1. Owens Coming Roofing and Asphalt, LLC3750 NW Yeon AvenuePortland, OR 97210
PERMITTING ACTION
2. The proposed permit is a renewal of an existing Standard Air Contaminant Discharge
Permit (ACDP) that was issued on 02/20/2009 and was originally scheduled to expire on09/01/2013. The permittee is on a Standard ACDP because they have source specificPSEL's greater than the generic PSEL and they have baseline/netting basis they wish toretain. The existing ACDP remains in effect until final action is been taken on the
renewal application because the permittee submitted a timely and complete application
for renewal.
3. Owens Coming Roofing and Asphalt, LLC has been determined to be an existing source
for the purposes of Cleaner Air Oregon in accordance with OAR 340-245-0020 because
the air quality permit application was submitted and deemed complete, or construction
had commenced on this facility prior to November 16, 2018. As an existing source the
permittee is required to perform a risk assessment in accordance with OAR 340-245-0050, and demonstrate compliance with the Risk Action Levels for an "Existing Source"
in OAR 340-245-8010 Table 1 when called in by DEQ. Owens Coming Roofing andAsphalt, LLC has not been called in and therefore, has not been required to perform a risk
assessment.
OTHER PERMITS
4. Other permits issued or required by the DEQ for this source include a hazardous waste
generator permit (ORD987180940).
ATTAINMENT STATUS
5. The source is located in an attainment area for PMio, NOx, and 802 and a maintenance
area for Ozone and CO. NOx and VOC are precursors to Ozone.
6. The source is not located within 10 kilometers of a Class I Air Quality Protection Area.
7. The permittee manufactures three types of roofing products: rolled roofing, standard(non-laminate) residential roofing, and laminated residential roofing. The facility was
established prior to 1972.
Raw materials (fillers, parting agents, and surfacing materials) are received by truck and
stored in silos, bins and bags. Filler is passed through the upper surge hopper, through
the filler heater, to the lower surge hopper. Emissions from the upper surge hopper arecontrolled by a dust collector.
Sealant asphalt received by bulk truck is loaded into storage tanks. Material from these
tanks is pumped to the sealant use tank or the laminate sealant use tank. Fumes from thesealant bulk storage tank are vented through the MLA/Sealant fiber bed filter. Fumes
from the laminate sealant use tank are vented through the Coating Area fiber bed filter.MLA means 'modified laminate adhesive'.
Coating asphalt is first placed in storage tanks, then mixed with filler for use in the
asphalt coater. "Filled coating" is moved from the mixer to the asphalt coater through a
surge tank. Both units are vented to the Coating Area fiber bed filter. During
manufacture, the mixture is continuously circulated between the surge tank and the
coater. For the Duration™ product, a blend of laminate and sealant asphalt is mixed with
filled coating in the sealant mix tanks prior to application to the product.
The manufacture of asphalt roofing is a continuous process. A roll offiberglass mat is
placed on a reel and unwound onto a dry looper. The looper acts as a reservoir of base
material and allows continuous operation. The fiberglass mat moves through the asphalt
coater, where filled coating is applied to top and bottom surfaces simultaneously. Theclearance between the coating rolls regulates the amount of coating applied.
After the asphalt coating is applied, surfacing materials (granules), parting agents, andrelease tape are applied to the sheet in the mineral surfacing area. Pressure rollers embed
the materials into the asphalt. For standard (non-laminated product), the asphalt sealantextruder applies three parallel beads of heated asphalt to the cooled mat. Air and water
sprays are applied to cool the sealant before the mat enters the finish looper. A
soap/water mixture is applied to prevent the sealant fi'om sticking to other sheets. The
mat is cut; sheets are stacked and moved to the packaging area.
Laminator asphalt received by truck is stored in the bulk storage tank and heated by a hotoil heater before being pumped to the MLA use tank. For laminated product, MLA is
applied to the cooled mat in the MLA application area. Next, sealant asphalt from the
laminate sealant use tank is applied in the laminate sealant application area.
Fiber bed filterFiber bed filterFiber bed FilterFiber bed filterFiber bed filterFiber bed filterFiber bed filterFiber bed filterFiber bed filterDust collector
11. The facility was inspected on 06/05/2018 and found to be in compliance with all permitconditions.
12. During the prior permit period there was one odor complaint received by the facility. The
complaint was forwarded to the facility for investigation.
13. No enforcement actions have been taken against this source since the last permit renewal.
EMISSIONS
14. Proposed PSEL information:
Pollutant
PM
PMio
PM2.5
S02
NOx
co
voc
Baseline
Emission
Rate
(tons/yr)
13686
26
278
79201
33
Netting Basis
Previous
(tons/yr)
1368626
260
7920133
Proposed
(tons/yr)
106
10626
26064
7946
Plant Site Emission Limits (PSEL)
PreviousPSEL
(tons/yr)
9696
n/a
0
3999
64
ProposedPSEL
(tons/yr)
9696
26n/a
399964
PSELIncrease
(tons/yr)
00
n/a
n/a
000
a. The baseline emission rate was established in previous permitting actions and
there is no new information that effects the previous determination.
b. The Baseline Emission Rates were recalculated in September 2003, and were
received after the last permit was issued. Emission factors developed by source
testing conducted by the trade association, ARMA, were used. The figures
listed under proposed Netting Basis reflect the changes. PM was not included in
the submitted calculations, so is assumed to be the same as PMio.
c. For Standard ACDPs, the netting basis is equal to the baseline emission rate
minus emission reductions required by rule plus emission increases approved in
accordance with OAR 340, division 224 (NSR rules).
d. The PM2.5 baseline emission rate was calculated as a ratio ofPMio emissions.
The total PMio emissions for the facility in 2019 was 61.39 tons and the totalPM2.5 emissions were 18.96, a ratio of 0.31. The PM2.5 emissions weredetermined by multiplying the ratio ofPM2.5 by PMio emissions.
e. The PSEL for NOx and CO are set to the generic PSEL levels.
f. The previous PSEL is the PSEL in this permit, with the addition ofPM2.5.
g. The basis for the PSEL can be found in Attachment A at the end of this
document.
h. S 02 emissions from the asphalt pre-heater and hot oil heaters are projected to be
0.04 tons per year and is not included in the PSEL.
i. The PSEL is a federally enforceable limit on the potential to emit.
15. In addition to the PSEL, the permit includes the following:
Pollutant
PM
PMio
S02
NOx
Unassigned Emissions (tons/yr)
101040
25
Emission Reduction Credits (tons/yr)
a. Owens-Coming shut down the asphalt blowing operation on IVIay 15, 2002. The
equipment was removed, ensuring a permanent reduction in actual emissions.The figures shown in the table above were incorrectly put in the Emission
Reduction Credits column because the company was offered the opportunity toapply for the credits on or before May 14, 2004.
b. The figures are now correctly placed in the Unassigned Emissions column. The802 figure has been reduced to one Significant Emission Rate per OAR 340-
222-0045. Requiring a permit modification, the permittee may use unassigned
emissions as necessary to address process changes and production increases solong as no criteria pollutant is emitted at a level above 99 tons/year.
SIGNIFICANT EMISSION RATE ANALYSIS
16. For each pollutant, the proposed Plant Site Emission Limit is less than the sum of the
Netting Basis and the significant emission rate, thus no further air quality analysis isrequired at this time.
TITLE V MAJOR SOURCE APPLICABILITY
17. A major source is a facility that has the potential to emit 100 tons/year or more of any
criteria pollutant or 10 tons/year or more of any single HAP or 25 tons/year or more ofcombined HAPs.
24. The Cleaner Air Oregon Toxic Air Contaminant emissions inventory for this source can
be found on this website: https://www.deq.state.or.us/AQPermitsonline/26-1815-ST-01 ATEI 2016.PDF
25. Owens Coming Roofing and Asphalt, LLC has not been called in and therefore, has notbeen required to perform a risk assessment.
TOXICS RELEASE INVENTORY
26. The Toxics Release Inventory (TRI) is federal program that tracks the management of
certain toxic chemicals that may pose a threat to human health and the environment, over
which DEQ has no regulatory authority. It is a resource for learning about toxic chemicalreleases and pollution prevention activities reported by certain industrial facilities.
Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA)created the TRI Program. In general, chemicals covered by the TRI Program are thosethat cause:
a. Cancer or other chronic human health effects;
b. Significant adverse acute human health effects; or
27. There are currently over 650 chemicals covered by the TRI Program. Facilities that
manufacture, process or otherwise use these chemicals in amounts above established
levels must submit annual TRI reports on each chemical.
28. Owens Coming reported the release of the following TRI-listed chemicals in 2019:
ON SITE RELEASES BY CHEMICAL
COPPER COMPOUNDSPOLYCYCLIC AROMATIC COMPOUNDS
LEAD COMPOUNDS
MERCURY COMPOUNDS
^ZO(G.HJ)PERYLENE
Quantity Reported
(Pounds)
NR
2.314
0.1178
I 0.0139
0,0001
Health
Cancer
•/
/
Effects
Other
/
•/
^
Air ^B Water ^B LandNR - No on-site releases reported for thischemical
ADDITIONAL REQUIREMENTS
NEW SOURCE PERFORMANCE STANDARDS APPLICABILITY
29. 40 CFR Part 60, Subpart UU: Standards of Performance for Asphalt Processing and
Asphalt Roofing Manufacture is applicable to the source because the source operates a
point source asphalt production facility.
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTSAPPLICABILITY
30. 40 CFR Part 63, Subpart HHHH is not applicable to the source because they are not a
major source ofHAP emissions.
31. 40 CFR Part 63, Subpart AAAAAAA: National Emission Standards for Hazardous AirPollutants for Area Sources: Asphalt Processing and Asphalt Roofing Manufacture is
applicable to the facility because they operate a roofing manufacture facility.
32. The source is subject to the following updated federal standards or requirements that, at
time of permit issuance, have not been adopted by the Environmental Quality
Commission. For any violations of the following specific regulation, the permittee maybe subject to enforcement action by EPA, but not DEQ. DEQ retains the authority to
modify the permit or issue addenda as provided in Oregon Administrative Rule Chapter
340 Division 216 if the EQC adopts these regulations.
Applicable Federal Standards Not Yet Adopted by EQC40 CFR Part
33. The source is not currently subject to greenhouse gas reporting under division 215
because actual greenhouse gas emissions are less than 2,500 metric tons (2,756 short
tons) ofC02 equivalents per year. If the calendar year greenhouse gas emissions (C02e)
are ever greater than or equal to 2,756 tons (2,500 metric tons), the permittee must
annually register and report its greenhouse gas emissions with DEQ in accordance with
OAR 340 division 215, in addition to reporting greenhouse gas emissions for PSELcompliance.
REASONABLY AVAILABLE CONTROL TECHNOLOGY APPLICABILITY
34. The facility is located in the Portland AQMA but it is not one of the listed sourcecategories in OAR 340-232-0010, thus the RACT rules do not apply.
TYPICALLY ACHIEVABLE CONTROL TECHNOLOGY APPLICABILITY
35. The source is likely meeting OAR 340-226-0130 Highest and Best Practicable Treatment
and Control and Typically Achievable Control Technology (TACT) by operating fivefiber bed filters and five dust collectors to control emissions.
SOURCE TESTING
PROPOSED TESTING
36. The Saturator will be tested at least once during the permit term for PM. or PAH
emissions according to the testing requirements listed in NESHAP AAAAAAA andNSPS UU. The following production and control device parameters will be recorded
during the tests: Opacity, Quantity of material processes and the emission rate, control
37. Pursuant to OAR 340-2 16-0066(4)(a)(A), issuance of Standard Air ContaminantDischarge Permits require public notice in accordance with OAR 340-209-0030(3)(b),which requires DEQ to provide notice of the proposed permit action and a minimum of
30 days for interested persons to submit written comments. The public notice was
emailed/mailed on December 30, 2020 and the comment period ended on January29th at 5:00 p.m.
38. No comments were received during the public notice period. The Standard ACDP for
Owens Coming Roofing and Asphalt, LLC abn Trumbull Asphalt located at 3750 NWYeon Avenue in Portland is issued as proposed.
OC - Compiled source test results from Owens Corning
Reg. - Regulatory grain loading limit
regonKate Brown, Governor
Department of Environmental QualityNorthwest Region Portland Office
700 NE Multnomah St., Suite 600
Portland, OR 97232
(503) 229-5263
FAX (503) 229-6945Tn/7ii
February 2, 2021
Justin Keamey
Owens Coming Roofing and Asphalt, LLC3750 NWYeon AvenuePortland OR 972101322
Re: Renewal of a Standard Air Contaminant Discharge PermitPermit No.: 26-1815-ST-01
Multnomah County
DEQ has completed processing your application for renewal of your Standard Air Contaminant
Discharge Permit. Based on the material contained in the application we have issued the enclosed
permit.
The permit became effective the date it was signed. If you wish to appeal any of the conditions or
limitations contained in the attached permit or if you have any questions, please contact Louis Bivins inour NWR Portland office at (503) 229-6333. If issues related to the permit conditions cannot beresolved to your satisfaction, you may request a hearing before the Environmental Quality Commissionor its authorized representative, pursuant to ORS Chapter 183 and OAR division 216. Such request for
hearing shall be made in writing to the Director on or before 20 days following the date of permit
issuance.
You may appeal conditions or limitations contained in the attached permit by applying to the
Environmental Quality Commission, or its authorized representative, within twenty days from the date
of this letter. Appeals are pursuant to ORS Chapter 183 and procedures are found in OAR Chapter 340Division 11.
A copy of the current permit must be available at the facility at all times. Failure to comply with permit
conditions may result in a civil penalty. You are expected to read the permit carefully and comply with
all conditions to protect the environment of Oregon.
