1.	Facility Name/Site Identifier	Louisiana-Pacific Corporation Engineered Wood Products Facility, Hines, Oregon

2.	Legal name (as registered with the Oregon Corporations Division) Louisiana-Pacific Corporation

3.	Mailing address

a.	PO box or street number P.O. Box 587

b.	city, state, and zip code  Hines, Oregon 97738

4.	Facility location address

a.	street address  Highway 20 West MP 128.4

b.	city and zip code Hines, Oregon 97738

c.	county Harney

5.	Contact information

a.	name and title Ray Hendricks, Environmental Manager, L-P Engineered Wood Products division

b.	area code and telephone number (503) 821-5147

c.	mailing address 111 SW Fifth Ave, Portland, Oregon 97204

6.	Business activity information

a.	primary SIC 2439

b.	facility description

The facility utilizes softwood veneer to produce Laminated Veneer Lumber (LVL) and I-Joists.
The plant, which has been in existence approximately 14 years, has significantly expanded production since it was acquired in March 1997 from Tecton Laminates Inc. by Louisiana-Pacific. The facility currently runs three shifts and has 240 employees. In early 1998, the Hines plant became the first L-P Engineered Wood Products facility to participate in Louisiana-Pacific Environmental Management System (EMS). 

7.	Please provide information about your current regulatory status.   

Regulatory Status Category 	
Permit Number	
Permitting or Compliance Issues	
RCRA:  Is your facility	
A Large Quantity Generator?	Y    N   DK			
A Small Quantity Generator?	Y    N   DK			
A Conditionally Exempt Generator?	Y    N   DK	ORD
987177086	A $6,000 DEQ civil penalty was assessed for RCRA violations from a September 1997 hazardous waste inspection. The penalty was reduced to $1,000 because the violations stemmed from problems L-P inherited from previous owners. The DEQ inspector said L-P was "extremely proactive and cooperative" in responding to the situation. In 1998, L-P's hazardous waste generator status changed from SQG to CEG. This reduction was a result of improved operating procedures implemented in the plant's early EMS stages. 	
A TSD Facility?	Y    N   DK			
AIR:  Is your facility	
Not required to have a permit?	Y    N   DK			
Permitted under an ACDP?	Y    N   DK	13-0016	L-P's Synthetic Minor ACDP controls particulate, CO, NOx and VOCs. L-P actively works with DEQ to control and reduce air emissions despite production increases. It is thus not a Title V major air pollution source. No air quality compliance issues have emerged since L-P assumed operation of the Hines facility. 	
Permitted under a Title V permit?	Y    N   DK			
WATER:  Is your facility	
Not required to have a permit?	Y    N   DK 			
Permitted under a WPCF permit?	Y    N   DK 			
Required to pretreat?	Y    N   DK 			
Permitted under an NPDES permit?	Y    N   DK 	1200-Z, 500-J	L-P has two NPDES permits, one for discharges from boiler blowdown, another for storm water discharges. L-P self-reported and immediately corrected pH level compliance problems with the boiler NPDES permit shortly after acquiring the plant in March 1997. DEQ compliance procedures required issuance of a Notice of Noncompliance (NON), but no civil penalty was assessed. 	
Permitted under a Tier I storm water permit?	Y    N   DK 			
Permitted under a Tier II storm water permit?	Y    N   DK 			
Regulated under the Underground Injection Control Program?	Y    N   DK 			
Permitted under a POTW discharge permit?	Y    N   DK 			
OTHER:  Is your facility	
Required to have a Solid Waste Permit?	Y    N   DK 	Letter 
Authorization	L-P received DEQ May 1999 letter permit to use wood waste as soil amendment at its site. This is part of a project to clean up debris accumulated by previous owner. 	
A TRI reporter?	Y    N   DK 			
A State Fire Marshal Hazardous Substance reporter?	Y    N   DK		Hazardous substances reported on the facility’s Tier II inventory include:
•	Formaldehyde
•	Methanecarboxylic acid
•	Toluene
•	Petroleum products
•	Acetylene
•	Ethylene glycol
•	Sodium hydroxide
•	Phosphoric acid
•	Diethylethanolamine
•	Nitrogen
•	Oxygen (compressed)
•	Propane
•	Potassium hydroxide
•	Sodium metabisulfite
•	Ethoxylated tallow alkylytrimethylene
•	Polyamide
•	Bark dust
•	Sodium carbohydrate
•	Ethylene vinyl acetate copolymer
•	Aluminum oxide
•	Silica 	
A potentially responsible party under Superfund?	Y    N   DK 		On March 6, 1997 L-P entered into a Prospective Purchaser Agreement with ODEQ. Under this agreement, L-P entered ODEQ's Voluntary Cleanup Program to remediate site contamination caused by previous operators. The site has been identified as “contaminated." A phase I environmental assessment identified petroleum products, BTEX compounds, polycyclic aromatic hydrocarbons, and heavy metal in the soil and/or groundwater. Because of the site contamination, L-P is technically a potential responsible party. However, the positive progress made to date through the Voluntary Cleanup Program makes the Superfund scenario very remote.	
Regulated under the Safe Drinking Water Act?	Y    N   DK 			
Subject to Underground Storage Tank Regulations?	Y    N   DK 			
Regulated under TSCA?	Y    N   DK 			
Required to have a SPCC Plan?	Y    N   DK 		L-P stores approximately 17,000 gallons of petroleum products in tanks, reservoirs, and containers.  Even though there is not a “reasonable potential” for a spill at the facility to reach “navigable waters”, L-P maintains the SPCC plan to heL-P mitigate any spill that may occur.	
Regulated under FIFRA?	Y    N   DK 			
Other?____________________	Y    N   DK 			
Other?____________________	Y    N   DK 			
Other?____________________	Y    N   DK 			
Other?____________________	Y    N   DK 			
Other?____________________	Y    N   DK 			

8.	
Please provide the following information about the implementation status of your Environmental Management System (EMS) (check the appropriate boxes or provide dates):  

	 Not yet developed    

	 Basic EMS    

	 ISO Comparable EMS     

	 ISO Certified EMS    

	Third Party Certified

EMS Element	In Development	Functioning Since (date)	
Environmental Policy Statement		May, 1997	
Identification of Environmental Aspects and Impacts		October, 1999	
Setting Objectives and Targets		October, 1999	
Structure and Responsibility		March, 1998	
Training		Completed December, 1998	
External Communications		November, 1999	
Monitoring and Measurement		January, 1999	
EMS Audits		May, 1999	
Management Review		May, 1999	
Certification	X		

L-P’s Environmental Management System is designed to continually evaluate processes to ensure environmental compliance. The EMS process also allows the facility to achieve defined environmental goals that exceed the specified standards of regulatory compliance. The primary goal of the corporate-wide EMS initiative is to create consistent systems to manage environmental risks. The EMS requires systematic review of each aspect of environmental compliance and assigns responsibility to those individuals most directly involved. L-P has highly qualified personnel, who are trained in and committed to tracking successes and looking for opportunities for improvement daily. Our EMS program involves every aspect of business management and production. Teams representing various segments of L-P’s organizational structure form a communication and support network to heL-P guide the progress of the EMS at each of our facilities. Top-level commitment to the program is reinforced through the Corporate Sponsor Team, while Business Sponsor teams (management level) coordinate program development throughout their respective business lines. 

At the plant level, the Plant Sponsor and EMS Core teams work to implement the EMS by writing Standard Operating Procedures (SOPs), organizing employee and management training, and establishing inspection and process change programs. The goal at each facility is to integrate compliance with identified environmental objectives into the daily work of every employee to ensure that all individuals take personal responsibility for their actions. Once a facility is deemed ready, the EMS Core Team at the plant level receives instruction in environmental permits and regulations specific to facility operations and training in the EMS 26-Step Process, a standardized means of program execution. Employees are also acquainted with programs de-signed to facilitate the rapid implementation of changes in the workplace. As training continues, the next and most essential step is to generate Standard Operating Procedures (SOPs) that outline how individual job tasks will be carried out. Working with environmental professionals, SOPs are developed by incorporating permits, regulations, L-P standard practices and other job-specific criteria. The success of the program lies in matching personnel with job-specific training and safety requirements to carry out individual SOP responsibilities. Once implementation of the 26-Step Process is complete throughout the facility, a comprehensive self-inspection program is executed to evaluate its effectiveness. SOPs are regularly updated and the overall EMS program is continuously improved. Continuous improvement includes an ongoing process, typically through the plant EMS core team, for identifying new environmental objectives and developing SOPs to accomplish those goals. 

With its clear, easy-to-follow process, the EMS allows Louisiana-Pacific to enhance its environmental record while improving productivity, safety, and shareholder value. Most importantly, in taking an active role in the process, employees experience an exhilarating sense of empowerment. Not only do they realize the benefits of building upon their leadership and job skills, but the workplace is made safer and performance is enhanced.

Local communities near L-P’s facilities also benefit from the EMS program. Adoptions of SOPs improve environmental controls, which in turn enhance plant performance and product quality, improving long-term economic stability. Implementation of the program at many facilities often is a collaborative effort that involves local regulators, members of the local community, and other interested parties such as environmental interest groups This is the approach being taken at the Hines facility.
The following highlights demonstrate the success of the EMS program:
•	The enhanced sense of environmental awareness resulting from the EMS program is leading to the development of new and innovative business practices throughout L-P. Mill employees report that changes implemented through the EMS have greatly improved individual performance and consequently that of the whole facility. Knowledge of and compliance with environmental regulations is at an all-time high.
•	As an outgrowth of the EMS program, L-P’s Laminated Veneer Lumber and I-Joist plant in Hines, Oregon began recycling planer shavings in early 1998. The wood “waste” material, originally disposed of at a cost to the company, is now being used in the production of other wood products such as medium density fiberboard. In February and March 1998, an estimated $12,900 was generated as a result of recycling the material rather than sending it to the local landfill. Total revenue from planner shavings is estimated at $90,000 for 1998.
•	In 1999, the Hines plant EMS team identified recycling product inner wrap as a desirable environmental goal. The team worked with the L-P supplier to identify recycling opportunities for the shrink-wrap used internally. The first shipment of wrap—48,000 pounds—was sent off for recycling in the fall of 1999. The Hines EMS team is now working on recycling the plastic wrap used to protect product shipments to L-P customers. This could eventually involve retrieving the wrap from L-P customers and sending it to one of L-P's plastics plants. This is an example of how the plant EMS team works to identify new environmental objectives that extend beyond regulatory compliance. Among longer-term projects, the Hines team is looking at the environmental practices of the plant's resin suppliers and the sustainable forest practices of all the plant suppliers of wood raw materials. 

9.	Please provide the following information on your facility’s significant environmental impacts. If your facility’s significant environmental impacts do not lend themselves to numerical values, please provide a written summary.  Include additional pages if necessary.  

a.  Significant Environmental Impacts	
b.  Performance Measure/
Normalization Factor	
c.  Current Levels	
d.  Past Performance	
e.  Regulatory Limit
 (if any)	
f.  Future Target/
Objective	
Air Emissions	a.  pounds/year
b.  pounds/tons product	a. 64,660 pounds per year (approximately 10% of permitted level of air emissions)
b. 0.098 pounds per ton of product (less than 1% of a pound)	a.                               rate
b.                             year
L-P recently acquired the Hines facility. See note following table. 	631,200 pounds per year.

This is a total of the following criteria pollutants:
•	PM
•	PM10
•	SO2
•	NOx
•	CO
•	VOC	Further Reductions:
L-P is looking for ways of reducing the air emissions from the facility. This has included the decision to eliminate all open topped cyclones and replace them with high efficiency baghouses. We are also testing the use of a gas-fired boiler in place of the wood waste boiler in an attempt to dramatically reduce air emissions. L-P has paved some high traffic areas of the facility to reduce fugitive dust emissions created by rolling stock. 	
Solid Waste Disposal	a.  tons waste/year
b.  tons waste/tons product	a.  15,675 tons per year
b.  0.02 tons per ton product	a.                               rate
b.                             year
L-P recently acquired the Hines facility. See note following table.		Reduction
L-P is striving for a 25% reduction of landfill waste by 2001. This will be accomplished through a combination of reduction in material usage and recycling or substitution of materials. 	
Note about past performance data: Louisiana-Pacific acquired the Hines facility in March 1997. Prior to reporting year 1998, records that accurately represent facility operations associated with these performance measures do not exist. We have used 1998 data as our current levels for this application. These performance measures are tracked on a monthly basis. The measures associated with air emissions are measured on a pollutant-specific basis but have been combined for this application. 

In addition to these measures we are also recording our EMS audits as a measure of performance. It is expected that additional measures will be used after discussions with stakeholders. 

The Hines, Oregon Environmental Management System is designed to focus on regulatory requirements. Because the EMS was not modeled after ISO 14001, a formal aspect analysis was not performed. Since regulatory requirements are the driving force behind our EMS, the targets and objectives are 100% compliance with laws and regulations. Included in the set of requirements are corporate policies relating to the environment.

The EMS uses hourly employees to customize the system to fit each particular facility’s needs. Environmental professionals train a team of employees designated as the “EMS Team” in three areas: waste, air and water. The team then examines their facility's operations to determine what requirements have an impact on them. Sets of Standard Operating Procedures (SOPs) are developed by the team to address those areas of operation that have an impact on the regulatory status of the facility. 

After a complete set of SOPs are developed and approved by environmental professionals the EMS Team trains the facility employees and management on them. The effectiveness of the SOPs is monitored routinely by management review.

10.	If not demonstrated in the table above, how has performance improved over the past three years?  

Data has only been recorded for one complete year following Louisiana-Pacific’s acquisition. Since 1997 L-P has entered DEQ’s voluntary cleanup program, improved the aesthetics of the property and committed to installing pollution control equipment not required by law. 

Some specific examples include:
•	The removal and cleanup of a “boneyard” (a location on the property where industrial waste was stored).
•	The installation of an effluent neutralization system to improve the quality of the boiler blowdown.
•	The maintenance of the “undeveloped” portion of property to be used for wildlife habitat.
•	The boiler conversion plans that would burn L-PG fuel in place of wood waste.
•	The replacement of open topped cyclones with primary filters to reduce particulate matter (PM) emissions by 80% on a throughput basis.
•	The review of all materials prior to purchase to ensure L-P does not generate more hazardous waste.
•	The replacement of air compressor systems that lower the water use.
•	Collection and treatment of parking lot runoff.
•	Environmental education for all employees.
•	The installation of a used oil-burning heater that eliminates disposal of used oil and heats the maintenance shop.
•	Implementation of a container tracking system.
•	Implementation of an emission inventory tracking system.
•	The tracking and review of any environmental issues. 

11.	How will the environmental performance be significantly better than would otherwise be required by law? 

L-P is continuously looking for ways to increase performance and reduce the facility’s “footprint” in the community. The next steps beyond those identified in question 10 will include:

•	Reduction in energy usage.
•	Reduction in water usage.
•	A goal has been set to eliminate landfill waste from leaving the facility by 2005.
•	Increased usage of recyclable and recycled materials.

12.	Please provide your Stakeholder Involvement Plan for reporting to and for involving stakeholders and citizens and identifying whom your key stakeholders might be in discussing the EMS and environmental performance of your facility.  Include current activities and demonstrate that you have initiated implementation of the Stakeholder Involvement Plan 

The facility will be working with stakeholders to identify concerns regarding the impacts of its operations. These concerns will be examined and addressed as appropriate. The facility will continue to use the EMS to improve operating procedures to minimize its “foot-print” as well as to keep stakeholders informed. L-P has had one meeting with the Community Advisory Council (CAC) and will continue meeting with this group on a quarterly schedule. Key community members were asked to sit on the CAC and the general public was invited through notification in the local newspaper. The CAC will serve as an advisory board for L-P by brining to light community concerns as well as providing input on key decisions regarding plant activities.

13.	Please describe desired incentives or waivers for consideration in your GEMS permit along with justification.

Expedited Permit Applications/Extended Permit Intervals
In order to facilitate the rapid expansion potential of the facility, we would like the option of having our permit modifications/applications handled as a “high priority” at the state level. Additionally, L-P would like permit periods to be extended to 10 years. 
Description of incentive: Permit applications and modifications submitted to DEQ by L-P/Hines would be reviewed, processed and sent out for public notice within 90 days of receipt by DEQ. Permit periods for the facility's Air Contaminant Discharge Permit and two NPDES water quality permits would be extended to 10 years. The current permit period for these permits is five years. 
Exceptions/conditions: The Title V air permit program. L-P/Hines is not a Title V source, but this incentive would not apply should the facility become subject to the federal Title V air permit requirements. Expedited permit review and processing would be conditional on complete submission packages from L-P/Hines. The facility's two NPDES permits are general permits that, unless conditions of the permits change, are reviewed for virtually automatic renewal. Permit interval extensions would not eliminate need for applicable public review of proposed permit modifications not covered with the scope of the existing permit conditions. 
Laws, rules or permit conditions that may require waiver to receive this incentive: Potentially none for ACDPs. Conditions for NPDES permits may require additional review and research before extended permit interval could be granted. 

Bubble Permit/Exemption from NOI
We would like to see the “bubble” concept adopted for our facility.  This would allow the facility to add/replace/modify its equipment or processes as long as the emissions did not exceed the bubble limit. 
	Description of incentive: The proposed incentive would adopt a "bubble" concept for L-P-Hines regarding the permitted air emissions in its DEQ Air Contaminant Discharge Permit (ACDP). As long as air emissions did not exceed the overall bubble limit, L-P-Hines could add, replace or modify its equipment or processes. The formal Notice of Intent (NOI) procedures required for ACDPs would be replaced with a simple notification letter. This would inform DEQ of changes being made and give the Department sufficient information to assure that the bubble would not be exceeded. 
	Exceptions/conditions: The proposed incentive would apply only to the Air Contaminant Discharge Permit. If L-P-Hines were to become a federal Title V source, the proposed incentive would have to be re-examined. Within State of Oregon environmental programs, however, it may be useful to explore how the "bubble" concept might work across other regulatory programs. 
	Laws, rules or permit conditions that may require waiver to receive this incentive: The existing ACDP program appears to accommodate the proposed incentive without waiver of any current requirements. However, DEQ may need to make a determination on this. 

Public Recognition
The L-P-Hines facility would receive public recognition as a member of the DEQ Green Permit program. 
	Description of incentive: DEQ would take the lead in advertising the benefits of the Green Permit program and publicly recognizing the participation and commitment of L-P-Hines to the program. In addition, L-P would have the right to recognize the Hines facility as a member of the program by means of direct advertising. 
	Exceptions/conditions: Public recognition activities by DEQ and L-P-Hines would be consistent with guidance established for appropriate public recognition of Tier II participants in the Green Permit program. L-P-Hines' use of the recognition program components (such as use of the Green Permit logo) would be limited to recognition of facility achievements, and may not be used in a manner that implies corporate accomplishments. 
	Laws, rules or permit conditions that may require waiver to receive this incentive: None

Single Point of Contact
We would like a single point of contact (SPOC) within DEQ. Ideally, this contact would to be very familiar with operations at L-P-Hines, so that he or she could heL-P make determinations and decisions on all environmental aspects of our facility. 
Description of incentive: This incentive would result in DEQ providing a single point of contact for interaction between L-P-Hines and DEQ on all DEQ regulatory and permit concerns, as well as any Green Permit program issues. This person would heL-P identify, track and resolve any issues relating to these regulatory and program matters. The single point of contact would consult with compliance staff from all DEQ programs regarding the findings of any compliance inspection conducted, and would ensure that the appropriate response is provided to the facility as outlined in the enforcement discretion policy for Green Permit program participants. 
Conditions/Exceptions: The single point of contact should be a person who is well acquainted with operations at L-P-Hines. This person, however, may not have sufficient expertise to provide direct responses to L-P-Hines about regulatory and permit matters for all programs. This contact would serve as a project manager who would have general knowledge of al DEQ programs but would relay on DEQ program staff to provide expertise on specific issues. 
Laws, rules or permit conditions that may require waiver to receive this incentive: None

Consolidated Permit Reporting
This proposed incentive would consolidate all regulatory reports submitted to DEQ into one report that accompanies the Green Permit annual report. 
Description of incentive: We would like to combine all of our environmental reporting into one annual report in a format that is supported by our database tracking system. If possible, this report would be combined with Green Permit reporting requirements. L-P-Hines would send copies of the annual reports to the DEQ single point of contact, who would distribute them within the Department as needed. The reports to be combined would include the following:
•	ACDP
•	NPDES (2)
•	Fire Marshal (Tier II reporting for SARA Title III) 
•	TRI
Exceptions/conditions: Any compliance report required by DEQ programs that cannot be included in the Green Permits annual report would need to be submitted to individual DEQ programs in accordance with existing pollicies and procedures for reporting. In addition, regulatory compliance issues that require immediate reporting under existing rules (reporting spills, for example) would be reported to the appropriate DEQ program at the time they occur. A further consideration is that reporting dates for reports required by other agencies (State Fire Marshal, EPA Form R for Toxics Release Inventory) may not be amenable to change. However, it may be possible to change ACDP and NPDES reporting dates to coincide with reporting dates required by other agencies. 
Laws, rules or permit conditions that may require waiver to receive this incentive: To be determined on an individual report basis. 

Tailored Enforcement Response 
Under this proposed incentive, DEQ would use enforcement discretion in carrying out facility inspections, as specified in DEQ guidance for Green Permits enforcement response. The inspection response would focus on improvements to the environmental management system to achieve and maintain compliance. 
	Description of incentive: L-P-Hines would be provided time to correct administrative errors and compliance deficiencies that do not result in any detrimental environmental impact, without DEQ issuing a formal notice of violation (for example, Notice of Noncompliance or Notice of Permit Violation). This would include problems discovered through self-reporting or as the result of DEQ site visits. L-P-Hines would utilize the corrective action process outlined in its EMS to correct these deficiencies in a timely manner and in a way that will prevent such deficiencies in the future. 
Conditions/exceptions: Deficiencies that indicate a major failure in the facility's EMS compliance assurance procedures and/or result in detrimental environmental impacts would be subject to formal compliance and enforcement action. 
Laws rules or permit conditions that may require waiver to receive this incentive: To be determined by DEQ; probably none, given the above conditions/exceptions. 

Stakeholder Involvement Assistance
We would like the public to see this program as a “joint partnership” between L-P and DEQ. To assist with this, DEQ would be an active participant in our interaction with stakeholders. We would like DEQ to participate in any public meetings, projects or functions that are deemed appropriate to keep our stakeholders involved. 
	Description of incentive: DEQ would be an active participant in interaction between L-P-Hines and its stakeholders. The purpose of DEQ participation will be to heL-P reinforce and communicate the "joint partnership: between DEQ and L-P-Hines through the Green Permits program. DEQ would participate as appropriate and as needed in public meetings, projects or other stakeholder functions.
Exceptions/conditions: DEQ's ability to participate in L-P-Hines stakeholder involvement activities may be limited at times by staff availability and conflicting commitments.
Laws, rules or permit conditions that may require waiver to receive this incentive: None 

Recycling Program
L-P-Hines would request DEQ assistance in its efforts to start and host a recycling program for Harney County. 
Description of incentive: DEQ would provide technical assistance to L-P-Hines in its efforts to develop and sponsor a recycling program for Harney County. This would include DEQ assistance in promoting recycling opportunities in Harney County. This could include assistance with reuse options, transportation issues and demand for recyclable materials.
Exceptions/conditions: Staff resources may at times limit the availability and/or extent of DEQ assistance. 
Laws, rules or permit conditions that may require waiver to receive this incentive: None

14.	Statement of Certification:

I have reviewed this application and all supporting documentation in their entirety and to the best of my knowledge, information, and belief formed after reasonable inquiry, the statements and information contained herein are true, accurate, and complete.

	
Name of designated responsible official:

Title of responsible official:

(note: Louisiana-Pacific’s application to participate in the Environmental Management Systems Incentives Project is on file at DEQ)

                                                                                                                                                        
Signature of responsible official					        Date