26-3051-P-04152009-AQ

This permit is being issued in accordance with the provisions of ORS 468A.040 and

ACDP	Air Contaminant Discharge Permit
ASTM	American Society for Testing and Materials
AQMA	Air Quality Maintenance Area
calendar year	The 12-month period beginning January 1st and ending December 31st
CFR	Code of Federal Regulations
CO	carbon monoxide
DEQ	Oregon Department of Environmental Quality
dscf	dry standard cubic foot
EPA	US Environmental Protection Agency
FCAA	Federal Clean Air Act
gal	gallon(s)
gr/dscf	grains per dry standard cubic foot
HAP	Hazardous Air Pollutant as defined by OAR 340-244-0040
I&M	inspection and maintenance
lb	pound(s)
MMBtu	million British thermal units
NA	not applicable
NESHAP	National Emissions Standards for Hazardous Air Pollutants
NO_X	nitrogen oxides
NSPS	New Source Performance Standard
NSR	New Source Review
O₂	oxygen
OAR	Oregon Administrative Rules
ORS	Oregon Revised Statutes
O&M	operation and maintenance
Pb	lead
PCD	pollution control device
PM	particulate matter
PM₁₀	particulate matter less than 10 microns in size
ppm	part per million
PSD	Prevention of Significant Deterioration
PSEL	Plant Site Emission Limit
PTE	Potential to Emit
RACT	Reasonably Available Control Technology
scf	standard cubic foot
SER	Significant Emission Rate
SIC	Standard Industrial Code
SIP	State Implementation Plan
SO₂	sulfur dioxide
Special Control Area	as defined in OAR 340-204-0070
VE	visible emissions
VOC	volatile organic compound
year	A period consisting of any 12- consecutive calendar months

1.1. Visible Emissions	The permittee must comply with the following visible emission limits, as applicable:
	a. Emissions from any air contaminant source must not equal or exceed 20% opacity for a period aggregating more than 3 minutes in any one hour.
	b. Emissions from any air contaminant source other than the boiler must not equal or exceed 20% opacity for a period aggregating more than 30 seconds in any one hour.
1.2. Particulate Matter Emissions	The permittee must comply with the following particulate matter emission limits, as applicable:
	a. Particulate matter emissions from the boiler must not exceed 0.1 grains per standard cubic foot, corrected to 12% CO₂ or 50% excess air.
	b. Particulate matter emissions from any air contaminant source installed, constructed, or modified after June 1, 1970 other than the boiler and fugitive emission sources must not exceed 0.1 grains per standard cubic foot.
1.3. Fugitive Emissions	The permittee must take reasonable precautions to prevent fugitive dust emissions by:
	a. Operating all air contaminant-generating processes so that fugitive type dust associated with the operation will be adequately controlled at all times.
	b. Storing collected materials from air pollution control equipment in a covered container or other method equally effective in preventing the material from becoming airborne during storage and transfer.
1.4. Particulate Matter Fallout	The permittee must not cause or permit the emission of any particulate matter larger than 250 microns in size at sufficient duration or quantity, as to create an observable deposition upon the real property of another person. The Department will verify that the deposition exists and will notify the permittee that the deposition must be controlled.
1.5. Nuisance and Odors	The permittee must not cause or allow air contaminants from any source to cause a nuisance. Nuisance conditions will be verified by Department personnel.
1.6. Fuels and Fuel Sulfur Content	The permittee must not use any fuel other than natural gas, propane, butane, ASTM grade fuel oils, or on-specification used oil.
	a. Fuel oils must not contain more than:
	i. 0.3% sulfur by weight for ASTM Grade 1 distillate oil;
	ii. 0.5% sulfur by weight for ASTM Grade 2 distillate oil;
	iii. 1.75% sulfur by weight for residual oil;
	b. The permittee is allowed to use on-specification used oil as fuel which contains no more than 0.5% sulfur by weight. The permittee must obtain analyses from the marketer or, if generated on site, have the used oil analyzed, so that it can be demonstrated that each shipment of oil does not exceed the used oil specifications contained in 40 CFR Part 279.11, Table 1.

3.1. Plant Site Emission Limits (PSEL)	Plant site emissions must not exceed the following:
	Pollutant	Limit	Units
	PM	24	tons per year
	PM₁₀	14	tons per year
	SO₂	39	tons per year
	NO_X	39	tons per year
	CO	99	tons per year
	VOC	39	tons per year

	Single HAP	9	tons per year
	Combined HAPs	24	tons per year

3.2. Annual Period	The annual plant site emissions limits apply to any 12-consecutive calendar month period.

4.1. PSEL Compliance Monitoring	Compliance with the PSEL is determined for each 12-consecutive calendar month period based on the following calculation for each pollutant: E = S(EF x P)/2000 lbs where, E = pollutant emissions (tons/yr); EF = pollutant emission factor (see Condition 11.0); P = process production (see Condition 5.1)
4.2. Emission Factors	The permittee must use the default emission factors provided in condition 11.0 for calculating pollutant emissions, unless alternative emission factors are approved by the Department. The permittee may request or the Department may require using alternative emission factors provided they are based on actual test data or other documentation (e.g., AP-42 compilation of emission factors) that has been reviewed and approved by the Department.
4.3. Mass Balance without controls	Annual VOC/HAP emissions for each 12 consecutive calendar month period are calculated by the following formula: E_VOC-A = [å(C_X * D_X * K_X) – W] x 1ton/2000 pounds Where, E_VOC-A= Annual VOC emissions in tons C = Material usage for the period in gallons D = Material density in pounds per gallon K = VOC/HAP concentration expressed as a decimal X = Subscript X represents a specific material W = Weight of VOC shipped offsite

5.1. Operation and Maintenance	The permittee must maintain the following records related to the operation and maintenance of the plant and associated air contaminant control devices on a monthly basis:
	a. Quantity of natural gas combusted, in million cubic feet;
	b. Quantity and type of fuel oils combusted, in thousand gallons;
	c. Hours of operation of the corrugators;
	d. Quantity of inks used, in pounds; e. Quantity of scrap paper/containerboard baled, in tons; f. Weighted average VOC content of inks, in percent; g. Gallons of VOC/HAP containing materials used, and percent of HAP, by weight; h. Gallons of VOC/HAP waste material shipped off site; i. Calculations required in Conditions 4.1 and 4.3; j. Percentage of containerboard that has been waxed
5.2. Excess Emissions	The permittee must maintain records of excess emissions as defined in OAR 340-214-0300 through 340-214-0340 (recorded on occurrence). Typically, excess emissions are caused by process upsets, startups, shutdowns, or scheduled maintenance. In many cases, excess emissions are evident when visible emissions are greater than 20% opacity for 3 minutes or more in any 60-minute period. If there is an ongoing excess emission caused by an upset or breakdown, the permittee must cease operation of the equipment or facility no later than 48 hours after the beginning of the excess emissions, unless continued operation is approved by the Department in accordance with OAR 340-214-0330(4).
5.3. Complaint Log	The permittee must maintain a log of all written complaints and complaints received via telephone that specifically refer to air pollution concerns associated to the permitted facility. The log must include a record of the permittee’s actions to investigate the validity of each complaint and a record of actions taken for complaint resolution.
5.4. Retention of Records	Unless otherwise specified, all records must be maintained on site for a period of two (2) years and made available to the Department upon request.

6.1. Excess Emissions	The permittee must notify the Department of excess emissions events if the excess emission is of a nature that could endanger public health.
	a. Such notice must be provided as soon as possible, but never more than one hour after becoming aware of the problem. Notice must be made to the regional office identified in Condition 8.3 by e-mail, telephone, facsimile, or in person.
	b. If the excess emissions occur during non-business hours, the permittee must notify the Department by calling the Oregon Emergency Response System (OERS). The current number is 1-800-452-0311.
	c. The permittee must also submit follow-up reports when required by the Department.
6.2. Annual Report	For each year this permit is in effect, the permittee must submit to the Department by February 15 two (2) copies of the following information for the previous calendar year:
	a. Operating parameters:
	i. Calculations required in Condition 4.0, these may be in the form of a spreadsheet.
	ii. The date of the last boiler tune-up, and any major repairs completed. iii. Average percentage of containerboard waxed.
	b. A summary of annual pollutant emissions determined each month in accordance with Condition 5.1.
	c. Records of all planned and unplanned excess emissions events.
	d. Summary of complaints relating to air quality received by permittee during the year.
	e. List permanent changes made in plant process, production levels, and pollution control equipment which affected air contaminant emissions.
	f. List major maintenance performed on pollution control equipment.
6.3. Notice of Change of Ownership or Company Name	The permittee must notify the Department in writing using a Departmental “Permit Application Form” within 60 days after the following:
	a. Legal change of the name of the company as registered with the Corporations Division of the State of Oregon; or
	b. Sale or exchange of the activity or facility.
6.4. Construction or Modification Notices	The permittee must notify the Department in writing using a Departmental “Notice of Construction Form,” or “Permit Application Form,” and obtain approval in accordance with OAR 340-210-0205 through 340-210-0250 before:
	a. Constructing, installing, or establishing a new stationary source that will cause an increase in any regulated pollutant emissions;
	b. Making any physical change or change in operation of an existing stationary source that will cause an increase, on an hourly basis at full production, in any regulated pollutant emissions; or
	c. Constructing or modifying any air pollution control equipment.
6.5. Where to Send Reports and Notices	The reports, with the permit number prominently displayed, must be sent to the Field office for the region where the source is located as identified in Condition 8.3

7.1. Permit Renewal Application	The completed application package for renewal of this permit is due on 11/01/2013. Two (2) copies of the application must be submitted to the DEQ Permit Coordinator listed in Condition 8.2.
7.2. Permit Modifications	Application for a modification of this permit must be submitted not less than 60 days prior to the source modification. A special activity fee must be submitted with an application for the permit modification. The fees and two (2) copies of the application must be submitted to the Business Office of the Department.

9.1. Annual Compliance Fee	The Annual Fee specified in OAR 340-216-0020, Table 2, Part 2 for a Simple ACDP is due on December 1 of each year this permit is in effect. An invoice indicating the amount, as determined by Department regulations, will be mailed prior to the above date. Late fees in accordance with Part 4 of the table will be assessed as appropriate.
9.2. Change of Ownership or Company Name Fee	The non-technical permit modification fee specified in OAR 340-216-0020, Table 2, Part 3(a) is due with an application for changing the ownership or the name of the company.
9.3. Special Activity Fees	The special activity fees specified in OAR 340-216-0020, Table 2, Part 3 (b through i) are due with an application to modify the permit.
9.4. Where to Submit Fees	Fees must be submitted to: Department of Environmental Quality Business Office 811 SW Sixth Avenue Portland, Oregon 97204-1390

10.1. Permitted Activities	This permit allows the permittee to discharge air contaminants from processes and activities related to the air contaminant source(s) listed on the first page of this permit until this permit expires, is modified, or is revoked.
10.2. Other Regulations	In addition to the specific requirements listed in this permit, the permittee must comply with all other legal requirements enforceable by the Department.
10.3. Conflicting Conditions	In any instance in which there is an apparent conflict relative to conditions in this permit, the most stringent conditions apply.
10.4. Masking of Emissions	The permittee must not cause or permit the installation of any device or use any means designed to mask the emissions of an air contaminant that causes or is likely to cause detriment to health, safety, or welfare of any person or otherwise violate any other regulation or requirement.
10.5. Department Access	The permittee must allow the Department’s representatives access to the plant site and pertinent records at all reasonable times for the purposes of performing inspections, surveys, collecting samples, obtaining data, reviewing and copying air contaminant emissions discharge records and conducting all necessary functions related to this permit in accordance with ORS 468-095.
10.6. Permit Availability	The permittee must have a copy of the permit available at the facility at all times.
10.7. Open Burning	The permittee may not conduct any open burning except as allowed by OAR 340 Division 264.
10.8. Asbestos	The permittee must comply with the asbestos abatement requirements in OAR 340, Division 248 for all activities involving asbestos-containing materials, including, but not limit to, demolition, renovation, repair, construction, and maintenance.
10.9. Property Rights	The issuance of this permit does not convey any property rights in either real or personal property, or any exclusive privileges, nor does it authorize any injury to private property or any invasion of personal rights, nor any infringement of federal, state, or local laws or regulations.
10.10. Permit Expiration	a. A source may not be operated after the expiration date of the permit, unless any of the following occur prior to the expiration date of the permit: i. A timely and complete application for renewal or for an Oregon Title V operating Permit has been submitted, or ii. Another type of permit (ACDP or Oregon Title V Operating Permit) has been issued authorizing operation of the source. b. For a source operating under an ACDP or Oregon Title V Operating Permit, a requirement established in an earlier ACDP remains in effect notwithstanding expiration of the ACDP, unless the provision expires by its terms or unless the provision is modified or terminated according to the procedures used to establish the requirement initially.
10.11. Permit Termination, Revocation, or Modification	The Department may modify or revoke this permit pursuant to OAR 340-216-0082 and 340-216-0084.

Emissions device or activity	Pollutant	Emission Factor (EF)	EF units	EF reference
Natural gas combustion	PM₁₀	7.6	lb/MMCF	AP-42
	SO₂	0.6	lb/MMCF	AP-42
	NO_X	100.0	lb/MMCF	AP-42
	CO	84.0	lb/MMCF	AP-42
	VOC	5.5	lb/MMCF	AP-42
Diesel fuel combustion	PM₁₀	2.0	lb/1,000 Gal.	AP-42
	SO₂	71.0	lb/1,000 Gal.	AP-42
	NO_X	20.0	lb/1,000 Gal.	AP-42
	CO	5.0	lb/1,000 Gal.	AP-42
	VOC	0.34	lb/1,000 Gal.	AP-42
Corrugator	PM₁₀	0.006	lb/MSF	Engineer Estimate
	VOC	0.0082	lb/MSF	Engineer Estimate
Finishing Inks	VOC	0.05	lb/lb ink	Mass Balance
Scrap Cyclones	PM	0.83	lb/ton scrap	Source Test