Issuance Date: March 16, 2001 

 Effective Date: April 1, 2001 

 Expiration Date: March 16, 2006 

AIR OPERATING PERMIT 000012-4 

In compliance with the provisions of The State of Washington 

Clean Air Act Chapter 70.94 Revised Code of Washington 

Weyerhaeuser Company

P.O. Box 188

Longview, Washington 98632

including 

North Pacific Paper Corporation 

P.O. Box 2069 

Longview, Washington 98632

are authorized to operate in accordance with the terms and conditions 

of this permit. 

Issued by: 

 

State of Washington 

DEPARTMENT OF ECOLOGY 

300 Desmond Drive 

P.O. Box 47600 

Olympia, Washington 98504-7600 

______________________________ ______________________________ 

Carol Kraege, P.E. Robert D. Carruthers, P.E. 

Industrial Section Supervisor Environmental Engineer 
2 

Table of Contents

INTRODUCTION AND LEGAL AUTHORITY ......................................................................... 3 

EMISSION UNIT SPECIFIC REQUIREMENTS ........................................................................ 4 

NORPAC 

A. ONP Baghouse.....................................................................................................................4 

 NORPAC I, II ......................................................................................................................5 

 NORPAC III ...................................................................................................................... 5 

KRAFT MILL................................................................................................................................ 6 

B. Fiberline ...................................................................................................................6 

C. Volatile Organic Liquid Storage Vessels.................................................................7 

D. East Powerhouse ......................................................................................................7 

E. Power Boiler #11 .....................................................................................................7 

F. Package Boiler (shutdown Feb 28, 2000)................................................................7 

G. Power Boilers 6, 7, 9................................................................................................8 

H. Recovery Furnace #10 .............................................................................................8 

I. Smelt Dissolving Tank...........................................................................................10 

J. NCG System ..........................................................................................................11 

K. Lime Kiln...............................................................................................................13 

L. Slaker Vent .......................................................................................................... 14 

 

NSPS GENERAL REQUIREMENTS...........................................................................................15 

NESHAPS STANDARDS.............................................................................................................15 

FACILITY-WIDE REQUIREMENTS..........................................................................................16 

MONITORING, RECORDKEEPING & REPORTING ............................................................ 19 

STANDARD TERMS & CONDITIONS.................................................................................... 21 

PERMIT SHIELD........................................................................................................................ 23 

Appendix A -- Permit Shield/Inapplicable Requirements ........................................................... 23 

Appendix B-- Definitions of Abbreviations Used in Permit ....................................................... 26 

Appendix C -- Algorithms for Emission Calculations................................................................. 27 

Appendix D -- Regulatory Orders ............................................................................................... 28 
3 

INTRODUCTION AND LEGAL AUTHORITY 

This Air Operating Permit is authorized under the Operating Permit Regulation, Chapter 173-

401 WAC. The provisions of this permit describe the emissions limitations, operating 

requirements, monitoring and recording requirements, and reporting frequencies for the 

permitted source. 

Weyerhaeuser Company requires a Title V Air Operating Permit because it emits or has the 

potential to emit, one hundred tons per year or more of one or more air pollutants (WAC 173-

401-300(1)). North Pacific Paper Corporation (NORPAC) is included in this permit because it is 

a 50/50 joint venture between Weyerhaeuser Company and Nippon Paper Corporation, is 

physically contiguous to the Weyerhaeuser Company facility, and is under common control of 

the Weyerhaeuser Company. The terms ìaffected facilityî or ìpermitted facilityî as used in this 

Permit refer to Weyerhaeuser Company and include NORPAC. 

During the drafting of this permit Ecology has attempted to incorporate requirements using the 

exact language of the law, regulation or order. In some cases, this has not been possible. Where 

there is a difference in language, this difference is presented in this permit only for clarification 

of the underlying requirement. The legal requirement remains the underlying applicable 

requirement cited in the ìApplicable Requirementsî column of the tables and the citations 

contained in brackets at the end of each requirement. Any conflict between the permit and an 

underlying requirement will be resolved by referring to the cited applicable requirement. Unless 

otherwise stated, the effective date of referenced regulations or statutes is that of the provision in 

effect on the date of permit issuance. 

The Title V Air Operating Permit consists of all parts of this assembled document including all 

Appendices, but does not include the accompanying Support Document 

The definition of terms contained in WAC 173-401-200, and as defined in all referenced 

regulations, apply to this permit unless otherwise defined in the permit. 

Any federal test method referenced, unless specifically stated otherwise within the body of the 

permit, is that which is contained in 40 CFR Part 60, Appendix A. Any state test method 

referenced, unless specifically stated otherwise within the body of the permit is that which is 

contained in the ìEcology Source Test Manualî as of July 12, 1990. 
4 

EMISSION UNIT SPECIFIC REQUIREMENTS [WAC 173-401-600] 

 The emission units identified in conditions A through I are subject to the emission unit 

specific requirements set forth in conditions A through I. These units are also subject to the 

facility-wide applicable requirements. The associated monitoring, record keeping and reporting 

requirements for these limits are in the Facility-Wide section of this permit. Unless specified 

otherwise, the basis of authority for the type and frequency of monitoring imposed in conditions 

A through I is WAC 173-401-615. 

The reference test method (RM) or compliance determination algorithm is identified under the 

column titled, ìMonitoring and Reportingî. The identified reference test method or compliance 

determination algorithm is that compliance determination method which is intended to be the 

default or absolute determinant of compliance. It may or may not also be the method by which 

ongoing compliance is indicated. 

Refer to Appendix C for emission estimate algorithms. These algorithms set forth the manner by 

which emissions are calculated for those requirements for which the Reference Method itself 

does not directly result in an emission estimate. Unless otherwise required by the applicable 

requirement, minor modifications to the test method may be used with the advanced approval of 

Ecology. Failure to obtain prior written approval for any test changes may invalidate the use of 

the test result(s) for Title V compliance purposes. 

 

The Permitted facility includes emission units that are subject to EPA New Source Performance 

Standards at 40 CFR Part 60 Subpart A and Subpart BB. These standards are set forth as generic 

stand-alone conditions in the section of the permit titled ìNSPS General Requirements.î

Emission units subject to NSPS requirements cross reference the specific applicable NSPS 

standards. 

North Pacific Paper Corporation (NORPAC) 

A. NORPAC ONP Baghouse

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

A.1 Particulate 0.005 gr/dscf At least every 5 years using reference test 

method EPA Method 5 (front half) or Method 

17. Conduct a minimum of three test runs. 

Submit annual emissions estimate. See 

Support Document 

 Order No. DE 98AQ-I046 

A.2 Operations Not applicable Maintain log of baghouse O&M activities. Order No. DE 98AQ-I046 
5 

A. NORPAC I and II (Principal sources of emissions are Rotary Valve Vents (9), 

Startup Scrubber Vent, Deink Spray Condenser Exhaust, Bleach Tower Exhaust (2), TMP 

Decker Exhausts, Paper Machine No. 1 Vacuum Vents, Wet End Vents and Exhausts, and 

Dryer Vents, Paper Machine No. 2 Vacuum Vents, Wet End Vents and Exhausts, and 

Dryer Vents. 

Parameter Limit

(shall not 

exceed)

Monitoring & Reporting Applicable 

Requirements

A.3 VOCs 9,636 lbs/day The reference test method and ongoing

compliance indicator is the summation of 

daily production rates multiplied by 

appropriate daily emission factors contained 

in Table 1 of PSD 97-01 

PSD-97-01 Condition 2 

A.4 VOCs 862 tons per 

year. (Total of 

approved annual 

rate of emissions 

identified in 

applicable 

requirements) 

The reference test method and ongoing 

compliance indicator is the summation of 

monthly calculated emission rates. Monthly 

emissions are calculated by multiplying 

monthly TMP and Paper Machine production 

values by appropriate emission factors from 

Table 1 of PSD-97-01. 

PSD-97-01 Condition 3 

(830 tons), Order DE 

95AQ-I076 (6tons), Order 

DE 96AQ-I093 (26 tons) 

A.5 CO 84 tons/year. 

(Total of 

approved annual 

rate of emissions 

identified in 

applicable 

requirements) 

The reference test method and ongoing 

compliance indicator is the summation of 

monthly calculated emission rates over the 

calendar year. Monthly emissions calculated 

by multiplying monthly TMP II production 

values by appropriate emission factors from 

Table 2 of PSD-97-01. 

81 tons allowed by PSD97-01 Condition 4 affecting 

only TMP lines 5,6,7,8,9 

and Paper Machine #2. 3 

tons resulting from Order 

DE 96AQ-I093 affecting 

all TMP lines.

A.6 The Permittee shall conduct source test of the NORPAC I and II units for VOC and CO, 

 to be performed by an independent testing firm per Conditions 5 and 6 of PSD -97-01. 

A.7 Per Condition 7 of PSD-97-01, the Permittee shall maintain records of emissions 

calculations, which will include production rates, the quantities of high brightness and normal 

brightness pulp produced during the month, the approximate percentages wood species types 

pulped during the month, the number of hours each month that pulp was produced while the 

Reboiler was down and the appropriate emission factors from Tables 1 and 2 of PSD-97-01. 

Weyerhaeuser shall report the monthly cumulative total VOC and CO emissions, in units of the 

standard, to Ecology in the ìmonthly air report.î 

A.8 The Permittee shall report each occurrence of excess emissions in accordance with 

Condition 8 of PSD-97-01. 

A. NORPAC III 

A.9 The Permittee shall maintain records of gross production (ADMT) from, and natural gas 

(cubic feet) consumed by, #3 Paper Machine Air Cap Dryer System and use as applicable in 

estimating air contaminant emission rates per Condition 4 of Order DE 97AQ-I041. 
6 

Weyerhaeuser Company 

KRAFT MILL

B. Fiberline (MCC Digester, No. 6 Bleach Plant, No. 8 MEE, High Solids Crystalizer, 

Washing and Screening facilities, Condensate Stripper) 

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

B.1 CO 349 lbs/hour and 300 tons per 

year (measured at bleach plant 

scrubber stack and oxygen 

delignification vent) 

The Reference Test Method and initial 

compliance determinant is EPA RM 10 at 

the bleach plant scrubber outlet and oxygen 

delignification vent. See Support 

Document. 

PSD 92-03 amendment 4 

Condition 1, Order DE 

92AQ I069 

B.2 TRS 5.0 ppmdv @ 10% O2, 12 

hour avg. 

Reference Test Method and compliance 

indicated by continuous collection and 

combustion of collected sources. 

Monitoring is accomplished through 

Condition J.4. 

40 CFR 60.283(a)(1) 

for limit. 

B.3 Reserved for future use. 

B.4 The preceeding fiberline units are subject to the NSPS requirements identified in the 

stand-alone generic NSPS section of this permit. 

The following state-only requirement is not federally enforceable under the federal 

Clean Air Act and is applicable to Digester, multiple-effects evaporators, condensate 

stripper system: 

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

B.5 TRS Treat noncondensible gas 

(NCG) to reduce TRS 

emission equal to reduction 

achieved by thermal oxidation 

in a lime kiln; install a backup 

treatment system 

Record number of hours system vents each 

month. Report periods of untreated 

venting. 

WAC 173-405-

040(4) 
7 

C. Volatile Organic Liquid Storage Vessels. (This condition is generic to the recent 

Industrial Section pulp and paper Title V permits. It is not currently applicable to 

Weyerhaeuser as the Permittee states no tanks are in use on site meeting the 

applicable criteria. It becomes applicable if triggered.) 

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

C.1 Recordkeeping 

Not Applicable The Permittee shall keep records showing the 

dimensions and capacities of all storage vessels 

having capacities greater than or equal to 40 cubic 

meters that are used to store volatile organic 

liquids and for which construction, reconstruction, 

or modification commenced after July 23, 1984. 

These records are to be kept for the life of each 

storage vessel. 

40 CFR 

60.116b (a) and 

(b) 

D. East Powerhouse Boilers (Officially Shutdown in 1998) 

E. Hogged Fuel Boiler #11 

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

E.1 Particulate 0.05 gr/dscf @ 7% 

O2. 

EPA RM 5 is the reference test method. 

Sample quarterly using EPA RM 5 [note 

1: the particulate emission limit is only 

applicable to the front half catch.] Report 

test results in next monthly report. 

WAC 173-400-091 for 

particulate limit 

implemented through Order 

DE 94AQ-I080. 

E.2a Particulate 0.2 gr/dscf @ 7% O2. EPA RM 5 is the reference test method. 

Sample quarterly using EPA Method 5. 

Report test results in next monthly report. 

WAC 173-405-040(5)(a) 

E.2b Particulate 0.10 lb per MMBtu EPA RM 5 is the reference test method. 

Sample quarterly using EPA Method 5. 

Report test results in next monthly report. 

Keep records of type and quantity of fuels 

used. 

40 CFR 60.42(a)(1) 

E.3a Opacity Average 20% for 

more than 6 

consecutive minutes 

in any 60 minute 

period, except for 

emissions due to soot 

blowing or grate 

cleaning for up to 15 

minutes in 8 

consecutive hours. 

EPA RM 9 is the reference test method. 

Monitor continuously using an approved 

COM. Report excursions monthly. 

Maintain COM in accordance with 40 

CFR Part 60.13(d). 

WAC 173-405-040(6) for 

opacity limit. 

E.3b Opacity ≤ 20% except for one 

6-minute period per 

hour of not more than 

27%. 

Reference Test Method is EPA RM 

Method 9. Monitor continuously using a 

COM that conforms to 40 CFR Pt. 60 

(July 1, 1992), App. F and App. B, Perf. 

Spec. 1. Report excursions monthly. 

40 CFR 60.42(a)(2) 
8 

E.4 SO2 1000 ppm @ 7% O2, 

hourly average. 

Reference Test Method is EPA RM 6. 

Ongoing compliance indicated by 

maintaining fuel oil sulfur content less 

than or equal to 2%. Record of sulfur 

content of each shipment will be 

maintained. See Support Document.

WAC 173-405-040(11)(b) 

E.5 SO2 0.80 lb per MMBtu 

(derived from liquid 

fossil fuel or liquid 

fossil fuel and wood 

residue) 

Reference Test Method is EPA RM 6. 

Monitor continuously using a COM that 

conforms to 40 CFR Pt. 60 (July 1, 1992), 

App. F and App. B, Perf. Spec. 2 or by 

fuel sampling and analysis as allowed by 

40 CFR 60.45(b)(2). Keep records of type 

and quantity of fuels used. Report 

excursions monthly.

40 CFR 60.43(a)(1) 

E.6 SO2 1.2 lb per MMBtu 

(derived from solid 

fossil fuel or solid 

fossil fuel and wood 

residue) 

Reference Test Method is EPA RM 6. 

Monitor continuously using a COM that 

conforms to 40 CFR Pt. 60 (July 1, 1992), 

App. F and App. B, Perf. Spec. 2 or by 

fuel sampling and analysis as allowed by 

40 CFR 60.45(b)(2). Keep records of type 

and quantity of fuels used. Report 

excursions monthly.

40 CFR 60.43(a)(2) 

E.7 SO2 (0.8y +1.2z)/ (y +z) 

lb per MMBtu. 

(derived from 

burning a mixture of 

liquid and solid fossil 

fuel) 

Reference Test Method is EPA RM 6. 

Monitor continuously using a COM that 

conforms to 40 CFR Pt. 60 (July 1, 1992), 

App. F and App. B, Perf. Spec. 2 or by 

fuel sampling and analysis as allowed by 

40 CFR 60.45(b)(2). Keep records of type 

and quantity of fuels used. Report 

excursions monthly.

40 CFR 60.43(b) which 

also defines the variables y 

and z. 

E.8 NOx 0.30 lb per MMBtu 

(derived from liquid 

fossil fuel or liquid 

fossil fuel and wood 

residue) 

Reference Test Method is EPA RM 7. 

Monitor continuously using a continuous 

monitoring system that conforms to 40 

CFR Pt. 60 (July 1, 1992), App. F and 

App. B, Perf. Spec. 2 if required per 40 

CFR 60.45(b)(3). Keep records of type 

and quantity of fuels used. Report 

excursions monthly. 

40 CFR 60.44(a)(2) 

E.9 NOx 0.70 lb per MMBtu 

(derived from solid 

fossil fuel or solid 

fossil fuel and wood 

residue) 

Reference Test Method is EPA RM 7. 

Monitor continuously using a continuous 

monitoring system that conforms to 40 

CFR Pt. 60 (July 1, 1992), App. F and 

App. B, Perf. Spec. 2 if required per 40 

CFR 60.45(b)(3). Keep records of type 

and quantity of fuels used. Report 

excursions monthly. If a COM is not 

required test performance once per permit 

term using RM 7.

40 CFR 60.44(a)(3) 
9 

E.10 NOx (0.30x + 0.70y)/(x + 

y) lb per MMBtu 

(derived from solid 

fossil fuel, liquid 

fossil fuel and wood 

residue) 

Reference Test Method is EPA RM 7. 

Monitor continuously using a continuous 

monitoring system that conforms to 40 

CFR Pt. 60 (July 1, 1992), App. F and 

App. B, Perf. Spec. 2 if required per 40 

CFR 60.45(b)(3). Keep records of type 

and quantity of fuels used. Report 

excursions monthly.

40 CFR 60.44(b) which 

also defines the variables y 

and z. 

F. Package Boiler (shutdown on Feb 28, 2000)(150,000 pounds/hour steam capacity). 

G. Power Boilers 6, 7, 9 

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

G.1 Particulate 0.1 gr/dscf @ 7% 

O2

Reference Test Method is EPA RM 5. 

Maintain records of type of fuel usage. See 

Support Document. 

WAC 173-405-040(5)(c) 

G.2 Opacity 20% for more than 

6 consecutive 

minutes in any 60 

minute period 

except for soot 

blowing per WAC 

173-405-040(6) 

Reference Test Method is EPA RM Method 

9. Perform visual opacity assessment shortly 

after startup at least once per week when 

firing oil. Record visual assessment. Report 

exceedances monthly. 

WAC 173-405-040(6) 

G.3 SO2 1000 ppm @ 7% 

O2 hourly average. 

Reference Test Method is EPA RM 6. 

Ongoing compliance indicated by 

maintaining fuel oil sulfur content less than 

or equal to 2%. Record of sulfur content of 

each shipment will be maintained. See 

Support Document.

WAC 173-405-040(11) 

H. Recovery Furnace No. 10 (as measured in the main stack)

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

H.1 PM 0.027 gr/dscf @ 

8% O2. 

Sample quarterly using reference test method 

DOE Method 5. Report average of three 1-hr 

runs monthly. 

PSD92-03 amend 4 

Condition 2; Order DE 92 

AQ-I069 for particulate 

limit. 

H.2 PM 0.044 gr/dscf @ 

8% O2. 

Sample quarterly using reference test method 

DOE Method 5. Report average of three 1-hr 

runs monthly. 

Case-by-case MACT 

determination, 40 CFR 

63.55(b)(4), proposed 

MACT standard 40 

CFR 63.862(a) and 

proposed monitoring 40 

CFR 63.864(a)(2) (63 

Fed. Reg. 18753, 18784 

(April 15, 1998).
10 

H.3 PM 0.10 gr/dscf @ 8% 

O2. 

Sample quarterly using reference test method 

DOE Method 5. Report average of three 1-

hr runs monthly. 

WAC 173-405-040(1)(a) 

and for particulate limit. 

H.4 PM 0.020 gr/dscf @ 

8% O2 annually. 

The reference method is the averaging of the 

quarterly RM (DOE Method 5) tests. 

PSD92-03 amend 4 

Condition 2 for particulate 

limit; Order DE 92 AQI069. 

H.5 PM 252 tons per year The reference test method is set forth in 

Appendix C. Report annual emissions in 

January air report of following year. 

PSD92-03 amend 4 

Condition 2 for particulate 

limit; Order DE 92 AQI069. 

H.6 PM10 0.027 gr/dscf @ 

8% O2. 

Sample quarterly using reference test method 

DOE Method 5. Report average of three 1-

hr runs monthly. See Support Document. 

PSD92-03 amend 4 

Condition 3; Order DE 92 

AQ-I069. 

H.7 PM10 0.020 gr/dscf @ 

8% O2 annually. 

The reference method is the averaging of the 

quarterly RM (DOE Method 5) tests. 

PSD92-03 amend 4 

Condition 3; Order DE 92 

AQ-I069. 

H.8 PM10 252 tons per year The reference test method is set forth in 

Appendix C. Report annual emissions in 

January air report of following year. 

PSD92-03 amend 4 

Condition 3; Order DE 92 

AQ-I069. 

H.9 Opacity 20% Reference Test Method is EPA RM Method 

9. Monitor continuously using a COM that 

conforms to 40 CFR Pt. 60 (July 1, 1992), 

App. F and App. B, Perf. Spec. 1. Report 

exceedances monthly. 

PSD92-03 amend 4 

Condition 4; Order DE 92 

AQ-I069. 

H.10 Opacity 35% Reference Test Method is EPA RM Method 

9. See Condition H9 for ongoing 

monitoring.

WAC 173-405-040(6) for 

the limit. 

H.11 SO2 75 ppm @ 8% O2, 

3-hour average 

(when not using 

supplemental oil 

or when using 

supplemental oil 

and BLS firing 

rate > 120,000 

lbs/hr). 

The compliance reference test method and 

ongoing monitoring method is the continuous 

use of a CEM that conforms to 40 CFR Pt. 60 

(July 1, 1992), App. F and App. B, Perf. 

Spec. 2. Report results monthly. 

PSD92-03 amend 4 

Condition 5.1; Order DE 

92 AQ I069 

H.12 SO2 500 ppm @ 8% 

O2, 3-hour average 

(when BLS firing 

rate < 120,000 

lbs/hr and firing 

supplemental oil). 

The compliance reference test method and 

ongoing monitoring method is the continuous 

use a CEM that conforms to 40 CFR Pt. 60 

(July 1, 1992), App. F and App. B, Perf. 

Spec. 2. Report results monthly. 

PSD92-03 amend 4 

Condition 5.2; Order DE 

92 AQ I069 

H.13 SO2 1000ppm @ 10% 

O2, hourly avg 

(when firing oil) 

Reference Test Method is EPA RM 6. 

Ongoing compliance indicated by 

maintaining fuel oil sulfur content less than 

or equal to 2%. Record of sulfur content of 

each shipment will be maintained. See 

Support Document. 

WAC 173-405-040(11)(b) 
11 

H.14 SO2 586 tpy + 0.036 

tpy for each hr 

operation of the 

NCG incinerator. 

The combined 

total not to exceed 

884 tpy. 

The reference test method is set forth in 

Appendix C. Report annual emissions in 

January air report of following year. 

PSD92-03 amend 4 

Condition 5. Order DE 92 

AQ I069 

H.15 TRS 5.0 ppmdv@8.0% 

O2 12-hr average

Reference Test Method is EPA RM 16 or 

16A. Ongoing compliance indicated by

continuous use of a CEM that conforms to 40 

CFR Pt. 60 (July 1, 1992), App. F and App. 

B, Perf. Spec. 5. Report results monthly. 

PSD92-03 amend 4 

Condition 6; Order DE 92 

AQ I069, WAC 173-405-

040(1)(c), and for limit 

H.16 TRS 31 tpy The reference test method is set forth in 

Appendix C. Report annual emissions in 

January air report of following year. 

PSD92-03 amendment 4 

Condition 6; Order DE 92 

AQ I069. 

H.17 NOx 140 ppmdv @ 

8.0% O2, 24 hr 

average. 

Reference Test Method is EPA RM 7, 

7A,7B, or 7E. Ongoing compliance 

indicated by continuous use of a CEM that 

conforms to 40 CFR Pt. 60 (July 1, 1992), 

App. F and App. B, Perf. Spec. 2. Report 

results monthly. 

PSD92-03 amendment 4 

Condition 7,Order DE 92 

AQ I069. 

H.18 NOx 1,179 tpy annual 

average 

The reference test method is set forth in 

Appendix C. Report annual emissions in 

January air report of following year. 

PSD92-03 amend 4 

Condition 7; Order DE 92 

AQ I069. 

H.19 CO 1,000 ppmdv 1-hr 

average

Reference Test Method is EPA RM 10. Initial source testing; no on-going monitoring 

required by this permit . See Support 

Document for unit emissions history. 

PSD92-03 amend 4 

Condition 8; Order DE 92 

AQ-I069. 

H.20 CO 2,564 tpy The reference test method is set forth in 

Appendix C. Initial source testing; no ongoing monitoring required by this permit . 

See Support Document for unit emissions 

history. 

PSD92-03 amend 4 

Condition 8; Order DE 92 

AQ-I069. 

H.21 VOC 50 ppmdv 1-hr 

average

Reference Test Method is EPA RM 25, 25A, 

or 25B. Initial source testing; no on-going 

monitoring required by this permit See 

Support Document for unit emissions history. 

PSD92-03 amend 4 

Condition 9; Order DE 92 

AQ-I069. 

H.22 VOC 201 tpy Reference Test Method is EPA RM 25, 25A, 

or 25B. Initial source testing; no on-going 

monitoring required by this permit . See 

Support Document for unit emissions history. 

PSD92-03 amend 4 

Condition 9; Order DE 92 

AQ-I069. 

H.23 Temp. at 

of 

entrance 

to No. 10 

recovery 

boiler ESP 

≤ 500 degrees F, 

hourly average 

Monitored continuously using thermocouple 

at ESP entrance. Report only exceedances of 

hourly average in monthly report. 

PSD -92-03 amend 4 

Condition 10; Order 

92AQ-I069
12 

I. Smelt Dissolver Tank Vent 

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

I.1 PM 0.20 lb/TBLS Sample quarterly using EPA Reference 

Method 5 as the reference test method. 

Report test results in next monthly report. 

Case-by-case MACT 

determination, 40 CFR 

63.55(b)(4), proposed 

MACT standard 40 CFR 

63.862(a) and proposed 

monitoring 40 CFR 

63.864(a)(2) (63 Fed. 

Reg. 18753, 18784 

(April 15, 1998).

I.2 Reserved 

I.3 PM 0.30 lb/TBLS Sample quarterly using EPA Reference 

Method 5 as the reference test method. 

Report test results in next monthly report. 

WAC 173-405-040(2) 

I.4 PM10 0.120 lb/TBLS Sample quarterly using EPA Reference 

Method 5 as the reference test method. 

Report test results in next monthly report. 

PSD92-03 amend 4 

Condition 14; Order DE 

92 AQ-I069 for PM10 

limit.

I.5 PM10 62.0 tons per year The reference test method is set forth in 

Appendix C. Report annual emissions in 

January air report of following year. 

PSD 92-03 amend 4 

Condition 14; Order DE 92 

AQ-I069. 

I.6 Opacity 20 % for more 

than 6 consecutive 

minutes in any 60 

minute period. 

EPA Reference Method 9 is the reference test 

method. 

PSD 92-03 amend 4 

Condition 15; Order DE 92 

AQ-I069 for opacity limit. 

I.7 Opacity Average 35% for 

more than 6 

consecutive 

minutes in any 60 

minute period. 

EPA Reference Method 9 is the reference test 

method. 

WAC 173-405-040(6) 

I.8 TRS 0.0168 lb/TBLS Sample quarterly using EPA RM 16 or 16A. 

Report average of three 1-hr runs in monthly 

report. After limit exceedance, sample 

monthly until limit met for three consecutive 

months then resume quarterly tests. 

PSD 92-03 amend 4 

Condition 16; Order DE 

92AQ-I069. 

I.9 Black 

Liquor 

Feed Rate 

Not applicable Record Black Liquor (TBLS) feed rate. PSD 92-03 amend 4 

Condition 16; Order DE 

92AQ-I069. 

I.10 TRS 9.0 tpy The reference test method is set forth in 

Appendix C. Report annual emissions in 

January air report of following year. 

PSD 92-03 amend 4 

Condition 16; Order DE 

92AQ-I069. 
13 

J. Noncondensible Gas (NCG) Collection & Treatment

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

J.1 Opacity 20%, 6 minute avg 

in any sixty 

minute period. 

None because exhaust is vented to RF stack. WAC 173-405-040(6) 

J.2 TRS ñ 

High 

Conc. 

NCG 

(Digester; 

evaporator

s; foul 

condensate 

stripping) 

Treat by 

incineration or its 

equivalent. 

Continuously monitor and record high 

concentration NCG venting from high 

concentration NCG header vent to recovery 

boiler stack (i.e., not being treated in 

incinerator or kiln). Report times, duration 

and causes of venting in monthly air report. 

PSD 92-03 amend 4 

Condition 11, WDOE 

92AQ I069 

J.3 TRS ñ 

Low Conc. 

NCG 

(Chip bin; 

blow 

tanks; 

brownstoc

k press, 

filtrate 

tanks,; 

O2 delig.; 

black 

liquor 

tanks D-J) 

Treat by 

incineration or its 

equivalent. 

Continuously monitor and record low 

concentration NCG venting from chip bin, 

fiberline roof vent, 24î standpipe, and 

conbined LC-NCG vent to recovery boiler 

stack (i.e., not being treated in incinerator). 

Report times, duration and causes of venting 

in monthly air report. 

PSD 92-03 amend 4 

Condition 11, WDOE 

92AQ I069 

J.4 TRSñ NCG 

(All sources 

listed in J.2 

and J.3) 

Incinerator 

performance: 

5.0 ppmdv @ 10% 

O2, 12 hour avg. 

Reference Test Method is EPA Method 16 or 

16A. Compliance indicated by maintaining 

12 hour average combustion temperature at 

the point of incineration ≥ 1350 F. 

PSD 92-03 amend 4 

Condition 12; Order DE 92 

AQ I069 

J.5 TRSñNCG, 

NSPS Units 

(Digester, 

flash tanks, 

blow tanks, 

brownstock 

washing, 

MEE #8, 

HSC, Foul 

Condensate

Stripper) 

Incinerator /Kiln 

performance while 

combusting NCG 

from NSPS units: 

a. Incinerator 

Combustion 

temp >1200F 

for at least 0.5 

second 

b. Lime Kiln 

TRS ≤ 8 ppmdv 

@ 10% O2, 12 

hour average 

(see Section K)

a. Continuously monitor combustion 

temperature. Excess emissions defined as 

ìall periods in excess of 5 minutes and 

their duration during which the 

combustion temperature at the point of 

incineration is less than 1200Fî. Report 

time, cause and duration of excess 

emission periods monthly. 

b. Lime Kiln: See Condition K.7 for 

monitoring requirement. 

40 CFR 60.283(a)(1)(iii)

for limit at incinerator. 40 

CFR 60.284(b)(1) for 

temperature monitoring 

Lime Kiln requirements 

cited in Condition K. 

J.6 Reserved 
14 

J.7 SO2 300 ppm @ 7% 

O2 hourly avg..

Reference Test Method is EPA Method 6. 

Compliance indicated by maintaining hourly 

average scrubber pH above 6.5. Record pH 

continuously. Report exceedances monthly. 

PSD 92-03 amend 4 

Condition 13; Order DE 92 

AQ I069 

J.8 SO2 1000ppm @ 7% 

O2, hourly avg. 

Reference Test Method is EPA Method 6. 

Compliance indicated by maintaining hourly 

average scrubber pH above 6.0. Record pH 

continuously. Report exceedances monthly. 

WAC 173-405-040(11)(b) 

J.9 Reserved for future use.

J.10 Reserved for future use. 

J.11 The NCG collection and treatment system is subject to the NSPS requirements identified 

in the stand-alone generic NSPS section of this permit.

K. Lime Kiln 

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

K.1

.a 

PM 0.035 gr/dscf @ 

10% O2 (gas fired) 

0.07 gr/dscf @ 

10% O2 oil fired. 

Sample quarterly using reference test method

EPA Method 5. Report average of three 1-

hour tests. 

Order DE 95AQ-I035 for 

particulate limit. 

K.1

.b 

PM 0.067 gr/dscf @ 

10% O2 

Same as above. Case-by-case MACT 

determination, 40 CFR 

63.55(b)(4), proposed 

MACT standard 40 CFR 

63.862(a) and proposed 

monitoring 40 CFR 

63.864(a)(2) (63 Fed. 

Reg. 18753, 18784 

(April 15, 1998).

K.2 PM 0.067 gr/dscf @ 

10% O2 (gas). 0.13 gr/dscf @ 

10% O2 (liquid 

fossil fuel) 

Sample quarterly using reference method EPA 

Method 5. Report average of three 1-hour 

tests. 

WAC-173-405-040(3)(a), 

40 CFR 60.282(a)(3) 

K.3 Reserved for future use. 

K.4 Reserved for future use. 

K.5 Opacity Average 25% for 

more than 6 

consecutive 

minutes in any 60 

minute period. 

EPA Test Method 9 is reference test method. 

Monitor continuously using a COM that 

conforms to 40 CFR Pt. 60 (July 1, 1992), 

App. B, Perf. Spec. 1. Report exceedances 

monthly. 

Order DE 95AQ-I035 

K.6 Opacity Average 35% for 

more than 6 

consecutive 

minutes in any 60 

minute period. 

EPA Test Method 9 is reference test method. 

See Condition K5 for ongoing monitoring. 

WAC 173-405-040(6) 
15 

K.7 TRS 8.0 ppmdv @ 10% 

O2, 12 hour avg. 

EPA Test Method 16 or 16A is reference test 

method. Monitor continuously using a CEM 

that conforms to 40 CFR Pt. 60 (July 1, 

1992), App. B, Perf. Spec. 5. Report results 

monthly. 

DE 95AQ-I035 and 40 

CFR 60.283(a)(5) for limit. 

40 CFR 60.284(a)(2) for 

CEM. 40 CFR 

60.284(c)(1),(3) for 

monitoring. 40 CFR 

60.284(d)(2) for 

reporting except that 

excess emissions 

reported monthly.

K.8 O2 Not Applicable Record 12 hour average on daily basis. 40 CFR 60.284(c)(2) for 

monitoring 

K.9

a 

SO2 500ppm @ 10% 

O2, hourly avg. 

Sample at Ecologyís request using reference 

test method EPA RM 6 or 6A. Report results 

monthly. See Condition K.9b for minimum 

O&M requirements intended to indicate 

compliance. 

WAC 173-405-040(11)(a) 

K.9

b 

No usage of pulp mill evaporator condensates to wash lime mud. Minimize introduction of sulfur compounds 

in washing of lime mud. See Support Document for emission history. 

K.10 The Lime Kiln is subject to the NSPS requirements identified in the stand-alone generic 

NSPS section of this permit.

K.11 Reserved for future use. 

K.12 The following state-only requirement is not federally enforceable under the federal 

Clean Air Act: 

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

K.12a TRS 80 ppm as H2S for 

no more than 3 

consecutive hours 

in any one day 

Monitor continuously using an approved 

CEM that conforms to 40 CFR Pt. 60 (July 1, 

1992), App. B, Perf. Spec. 5. Report test 

results monthly. 

WAC 173-405-040(3)(b) 

K.12b TRS 20 ppm @ 10% O2

on daily avg. 

Monitor continuously using an approved 

CEM that conforms to 40 CFR Pt. 60 (July 1, 

1992), App. B, Perf. Spec. 5. Report test 

results monthly. 

WAC 173-405-040(3)(c) 

L. Slaker Vent Scrubber Stack

Parameter Limit

(shall not exceed)

Monitoring & Reporting Applicable 

Requirements

L.1 Particulate 0.07 gr/dscf EPA Test Method 5 is the reference test 

method. See Condition L.3 for minimum 

monitoring and reporting requirements 

intended to indicate compliance with the 

particulate limit.

 WAC 173-400-110 and 

Order DE 95 AQ I035.for 

the particulate limit. 
16 

L.2 Opacity Average 25% for 

more than 6 

consecutive 

minutes in any 60 

minute period. 

DOE Test Method 9B is the reference test 

method. See Condition L.3 for minimum 

monitoring and reporting requirements 

intended to indicate compliance with the 

particulate limit. 

WAC 173-400-110 and 

Order DE 95AQ-I035 for 

the opacity limit. 

L.3 Maintain water flow ≥ 50 gpm on a daily average. Maintain scrubber nozzle pressure ≥ 23 psi. Monitor 

scrubber water flow continuously. Monitor and record pressure monthly. Whenever daily average water 

flow is less than 50 gpm, the permittee shall immediately, but no later than 24 hours, take corrective action to 

bring the parameter within prescribed range. Whenever monitored pressure value is less than 23 psi, the 

permittee shall as soon as practical, but no later than 30 days, take corrective action to bring the parameter 

within prescribed range. Failure to take corrective action is a violation of WAC 173-405-040(10) and may be 

a violation of the underlying applicable requirement. Report exceedances and corrective action taken in 

monthly report.

NSPS GENERAL REQUIREMENTS 

Affected Units under NSPS NSPS General Requirement Applicable Requirement 

B (MCC Digester, No. 8 

MEE, High solids crustalizer, 

washing and screening 

facilities, condensate stripper), 

E (PB #11), J (NCG 

Collection/Treatment System), 

and K (Lime Kiln) 

Operate affected units 

consistent with good air 

pollution control practices for 

minimizing emissions. 

40 CFR 60.11(d) 

B (MCC Digester, No. 8 

MEE, High solids crustalizer, 

washing and screening 

facilities, condensate stripper),

E (PB #11), J (NCG 

Collection/Treatment System), 

and K (Lime Kiln) 

Concealing an emission that 

would be a violation is 

prohibited. 

40 CFR 60.12 

E (PB #11), J (NCG 

Collection/Treatment System), 

and K (Lime Kiln)

Operate and maintain CEMs 

as required. 

40 CFR 60.13 

B (MCC Digester, No. 8 

MEE, High solids crustalizer, 

washing and screening 

facilities, condensate stripper), 

E (PB #11), J (NCG 

Collection/ Treatment 

System), and K (Lime Kiln) 

Notification, Recordkeeping, 

and Credible Evidence. 

40 CFR 60.4(a), 40 CFR 

60.4(b), 40 CFR 60.11(c) and 

(g). 

National Emission Standards for Hazardous Air Pollutants, 

40 CFR Part 63 Subpart A and S 
17 

The Permitted source includes emission units that are subject to EPA National Emission 

Standards for Hazardous Air Pollutants, 40 CFR Part 63 Subpart A and S. 

1. The Permittee shall timely submit initial notification reports concerning MACT 

applicablity. 40 CFR 63.9(b)(2); 40 CFR 63.455(a). 

2. The Permittee shall timely submit and update a non-binding control strategy report for a 

kraft pulping system specified in 40 CFR 63.440(d)(1) or a bleaching system specified in 

40 CFR 63. 440(d)(3)(iii). 40 CFR 63.455(b). 

3. The Permittee shall timely comply with the applicable provisions contained in 40 CFR 

Part 63 Subparts A and S at such time as compliance is required. 

FACILITY-WIDE GENERAL REQUIREMENTS [WAC 173-401-600] 

 These generally applicable requirements apply facility-wide, including insignificant 

emission units or activities. Insignificant emission units or activities, however, are not subject to 

monitoring, testing, recordkeeping, reporting, or compliance certification requirements. 

1. The permittee cannot vary the rate of emission of a pollutant according to atmospheric 

conditions or ambient concentrations of that pollutant, except as directed according to air 

pollution episode regulations. [WAC 173-400-205] 

2. The permittee shall not cause or permit emission of any contaminant if it is detrimental to 

the health, safety, or welfare of any person, or causes damage to property or business. 

[WAC 173-400-040(5)] 

3. The permittee shall not install or use any means that conceal or mask an emission of an 

air contaminant that would otherwise violate provisions in this permit. [WAC 173-400-

040(7);] 

4. The permittee shall take reasonable precautions to prevent the release of air contaminants 

from emission units engaged in material handling, construction, demolition, or any other 

operation that is a source of fugitive emissions. Reasonable precautions include but are 

not limited to application of water to paved areas and debris piles as necessary to control 

fugitive dust or the timely removal or coverage of material piles. [WAC 173-400-

040(3)(a)] 

5. The permittee shall take reasonable precautions to prevent fugitive dust from becoming 

airborne and maintain and operate the source to minimize emissions. Reasonable 

precautions include but are not limited to application of water to paved areas and debris 
18 

piles as necessary to control fugitive dust or the timely removal or coverage of material 

piles.[WAC 173-400-040(8)(a)] 

6. The following condition is state-only and is not federally enforceable under the Clean 

Air Act: No deposit of particulate matter beyond property line so as to interfere 

unreasonably with use and enjoyment. [WAC 173-400-040(2)] 

7. The following condition is state-only and is not federally enforceable under the Clean 

Air Act: Any person causing odor which may unreasonably interfere with use & 

enjoyment of property must use recognized good practice and procedures to reduce odors 

to a reasonable minimum. [WAC 173-400-040(4)] 

8. The permittee may not cause or allow the emission of a plume from any emission unit 

other than a kraft recovery furnace, smelt dissolver tank, or lime kiln, which has an 

average opacity greater than 20% for more than 6 consecutive minutes in any 60 minute 

period except as provided in WAC 173-405-040(6). [WAC 173-405-040(6)] 

9. Except where specific requirements are defined elsewhere, the Permittee shall assure 

compliance with conditions 1 through 8 by recordkeeping of actions taken by the 

permittee in response to complaints received by the permittee or of possible 

noncompliance noticed by the facility staff in day to day operations. The permittee shall 

assess the validity of each complaint and commence corrective action, if warranted, as 

soon as possible but no later than 3 working days of receiving the complaint. The 

permittee shall keep records of the following: complaints received; the assessment of 

validity; and what, if any, corrective action is taken in response to the complaint. 

10. The emission of sulfur dioxide from any emissions unit other than a recovery furnace or 

lime kiln shall not exceed 1,000 parts per million for an hourly average, corrected to 7% 

oxygen for combustion units. [WAC 173-405-040(11)] 

11. Where this permit specifically requires continuous monitoring, the source shall, 

consistent with the requirements of Ecologyís Source Test Manual, calibrate, maintain 

and operate equipment for continuously monitoring and recording the emissions 

specified. The source may be temporarily exempted from monitoring and reporting 

requirements during periods of monitoring system malfunctions, provided that the source 

shows to Ecology's satisfaction that the malfunction was unavoidable and is being 

repaired as expeditiously as practicable. [WAC 173-400-105(5)(h)]. 

 Ecology recognizes that monitoring data may be lost for legitimate reasons. The 

permittee shall make every reasonable effort to acquire, maintain, and recover valid 

monitoring data. Except where an applicable requirement contains more stringent 

provisions, permittee shall recover valid monitoring data and recordkeeping for at least 

90% of the averaging periods during each month or, if no averaging period is used, 

collected during each month, in which this permit requires monitoring of a process or 

parameter. The 10% allowance is contingent on the permittee providing an acceptable 

explanation for the loss of monitoring data. [WAC 173-401-615] 
19 

12. The Permittee shall at all times, including periods of abnormal operation and upset 

conditions, to the extent practicable, maintain and operate any affected facility, including 

associated air pollution control equipment, in a manner consistent with good air 

pollution control practice. Determination of whether acceptable operating and 

maintenance procedures are being used will be based on information available to Ecology 

which may include, but is not limited to, monitoring results, opacity observations, review 

of operating and maintenance procedures, and inspection of the source. [WAC 173-405-

040(10);] 

13. Chemical Accidental Release Program ñ This stationary source, as defined in 40 CFR 

section 68.3, is subject to part 68, the accidental release prevention regulations. This 

stationary source shall submit a risk management plan (RMP) by the date specified in 

section 68.10. [40 CFR Part 68] 

14. Ozone Protection - The Permittee shall comply with the applicable standards for 

recycling and emissions reductions pursuant to 40 CFR Part 82, Subpart F. 

a. Persons opening appliances for maintenance, service, repair or disposal must 

comply with the required practices pursuant to ß 82.156. 

b. Equipment used during the maintenance, service, repair or disposal must comply 

with the standards for recycling and recovery equipment pursuant to ß 82.158. 

c. Persons performing maintenance, service, repair or disposal of appliances must be 

certified by an approved technician certification program pursuant to ß 82.161. 

d. Persons disposing of small appliances, MVACs, and MVAC-like appliances must 

comply with recordkeeping requirements pursuant to ß 82.166. ("MVAC-like 

appliance" is defined at ß 82.152.) 

e. Persons owning commercial or industrial process refrigeration equipment must 

comply with the leak repair requirements pursuant to ß82.156. 

f. Owners/operators of appliances normally containing 50 or more pounds or 

refrigerant purchased and added to such appliances must do so in compliance with 

ß82.166. 

15. Reserved for future use. 

16 The generally applicable requirements that apply to IEUs are WAC 173-405-040(5), 

WAC 173-400-050(1)&(3), and WAC 173-400-060. [WAC 173-401-530(2)(b)] 

17. The Permittee will continue to comply with applicable requirements with which the 

 Permittee is in compliance. WAC 173-401-630(3) and 510(2)(h)(iii)(A) 

 The Permittee will meet applicable requirements that become effective during the permit 

 term on a timely basis. WAC 173-401-630(3) and 510(2)(h)(iii)(B) 

18. Volatile Organic Liquid Storage Vessels - The Permittee shall keep records showing the 

dimensions and capacities of all storage vessels having capacities greater than or equal to 

40 cubic meters that are used to store volatile organic liquids and for which construction, 
20 

reconstruction, or modification commenced after July 23, 1984. These records are to be 

kept for the life of each storage vessel. [40 CFR 60.116b (a) and (b)] 

19. Reserved for future use.

20. The following condition is state-only and is not federally enforceable under the Clean 

Air Act. The permittee cannot burn used oil not meeting standards prescribed in RCW 

70.94.610(1). [RCW 70.94.610] 

21. The permittee must comply with 40 CFR sections 61.145 and 61.150 and WAC 173-400-

075 if asbestos-containing material is present above specified quantities in a facility 

being demolished or renovated. [40 CFR Part 61, Subpart M] 

MONITORING, RECORDKEEPING & REPORTING 

Monitoring Requirements [WAC 173-401-630(5)(b).] 

22. Unit-Specific Requirements. The permittee shall conduct routine monitoring of 

emissions in accordance with the program of monitoring or testing required for specific 

emission units in conditions A through L of this permit. [WAC 173-405-072]. 

23. Unavoidable Excess Emissions. This condition applies, where applicable, to excess 

emissions that are claimed to be unavoidable pursuant to WAC 173-400-107. The 

permittee may include in its reports demonstrations that excess emissions were 

unavoidable, consistent with the requirements of WAC 173-400-107. The permittee shall 

have the burden to prove that deviations from permit terms were unavoidable. Excess 

emissions that are unavoidable are excused and are not subject to penalty. [WAC 173-

400-107] 

24. Reserved for Future Use 

25. Reserved for Future Use

Recordkeeping Requirements 

26. The permittee shall keep records of any periodic and continuous monitoring required by 

this permit. These records shall include the following, where applicable: 

a. The date, place as defined in requirement, and time of sampling or 

measurement; 

b. The date(s) analysis were performed; 

 c. The company or entity that performed the analysis; 

 d. The analytical techniques or methods used; 

 e. The results of such analysis; 
21 

f. The operating conditions existing at the time of sampling or measurement. 

[WAC 173-401-615(2)(a); WAC 173-400-105] 

27. The permittee shall keep records describing changes made at the source that result in 

emissions of a regulated air pollutant subject to an applicable requirement, but not 

otherwise regulated under the permit, and the emissions resulting from those changes. 

[WAC 173-401-724(5).] 

28. The permittee shall retain records of all required monitoring data and support information 

for a period of 5 years from the date of 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 this permit. [WAC 173-401-615(2)(c)] 

29. The permittee shall maintain a contemporaneous record of any deviation from the 

requirements of this permit. [WAC 173-401-615(3)(b).] 

Reporting Requirements [WAC 173-401-520, -615(3), & -710] 

30. In addition to any emission unit specific reporting requirements identified below, 

emission unit specific reporting requirements are identified in conditions A through I. 

31. Report within 15 days of the end of each month average daily production of air-dried 

unbleached pulp. [WAC 173-405-072(4)] 

32. Monitoring reports required by this permit must be submitted to Ecology within 15 days 

of the end of each calendar month. [WAC 173-405-072]. The reports must clearly 

identify all instances of deviations from permit requirements. [WAC 173-401-615(3)(a)] 

33. Submit an inventory of emissions from the source each year no later than 105 days after 

the end of the calendar year; maintain records of information necessary to substantiate 

any reported emissions. [WAC 173-400-105(1)] 

34. The permittee shall promptly submit a report of any deviations from permit conditions. 

[WAC 173-401-615(3)(b).] 

a. For purposes of this permit, submitting a report "promptly" means the following: 

(a) if the deviation presents a potential threat to human health or safety, the report 

shall be made as soon as possible but no later than 12 hours after the discovery of 

the deviation; (b) for other deviations, "promptly" means that the deviations are 

identified in the respective monthly report. 

b. Reports shall describe the probable cause of such deviations, and any corrective 

actions or preventive measures taken. [WAC 173-401-615(3)]]. The permittee 

may include in its reports demonstrations that excess emissions were unavoidable, 

consistent with the requirements of WAC 173-400-107. 
22 

35. Certification of truth, accuracy and completeness. Any application form, report or 

compliance certification required to be submitted by this permit or by Chapter 401 WAC 

shall contain certification by a responsible official of truth, accuracy and completeness. 

Where the permit requires reporting more frequently than once every 3 months the 

responsible officialís certification need only be submitted once every 3 months covering 

all required reporting since the date of the last certification. This certification shall state 

that, based on information and belief formed after reasonable inquiry, the statements and 

information in the document are true, accurate, and complete. [WAC 173-401-520.] 

36. All reports and renewal applications required by this permit shall be submitted to: 

Department of Ecology 

Industrial Section 

P.O. Box 47706 

Olympia, WA 98504-7706 

37. Compliance Certification. The permittee shall submit a report to the Department of 

Ecology and to EPA Region 10 12 months after the effective date of this permit and 

every year thereafter, within 45 days after the close of the year that the certification 

covers, certifying compliance with the terms and conditions contained in this permit. 

The term ìyearî means a consecutive 365 day period and does not refer to a calendar 

year. The certification shall describe the following: 

a. the permit term or condition that is the basis of the certification; 

b. the compliance status; 

c. whether compliance was continuous or intermittent; and 

d. the methods used for determining compliance. [WAC 173-401-630(5)] 

The permittee is not required to certify compliance for insignificant emission units or 

activities. [WAC 173-401-530(2)(d)] 

STANDARD TERMS & CONDITIONS 

38. Duty to Comply. The permittee must comply with all conditions of this permit. Any 

permit noncompliance constitutes a violation of chapter 70.94 RCW and, for federally 

enforceable provisions, a violation of the FCAA. Such violations are grounds for 

enforcement action; for permit termination, revocation and reissuance, or modification; 

or for denial of a permit renewal application. [WAC 173-401-620(2)(a).] 

39. Need to Halt or Reduce Activity Not a Defense. It shall not be a defense for a permittee 

in an enforcement action that it would have been necessary to halt or reduce the 
23 

permitted activity in order to maintain compliance with the conditions of this permit. 

[WAC 173-401-620(2)(b).] 

40. Permit Actions. This permit may be modified, revoked, reopened, and reissued or 

terminated for cause. 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. [WAC 173-401-

620(2)(c).] 

41. Property Rights. This permit does not convey any property rights of any sort, or any 

exclusive privilege. [WAC 173-401-620(2)(d).] 

42. Duty to Provide Information. The permittee shall furnish to the permitting authority, 

within a reasonable time, any information that the permitting authority 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 permitting authority copies of records required to be 

kept by the permit or, for information claimed to be confidential, the permittee may 

furnish such records directly to the EPA administrator along with a claim of 

confidentiality. Permitting authorities shall maintain confidentiality of such information 

in accordance with RCW 70.94.205. [WAC 173-401-620(2)(e).] 

43. Permit Fees. The permittee shall pay fees as a condition of this permit in accordance 

with the permitting authority's fee schedule. Failure to pay fees in a timely fashion shall 

subject the permittee to civil and criminal penalties as prescribed in chapter 70.94 RCW. 

[WAC 173-401-620(2)(f).] 

44. Emissions Trading. No permit revision shall be required, under any approved economic 

incentives, marketable permits, emissions trading, and other similar programs or 

processes for changes that are provided for in this permit. [WAC 173-401-620(2)(g).] 

45. Severability. If any provision of this permit is held to be invalid, all unaffected 

provisions of the permit shall remain in effect and be enforceable. [WAC 173-401-

620(2)(h).] 

46. Permit Appeals. This permit or any conditions in it may be appealed only by filing an 

appeal with the pollution control hearings board and serving it on the permitting authority 

within thirty days of receipt pursuant to RCW 43.21B.310. This provision for appeal in 

this section is separate from and additional to any federal rights to petition and review 

under ß 505(b) of the FCAA. [WAC 173-401-620(2)(i).] 

47. Permit Continuation. This permit is issued for a 5 year term; however, this permit and all 

terms and conditions contained therein, including any permit shield provided under WAC 

173-401-640, shall not expire until the renewal permit has been issued or denied if a 

timely and complete application has been submitted. An application shield granted 

pursuant to WAC 173-401-705(2) shall remain in effect until the renewal permit has been 
24 

issued or denied if a timely and complete application has been submitted. [WAC 173-

401-620(2)(j).] 

48. Inspection and Entry. Upon consent of the permittee or upon presentation of credentials 

and other documents as may be required by law, the Department of Ecology or an 

authorized representative shall be allowed to: 

(1) Enter the source; 

(2) Have access to and copy at reasonable times any records that must be kept under 

this permit; 

(3) Inspect at reasonable times any facilities, equipment (including monitoring and 

air pollution control equipment), practices, or operations regulated or required 

under this permit; and 

(4) As authorized by WAC 173-400-105 and the FCAA, sample or monitor, at 

reasonable times, substances or parameters for the purpose of assuring 

compliance with the permit or other applicable requirements. 

 [WAC 173-400-105(4); WAC 173-401-630(2).] 

PERMIT SHIELD 

 Compliance with the conditions in this permit is deemed to constitute compliance with 

applicable requirements as contained in this permit on which the term or condition is based, as of 

the date the permit is issued. [WAC 173-401-640(1).] 

 The Department of Ecology has determined that the requirements listed in Appendix A to 

this permit do not apply to the facility, as of the date the permit is issued, for the reasons 

specified. [WAC 173-401-640(2)]. 

Appendix A. Permit Shield/Inapplicable Requirements 

The following requirements do not apply to the facility as of the date of permit issuance for the 

reasons indicated: 

CITE BRIEF DESCRIPTION REASON 

40 CFR Part 60 Subpart Da, 

Standards of Performance 

for Electric Utility Steam 

Generators (construction or 

modification commenced 

after 9/18/78) 

applies to the following types of generating 

units for which construction or modification 

commenced after September 18, 1978: 

generating greater than 250 MMBtu/Hr 

Facility does not have this emission unit. 

40 CFR Part 60 Subpart 

Db, Standards of 

Performance for IndustrialCommercial-Institutional 

Steam Generating Units 

(construction or 

modification commenced 

after 7/19/84) 

applies to the following types of generating 

units for which construction or modification 

commenced after July 19, 1984: generating 

greater than 29MW (100MMBtu/Hr) 

Facility does not have this emission unit. 
25 

40 CFR Part 60 Subpart Dc, 

Standards of Performance 

for Small IndustrialCommercial-Institutional 

Steam Generating Units 

applies to the following types of generating 

units for which construction or modification 

commenced after June 9, 1989: generating 

greater than 10 MMBtu/Hr and less than 100 

MMBtu/hr 

Facility does not have this emission unit. 

40 CFR ß60.110a Subpart Kb, Standards of Performance for 

Storage Vessels for Petroleum Liquids with a 

capacity greater than 40,000 gallons and for 

which construction is commenced after May 

18, 1978. 

Fuel oil tanks at the site have not been 

modified since the applicability date. All 

other tanks are either below the size 

applicability criteria or do not contain volatile 

organic liquids. 

40 CFR 63, Subpart Q as 

amended through 9/8/94 

No chromium based water treatment 

chemicals may be used in industrial process 

cooling towers 

The facility does not use chromium based 

water treatment chemicals 

SWAPCA Order of 

Approval 78-302 as 

amended through 1/16/78 

approval to operate Pacific Lamination Weyerhaeuser does not own or operate this 

source 

SWAPCA Order of 

Approval 78-3015 as 

amended through 2/2/78 

approval to operate Pacific Lamination Weyerhaeuser does not own or operate this 

source 

WAC 173-400-040(3)(b) emissions unit identified as a significant 

contributor to nonattainment must use 

reasonable and available control methods to 

control emissions of contaminants for which 

area is designated nonattainment 

The facility is not in a special 

control/nonattainment area 

WAC 173-400-040(8)(b) Sources of fugitive dust identified as 

significant contributors to a PM-10 

nonattainment area must use RACT to control 

fugitive dust emissions. 

The facility is not in a special 

control/nonattainment area 

WAC 173-400-070 as 

amended through 2/19/91 

emission standards for certain source 

categories 

The facility is not in this source category and 

hogged fuel boilers regulated under 173-405 

WAC 

WAC 173-400-100 

Registration 

Registration required for listed sources, 

excluding sources subject to the operating 

permit program, after EPA grants interim or 

final approval to the state program. 

Facility is subject to the operating permit 

program; EPA has granted interim approval 

for the state program. 

WAC 173-400-105(6) Applies to sources that are not subject to 

operating permit program. 

Facility is subject to the operating permit 

program. 

WAC 173-400-151 

Retrofit requirements for 

visibility protection 

BART required for sources to which 

significant visibility impairment of a Class 1 

area is reasonably attributable. 

Facility has not been identified as a source 

impacting a Class I area. 

 

WAC 173-405-040(1)(b) 

as amended through 2/1/95 

[STATE ONLY, NOT 

FEDERALLY 

ENFORCEABLE]

17.5 ppm daily average TRS limit for 

recovery furnaces constructed before 1/1/70 

and recovery furnaces with direct contact 

evaporators 

RF #10 built after 1/1/70 without direct 

contact evaporator 

Chapter 173-410 WAC; 

Sulfite Pulping Mills 

 facility is not a sulfite pulping mill 

Chapter 173-433 WAC as 

amended through 2/3/93; 

Solid Fuel Burning Devices 

Applies to wood stoves and fireplaces. facility does not operate such devices 

WAC 173-435-050(2) no open fires during an air pollution episode Facility does not conduct open burning. 

Chapters 173-470, 474, 

475, 480, 481 WAC 

Ambient Air Quality Standards AAQS apply to airsheds, not individual 

sources 
26 

Chapter 173-490 WAC Emission Standards and Controls for Sources 

of VOCs 

The facility is not in a special 

control/nonattainment area 

APPENDIX B 

Definitions of Abbreviations Used in Permit

AAQS ambient air quality standard 

ADMT air dry metric ton 

avg average 

BACT Best available control technology 

BART Best available reasonable technology 

BDMT bone dry metric ton 

BL black liquor 

BLS black liquor solids 

BTU British thermal unit 

CEM continuous emission monitor 

CO carbon monoxide 

DOE Department of Ecology 

dscf dry standard cubic foot 

EPA Environemtnal Protection Agency 

ESP electrostatic precipitator 

FCAA Federal Clean Air Act 

gpm gallons per minute 

gr grain 

HAP hazardous air pollutant 

IEU insignificant emission unit 

kg kilogram 

lbs pounds 

LM lime mud 

MACT maximum available control technology 

MMBTU million British thermal units 

NOx oxides of nitrogen 

NCG noncondensible gas 

NSPS new source performance standards 

PM particulate matter 

PM-10 particulate matter less than 10 microns in diameter 

ppm parts per million 

ppmdv part per million dry volume 

RF, RB recovery furnace, recovery boiler 

RACT Reasonable available control technology 

RM Reference method 

SERP source emission reduction plan 

SIP state implementation plan 

SO2 sulphur dioxide 

tpy tons per year 
27 

TRS total reduced sulphur 

TSP total suspended particulate 

U.S.C. United States Code 

 VOC volatile organic compound 

WAC Washington Administrative Code 
28 

Appendix C 

Algorithms for Emissions Calculation 

The Permittee may use an equivalent alternative method with written approval by Ecology 

Permit Conditions E.2b, E.5, E.6, E.7, E.8, E.9, E.10 Particulate Matter, SO2, NOx (mass per fuel 

heat input) 

= (Concentration * Air Flow Rate * Unit Conversion Factor )/ Heat Input 

Concentration, EPA RM 5 or DOE RM 5. RM6, or RM7 as specified in the respective condition, gives 

results in terms of gr/dscf or lbs/ft3. 

Air Flow is calculated per specified RM 5. 

Unit Conversion Factor is case specific. For example 1 lb = 7,000 grains. 

Heat Input is calculated by multiplying the measured steaming rate by the rated efficiency of the boiler. 

The boiler manufacturerís rated efficiency is 64.23%. If future performance tests 

demonstrate a different efficiency, that may be used to calculate heat input after 

consultation with the Department of Ecology.

 

 Permit Conditions H.5, H.8, I.5 Particulate Matter (mass per time) 

= Concentration * Air Flow Rate * Unit Conversion Factor * Black Liquor Solids Firing Rate * 

Black Liquor Solids Fired

Concentration, whether EPA RM 5 or DOE RM 5 as specified in the respective condition, gives results in 

terms of gr/dscf. 

Air Flow is calculated per specified RM 5. 

Unit Conversion Factor is case specific. For example 1 lb = 7,000 grains. 

Black Liquor Solids Firing Rate is the average firing rate during the stack test. 

Blck Liquor Solids Fired is the total tons fired over the period in question. 

Permit Condition H.13, J.9 SO2 (mass per time) 

Permit Condition H.15, I.10 TRS (mass per time) 

Permit Condition H.17 NOx (mass per time) 

= concentration x air flow x natural gas law conversion x black liquor solids firing rate * 

black liquor solids fired 

 

Concentration is in terms of ppmdv at standard conditions. It is derived either from average CEM values 

over the period of the particulate testing (e.g. SO2 on the Recovery Boiler) or from stack 

testing using specified RM (e.g. TRS on the smelt dissolver tank vent). 

Air Flow is calculated per specified particulate test from the respective emission unit. 

Natural Gas Law Conversion is case specific. It converts ppm to mass per volume of air and is 

dependent on the molecular weight of the specific pollutant. 

Black Liquor Solids Firing Rate is the average firing rate during the stack test. 

Blck Liquor Solids Fired is the total tons fired over the period in question. 
29 

Permit Conditions I.3, I.4 Particulate Matter (mass/mass BLS) 

= (Concentration x Air Flow Rate x Unit Conversion Factor x Time Adjustment)/ 

 Black liquor solids firing rate 

Concentration is in terms of gr/dscf . 

Air Flow is calculated per specified RM 1 and 2. 

Unit Conversion Factor is case specific. For example 1 lb = 7,000 grains. 

Time Adjustment is case specific and is dependent on the flow rate time unit. For example, if 

the flow rate from a RM 1 and 2 was in terms of dscfm and the black liquor firing 

rate is in hours then the time adjustment would be 60 minutes/hour. 

Black liquor solids firing rate is the ìas-firedî firing rate average for the test period. The firing 

rate is in terms of mass per time. 

Permit Condition I.8 TRS (mass per BLS) 

= (TRS(mass) x Air Flow Rate x Unit Conversion Factor x Time Adjustment)/ 

 Black liquor solids firing rate 

TRS mass is converted from Method 16 or 16a concentration in terms of ppm by multiplying by 

the respective MW of the four TRS compounds for Method 16 or by the MW of 

SO2 for Method 16A. 

Air Flow is calculated as specified in RM 1, 2, 3 & 4.

Unit Conversion Factor is case specific. For example 1 lb = 7,000 grains. 

Time Adjustment is case specific and is dependent on the flow rate time unit. For example, if 

the flow rate from a RM 1 and 2 was in terms of dscfm and the black liquor firing 

rate is in hours then the time adjustment would be 60 minutes/hour. 

Black liquor solids firing rate is the ìas-firedî firing rate average for the test period. The firing 

rate is in terms of mass per time. 

Appendix D -- Regulatory Orders 

The Orders containing applicable requirements reflected in this Permit are presented here in 

Appendix D in the chronological order listed below. 

PSD-92-03 Amendment 4 

Order No. DE 98AQ-I046 

PSD 97-01 

Order No. DE 95AQ-I035 

Order No. DE 96AQ-I093 

Order No. DE 95AQ-I076 

Order No. DE 97AQ-I041 

Order No. DE 94AQ-I080