OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY

OREGON TITLE V OPERATING PERMIT

REVIEW REPORT

Eastern Region

475 NE Bellevue, Suite 110

Bend, OR 97701

Source Information:

Compliance and Emissions Monitoring Requirements:

Reporting Requirements

Air Programs

TABLE OF CONTENTS

PERMITTEE IDENTIFICATION  5

FACILITY DESCRIPTION  5

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING  8

PLANT SITE EMISSION LIMITS  11

HAZARDOUS AIR POLLUTANTS  15

GENERAL BACKGROUND INFORMATION  15

COMPLIANCE HISTORY  15

SOURCE TEST RESULTS  15

PUBLIC NOTICE  16

EMISSIONS DETAIL SHEETS  16

LIST OF ABBREVIATIONS USED IN THIS REVIEW REPORT

INTRODUCTION

1.  [Provide a brief discussion of the proposed permit action. Is this a new permit, renewal of existing permit, or modification? Include the following statement (or something like it):]

2.  In accordance with OAR 340-218-0120(1)(f), this review report is intended to provide the legal and factual basis for the draft permit conditions. In most cases, the legal basis for a permit condition is included in the permit by citing the applicable regulation. In addition, the factual basis for the requirement may be the same as the legal basis. However, when the regulation is not specific and only provides general requirements, this review report is used to provide a more thorough explanation of the factual basis for the draft permit conditions.

3.  If this is a permit renewal, discuss any off-permit changes, 502(b)(10) changes, administrative amendments, and minor modifications that occurred during the last permit renewal. The public did not have the opportunity to review these changes so it is important to highlight them during the permit renewal.

4.  For permit renewals, it is also recommended that you provide a list of condition-by-condition changes between the previous permit and the proposed permit. One format that may be helpful is provided below:

PERMITTEE IDENTIFICATION

5.  <Identify the permittee, generally what they do, and where the facility is located.>

FACILITY DESCRIPTION

6.  <Provide a more detailed description of the processes.>

EMISSIONS UNIT AND POLLUTION CONTROL DEVICE IDENTIFICATION

7.  The emissions units at this facility are the following: [Describe the emissions units at the facility by providing enough detail to help the inspector, but not necessarily needed for the permit. Some things to consider are design capacity, fuels, raw materials, unique design features (e.g., common stacks, bypass stacks, alternative operating scenarios), serial numbers if equipment can easily be removed and replaced, and any control device parameters such a water flows, water temperature, pressure drop, voltage, etc.]

8.  Categorically insignificant activities include the following: [Check this list to make sure it is consistent with what was reported in the application or previous permit.]

•  Constituents of a chemical mixture present at less than 1% by weight of any chemical or compound regulated under OAR Chapter 340, Divisions 200 through 268, excluding Divisions 248 and 262, or less than 0.1% by weight of any carcinogen listed in the U.S. Department of Health and Human Service's Annual Report on Carcinogens when usage of the chemical mixture is less than 100,000 pounds/year

•  Evaporative and tail pipe emissions from on-site motor vehicle operation

•  Distillate oil, kerosene, gasoline, natural gas or propane burning equipment, provided the aggregate expected actual emissions of the equipment identified as categorically insignificant do not exceed the de minimis level for any regulated pollutant, based on the expected maximum annual operation of the equipment. If a source’s expected emissions from all such equipment exceed the de minimis levels, then the source may identify a subgroup of such equipment as categorically insignificant with the remainder not categorically insignificant.

•  Distillate oil, kerosene, gasoline, natural gas or propane burning equipment brought on site for six months or less for maintenance, construction or similar purposes, such as but not limited to generators, pumps, hot water pressure washers and space heaters, provided that any such equipment that performs the same function as the permanent equipment, must be operated within the source's existing PSEL;

•  Office activities

•  Food service activities

•  Janitorial activities

•  Personal care activities

•  Groundskeeping activities including, but not limited to building painting and road and parking lot maintenance

•  On-site laundry activities

•  On-site recreation facilities

•  Instrument calibration

•  Maintenance and repair shop

•  Automotive repair shops or storage garages

•  Air cooling or ventilating equipment not designed to remove air contaminants generated by or released from associated equipment

•  Refrigeration systems with less than 50 pounds of charge of ozone depleting substances regulated under Title VI, including pressure tanks used in refrigeration systems but excluding any combustion equipment associated with such systems

•  Bench scale laboratory equipment and laboratory equipment used exclusively for chemical and physical analysis, including associated vacuum producing devices but excluding research and development facilities

•  Temporary construction activities

•  Warehouse activities

•  Accidental fires

•  Air vents from air compressors

•  Air purification systems

•  Continuous emissions monitoring vent lines

•  Demineralized water tanks

•  Pre-treatment of municipal water, including use of deionized water purification systems

•  Electrical charging stations

•  Fire brigade training

•  Instrument air dryers and distribution

•  Process raw water filtration systems

•  Pharmaceutical packaging

•  Fire suppression

•  Blueprint making

•  Routine maintenance, repair, and replacement such as anticipated activities most often associated with and performed during regularly scheduled equipment outages to maintain a plant and its equipment in good operating condition, including but not limited to steam cleaning, abrasive use, and woodworking

•  Electric motors

•  Storage tanks, reservoirs, transfer and lubricating equipment used for ASTM grade distillate or residual fuels, lubricants, and hydraulic fluids

•  On-site storage tanks not subject to any New Source Performance Standards (NSPS), including underground storage tanks (UST), storing gasoline or diesel used exclusively for fueling of the facility's fleet of vehicles

•  Natural gas, propane, and liquefied petroleum gas (LPG) storage tanks and transfer equipment

•  Pressurized tanks containing gaseous compounds

•  Vacuum sheet stacker vents

•  Emissions from wastewater discharges to publicly owned treatment works (POTW) provided the source is authorized to discharge to the POTW, not including on-site wastewater treatment and/or holding facilities

•  Log ponds

•  Storm water settling basins

•  Fire suppression and training

•  Paved roads and paved parking lots within an urban growth boundary

•  Hazardous air pollutant emissions in fugitive dust from paved and unpaved roads except for those sources that have processes or activities that contribute to the deposition and entrainment of hazardous air pollutants from surface soils

•  Health, safety, and emergency response activities

•  Emergency generators and pumps used only during loss of primary equipment or utility service due to circumstances beyond the reasonable control of the owner or operator, or to address a power emergency, provided that the aggregate horsepower rating of all stationary emergency generator and pump engines is not more than 3,000 horsepower. If the aggregate horsepower rating of all stationary emergency generator and pump engines is more than 3,000 horsepower, then no emergency generators and pumps at the source may be considered categorically insignificant

•  Non-contact steam vents and leaks and safety and relief valves for boiler steam distribution systems

•  Non-contact steam condensate flash tanks

•  Non-contact steam vents on condensate receivers, deaerators and similar equipment

•  Boiler blowdown tanks

•  Industrial cooling towers that do not use chromium-based water treatment chemicals

•  Ash piles maintained in a wetted condition and associated handling systems and activities

•  Uncontrolled oil/water separators in effluent treatment systems, excluding systems with a throughput of more than 400,000 gallons per year of effluent located at the following sources:

◦  Petroleum refineries;

◦  Sources that perform petroleum refining and re-refining of lubricating oils and greases including asphalt production by distillation and the reprocessing of oils and/or solvents for fuels; or

◦  Bulk gasoline plants, bulk gasoline terminals, and pipeline facilities;

•  Combustion source flame safety purging on startup

•  Broke beaters, pulp and repulping tanks, stock chests and pulp handling equipment, excluding thickening equipment and repulpers

•  Stock cleaning and pressurized pulp washing, excluding open stock washing systems

•  White water storage tanks

EMISSION LIMITS AND STANDARDS, TESTING, MONITORING, AND RECORDKEEPING

This is the most important section of the review report from EPA’s perspective. In the permit, you identify which requirements apply to each emissions unit and specify the testing, monitoring, and recordkeeping that will be used for assuring compliance. In this section you explain why the requirements are applicable to the emissions unit and the rationale for the testing, monitoring, and recordkeeping requirements. There are various ways of organizing information, but if you use the following outline, you should end up with an adequate “statement of basis”.

Oregon Administrative Rules (OAR)

ACDP requirements, including source specific RACT, BACT, LAER, and TACT determinations

Federal Requirements, including:

NSPS (Part 60)

NESHAP (Parts 61 and 63)

CAM (Part 64)

Accidental Release Prevention (Part 68)

Acid Rain (Parts 72, 74, and 75)

Insignificant activities

For each applicable requirement, provide the following information:

•  Affected emission units

•  A discussion for why or why not the requirements apply to the emissions unit. In most cases, this is straight forward, but for some emissions units, it may not be clear why a requirement does not apply. Examples: boilers that were installed prior to the NSPS date and storage tanks that are smaller than the regulated size or don’t store volatile compounds.

•  For applicable requirements that come from an ACDP, it is assumed that all requirements are federally enforceable even if the underlying rule is not part of the SIP. Therefore, it is necessary to use the procedures in OAR 340-218-0040(3)(i) to change them to state only enforceable if the rule is only state enforceable. This would apply to new Title V permits and when an NSR or PSD permit is incorporated into the Title V permit. For Title V renewals, it is not necessary to revisit past decisions about state versus federal enforceability. Nuisance conditions are never federally enforceable.

•  Applicable requirements from ACDPs can be revoked or modified in accordance with OAR 340-218-0040(3)(i) unless they are based on a rule that is applicable to the source. Examples of ACDP conditions that can be revoked or modified are those that were established in accordance with the PSD or NSR rules. However, any change in PSD or NSR requirements must be done in accordance with the PSD or NSR rules and discussed in this review report.

•  Discuss any testing requirements or provide an explanation for why testing is not required. Testing may be done for two reasons: compliance determination or emission factor verification testing. In many cases, simple reference to DEQ’s Title V Testing and Monitoring Guidance Document will be enough justification for why or why not testing is required. If testing is required, discuss any unusual requirements associated with the testing, such as testing before and after a control device for measuring destruction efficiency.

•  Explain what monitoring is being required and why. Refer to DEQ’s Title V Testing and Monitoring Guidance Document for assistance. Except for rare cases, monitoring is required for all emissions units/applicable requirements. In some cases, the monitoring is required by the underlying applicable requirement or by the compliance assurance monitoring rule, but if it is not, a reasonable monitoring protocol will have to be developed for the specific emissions unit. In general, monitoring is not required for insignificant activities or emissions units that have no potential to exceed the emissions limit or standard, such as natural gas boilers subject to opacity and grain loading limits.

•  Explain any special recordkeeping requirements; especially if recordkeeping is the sole means of providing a reasonable assurance of compliance with the emission limits and standards.

If an NSPS is applicable, the permittee and permit writer should determine whether the source is in compliance with all of the requirements including the general notification and initial testing requirements. If it is not possible to determine if the general requirements were satisfied, the permit writer should not list those requirements as non-applicable in the permit. In many cases, the records necessary to determine whether the initial notification requirements were met are no longer available so it will not be possible to verify compliance with the requirements. A simple statement to that effect will suffice. For example, if subpart Db applies to a boiler that has been operating since 1989, the initial notification records may not be available. The permit writer could say: “Since this boiler has existed since 1989, it is assumed that the general requirements of subpart A have been met, but the permit does not provide a shield for those requirements because it is not possible to verify the requirements have been satisfied.” If the emissions unit was installed during the last permit term or if the records are available to determine if the general requirements were satisfied, then the requirements could be listed as non-applicable in the permit. Provided below is a list of the NSPS general requirements that may need to be included in the permit as applicable requirements:

<Include the following language for insignificant emission units:>

9.  As identified earlier in this Review Report, this facility has insignificant emissions units (IEUs) that include categorically insignificant activities and aggregate insignificant emissions, as defined in OAR 340-200-0020. For the most part, the standards that apply to IEUs are for opacity (20% limit) and particulate matter (0.10 gr/dscf limit). DEQ does not consider it likely that IEUs could exceed an applicable emissions limit or standard because IEUs are generally equipment or activities that do not have any emission controls (e.g., small natural gas fired space heaters) and do not typically have visible emissions. Since there are no controls, no visible emissions, and the emissions are less than one ton per year, DEQ does not believe monitoring, recordkeeping, or reporting is necessary for assuring compliance with the standards. [More explanation may be necessary for emissions units included in the aggregate insignificant emissions if they have control equipment (e.g., baghouses).

Categorically insignificant activities are general categories of activities. If a specific activity within a categorical activity is subject to an NSPS or NESHAP, then that activity must be identified as a unique emissions unit and all of the applicable requirements (including monitoring, recordkeeping, and reporting requirements) must be included in the permit for that emissions unit. Some categorically insignificant activities that may include specific activities subject to a NESHAP included, but are not limited, to the following:

•  Automotive repair shops or storage garages; This category could inlcude degreasers subject to a MACT.

•  Pre-treatment of municipal water: If chlorinating, this category could be subject to 112(r).

•  Routine maintenance: This could include plating (hard surfacing of cutting tools, etc) or degreasing, bot of which may be subject to a MACT.

•  Pressurized tanks containing gaseous compounds: This category could be subject to 112(r).

•  Emergency generators (reciprocating internal combustion engines or RICE) are subject to 40 CFR Part 63, subpart ZZZZ

•  Gasoline dispensing facilities (GDF) are subject to 40 CFR Part 63, subpart CCCCCC

PLANT SITE EMISSION LIMITS

[Use the following tables and guidance for explaining the basis of the PSEL. Details of the baseline emission rate and the PSEL for individual pieces of equipment should be provided as an attachment to the review report]

10.  Provided below is a summary of the baseline emissions rate, netting basis, plant site emission limits, and emissions capacity.

10.a.  Explain basis for baseline emission rate (refer to detail sheet or calculations from previous permitting actions because baseline is frozen after the first permit renewal after 7/1/01)

10.b.  Explain the basis for the netting basis, both previous and proposed, if being changed. Normally, increasing the netting basis would have to be done with an ACDP for a PSD/NSR action, but the netting basis could be reduced in a Title V permit because of a new rule.

10.c.  Discuss the basis of the PSEL and the proposed changes. For the basis, it might be easiest to just refer to the emission detail sheets, if applicable.

10.d.  Explain Capacity if it has a bearing on the status of the source. For example, you might want to set the PSEL for a HAP or combined HAPs at the generic PSEL so that the source would not be subject to a NESHAP. In that case, you might want to discuss the capacity of the source and the PTE based on the Generic PSEL. Capacity is also necessary for determining unassigned emissions. If the Capacity column has no significance for the source, modify the table by deleting the column.

11.  Include a daily PSEL for PM₁₀ for sources located in the Medford-Ashland AQMA.

12.  [Only include this section if applicable to the source.] In addition to the PSEL, the permit includes the following:

12.a.  Explain basis and terms for unassigned emissions.

12.b.  Explain basis and terms for emission reduction credits.

SIGNIFICANT EMISSION RATE

13.  The proposed PSEL is/is not greater than the previous netting basis as shown below. [Provide any additional discussion as needed]

*For PM₁₀, the first value is for sources located anywhere in the state other than the maintenance portion of the Medford-Ashland AQMA. In the Medford-Ashland Maintenance Area, the SER for PM₁₀ is 5 tons/yr.

Definition of terms: [These definitions are provided for assistance, but need not be included in the review report. Instead, the permit writer should provide a discussion of the information included in the tables. The definitions could be moved to an attachment, if desired.]

Plant Site Emissions Limit Table:

Pollutant: Plant site emission limits must be established for all regulated pollutants listed that have a Significant Emission rate in OAR 340-200-0020 that are emitted above the de minimis levels defined in 340-200-0020. It is possible to include the Generic PSEL for a single or combined HAPs so the source will not be considered a major source of HAPs. This would be important for any source that has the capacity to emit greater than 10 tons of a single HAP or 25 tons of combined HAPs but wants to avoid being subject to a future MACT standard.

Other pollutant mass emission limits may be established, but these should be considered performance standards and not PSELs. For example, during the initial permitting of a fiberglass facility, DEQ may establish a mass emissions limit specifically for styrene. This limit should not be considered a PSEL because there is no ambient air quality, NSPS, or Part 61 NESHAP standard for styrene, but the styrene would be included in the PSEL for VOC. Another example: If DEQ believes it is necessary to establish an ammonia emission limit for a combustion device utilizing ammonia injection for control of NO_x. The ammonia limit should not be a PSEL because there is no ambient air quality standard for ammonia. Lead is one hazardous air pollutant for which it may be necessary to establish a PSEL because there is an ambient air quality standard for lead. However, it is not included in the table above because most sources do not emit lead above the de minimis level. Lead would have to be added for the sources that do emit lead.

The annual PSEL applies to each 12 consecutive month period. Therefore, it is considered a limit on the potential to emit (PTE). Short term PSELs (e.g., lb/hr, lb/day, lb/week, lb/month) are not required, except for sources located in the Medford-Ashland AQMA must have a lb/day PSEL for PM₁₀ if the emissions are greater than 5 lbs/day.

The baseline emission rate equals the actual pollutant emissions during the baseline period of 1977 or 1978 or 12 consecutive months in the period 2000 to 2010 for greenhouse gases. An earlier year may be used if neither 1977 nor 1978 are representative of normal operations but not for greenhouse gases. (Note: Each source should have already identified an appropriate baseline period, so only in very rare cases will DEQ approve an alternative year.) Once established, the baseline emission rate never changes, except that it may be corrected when better information about the actual emissions during the baseline period becomes available (e.g., source test data). For new sources (those that were installed after 1978 or after 2010 for greenhouse gases), the baseline emission rate is zero for all pollutants. If a current source operated in the baseline period, and continuously since that time, the source has a baseline emission rate whether or not it is permitted. However, a source that permanently shut down and then started up again after the baseline period would have a baseline emission rate equal to zero, even if the source is the original facility and includes the original equipment. In addition, any source that elects to have a Basic, General, or Simple ACDP forfeits their baseline emission rate.

With the first permitting action for a source after July 1, 2001, the production basis for the baseline emission rate may only be changed if a material mistake or an inaccurate statement was made in establishing the production basis for the baseline emission rate.

The netting basis is the baseline for determining net increases as a result of a major modification as defined in OAR 340-222-0046. The netting basis equals the baseline emission rate or the emissions that were approved during the last NSR action in accordance with OAR Chapter 340, Division 224, but only for the pollutants subject to NSR. In addition, the netting basis must be adjusted to reflect any emission reductions required by rule, unassigned emissions, and emission reduction credits. Reductions required by rule will affect the netting basis at the time the rule is adopted, which could occur at any time during the permit term. The previous netting basis would be adjusted at the next permit renewal.

In situations where actual emissions are set equal to PTE, the netting basis will be reduced from PTE down to the highest actual emissions.

•  For GHG sources that were approved prior to 12/31/10 but had not begun normal operations by 12/31/10, PTE will be reduced to the highest actual emissions 10 years after the baseline period.

•  For sources permitted under division 224 after 5/1/11, PTE will be reduced to the highest actual emissions 10 years after the date the permit is issued.

•  DEQ may extend the date or resetting by five additional years upon satisfactory demonstration by the source that construction is ongoing or normal operation has not yet been achieved.

The reduction to the netting basis will be required before any future netting can take place to prevent sources from using the “potential emissions” to offset new projects and net out of NSR. Sources that reduce actual emissions because of voluntary controls will not lose that portion of the netting basis. In addition, the reduction to the netting basis will not affect the PSEL so that sources will be able to utilize the capacity that was allowed by the NSR permit.

Both the previous and proposed netting basis should be shown in the columns if it is being changed due to the current permit action. If the netting basis is changed, the review report will also need a complete discussion of the NSR action or reductions due to a new rule. Normally, the netting basis is not changed with a Title V permitting action because the rules require that an ACDP be issued for any NSR/PSD action.

The previous PSEL is the PSEL approved in the previous permit. In some cases, the previous PSEL will need corrections if new emissions information becomes available. If there are corrections, they should be explained in the review report. The previous PSEL is provided to show whether there are any proposed PSEL increases.

The proposed PSEL is the PSEL requested by the permittee and approved by DEQ. The PSEL shall equal the netting basis and be adjusted upward or downward in accordance with OAR 340-222-0041. Since the PSEL cannot include emission reductions required by a rule, the PSEL is equal to the netting basis plus any past or present requested increases approved by DEQ. Requested increases are evaluated as follows:

1.  If the requested increase is due to utilizing existing capacity that also existed during the baseline period (e.g., the increase is not due to a physical modification and it is not due to, or associated with, capacity that was installed after the baseline period), the permittee shall demonstrate a need and:

•  demonstrate that the requested increase above the netting baseline is less than the significant emission rate (SER); or

•  if greater than or equal to the SER, provide an assessment of the air quality impact showing that no ambient air quality standard or PSD increment will be violated in an attainment area or an offset has been obtained in a nonattainment area.

2.  If the requested increase is due to a proposed physical modification or change in the method of operation (e.g., de-bottle necking that would increase the capacity of the facility), the permittee shall:

•  demonstrate that the net emission increase above the netting baseline is less than the significant emission rate (SER);

•  emission increases shall be calculated as follows: For each unit with a physical change or change in the method of operation occurring at the source since the baseline period as applicable for each pollutant, subtract the unit’s portion of the netting basis from its post-change potential to emit taking into consideration any federally enforceable limits on potential to emit. Emissions from categorically insignificant activities, aggregate insignificant emissions, and fugitive emissions must be included in the calculations.

◦  “The unit’s portion of the netting basis” means the portion of the netting basis assigned to or associated with the unit in question, taking into consideration the following, as applicable:

▪  The unit’s portion of the netting basis when the netting basis is established under OAR 340-222-0046(2); and

▪  Any adjustments under OAR 340-222-0046(3) that affect the unit’s portion of the netting basis.

•  if the emission increase is greater than or equal to the SER but not subject to NSR, provide an assessment of the air quality impact showing that no ambient air quality standard or PSD increment will be violated in an attainment area or an offset has been obtained in a nonattainment area; or

•  if the emission increase is greater than or equal to the SER and subject to NSR, satisfy the requirements of the NSR rules in OAR Chapter 340, Division 224.

3.  If the requested increase is due to both utilizing existing capacity and a physical modification, the increases shall be tracked separately as shown in the significant emissions rate table. If the total increase is greater than the SER, but the increase due to a physical modification is less than the SER, the source shall satisfy the requirements of item 1 above.

4.  PSELs shall not be established which allow emissions in excess of those allowed by any applicable federal or state regulation in accordance with OAR 340-222-0035(1). Note that reductions required by rule do not affect the baseline emission rate, but they will affect the netting basis.

PSEL increase means the difference between the proposed PSEL and the previous PSEL. This can be a positive or negative number. This information is primarily for the purpose of keeping the public informed of any recent changes in the allowable emissions of a source. The information is not used to determine if an SER has been exceeded. SER exceedances are determined as the difference between the proposed PSEL and the netting basis.

Capacity means the maximum capacity of a stationary source to emit any air pollutant under its physical and operational design. Capacity is necessary for establishing the PSEL and unassigned emissions if the current capacity is less than the netting basis.

Potential to Emit (PTE) means the lesser of the capacity of a source or the maximum allowable emissions taking into consideration any physical or operational limitation, including the PSEL, air pollution control equipment and restrictions on hours of operation or on the type and amount of material combusted, stored, or processed, if the limitation is enforceable by the DEQ and EPA.

PTE is used to determine which type of permit is required. If the PTE is less than the Title V major source threshold levels, the source would be required to obtain an ACDP. If the PTE is greater than the Title V major source threshold levels, the source would be required to obtain an Oregon Title V Air Operating Permit.

The PSEL can be used to establishe the PTE but the PSEL shall not be reduced solely because of the PTE. However, it is not expected that any previous action that decreased PSELs to equal the PTE be reversed.

Unassigned emissions are that portion of the netting basis that is greater than the source’s current capacity to emit, excluding any credits. The source’s current capacity can be thought of as the source’s potential emissions at the maximum possible production levels without considering the PSEL. If applicable, unassigned emissions are established during permit renewals. If the unassigned emissions are not used during the permit term, they are reduced to the significant emission rate during the next permit renewal.

Emission Reduction Credits are established by OAR 340, Division 268. Emission reduction credits are a portion of the netting basis. Credits need to be identified separately in the permit with the terms (e.g., expiration date) of the credit clearly stated. Note, the baseline emission rate is not affected by credits and the PTE of a source would, by definition, not include any credits, whether transferred or banked.

Emission reduction credits, whether from shutdowns, curtailments, or over-control, are available for external offsets for a period of two years from the date of the actual emissions reduction. Emission reduction credits may also be banked for a specified period up to ten years. Requests for emission reduction credit banking shall be submitted to DEQ prior to or within two years following the actual emissions reduction.

If credits are not used either internally or externally within the banked period, they are converted to unassigned emissions.

Significant Emission Rate table:

The SER (significant emission rate) for each pollutant is defined in OAR 340-200-0020. Pollutant emission increases above the SER are subject to additional requirements. For PSEL increases that do not involve a physical modification or change in the method of operation, an air quality assessment is required to show that there will not be a violation of an ambient air quality standard or PSD increment. For PSEL increases resulting from physical modification or change in the method of operation at major sources in nonattainment and maintenance areas or federal major sources in attainment areas, the permittee must comply with the NSR requirements in OAR Chapter 340, Division 224.

The requested increase is the difference between the proposed PSEL and the previous netting basis less any credits and reductions required by rule since the last permit action. The requested increase is also divided into portions that are due to utilization of capacity that existed in the baseline period and/or physical modifications at the facility as discussed in the Proposed PSEL section above. If the requested increase is greater than the SER, the review report will have to include a discussion of why DEQ is approving the increase. This could be the result of an air quality assessment or NSR review, depending on the reason for the increase.

HAZARDOUS AIR POLLUTANTS

[Provide a summary of the HAP emissions from the source. In general, this should be based on the capacity of the facility. The application forms for permit renewals request the permittee to provide an updated HAP emissions inventory along with the most recent toxic release inventory (TRI) report. This information should be reviewed by the permit writer for any discrepancies.]

GENERAL BACKGROUND INFORMATION

[Use the existing format to provide information about the last permit, attainment status of the area where the source is located, and other permits. For new Title V permits, the Title V permit will replace the ACDP, but the ACDP still exists for historical enforcement purposes and as a basis for determining applicable requirements.]

COMPLIANCE HISTORY

[Provide the date and results of inspections conducted during the last permit term. Discuss any complaints or enforcement actions that occurred during the last permit period. Also discuss any current compliance issues and proposed compliance schedules included in the permit.]

SOURCE TEST RESULTS

[Summarize the results of any source testing performed during the last permit term and further back, if available. This information is helpful for the next permit renewal as well as showing the compliance status of the source(s). All source test data should be reviewed to determine if emission factors should be updated in accordance with the internal management directive (IMD) for establishing emission factors. Any future testing should have been discussed with the applicable requirement discussion earlier in the review report.]

PUBLIC NOTICE

[Provide a brief discussion of the public notice process. Once example is provided as follows:

14.  This permit will be put on public notice from xxxxxx to xxxxx. Comments may be submitted in writing during the comment period. DEQ will hold a public hearing if requested by 10 or more individuals or one person representing a group of 10 or more individuals. After the comment period and hearing, if requested, DEQ will review the comments and modify the permit as may be appropriate. A proposed permit will be sent to EPA for a 45 day review period. DEQ may request and EPA may agree to an expedited review of 5 days if there were no substantive or adverse comments during the comment period.

If EPA does not object in writing, any person may petition the EPA within 60 days after the expiration of EPA's 45-day review period to make such objection. Any such petition must be based only on objections to the permit that were raised with reasonable specificity during the public comment period provided for in OAR 340-218-0210, unless the petitioner demonstrates it was impracticable to raise such objections within such period, or unless the grounds for such objection arose after such period.

<For the proposed permit, the discussion will have to be changed to address the comments and/or testimony received at the hearing. Refer to the permit coordinators handbook for suggested language and options for requesting an expedited review by EPA.>

EMISSIONS DETAIL SHEETS

[Provide sufficient detail for how the PSEL was determined. This includes clear documentation of emission factors, anticipated maximum production levels, and any other information or assumptions used to calculate short and long term emissions.]

jinahar, 2015-03-16T13:51:00Z
Need to explain that this might count towards NSR