DRAFT/PROPOSED AIR EMISSION PERMIT NO IS ISSUED TO. Potlatch Land & Lumber LLC, Bemidji

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1 DRAFT/PROPOSED AIR EMISSION PERMIT NO IS ISSUED TO Potlatch Land & Lumber LLC, Bemidji POTLATCH LAND & LUMBER LLC, BEMIDJI County Road 45 Bemidji, Hubbard County, Minnesota The emission units, control equipment and emission stacks at the stationary source authorized in this permit reissuance are as described in the Permit Application Table. This permit reissuance supersedes Air Emission Permit No , and authorizes the Permittee to operate the stationary source at the address listed above unless otherwise noted in Table A. The Permittee must comply with all the conditions of the permit. Any changes or modifications to the stationary source must be performed in compliance with Minn. R to Terms used in the permit are as defined in the state air pollution control rules unless the term is explicitly defined in the permit. Unless otherwise indicated, all the Minnesota rules cited as the origin of the permit terms are incorporated into State Implementation Plan under 40 CFR and as such as are enforceable by U.S Environmental Protection Agency (EPA) Administrator or citizens under the Clean Air Act. Permit Type: Federal; Part 70/Limits to Avoid NSR/Limit to Avoid Part 63 Issue Date: {issue date} Expiration Date: { } - All Title I Conditions do not expire. Don Smith, P.E., Manager Air Quality Permits Section Industrial Division For John Stine Commissioner Minnesota Pollution Control Agency TDD (for hearing and speech impaired only): (651) Printed on recycled paper containing at least 10% fibers from paper recycled by consumers

2 Permit Application Type Application Date(s) Permit Action Total Facility Operating Permit-Reissuance Administrative Amendment Major Amendment October 25, 2006 November 24, 2008 June 7, TABLE OF CONTENTS Notice to the Permittee Permit Shield Facility Description Table A: Limits and Other Requirements Table B: Submittals Appendix: Attached and Referenced in Table A Appendix I: Insignificant Activities and Likely Applicable Requirements

3 NOTICE TO THE PERMITTEE: Your stationary source may be subject to the requirements of the Minnesota Pollution Control Agency s (MPCA) solid waste, hazardous waste, and water quality programs. If you wish to obtain information on these programs, including information on obtaining any required permits, please contact the MPCA general information number at: Metro Area Outside Metro Area TTY The rules governing these programs are contained in Minn. R. chs Written questions may be sent to: Minnesota Pollution Control Agency, 520 Lafayette Road North, St. Paul, Minnesota Questions about this air emission permit or about air quality requirements can also be directed to the telephone numbers and address listed above. PERMIT SHIELD: Subject to the limitations in Minn. R , compliance with the conditions of this permit shall be deemed compliance with the specific provision of the applicable requirement identified in the permit as the basis of each condition. Subject to the limitations of Minn. R and , subp. 2, notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

4 FACILITY DESCRIPTION: Potlatch Forest Products Corporation owns and operates a lumber mill located at Hubbard County Road 45, about 10 miles east of Bemidji, Minnesota. The facility makes dimensional lumber of various sizes for the building industry. The plant is located on an approximately 49-acre site in a rural wooded area. The existing facility consists of three lumber drying kilns, two wood fired boilers, and two wood working operations. The major emissions from the kilns are volatile organic compounds (VOCs) that are released from the drying wood. Particulate emissions are emitted from the boilers which are controlled by a multiclone and an electrostatic precipitator (ESP). Opacity emissions from the boilers are monitored by the continuous opacity monitoring system (COMS). Each of the wood working operations is controlled by a cyclone/baghouse system. This facility also has several insignificant emission units. This permit action is the reissuance of the Title V operating permit. The changes allowed with this permit reissuance that were not permitted before includes an administrative amendment for a change in ownership, major amendment to install and operate a new kiln, and mandatory reopenings to address new limits based on performance tests for the boilers. Additionally, new regulatory requirements that have been established through promulgation of new and modified regulations have been incorporated as needed. Finally, various existing permit terms have been clarified or corrected in this permit.

5 A-1 Table A contains limits and other requirements with which your facility must comply. The limits are located in the first column of the table (What To do). The limits can be emission limits or operational limits. This column also contains the actions that you must take and the records you must keep to show that you are complying with the limits. The second column of Table A (Why to do it) lists the regulatory basis for these limits. Appendices included as conditions of your permit are listed in Table A under total facility requirements. Subject Item: Total Facility What to do SOURCE-SPECIFIC REQUIREMENT Permit Appendix: This permit contains an appendix as listed in the permit Table of Contents. The Permittee shall comply with all requirements contained in the Appendix I. The facility currently uses ozone-depleting substances as defined in 40 CFR pt. 82. Sections of the 1990 Clean Air Act Amendments and 40 CFR pt. 82 may apply to your facility. Read Sections and 40 CFR pt. 82 to determine all the requirements that applies to your facility. OPERATIONAL REQUIREMENTS The Permittee shall comply with National Primary and Secondary Ambient Air Quality Standards, 40 CFR pt. 50, and the Minnesota Ambient Air Quality Standards, Minn. R to Compliance shall be demonstrated upon written request by the MPCA. Circumvention: Do not install or use a device or means that conceals or dilutes emissions, which would otherwise violate a federal or state air pollution control rule, without reducing the total amount of pollutant emitted. Operation and Maintenance Plan: Retain at the stationary source an operation and maintenance plan for all air pollution control equipment. At a minimum, the O & M plan shall identify all air pollution control equipment and shall include a preventative maintenance program for that equipment, a description of (the minimum but not necessarily the only) corrective actions to be taken to restore the equipment to proper operation to meet applicable permit conditions, a description of the employee training program for proper operation and maintenance of the control equipment, and the records kept to demonstrate plan implementation. Operation Changes: In any shutdown, breakdown, or deviation the Permittee shall immediately take all practical steps to modify operations to reduce the emission of any regulated air pollutant. The Commissioner may require feasible and practical modifications in the operation to reduce emissions of air pollutants. No emissions units that have an unreasonable shutdown or breakdown frequency of process or control equipment shall be permitted to operate. Air Pollution Control Equipment: Operate all pollution control equipment whenever the corresponding process equipment and emission units are operated, unless otherwise noted in Table A. Fugitive Emissions: Do not cause or permit the handling, use, transporting, or storage of any material in a manner which may allow avoidable amounts of particulate matter to become airborne. Comply with all other requirements listed in Minn. R Noise: The Permittee shall comply with the noise standards set forth in Minn. R to at all times during the operation of any emission units. This is a state only requirement and is not enforceable by the EPA Administrator or citizens under the Clean Air Act. Inspections: The Permittee shall comply with the inspection procedures and requirements as found in Minn. R , subp. 9(A). The Permittee shall comply with the General Conditions listed in Minn. R , subp. 16. PERFORMANCE TESTING REQUIREMENTS Performance Testing: Conduct all performance tests in accordance with Minn. R. ch unless otherwise noted in Tables A and B. Limits set as a result of a performance test (conducted before or after permit issuance) apply until superseded as stated in the MPCA's Notice of Compliance letter granting preliminary approval. Preliminary approval is based on formal review of a subsequent performance test on the same unit as specified by Minn. R , subp. 3. The limit is final upon issuance of a permit amendment incorporating the change. Why to do it Minn. R , subp CFR pt CFR pt. 50; Minn. Stat. Section , subds. 4a & 9; Minn. R , subps. 7A, 7L & 7M; Minn. R , subps. 1, 2 & 4; Minn. R Minn. R Minn. R , subps. 14 and 16(J) Minn. R , subp. 4 Minn. R , subp. 2; Minn. R , subp. 16(J) Minn. R Minn. R Minn. R , subp. 9(A) Minn. R , subp. 16 Minn. R. ch Minn. R , subp. 3

6 A-2 Performance Test Notifications and Submittals: Performance Tests are due as outlined in Table A of the permit. See Table B for additional testing requirements. Minn. R ; Minn. R , subps. 1-4, Minn. R , subps. 1-2 Performance Test Notification (written): due 30 days before each Performance Test Performance Test Plan: due 30 days before each Performance Test Performance Test Pre-test Meeting: due 7 days before each Performance Test Performance Test Report: due 45 days after each Performance Test Performance Test Report - Microfiche Copy: due 105 days after each Performance Test The Notification, Test Plan, and Test Report may be submitted in an alternative format as allowed by Minn. R The following U.S. EPA reference methods (as amended) shall be used, with any modifications required by an applicable requirement, when conducting performance tests pursuant to this permit, unless an applicable requirement specifies a different method: Minn. R , subp. 2; and Minn. R , subp. 1 Method 5, as amended by Minn. R , for Total Particulate Matter Methods 201A and 202 for PM10 Methods 7 or 7E for NOx Method 9 for Opacity Method 10 for Carbon Monoxide Method 25 or Method 25A (with optional Methane correction) for VOC A minor change or an alternative or equivalent method may be approved by the Commissioner in accordance with Minn. R , subp. 2. MONITORING REQUIREMENTS Operation of Monitoring Equipment: Unless otherwise noted in Tables A and/or B, monitoring a process or control equipment connected to that process is not necessary during periods when the process is shutdown, or during checks of the monitoring systems, such as calibration checks and zero and span adjustments. If monitoring records are required, they should reflect any such periods of process shutdown or checks of the monitoring system. Monitoring Equipment Calibration: The Permittee shall calibrate all required monitoring equipment at least once every 12 months (any requirements applying to continuous emission monitors are listed separately in this permit). RECORDKEEPING REQUIREMENTS List of Insignificant Activities Required to be Listed: Appendix I includes activities and sources at the facility that have been determined to be insignificant activities under Minn. R This list may not include every insignificant activity and is subject to change. If the Permittee determines that no permit amendment or notification is required prior to making a change, the Permittee must retain records of all calculations required under Minn. R For expiring permits, these records shall be kept for a period of five years from the date the change was made or until permit reissuance, whichever is longer. The records shall be kept at the stationary source for the current calendar year of operation and may be kept at the stationary source or office of the stationary source for all other years. The records may be maintained in either electronic or paper format. Recordkeeping: Retain all records at the stationary source for a period of five (5) years from the date of monitoring, sample, measurement, or report. Records which must be retained at this location include all calibration and maintenance records, all original recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Records must conform to the requirements listed in Minn. R , subp. 5(A). Recordkeeping: Maintain records describing any insignificant modifications (as required by Minn. R , subp. 3) or changes contravening permit terms (as required by Minn. R subp. 2), including records of the emissions resulting from those changes. REPORTING/SUBMITTALS Application for Permit Amendment: If a permit amendment is needed, submit an application in accordance with the requirements of Minn. R through Minn. R Submittal dates vary, depending on the type of amendment needed. Minn. R , subp. 4(D) Minn. R , subp. 4(D) Minn. R , subp. 2; Minn. R Minn. R , subp. 4 Minn. R , subp. 5(C) Minn. R , subp. 5(B) Minn. R through Minn. R

7 A-3 Extension Requests: The Permittee may apply for an Administrative Amendment to extend a deadline in a permit by no more than 120 days, provided the proposed deadline extension meets the requirements of Minn. R , subp. 1(H). Performance testing deadlines from the General Provisions of 40 CFR pt. 60 and pt. 63 are examples of deadlines for which the MPCA does not have authority to grant extensions and therefore do not meet the requirements of Minn. R , subp. 1(H). Shutdown Notifications: Notify the Commissioner at least 24 hours in advance of a planned shutdown of any control equipment or process equipment if the shutdown would cause any increase in the emissions of any regulated air pollutant. If the owner or operator does not have advance knowledge of the shutdown, notification shall be made to the Commissioner as soon as possible after the shutdown. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 3. At the time of notification, the owner or operator shall inform the Commissioner of the cause of the shutdown and the estimated duration. The owner or operator shall notify the Commissioner when the shutdown is over. Breakdown Notifications: Notify the Commissioner within 24 hours of a breakdown of more than one hour duration of any control equipment or process equipment if the breakdown causes any increase in the emissions of any regulated air pollutant. The 24-hour time period starts when the breakdown was discovered or reasonably should have been discovered by the owner or operator. However, notification is not required in the circumstances outlined in Items A, B and C of Minn. R , subp. 2. Minn. R , subp. 1(H) Minn. R , subp. 3 Minn. R , subp. 2 At the time of notification or as soon as possible thereafter, the owner or operator shall inform the Commissioner of the cause of the breakdown and the estimated duration. The owner or operator shall notify the Commissioner when the breakdown is over. Notification of Deviations Endangering Human Health or the Environment: As soon Minn. R , subp. 1 as possible after discovery, notify the Commissioner or the state duty officer, either orally or by facsimile, of any deviation from permit conditions which could endanger human health or the environment. Notification of Deviations Endangering Human Health or the Environment Report: Minn. R , subp. 1 Within 2 working days of discovery, notify the Commissioner in writing of any deviation from permit conditions which could endanger human health or the environment. Include the following information in this written description: 1. the cause of the deviation; 2. the exact dates of the period of the deviation, if the deviation has been corrected 3. whether or not the deviation has been corrected; 4. the anticipated time by which the deviation is expected to be corrected, if not yet corrected; and 5. steps taken or planned to reduce, eliminate, and prevent reoccurrence of the deviation. Emission Inventory Report: due on or before April 1 of each calendar year following Minn. R through Minn. R permit issuance, to be submitted on a form approved by the Commissioner. Emission Fees: due 30 days after receipt of an MPCA bill. Minn. R through Minn. R

8 Facility Name: Permit Number: Potlatch Land & Lumber LLC - Bemidji Subject Item: GP 001 Kilns Associated Items: EU 001 Kiln #1 EU 002 Kiln #2 EU 003 Kiln #3 EU 013 Kiln #4 SV 001 Kiln #1 SV 002 Kiln #2 SV 003 Kiln #3 SV 010 Kiln #4 A-4 EMISSION LIMITS What to do Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R This limit applies individually to each emission unit listed above under Associated Items. Opacity: less than or equal to 20 percent opacity except for one six-minute period per hour of not more than 60 percent opacity. This limit applies individually to each emission unit listed above under Associated Items. HAP-Single: less than or equal to 9.0 tons/year using 12-month Rolling Sum to be calculated by the 15th day of each month for the previous 12-month period (methanol). Why to do it Minn. R , subp. 1(A) Minn. R , subp. 1(B) Title I Condition: To avoid major source classification under 40 CFR Section 63.2 All emission units or stacks added to GP 001 as allowed in this permit shall be included in this calculation for methanol emissions. MONITORING AND RECORDKEEPING REQUIREMENTS Daily Recordkeeping. On each day of operation, the Permittee shall calculate, record, and maintain the total methanol emissions used under GP 001. Emission Factor: The Permittee shall use the following emission factor of lb/mbf for methanol or on-site generated emission factors, or voluntary industry testing standards. The Permittee shall submit to the Commissioner for approval on-site generated emission factors and voluntary industry testing standards within 60 days before use, and shall not use such factors until approved by the Commissioner. Monthly Recordkeeping - HAP Emissions. By the 15th of the month, the Permittee shall calculate and record the following: 1). The individual HAP (methanol) used in the previous calendar month using the daily usage records. and 2). The 12-month rolling sum individual HAP (methanol) emissions for the previous 12-month period by summing the monthly emissions data for the previous 12 months. Title I Condition: To avoid major source classification under 40 CFR Section 63.2; Minn. R , subps. 4 and 5 Title I Condition: To avoid major source classification under 40 CFR Section 63.2 Minn. R , subps. 4 and 5

9 Facility Name: Permit Number: Potlatch Land & Lumber LLC - Bemidji Subject Item: EU 005 Steam Boiler A-5 Associated Items: CE 001 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones CE 002 Electrostatic Precipitator - High Efficiency SV 005 Boiler #1 EMISSION AND OPERATING LIMITS What to do Total Particulate Matter: less than or equal to 0.10 lbs/million Btu heat input using 3-hour Block Average. The standard does not apply during periods of startup, shutdown, or malfunction. Opacity: less than or equal to 20 percent opacity using 6-minute Average, except for one 6-minute period per hour of not more than 27 percent opacity. This standard does not apply during periods of startup, shutdown, or malfunction. Fuels Allowed: Biomass fuels as defined in 40 CFR Section , and up to 1 percent by weight of the total fuel combusted may consist of manufacturing residue or absorbent material. The manufacturing residue and absorbent material must be generated on site, and may consist of the following: absorbent materials from spills containing oil, lubricating and hydraulic oils; anti-freeze; water-based paints; boiler blow down; dried solid-wood adhesive; and other non-hazardous manufacturing residue. The manufacturing residue and absorbent material shall not contain any of the hazardous waste listed in Minn. R , any wastes specified in Minn. R as hazardous, or any batteries, lamps, switches or any other material where mercury has been purposely introduced. (continued below) The oil contained in any absorbent material that is combusted in EU 005 shall be used oil which is defined as any oil which has been used and as a result of such use has become contaminated by physical or chemical impurities. The used oil shall not contain any hazardous waste listed in Minn. R The used oil must be on-specification and meet the following restrictions: Total Arsenic not to exceed 5 ppm, Total Cadmium not to exceed 2 ppm, Total Chromium not to exceed 10 ppm, Total Lead not to exceed 100 ppm, Flash Point not less than 100 degrees F, Total Halogens not to exceed 1,000 ppm. Prior to combusting any used oil, the Permittee must obtain and keep on-site for at least five years a laboratory analysis or other information, such as the manufacturer's spec. sheet, demonstrating that the used oil is on-specification. (continued below) Other materials may be combusted in this emission unit for a short period of time during a trial burn as approved by the appropriate amendment to this permit. Steam Flow: less than or equal to 27,465 lbs/hour using 8-hour Block Average. Downtime of 15 or more minutes is not included as operating time. Recordkeeping of Steam Flow: The Permittee shall calculate the average steam flow for each 8-hour block by dividing the total steam flow by the total operating time in each 8-hour block. Downtime of 15 or more minutes is not to be included as operating time. CONTROL EQUIPMENT OPERATING REQUIREMENTS (See subject items CE 001 and CE 002 for specific control equipment operating requirements). PERFORMANCE TESTING REQUIREMENTS Performance Test: due before 03/11/2014 to measure Total Particulate Matter emissions from SV 005. MONITORING REQUIREMENTS Emission Monitoring for Opacity: The Permittee shall use COMS to measure opacity from SV 005 (EU 005). See subject item MR 001 and Table B for additional monitoring requirements. Why to do it 40 CFR Section 60.43c(b); 40 CFR Section 60.43c(d); Minn. R CFR Section 60.43c(c); 40 CFR Section 60.43c(d); Minn. R Minn. R , subp. 2 Minn. R , subp. 2 Minn. R , subp. 2 Minn. R , subp. 3 Minn. R , subp. 3 Minn. R , subp.1 40 CFR Section 60.47c; Minn. R The COMS data shall also be used in assessing the control device as required by 40 CFR Section 64.3(d). RECORDKEEPING REQUIREMENTS

10 A-6 Recordkeeping of Fuel Feed Stream: The fuel feed stream composition calculation shall be the ratio of the weights of manufacturing residue and absorbent material to the weight of total fuel (manufacturing residue, absorbent material, and wood) delivered to the boiler. The calculation shall be made by the fifteenth day of each month for the preceding month. The calculated value shall not exceed one percent. The Permittee shall maintain an operating log where the date, weights of manufacturing residue and absorbent material combusted, and weight of wood combusted is recorded daily. The fuel feed stream calculation shall be recorded monthly. Record and maintain records of amount of each fuel combusted during each calendar month as required by 40 CFR Section 60.48c(g)(2). NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR INDUSTRIAL, COMMERICAL, AND INSTITUTIONAL BOILERS AREA SOURCES, 40 CFR pt. 63, subp. JJJJJJ The Permittee must have a one-time energy assessment performed by a qualified energy assessor. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in 40 CFR pt. 63, subp. JJJJJJ, Table 2 satisfies the energy assessment requirement. Energy assessor approval and qualification requirements are waived in instances where past or amended energy assessments are used to meet the energy assessment requirements. A facility that operates under an energy management program compatible with ISO that includes the affected units also satisfies the energy assessment requirement. The energy assessment must include the following with extent of the evaluation for items (1) to (4) appropriate for the on-site technical hours listed in 40 CFR Section ) A visual inspection of the boiler system, (2) An evaluation of operating characteristics of the affected boiler systems, specifications of energy use systems, operating and maintenance procedures, and unusual operating constraints, (3) An inventory of major energy use systems consuming energy from affected boiler(s) and which are under control of the boiler owner or operator, (4) A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage, (5) A list of major energy conservation measures that are within the facility's control, (6) A list of the energy savings potential of the energy conservation measures identified, and (7) A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. (a) At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. If you own or operate an existing or new biomass-fired boiler or an existing or new oil-fired boiler, you must conduct a performance tune-up according to 40 CFR Section (b) and you must submit a signed statement in the Notification of Compliance Status report that indicates that you conducted a tune-up of the boiler. If you own or operate an existing affected boiler with a heat input capacity of 10 million Btu per hour or greater, you must submit a signed certification in the Notification of Compliance Status report that an energy assessment of the boiler and its energy use systems was completed according to 40 CFR pt. 63, subp. JJJJJJ, Table 2 and is an accurate depiction of your facility. For affected sources subject to the work practice standard or the management practices of a tune-up, you must conduct a performance tune-up according to paragraph (b) of this section and keep records as required in 40 CFR Section (c) to demonstrate continuous compliance. You must conduct the tune-up while burning the type of fuel (or fuels in the case of boilers that routinely burn two types of fuels at the same time) that provided the majority of the heat input to the boiler over the 12 months prior to the tune-up. Minn. R , subp CFR Section 60.48c(g); Minn. R CFR Section CFR Section ; 40 CFR pt. 63, subp. JJJJJJ, Table 2 40 CFR Section CFR Section (b) 40 CFR Section (c) 40 CFR Section (a)

11 A-7 Except as specified in paragraphs (c) through (f) of this section, you must conduct a tune-up of the boiler biennially to demonstrate continuous compliance as specified in 40 CFR Section (b)(1) through (7) of this section. Each biennial tune-up must be conducted no more than 25 months after the previous tune-up. For a new or reconstructed boiler, the first biennial tune-up must be no later than 25 months after the initial startup of the new or reconstructed boiler. (1) As applicable, inspect the burner, and clean or replace any components of the burner as necessary (you may delay the burner inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months from the previous inspection. (continued below) (2) Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available. 40 CFR Section (b) 40 CFR Section (b) (3) Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (you may delay the inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 36 months from the previous inspection. (4) Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any nitrogen oxide requirement to which the unit is subject. (continued below) 5) Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. 40 CFR Section (b) (6) Maintain on-site and submit, if requested by the Administrator, a report containing the information in paragraphs (b)(6)(i) through (iii) of this section. (i) The concentrations of CO in the effluent stream in parts per million, by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler. (ii) A description of any corrective actions taken as a part of the tune-up of the boiler. (continued below) (iii) The type and amount of fuel used over the 12 months prior to the tune-up of the boiler, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel use by each unit. (7) If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 days of startup. The Permittee must maintain the records specified in 40 CFR Section (c)(1) through (7) below. (1) As required in 40 CFR Section 63.10(b)(2)(xiv), you must keep a copy of each notification and report that you submitted to comply with this subpart and all documentation supporting any Initial Notification or Notification of Compliance Status that you submitted. 40 CFR Section (b) 40 CFR Section (c) (2) You must keep records to document conformance with the work practices, emission reduction measures, and management practices required by 40 CFR Section and 40 CFR Section as specified in 40 CFR Section (c)(2)(i) through (vi). (i) Records must identify each boiler, the date of tune-up, the procedures followed for tune-up, and the manufacturer's specifications to which the boiler was tuned. (continued below)

12 A-8 (ii) For operating units that combust non-hazardous secondary materials that have been determined not to be solid waste pursuant to 40 CFR Section 241.3(b)(1) of this chapter, you must keep a record which documents how the secondary material meets each of the legitimacy criteria under 40 CFR Section 241.3(d)(1). If you combust a fuel that has been processed from a discarded non-hazardous secondary material pursuant to 40 CFR Section 241.3(b)(4) of this chapter, you must keep records as to how the operations that produced the fuel satisfies the definition of processing in 40 CFR Section and each of the legitimacy criteria in 40 CFR Section 241.3(d)(1) of this chapter. If the fuel received a non-waste determination pursuant to the petition process submitted under 40 CFR Section 241.3(c) of this chapter, you must keep a record that documents how the fuel satisfies the requirements of the petition process. (continued below) For operating units that combust non-hazardous secondary materials as fuel per 40 CFR Section 241.4, you must keep records documenting that the material is a listed non-waste under 40 CFR Section 241.4(a). 40 CFR Section (c) 40 CFR Section (c) (iii) For each boiler required to conduct an energy assessment, you must keep a copy of the energy assessment report. (3) For sources that demonstrate compliance through fuel analysis, a copy of all calculations and supporting documentation that were done to demonstrate compliance with the mercury emission limits. Supporting documentation should include results of any fuel analyses. You can use the results from one fuel analysis for multiple boilers provided they are all burning the same fuel type. (4) Records of the occurrence and duration of each malfunction of the boiler, or of the associated air pollution control and monitoring equipment. (continued below) (5) Records of actions taken during periods of malfunction to minimize emissions in accordance with the general duty to minimize emissions in 40 CFR Section (a), including corrective actions to restore the malfunctioning boiler, air pollution control, or monitoring equipment to its normal or usual manner of operation. (6) You must keep the records of all inspection and monitoring data required by 40 CFR Sections and , and the information identified in paragraphs (c)(6)(i) through (vi) below for each required inspection or monitoring. (i) The date, place, and time of the monitoring event. (ii) Person conducting the monitoring. (iii) Technique or method used. (iv) Operating conditions during the activity. (v) Results, including the date, time, and duration of the period from the time the monitoring indicated a problem to the time that monitoring indicated proper operation. (vi) Maintenance or corrective action taken (if applicable). (continued below) (7) If you use a bag leak detection system, you must keep the records specified in (c)(7)(i) through (iii) below. 40 CFR Section (c) 40 CFR Section (c) 40 CFR Section (c) (i) Records of the bag leak detection system output. (ii) Records of bag leak detection system adjustments, including the date and time of the adjustment, the initial bag leak detection system settings, and the final bag leak detection system settings. (iii) The date and time of all bag leak detection system alarms, and for each valid alarm, the time you initiated corrective action, the corrective action taken, and the date on which corrective action was completed.

13 Facility Name: Permit Number: Potlatch Land & Lumber LLC - Bemidji Subject Item: EU 007 Sawdust Collection Cyclone A-9 Associated Items: CE 004 Fabric Filter - Low Temperature, i.e., T<180 Degrees F SV 006 Sawdust Collection Baghouse EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to 2.12 lbs/hour using 3-hour Rolling Minn. R , subp. 2 Average. This limit is more stringent and also meets the requirements of Minn. R , subp. 1(A). PM < 10 micron: less than or equal to 2.12 lbs/hour using 3-hour Rolling Average Minn. R , subp. 2 Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Because it has been shown that the facility does not cause a violation of ambient air quality standards, and is located outside the Mpls/St. Paul air quality control region and the city of Duluth, and is located at least ¼ mile from any residence or public roadway, and EU 007 is controlled by control equipment which has a collection efficiency of 85% by weight, EU 007 is considered to be in compliance with this requirement. Opacity: less than or equal to 20 percent opacity SEE CE 004 FOR ALL CONTROL EQUIPMENT OPERATING REQUIREMENTS PERFORMANCE TESTING REQUIREMENTS Minn. R , subp. 1(A) Minn. R , subp. 1(B) Initial Performance Test: due 180 days after Resuming Operation to measure PM. Minn. R , subp. 1 Initial Performance Test: due 180 days after Resuming Operation to measure PM10. NOTIFICATION REQUIREMENT Minn. R , subp. 1

14 Facility Name: Permit Number: Potlatch Land & Lumber LLC - Bemidji Subject Item: EU 011 Planer Cyclone A-10 Associated Items: CE 005 Fabric Filter - Low Temperature, i.e., T<180 Degrees F EMISSION LIMITS What to do Why to do it Total Particulate Matter: less than or equal to 3.56 lbs/hour using 3-hour Rolling Minn. R , subp. 2 Average. This limit is more stringent and also meets the requirements of Minn. R , subp. 1(A). PM < 10 micron: less than or equal to 3.56 lbs/hour using 3-hour Rolling Average Minn. R , subp. 2 Total Particulate Matter: less than or equal to 0.30 grains/dry standard cubic foot of exhaust gas unless required to further reduce emissions to comply with the less stringent limit of either Minn. R or Minn. R Because it has been shown that the facility does not cause a violation of ambient air quality standards, and is located outside the Mpls/St. Paul air quality control region and the city of Duluth, and is located at least ¼ mile from any residence or public roadway, and EU 011 is controlled by control equipment which has a collection efficiency of 85% by weight, EU 011 is considered to be in compliance with this requirement. Opacity: less than or equal to 20 percent SEE CE 005 FOR ALL CONTROL EQUIPMENT OPERATING REQUIREMENTS PERFORMANCE TESTING REQUIREMENTS Performance Test: due before 04/17/2017 to measure PM emissions, not to exceed 60 months between test dates. Performance Test: due before 04/17/2017 to measure PM10 emissions, not to exceed 60 months between test dates. Minn. R , subp. 1(A) Minn. R , subp. 1(B) Minn. R , subp. 1 Minn. R , subp. 1

15 Facility Name: Permit Number: Potlatch Land & Lumber LLC - Bemidji Subject Item: EU 012 Boiler #2 A-11 Associated Items: CE 006 Multiple Cyclone w/o Fly Ash Reinjection - Most Multiclones CE 007 Electrostatic Precipitator - High Efficiency MR 002 Lumbermill Boiler SV 009 Boiler #2 EMISSION LIMITS What to do Total Particulate Matter: less than or equal to 0.30 lbs/million Btu heat input using 3-hour Block Average. This limit applies at all times, except during periods of startup, shutdown, or malfunction. Opacity: less than or equal to 20 percent (6-minute average), except for one 6-minute period per hour of not more than 27 percent opacity. This limit applies at all times, except during periods of startup, shutdown, or malfunction. Fuels allowed: Biomass fuels as defined in 40 CFR Section , and up to one percent by weight of the total fuel combusted may consist of manufacturing residue or absorbent material. The manufacturing residue and absorbent materials must be generated on site, and may consist of the following: absorbent materials from spills containing oil, lubricating and hydraulic oils; anti-freeze; water-based paints; boiler blow down; dried solid-wood adhesive; and other non-hazardous manufacturing residue. The manufacturing residue and absorbent material shall not contain any of the hazardous waste listed in Minn. R , any wastes specified in Minn. R as hazardous, or any batteries, lamps, switches or any other material where mercury has been purposely introduced. (continue below) The oil contained in any absorbent material that is combusted in EU 005 shall be used oil which is defined as any oil which has been used and as a result of such use has become contaminated by physical or chemical impurities. The used oil shall not contain any hazardous waste listed in Minn. R The used oil must be on-specification and meet the following restrictions: Total Arsenic not to exceed 5 ppm, Total Cadmium not to exceed 2 ppm, Total Chromium not to exceed 10 ppm, Total Lead not to exceed 100 ppm, Flash Point not less than 100 degree F, Total Halogens not to exceed 1,000 ppm. Prior to combusting any used oil, the Permittee must obtain and keep on-site for at least five years a laboratory analysis or other information, such as the manufacturer's spec. sheet, demonstrating that the used oil is on-specification. (continued below) Other materials may be combusted in this emission unit for a short period of time during a trial burn. The Permittee is required to obtain an approval before proceeding with a trial burn. CONTROL EQUIPMENT OPERATING REQUIREMENTS (see subject items CE 006 and CE 007 for specific control equipment operating requirements) MONITORING REQUIREMENTS Emissions Monitoring for Opacity: The Permittee shall use COMS to measure opacity emissions from SV 009. See subject item MR 002 and Table B for additional monitoring requirements. The COMS data shall also be used in assessing the control device as required by 40 CFR Section 64.3(d). PERFORMANCE TESTING REQUIREMENTS Performance Test: due before 04/17/2017 to measure PM emissions, not to exceed 60 months between test dates. Tests shall be performed in accordance with 40 CFR Section 60.45c. In place of particulate matter testing you may elect to install, calibrate, maintain and operate a continuous emission monitoring system for monitoring particulate matter in accordance with 40 CFR Section 60.45c(d) and 40 CFR Section 60.47c. RECORDKEEPING REQUIREMENTS Record and maintain records of amount of each fuel combusted during each calendar month as required by 40 CFR Section 60.48c(g)(2). Why to do it 40 CFR Sections 60.43c(e) and 60.43c(d); Minn. R CFR Sections 60.43c(c) and 60.43c(d); Minn. R Minn. R , subp. 2 Minn. R , subp. 2 Minn. R , subp CFR Section 60.47c; Minn. R CFR Sections 60.8 and 60.45c; Minn. R , subp CFR Section 60.45c(d) 40 CFR Section 60.48c(g); Minn. R

16 A-12 Maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility; any malfunction of the air pollution control equipment; or any periods during which a continuous monitoring system or monitoring device is inoperative. Maintain a file of all measurements, including continuous monitoring system, monitoring device, and performance testing measurements; all continuous monitoring system performance evaluations; all continuous monitoring system or monitoring device calibration checks; adjustments and maintenance performed on these systems or devices; and all other information required by this Part 60 recorded in a permanent form suitable for inspection. The file shall be retained for at least two years following the date of such measurements, maintenance, reports, and records, except as specified in 40 CFR Section 60.7(f). Recordkeeping of Fuel Feed Stream: the fuel feed stream composition calculation shall be the ratio of the weights of manufacturing residue and absorbent material to the weight of total fuel (manufacturing residue, absorbent material, and wood) delivered to the boiler. The calculation shall be made by the fifteenth day of each month for the preceding month. The calculated value shall not exceed one percent. The Permittee shall maintain an operating log where the date, weights of manufacturing residue and absorbent material combusted, and weight of wood combusted is recorded daily. The fuel feed stream calculation shall be recorded monthly. NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR INDUSTRIAL, COMMERICAL, AND INSTITUTIONAL BOILERS AREA SOURCES, 40 CFR pt. 63, subp. JJJJJJ The Permittee must have a one-time energy assessment performed by a qualified energy assessor. An energy assessment completed on or after January 1, 2008, that meets or is amended to meet the energy assessment requirements in 40 CFR pt. 63, subp. JJJJJJ, Table 2 satisfies the energy assessment requirement. Energy assessor approval and qualification requirements are waived in instances where past or amended energy assessments are used to meet the energy assessment requirements. A facility that operates under an energy management program compatible with ISO that includes the affected units also satisfies the energy assessment requirement. The energy assessment must include the following with extent of the evaluation for items (1) to (4) appropriate for the on-site technical hours listed in 40 CFR Section ) A visual inspection of the boiler system, (2) An evaluation of operating characteristics of the affected boiler systems, specifications of energy use systems, operating and maintenance procedures, and unusual operating constraints, (3) An inventory of major energy use systems consuming energy from affected boiler(s) and which are under control of the boiler owner or operator, (4) A review of available architectural and engineering plans, facility operation and maintenance procedures and logs, and fuel usage, (5) A list of major energy conservation measures that are within the facility's control, (6) A list of the energy savings potential of the energy conservation measures identified, and (7) A comprehensive report detailing the ways to improve efficiency, the cost of specific improvements, benefits, and the time frame for recouping those investments. (a) At all times you must operate and maintain any affected source, including associated air pollution control equipment and monitoring equipment, in a manner consistent with safety and good air pollution control practices for minimizing emissions. The general duty to minimize emissions does not require you to make any further efforts to reduce emissions if levels required by this standard have been achieved. Determination of whether such operation and maintenance procedures are being used will be based on information available to the Administrator that may include, but is not limited to, monitoring results, review of operation and maintenance procedures, review of operation and maintenance records, and inspection of the source. If you own or operate an existing or new biomass-fired boiler or an existing or new oil-fired boiler, you must conduct a performance tune-up according to 40 CFR Section (b) and you must submit a signed statement in the Notification of Compliance Status report that indicates that you conducted a tune-up of the boiler. If you own or operate an existing affected boiler with a heat input capacity of 10 million Btu per hour or greater, you must submit a signed certification in the Notification of Compliance Status report that an energy assessment of the boiler and its energy use systems was completed according to 40 CFR pt. 63, subp. JJJJJJ, Table 2 and is an accurate depiction of your facility. 40 CFR Section 60.7(b) 40 CFR Section 60.7(f) Minn. R , subp CFR Section CFR Section ; 40 CFR pt. 63, subp. JJJJJJ, Table 2 40 CFR Section CFR Section (b) 40 CFR Section (c)

17 A-13 For affected sources subject to the work practice standard or the management practices of a tune-up, you must conduct a performance tune-up according to paragraph (b) of this section and keep records as required in 40 CFR Section (c) to demonstrate continuous compliance. You must conduct the tune-up while burning the type of fuel (or fuels in the case of boilers that routinely burn two types of fuels at the same time) that provided the majority of the heat input to the boiler over the 12 months prior to the tune-up. Except as specified in paragraphs (c) through (f) of this section, you must conduct a tune-up of the boiler biennially to demonstrate continuous compliance as specified in 40 CFR Section (b)(1) through (7) of this section. Each biennial tune-up must be conducted no more than 25 months after the previous tune-up. For a new or reconstructed boiler, the first biennial tune-up must be no later than 25 months after the initial startup of the new or reconstructed boiler. (1) As applicable, inspect the burner, and clean or replace any components of the burner as necessary (you may delay the burner inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). Units that produce electricity for sale may delay the burner inspection until the first outage, not to exceed 36 months from the previous inspection. (continued below) (2) Inspect the flame pattern, as applicable, and adjust the burner as necessary to optimize the flame pattern. The adjustment should be consistent with the manufacturer's specifications, if available. 40 CFR Section (a) 40 CFR Section (b) 40 CFR Section (b) (3) Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is correctly calibrated and functioning properly (you may delay the inspection until the next scheduled unit shutdown, not to exceed 36 months from the previous inspection). Units that produce electricity for sale may delay the inspection until the first outage, not to exceed 36 months from the previous inspection. (4) Optimize total emissions of CO. This optimization should be consistent with the manufacturer's specifications, if available, and with any nitrogen oxide requirement to which the unit is subject. (continued below) 5) Measure the concentrations in the effluent stream of CO in parts per million, by volume, and oxygen in volume percent, before and after the adjustments are made (measurements may be either on a dry or wet basis, as long as it is the same basis before and after the adjustments are made). Measurements may be taken using a portable CO analyzer. 40 CFR Section (b) (6) Maintain on-site and submit, if requested by the Administrator, a report containing the information in paragraphs (b)(6)(i) through (iii) of this section. (i) The concentrations of CO in the effluent stream in parts per million, by volume, and oxygen in volume percent, measured at high fire or typical operating load, before and after the tune-up of the boiler. (ii) A description of any corrective actions taken as a part of the tune-up of the boiler. (continued below) (iii) The type and amount of fuel used over the 12 months prior to the tune-up of the boiler, but only if the unit was physically and legally capable of using more than one type of fuel during that period. Units sharing a fuel meter may estimate the fuel use by each unit. 40 CFR Section (b) (7) If the unit is not operating on the required date for a tune-up, the tune-up must be conducted within 30 days of startup.

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