore based on

weekly also.

The RACT compliance determination is essentially based on

the wafer start (processed; not the final number of finished

product) and CMB. The ratio of the amount (lbs) of VOC

emitted in a week period is taken against the amount (cm2 )

of wafer start in that same week period. The result is

measured..- against the___pemitted RACT standard to determine

the permittee's compliance status.

The wafer production lines continuously operate . for about 5

to 7 days. Raw chemicals/solvents used in wafer production

have uniform VOC content (%), and the production. rate (and

thus VOC emission rate) remains consistent throughout a

given weekly production cycle. This means weekly emission

is essentially the sum of daily (hourly) emissions, if such

(hourly/daily) measurement is viable. A weekly period is

determined to be the shortest practical period most

compatible with the source operations, and thus the

averaging period selected in this permit.

Summary:_ The RACT standard established in'this permit.

(*l4.a.) for the photoresist operations is actually the

universal (plant-wide) standard applicable to the entire

spectrum of semi-conductor manufacturing performed at the

Intel Aloha campus. The Free Board Ratio (FBR) established

in this permit (##14.b.) is applicable only to the solvent

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cleaning stations, and it essentially serves as a built-in

performance standard that further encourages (additional

layer of) emission control from the permittee. Condition

14.c. is to be used as a vehicle to trigger the RACT

standards proposed in Conditions 14.a. and 14.b. once the

Department receives an approval from EPA.

15. Condition 15. provides conditional compliance schedule, a

mechanism necessary to establish alternative RACT controls

acceptable to (or recommended by) EPA, to be used in the

event the proposed standards are disapproved. Note that

this conditional compliance schedule is triggered only if

the proposed standards in 14. are disapproved by EPA.

POLLUTION PREVENTION AND PRE-APPROVED CHANGES

Permit conditions 16. through 18. represent an attempt to

incorporate pollution prevention conditions in the Title-V

operating permit and provide the permittee o.perating flexibility

to meet pollution prevention goals and objectives by preapproving a narrowly defined set of changes. The Department

views this as a trial project and an opportunity for-the

Department to gain a wealth of information on the viability and

effectiveness of including pollution prevention requirements in a

Title-V operating permit.

16. Pollution Prevention

The pollution prevention condition requires the permittee to

develop and implement a pollution prevention program and

submit reports on implementation of the program.

16.a. Implementation of the program, as established in

item 16.a., is fairly short and designed to implement the

pollution prevention quickly upon issuance of this permit.

16.b. The program consists of at minimum the following

program elements:

16.b.i. A description. of the process the permittee

will use to introduce pollution prevention into their

decision-making procedures;

16.b.ii. a partnership/agreement the permittee will

establish with its material suppliers to minimize

hazardous air pollutants and volatile organic compounds

from the raw materials and products;

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16.b.iii. a partnership/agreement the permittee will

establish with its equipment vendors to minimize

hazardous air pollutants and volatile organic compounds

using pollution prevention in equipment design;

16.b.iv. development of a data collection system

appropriate for evaluating pollution prevention

effectiveness;

16.b.v. development of an employee training program

to promote pollution prevention at the permitted

facility; and

16.b.vi. a statement of commitment to pollution

prevention at the permitted facility.

16.c. Item c.. is a provision for changing elements in

the pollution prevention program, differentiating between

minor changes that can be made immediately and reported in

the annual report and major changes which require 30 day

notification prior to change and a demonstration of need for

the change. A' major change is.eliminating a program

element, such as the employee training program. .

Modification of a program element, such as a change to the

training program, is considered a minor modification.

16.d. The permittee is required to develop a detailed

annual report that outlines progress made during the

preceding calendar , year. As this detailed report will

contain market-sensitive information, it will be kept at the

s-te....and _made availab.l.e__..to.._Dep_artment epr_e..s_entatires_...f'ar

inspection at the facility. The permittee shall also submit

an executive summary of the detailed annual report. The

annual report during the last year of this permit shall

contain a summary of the project and a self-evaluation of

the effectiveness of the program.

17. Pre-approved Changes,

Through pre-approval of a narrowly defined set of changes,

Intel and Oregon DEQ will expedite the administrative

procedural requirements of minor new source review (OAR 340-

28-2270). These pre-approvals do not involve increase in

emissions or major modifications, and definitely do not

represent an exemption to any applicable requirement. These

conditions are drafted to be fully protective of environment

and.to promote pollution prevention.

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17.a. Item a. states the approved changes only extends

to VOC emitting activities at stationary sources EU1.1 and

EU1.2. The only other remaining stationary source (EU1.3)

at EUl consists of two office buildings which are listed in

the permit for identification purpose only.

17.b. Item b. strictly prohibits the permittee from

adding a new stationary source.

17.c. Item c. states all new or modified activities must

continue to comply with the VOC PSEL. This condition also

binds the permittee to do the pollution prevention as

specified Condition 16.

17.d. Item d. prohibits addition of a new Pollution

Control Device, and it also prohibits the permittee from

making changes to existing VOC control devices (PCDI & -

PCD26) such that the performance (control efficiency) would

be degraded.

17.e. Item e. states all new or modified activities must

continue to comply with the source=specific RACT standard.

17.f Item f. states the permittee. cannot deviate from

the existing compliance monitoring requirements established

for the VOC PSEL and RACT Conditions.

17.g. On top of all the restrictive criteria specified

in items a. through f., item g. is established to further

insures that no new applicable requirement is triggered.

17.h. Item h. directs the permittee to the appropriate

monitoring and reporting that they must abide by.

18. This condition is a sunset provision which conveys that the

pollution prevention (16.) and pre-approval (17.) conditions will

expire at the expiration date of this permit unless there is a

mutual agreement between the permittee and the Department to

continue.

19. AGGREGATE HAP EMISSION LIMIT

The aggregate combined Hazardous Air Pollutants (HAPs) limit

of 10 tons/yr for each organic and inorganic HAPs set forth

in this section comprises a cap on the permittee's total

HAPs emissions. It limits the permittee's potential to emit

and categorizes the permittee as a minor HAP source. As

long as the permittee operates within the HAP limits set

forth in this section, the permittee retains the minor HAP

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source status and the provisions set forth in OAR 340-32-300

through 340-32-4500 remain not applicable.

The minor HAP source status was initially determined from

the permit application (specific chemical usage is

confidential and all records are kept at the plant site and

are made available to the Department/EPA representative). A

review indicates the HAP minor source status was determined

(conservatively) by using the HAP usacae data and not the

emission data for certain chemicals. Toxic substance usage

data are provided in Attachment 14 (A14).

The emission cap set forth in this section is actually more

stringent than what the applicable rule requires: OAR 340--

32-120 defines a major source as one that has the potential

to emit, considering control, in the aggregate, 10 tons/yr:

or more of any individual HAP or 25 tons/yr or more of any

combination of HAPs. The 10 tons/yr emission cap in this

permit applies to emissions of a total combined organic

-HAPs, and similarly a separate 10 tons/yr emission cap

applies to inorganic HAPs emissions.

The.., individual organic. or inorganic, HAP emission can never

exceed 10 tons/yr since the combined emissions of either

organic or inorganic HAPs must remain below the 10 tons/yr

cap. Therefore the permit compliance demonstration

requirements do not require monitoring of individual HAPs.

(This is an excellent trade-off, more stringent limit for

easy of monitoring) Only the aggregate amount is needed to

determine the permittee's compliance status with respect to

the _.1.0. __tons./yr ._aggregate limits _ set _forth zn phis pertni t

MONITORING REQUIREMENTS

Monitoring requirements provided in this section are the primary

tools used by the. permittee and the Department to assess the

permittee's compliance status. Monitoring requirements in this

section are divided into six (6) parts: Condition 20. specifies

the monitoring related to the facility-wide applicable

requirements. Condition 21. specifies the monitoring related to

those applicable requirements targeted at specific emission

unit(s). Condition 22. deals with the monitoring associated with

the limits applicable to "insignificant" activities. Condition

23. outlines the compliance determination for the (EU2 & ELT3)

boiler PSELs. Condition 24. is reserved for the monitoring

associated with the VOCs and HAPs PSELs and the source-specific

RACT requirements. And lastly Condition 25. identifies

monitoring related to the pre-approval condition.

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20 "Facility-wide" Monitoring

Before individual monitoring protocol associated with the

applicable standard(s) in this section is judged solely by

its content, a thorough. understanding of what is actually

being regulated is necessary, as this influences the level

of monitoring related to such activities. Intel is a major

source of VOCs emissions. Emissions of other criteria

pollutants are generated from natural gas burning boilers.

Intel is an insignificant source of particulate/visible

emissions. Besides natural gas combustion, the only

potential particulate generating processes performed at the

Aloha campus is the wafer grinding operations. As discussed

extensively (considering the subject of discussion was

"insignificant") in item 13. of this review report, the

wafer grinding operations are controlled by PCD3 and PCD4

baghouses, and the emissions from these baghouses total

about 0.02 tons/yr.

20.a. " This Condition establishes the monitoring

prOtocols'necessary to determine compliance with respect to

the process fugitive dust control requirements set forth in

Condition 5.a and the odor/nuisance control requirements set

forth in Condition 5.b. Solid materials (mostly. wafers)

that Intel use in their processes have minimal chance of

becoming air borne. The source also has an' excellent

compliance history (no permit violation nor public

complaints to this date).

Monitoring requirements consist of complaint investigations

as they occur and the subsequent reporting in the semiannual report. For example, the Department may request

Intel to investigate upon receiving complaints from the

public; or Intel may initiate the investigation themselves

upon receiving complaints related to referenced permit

conditions. The permittee is also subject to the Department

and/or EPA inspection, which is another vehicle used to

determine the permittee's compliance status with respect to

the permit nuisance conditions.

20.b. Reiterating, Intel is an insignificant source of

particulate emissions; the only notable particulate

emissions come from PCD3 and PCD4 and these baghouses are

incapable of emitting particulate matters. larger than 250

micron. In addition, natural gas burning boilers are the

only potential source of SO2 emissions. Natural gas burning

boilers are simply not capable of emitting SO2 at a level

greater than 1000 ppm. Reflecting such, the permit

monitoring basically consists of self-evaluation every six

months to ensure that no such equipment have been added.

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20.c. This Condition requires the permittee to keep a

summary of actions taken during an air emergency episode

declared in the Portland area by the Department for ozone.

20.d. This Condition references the monitoring

associated with the Labeling of Products Using Ozonedepleting chemicals.

21. "Emission Unit S•ecific" Monitorin

21.a. The 0.1 gr/scf grain loading and the 20% opacity

standards are federally and state enforceable conditions

that apply to all fuel burning equipments. These standards

therefore apply to all EU2 and EU3 natural gas burning

boilers.

Again, the nature and characteristics of an affected

emission source must be considered and then reviewed with

respect-to the intent and (occasionally) history of

applicable standards in order to develop a.meaningful

monitoring requirement. The grain loading and opacity

standards cited above were developed in the early seventies

in order - to regulate the boilers fueled by wood wastes,

coal, and heavy residual oils, that are generally operated

without any control.

Natural gas is one of the cleanest fuels available, and

visible/particulate emissions from natural gas combustion

are insignificant when compared to combustion of oil, coal,

or wood wastes. Visible emissions, other then heat wave (or

condensed water) during cold weather, from natural gas

. combustion are virtually non-detectable to the human eye.

It is safe and reasonable to conclude (assume) that the 20%

opacity standard would not be exceeded during natural gas

combustion.

Grain loading from natural gas combustion would generate

particulates (all considered to be PM:o) at a level below the

grain loading standard of 0.1 gr/scf, corrected to 12% C02

(stoichiometric feed of air). EPA AP42 , indicates 12 lbs of

particulate is generated from million (10 6 ) ft3 of natural.

gas combustion. In reference to 40 CFR, Part 60, AppendixA, Method 19; a million ft3 of natural gas combustion based

on stoichiometric feed of air would yield 9.15 x 106 ft 3 , of

dry flue gases: ,

106 ft3 x {1050 btu/ft3 ) x Fd = 9.15 x 106 dscf

where Fd = 8,710 dscf/10 6 btu

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Twelve pounds (12 lbs) of particulates in 9.15 x 106 dscf of

flue gases are equivalent to grain loading of about 0.01

gr/scf.

12 lbs x 7000grab 0.009 . gr/scf 0.1 gr/scf.

9.15 x 106 dscf

Even a conservative EPA AP42 figure of 12 lbs/10 6 ft3

indicates the average grain loading from natural gas

combustion is less than 10% of the rule, standard of 0.1

gr/scf.

In conclusion, as long as the permittee uses natural gas

only, the 20% opacity and 0.1 g/scf grain loading standards

. would be met. The compliance demonstration requirements

include necessary monitoring and reporting of type(s) of

fuel used and its consumption rate(s). In the event the

permittee elect to use fuels other then natural gas (oil for

instance), the permit must be opened to incorporate

necessary applicable requirements, such as OAR 340-22-010 to

340-22-0250, and to modify compliance demonstration

requirements, pursuant to item 21.a.iii.

21.b. Periodic monitoring requirements established in

this condition adequately demonstrate the compliance status

with respect to the O&M requirements set forth for PCD1.

The water pressure drop across the scrubber packing is

directly influenced by the water flow rate, and therefore

the pressure drop in place of actual water flow rate is an _

acceptable substitute monitoring parameter. The water flow

rate can also be obtained from the pump curve. The key

parameter to monitor and record, per this' condition, is the

changed status of the water flow rates. However, it is

expected that once the optimum water flow is determined

through a source test, the water flow rate would be kept

constant ' at or above the optimum level.

22. "Insignificant Activities" Monitorinq

22.a. The grain loading standard of 0.1 gr/scf (11,a.)

and the 20% opacity limit (Condition ll.b) apply to non-fuel

burning sources. However, as discussed earlier (see Review

#20) the measurable particulate emissions from the Aloha

campus . total about 0.02 tons annually. The fact that semiconductor manufacturing must be performed inside the clean

room environment, a significant amount of capital is spent

just to clean the ambient air routed to the process area, is

an indication that such operation does not even come close

to the particulate/visible emission standards set forth in

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this permit. Furthermore, the most, if not all, solvents

(VOCs) emitted from the Aloha campus are believed to be

colorless, which leads to believe the visible (opacity}

emissions would not be a major concern.

Periodic monitoring requirements consist of a visible

emission survey once every six month to conform with the.

semi-annual compliance certification protocol. In addition

the source is subject to the Department/EPA inspections,

which further ensures the permittee's compliance performance

toward the 0.1 gr/scf and 200 opacity standards would be

measured and potentially changed if deemed necessary.

22.b. A written certification can be in the form of.

Material and Safety Data Sheet (MSDS).

22.c. A periodic monitoring requirement for the facility

wide limits for insignificant activitie's consists of an

inspection every six month to confirm that no significant

change(d) has been made such that the aggregate limits would

be exceeded. The permittee is also required to quantify the

emissions from insignificant activities once per permit

period, preferably at the time of permit renewal.

' 23. "EU2/EU3 Boilers PSEL" Monitoring

The boiler emissions are calculated based on natural gas

usage and the appropriate emission factors. The EU3 boilers

are equipped with LowNOX control, and comparatively EU3

boilers' NOx emissions are much less than EU2 boilers. See

emission detail sheets; attachments Al through A6.

23.a. The annual emission is determined by multiplying

annual fuel usage to appropriate EF listed in the Table.

All EFs are the AP42 data, except EU3 boiler's NO, and CO

EPs which are based on manufacturer data, verified by source

test.

23.b. The monthly emission is determined by multiplying

monthly fuel usage to. appropriate EF listed in the Table.

The EU2/EU3 boilers' monthly PSELs are based on the sum of

each boiler's maximum capacity, and theoretically this

maximum capacity can never be exceeded. As long as no

physical modification is made to the boilers, the capacity

remains the same. In actual practice, all boilers are

operated well below their maximum capacity.

23.c. The permittee obtains the natural gas usage from

the natural gas supplier's monthly billing. The billing

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documents the actual natural gas usage between two dates

approximately a month apart. For example, Intel receives an

invoice on 4/15 for actual usage from 3/3 to 4/5. From this

data, the permittee can approximate the amount of natural

gas used from the beginning (1st) to the end of the month.

For the sole purpose of assessing compliance with respect to

the combustion PSELs established in Condition 12.b., this is

an acceptable method for calculating the monthly emissions

from the EU2/EU3 boilers.

23.d. Pursuant to 40 CFR (§), Subpart Dc, "Standards of

Performance for Small Industrial-Commercial-Institutional

Steam Generating Units", this condition establishes the

daily monitoring (per § 60.48.c (g)) of natural gas usage on

EU3 boilers. The sole purpose of the daily monitoring of

the EU3 natural gas usage is to meet the NSPS (§ 60.48.c

(g)) monitoring requirement.

The permit minimum recordkeeping requirement of 5 years, as

specified in Condition 29., more than satisfies the NSPS

(per § 60.48 . .c (i)) recordkeeping requirement of 2 years.

This is the reason the less stringent 2-year NSPS

recordkeeping requirement is omitted.

24. Monitoring related to "source specific" Applicable

Requirements

This condition determines the permittee's compliance status

with respect to the VOC PSEL and RACT conditions, and the

aggregate HAP limits. They are combined here because

certain parameters monitored are shared by the VOC and

(organic) HAP PSELs and RACT conditions. The monitoring

requirements in this section are specifically written to

accommodate the source-specific types of conditions and to

reflect source's unique parametric monitoring needs.

Items a., b., and c. determine the annual VOC emissions

through chemical mass balance. However, the nature and

complexity of Intel's manufacturing processes interfere with the direct monitoring of VOC emissions in a short-term

(weekly) basis. The weekly VOC emission monitoring is best

accomplished by a combination of direct and indirect

measurements.

This permit utilizes the bi-monthly VOC emission factor (EF)

calculated based on the actual solvent usage and the actual

production. figures from the previous two month. The bimonthly EF will be updated every two month to reflect the

most recent process changes. This is needed to compensate

for the on-going process changes. Weekly emission is then

108
Review Report: 34-2681 (

Application No.: 14659

Page 37 of 42 Pages

estimated-by multiplying EF to weekly production output.

The proposed VOC weekly emission monitoring, although

indirectly measured,. is proven to produce consistent and

accurate emission data. As shown in Figure-1 (attachment

. A8), the EF dependent monitoring closely reflect the actual

emissions. Furthermore, the actual emission. monitoring is

not omitted in this permit, but rather it is delayed for a

short period (two month') of time.

The VOC monitoring also contains a built-in quality

assurance measure. The accuracy of each EF is verified at

the end of each monitoring. period (2 months) by comparing

the EF dependent emissions (2 month sum of item g.) to the

actual emissions obtained from the actual bi-monthly solvent

monitoring as specified in items a, b, and c.

Item d. establishes the monitoring requirements necessary to

verify the permittee's (synthetic) minor HAP source status.

Item d. requires a separation of organic HAPs from the

inorganic HAPs. Emissions organic HAPs are estimated

through chemical mass balance, the same method used to

determine VOC emissions. Estimating emissions of inorganic

HAPs is a different matter, however, and there are several

factors to consider.

As documented in item 13 of this review report, inorganic

HAP emissions are well controlled, and the current inorganic

HAPs emissions total less than one fourth (2.5 tons/yr) the

permitted level of 10 tons/yr. Of related topic, emissions

from the aggregate insignificant activities must be included

in the HAP emissions calculations, but the permittee needs

to quantify emissions from aggregate insignificant

activities only once per permit period, as specified in the

permit condition 22.b.i.

No simple calculation or emission factor are available for

inorganic HAP emissions. The emissions of inorganic HAPs

are best estimated through the usage data and the efficiency

of control device. The monthly inorganic HAP emissions can

be extrapolated from the 1994 (application) emissions/usage

data, provided the' . type(s) and quantity of inorganic HAPs

are not significantly changed from the current (1994

application) level, and the existing inorganic HAP control

equipment are not altered (which are verified per permit

condition 22.c.ii.).

As an insurance, when the inorganic HAP usage starts to

depart significantly from the current level, and the total

annual inorganic HAP emissions (verified monthly) start to

exceed the level beyond three fourth (3/4) the permit 10 ton

limit, the Department may request the permittee to perform

109
Review Report: 34-2681

Application No.: 14659

Page 38 of 42 Pages

emission testing at PCDs/activities causing the significant

increase to confirm actual emissions.

As stated before, the 10 tons/yr annual cap set forth in

this permit is based on a monthly rolling average,

continuously averaged over previous 12 month period. This

means the permittee must be able to demonstrate each month

that their aggregate annual RAPS emissions during the

previous 12 month period was below the 10 tons/yr cap.

Items e. through h. depend an empirical equation (bi-monthly

EF) formulated from a combination of (weekly) production

monitoring and chemical mass balance to determine compliance

status with respect to the RACT standard of 2X10 lbs

VOC/cm2 and the weekly PSEL of 8 tons. Item i. specifies

the monitoring related to the RACT FBR, and item j.

indicates the trigger date for the RACT monitoring.

The last item (k.) of Condition 24. establishes source

testing' requirements for PCD1. Unlike PCD26, source testing

is required on PCD1 to determine its control efficiency. No

source testing is required on PCD2.6 (as discussed in #4.)

because the amount of solvent recovered is already measured

(as waste) to complete the mass balance.

25 Monitoring related to : Pre-approval

This condition requires the permittee to verify whether new

VOC emitting activities and/or changes made to the existing

VOC emitting activities at the stationary sources EU1.1

and/or EU1.2 comply with the criteria set forth in Condition

17. Verification with respect to the criteria set forth in

Conditions 17.a., 17.b., and 17.d. through 17.g. must be

done on a six-month basis, and these should be straight

forward. The permittee needs to include in the semi-annual

report a summary of these inspection results.

As specified in Conditions 25.a. and 25.c., verification

with respect to the criterion set forth in Condition 17.c.

is more involved.. The permittee must determine whether or

not the maximum combined capacity to emit of each stationary

source at EU1 has been increased beyond the weekly PSEL.

The permittee must also monitor the changes in the maximum

capacity to emit of stationary sources at EU1 on a six month

basis. If no increase is noted from the previous level, no

further action is necessary. If any increase has occurred,

the permittee shall submit Notice of Completion, containing

the required information as specified in item 25.c.i.

through 25.c.iv.

110
Review Report: 34-2681

Application No.: 14659

Page 39 of 42 Pages

TEST METHODS AND PROCEDURES

26. This section, titled "Test Methods and Procedures", is

provided so that the permittee and Department will know what

test methods should be used to measure pollutant emissions

in the event that testing is conducted for any reason. This

section does not by itself require the permittee to conduct

any more testing than was previously included in the permit.

Although the permit may not require testing because other

routine monitoring is used to determine compliance, the

Department and EPA always have the authority to require

testing if deemed necessary to determine compliance with an

emission limit or standard. In addition, the permittee may

elect to voluntary conduct testing to confirm . the compliance

status. In either case, the methods to be used for testing

in the event that testing is conducted are included in the

permit. This is true for SIP as well as NSPS emission limits

and standards.

RECORDKEEPING REQUIREMENTS

Recordkeeping requirements, Condition 27. through 29 . ,•' of 'this

permit are drafted pursuant to OAR 340-28-2130(3)(b). As was

the case with the ACDP records, all records related to the Oregon

Title-V Operating Permit 34-2681 compliance monitoring must be

kept at the plant site for at least . 5 years.

REPORTING REQUIREMENTS

Reporting requirements, conditions 30. through .32, of this permit

are drafted pursuant to OAR 340-28-2130(3)(c). Under the Source

specific Reporting Requirements, of Condition 32., the fuel usage

data obtained per item 32.e. is used to estimate the annual

emissions from the EU2/ET33 boilers. Items 32.f. through 32. j .

report the compliance status with respect to the VOC PSEL and

RACT conditions; and item 32.k. provides a summary of compliance

status with respect to the rolling HAP limits.

The annual (PSEL) emissions.reported for criteria pollutants are

based on calendar year, and the compliance. status is determined

at the end of the year. However, the annual aggregate emissions

reported for (HAPs) per item 32.k. are based on rolling monthly

average. The compliance status with respect to the annual

(synthetic minor) HAP limit is determined at the end of each

month; and this means a total of 12 compliance determination per

year will be made with respect to the annual HAP limits set forth

in Condition 19.

111
Review Report; 34-2681

Application No.: 14659

Page 40 of 42 Pages

NON-APPLICABLE REQUIREMENTS

Pursuant to OAR 340--28-2190, the permit shield rule, nonapplicable rules are grouped in this section according to the

reasons (summary.) as provided in the permit. Note that a

particular rule that is already mentioned elsewhere in the

permit, conditional type of rule in the general conditions

section for example, regardless of its current applicability, is

not mentioned in this section.

GENERAL CONDITIONS

The "General Conditions" section lists additional applicable rule

requirements that permittee must adhere to, as with any other

permit conditions; and with a few minor exceptions, the

requirements of general conditions are common among all Title-5

sources.

As specified in the General condition G6., the permittee is

subject to_the immediate reporting of excess emissions.

As specified in the General condition G21., the permittee is

subject to the modification procedural requirements applicable to

non-major HAP source.

SUMMARY/PUBLIC NOTICE

The proposed permit was placed on public notice from 6/06/95 to

7/20/95, for a total of 45 days. In addition, with respect to

the procedural requirements of 40 CFR Part 51.102, a separate

public notice was posted in the Oregonian newspaper on 6/08/95,

36 days prior to the date of the public hearing held on 7/13/95.

The RACT proposal portion of this permit was also posted on the

secretary of state notice to conform with the source-specific SIP

revision process. The Department received no comments from the

general public.

However, during the public comment period, the Department became

aware the draft permit inadvertently omitted a few (see items Rl

through R4) applicable requirements. The Department also

received some comments (see R5 through R7) from the U.S. EPA and

the permittee, and respectably the (draft) permit has been

revised as advised. In summary, the following administrative

amendments have been incorporated into the draft permit:

112
Review Report: 34-.2681

Application No.: 14659

Page 41 of 42 Pages

R1. The facility-wide (state-only enforceable) applicable

requirement of the 1000 ppm S02 limit, OAR 340-30-530,

is incorporated into (No. 6.b) the permit, which the

draft permit inadvertently omitted. The 1000 ppm SOZ

limit is an (triocounty) area specific limit that

applies to all permitted sources located inside the

tri-county area. Intel currently has no equipment that

has any chance of exceeding this area specific S02

:limit.

R2. Recently adopted the paint spray and architectural

coating rules, OAR 340-22-900 to OAR 340-22-10.50, are

incorporated into (No. 11.c.) the permit.

R3. The labeling requirements (40 CFR Part 82, Subpart E)

applicable to sources using ozone depleting chemicals

have been inadvertently omitted from the draft permit,

and these requirements have been incorporated into the

permit, condition 8..

R4. The draft permit which previously determined the

natural gas burning EU3 boilers to be non-NSPS boilers

was in error. Pursuant o 40 CFR (§) Part 60.40c,

Subpart Dc, "Standards of Perforrrtance for Small

Industrial-Commercial-Institutional Steam Generating

Units", the EU3 boilers do indeed heat water (hot water

to be used throughout the Aloha campus) and thus

subject to the NSPS standard. Appropriately, the NSPS

daily monitoring (No. 23.c) of natural gas usage is now

incorporated into the proposed permit.

R5. The permit condition 14.c, the RACT compliance schedule

language, has been simplified to. further clarify the

RACT trigger date.

R6. The permit condition 10, the operation and maintenance

requirements for PCD1, has been revised to require PCD1

to operate at or above the optimum control efficiency,.

yet to be determined through source tests.

Appropriately the associated monitoring condition 21.b

has been also revised to reflect the amended O&M

requirements.

R7. The permit conditions 24.b and 24.c, a part of the

over-all VOC monitoring requirements, have been revised

to clarify the waste stream and to specify the

analytical method(s) used to determine the VOC content

of the waste stream.

113
Review Report: 34-2.681

Application No.: 14659

Page 42 of 42 Pages

Pursuant to the permit review procedural requirements of OAR 340

28-2310, the proposed permit was then sent to Environmental

Protection Agency, Region 10 on August 15, 1995. As of October

2, 1995, the Department received no objection from EPA; and all

the criteria set forth in OAR 340-28-2200 (a) are now satisfied.

During the EPA 45 day review period, the following two minor

change were incorporated into the (proposed) permit, and these

changes are reflected in the , (final) permit being issued:

R8. Condition 20.a, the monitoring associated with the

permit nuisance condition (No. 5.), has been modified

to shorten the permittee's response time to public

complaint from 14 days to 7 days.

R9. The excess emissions reporting requirements, General

Condition G6, have been modified to add a general

recordkeeping requirement: Item f has been added.

GDY

October 3, 1995

PERMITS\T342681R

114
BASELINE; EU1

BASELINE; EU2 & EU3

PSEL; EU1

PSEL; EU2 & EU3

OVER (- UNDER) BASELINE

SER

BASELINE

PSEL

PLANT SITE EMISSION DETAIL SHEET REVIEW REPORT: 34-2681

.EMISSION SUMMARY APPLICATION NO.: 14659

PAGE: Al

ANNUAL EMISSIONS (TONS PER YEAR)

PM10 ' S02 NOx CO VOCs

190

0.40 14.16 3.99 1.00 0.07

190.00

6.35 1.24 21.52 31.95 1.43

5.95 -12.93 17.53 30.95 1.36

25.00 40.00 40.00 100.00. 40.00

EU2 & EU3 BOILERS - MONTHLY EMISSIONS (TONS(

PM10 SO2 NOx CO VOCS

0.12 4.42 1.25 0.31 0.03

0.77 0.22 3.14 ' 3.55 0.16

NOTE - Enter input data ONLY 0 AS of this Spreadsheet Program

115
PLANT SITE EMISSION DETAIL SHEET REVIEW REPORT: 34-2681

BASELINE {YEAR 1978) BOILER EMISSIONS APPLICATION NO.: 14659

PAGE; A2

MAX. HR.

CAPACITY

YEAR 10E+6 btu

--- ANNUAL FUEL ---

OIL

1000 gal PM10

ANNUAL EMISSIONS (LES/YR)

VOC EMISSION UNIT

GAS

10+5 cf S02 NOx CO'

EU2.1 FA34-61 1977 0.00 54.41 109 3863 1088 272 18

EU2.2 FAB4-#2 1977 0.00 54.41 109 38E3 1088 272 18

EU2.3 FA94-#3 1977 0.00 54.41 104 3863 1088 272 18

EU2.4 FAB5-#1 1978 0.00 117.89 236: 8370 2358 589 40

EU2.5. FA85-62 1978 0.00 117.89 236 B370 2358 589 40

EU2.6 FAB5-#3 1992 0.00 0.00 q 0 0 0 0

EU2.7 FAB5-#4 1992 0.00 0.00 0 0 0 0 0

EU2 . $ FAB5-65 ELECTRIC 0.00 0.00 0 0 0 0 0

EU2.9 FAE5-#6 1993 0.00 0.00 0 0 0 0 0

EU2.10 FAB5-67 1993 0.00 0.00 0 0 0 0 0

EU2.11 FAB5-#8 1993 0.00 0.00 0 _0 0 0 0

EU2.12 AL4-61 1990 0.00 0.00 0 0 0 0 0

EU2.13 AL4-#2 1990 0.00 0.00 0 0 0 0 0

EU2.14 AL4-63 1990 0.00 0.00 0 0 0 0 0

EU2 TOTAL (TONS/YR): 0.40 14.16 3.99 1.00 q .07

EU3.1 D1-#1 1992 0.00 0.00 0 0 q 0

8013.2 D1-#2 1992 0.00 0.00 0 . 0 0 0 0

£U3.3 01-#3 1992 0.00 0.00 0 0 0 0 q

EU3.4 D1-#4 1994 0.00 0.00 q 0 0 q 0

EU3.5 D1-#5 1994 0.00 0.00 0 0 0 0 0

EU3 TOTAL (TONS/YR): oo

q poo=

D.00 0.00

--_-

0.00

......

116
PLANT SITE EMISSION DETAIL SHEET

BASELINE (YEAR 19761 BOILER EMISSIONS

REVIEW REPORT: 34-2661

APPLICATION NO.: 14659

PAGE: A3

MAX. HR. ---- FUEL BASIS --- HOURLY EMISSIONS (IBS/HR)

CAPACITY GAS OIL ======-00--==----.-. ====

W = ---s-=

BOILER YEAR 10E+6 btu 10+6 c€ 1000 gal PM10 S02 NOx CO VOC

EU2.1 FAB4-41 1977 3 2.86E-03 2.28E-02 0.046 1.621 0.457 0.114 0.011

EU2.2 FAB4-#2 1977 3 2.86E-03 2.26E-02 0.046 1.621 0.457 0.114 0.011

EU2.3 FAB4-#3 1977 3 2.86E-03 2.28E-02 0.046 1.621 0.457 0.114 0.011

EU2.4 FA25-#1 1978 6.5 6.19E-03 4.95E-02 0,099' 3.512 D.989 0:247 0.024

EU2.5 FAE542 1976 6.5 6.19E-03 4,95E-02 0.099 3.512 0.989 0.247 0.024

EU2.6 FA85-#3 1992 6.277 0.000 0.000 0.000 0.000 0.000

EU2.7 FADS-#4 1992 6.277 0.000 0.000 0.000 0.000 0,000

EU2.8 FA85-45 ELECTRIC 0,000 0.000 0.000 0.000 0.000

EU2.9 FA85-#6 1993 1.255 0.000 0.000 0.000 0.000 0.000

EU2.10 FABS-#7 1993 4.185 0.000 0.000 0.000 0.000 0.000

EU2.11 FAB548 1993 4.185 0.000 0.000 0.000 0.000 0.000

EU2,12 A14-41 1990 2.929 0,000 0,000 0.000 0.000 0.000

EU2.13 AL4-42 1990 2.929 0.000 0.000 0.000 0.000 0.000

EU2.14 AL4-#3 1990 2.929 0.000 0.000 0.000 0.000 0.000

EU2 TOTAL 0.335 11.887 3.349 0.837 0.080

EU3.1 01-81 1992 20.922 0,000 0.000 0.000 0.000 0.000

EU3.2 01-92 1992 20.922 0.000 0.000 0.000 0,000 0.000

EU3.3 D1-#3 1992 29.4 0.500 0.000 0.000 0.000 0.000

503.4 01-84 1994 20.922 0.000 0.000 0.000 0.000 0.000

EU3.5 01-45 1994 20.922 0.000 0.000 0.000 0.000 0.000

EU3 TOTAL 0.000 0.000 0.000 0.000 0.000

117
PLANT SITE EMISSION DETAIL SHEET REVIEW REPORT: 34-2681

CURRENT BOILER EMISSIONS APPLICATION NO.: 14659

PAGE: A4

MAX. HR.

CAPACITY

YEAR 10E+6 btu

--- ANNUAL FUEL ---

GAS OIL .

ANNUAL EMISSIONS (LBS/YR)

............

CO VOC

._=

PM1D S02

......

NOx BOILER 1006 cf 1000 gal .

502.1 FA04-41 1977 10.82 0.00 130 28 1082 227 41

EU2.2 FAB4-#2 1977 10.82 0.00 130 28 1082 227 41

EU2.3 FAE4-#3 1977 10.82 0.00 130 28 1082 227 41

EU2.4 FAG5-#1 1978 23.44 0.00 281: 61 2344 492 89

EU2.5 FA35-#2 1978 23.44 0.00 281 61 2344 492 89

EU2.6 FAE5-#3 1992 22.64 0.00 272 59 2264 475 86

EU2.7 FAB5-#4 1992 22.64 0.00 272 59 2264 475 86

£U2.8 FAES-45 ELECTRIC 0.00 0.00 0 0 0 0 0

EU2.9 FABS-#6 1993 4.53 0.00 54 12 453 95 17

EU2.10 FABS-#7 1993 15.09 0.00 181 39 1509 317 57

EU2.11 FA35-#8 1993 15.09 0.00 267. 39 1509 317 57

EU2.12 AL4-41 1990 10.56 0.00 127 27 1056 222 40.

EU2.13 AL4-#2 1990 10.56 0.00 127 27 1056 222 40

EU2.14 AL4-#3 1990 10.56 0.00 127 27 1056 222 40

EU2 TOTAL EU2 TOTAL (TONS/YR): 1.15 0.25 9.55 2.01 0.36

EU3.1 q I-#1 1992 149.60 0.00 1926 366 4429 11080 394

EU3.2 01-42 1992 140.60 0.00 1926 366 4429 11080 394

EU3.3 01-83 1992 197.58 0.00 2707 514 6224 . 15569 553

EU3.4 D1-#4 1994 140.60 0.00 1926 366 4429 11080 394

EU3.5 D1-#5 1994 140.60 0.06 1926 366 4429 11080 394

=..a..Ra=.=R=_a= =3==-_=____==a=te==a=

EU3 TOTAL EU3 TOTAL (TONS/YR): 5.21 0.99 11.97 29.94 1.06

118
PLANT SITE EMISSION DETAIL SHEET REVIEW REPORT: 34-2681

CURRENT BOILER EMISSIONS APPLICATION NO.: 14659

PAGE; AS

MAX. HR. ---- FUEL BASIS --- HOURLY EMISSIONS (LBS/HR)

CAPACITY GAS OIL = ===='°=L====-°°°°___====^°0======ag-= °--

BOILER YEAR 102+6 btu 10+6 of 1000 gal PM10 S02 NOx CO -- VOC

EU2.3 FAB4-#1 1977 3 2.86E-03 2.28E-02 0.034 0.011 0.286 0.060 0.011

EU2.2 FAB4-#2 1977 3 2.86E-03 2.28E-02 0.034 0.011 0.286 0.060 0.011

EU2.3 FAB4-#3 1977 3 2.86E-03 2.28E-02 0.034 0.011 0.286 0.060 0.011

EU2.4FAB5-#1 1978 6.5 6.19E-03 4.95E-02 0.074: 0.024 0.619 0.130 0.024

EU2.5 FAB5-52 1978 6.5 6.19E-03 4.95E-02 0.074 0.024 0.619 0.130 0.024

EU2.6 FAB5-#3 1992 6.277 5.98E-03 0.072 0.023 0.598 0.126 0.023

EU2.7 FAB5-#4 1992 6.277 5.98E-03 0.072 0.023 0.598 0.126 0.023

EU2-8 FABS-#5 ELECTRIC 0.00E+00 0.000 0.000 0.000 0.000 0.000 EU2.9 FABS-#6 1993 1.255 1.20E-03 0.014 0.005 0.120 0.025 0.005

EU2.1O FAES-#7 1993 4.185 3.99E-03 0.048 0.015 0.399 0.084 0,015

EU2.11 FA55-#8 1993 4.185 3.99E-03 0.048 0.015 0.399 0.084 0.015 EU2.12 AL4-#1 1990 2.929 2.79E-03 0.033 0.011 0.279 0.059 0.011

E012.13 AL4-#2 1990 2.929 2.79E-03 0.033 0.011 0.279 0.059 0.011

EU2.14 AL4-#3 1990 2.929 2.79E-03 0.033 0.011 0.279 0.059 0.011

EU2 TOTAL

EU3.1 01-#1 1992 20.922 1.99E-02 0.273 .0.076 0.623 1.570 0.056

EU3.2 01-52 1992 20.922 1.99E-02 0.273 0.076 0.628 1.570 0.056

-EU3.3 01-#3 1992 . 29.4 2.80E-02 . 0.384 0.106 0.882 2.206 0.078

EU3.4 01-54 1994 20.922 1.99E-02 0.273 0.076 0.628 1.570 0.056

EU3.5 01-#5 1994 20.922 1.99E-02 0.273 0.076 0.628 1.570 0.056

£U3 TOTAL 1 476 ==a=O6' 0.409 =sa = O83.393

='666==

9 8.487 0.302

0.605 0.192 5.044 1.059 0.192

119
- BOILER DATA ENTRY SHEET -

FUEL USAGE SUMMARY

BOILER

MAX. HR.

CAPACITY

10E+6 btu

YEAR

INSTALLED

ANNUAL GAS USAGE ANNUAL OIL USAGE

(therms/year) (gallons/year)

Baseline Current Baseline Current

EU2.1 FAB4-41 3 1977 0 113592 54409 0

EU2.2 FAB4-#2 3 1977 0 113592 54409 0

EU2.3 FAB4-4.3 3 1977 0 113592 54409 0

EU2.4 FA25-#1 6.5 1978 0 246115 117886,' 0

EU2.5 FAB5-42 6.5 1978 0 246115 117886 0

EU2.6 FAGS-#3 6.277 1992 0 237672 0 0

EU2.7 FAB5-#4 6.277 1992 0 237672 0 0

EU2.8 FAB5-#5 ELECTRIC 0 --

EU2.9 FAB5-#6 1.255 1993 0 47519 0 0

EU2.10 FAB5-#7 4.185 1993 0 158460 0 0

EU2.11 FAB5-#8 4.185 1993 0 158460 0 0

EU2.12 AL4-#1 2.929 1990 0 110903 0 0

EU2.13 AL4-#2 2.929 1990 0 110903 0 0

EU2,14 AL4-43 2.929 1990 0 110903 0 0

EU3.1 D1-#1 20.922 1992 0 1476351 0 0

EU3.2 D1-#2 20.922 1992 0 1476351 0 q

EU3.3 D1-#3 29.4 1992 0 207497 0 0

EU3.4 D1-#4 20.922 1994 0 1476351 0 0

EU3.5 D1-#5 20.922 1994 1476351 0 O

AP42 EMISSION FACTORS COMMERCIAL BOILER

(except as noted *) (0.5 to 10 million btu/hr)

.. . m_

222-22

s

Y OIL-

-

1bs/10E6 cf lbs/1000 gal

INDUSTRIAL BOILER

(10 to 100 million btu/hr)

GAS OIL

lbs/10E6 cf lbs/1000 gal

PM10 12 2 13.7

S02 2.6 71 2.6

NOx 100 20 140

CO 21 5 35

VOC 3.8 0.34 2.8

S02 (HR. MAX) 3.8 71 3.8

2

71

20

5

0.2

71

FUEL OIL DATA kS

OAR 340-22-015: ASTM-2 0.5

OAR 340-22-015: ASTM-2 0.3

INTEL MAX. FUEL S% 0.05

PROCESS EMISSIONS tons/yr

......................... ............

VOCs (PSEL) 150.00

VOC HAPs 10.00

non-VOC HAPs 0.00

CONVERSION FACTORS

btu/therm 100000

btu/scf. 1050

btu/gal dsl, 131400

FEE ($$$/TON/YR)

2M10 T _ 29.26

S02 29.26

NOx 29.26

CO 0

VOCs 29.26

HAPs 29.26

REVIEW REPORT: 34-2681

APPLICATION NO.: 14659

PAGE: AS

INDUSTRIAL BOILER w/ LowNOx

(10 to 100 million btu/.hr)

GAS

lbs/10E6 cf

GAS

lbs/10E6 cf

13.7 23.7

2.6 2.6

31.5 * 30

78.8 * 37

2.8 2.8

3.8 3.8

* Manufacturer's specified EFs

EFs maybe updated at permit renewal

based on stack test results

120
- GASEOUS EMISSIONS FROM FUEL COMBUSTION -

-BOILER ID: EU2.1 through EU2.5

burning oil 365 days/yr

' REVIEW REPORT: 34-2681

APPLICATION NUMBER: 14659

PAGE: A7

ENTER CODE:

MAX. CAPACITY

2 1 if Industrial Boiler (10 to 100 million btu/hr)

2 it Commercial Boiler (0.5 TO 10 million btu/hr)

NATURAL GAS: 22 million btu/hr

DIST. FUEL OIL: 167.43 gallon/hr 0.5 % sulfur

RESIDUAL OIL: gallon/hr 0 sulfur

ANNUAL FUEL USAGE

0 t nitrogen, if known

NATURAL GAS: 0.00E+00 therms/yr

DISTILLATE OIL: 1.47E+06 gallon/yr

RESIDUAL OIL: 0.00E+00 gallon/yr

NATURAL GAS / DISTILLATE FUEL OIL COMBUSTION

- AP42 EMISSION FACTORS - MAX HR EMISSION ANNUAL EMISSION

lb/10+6cf nat. gas lb/10+3 gal

dist. oil

ng

(lb/hr)

oil ng oil

average hourly (tons/yr)

PARTICULATES 12 12 2• 0.251 0.335 0.000 1.467

S02 2.6 3.8 71 0.080 11.887 0.000 52.067

NOx 100 100 20 2.095 3.349 0.000 14.667

CO 21 21 5 0.440 0.837 0.000 3.667

VOCs 2.9 2.B 0.34 0.059 0.057 0.000 0.249

RESIDUAL FUEL OIL COMBUSTION

--- EMSION (r) --- -- ANNUAL EMISSION {ton/yri --

GRADE 6 GRADE 5 GRADE 4 GRADE 6 GRADE 5 GRADE 4

PARTICULATES 0.000 0.000 0.000 0.000 0.000 0.000

S02 0.000 0.000 0.000 0.000 0.000 0.000

0.000 * NOx 0.000 ' 0.000 0.000 0.000 0.000

CO 0.000 0.000 0.000 0.000 0.000 0.000

VOCs 0.000 0.000' 0.000 0.000 0.000 0.000

NOx emission (below) reflects residual oil N2 content (if tN2 is known) ,

* NOx 0.000 `000

HOURLY I lb/

121
1993 VOC EMISSIONS SUMMARY PERMIT NUMBER: 34-2681

APPLICATION NUMBER: 14659

PAGE: A8

- BIMONTHLY VOC EMISSIONS -

tons/61month

ElMONTH

JAN/FEB

ACTUAL

(CMB6

15.9

EF &

PROD.

15.6

MAR/APR 26.0 26.2

MAY/JUN 25.3 25.3

JUL/AUG 17.0 16.4 0

SEP/OCT 26.7 27.B

Cl

.zd9

0

4- NOV/DEC 41.4 39.6

FIGURE 1. 1993 VOC EMISSIONS

REAL -us-- E BASED

JAN E

1771 Actual Emi.:aans

MAR/APR MAY/JUN JUL/AW SEP/OCT NC /EEG

EN--MCrm1LY EMLS ONS

^a^ an EF Prod.

122
Permit Number: 34-2681

Application No.: 14659

Page: A9

Table 1

Control Equipment and Control Efficiencies

VOC Contro'I E quipment

Cold Cleaner (low volatility)

o cover,

o mechanically assisted cover and

spray and agitation control

Cold Cleaner (high volatility)

o cover

o mechanically assisted covers and

spray and agitation controls

Batch-loaded Vapor Cleaner

o cover

o mechanically assisted covers and

spray and agitation-controls

Conveyorized Vapor Cleaner

o cover .

o mechanically assisted covers and

spray and agitation controls

Carbon Absorbers

Refrigerated Chillers

Higher Freeboard Ratio

Use of Non-VOC Solvents

Control Efficiencies (o)

55 - 80

50 - 9Q

45 - 60

60 -- 75

25

60

40 - 9511

10 -- 40 121

-25 - 50`L

100

55

70

CI

g A typical value is about 40 percent.

For a batch-loaded vapor cleaner.

Based on a baseline freeboard ratio of 0.5 ' for batch-loaded

vapor cleaners. Increasing the ratio from 0.5 to 0.75 and.

1.0 results in about 25 and 50 percent emission reduction,

respectively.

123
" •r

Permit Number: 34-2681

Application No.: 14659

Page: A10

ATTACHMENT A

STACK TEST SUMMARY

N/A = Not Applicable

TEST SOURCE/STACK

USAGE

CHEMICAL , (LB/HR)

EMISSIONS

9.18

0

1.43

0

0

(LB/HR) %E^TAP

IPA 0.83

TCA 0.46

Acetone 0.27

Freon N/A

' HMDS N/A .

Cyclohex N/A

Cel Acet N/A

Xylene N/A

.

Degreaser

Hood Fan

FAB 4:

1

0.0762

0

0.0038

0.0050

0.0009

0.0001 0

0.0004 0

0.0005 0

" The hood was used for 15 minutes to clean D&W

parts.

2 Degreaser IPA 1.37 0.1384 10.10

Hood Fan Freon 0.55 0.0016 0.30

Acetone N/A 0.0013 0

Methyl Ce1N/A 0.0003 0

TCA N/A 0.0053 0

CTC N/A 0.0002 0

Cyclohex N/A 0.0001 0

Cel Acet N/A 0.0012 0

Xylene N/A 0.0003 0

The hood was used for 1 hour to degrease 30 parts.

1 Solvent Hood Cel Acet 18.8 0.0342 0.18

Fan NBA 2.16 0.0008 0.4

Xylene 3.38 0.0178 0.53

Acetone N/A 0.0003 0

IPA N/A 0.0038 0

Freon N/A 0.0004 0

Methyl CelN/A 1.5775 0

TCA N/A 0.0003 0

Cyclohex N/A 0.0001 0

Chloroben N/A 0.0010 0

Sink was used for 5 hours. Poured 43 gallons of

waste resist.

124
Permit Number: 34-2681

Application No. 14659

Page: All

TEST SOURCE/STACK CHEMICAL

USAGE

(LB/HR)

EMISSIONS

(LB/HR) , oEVAP

2 Solvent Hood Cel Acet 20.11 0.3484 1.74

Fan NBA 2.31 0.0026 31.32

Xylene 3.53 1.1055 0.11

Acetone N/A. 0.1837 0

IPA N/A 0.0053 0

Methyl . Ce1N/A. 0.0030 0

TCA N/A 0.0003 0

Cyclohex N/A 0.0001 0

Chloroben N/A 0.0010 0

1

Sink was used for 6

waste resist.

hours.

1..10

Poured 46 gallons of

Small Solvent Acetone 0.6341 57.65

Hood IPA N/A 0.0009 0

Freon N/A 0.0.001 0

HMDS N/A 0.0016 0

NBA N/A 0.0036 0

Chloroben N/A 0.0108 0

Cel Acet N/A 0.1099 0

Xylene: N/A 0.0607 0

2

Used for 2 hours.

Small Solvent Acetone 1.10 0.4235 38.51

Hood IPA N/A. 0.0013 0

NBA N/A 0.0005 0

Cel Acet N/A 0.0178 0

Xylene N/A 0.0635 0

FAB 5:

1

Used for 2 hours

Degreaser IPA 1.86 0.0824 4.43

Hood Freon 0,27 0 0

TCA 0.23 0.0223 9.72

Acetone 0.14 0.0884 63.21

HMDS 0.03 0 0

NBA N/A 0.0001

Cel Acet N/A 0.0027

Xylene N/A 0.0011

Hood used 7 separate occasions.

125
Permit Number: 34-2681

Application No.: 14659

Page: A12

TEST SOURCE/STACK

USAGE

CHEMICAL (LB/HR),

EMISSIONS

, (LB/HR) %EVAP

Degreaser HMDS 0.53 0.0027 0.51

Hood Acetone N/A 0.0443 0

IPA N/A 0.0734 0

Methyl CelN/A 0.0025 0

TCA N/A 0.0183 0

Cyclohex N/A 0.0029 0

NBA N/A 0.0001 0

Chloroben N/A 0.0001 0

Cel Acet .N/A 0.0016 0

Xylene N/A 0.0009 0

1

Hood used once.

Solvent Hood Acetone 12.48 0.2037 1.63

Cel Acet 0.01 _ 0.0226 226.89

Xylene 0.001 0.0087 871.69

NBA 0.001 0.0002 23.54

M-pyrrol

IPA

0.40

N/A

Not Tested

0.0020 0

Freon N/A 0.0001 0

'TCA N/A 0.0043 0

2

Hood used 8 times.

Solvent Hood Acetone 0.93 0.2606 28.03

Cel Acet 0.02 0.0177 '88.96

Xylene 0.003 0.0103 344.08

NBA 0.003 0.0001 3.49

M-pyrrol

IPA.

0.40

N/A

Not Tested

0.0013 0

TCA N/A 0.0159 0

Chloroben N/A 0.0004 0

1 Degreaser Hood TCA 0.92 0.117 12.71

Downstairs IPA 0.55 0.065 11.82

Acetone 0.55 0.072 13.09

NBA N/A 0.002 0

Cel Acet N/A 0.001 0

Hood used once to degrease parts.

126
Permit Number: 34-2. 681

Application No.: 14659

Page: AI3

TEST SOURCE/STACK CHEMICAL

USAGE

LB HR

EMISSIONS

{LB/HR) oEVAP

2 Degreaser Hood TCA 0.92 0.0349 3.79

Downstairs IPA 0.55 0.0097 1.76

Acetone 0.55 0.0069 1.25

Freon N/A 0.0007 0

NBA N/A 0.0036 0

Cel Acet N/A 0.0010 0

Xylene N/A 0.0005 0

Trimethyl N/A 0.0020 0

Hood was used once to degrease parts.

CHEMICAL NAME INDEX

Isopropyl Alcohol

1,111, Trichloroethane

N Butyl Acetate

1-Methyl-2-Pyrrolidone

Cellosolve Acetate

Freon 113

Cyclohexanone

Chlorobenzene

Methyl Cellosolve

Hexamethyldisilazane

Carbon Tetrachloride

Trimethylbenzene

IPA

TCA

NBA

M-pyrrol

Cel Acet

Freon

Cyclohex

Chloroben

Methyl Cel

HMDS

CTC

Trimethyl

127
- TOXIC SUBSTANCE USAGE -

ESTIMATED ANNUAL USAGE (ranges in lbs/yr)

1,001 10,001 20,000

CHEMICAL NAME CAS NUMBER INSIGNIFICANT - 10,000 - 20,000 - 50,000 s 50,000

Ammonia (anhydrous} -

Boron trichloride

Boron trifluoride

7664417

10294345

7637042 X

X

X

Chlorine

Diborane

7782505

19287457 X

X

Dichlorosilane

Hydrochloric acid

(solution conc. > 25%)

Hydrogen

Hydrogen chloride

4109960

7647010

1333740

7647010

x

X

X

(anhydrous)

Hydrogen fluoride 7664393 X

Nitric acid

Phosphine

Phosphrous oxychloride

7697372

7803512

10025873

X

X

X

Silane 7803625 X

Sulfuric acid 664939 X

REVIEW REPORT: 34-2681

APPLICATION NO.: 14659

PAGE: A14

128
(

129
Permit No. 26-1867

Expires 4-1-2000

Page 1 of 4 Pages

AIR CONTAMINANT DISCHARGE PERMIT ADDENDUM

Department of Environmental Quality

Northwest Region'.

2020 SW 4th, Suite 400

Portland, Oregon 97201-4987

Telephone: (503) 229-5263

Issued in accordance with the provisions of ORS 468A.040 and based on

the land use compatibility findings included in the permit record.

ISSUED TO: INFORMATION RELIED UPON:

PCC Structurals, Inc. VOC RACT Analysis

4600 S.E. Harney Drive Submitted: May, 1993

Portland, OR 97206

PLANT SITE LOCATION:

Johnson Creek Complex

4600 S.E. Harney Drive

Portland, Oregon

ISSUED BY THE DEPARTMENT OF ENVIRONMENTAL QUALITY:

Tom Bispham, Northwest Region Administrator

Supplementary Information

Submitted: May, 1994

' 4 1997_

Dated

ADDENDUM NO. .2

130
131
Permit No. 26-1867

Expires 4-1-2000

Page 3 of 4 Pages

RACT Rehr. uirements,

19. By no later than one year after notification by the Department of

approval by the EPA of the source specific RACT determination,

the permittee shall provide controls to reduce the VOC emissions

from the Large Parts Campus Steel and Titanium (LPC-S and LPC-T)

investment casting operations by a minimum of 90 percent.

(This condition is included in the Oregon state Implementation

Plan (SIP). Any changes to this condition must be submitted as

SIP revisions.)

20. By no later than 90 days after the notification of EPA approval,

the permittee shall submit to the Department a final control

strategy concerning the VOC emissions from the investment casting

operations. The plan shall include a schedule and dates of the

project interim steps leading up to the compliance date specified

in Condition 19. above. The emission reductions . may be

demonstrated by the source testing required by Conditions 16. and

17. in the existing permit, or an alternative plan that is

approved by the Department.

(This condition is ' included in the Oregon State Implementation

Plan (SIP). Any changes to this condition must be submitted as

SIP revisions.)

21. In order to calculate compliance with Condition 19., the

permittee may average the destruction and removal efficiency of

all its investing rooms using VOC containing slurries. Any

investing'room for which the VOC content of the slurries used is

less than 2% (not including water). VOC on a weighted average

basis shall be exempt from RACT and this condition's compliance

calculation.

(This condition is included in the Oregon State Implementation

Plan (SIP). Any changes to this condition must be submitted as

SIP revisions.)

132
133
.Penuit No,» 19-01)02

Expiration Date; 11-1-2002

Page 1 of6 Pages

AM CONTAMINANT DISCHARGE PERMIT

Depa rtment of Environmental Quality

Eastern Region, Bend Office

214 N.E. 4th Street, Suite 104

Bend, OR 97701

Telephone: (54l) 388-6146 .

Issued in accordance with the peovislgns of ORS 468A.040 and based

on the land use cum atileility findings secluded in the permit record.

' ISSUED TO:

Ostrander )lesonrees Company

P.0, Box 1340

Lakeview, OR 97630

PLANT SITE LOCATION:

Fremont Sawmill

Missouri Ave.

Lakeview, OR 97630

INFORMATION RELIED UPON

Application No.: 0165.59

Date Received: 812211997

LAND USE COMPATIBILITY STATEMENT

From: Lake County Planning and Town of Lakeview

Date; 312411989 and 312711 P .9

ISSUED BY THE DEPARTMENT OF ENVIRONMENTAL QUALITY

Stephanie H. lock, Eastern i n Adredaistrater

aa: L1

Scuree(s) Permitted to T ianl atge Air Contaminants:

TYPE OF FACILITY (FROM TABLE 4, OAR 340-' 8 . 1750)

10.a, Smwamitl and Planing Mitt, greater than 25,040 bd fh'shlft

6f1. Fuel Burning Equipment; outside AQMA

wond4fired, greater than 30 million Emilie

PERMI TED ACTIVITIES

1. The permit-tee is herewith allowed to discharge exhaust gases containing air contaminants only in accordance with

the permit application and the limitations eontaLned ia this permit, Until such time as this permit a pu s or is

modified or revoked, the perm ittee is herewith allowed to discharge exhaust gases from those processes and

activities directly related or associated thereto in tieearclance with the requiremente, limitations, and conditions of

this permit from the air contaminarit source(s) listed above.

STANI AR1o INDUSTRY CODE

2421

4961

134
Permit No,; I9-1002

Expiration Dater 11-4-2002

Page 2 of 6 Pape

2. Compliance with the specific requirements, limitations and conditions contained herein does not relieve the

pesrnittee from complying with all other hors. Moe end standards admiriist d by the Department, lot does it allow

significant leech of emissions oeaie contatninents not limited in this penult or contained in t^se permit appiicatian_

p SPORNIANCI?i T4111 SAND EMS9Ifl11 ,^,^, A.t1+4^`1"

3, ParIieulste emissions from any single air contarei ant source (except for fuel burnistg equipment) shall not exoeed

aty of the following=

a. 0.2 grains per standard cubic foot, forsources existing prior to June I, 1970;

b. 0,1 grains per standard cubic foot, for sources installed, constructed, or modified after luny 1, 1970; and

c, An opacity equal to or greater then twenty percent (t}%) for a period aggregating more than three (s).

minutes in any one (1) hour, excluding uncambined water vapor.

4, The pennittee shall Operate and control the steam generating boiler(s) in accordance with the following list of boiler

operating parameters and emission limitations;

Maximsum pro sit n Limits

Boiler ldemification Fuel Used Opacity' Partieulateei Maximum Operation

^elbes _

#2 it ellons

l-1ogged Woad Waste

Hogged Wood Waste

20

2U .. O.Y

24,000

24,000

Maximum opacity that shall not be equaled or exceeded for a period oe periods aggregating more than

three minutes in eny a hour, excluding uncambined water vapor.

Particulate emiissiort limitation is stated in grains per standard cubic foot, ean'ected to 12% carbon dioxide.

Maximum hourly average steam production (pounds per hour).

5. The permittee shall not operate the boillers with any fuels other than those fired during the Department approved

emissions source test.

6. The penult-toe shall not allow the emission of odorous matter or other fugitive emissions so as to create nuisance

conditions o the permittee's property. Nuisance conditions will be verified by Deperbnerrt personnel. The creation

ofnuiattee conditions may, in additien m any other action the Department may take, result in a permit modification

to require a compliance schedu ie to control the nuisance conditions.

The permittee shall minimize fugitive dust omissions by: 7.

a. Treating vehicular traffic areas of the ,plant site under the control of the permittee.

b. Storing collected material from air pollution control equipment in a covered container or other method

equally effective in preventing the material from becoming airborne during storage and transfer,

135
Permit No.: 19.0002

Expiration Date: 11-1-2002

Page 3 af6 i es

8. Emissions from the eourcas listed shall not exceed the following:

L1'rd P1rl ._. CO lY x

.:. ...

}./9 Y Off-/

:Source tonlyr 11blhr tonlyr lb/hr ton/ye lb/he ton;yr bait t itt/yr 1bfhr ton/3,r

Boiler . NMI 58 1 .4 52 66 14.9 62 0.7

Cyclones WEIMMEN 5.6 6

=ME

€ ilns 50 60

TOTALS 70 l8 15.8 66

.....

14.9 62

.....

0.3 3 154

Note: Target boxes and other wood dust emission points are included with cyclone emissions.

The PEI., for the boilers is bossed on a combined annual production (1400,000,000 pounds ofsteam at a maximum

hourly steam production of 24,100 pounds per boiler: The cyclone PSEL is based on 34,058 bone dry tons

(BI)T)lyeeer and 18 I3DT/hr of material processed through the cyclones, 47,015 ^3F 'ffyt and 15 TOT/he QC material

processed through the tenet boxes, and 23,545 B0T/yr end 6 EDT/he of material processed through the wigwag.

The Plant Site Emission Limit for the kilns is based on 60,000,000 board feet of lumber dried in the kiln& Any

increases above these levels must receive the prior approval of the Department,

SOURCE TE.CTIE14n

9. By no later than December 31, 2000, the permitted shall demonstrate that each hogged fuel boiler is capable of

operating at its maximum operating capacity in continuous compliance with Conditions 4 and S by conducting a

source test for particulate, PM=a, NO,, end CO emissions.

All tests shall be conducted in accordance with the testing procedures an file at the Department and with the pretest

plan submitted at least 15 days in advance end approved by the Source Test Coordinator in rho Eastern Region of

the Department in Bend (unless otherwise notified). Test data and results shall be subinitted for review to the

Source Test Coordinator within 30 days after testing.

Only regular operating staff may adjust the combustion system and emission control parameters during the source

performance tests and within two (2) hours prior to the tests. Any operating adjustments made during the source

performance tests, which are a result of consultation during the tests with source testing personnel, equipment

vendors or consultants, may render the source performance test invalid:

During the source rest the following parameters should be monitored end recorded:

PLA"lT x IT EMISSION LIMITS

a. Opacity readings ott the exhaust stack following the procedures of EPA Method R.

b. Steam flow rate.

e. Type of fuel or phyeicel characteristics of the fuel, including species of weed bark, percent fines (less than

1/8"), and moisture eentent (wet basis).

4. Process operating parameters during the emissions source test, including but not limited to time and

frequency of grate cletutxtig.

136
1 errmit Tula.: 19-0002

l t;pittion Data; 11-1-2002

Page 4 of b' Pages

MCNrropaNOIEQUI1 M T'S

10, The pierioit a shell effectively impact end monitor the operation and maintenance of the plant and nssoeiated air

contain heat eozt l facilities and shall implement the procedures ttec sary to moiritor and record the fallowing

parameters, A record elan, such data shall be maintained for palled of two years at the plant site for inspection by

the authorized representatives of the Department. A11 required continuous monitoring shall be conducted in

accordance with a Department approved plan, which must be submitted within sixty (d0) days of permit issuance,

a. Ali operating and production parameters to be reported to the Department annually as required in

Condition 11.

b. Excess ettiieaicns records as defined hi OAR 340-28-1411a tbrottgh 340-25-1440 (recorded on oocotrreace).

o. A description of any maintenance to the air contaminant control system (recorded an a occurrence),

1? PORTINf RBQ JLFBM s• NT

11. The pertxtittee shall submit to the Depa ►eiri by January 15 of each year this permit is in effect three (3) copies of

the fofcwittg information for the preceding calendar year:

a. Operating parameters:

i) - Sawmill production (board feet),

ii) Type and amount of fuel burned in boiler (EDT/yr) (include average moisture content of wood).

Annual steam pr diction of each boiler (tbslyr).

iv) Maximum hourly steam production of each boiler (lbt hr),

v) Annual and maximum hourly throughput for cyclones and ergot box (1EDT, include calculation

prtrtcacol if direct measurements are met used).

vi) Total lumber dried iii kilns (lord ft/Yr).

b. A leg of all planned and unplam.tied excess emissions eccr rdanee with OAR 340-28-1440.

c. Explain any permanent chanes made in the plant process or production which would affect air

contaminant emissions, (Indicate when changes were made,)

d. List all major maioteaanoe performed on air pollution equipment.

The report shall be sent to the Eastern Region, Bend Office, 2146 N.E. 4th St., Suite 104, Bend, Oregon

97701, unless otherwise notified. The permit number must be prominently displayed on the report.

s SCHDI.II,

12. The Annual Compliance Determination pee for this permit is due on October 1 of each year this permit is in effect.

An invoice indloatting the amount, as detorniiaed by Department regulati*ns, Will be mailed prior to the above data.

The fee shall be submitted to the Business Office of the Department in Portland (unless otherwise notified).

OBNEl€!4T^cON ITIO1 AND DISCLAIMERS

Cl. The permittee shall allow Department of Environmental Quality representatives access to the plant site and pe tittent

recaxie at all reasonable times for the purposes of malting inspections, surveys, collecting samples, obtaining data,

reviewing and copying air contaminant emission discharge records and otherwise conducting all necessary functions

seater'tta this permit in accorrdartoe.with ORS 468.005.

C'r2, The pcrmirlee shall have available at the facility at all times a copy of the Air Contaminant Dieehau e'i'ermit,

137
Permit Nei : L9.0002

Expiration Date: l [-12002

Page 5 of C6 "ages

G3. 'll`fte permittee is prohibiter!. from cenductittg open Nanning, eeeept as allowed by OAR 340 Division 23.

G4. The pennittee ia1l at all times conduct dust suppression measares to meet the requirements eel forth in "Fugitive

Emissions' and "Nuisance Conditions" In OAR X40.25-0. 0 through 340-21-060,

G5. In accordance' ride OAR 340-211-I400 tlhroirgh; 40-28-1450, the pe$mittiee shall irrirnediately (i.e. as srrvzt as

possible but in no case more than lark hour after the beginning of the excess emission period) notify the Deparirnent

by telephone or in parson of any excess emission, other than pre•epproved startup, sha)tdown, or scheduled

maintenance. Nottfcatioe shall include the source awe, nature of the emissions problem, name of the perm

making the report, name and telephone number of contact person for further information, date and time of the onset

of the upset condition, whether or not the incident was planned, the cause of the excess emission (startup, shutdown,

maintenance, breakdown, or Other), equipment involved in the upset, estimated type enrt quantity of eiice gs

emissions, estimated time of return to normal operations, efforts made to minimize emissions, and a description of

remedial actions to be taken. Fol low-up reporting shall be made in accordance with Department direction and OAR

340-28-1430(2) and 340.28-1441.

Notification shall be made to the appropriate regional or branch, office. C urreet Departmental telephone timbers

are:

Klamath Faits 883-5603

Bend 388-6146

In the event of any excess emissions which are of a nature that could a,danger public health and oceiic during

nonbisfness hours, weekends, or holidays, the permittee shall immetLiateiy notify the l parlmeiii by calling the

Oregon Emergency Response System (OERS). 'TSae current nierribet is 1-800-452-tX 11.

Cr6. The perrxiittee shall notify the Depatlttt erit in writing using a Departmental "Notice ofConstrudion" form, Or

"Penal* Application Form'", and obtain approval in aeeordanee with OAR 340-28400 through 340-28-820 before:

a. Constructing or installing any new Pearce of air contaminant emissions, intleding air pollution control

equipment, or

b. Modifying or altering an existing mauve that may significantly affect the emission of air contaminants, or

e, Making any physical eheage which increases emissions, or

d. Changing the method of operation, the process, or the fuel use, or morels ing the normal ileum of operation

to levels above time contained in the permit appllcs.tiem and reflected in this permit and which result in

increased emissions.

G7. Application for a rnadiReednn of tltls permit must be submitted not less than 40 days prior to the source

modification,. A riling Fee and an Application Processing Fee mast be submitted with an appiicatlon far the permit

modification.

G. The permit-tee shall notify the Department in writing tisitag a Departmental "Permit Application Form" within 60

days after the following:

a. Legal change of the registered name of the company with the Corporations Division of the State of Oregon,

or

b. Sale or exchange of the activity or facility.

Applicable Permit Foes mast be submitted with an application for the name c flange.

138
Permit No.: 10-0002

Expiration Date: 11-1-2002

Page 6 of 61 Pages

G9, Application for renewal of this permit must be submitted not less than Ertl days prior to the permit expiration date, A

Filing Fee, antApplication Processing Fee and an Annual Comp dance Determination Fee must be submitted with

the application f o r the p it renewal.

C3 10. The issaanee of this permit does riot convey any property rights hi either real -or personal property, or any exclusive

privileges, nor does it authorize any injury to private property or any invasion of personal rights, 'tor any

infringement of federal, state, or local lsrxs or regulations. "

G11. This permit is subject to revocation for cause as provided in OAR 340-14445.

ALL TN'QL ES SHOULD Be DI CTED TO:

Department of Environmental Quality

Eastern Region, Bend Office

21461*I,,l~. 4th Street, Suite 104

Bond, Olt 1101

Telephone: (541) 388. 6146

139