Permit Number: 26 . 3025• Expiration Date: 11/1/B7 Page I of 5 Pages
AIR CONTAMINANT DISCHARGE PERMIT

. De p artment 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 De p artment, fated DD.; ITsjPage 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 LevelPage 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 p liance 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.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 p i=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.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. 

### provic

l ion: 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." P26302.5I 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, o p erates 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 1979.1 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 Pul p & 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 ) ) )1 States Environmental Protection Agency's ( " EPA") im p lementing 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 t lcTh.^^.z 4 • [State of 9 in 

### rpor;,tion] corporation, owned' and. operates a flat 

### tam coating facility 10 at Beaverton, 

### Ore g 

### on. B.G. Shelter Produc = Ls opereted is Pe a eeton 11 

### facility and emitted 97 torts pf:r y 

### ear of VcX therefrom pursuant 

### to air 12 contaminant discharge p ermit .^'',o. 34-2632 _issued by the 

### a_ p ar°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 S p aulding 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

### 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 sa g e 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 q uence 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 a p artment 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 c jrnshas 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 OR D ERl 

### subject to. amendment by the Commission to ex p 

### ressly 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 p 

### ulation and Consent Final Order 6 is subject to review and approval, or disap p 

### roval by the Crmissidn and CPA. If disapproved by either, Vanply understands that .the...final or d 

### er 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 a p 

### plications 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 p osing 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

### 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 

### a p 

### ply 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 sub p aragraph . (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 E R 

### 6
8• 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: r E'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 {]AIR CONTAMINANT DISCHARGE PERMIT 

### Department of Environmental Quality 522 Southwest Fifth A g ue, 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

### 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 

### • Max .m om, 

### a

_ ^ Used Ca 2

### 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

_ ea

### GI. 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: a. Constructing or install ' any new source of air 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 forviolation 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

### 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)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 QUALI T [ ( 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 p eration 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 p retative Ruling, a'R Vol.44 No. 11, San 16, 1979.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-,000pph2). 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., . .(

### Permit Na'.: 26°3112 Expiration Date: 09-01-97

Page 1 of 2 Pages AIR CONTAMINANT DISCHARGE PERMIT Department of Environmental Q ualit Y 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 QUALI T Y 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 DatedPermit 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
PSD NSR: C'^1S 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

### 13. The source is required to submit re p orts 

## 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 r c 

### e a 

### s • j ect to federal regulations-for New source P rfo z anda ds 

### (NSP ) ,.Prevention of Signi:ficaartt Deteri or ation r ational .i.ssio> 

# Stance for .Hazardous 

### Ai:r Pollutants

ce Review 

### (MR) II. THE ALTERNATE RAC' DE ION Pursuant. to a.. source-speci 

### r fic 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 issvan c 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 SUR F

ACE COAT]NG- STA ARDS ; The surface coating RACr standards . (CAR 340-22-170) ' n'Oreg gon 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 r s. sins' unavailable. ' 17: r IHE ARC- ITECI JRAL ODATTh LZMQUE SS: Du_Ya. Industries, Enc. coats exterior alumieurr p anels ' and extrusion parts , for (hi.ghrise) cc rrercial

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

. Manufacturing Association (APP g O . speca ficati on 605..2; which requires

Peet Nor: . 26 

### . -3112 Application No.: 12047 Page 4 of 8 PagesPermit 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 Ah m 

### A 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 

### p roblems. 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

AAMN n-Attei rrrent . . Pear, . HPAG limit . Corr-cane/Lome ion Status tons /vr l.bs /cal . Moderate ?EFCO, Inc./ 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 ..

### 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 rent 

### ly 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: ' 

### Year (Date) ; ; ...# Exceedances Canc : gy m) 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.-a tectural 

### coating ' 

### s and 

### cleanup solvent usage 0.126

There is only 

### one -other 

### s mila ,r archit e 

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

-

cg lel,i,ty (or Portland ozone : .u nance plan) caused by proposed alternate pecif 3 c - 'only applies to Lora Inc.) Mild be . PACT limit (source specific .' insignificant: 

### The ozone n n-attaiznsnt status



### 'Serious E 

# r .

### 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 appro p 

### riate (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 g reet 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 Bep 

### rtaent 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•

The t '^.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 '

### Permit Number: . 26-3112 Application No. : 12047 Page 

### $of 8 Pages 

### architectural coatings that are' subject to the AAt 

### vr A 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: 6.2 tbs. , 39.3 Lbs VOC 0.1576 gal 

### gal' coating 

## solids ADDITTONP:L REQtaRl 

### `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 

### toad

s rer

_ ±: 

## 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 p osed` permit' If 'A es' of "tom al gate PACT lam t, the complianc e ' 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 ou t]: 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

### 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 Det e rmination

-.i

### 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).

Ca

Weekly Average Content by Coating at Category
• /'`y 

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

U SE ..e 

### sa Ep ieS Al nt Ps-awash Prs zee: - Ta r" 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 e 

### rm i 

### nation 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 trainin g 

### ' 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.

### 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

### Penult No.: 34-2060 Expiration Date: 8-1-97 Page 1 of 7 Pages

AIR UONTAMZNANT DISCHARGE PERMI 

### T 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 throu g h 

### 16 shall read as follows:.

### ( 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, O r egon 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

### 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. Typir e 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

## Permit Number: 34-2060 PACT Determination Page 3 , of 5 Pages

a) b) proposed coating standards are e quivalent 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 t ec h nology. 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 Topcoats b 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 proces s . Where a limit is expressed in terms of lb 11 C/gal, as applied, no limits were proposed 

## in the re-neg pro' es s, and the equivalent limit was not determined due to insufficient coating - solids content data. Transfer Efficiency

### 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 cus

p coatings for short production runs or spec'el orders. lvent Cleaning Operations The solvent cleaning' operations permit conditions are based on the Alternative Control Techni q ues Document ndustr-i_al Clean.inci Solvents (EPA-453/R 94-015) doci rent along' with the me a 

### s ur es 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 pL 

### codices . 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

### 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( "File: 

### October 4, 1995 r

V e 

# rp tn la do C : 

## 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 4 w 0 :•,,-zi: z. tiI I SW Si\th Avenue I'ortl<ind, O 

### '-1 2[)-4- '-)U 003i 22'-1-5o , n h lL)l) 4Et13) IIC?-I

### 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 of Land Use & Transportation Aloha, Oregon 97007 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) 642-6592Permit 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 32Permit 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 compoundPermit 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 None EARS D 1 EU 1.2 Carbon Concentration Condensation Unit (CCCU) PCD26
AL3 EU 1.3 None
- ALPermit 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 20.922Permit 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 - alternativesPermit 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.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 RecordkeepingPermit 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 = 53x10 6 btu/hr EU3 max capacity = I13xI0 6 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 tonslyrPermit 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 (cm 2 ) 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).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.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: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 ofoperation 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.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 shallkeep 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.).Permit No.: 34-2681 Expiration Date: 10-31-99 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.Permit No.: 34-2681 Expiration Date: 10-31-99Page 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 (1bs1I0 6 acf) Pollutant PM 14 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.Permit No.: 34-2681 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 "cm z " 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)Permit No.: 34-2681 Expiration Date: 10-31-99 Page 18 of 32 Pages

Minimum Parameter Monitoring Frequency 24,h. Weekly RACT compliance Weekly determination. "lbsVOC /cm 2 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)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.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).Permit No.: 34-2681 Expiration Date: 10-31-99 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 "cm z " 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 tothe 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.Permit No.: 34-2681 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/cm 2 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 98101Permit 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.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.Permit No.: 34-2681 Expiration Date: 10-31-99 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.Permit No.: 34-2681 •EXpiration Date: 10-31-99 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.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.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, orPermit 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.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).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

T342681Permit 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

T342681Review 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 A2 M R N Al © ^ ^ 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.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 40Review 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 ofReview 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) basedon 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 physicallyReview 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.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.gasReview Report: 34-2681 Application No.: 14659 Page 7 of 42 Pages

EU2.11 1993 93.0 n.gas

FAB5.- #8 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.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.Review Report: 342681 Application No.: 14659 Page 9 of 42 Pages
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 andReview Report: 34-2681 Application No.: 14659 Page 10 of 42 Pages 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 yetReview Report: 34-2681 Application No.: 14659 Page 11 of 42 Pages 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.Review Report: 34-2681 Application No.; 14659 Page 12 of 42 Pages
PLANT SITE 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 8.0Review Report: 34-2681 Application No.: 14659 Page 13 of 42 Pages
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 1.06Review Report: 34-2681 Application No.: 14659 Page 14 of 42 Pages 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 LowNO x 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 PM 1 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.Review Report: 34-2681 Application No.: 14659 Page 15 of 42 Pages 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 -- per year 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

### Review Report: 34-2681 Application No.: 14659 Page 16 of 42 Pages
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 CH 2 0 = 88.12 lbs per 10 12 btu heat input for EU2 bailers EF CH 2 O = 997 lbs per 10 12 btu heat input for EU3 boilersReview Report: 34-2681 Application No.: 14659 Page 17 of 42 Pages 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 (CH Z O) 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,Review Report: 34-2681 Application No.: 14659 Page 18 of 42 Pages 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 

### p CD2.2 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

### Review Report: 34-2681 Application No.: 14659 Page 19 of 42 Pages
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

### Review Report: 34-2681 Application No.: 14659 Page 20 of 42 Pages
"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

### Review Report: 34-2681 Application No.: 14659 Page 21 of 42 Pages
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

### Review Report: 34-2681 Application No.: 14659 Page 22 of 42 Pages 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

### Review Report: 34-2681 ( Application No.: 14659 Page 23 of 42 Pages
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 built### Review Report: 34-2681 Application No.: 14659 Page 24 of 42 Pages
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.

### Review Report: 34-2681 Application No.: 14659 Page 25 of 42 Pages 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 unitat the Aloha campus. This opens up the possibility of over

## C controlling (tweaking, P2, etc.) each and every positive units (already considered RACT equivalent) to a degree suchthat it. would not be considered cost excessive. Over

### controlling "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, rapidlyReview Report: 34-2681 Application . No.: 14659 Page 26 of 42 Pages 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 theVOCs emissions from the traditional (those without EBR/cuprinse) positive photoresist process. The positive processunits 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

### Review Report: 3.4--2681 Application No.: 14659 Page 27 of 42 Pages
(2X10 4 lbs VOC/cm 2 ) 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 (cm 2 ) 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 (cm 2 ) 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 solventReview Report: 34-2681 Application No.: 14659 Page 28 of 42 Pages 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 flexibilityto 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;

### Review Report: 34-2681 Application No.: 14659 Page 29 of 42 Pages 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.

### Review Report.: 34-2681 Application No.: 14659 Page 30 of 42 Pages
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

### Review Report: 34

_ 2681( Application No.: 14659 Page 31 of 42 Pages 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.Review Report: 34-2681 Application No.: 14659 Page 32 of 42 Pages
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 investigationsas 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.

### Review Report: 34-2681 Application No.: 14659 Page 33 of 42 Pages
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 monitoringassociated 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/ft 3 ) x Fd 

### = 9.15 x 106 dscf where Fd = 8,710 dscf/10 6 btu

### Review Report: 34-2681 Application No.: 14659 Page 34 of 42 Pages 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 7000 

### grab 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 inReview Report: 34-2681 Application No.: 14659 Page 35 of 42 Pages 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 LowNO X 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

### Review Report: 34-2681 Application No.: 14659 Page 36 of 42 Pages 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 actualproduction. 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 thenReview 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 performReview 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/cm 2 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.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.Review Report; 34-2681 Application No.: 14659 Page 40 of 42 Pages
NON-APPLICABLE REQUIREMENTSPursuant 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: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.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\T342681RBASELINE; 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 ProgramPLANT 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 ......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 0.000PLANT 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 1.06PLANT 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 = O8 3.393 ='666== 8.487 0.302 9 0.605 0.192 5.044 1.059 0.192- BOILER DATA ENTRY SHEET -

FUEL USAGE SUMMARY

BOILER MAX. HR. CAPACITY 10E+6 btu YEAR

INSTALLED ANNUAL GAS USAGE ANNUAL OIL USAGE (gallons/year) (therms/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 _ 29.26 T 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- 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 * NOx 0.000 ' 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) , `000

* NOx 0.000 HOURLY I lb/1993 VOC EMISSIONS SUMMARY PERMIT NUMBER: 34-2681 APPLICATION NUMBER: 14659

PAGE: A8

- BIMONTHLY VOC EMISSIONS - tons/61monthElMONTH

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 d9 .z 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.

### Permit Number: 34-2681 Application No.: 14659

Page: A9

Table 1 Control Equipment and Control Efficiencies VOC Contro'I E q uipment 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 - 95 11 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." •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.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. 1.10 0.4235 38.51

Small Solvent Acetone 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
1.86 0.0824 4.43



### Degreaser IPA 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.Permit Number: 34-2681 Application No.: 14659

Page: A12

TEST SOURCE/STACK USAGE CHEMICAL (LB/HR) , EMISSIONS
, (LB/HR) %EVAP Degreaser 0.0027 0.51

HMDS 0.53 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. 12.48 0.2037 1.63

Solvent Hood Acetone

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. 0.93 0.2606 28.03

Solvent Hood Acetone

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.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- 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(

### 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

### 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.).Penuit No,» 19-01)02 Expiration Date; 11-1-2002

Page 1 of6 Pages

AM CONTAMINANT DISCHARGE PERMIT Depa r tment 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 peovisl g ns 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 4961Permit 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 T41 11 S AND 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, for sources 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' Partieulatee i 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. 7. The permittee shall minimize fugitive dust omissions by: 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,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 WEI MMEN 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 (1 400,000,000 pounds of steam 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.1 errmit T u la.: 19-0002 l t;pittion Data; 11-1-2002 Page 4 of b' Pages
MCNrro p

aNOIEQUI1 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^ 

## c ON 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,Permit Ne i : 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 g s 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 activit y or facility. Applicable Permit Foes mast be submitted with an application for the name c flange.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