Questions:

What monitoring are you doing to show you are in compliance with grain loading and opacity at all times?

FRANK: opacity readings at least once/quarter

source testing 1/5 years

multiclone inspection 1/year

continuous O2 monitor

pressure gauge for pressure drop across multiclone

steam flow meter

BOISE CASCADE – Pilot Rock

Residual oxygen

For BC: How often have you run the HFBs that are backup to NG in the past 10 years? And for how long?

COLUMBIA FOREST PRODUCTS:

continuous O2 monitor

steam flow meter

multiclone inspection 1/year

183. The semi-annual compliance certification must include the following (provided that the identification of applicable information may cross-reference the permit or previous reports, as applicable): [OAR 340-218-0080(6)(c)]

183.a. The identification of each term or condition of the permit that is the basis of the certification;

183.b. The identification of the method(s) or other means used by the owner or operator for determining the compliance status with each term and condition during the certification period, and whether such methods or other means provide continuous or intermittent data. Such methods and other means must include, at a minimum, the methods and means required under OAR 340-218-0050(3). Note: Certification of compliance with the monitoring conditions in the permit is sufficient to meet this requirement, except when the permittee must certify compliance with new applicable conditions that are not yet in the permit. When certifying compliance with new applicable conditions that are not yet in the permit, the permittee must provide the information required by this condition.

183.c. If necessary, the owner or operator also must identify any other material information that must be included in the certification to comply with section 113(c)(2) of the FCAA, which prohibits knowingly making a false certification or omitting material information;

183.d. The status of compliance with terms and conditions of the permit for the period covered by the certification, based on the method or means designated in OAR 340-218-0040(6)(c)(B). The certification must identify each deviation and take it into account in the compliance certification. The certification must also identify as possible exceptions to compliance any periods during which compliance is required and in which an excursion or exceedance, as defined under OAR 340-200-0020, occurred; and

183.e. Such other facts as the Department may require to determine the compliance status of the source.

183.f. Notwithstanding any other provision contained in any applicable requirement, the owner or operator may use monitoring as required under OAR 340-218-0050(3) and incorporated into the permit, in addition to any specified compliance methods, for the purpose of submitting compliance certifications. [OAR 340-218-0080(6)(e)]