OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY · OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY ... led to some confusion, ... FLARE1 F-1 Plant No. 3 Flare 0.05 1994

DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM September 1, 2009

TO: Phillip Fielder, P.E., Permits and Engineering Group Manager,

Air Quality Division

THROUGH: Kendal Stegmann, Senior Environmental Manager, Compliance

and Enforcement

THROUGH: Phil Martin, P.E., Engineering Section

THROUGH: Peer Review

FROM: David Schutz, P.E., New Source Permits Section

SUBJECT: Evaluation of Permit Application No. 2009-198-TV

Enogex Products LLC

Cox City Processing Plant

Section 26, T4N, R6W, Grady County

Direction: From the Junction of US-81 and SH-17 at Rush Springs, 10 Miles

East, Two Miles North, West Into Facility

Latitude: 34.796oN, Longitude 97.798

oW

SECTION I. INTRODUCTION

Enogex has applied for an operating permit for merging two existing, separate facilities into one

combined facility. The two facilities are the Cox City Processing Plant and the Comanche Tie

Compressor Station. A pipeline was installed between the two adjacent facilities to allow them to

operate as a single natural gas processing plant (SIC 1321). The merging was conducted under

Permit No. 2004-235-C (M-3) issued February 23, 2009.

However, the operating permit application includes several changes which are “significant” as

defined in OAC 252:100-8-7. The operating permit will be required to undergo Tier II review.

The changes between the construction permit and the operating permit are:

- The condensate throughput of Tank-5 is being changed from 30,660 gallons per year to

420,000 gallons per year.

- Condensate storage emissions limits will be revised; flash emissions are now being

estimated by process simulator.

- Condensate loading emissions will increase based on that increased throughput.

- The two condensate loading operations will be split between two EUGs, one with limited

throughput and the other as an “insignificant activity.”

- Fugitive VOC leakage will also be split between two EUGs, one of which remains

subject to NSPS Subpart KKK.

PERMIT MEMORANDUM 2009-198-TV 2 DRAFT

- The two dehydration units will be allowed to be operated up to 200 hours per year

without emissions controls being used. This allowance is being requested pursuant to

recent changes in OAC 252:100-9.

- The capacity of a turbine will be revised from “1,300-hp” to “1,360-hp,” and emissions

will be revised accordingly. The manufacturer horsepower rating is shown on the

nameplate as “1,360,” but in previous permitting actions, the turbine had been site-rated

by the manufacturer for altitude, humidity, and average temperature. That site-rating has

led to some confusion, which this change is attempting to eliminate.

SECTION II. FACILITY DESCRIPTIONS

a. Cox City Processing Plant

This facility currently consists of one 1,478-hp Waukesha Model L7042GSI stationary internal

combustion engine equipped with a catalytic converter; two 1,232-hp Waukesha Model L7042

GSI engines with catalytic converters; one 1,100-hp White-Superior Model 8GTLE stationary

internal combustion engine; two glycol dehydration units, each equipped with a 0.75 MMBTUH

reboiler; four 400-bbl condensate tanks; one 400-bbl methanol tank; one 3.3 MMBTUH gas-fired

process heater; one 2.15 MMBTUH regeneration heater; one 2.7 MMBTUH regeneration heater;

one 7.0 MMBTUH hot oil heater; a condensate stabilizer unit; a truck loading operation for

condensate; two cryogenic skids for extraction of natural gas liquids from field gas; and two

emergency flares.

The facility includes 8 electrically-powered compressors. There are also tanks storing produced

water, wastewater, engine oil and antifreeze.

The equipment has been divided into three areas, designated “Cox City No. 1 and No. 2,” “Cox

City No. 3,” and “Cox City No. 4.”

b. Comanche Tie Compressor Station

The facility consists of one 4,500-hp Solar Centaur turbine (C-5), one 1,360-hp Solar Saturn

turbine, and one 300-bbl condensate tank.

SECTION III. PROCESS DESCRIPTIONS

a. Cox City Processing Plant

Natural gas is transported to the facility by a pipeline gathering system. The field gas enters the

facility through inlet separators where produced condensate and water are separated from the gas

stream. This condensate is processed by a stabilizer to remove light hydrocarbons and eliminate

flash emissions during storage. The gas is first compressed in inlet compressors, then processed

by two glycol dehydration units. A second dehydration step is conducted by a molecular sieve

unit. Dehydrated gas flows to a cryogenic processing skid for removal of natural gas liquids

(ethane, propane, butane, pentane, etc.). Some of the natural gas liquids are processed to distill

out propane, which is stored in pressurized tanks. Remaining natural gas liquids and “residue”

gas from cryogenic processing leave the facility by pipelines.


b. Comanche Tie Compressor Station

The facility is a natural gas transmission station responsible for the compression of natural gas

into a pipeline. Storage of condensate occurs on-site as well. Natural gas is transported to the

facility via a pipeline transmission system. The gas stream enters the Facility through an inlet

separator where condensate and produced water are removed from the inlet gas stream. The gas

stream is then compressed by one (1) Solar Centaur turbine (COMP5) driven compressor rated at

4,500 horsepower (Hp) and one (1) Solar Saturn turbine (COMP6) driven compressor rated at

1,360-hp. After the inlet gas passes through the compressors, the gas exits the facility for

transmission via pipeline.

SECTION IV. EQUIPMENT

EUG 1. Engines

EU Point Make/Model HP Serial # Installed

Date

COMP1 152 Waukesha L7042GSI 1,478 387240 2000



COMP4 546 White-Superior 8GTLE 1,100 20548 1992

EUG 2. Turbines

EU Point Make/Model HP Serial # Installed

Date

COMP5 415 Solar Centaur 4,500 OHD08-C0513 1994

COMP6 411 Solar Saturn 1,360 1150S 1990

EUG 3 is shown on the application as “electric compressor engines.” Since electrical drivers will

not have air emissions, they are omitted from this permit.

EUG 4. Dehydration Units

EU Point Equipment Throughput

MMSCFD Installed Date

DEHY1 D-1 West Dehydration Unit 100 1995

DEHY2 D-2 East Dehydration Unit 100 1995

EUG 5A. Other Fuel-Burning Equipment

EU Point Equipment MMBTUH Installed Date

HEAT1 H-1 Regeneration Heater 2.15 1992

HEAT2 H-2 Hot Oil Heater 7.0 1992

HEAT3 H-3 West Dehydration Reboiler 0.75 1995

HEAT4 H-4 East Dehydration Reboiler 0.75 1995

HEAT5 H-5 Gas Heater 3.3 1995

HEAT6 H-6 Regeneration Heater 2.7 1992


EUG 5B. Plant Flares


FLARE1 F-1 Plant No. 3 Flare 0.05 1994

FLARE2 F-2 Plant No. 4 Flare 0.15 1995

EUG 6. Condensate Tanks

EU Point Contents Gallons Installed Date

TANK1 T-1 Condensate 16,800 1999





EUG 7A. Other Tanks (Not Subject to OAC 252:100-37)


TANK11 T-11 Engine Oil 500 NA






TANK17 T-17 Engine Oil 8,400 NA






TANK25 T-25 Methanol 300 NA








TANK 33 T-33 Coolant 500 NA



TANK 36 T-36 Produced Water 8,820 NA



TANK 39 T-39 Soap 500 NA

TANK 40 T-40 Triethylene Glycol 500 NA


TANK 42 T-42 Triethylene Glycol 1,500 NA

TANK 43 T-43 Diesel 300 NA


EUG 7B. Other Tanks (Subject to OAC 252:100-37)

EU Point Contents Gallons Construction

Date

TANK6 T-6 Propane (pressure tank) 41,000 1984





TANK23 T-23 Methanol 16,800 1981

TANK24 T-24 Methanol 2,000 >1974

EUG 8A. Cox City Plant Truck Loading

EU Point Equipment

Maximum

Anticipated Annual

Throughput,

Gallons

Installed

Date

LOAD1 L-1 Cox City Plant Truck Loading 6,200,000 1992

EUG 8B. Comanche Tie Plant Truck Loading

EU Point Equipment

Maximum

Anticipated Annual

Throughput,

Gallons

Installed

Date

LOAD2 L-2 Comanche Tie Truck Loading 420,000 1995

EUG 9A. Cox City Plant Process Piping Fugitive VOC Leakage

EU Point Description Number of Items Installed

Date

F-FUG P-FUG Fugitive VOC

Leakage

3,445 Valves

1992 to

present

5,541 Flanges

175 Relief Valves

96 Pump Seals

EUG 9B. Comanche Tie Process Piping Fugitive VOC Leakage


Date

F-FUG P-FUG Fugitive VOC

Leakage

100 Gas/Vapor Valves

1992 to

present

110 Gas/Vapor Flanges

40 Compressor Seals

25 Gas/Vapor Relief Valves

10 Light Liquid Valves

11 Light Liquid Flanges

6 Light Liquid Pump Seals

5 Light Liquid Relief Valves

10 Heavy Liquid Pump Seals


SECTION V. EMISSIONS

Emissions were calculated using the following methods:

EUG-1: Engine emissions are based on the following operating hours and manufacturer’s data,

except for formaldehyde from the White-Superior engine which was estimated using AP-42

&7/00), Section 3.2.

Unit ID Description

Hours of

Operations

Per Year

NOx

g/hp-

hr

CO

g/hp-

hr

VOC

g/hp-hr

Formaldehyde

g/hp-hr

COMP1 1,478-HP Waukesha

L7042GSI 3,500 2.0 2.0 0.15 0.015


L7042GSI 8,760 2.0 2.0 0.15 0.015


L7042GSI 8,760 2.0 2.0 0.15 0.015

COMP4 1,100-HP White-

Superior 8GTLE 8,760 2.0 2.0 1.25 0.183

EUG-2: Turbine emissions are based on the following operating hours and manufacturer’s data.

Unit ID Description

Hours of

Operations

Per Year

NOx

g/hp-

hr

CO

g/hp-

hr

VOC

g/hp-hr

Formaldehyde

lb/MMBTU

COMP5 4,500-HP Solar

Centaur 8,760 1.75 1.0 0.30 0.00479

COMP6 1,360-HP Solar Saturn 8,760 1.75 1.0 0.30 0.00479

EUG-4: VOC and HAP emissions from the dehydration units were estimated using the GRI

software, “GLYCalc 4.0” using the “Atmospheric Rich/Lean” method, an extended gas analysis,

and maximum glycol circulation capacity. A gas flow of 100 MMSCFD and a glycol circulation

rate of 7.8 GPM were entered into the program for each of the two dehydration units. A

combined control efficiency of 95% was used for a condenser on each dehydration unit and

combustion of the uncondensed gases except for 200 hours per year uncontrolled emissions.

EUG-5A: Emissions from the plant heaters were estimated using factors from AP-42 (7/98),

Section 1.4.

EUG-5B: Emissions from the flares were based on pilot flame fuel combustion and factors in

AP-42 (1/95), Section 13.5.


EUG-6: Condensate tanks TANK1, TANK2, TANK3, and TANK4 emissions were calculated

using the TANKS 4.09 computer software using a maximum total annual throughput of

6,200,000 gallons (1,550,000 gallons per year per tank) and an average vapor pressure of 5.4

psia. The applicant has not estimated flash emissions from these tanks since light hydrocarbons

are distilled from the condensate in the condensate stabilizer unit.

Condensate tank TANK5 emissions were calculated using the TANKS 4.09 computer software

using a maximum annual throughput of 420,000 gallons and an average vapor pressure of 6.02

psia. Flash emissions were calculated using the HYSYS process simulator.

EUG-7A and EUG-7B: VOC emissions from the pressure tanks and auxiliary tanks are

expected to be negligible.

EUG-8A and EUG-8B: Emissions from the Cox City Plant condensate truck loading operation

were calculated using 6,200,000 gallons per year throughput and 5.4 psia vapor pressure, using

the methods of AP-42 (1/95), Section 5.2.

Emissions from the Comanche Tie Compressor Station condensate truck loading operation were

calculated using 420,000 gallons per year throughput and 6.02 psia vapor pressure, using the

methods of AP-42 (1/95), Section 5.2.

EUG-9A and EUG-9B: Emissions from fugitive equipment leaks are based on EPA’s

document, “1995 Protocol for Equipment Leak Emission Estimates,” Table 2-4, Oil and Gas

Operations Average Emissions Factors for process piping fugitives, and counts of components.

Fuel consumption for the 1,478-hp Waukesha Model L7042GSI compressor engine was stated at

11,560 SCFH. Air emissions from the engine are discharged through a 12-inch diameter stack, 20

ft. above grade, at a rate of 6,967 ACFM at 1,125oF. Moisture content of stack gases has been

estimated at 17% from fuel usage and the stoichiometric ratio of two SCF of water per SCF of

natural gas fuel.

Fuel consumption for each 1,232-hp Waukesha Model L7042GSI compressor engines was stated

at 9,340 SCFH. Air emissions from each engine are discharged through a 12-inch diameter stack,

20 ft. above grade, at a rate of 5,377 ACFM at 1,055oF. Moisture content of stack gases has been


natural gas fuel.

Fuel consumption for the 1,100-hp White-Superior Model 8GTLE compressor engine was stated

at 8,415 SCFH. Air emissions from the engine are discharged through a 12-inch diameter stack,

20 ft. above grade, at a rate of 6,394 ACFM at 788oF. Moisture content of stack gases has been


natural gas fuel.


CRITERIA POLLUTANT EMISSIONS

A. Pre-Project

NOx CO VOC

Source Unit ID lb/hr TPY lb/hr TPY lb/hr TPY

Cox City Plant No. 4

1,478-hp Waukesha L-7042GSI,

S/N 387240 COMP1 6.52 11.40 6.52 11.40 0.49 0.86

West Dehydration Unit Still Vent D-1 -- -- -- -- 1.26 5.51

West Dehydration Unit Reboiler

(0.75 MMBTUH) H-3 0.07 0.32 0.06 0.27 0.01 0.02

East Dehydration Unit Still Vent D-2 -- -- -- -- 1.26 5.51

East Dehydration Unit Reboiler

(0.75 MMBTUH) H-4 0.07 0.32 0.06 0.27 0.01 0.02

Direct-Fired Gas Heater

(3.3 MMBTUH) H-5 0.32 1.42 0.27 1.19 0.02 0.08

Process Piping Fugitive VOC

Leakage P-FUG -- -- -- -- 6.39 27.97

400-bbl Condensate Storage Tank T-1 -- -- -- --

--

11.94 400-bbl Condensate Storage Tank T-2 -- -- -- --


Emergency Flare P-11 0.01 0.05 0.06 0.25 0.02 0.09

Truck Loading L-1 -- -- -- -- -- 15.64


Emergency Flare F-1 0.01 0.02 0.02 0.08 0.01 0.03


S/N 306628 COMP2 5.43 23.79 5.43 23.79 0.41 1.78


S/N 179133 COMP3 5.43 23.79 5.43 23.79 0.41 1.78

1,100-hp White-Superior 8GTLE,

S/N 20548 COMP4 4.85 21.24 4.85 21.24 3.03 13.28

Regeneration Heater, 2.15

MMBTUH H-1 0.21 0.92 0.18 0.78 0.01 0.05

Hot Oil Heater, 7.0 MMBTUH H-2 0.69 3.01 0.58 2.52 0.04 0.17

400-bbl Condensate Storage Tank T-4 -- -- -- -- -- 1.37

400-bbl Methanol Storage Tank T-23 -- -- -- -- -- 0.08


Leakage P-FUG -- -- -- -- 1.03 4.53

Cox City Plants No. 1 and 2

2.7 MMBTUH Process Heater H-6 0.26 1.16 0.22 0.97 0.01 0.06


Leakage P-FUG -- -- -- -- 1.92 8.27

Totals 23.87 87.44 23.68 86.55 16.33 99.04


A. Post-Project

NOx CO VOC




S/N 387240 COMP1 6.52 11.40 6.52 11.40 0.49 0.86

West Dehydration Unit Still Vent D-1 -- -- -- -- 34.81 22.52

West Dehydration Unit Reboiler

(0.75 MMBTUH) H-3 0.07 0.32 0.06 0.27 0.01 0.02

East Dehydration Unit Still Vent D-2 -- -- -- -- 34.81 22.52

East Dehydration Unit Reboiler

(0.75 MMBTUH) H-4 0.07 0.32 0.06 0.27 0.01 0.02

Direct-Fired Gas Heater

(3.3 MMBTUH) H-5 0.32 1.42 0.27 1.19 0.02 0.08


Leakage P-FUG -- -- -- -- 6.39 27.97


-- 11.94 400-bbl Condensate Storage Tank T-2 -- -- -- --


Emergency Flare P-11 0.01 0.05 0.06 0.25 0.02 0.09

Truck Loading L-1 -- -- -- -- -- 15.64


Emergency Flare F-1 0.01 0.02 0.02 0.08 0.01 0.03


S/N 306628 COMP2 5.43 23.79 5.43 23.79 0.41 1.78


S/N 179133 COMP3 5.43 23.79 5.43 23.79 0.41 1.78

1,100-hp White-Superior 8GTLE,

S/N 20548 COMP4 4.85 21.24 4.85 21.24 3.03 13.28

Regeneration Heater, 2.15

MMBTUH H-1 0.21 0.92 0.18 0.78 0.01 0.05

Hot Oil Heater, 7.0 MMBTUH H-2 0.69 3.01 0.58 2.52 0.04 0.17

400-bbl Condensate Storage Tank T-4 -- -- -- -- -- 1.37

400-bbl Methanol Storage Tank T-23 -- -- -- -- -- 0.08

Process Piping Fugitive VOC P-FUG -- -- -- -- 1.03 4.53

Cox City Plants No. 1 and 2

2.7 MMBTUH Process Heater H-6 0.26 1.16 0.22 0.97 0.01 0.06

Process Piping Fugitive VOC P-FUG -- -- -- -- 1.88 8.23

Comanche Tie Compressor

4,500-hp Solar Centaur turbine COMP5 17.36 76.04 9.92 43.45 2.98 13.04

1,360-hp Solar Saturn turbine COMP6 5.25 22.98 3.00 13.13 0.90 3.94

300-bbl Condensate Tank T-5 -- -- -- -- -- 45.47

Truck Loading L-2 -- -- -- -- -- 1.20

Process Piping Fugitive VOC P-FUG2 -- -- -- -- 0.41 1.81

Totals 46.48 186.46 36.60 143.13 87.68 198.48

Pre-Project Emissions 23.87 87.44 23.68 86.55 16.33 99.04

NET EMISSIONS CHANGES 22.61 99.02 12.92 56.58 71.35 99.44


Brake-specific fuel consumption for the 4,500-hp Solar Centaur turbine is listed at 8,167

BTU/hp-hr at 15,700 RPM for a fuel consumption of 36,750 SCFH. Air emissions from the

turbine are discharged through a stack 2 feet in diameter, 25 feet above grade, at a rate of 80,500

ACFM at 838oF. Moisture content of stack gases has been estimated at 4% from fuel usage and

the stoichiometric ratio of two SCF of water per SCF of natural gas fuel.

Brake-specific fuel consumption for the 1,360-hp Solar Saturn turbine is listed at 10,770

BTU/hp-hr at 22,300 RPM for a fuel consumption of 14,000 SCFH. Air emissions from the

turbine are discharged through a stack 1.5 feet in diameter, 24 feet above grade, at a rate of

27,735 ACFM at 905oF. Moisture content of stack gases has been estimated at 3% from fuel

usage and the stoichiometric ratio of two SCF of water per SCF of natural gas fuel.

The engines and turbines will have emissions of HAPs, the most significant being formaldehyde.

Emissions of formaldehyde were calculated using the manufacturer emission factor of 0.015

g/hp-hr for the Waukesha engines and 0.00479 lb/MMBTU for the Solar turbines. Emissions of

formaldehyde were calculated using AP-42 (7/00) Table 3.2-2 emission factor of 0.183 g/hp-hr

for the White-Superior engine. Formaldehyde emissions are below major source levels.

FORMALDEHYDE EMISSIONS

Source Formaldehyde

lb/hr TPY

COMP1, 1,478-hp Waukesha L-7042 GSI 0.05 0.09



COMP4, 1,100-hp White-Superior 8GTLE 0.44 1.95

COMP5, 4,500-hp Solar Centaur 0.18 0.77

COMP6, 1,360-hp Solar Saturn 0.07 0.29

TOTALS 0.82 3.46

COMBINED DEHYDRATION UNITS HAP EMISSIONS

Pollutant Controlled Emissions

Uncontrolled

Emissions

(200 hours/year)

Totals

lb/hr TPY lb/hr TPY lb/hr TPY

Benzene 0.26 1.14 5.04 0.50 5.3 1.64

Toluene 0.66 2.86 12.86 1.28 13.52 4.14

Ethyl Benzene 0.02 0.12 0.50 0.02 0.52 0.14

Xylene 0.18 0.76 3.46 0.34 3.64 1.1

Hexane 0.22 0.98 2.16 0.22 2.38 1.2

TOTALS 1.39 5.95 24.02 2.36 25.41 8.31

HAP emissions are less than the 10/25 TPY thresholds.


SECTION V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application are duplicated below.

Appropriate record keeping of activities indicated below with “*” is specified in the Specific

Conditions.

1. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5

MMBTUH heat input (commercial natural gas). Heaters 1, 3, 4, 5, and 6 are rated less than

5 MMBTUH. The flares, although rated below 5 MMBTUH, are subject to NSPS, therefore

cannot be classified as “insignificant activities.”

2. * Emissions from fuel storage/dispensing equipment operated solely for facility owned

vehicles if fuel throughput is not more than 2,175 gallons per day, averaged over a 30-day

period.

3. * Storage tanks with less than or equal to 10,000 gallons capacity that store volatile organic

liquids with a true vapor pressure less than or equal to 1.0 psia at maximum storage

temperature. Glycol and lube oil storage tanks all have capacities less than 10,000 gallons

and store liquids with a vapor pressure below 1.0 psia.

4. * Emissions from storage tanks constructed with a capacity less than 39,894 gallons which

store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature.

5. Cold degreasing operations utilizing solvents that are denser than air. One parts washer is

located at the facility and it uses a solvent that is denser than air.

6. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria

pollutant. This category includes Heater H-2 and the Comanche Tie condensate loading

operation.

SECTION VII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable]

Final total emissions are less than the threshold of 250 TPY of any single regulated pollutant and

the facility is not one of the 26 specific industries with a threshold of 100 TPY.

NSPS, 40 CFR Part 60 [Subparts GG and KKK Applicable]

Subpart Kb, VOL Storage Vessels. This subpart regulates hydrocarbon storage tanks larger than

19,813-gallons capacity and built after July 23, 1984. All storage tank capacities at this facility

are less than the threshold level.

Subpart GG, Stationary Gas Turbines. This subpart sets standards for stationary gas turbines, with

a heat input at peak load of greater than or equal to 10.7 gigajoules per hour (10 MMBTUH)

based on the lower heating value (LHV) of the fuel and that commenced construction,

reconstruction, or modification after October 3, 1977. Turbines COMP5 and COMP6 are subject

to the nitrogen oxide emission limitations of 40 CFR 60.332(a)(2), the sulfur dioxide emission

limitations of 40 CFR 60.333(a) or (b), and the fuel monitoring requirements of 40 CFR

60.334(b). Monitoring of fuel nitrogen content shall not be required as long as the permittee does

not take an allowance for fuel bound nitrogen. Sulfur dioxide standards specify that no fuel shall


be used which exceeds 0.8% by weight sulfur nor shall exhaust gases contain in excess of 150

ppm SO2. The owner or operator may elect not to monitor the total sulfur content of the gaseous

fuel combusted if the gaseous fuel is demonstrated to meet the definition of “natural gas” using

either the gas quality characteristics in a current, valid purchase contract, tariff sheet, or

transportation contract, or using representative fuel sampling data. The maximum total sulfur

content of “natural gas” is 20 grains/100 SCF (680 ppmw or 338 ppmv) or less.

Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. This

subpart sets standards for natural gas processing plants which are defined as any site engaged in

the extraction of natural gas liquids from field gas, fractionation of natural gas liquids, or both.

The standards of Subpart KKK have been incorporated into the permit.

Subpart LLL, Onshore Natural Gas Processing: SO2 Emissions. This subpart sets standards for

natural gas sweetening units. There is no natural gas sweetening operation at this site.

Subpart JJJJ, Stationary Spark Ignition Internal Combustion Engines (SI-ICE), promulgates

emission standards for all new SI engines ordered after June 12, 2006, and all SI engines

modified or reconstructed after June 12, 2006, regardless of size. All engines at this facility were

manufactured prior to the applicability date of Subpart JJJJ.

Subpart KKKK affects stationary gas turbines that commenced construction, modification, or

reconstruction after February 18, 2005. These turbines were manufactured prior to Subpart

KKKK.

NESHAP, 40 CFR Part 61 [Not Applicable]

There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium,

coke oven emissions, mercury, radionuclides, or vinyl chloride except for trace amounts of

benzene. Subpart J, Equipment Leaks of Benzene, concerns only process streams that contain more

than 10% benzene by weight. Analysis of Oklahoma natural gas indicates a maximum benzene

content of less than 1%.

NESHAP, 40 CFR Part 63 [Subpart HH Applicable]

Subpart HH, Oil and Natural Gas Production Facilities. This subpart applies to affected emission

points that are located at facilities that are major sources and area sources of HAPs and either

process, upgrade, or store hydrocarbons prior to the point of custody transfer or prior to which

the natural gas enters the natural gas transmission and storage source category. The facility is a

minor source of HAPs.

Sources with either an annual average natural gas flowrate less than 3 MMSCF/D or benzene

emissions less than 0.9 megagrams (1.0 TPY) are exempt from control requirements. Each

dehydrator at the facility has the potential to emit 0.57 TPY of benzene. Since the TEG units

were constructed/reconstructed before July 8, 2005, and are not located within an Urban-1

County or in an Urban Area plus offset or Urban Cluster, they are considered existing sources. A

requirement to comply with the standard by the applicable effective date has been incorporated

into the permit.


Subpart HHH, Natural Gas Transmission and Storage. This subpart was published in the Federal

Register on June 17, 1999, and affects Natural Gas Transmission and Storage Facilities. It applies

to affected emission points that are located at facilities that are major sources of HAPs, as

defined in this subpart, and that transport or store natural gas prior to entering the pipeline to a

local distribution company or to a final end user. This facility is a minor source of HAPs.

Subpart YYYY, Stationary Combustion Turbines. This subpart was promulgated on March 5,

2004 and affects stationary combustion turbines that are located at major source of HAP. The

turbines were both built in 2002, therefore, are “existing” gas-fueled turbines. There are no

standards in Subpart YYYY for existing units.

Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart previously

affected only RICE with a site-rating greater than 500 brake horsepower that are located at a

major source of HAP emissions. On January 18, 2008, the EPA published a final rule that

promulgates standards for new and reconstructed engines (after June 12, 2006) with a site rating

less than or equal to 500 HP located at major sources, and for new and reconstructed engines

(after June 12, 2006) located at area sources. Owners and operators of new or reconstructed

engines at area sources and of new or reconstructed engines with a site rating equal to or less than

500 HP located at a major source (except new or reconstructed 4-stroke lean-burn engines with a

site rating greater than or equal to 250 HP and less than or equal to 500 HP located at a major

source) must meet the requirements of Subpart ZZZZ by complying with either 40 CFR Part 60

Subpart IIII (for CI engines) or 40 CFR Part 60 Subpart JJJJ (for SI engines). Owners and

operators of new or reconstructed 4SLB engines with a site rating greater than or equal to 250 HP

and less than or equal to 500 HP located at a major source are subject to the same MACT

standards previously established for 4SLB engines above 500 HP at a major source, and must

also meet the requirements of 40 CFR Part 60 Subpart JJJJ, except for the emissions standards

for CO. The engines at this facility were all constructed prior to the applicability dates of this

subpart and are not affected emission units.

Subpart DDDDD, National Emission Standards for Hazardous Air Pollutants for Industrial,

Commercial and Institutional Boilers and Process Heaters. In March, 2007, the EPA filed a

motion to vacate and remand this rule back to the agency. The rule was vacated by court order,

subject to appeal, on June 8, 2007. No appeals were made and the rule was vacated on July 30,

2007. Existing and new small gaseous fuel boilers and process heaters (less than 10 MMBtu/hr

heat rating) were not subject to any standards, recordkeeping, or notifications under Subpart

DDDDD.

EPA is planning on issuing guidance (or a rule) on what actions applicants and permitting

authorities should take regarding MACT determinations under either Section112(g) or Section

112(j) for sources that were affected sources under Subpart DDDDD and other vacated MACTs.

It is expected that the guidance (or rule) will establish a new timeline for submission of section

112(j) applications for vacated MACT standards. At this time, AQD has determined that a 112(j)

determination is not needed for sources potentially subject to a vacated MACT, including

Subpart DDDDD. This permit may be reopened to address Section 112(j) when necessary.


CAM, 40 CFR Part 64 [Applicable]

Compliance Assurance Monitoring (CAM) as published in the Federal Register on October 20,

1997, applies to any pollutant specific emission unit at a major source, that is required to obtain a

Title V permit, if it meets all of the following criteria:

It is subject to an emission limit or standard for an applicable regulated air pollutant

It uses a control device to achieve compliance with the applicable emission limit or standard

It has potential emissions, prior to the control device, of the applicable regulated air

pollutant of 100 TPY

The facility will have until renewal of their Title V operating permit to submit CAM plans for the

engines with catalytic converters and the dehydration units’ condensers.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable]

The definition of a stationary source does not apply to transportation, including storage incident

to transportation, of any regulated substance or any other extremely hazardous substance under

the provisions of this part. Naturally occurring hydrocarbon mixtures, prior to entry into a

natural gas processing plant or a petroleum refining process unit, including: condensate, crude

oil, field gas, and produced water, are exempt for the purpose of determining whether more than

a threshold quantity of a regulated substance is present at the stationary source. More

information on this federal program is available on the web page: www.epa.gov/ceppo.

Stratospheric Ozone Protection, 40 CFR Part 82 [Subpart A and F Applicable]

These standards require phase out of Class I & II substances, reductions of emissions of Class I

& II substances to the lowest achievable level in all use sectors, and banning use of nonessential

products containing ozone-depleting substances (Subparts A & C); control servicing of motor

vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations

which meet phase out requirements and which maximize the substitution of safe alternatives to

Class I and Class II substances (Subpart D); require warning labels on products made with or

containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon

disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds

under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons

(Subpart H).

Subpart A identifies ozone-depleting substances and divides them into two classes. Class I

controlled substances are divided into seven groups; the chemicals typically used by the

manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform

(Class I, Group V). A complete phase-out of production of Class I substances is required by

January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are

hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.

Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances,

scheduled in phases starting by 2002, is required by January 1, 2030.

This facility does not utilize any Class I & II substances.


SECTION VIII. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable]

Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-2 (Incorporation by Reference) [Applicable]

This subchapter incorporates by reference applicable provisions of Title 40 of the Code of

Federal Regulations. These requirements are addressed in the “Federal Regulations” section.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]

Subchapter 3 enumerates the primary and secondary ambient air quality standards and the

significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these

standards.

OAC 252:100-5 (Registration, Emission Inventory, and Annual Operating Fees) [Applicable]

Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission

inventories annually, and pay annual operating fees based upon total annual emissions of

regulated pollutants. Emissions inventories have been submitted and fees paid for previous years.

OAC 252:100-8 (Permits for Part 70 Sources) [Applicable]

Part 5 includes the general administrative requirements for Part 70 permits. Any planned

changes in the operation of the facility that result in emissions not authorized in the permit and

that exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior

notification to AQD and may require a permit modification. Insignificant activities refer to those

individual emission units either listed in Appendix I or whose actual calendar year emissions do

not exceed the following limits.

* 5 TPY of any one criteria pollutant

* 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of

any threshold less than 10 TPY for a HAP that the EPA may establish by rule

Emission limitations and operational requirements necessary to assure compliance with all

applicable requirements for all sources are taken from the permit application, or developed from

the applicable requirement.

OAC 252:100-9 (Excess Emissions Reporting Requirements) [Applicable]

Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess

emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following

working day of the first occurrence of excess emissions in each excess emission event. No later

than thirty (30) calendar days after the start of any excess emission event, the owner or operator

of an air contaminant source from which excess emissions have occurred shall submit a report

for each excess emission event describing the extent of the event and the actions taken by the

owner or operator of the facility in response to this event. Request for affirmative defense, as

described in OAC 252:100-9-8, shall be included in the excess emission event report. Additional

reporting may be required in the case of ongoing emission events and in the case of excess

emissions reporting required by 40 CFR Parts 60, 61, or 63.


OAC 252:100-13 (Prohibition of Open Burning) [Applicable]

Open burning of refuse and other combustible material is prohibited except as authorized in the

specific examples and under the conditions listed in this subchapter.

OAC 252:100-19 (Particulate Matter) [Applicable]

Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with

emission limits based on maximum design heat input rating. Fuel-burning equipment is defined

in OAC 252:100-19 as any internal combustion engine or gas turbine, or other combustion device

used to convert the combustion of fuel into usable energy. Thus, the listed equipment items

following are subject to the requirements of this subchapter. This permit requires the use of

natural gas for all fuel-burning equipment to ensure compliance with Subchapter 19.

Equipment

Maximum Heat

Input

(MMBTUH)

Appendix C

Emission Limit

(lbs/MMBTU)

Potential

Emission Rate

(lbs/MMBTU)

1,478-HP Waukesha

L7042GSI

11.56 0.59 0.01

1,232-HP Waukesha

L7042GSI

9.34 0.60 0.01

1,232-HP Waukesha

L7042GSI

9.34 0.60 0.01

1,100-HP White-Superior

8GTLE

8.42 0.60 0.01

4,500-hp Solar Centaur 36.75 0.44 0.0066

1,360-hp Solar Saturn 14.00 0.56 0.0066

Regeneration Heater 2.15 0.60 0.0076

Hot Oil Heater 7.0 0.60 0.0076

West Dehydration Reboiler 0.75 0.60 0.0076

East Dehydration Reboiler 0.75 0.60 0.0076

Gas Heater 3.3 0.60 0.0076

Regeneration Heater 2.7 0.60 0.0076

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]

This subchapter states that no person shall allow the discharge of any fumes, aerosol, mist, gas,

smoke, vapor, particulate matter, or any combination thereof exhibiting greater than 20% opacity

except for short term occurrences, which consist of not more than one six-minute (6) period in

any consecutive 60 minutes, not to exceed three such periods in any consecutive 24-hour period.

In no case shall the average of any six-minute (6) period exceed 60% opacity. When burning

natural gas, there is very little possibility of exceeding the opacity standards.

OAC 252:100-29 (Fugitive Dust) [Applicable]

No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the

property line on which the emissions originate in such a manner as to damage or interfere with

the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the

maintenance of air quality standards. Under normal operating conditions, this facility will not

cause a problem in this area, there it is not necessary to require specific precautions to be taken.


OAC 252:100-31 (Sulfur Compounds) [Applicable]

Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1,

1972). For gaseous fuels the limit is 0.2 lb/MMBTU heat input averaged over 3 hours. For fuel

gas having a gross calorific value of 1,000 BTU/SCF, this limit corresponds to fuel sulfur content

of 1,203 ppmv. The permit requires the use of gaseous fuel with sulfur content less than 343

ppmv to ensure compliance with Subchapter 31.

OAC 252:100-33 (Nitrogen Oxides) [Not Applicable]

This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or

equal to 50 MMBTUH to emissions of 0.2 lb of NOx per MMBTU. There are no equipment

items that exceed the 50 MMBTUH threshold.

OAC 252:100-35 (Carbon Monoxide) [Not Applicable]

This facility has none of the affected sources: gray iron foundry, blast furnace, basic oxygen

furnace, petroleum catalytic cracking unit, or petroleum catalytic reforming unit.

OAC 252:100-37 (Volatile Organic Compounds) [Applicable]

Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons

or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a

permanent submerged fill pipe or with an organic vapor recovery system. The condensate tanks,

propane tanks, and methanol tanks larger than 400-gallons are subject to this requirement. The

lube oil and antifreeze tanks have vapor pressures below the 1.5 psia de minimis level.

Part 3 requires loading facilities with a throughput equal to or less than 40,000 gallons per day to

be equipped with a system for submerged filling of tank trucks or trailers if the capacity of the

vehicle is greater than 200 gallons. This facility does not have the physical equipment (loading

arm and pump) to conduct this type of loading. Therefore, this requirement is not applicable.

Part 5 limits the VOC content of coating of parts and products. Any painting operation will

involve maintenance coatings of building and equipment and emit less than 100 pounds per day

of VOCs and so is exempt.

Part 7 requires fuel-burning and refuse-burning equipment to be operated to minimize emissions

of VOC. The equipment at this location is subject to this requirement.

Part 7 also requires effluent water separators which receive water containing more than 200

gallons per day of any VOC to be equipped with vapor control devices. There is no water

effluent separator at this location.

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable]

This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in

areas of concern (AOC). Any work practice, material substitution, or control equipment required

by the Department prior to June 11, 2004, to control a TAC, shall be retained, unless a

modification is approved by the Director. Since no AOC has been designated there are no

specific requirements for this facility at this time.


OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable]

This subchapter provides general requirements for testing, monitoring and recordkeeping and

applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.

To determine compliance with emissions limitations or standards, the Air Quality Director may

require the owner or operator of any source in the state of Oklahoma to install, maintain and

operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant

source. All required testing must be conducted by methods approved by the Air Quality Director

and under the direction of qualified personnel. A notice of intent-to-test and a testing protocol

shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.

Emissions and other data to demonstrate compliance with any federal or state emission limit or

standard, or any requirement set forth in a valid permit shall be recorded, maintained, and

submitted as required by this subchapter, an applicable rule, or permit requirement. Data from

any required testing or monitoring not conducted in accordance with the provisions of this

subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive

use, of any credible evidence or information relevant to whether a source would have been in

compliance with applicable requirements if the appropriate performance or compliance test or

procedure had been performed.

The following Oklahoma Air Pollution Control Rules are not applicable to this facility:

OAC 252:100-11 Alternative Reduction not requested

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Feed & Grain Facility not in source category

OAC 252:100-39 Nonattainment Areas not in a subject area

OAC 252:100-47 Landfills not type of source category

SECTION IX. COMPLIANCE

Inspection

An initial compliance evaluation was conducted on July 28, 2009. Present for the inspection

were Lance Lodes and Kervin Schulz of Enogex and David Schutz of Air Quality Division. The

facility was constructed and is operating as described in the permit application. Identification

plates with the make, model, and serial number were attached to the engines. All condensate

tanks are equipped with submerged fill pipes.

Testing

The latest quarterly testing results shows the engines to be in compliance with permit limits.


Unit

ID Description

NOx CO

Test Result

(lb/hr)

Permit

Limit (lb/hr)

Test Result

(lb/hr)

Permit Limit

(lb/hr)

COMP1 1,478-hp Waukesha L-

7042 GSI Not operated 220 hours in quarter


7042 GSI 4.22 5.43 3.69 5.43


7042 GSI 2.39 5.43 3.55 5.43

COMP4 1,100-hp White-Superior

8GTLE 0.60 4.85 4.64 4.85

COMP5 4,500-hp Solar Centaur

turbine Not operated 220 hours in quarter

COMP6 1,360-hp Solar Saturn

turbine Not operated 220 hours in quarter

Tier Classification and Public Review

This application has been determined to be a Tier II based on the request for an operating permit

which changes a minor source to a major source but which has “significant” changes between the

initial construction permit and the operating permit.

Public review of the application and permit are required. The applicant has submitted a signed

affidavit from the The Chickasha Express-Star, a daily newspaper printed in Grady County, that

a “Notice of Filing a Tier II Application” was published on June 26, 2009. The notice stated that

the application was available for public review at Chickasha Public Library (527 Iowa Avenue)

or at the Air Quality Division’s main office. The applicant will also publish a “Notice of Tier II

Draft Permit.”

The permittee has submitted an affidavit that they are not seeking a permit for land use or for any

operation upon land owned by others without their knowledge. The affidavit certifies that the

applicant owns the real property.

Information on all permit actions is available for review by the public in the Air Quality section

of the DEQ Web Page: http://www.deq.state.ok.us.

Fees Paid

Initial Part 70 operating permit fee of $2,000

SECTION X. SUMMARY

The facility is operating as described in the permit application. Ambient air quality standards are

not threatened at the site. There are no active Air Quality compliance or enforcement issues

concerning this facility. Issuance of the operating permit is recommended, contingent on public

and EPA review.

http://www.deq.state.ok.us/

DRAFT PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Enogex Products LLC Permit No. 2009-198-TV


The permittee is authorized to operate in conformity with the specifications submitted to the Air

Quality Division on October 3, 2005, with supplemental information received August 22,

October 10, and November 7, 2008; and June 26, 2009. The Evaluation Memorandum dated

September 1, 2009, explains the derivation of applicable permit requirements and estimates of

emissions; however, it does not contain operating limitations or permit requirements. Continuing

operations under this permit constitutes acceptance of, and consent to, the conditions contained

herein:

1. Points of emissions and emission limitations: [OAC 252:100-8-6(a)(1)]

EUG 1. Engines

NOx CO VOC


1,478-hp Waukesha L-7042 GSI COMP1 6.52 11.40 6.52 11.40 0.49 0.86



1,100-hp White-Superior 8GTLE COMP4 4.85 21.24 4.85 21.24 3.03 13.28

A. The 1,478-HP Waukesha L-7042 GSI (COMP1) shall be operated no more than 3,500

hours in any rolling 12-month period.

B. The make, model number and serial number shall be permanently identified on the

engines at the facility.

C. Engines COMP1, COMP2, and COMP3 shall be operated with exhaust gases passing

through functional catalytic converters.

D. At least once per calendar quarter, the permittee shall conduct tests of NOx and CO

emissions in exhaust gases from the engines in EUG-1 and from each replacement

engine/turbine when operating under representative conditions for that period. Testing is

required for any engine/turbine that runs for more than 220 hours during that calendar

quarter. Engines/turbines shall be tested no sooner than 20 calendar days after the last

test. Testing shall be conducted using a portable analyzer in accordance with a protocol

meeting the requirements of the “AQD Portable Analyzer Guidance” document or an

equivalent method approved by Air Quality. When four consecutive quarterly tests show

the engine/turbine to be in compliance with the emissions limitations shown in the

permit, then the testing frequency may be reduced to semi-annual testing. Likewise,

when the following two consecutive semi-annual tests show compliance, the testing

frequency may be reduced to annual testing. Upon any showing of non-compliance with

emissions limitations or testing that indicates that emissions are within 10% of the

SPECIFIC CONDITIONS 2009-198-TV 2

DRAFT

emission limitations, the testing frequency shall revert to quarterly. Any reduction in the

testing frequency shall be noted in the next required compliance certification. Reduced

testing frequency does not apply to engines with catalytic converters.

E. When periodic compliance testing shows engine exhaust emissions in excess of the lb/hr

limits in Specific Condition Number 1, the permittee shall comply with the provisions of

OAC 252:100-9 for excess emissions. Requirements of OAC 252:100-9 include

immediate notification and written notification of Air Quality and demonstrations that the

excess emissions meet the criteria specified in OAC 252:100-9.

F. Replacement, including temporary periods (6 months or less for maintenance purposes) of

the internal combustion engine shown in this permit with an engine of lesser or equal

emissions of each pollutant, is authorized under the following conditions:

1. The permittee shall notify AQD in writing not later than 7 days prior to start-up of

the replacement engine(s)/turbine(s). Said notice shall identify the old

engine/turbine and shall include the new engine/turbine make and model, serial

number, horsepower rating, and pollutant emission rates (g/hp-hr, lb/hr, and TPY)

at maximum horsepower for the altitude/location.

2. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted

to confirm continued compliance with NOX and CO emission limitations. A copy

of the first quarter testing shall be provided to AQD within 60 days of start-up of

each replacement engine/turbine. The test report shall include the engine/turbine

fuel usage, stack flow (ACFM), stack temperature (oF), and pollutant emission rates

(g/hp-hr, lbs/hr, and TPY) at maximum rated horsepower for the altitude/location.

3. Replacement equipment and emissions are limited to equipment and emissions

which are not a modification under NSPS or NESHAP, or a significant

modification under PSD. For existing PSD facilities, the permittee shall calculate

the PTE or the net emissions increase resulting from the replacement to document

that it does not exceed significance levels and submit the results with the notice

required by F.1 of this Specific Condition.

4. Engines installed as allowed under the replacement allowances in this Specific

Condition that are subject to 40 CFR Part 63, Subpart ZZZZ and/or 40 CFR Part 60,

Subpart JJJJ shall comply with all applicable requirements.


DRAFT

EUG 2. Turbines

NOx CO VOC

Source Unit ID ppm1 lb/hr TPY lb/hr TPY lb/hr TPY

4,500-hp Solar Centaur turbine COMP5 187 17.36 76.04 9.92 43.45 2.98 13.04

1,360-hp Solar Saturn turbine COMP6 150 5.25 22.98 3.00 13.13 0.90 3.94 1 ppmv, dry, corrected to 15% oxygen.

A. The make, model number and serial number shall be permanently identified on the

turbines at the facility.

B. At least once per calendar quarter, the permittee shall conduct tests of NOx and CO

emissions in exhaust gases from the turbines in EUG-2 and from each replacement

engine/turbine when operating under representative conditions for that period. Testing

is required for any engine/turbine that runs for more than 220 hours during that

calendar quarter. Engines/turbines shall be tested no sooner than 20 calendar days

after the last test. Testing shall be conducted using a portable analyzer in accordance

with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance”

document or an equivalent method approved by Air Quality. When four consecutive

quarterly tests show the engine/turbine to be in compliance with the emissions

limitations shown in the permit, then the testing frequency may be reduced to semi-

annual testing. Likewise, when the following two consecutive semi-annual tests show

compliance, the testing frequency may be reduced to annual testing. Upon any

showing of non-compliance with emissions limitations or testing that indicates that

emissions are within 10% of the emission limitations, the testing frequency shall

revert to quarterly. Any reduction in the testing frequency shall be noted in the next

required compliance certification.

C. When periodic compliance testing shows turbine exhaust emissions in excess of the

lb/hr limits in Specific Condition Number 1, the permittee shall comply with the

provisions of OAC 252:100-9 for excess emissions. Requirements of OAC 252:100-

9 include immediate notification and written notification of Air Quality and

demonstrations that the excess emissions meet the criteria specified in OAC 252:100-

9.

D. Replacement, including temporary periods (6 months or less for maintenance purposes)

of the turbines shown in this permit with an engine of lesser or equal emissions of each

pollutant, is authorized under the following conditions:

1. The permittee shall notify AQD in writing not later than 7 days prior to start-up

of the replacement engine(s)/turbine(s). Said notice shall identify the old

engine/turbine and shall include the new engine/turbine make and model,

serial number, horsepower rating, and pollutant emission rates (g/hp-hr, lb/hr,

and TPY) at maximum horsepower for the altitude/location.


DRAFT

2. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be

conducted to confirm continued compliance with NOX and CO emission

limitations. A copy of the first quarter testing shall be provided to AQD within

60 days of start-up of each replacement engine/turbine. The test report shall

include the engine/turbine fuel usage, stack flow (ACFM), stack temperature

(oF), and pollutant emission rates (g/hp-hr, lbs/hr, and TPY) at maximum rated

horsepower for the altitude/location.

3. Replacement equipment and emissions are limited to equipment and

emissions which are not a modification under NSPS or NESHAP, or a

significant modification under PSD. For existing PSD facilities, the permittee

shall calculate the PTE or the net emissions increase resulting from the

replacement to document that it does not exceed significance levels and

submit the results with the notice required by a. of this Specific Condition.

E. Each turbine is subject to the federal New Source Performance Standards (NSPS) for

Stationary Gas Turbines, 40 CFR 60, Subpart GG, and shall comply with all

applicable requirements. [40 CFR §60.330 to §60.335]

1. No turbine shall discharge into the atmosphere any gases that contain

nitrogen oxides in excess of the limitation of §60.332(a)(2) except

when firing emergency fuel.

2. Each turbine shall comply with either the sulfur dioxide emission

limitation of §60.333(a) or the fuel sulfur content limitation of

§60.333(b).

3. Emissions monitoring for NOX per §60.334.

4. Monitoring of the sulfur and nitrogen content of the turbine fuel pursuant

to §60.334(h)(1) and (2), and §60.334(i). Per §60.334(h)(2), monitoring of

the fuel nitrogen content is not required if the owner or operator does not

take a NOX allowance for fuel-bound nitrogen. Monitoring of fuel sulfur

content is not required when a gaseous fuel is fired in the turbine and the

owner or operator demonstrates that the gaseous fuel meets the definition

of "natural gas" using one of the methods in §60.334(h)(3)(i) or (ii).

§60.331 defines natural gas as containing 20 grains or less of total sulfur

per 100 standard cubic feet and is either composed of at least 70 percent

methane by volume or has a gross caloric value between 950 and 1100

BTU/scf.


DRAFT

EUG 4. Dehydration Units

NOx CO VOC


West Dehydration Unit Still Vent

D-1

-- -- -- -- 4.35 19.04

West Vent Uncontrolled 200

hours per year -- -- -- -- 34.81 3.48

East Dehydration Unit Still Vent

D-2

-- -- -- -- 4.35 19.04

East Vent Uncontrolled 200

hours per year -- -- -- -- 34.81 3.48

A. The permittee shall comply with all applicable requirements of the National Emission

Standards for Hazardous Air Pollutants (NESHAP) for Oil and Natural Gas Production,

Subpart HH, for the TEG dehydration unit including, but not limited to, the following:

[40 CFR 63.760 through 63.775]

1. An owner or operator of a glycol dehydration unit that meets the exemption criteria in

§ 63.764(e)(1) shall maintain the records specified in §§ 63.774(d)(1), for that glycol

dehydration unit.

B. The glycol dehydration units shall be operated as follows:

1. Each glycol dehydration unit shall be equipped with a condenser.

2. The discharges from each condenser shall be vented to the units’ fireboxes, facility

flares, or equivalent devices for VOC emissions controls.

3. Each glycol dehydration unit shall be equipped with a flash tank on the rich glycol

stream.

4. The off-gases from each flash tank shall be routed to the station’s inlet or the reboiler

firebox.

5. Natural gas throughput, total of the two dehydration units, shall not exceed 200

MMSCFD (monthly average).

6. Each glycol dehydration unit may be operated up to 200 hours per year without

emissions controls. Records shall be kept of operating hours each day when controls

are bypassed or otherwise inoperative and reasons for control equipment downtime.


DRAFT

EUG 5A. Other Fuel-Burning Equipment Emissions from the following units are insignificant

and do not have a specific limitation.


HEAT1 H-1 Regeneration Heater 2.15 NA

HEAT2 H-2 Hot Oil Heater 7.0 NA

HEAT3 H-3 West Dehydration Reboiler 0.75 NA

HEAT4 H-4 East Dehydration Reboiler 0.75 NA

HEAT5 H-5 Gas Heater 3.3 NA

HEAT6 H-6 Regeneration Heater 2.7 NA

EUG 5B. Flares Emissions from the following units do not have a specific limitation.


FLARE1 F-1 Plant No. 3 Flare 0.05 NA

FLARE2 F-2 Plant No. 4 Flare 0.15 NA

A. The flares shall comply with the provisions of 40 CFR Part 60.18.

EUG 6. Condensate Tanks

EU Point Contents Capacity,

Gallons

VOC Emissions,

TPY

TANK1 T-1 Condensate 16,800

13.31 TANK2 T-2 Condensate 16,800



TANK5 T-5 Condensate 12,600 45.47

A. Condensate throughput of the atmospheric tanks (TANK1 – TANK4) shall not exceed

a total of 6,200,000 gallons per 12-month rolling period.

B. All condensate stored in the atmospheric condensate tanks (TANK-1 to TANK-4)

shall have been processed in the condensate stabilizer to reduce the vapor pressure of

the condensate. Off-gases from the condensate stabilizer shall be routed to the plant

inlet, flare, or an equally-efficient method of VOC emissions control.

C. Condensate throughput of the atmospheric tank TANK5 shall not exceed 420,000

gallons per 12-month rolling period.


DRAFT

EUG 7A. Other Tanks (Not Subject to OAC 252:100-37) Emissions from the following units

do not have a specific limitation.








TANK17 T-17 Engine Oil 8,400 NA




















TANK 39 T-39 Soap 500 NA



TANK 42 T-42 Triethylene Glycol 1,500 NA

TANK 43 T-43 Diesel 300 NA


DRAFT

EUG 7B. Other Tanks (Subject to OAC 252:100-37) Emissions from the following units do

not have a specific limitation.

EU Point Contents Gallons Construction

Date






TANK23 T-23 Methanol 16,800 1981

TANK24 T-24 Methanol 2,000 >1974

A. Propane shall be stored in pressure tanks. [OAC 252:100-37]

B. Methanol shall be stored in tanks which are equipped with submerged fill pipes.

[OAC 252:100-37]

EUG 8A. Cox City Plant Truck Loading

EU Point Equipment Annual

Throughput

VOC

Emissions TPY

LOAD1 L-1 Cox City Plant Truck Loading 6,200,000 gal 15.64

EUG 8B. Comanche Tie Plant Truck Loading Emissions from the following unit do not have a

specific limitation.

EU Point Equipment

Maximum

Anticipated Annual

Throughput,

Gallons

Installed

Date

LOAD2 L-2 Comanche Tie Truck Loading 420,000 1995

EUG 9A. Cox City Plant Fugitive VOC Leakage Fugitive VOC emissions do not have a

specific limitation, but are subject to NSPS Subpart KKK per Specific Condition No. 4.


Date

P-FUG P-FUG Fugitive VOC

Leakage

3,445 Valves

1992 to

present

5,541 Flanges

175 Relief Valves

96 Pump Seals


DRAFT

EUG 9B. Comanche Tie Fugitive VOC Leakage Fugitive VOC emissions do not have a specific

limitation.


Date

P-FUG P-FUG Fugitive VOC

Leakage

100 Gas/Vapor Valves

1995

110 Gas/Vapor Flanges

40 Compressor Seals

25 Gas/Vapor Relief Valves

10 Light Liquid Valves

11 Light Liquid Flanges

6 Light Liquid Pump Seals

5 Light Liquid Relief Valves

10 Heavy Liquid Pump Seals

2. The fuel-burning equipment shall be fired with pipeline grade natural gas or other

gaseous fuel with a sulfur content less than 343 ppmv. Compliance can be shown by the

following methods: for pipeline grade natural gas, a current gas company bill; for other

gaseous fuel, a current lab analysis, stain-tube analysis, gas contract, tariff sheet, or other

approved methods. Compliance shall be demonstrated at least once annually.

[OAC 252:100-31]

3. Except for Engine COMP1, the permittee shall be authorized to operate the facility

continuously (24 hours per day, every day of the year). [OAC 252:100-8-6(a)]

4. The permittee shall comply with the Standards of Performance for Equipment Leaks of

VOC from Onshore Natural Gas Processing Plants NSPS Subpart KKK, for each of the

affected facilities. [OAC 252:100-2]

A. The owner operator shall comply with the requirements of §§ 60.482-1(a), (b), and

(d) and § 60.482-2 through § 60.482-10 except as provided in § 60.333

1) The operator shall demonstrate compliance with §§ 60.482-1 to 60.482-10 for all

affected equipment within 180 days of initial startup which shall be determined by

review of records, reports, performance test results, and inspection using methods

and procedures specified in § 60.485 unless the equipment is in vacuum service

and is identified as required by § 60.486(e)(5).

2) The owner operator shall comply with the monitoring, inspection, and repair

requirements, for pumps in light liquid service, of §§ 60.482-2(a), (b), and (c)

except as provided in §§ 60-482-2(d), (e), and (f).

3) Each compressor shall be equipped with a seal system that includes a barrier fluid

system and that prevents leakage of VOC to the atmosphere, except as provided in

§ 60.632(c), § 60.633(f), § 60.482-1(c), § 60.482-3(h), and § 60.482-3(i).

i) Each compressor seal system shall comply with the requirements of §§

60.482-3(b).


DRAFT

ii) Each barrier fluid system shall be equipped with a sensor as required by §

60.482-3(d) that is monitored or equipped with an alarm as required by §

60.482-3(e) and repaired as required by §§ 60.482-3(f) and (g).

4) Any existing reciprocating compressor in a process unit which becomes an

affected facility under provisions of § 60.14 or § 60.15 is exempt from §§

60.482(a), (b), (c), (d), (e), and (h) , provided the owner or operator demonstrates

that recasting the distance piece or replacing the compressor are the only options

available to bring the compressor into compliance with the provisions of §§

60.482-3(a) through (e) and (h).

5) The owner operator shall comply with the operation and monitoring requirements,

for pressure relief devices in gas/vapor service, of §§ 60.482-4(a) and (b) except

as provided in § 60-482-4(c) and § 60.633(b).

6) Sampling and connection systems are exempt from the requirements of § 60.482-

5.

7) Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or

a second valve, except as provided in § 60.632(c). The cap, blind flange, plug, or

second valve shall seal the open end at all times except during operations

requiring process fluid flow through the open-ended valve or line. Each open-

ended valve or line equipped with a second valve shall be operated in a manner

such that the valve on the process fluid end is closed before the second valve is

closed. When a double block-and-bleed system is being used, the bleed valve or

line may remain open during operations that require venting the line between the

block valves but shall be closed at all other times.

8) The owner operator shall comply with the monitoring, inspection, and repair

requirements, for valves in gas/vapor service and light liquid service, of §§

60.482-7(b) through (e), except as provided in §§ 60.633(d), 60.482-7(f), (g), and

(h), §§ 60.483-1, 60.483-2, and 60.482-1(c).

9) The owner operator shall comply with the monitoring and repair requirements, for

pumps and valves in heavy liquid service, pressure relief devices in light liquid or

heavy liquid service, and flanges and other connectors, of §§ 60.482-8(a) through

(d).

10) Delay of repair of equipment is allowed if it meets one of the requirements of

§§ 60.482-9(a) through (e).

11) The owner or operators using a closed vent system and control device to comply

with these provisions shall comply with the design, operation, monitoring and

other requirements of 60.482-10(b) through (g).

B. An owner or operator may elect to comply with the alternative requirements for

valves of §§ 60.483-1 and 60.483-2.


DRAFT

C. An owner or operator may apply to the Administrator for permission to use an

alternative means of emission limitation that achieves a reduction in emissions of

VOC at least equivalent to that achieved by the controls required in NSPS Subpart

KKK. In doing so, the owner or operator shall comply with requirements of §

60.634.

D. Each owner or operator subject to the provisions of NSPS Subpart KKK shall

comply with the test method and procedures of § 60.485 except as provided in §§

60.632(f) and 60.633(h).

E. Each owner or operator subject to the provisions of NSPS Subpart KKK shall

comply with the recordkeeping requirements of § 60.486 and the reporting

requirements of § 60.487 except as provided in §§ 60.633, 60.635, and 60.636.

F. Each owner or operator subject to the provisions of NSPS Subpart KKK shall

comply with the recordkeeping requirements of §§ 60.635(b) and (c) in addition to

the requirements of § 60.486.

G. Each owner or operator subject to the provisions of NSPS Subpart KKK shall

comply with the reporting requirements of §§ 60.636(b) and (c) in addition to the

requirements of § 60.487.

5. The permittee shall keep records as follows. These records shall be retained on site or at a

local field office for a period of at least five years following dates of recording, and shall

be made available to regulatory personnel upon request. [OAC 252:100-43]

A. Periodic testing of NOx and CO emissions from the engines and turbines.

B. Hours of operation for any engine/turbine if less than 220 hours per quarter and

testing is not conducted.

C. Condensate throughputs (monthly and 12-month rolling totals) at each loading

operation.

D. Total combined natural gas throughput of both dehydration units, MMSCFD

(monthly average)

E. Records as required by 40 CFR Part 60, Subpart KKK.

F. Hours of operation of Engine COMP1 (monthly and 12-month rolling totals).

G. Records as required by 40 CFR Part 63, Subpart HH.

H. For the fuel(s) burned, the appropriate document(s) as described in Specific

Condition No. 2.


DRAFT

I. Records shall be kept of operating hours of each dehydration unit each day when

controls are bypassed or otherwise inoperative while the dehydration unit is in

operation.

6. This permit supersedes all previous Air Quality permits, which are now null and void.

PERMIT


STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2009-198-TV

Enogex Products LLC

having complied with the requirements of the law, is hereby granted permission to operate

the Cox City Processing Plant located in Sec. 26 – 4N – 6W, Grady County, Oklahoma,

subject to standard conditions dated July 21, 2009, and specific conditions, both attached.__

_________________________________

Division Director, Air Quality Division Date

DEQ Form #100-890 Revised 10/20/06

Enogex Products LLC

Attn: Lance Lodes

P. O. Box 24300, M/C E656

Oklahoma City, OK 73124

Re: Permit No. 2009-198-TV


Sec. 26 – T 4N – R 6W

Grady County, Oklahoma

Dear Mr. Lodes:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this

permit is issued subject to standards and specific conditions, which are attached. These

conditions must be carefully followed since they define the limits of the permit and will be

confirmed by periodic inspections.

Also note that you are required to annually submit an emissions inventory for this facility. An

emissions inventory must be completed on approved AQD forms and submitted (hardcopy or

electronically) by April 1st of every year. Any questions concerning the form or submittal

process should be referred to the Emissions Inventory Staff at 405-702-4100.

Thank you for your cooperation in this matter. If we may be of further service, please contact me

at (405) 702-4100.

Sincerely,

David S. Schutz, P.E.

New Source Permits Section


Enclosure

MAJOR SOURCE AIR QUALITY PERMIT

STANDARD CONDITIONS

(July 21, 2009)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with the federal

Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act

and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma

Department of Environmental Quality (DEQ). The permit does not relieve the holder of the

obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or

ordinances. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance

shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement

action, permit termination, revocation and reissuance, or modification, or for denial of a permit

renewal application. All terms and conditions are enforceable by the DEQ, by the Environmental

Protection Agency (EPA), and by citizens under section 304 of the Federal Clean Air Act

(excluding state-only requirements). This permit is valid for operations only at the specific

location listed.

[40 C.F.R. §70.6(b), OAC 252:100-8-1.3 and OAC 252:100-8-6(a)(7)(A) and (b)(1)]

D. It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

conditions of the permit. However, nothing in this paragraph shall be construed as precluding

consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for

noncompliance if the health, safety, or environmental impacts of halting or reducing operations

would be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from an emergency and/or posing an imminent and substantial

danger to public health, safety, or the environment shall be reported in accordance with Section

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported

consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

[OAC 252:100-8-6(a)(3)(C)(iv)]

C. Every written report submitted under this section shall be certified as required by Section III

(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

MAJOR SOURCE STANDARD CONDITIONS July 21, 2009 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. These records, including

monitoring data and necessary support information, shall be retained on-site or at a nearby field

office for a period of at least five years from the date of the monitoring sample, measurement,

report, or application, and shall be made available for inspection by regulatory personnel upon

request. Support information includes all original strip-chart recordings for continuous

monitoring instrumentation, and copies of all reports required by this permit. Where appropriate,

the permit may specify that records may be maintained in computerized form.

[OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:100-8-6(c)(1), and OAC 252:100-8-6(c)(2)(B)]

B. Records of required monitoring shall include:

(1) the date, place and time of sampling or measurement;

(2) the date or dates analyses were performed;

(3) the company or entity which performed the analyses;

(4) the analytical techniques or methods used;

(5) the results of such analyses; and

(6) the operating conditions existing at the time of sampling or measurement.

[OAC 252:100-8-6(a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the

original Part 70 operating permit or alternative date as specifically identified in a subsequent Part

70 operating permit, the permittee shall submit to AQD a report of the results of any required

monitoring. All instances of deviations from permit requirements since the previous report shall

be clearly identified in the report. Submission of these periodic reports will satisfy any reporting

requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the

submitted report. [OAC 252:100-8-6(a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or

operator shall comply with the provisions of Section II (Reporting Of Deviations From Permit

Terms) of these standard conditions. [OAC 252:100-8-6(a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this

permit, monitoring and reporting may be required under the provisions of OAC 252:100-43,

Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean

Air Act or Oklahoma Clean Air Act. [OAC 252:100-43]

F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report,

Excess Emission Report, and Annual Emission Inventory submitted in accordance with this

permit shall be certified by a responsible official. This certification shall be signed by a

responsible official, and shall contain the following language: “I certify, based on information

and belief formed after reasonable inquiry, the statements and information in the document are

true, accurate, and complete.”

[OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC

252:100-9-7(e), and OAC 252:100-5-2.1(f)]


G. Any owner or operator subject to the provisions of New Source Performance Standards

(“NSPS”) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants

(“NESHAPs”) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other

information required by the applicable general provisions and subpart(s). These records shall be

maintained in a permanent file suitable for inspection, shall be retained for a period of at least

five years as required by Paragraph A of this Section, and shall include records of the occurrence

and duration of any start-up, shutdown, or malfunction in the operation of an affected facility,

any malfunction of the air pollution control equipment; and any periods during which a

continuous monitoring system or monitoring device is inoperative.

[40 C.F.R. §§60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q]

H. The permittee of a facility that is operating subject to a schedule of compliance shall submit

to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for

achieving the activities, milestones or compliance required in the schedule of compliance and the

dates when such activities, milestones or compliance was achieved. The progress reports shall

also contain an explanation of why any dates in the schedule of compliance were not or will not

be met, and any preventive or corrective measures adopted. [OAC 252:100-8-6(c)(4)]

I. All testing must be conducted under the direction of qualified personnel by methods

approved by the Division Director. All tests shall be made and the results calculated in

accordance with standard test procedures. The use of alternative test procedures must be

approved by EPA. When a portable analyzer is used to measure emissions it shall be setup,

calibrated, and operated in accordance with the manufacturer’s instructions and in accordance

with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document

or an equivalent method approved by Air Quality.

[OAC 252:100-8-6(a)(3)(A)(iv), and OAC 252:100-43]

J. The reporting of total particulate matter emissions as required in Part 7 of OAC 252:100-8

(Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and

OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing

or calculation procedures, modified to include back-half condensables, for the concentration of

particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of only

particulate matter emissions caught in the filter (obtained using Reference Method 5).

K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required

by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit

subject to such standards. [OAC 252:100-8-6(c)(1) and OAC 252:100, Appendix Q]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70

operating permit or alternative date as specifically identified in a subsequent Part 70 operating

permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a

certification of compliance with the terms and conditions of this permit and of any other

applicable requirements which have become effective since the issuance of this permit.

[OAC 252:100-8-6(c)(5)(A), and (D)]


B. The compliance certification shall describe the operating permit term or condition that is the

basis of the certification; the current compliance status; whether compliance was continuous or

intermittent; the methods used for determining compliance, currently and over the reporting

period. The compliance certification shall also include such other facts as the permitting

authority may require to determine the compliance status of the source.

[OAC 252:100-8-6(c)(5)(C)(i)-(v)]

C. The compliance certification shall contain a certification by a responsible official as to the

results of the required monitoring. This certification shall be signed by a responsible official, and

shall contain the following language: “I certify, based on information and belief formed after

reasonable inquiry, the statements and information in the document are true, accurate, and

complete.” [OAC 252:100-8-5(f) and OAC 252:100-8-6(c)(1)]

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions

units or stationary sources that are not in compliance with all applicable requirements. This

schedule shall include a schedule of remedial measures, including an enforceable sequence of

actions with milestones, leading to compliance with any applicable requirements for which the

emissions unit or stationary source is in noncompliance. This compliance schedule shall

resemble and be at least as stringent as that contained in any judicial consent decree or

administrative order to which the emissions unit or stationary source is subject. Any such

schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the

applicable requirements on which it is based, except that a compliance plan shall not be required

for any noncompliance condition which is corrected within 24 hours of discovery.

[OAC 252:100-8-5(e)(8)(B) and OAC 252:100-8-6(c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the

permit term and that are applicable to the facility. Compliance with all new requirements shall

be certified in the next annual certification. [OAC 252:100-8-6(c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions

established for alternate operating scenarios, emissions trading, and emissions averaging, but

excluding terms and conditions for which the permit shield is expressly prohibited under OAC

252:100-8) shall be deemed compliance with the applicable requirements identified and included

in this permit. [OAC 252:100-8-6(d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific

Conditions of this permit. Those requirements that the applicant requested be determined as not

applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6(d)(2)]


SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees

based on emissions inventories. The methods used to calculate emissions for inventory purposes

shall be based on the best available information accepted by AQD.

[OAC 252:100-5-2.1, OAC 252:100-5-2.2, and OAC 252:100-8-6(a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date

of issuance. [OAC 252:100-8-6(a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely

and complete renewal application has been submitted at least 180 days before the date of

expiration. [OAC 252:100-8-7.1(d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and

become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction

is not commenced within 18 months after the date the permit or authorization was issued, or if

work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified

operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application

of any provision of this permit to any circumstance, is held invalid, the application of such

provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

[OAC 252:100-8-6 (a)(6)]

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege.

[OAC 252:100-8-6(a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon

which the equipment is located and does not release the permittee from any liability for damage

to persons or property caused by or resulting from the maintenance or operation of the equipment

for which the permit is issued. [OAC 252:100-8-6(c)(6)]


SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty

(60) days of the request unless the DEQ specifies another time period, any information that the

DEQ may request to determine whether cause exists for modifying, reopening, revoking,

reissuing, terminating the permit or to determine compliance with the permit. Upon request, the

permittee shall also furnish to the DEQ copies of records required to be kept by the permit.

[OAC 252:100-8-6(a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted

pursuant to 27A O.S. § 2-5-105(18). Confidential information shall be clearly labeled as such

and shall be separable from the main body of the document such as in an attachment.

[OAC 252:100-8-6(a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and

shall be made in writing within thirty (30) days after such sale or transfer.

[Oklahoma Clean Air Act, 27A O.S. § 2-5-112(G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause.

Except as provided for minor permit modifications, the filing of a request by the permittee for a

permit modification, revocation and reissuance, termination, notification of planned changes, or

anticipated noncompliance does not stay any permit condition.

[OAC 252:100-8-6(a)(7)(C) and OAC 252:100-8-7.2(b)]

B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the

following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source

category three or more years prior to the expiration date of this permit. No such

reopening is required if the effective date of the requirement is later than the expiration

date of this permit.

(2) The DEQ or the EPA determines that this permit contains a material mistake or that the

permit must be revised or revoked to assure compliance with the applicable requirements.

(3) The DEQ or the EPA determines that inaccurate information was used in establishing the

emission standards, limitations, or other conditions of this permit. The DEQ may revoke

and not reissue this permit if it determines that the permittee has submitted false or

misleading information to the DEQ.

(4) DEQ determines that the permit should be amended under the discretionary reopening

provisions of OAC 252:100-8-7.3(b).

C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-8-

7.3(d). [OAC 100-8-7.3(d)]


D. The permittee shall notify AQD before making changes other than those described in Section

XVIII (Operational Flexibility), those qualifying for administrative permit amendments, or those

defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The

notification should include any changes which may alter the status of a “grandfathered source,”

as defined under AQD rules. Such changes may require a permit modification.

[OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]

E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that

are not specifically approved by this permit are prohibited. [OAC 252:100-8-6(c)(6)]

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of credentials and other documents as may be required by law, the

permittee shall allow authorized regulatory officials to perform the following (subject to the

permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18)

for confidential information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a

source is located or emissions-related activity is conducted, or where records must be

kept under the conditions of the permit;

(2) have access to and copy, at reasonable times, any records that must be kept under the

conditions of the permit;

(3) inspect, at reasonable times and using reasonable safety practices, any facilities,

equipment (including monitoring and air pollution control equipment), practices, or

operations regulated or required under the permit; and

(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit.

[OAC 252:100-8-6(c)(2)]

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later

than 4:30 p.m. on the next working day after the permittee first becomes aware of the

exceedance. This notice shall contain a description of the emergency, the probable cause of the

exceedance, any steps taken to mitigate emissions, and corrective actions taken.

[OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)]

B. Any exceedance that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to AQD as soon as is practicable; but under no circumstance shall

notification be more than 24 hours after the exceedance. [OAC 252:100-8-6(a)(3)(C)(iii)(II)]

C. An "emergency" means any situation arising from sudden and reasonably unforeseeable

events beyond the control of the source, including acts of God, which situation requires

immediate corrective action to restore normal operation, and that causes the source to exceed a

technology-based emission limitation under this permit, due to unavoidable increases in

emissions attributable to the emergency. An emergency shall not include noncompliance to the


extent caused by improperly designed equipment, lack of preventive maintenance, careless or

improper operation, or operator error. [OAC 252:100-8-2]

D. The affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8-6 (e)(2)]

(1) an emergency occurred and the permittee can identify the cause or causes of the

emergency;

(2) the permitted facility was at the time being properly operated;

(3) during the period of the emergency the permittee took all reasonable steps to minimize

levels of emissions that exceeded the emission standards or other requirements in this

permit.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an

emergency shall have the burden of proof. [OAC 252:100-8-6(e)(3)]

F. Every written report or document submitted under this section shall be certified as required

by Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop

and register with the appropriate agency a risk management plan by June 20, 1999, or the

applicable effective date. [OAC 252:100-8-6(a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate individual emissions units that are either on the list in Appendix I to OAC Title 252,

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.

Any activity to which a State or Federal applicable requirement applies is not insignificant even

if it meets the criteria below or is included on the insignificant activities list.

(1) 5 tons per year of any one criteria pollutant.

(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an

aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year

for single HAP that the EPA may establish by rule.

[OAC 252:100-8-2 and OAC 252:100, Appendix I]

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate any individual or combination of air emissions units that are considered inconsequential

and are on the list in Appendix J. Any activity to which a State or Federal applicable

requirement applies is not trivial even if included on the trivial activities list.

[OAC 252:100-8-2 and OAC 252:100, Appendix J]


SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the

need for any permit revision or any notification to the DEQ (unless specified otherwise in the

permit). When an operating scenario is changed, the permittee shall record in a log at the facility

the scenario under which it is operating. [OAC 252:100-8-6(a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

(1) result in no net emissions increases,

(2) are not modifications under any provision of Title I of the federal Clean Air Act, and

(3) do not cause any hourly or annual permitted emission rate of any existing emissions unit

to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required

below in advance of the proposed changes, which shall be a minimum of seven (7) days, or

twenty four (24) hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the

DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such

change, the written notification required above shall include a brief description of the change

within the permitted facility, the date on which the change will occur, any change in emissions,

and any permit term or condition that is no longer applicable as a result of the change. The

permit shield provided by this permit does not apply to any change made pursuant to this

paragraph. [OAC 252:100-8-6(f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility

unless elsewhere covered by a more restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized

in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-13]

(2) No particulate emissions from any fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an opacity limit promulgated under 40 C.F.R., Part

60, NSPS, no discharge of greater than 20% opacity is allowed except for:

[OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any

consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours.

In no case shall the average of any six-minute period exceed 60% opacity;

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7;

(c) An emission, where the presence of uncombined water is the only reason for failure to

meet the requirements of OAC 252:100-25-3(a); or


(d) Smoke generated due to a malfunction in a facility, when the source of the fuel

producing the smoke is not under the direct and immediate control of the facility and

the immediate constriction of the fuel flow at the facility would produce a hazard to

life and/or property.

(4) No visible fugitive dust emissions shall be discharged beyond the property line on which

the emissions originate in such a manner as to damage or to interfere with the use of

adjacent properties, or cause air quality standards to be exceeded, or interfere with the

maintenance of air quality standards. [OAC 252:100-29]

(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2

lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and

with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or

greater under actual conditions shall be equipped with a permanent submerged fill pipe or

with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of

ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an order for production or importation of certain

class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the

requirements of §82.4;

(2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain

class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping

requirements at §82.13; and

(3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,

HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane

(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an

ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air

conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the

vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the

air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger

buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions


reduction except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply

with the required practices pursuant to § 82.156;

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must

comply with the standards for recycling and recovery equipment pursuant to § 82.158;

(3) Persons performing maintenance, service, repair, or disposal of appliances must be

certified by an approved technician certification program pursuant to § 82.161;

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply

with record-keeping requirements pursuant to § 82.166;

(5) Persons owning commercial or industrial process refrigeration equipment must comply

with leak repair requirements pursuant to § 82.158; and

(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant

must keep records of refrigerant purchased and added to such appliances pursuant to §

82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is

not inconsistent with Federal requirements, to provide for incorporation of requirements

established through construction permitting into the Source’s Title V permit without causing

redundant review. Requirements from construction permits may be incorporated into the Title V

permit through the administrative amendment process set forth in OAC 252:100-8-7.2(a) only if

the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the

procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to

the public that this permit is subject to EPA review, EPA objection, and petition to

EPA, as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit

will be incorporated into the Title V permit through the administrative amendment

process; that the public will not receive another opportunity to provide comments when

the requirements are incorporated into the Title V permit; and that EPA review, EPA

objection, and petitions to EPA will not be available to the public when requirements

from the construction permit are incorporated into the Title V permit.

(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR §

70.8(a)(1).

(3) A copy of the draft construction permit is sent to any affected State, as provided by 40

C.F.R. § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period

as provided by 40 C.F.R.§ 70.8(a) and (c).

(5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day

comment period of any EPA objection to the construction permit. The DEQ shall not

issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 C.F.R. § 70.8(d).

(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).


(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these

permit conditions.

(9) Any requirements of the construction permit may be reopened for cause after

incorporation into the Title V permit by the administrative amendment process, by DEQ

as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40

C.F.R. § 70.7(f) and (g).

(10) The DEQ shall not issue the administrative permit amendment if performance tests fail

to demonstrate that the source is operating in substantial compliance with all permit

requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the

Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing

shall preclude the use, including the exclusive use, of any credible evidence or information,

relevant to whether a source would have been in compliance with applicable requirements if the

appropriate performance or compliance test or procedure had been performed.

[OAC 252:100-43-6]

Documents

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY · OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY ... led to some confusion, ... FLARE1 F-1 Plant No. 3 Flare 0.05 1994