Oregon Cascade Building Materials, Inc. Page 1 of 7. Lane Regional Air Protection Agency Standard Air Contaminant Discharge Permit.

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1 Orego Cascade Buildig Materials, Ic. Page 1 of 7 Expiratio Date: December 12, 2023 Orego Cascade Buildig Materials Ic Highway 99 South Juctio City, Orego Lae Regioal Air Protectio Agecy Stadard Air Cotamiat Discharge Permit Source Iformatio: SIC 2491 ICS Source Categories (LRAPA Title 37, Table 1) Public Notice Category B 73 II Compliace ad Emissios Moitorig Requiremets: Uassiged emissios Source test [date(s)] Emissio credits COMS Special Coditios CEMS Compliace schedule Ambiet moitorig Reportig Requiremets Aual report (due date) Feb 15 NSPS Report (due date) Mothly report (due dates) Excess emissios report Other reports y Air Programs NSPS (list subparts) NESHAP (list subparts) CAM Regioal Haze (RH) Sythetic Mior (SM) Part 68 Risk Maagemet Title V ACDP (SIP) New Source Review (NSR) Prevetio of Sigificat Deterioratio (PSD) Acid Rai Clea Air Mercury Rule (CAMR) TACT A, QQQQQQ

2 Orego Cascade Buildig Materials, Ic. Page 2 of 7 Expiratio Date: December 12, 2023 REVIEW REPORT Orego Cascade Buildig Materials Ic. 1. Permittee Idetificatio Orego Cascade Buildig Materials Ic. ( the facility ) operates a wood preservig facility located at Highway 99 South i Juctio City. 2. Geeral Backgroud Iformatio The facility curretly is used for the re-maufacturig of woode guard rail posts, equipmet repair, ad lumber storage. The facility is applyig to coduct wood treatmet usig several water-based solutios: aqueous copper azole (CA-C), chromated copper arseate (CCA), copper ammoium carboate (ACQ) ad borate-based solutio. The wood products are treated uder pressure i a closed cylidrical vessel or retort by forcig water-bore preservatives deep ito the cells of the wood. The maximum operatig schedule for the facility is 7,000 hours per year (20 hours per day, 7 days per week, ad 50 weeks per year). 3. Reasos for Permit Actio The facility operates a process listed i Table 1, Part B, of LRAPA Title 37 ad is, therefore, required to obtai a permit. The facility will emit a maximum of less tha 10 tos/year of each criteria pollutat ad qualifies for a Simple Low ACDP. LUCS: The Lad Use Compatibility Statemet (LUCS) icluded with the facility applicatio was approved by Lae Couty o October 28, 2014 submitted by Superior Forest Products for a water quality NPDES stormwater geeral permit. LRAPA also has a LUCS o file from a previous permit applicatio for the facility locatio that was approved by Lae Couty o July 11, The more recet LUCS was submitted by Hexio Ic. for a Air Quality Notice of Costructio. LRAPA cosiders the LUCS requiremet fulfilled by the submittal of both approved statemets. 4. Emissio Uit Descriptio The emissio uits regulated by the permit are the followig: Emissio Uit EU ID Three (3) Retorts waterbore preservig, electrically heated Wood processig Cuttig, icisig, staiig Drip Pad ad Product Storage Categorically Isigificat Activities Icludig: Multiple Storage Taks ot subject to a New Source Performace Stadard (NSPS) Retorts CIA

3 Orego Cascade Buildig Materials, Ic. Page 3 of 7 Expiratio Date: December 12, Process Descriptio The basic process at the facility is as follows. The facility has cut, virgi (gree/udried) wood, as well as wood kil-dried by others, trasported to the site. Wood received gree is treated gree. The facility does ot perform ay kil dryig of wood osite. Prior to treatmet, the wood is take to a icisor. The icisor mechaically cuts slits ito the wood. If the product is staied, it will be placed i a storage area util it is trasferred to a retort for treatmet. If the product is ot staied, it is trasferred directly to a retort for treatmet. The water-based preservatives used at the facility are: aqueous copper azole (CA-C); chromated copper arseate (CCA); ammoia copper carboate (ACQ); ad borate-based solutio The wood is the pushed ito the retort. The retort is filled with the preservative ad the vessel is the pressurized. Oce the wood has bee treated, the pressure is relieved, ad the liquid is pumped out of the retort ito a holdig tak. The retort is the opeed ad the charge is pulled out to dry o the drip pad. The charges are required to stay o the drip pads util the treatmet egieer certifies that drippig has ceased. Oce the charge is determied to stop drippig, it is moved off of the pad ad put ito the storage yard util shipped. 6. Eforcemet History This is a ew facility ad has ot received ay eforcemet actios. 7. Performace Test Results The facility is ot required to coduct testig. 8. Plat Site Emissio Limits (PSELs) The followig aual (rollig 12-moth) PSELs are detailed i the permit (all values are i tos per year). Aual (12-Moth Rollig) PSELS (tos/year) Source VOC Plat Site Total 39 I accordace with LRAPA title 42 the Plat Site Emissio Limits (PSELs) i the permit are set at the Geeric PSEL level for all pollutats emitted above the de miimis level. The attachmet to this review report cotais the calculatios of estimated emissios based upo actual throughputs. The facility is required to record mothly wood preservatio throughput by treatmet type to determie compliace with the 12-moth rollig PSELs.

4 Orego Cascade Buildig Materials, Ic. Page 4 of 7 Expiratio Date: December 12, Baselie Emissio Rate (BER), Nettig Basis ad Sigificat Emissio Rate (SER) The facility did ot operate i the baselie period for criteria pollutats or for greehouse gases (GHGs) ad does ot have a baselie emissio rate. Pollutat PM PM10 PM2.5 CO NOx SO2 VOC GHG Baselie Emissio Rate (tos/yr) Previous (tos/yr) Nettig Basis Proposed (tos/yr) Plat Site Emissio Limit (PSEL) PSEL Icrease Previous Proposed over PSEL PSEL ettig (tos/yr) (tos/yr) basis (tos/yr) VOCs from the wood treatig process are estimated to be a maximum of approximately 2 tos/year. 10. Other Emissio Limitatios The permit icludes geeral visible emissios limitatios for the facility. The permit also icludes geeral grai-loadig (particulate matter) limitatios for the facility. Stadards ad rules pertaiig to fugitive emissio sources, icludig EU-Woodworkig, are specified i the permit. 11. Hazardous Air Pollutats (HAPs) The projected maximum potetial HAP emissios from the facility are show i the followig table: Pollutat Pouds/year Chromium Total HAPs Natioal Emissio Stadards for Hazardous Air Pollutats (NESHAPs) The HAP estimatios show that the facility emits less tha 10 tos per year of ay sigle HAP ad less tha 25 tos per year for ay combiatio of HAPs ad is, therefore, a mior or Area source of HAPs. The facility is subject to the area source wood-treatmet NESHAP (Subpart QQQQQQ Natioal Emissio Stadards for Hazardous Air Pollutats for Wood Preservig Area Sources) ad the requiremets from the NESHAP are cotaied i the permit.

5 Orego Cascade Buildig Materials, Ic. Page 5 of 7 Expiratio Date: December 12, Emissios of Ammoia Ammoia is ot a HAP, or is it a directly-regulated air or criteria pollutat. The permit does ot cotai ay limits o emissios of ammoia, but the facility is required to record ad aually report all wood preservig chemical usage by amout ad type, icludig ammoia. 14. Typically Achievable Cotrol Techology (TACT) LRAPA requires a existig emissio uit at a facility to meet TACT if the emissios uit has emissios of criteria pollutats greater tha 10 tos per year of ay gaseous pollutat or five (5) tos per year of particulate, ad the emissios uit is ot subject to the emissios stadards uder LRAPA Title 32, Title 33, Title 39, or Title 46 for the pollutats emitted, ad the facility is required to have a permit. There are ot emissio uits at the facility that are required to meet TACT. 15. New Source Review (NSR) ad Prevetio of Sigificat Deterioratio (PSD) Because the proposed PSELs for all regulated pollutats are below the Sigificat Emissio Rates (SERs) i LRAPA Title 38, the facility is ot subject to LRAPA s New Source Review (NSR) requiremets for PM10, or the Prevetio of Sigificat Deterioratio (PSD) requiremets for SOX, NOX, CO, ad VOC. 16. New Source Performace Stadards (NSPSs) There are o sources at the facility subject to ay NSPS. 17. Recordkeepig The facility is required to record ad maitai a record of the followig iformatio for a period of five (5) years: Item Parameter a. Amout of wood treated by treatmet solutio type (cubic feet) b. Name, type ad quatity (gallos or pouds) of all chemicals used i the wood treatmet process Miimum Recordig Frequecy Mothly Mothly 18. Reportig Requiremets The facility is required to record wood treatig o a mothly basis ad submit a aual report by February 15 th of each year. 19. Public Notice The draft permit was o public otice from November 7, 2018 to December 6, No public hearig was required or held. Writte commets were submitted by oe (1) idividual durig the commet period ad are summarized i item 20 below. 20. Public Commet ad Respose Commet: Oe perso commeted that they had the experiece of previously bee exposed to chemicals that were cosidered miimally harmful ad were curretly sufferig sigificat chroic ad debilitatig symptoms. Based o that experiece, the commeter suggested LRAPA place

6 Orego Cascade Buildig Materials, Ic. Page 6 of 7 Expiratio Date: December 12, 2023 icreased operatioal restrictios o the facility. The commeter oted that orgaophosphates, CCA, chromium, etc. are very harmful to humas, aimals ad the eviromet. Additioally, the commeter proposed as a potetial solutio that the facility use plastic guard rail posts istead of wood i their productio process. The beefits of such a chage would both decrease timber usage ad help reduce plastic pollutio. Lastly the commeter emphasized that LRAPA should reduce the public s exposure to toxic air cotamiats ad ot approve the proposed permit. The commeter oted that plats i Caada operate ecoomically with much more striget filters ad cotrols, ad that Orego ad the Uited States are able to do the same. LRAPA Respose: LRAPA appreciates the poits raised i the commet ad thaks the commeter for their iterest i the draft permit. With this permit actio, LRAPA is placig additioal operatioal restrictios o the facility by way of federal work practice stadards to miimize emissios (see Coditios 8, 9, 10 ad 11 i the permit). Also, i Jauary of 2018 LRAPA adopted rule chages that removed permittig exemptios for facilities that perform wood preservatio usig waterbore chemicals. Had the LRAPA Board of Directors ot adopted those chages suggested by LRAPA staff, this facility would ot have bee required to obtai a Air Cotamiat Discharge Permit (air permit) from LRAPA sice all of their preservatio chemicals are waterbore. Without the rule chage, the facility may have volutarily complied with the ewly imposed work practice requiremets, but ow the LRAPA-issued permit requires the facility to comply be subject to additioal oversight from the Agecy. The use of alterative process materials is ot somethig LRAPA has the authority to require, but your commet about substitutig plastic for wood materials is oted for the permit record. For the last commet about reducig exposure ad requirig more striget filters ad cotrols, LRAPA otes that most or all of the emissios are what are called fugitive emissios, which are those emissios that could ot reasoably pass through a stack. As such, they are ot able to be veted to a cotrol device such as a carbo filtratio system. Give the fugitive ature of the emissios, work practices to reduce chemical usage ad miimize public exposure is cosidered a appropriate cotrol techology that is available. Max 12/10/18

7 Orego Cascade Buildig Materials, Ic. Page 7 of 7 Expiratio Date: December 12, 2023 Emissio Factors ad Emissio Details: