OKLAHOMA DEPARTMENT OF ENVIRONMENTAL · PDF fileOKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY ... separation, with the aqueous ... condenser on reactor C-6005 and an associated decanter

DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM December 17, 2010

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

THROUGH: Kendal Stegmann, Senior Environmental Manager

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

THROUGH: Peer Review, David Pollard

FROM: Herb Neumann, Regional Office at Tulsa

SUBJECT: Evaluation of Permit Application No. 2010-002-TVR2

Baker Petrolite Corporation

Synthetic Polymer Manufacturing Facility

820 Birch Lake Road, Barnsdall, Osage County

SE/4 18, T24 N, R11 E (36.555 N, 96.166 W)

West on OK 11 approximately one mile from its intersection with OK 123;

turn left (west) on Chestnut as OK 11 bends to the north entering Barnsdall, ¼

mile to 8th

Street (Birch Lake Road), turn left (south) ¼ mile to facility.

I. FACILITY DESCRIPTION

This facility started operations as a petroleum refinery in 1907. By the 1950s, the facility had

specialized in microcrystalline waxes and most other activities were discontinued. A production

unit for the manufacture of synthetic waxes (SIC 2869) was built in 1970 and a second unit was

constructed in 1989. The two production units, referred to as EP Units (for Ethylene Polywax) or

just Polywax Units, are identified as Unit A for the older area and Unit B for the newer area. All

microcrystalline wax manufacture was ended in 1996. The facility currently operates under Part

70 permit No. 2004-162-TVR (M-1), issued September 6, 2006. The current request is to renew

the Part 70 operating permit. Applicant requests that the Insignificant Activity list be updated, that

changes in compliance dates for NESHAP FFFF be identified in the permit, and that various minor

changes at the facility that have been made through notification or through applicability

determination be incorporated into the operating permit. Each of these requested changes will be

addressed at appropriate points in the memorandum and Specific Conditions.

II. PROCESS DESCRIPTIONS

The Barnsdall Plant manufactures organic chemicals in three primary production units and

support operations. The three production units are Synthetic Wax Production Unit, Resin Unit,

and Oxidation Unit, and they will be discussed in the order listed. Miscellaneous Sources are

listed following discussion of the production units.

PERMIT MEMORANDUM 2010-002-TVR2 DRAFT

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SYNTHETIC WAX PRODUCTION UNIT

BPC manufactures low molecular weight synthetic waxes, designated as ethylene polywax (EP)

products. The synthetic waxes are produced by polymerizing organic monomers, principally

ethylene and propylene. EP finished products are solids at ambient temperature and have

negligible volatility. Raw materials used in the EP process are organic monomers (principally

ethylene and propylene), reaction initiators, reaction catalyst, and carrier solvent. With the

exception of the reaction catalyst, all these raw materials are received and stored in bulk tanks.

The plant operates two ethylene bulk tanks that are nominally sized at approximately 30,000

gallons capacity, and one propylene bulk tank nominally sized at 15,000 gallons capacity. The

reaction initiators and carrier solvent are stored and dispensed from three separate bulk tanks.

The reaction catalyst is received and dispensed from 55-gallon drums. Major processing steps

employed to produce synthetic waxes follow.

Polymerization Reaction

The polymerization reaction is conducted in water-cooled agitated reactor vessels. In this

process, the carrier solvent (toluene, the principal HAP), initiator, and catalyst are fed to the

reactor, and then the monomer is added. Polymerization occurs, converting the monomer into a

long-chain synthetic wax. The reaction mass is fed to a surge tank or directly to a wash tank for

further processing. The facility can also route the reaction mass to an oxidization vessel to

produce high molecular weight alcohols (Unilin®). These alcohols are very similar to the

synthetic waxes, having negligible volatility.

Hydrolysis and Aqueous Washing

The reaction mass is fed to a hydrolysis and washing system. The purpose of this step is to

hydrolyze the wax product and to remove the water-soluble initiator and catalyst compounds

from the reaction mass. Washing consists of sequential water washes followed by phase

separation, with the aqueous phase discharging to solvent recovery and the organic phase routed

to polymer recovery.

Polymer Recovery

The organic phase discharged from the washing step is initially transferred to a flash

evaporator/condenser system. This removes the majority of carrier solvent from the polymer

product. A steam stripping process then removes the residual carrier solvent. Overheads from

the stripping process are condensed and collected. The solvent with entrained water content

mixture from both condensing systems discharges to “wet” solvent collection tanks. Polymer

from the steam stripping unit discharges to accumulation/storage tanks where it is tested and then

pumped to liquid product storage tanks or to the facility’s prilling tower (see page 6), where wax

beads are formed as the final product.

Aqueous Phase Solvent Recovery

The aqueous phase material discharged from the washing system and from the phase separation

of the wet solvent is fed to a flash tank/condenser system or to a steam stripping

column/condenser to remove and recover the carrier solvent. The condensers discharge to the

wet solvent collection tanks. The stripped aqueous phase discharges to a solid/liquid separator


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and lagoon system, and is ultimately pumped to a deep well injection system. The well is a Class

1 non-hazardous injection well permitted by the EPA.

Solvent Purification/Drying

The recovered carrier solvent accumulated in the wet solvent collection tanks is allowed to phase

separate with the aqueous phase fed to the aqueous solvent recovery systems, and the organic

phase fed to a distillation column for purification. Overheads from the distillation column are

condensed and returned to the column as reflux. Water that is condensed is drawn off to the

plant effluent system. Purification residuals from the distillation column are accumulated in a

tank system and eventually sold to customers as Solvent 250. A side draw of the purified solvent

is routed to an accumulation tank. This tank feeds a second distillation column for removal of

any residual water. Solvent from this second drying column is fed to a molecular sieve bed that

further reduces the water content. Dried purified solvent is then routed to another accumulation

tank that recycles the solvent back to the initial polymerization reaction step.

Reactor Wash Processing

Off-specification product, line flushings, raw samples and material from reactor-cleaning are

recycled in the reactor wash processing system. This system recovers solvents from the above-

listed material using a flash evaporator and condenser. The condenser discharges recovered

solvent back to the wet solvent collection tanks. Other material recovered from the system is

collected, allowed to solidify, and stored prior to landfill disposal off-site.

Unicid® Acid

This new process (May 2006) manufactures long chain carboxylic acids, using high molecular

weight alcohol wax manufactured at the facility. This raw material had previously been shipped

off site to an independent contractor, who manufactured the acid and returned the finished

product to the facility for packaging. Alcohol is pumped into a heated 4,000-gallon reactor, an

aqueous solution of caustic is added, and more heat is added to distill the water out. Water vapor

is condensed and routed to the existing aqueous handling system. The remaining material is

heated to reaction temperature, forming a viscous salt. Nitrogen is used to purge the system

during the reaction in order to remove minimal amounts of hydrogen generated. The salt is

cooled and toluene from the existing toluene recycle process is added as a solvent to reduce

viscosity. The salt/solvent mass is pushed into a glass-lined 4,000-gallon reactor containing

aqueous hydrochloric acid (HCl). The resulting reaction forms potassium chloride (KCl) and the

desired carboxylic acid. Water washes remove KCl and excess HCl and the washwater is routed

to the existing aqueous handling system. The remaining material is heated and steam stripped to

remove the solvent, which is routed to the existing solvent recycle system, and the product is sent

to a packaging unit. The only equipment added for this process was two 4,000-gallon reactors,

two condensers, a gas-fired 1-MMBTUH oil heater, two small pumps, and necessary piping

components.

RESIN UNIT

The resin unit is a batch operation that manufactures various waxes through chemical reactions.

These reactions require catalysts and elevated temperature and/or pressure, will usually generate

heat, and generally use cooling water to maintain control of the reactions. The cooling water

from this process is recirculated to the facility’s non-contact cooling water tower. This system


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consists of four reactors; one 750-gallon (Equipment ID No. C-6001), one 1,500-gallon (C-

6003), and two 8,500-gallon (C-6005 and C-6006). Volatile organic vapors are generated during

the chemical addition and reaction processes. These vapors are condensed and collected in four

storage tanks as a co-product. Vapors from each storage tank associated with a reactor are

routed to a vent condenser (E-6026A, E-6026B, E-6027, and E-6028). The vent condensers are

cooled with chilled water at approximately 40 F in a closed-loop system, resulting in high

removal efficiency (> 70%) of organic compounds vented through the system. Vent parameters

are listed at the end of Section III of this Memorandum. The product waxes from the resin unit

are shipped in bulk, packaged into drums or pails, or transferred to the packaging unit systems.

Cold Flow Description

A new product line being manufactured at the Resin Unit is a Cold Flow Improver (CFI) used for

depressing the pour points of crude oil has no appreciable effect on emissions, and is described

here only for completeness. These CFIs are produced in existing equipment in the Resin Unit

and use reactions similar to those for other current products. Production of the CFIs required

minor changes to the existing system. The changes include the addition of a small reflux

condenser on reactor C-6005 and an associated decanter that collects liquid and returns it to the

reactor while venting any vapors to existing condenser E-6005. This condenser is installed prior

to the vacuum receiver leading to condenser E-6010, where some emissions from the resin

process are vented to the atmosphere through emission point EP-6010. The new product also

requires use of a new solvent referred to as Solvent 14 or Aromatic 100 Solvent, which is stored

in a new 8,000-gallon tank before being added to the process. This tank is vented to condenser

E-6028, described in the preceding paragraph. Products from this process are transferred directly

to a tank truck for shipment or to totes for storage. The changes to the Resin Unit do not

increase the overall production capacity of the unit and when combined with the existing

production, do not exceed the limits specified in the current Title V permit.

OXIDATION UNIT

The oxidation unit consists of two approximately 7,500-gallon vessels (C-6101 and C-6105),

which are equipped to treat wax by forcing air through spargers at the bottom of each oxidizer.

The air is supplied from two 2,000-scfm blowers (G-6111A and G-6111B) and is used as the

source of oxygen for agitation of the wax during the oxidation process and to maintain control of

the oxidation rates at specific temperatures. The excess air exits the oxidation units through a

knockout pot and is then burned in a catalytic oxidizer, Emission Point V-6101. Steam and

cooling water are also used to assist in temperature control for the oxidation units. The steam

condensate is returned to the facility feed water system and the cooling water is routed to the

non-contact cooling water tower. One of the oxidation units is outfitted as a pressure vessel (C-

6105) and contains a vacuum jet that removes vapors. This vacuum jet operates approximately

12 hours per month and results in discharges containing an aromatic substitute of urea through

the catalytic oxidizer. The oxidizer vents to the atmosphere through a 1.5 diameter stack,

exhausting a maximum 4,000 scfm at 1,000 F at 58 above grade. The product waxes (oxidized

waxes) can be transferred directly to the packaging unit systems or to storage tanks, pending

final packaging.


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MISCELLANEOUS SOURCES

Emulsions Production

Emulsions are produced by dispersing wax products in water. The generic materials for the

process are wax, water, surfactant, and biocide, which is optional. Emulsion processing uses

several different procedures, namely wax to water, water to wax, heat/mix, and finally

blend/homogenize.

Wax to water and water to wax processes are very similar. The two components start in separate

vessels at elevated temperatures, with the surfactant mixed in one of them. To form the

emulsion, one of the components is slowly added to the other component while mixing. After

the emulsion is formed, the product is cooled and packaged. When biocide is used, it is added

just before packaging.

Heat/mix operations are very basic. All of the raw materials are put into a single vessel and

heated. The material is agitated to disperse the components. The product is then cooled, and

finally packaged.

Blend/homogenize operations are more complex. First, the materials are blended together in one

vessel. Then they are heated and mixed using the coils and agitator in the vessel. Next, they are

transferred through a homogenizer to a second vessel. The homogenizer is a very high-pressure

pump with a very small orifice. It causes extreme mixing in the liquid being pumped.

Numerous processing steps are required to accomplish this due to the high pressure involved,

and the need to protect the homogenizer equipment from physical damage. The liquid may be

passed back and forth through the homogenizer between the two vessels several times to achieve

the desired product characteristics. After homogenizing, the product is cooled and packaged.

Equipment for the emulsion system consists of two stainless steel vessels with approximately

2,000-gallon working capacity. The vessels are pressure rated to 150 psi, with internal coils and

agitators. The homogenizer pumps approximately 15 gpm, and is rated for about 15,000 psi. A

small gear pump is installed before the homogenizer to maintain positive suction pressure. De-

ionized water is produced using an off-the-shelf ion exchange system. Because the water-based

emulsions are non-hazardous, packaging is accomplished by simply transferring the product to a

container through a bag type filter and a hose. The container may be a drum, pail or tote. The

proper amount of product is weighed as it is added to the container, and then sealed for shipment.

The emissions from this process are negligible, so this process has been added to the

insignificant activity list.

Microcrystalline Wax Blending and Packaging

Microcrystalline waxes are produced by simply blending different waxes together, and

packaging, or shipping out as liquid bulk product. Some of the waxes are purchased from

outside sources and brought in by tank truck. Other components of the blends are waxes made at

the Barnsdall plant, which may be obtained from liquid bulk stock, or from packaged product

stock. The blending may be done in any available tank, and agitation may be provided by rolling

with nitrogen if no mechanical agitator is present. “Rolling” is equivalent to fluidized bed

action.

Packaging of microcrystalline waxes is accomplished by prilling, mini-prilling, pastilling,

micronizing, or slabbing. “Slabbing” is the production of wax in large blocks.


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Packaging and Shipping

Both liquid and solid products are shipped from BPC to customers. Liquids are shipped via

tanker truck, or in packages such as drums, bulk bags, and pails. Solid waxes are sized and

packaged into various bags, totes, and drums for shipment.

Spray Micronizer

This is a process that atomizes wax into extremely fine particles. Molten wax and steam are

injected into a “micronizing” nozzle. The exiting wax particles are air cooled and captured in a

baghouse, from which they are removed with compressed air. They are sorted through a sizing

shaker screen and drummed or bagged as a product. Oversized particles are melted and returned to

feedstock. Moisture content and particle size are partially controlled with elevated temperatures

and occasional use of nitrogen. A 2,500-scfm blower induces heated air through the ductwork and

baghouse. The baghouse is integral to production, and applicant does not consider it to be a piece

of pollution control equipment. It has an efficiency of 99.99%. The baghouse exhausts 2,500 scfm

at 120 F through a 10 diameter stack identified as emission point G-6303, venting at 39 above

grade.

Sandvik Belt Unit

This process produces small wax beads called pastilles. Molten wax is pumped through

pastillating heads to produce small drops of wax, which fall onto a stainless steel conveyor belt.

Chilled and/or cooling water is sprayed on the underside of the belt, causing the drops to solidify

upon contacting the belt surface. A scraper blade separates the pastilles from the belt; they are

sorted on a screen shaker, and packaged as product. Oversized drops are returned to feedstock.

There are two lines, identical in operation and length, but with different widths.

Air Attrition Unit

In this process solid wax is tumbled by compressed air, fracturing the pieces of wax into smaller

particles. Particles are carried into a cyclone by the exhaust air stream. Fine particles collect in the

center of the cyclone and pass to a baghouse. Particles are removed from the baghouses using

compressed air, and the products are packaged. One difference from the micronizer system is that

a flexible hose is attached to the exhaust system only during start-up, and a filter sack is placed

over the end of the hose. Once the system is operating properly, air is routed through the baghouse

and the hose is disconnected. This prevents emissions during the start-up process. As with the

micronizer system, the baghouse is integral to production, and applicant does not consider it to be a

piece of pollution control equipment. It has an efficiency of 99%. The baghouse exhausts 105

scfm at 100 F through a 4 diameter stack identified as emission point AAM, venting at grade.

Prilling Tower

Molten synthetic wax is pumped from storage to the top of the prilling tower and sprayed

downward. Ambient air is pulled upwards through the tower and the resulting countercurrent heat

transfer allows the droplets of copolymer to form into hard beads. The beads are screened for size,

with the larger beads being returned to the heated storage tanks. The reverse air is fed to cyclones

for recovery of copolymer fines, which are also returned to the heated storage tanks. Although the

cyclones act as pollution control devices, they are integral to the process and recover valuable

material for processing.


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Mini-Prill Description

Mini-Prilling (MP) is very similar to prilling. The primary differences between prilling and MP

are: that MP produces a much smaller bead; that MP uses different geometry, spraying the liquid

up into the air, and allowing it to fall back down into the bed; that MP allows the potential to

recirculate air back into the MP system; that MP uses a cooling exchanger and a filter cloth to

prepare the cooling air before re-using it; and that a refrigeration unit is used to help chill the air

that flows through the unit. Liquid wax is fed from existing wax storage tanks to a booster pump

which forces wax through heated spray bars. As it is forced through the nozzles it is sprayed up

into a spray chamber. As the wax is sprayed up, most of it forms spherical particles that descend

onto a perforated plate. Air is forced through the holes of the perforated plate causing the wax

particles to hover in a layer above the perforated plate. As the particles hover, they are

continuously moving and being cooled by air, which is being cooled itself in an exchanger by a

chilled water system. A blower forces this air through a cooler into an air box with the

perforated plate on top. After going through the perforated plate, the forced air continues

upward, also cooling and slowing down the descending wax particles. Very small wax dust

particles that do not agglomerate onto the larger spherical particles rise to the top of the spray

chamber. At the top of the spray chamber, the air is sucked through a cotton cloth by a fan with

an adjustable shutter, which regulates the air velocity in the spray chamber. As the air goes

through the cotton cloth, wax dust is collected and the filtered air is either released through

shutters in the ductwork or recirculated through the air cooler. The device in which the fluidized

bed and air separation system are contained is called a granulator. The wax particles exit the

granulator by overflowing a dam above the perforated plate. A pneumatic conveyor moves the

particles to a large hopper that feeds a standard bagger.

The Mini-Prill process and the Prill Tower operation are both currently active, but MP emissions

are so slight as to be considered an insignificant activity. The production limit set for the tower

satisfies compliance requirements for both activities.

SUPPORT OPERATIONS

Support operations at the facility include utilities, packaging and shipping (including wax

prilling), wastewater collection and treatment, other maintenance activities, and a staging area

for oil well field treatment activities.

Utilities

The plant operates three boilers to generate steam used in the production areas. Boilers #1 and

#2 have maximum design firing rates of 72.2 MMBTUH and Boiler #3 has a maximum design

firing rate of 52.5 MMBTUH. The primary fuel for the boilers is pipeline grade natural gas.

Boilers #1 and #2 are also capable of burning No. 2 fuel oil, but are limited to 480,000 gallons

(total in both boilers) each calendar year. Oil use is intended for periods of gas curtailment. Co-

products may be used as fuel, as might other materials, if approved by DEQ. A discussion of

alternate fuels is found in the following Emissions section and at other appropriate locations in

this Memorandum. Other utilities described at this point in the application have been moved to

the Insignificant Activities listed at the end of Section V below.


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III. EQUIPMENT

There are many process vessels in this facility, but only those vessels capable of emitting to the

atmosphere through a vent or control device are listed.

EUG 1 Polywax Units (EP A & B)

Point Service Capacity Const Date

C-1005 Reaction Initiator Tank & Weigh Cell 10,000 gal 1970


C-1002 Carrier Solvent Storage Tank 10,000 gal 1970

E-4351 Oxidation Vessel Condenser (Plant A) N/A 1993

E-4350 Final Vent Condenser (Plant A) N/A 1993

E-4310 Final Vent Condenser (Plant B) N/A 1989

F-0000 Fugitives (Plants A & B) N/A 1989

Fugitives include storage tanks, wastewater basin and lagoons, as well as piping, flanges, etc.

EUG 2 Prilling Tower

CYVENT Buffalo Type L-39 1975

Note that the mini-prill equipment is treated as Insignificant.

EUG 3 Boilers

Point Make/Model Serial # Capacity Const Date

BLR1 Trane/Coen 10837 72.2 MMBTUH 1978



EUG 4 Resin Unit

Point Service Const Date

E-6010 Condenser vent 2004

E-6026A Co-product storage tank condenser vent 1989

E-6026B Co-product storage tank condenser vent 2004

E-6027 Co-product storage tank condenser vent 2004


EUG 5 Oxidation Unit


V-6101 Catalytic oxidizer exhaust 1999

EUG ALL Facility Wide

This EUG is established to consider all rules and regulations that apply to the entire facility.


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The following table shows pertinent information about each of the stacks. Note that all flow and

temperature data reflect maximum conditions. For instance, vents flow only under certain

pressure conditions and the point identified as E-4351 has flow only when the polymer oxidizer

is processing material.

STACK PARAMETERS

Height Diameter Flow Temperature

Point (Feet) (Inches) (ACFM) ( F)

C-1005* 0 1 240 Ambient

C-3020* 0 1 240 Ambient

C-1002 22 4 25 Ambient

E-4351 48 2 116 100

E-4350 43 3 116 100

E-4310 59 6 66 100

CYVENT 28 47 80,000 100

BLR1 30 42 7,392 290

BLR2 30 42 8,477 290

BLR3 30 36 5,207 270

E-6010 22 2 15 70

E-6026A 18 2 5 70

E-6026B 18 2 5 70

E-6027 19 2 5 70

E-6028 16 2 15 70

V-6101 58 18 4,000 1000

G-6303 39 10 2,500 120

AAM -0- 4 105 100 * Emissions from tank C-1005 flow through a seal pot (D-1002) and are emitted

there. Similarly, emissions from C-3020 actually vent through D-3022.

IV. AIR EMISSIONS

Copolymer Production

Calculation of emissions from the various units involved in producing the synthetic waxes

require the use of proprietary data that the permittee requests be kept confidential. The process

used by permittee is in the public domain, but stating actual amounts of solvent and raw

materials used could reveal the specific techniques used. Only a description of the calculation

technique will be presented in this public document. The actual calculations may be found in the

confidential permit application package and will be required under a Specific Condition of the

permit for compliance demonstrations.

Emissions of solvent to atmosphere are based on material balance. The conservatively high

assumption is that the difference between purchases of solvent and all known outputs is assumed

to represent emissions. Following is a list of outputs.

Synthetic waxes have been analyzed to determine the amount of solvent present. This

amount is multiplied by the quantity of product manufactured.


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Wastes injected at the disposal well are analyzed for solvent content in ppm. A simple

calculation yields the total amount of solvent disposed.

Some material is also shipped off-site and is considered by the permittee to be a co-

product. This material is analyzed for solvent content per barrel. Solvent disposed is the

sum of solvent content of each barrel.

Other waste solvent is collected in drums, analyzed for solvent content, and then shipped

off-site for disposal.

Emissions of raw materials are also based on material balance. Since ethylene is the principal

raw material, the calculation process analyzes the other components first. Calculating the ratio

of all waste (which may be off-spec product or material washed out of reactors) solids to total

production forms an approximation of solid losses. This ratio is assumed to apply equally to

each raw material. Each propylene co-polymer manufactured has a known theoretical content of

propylene. Total quantity of each propylene co-polymer is multiplied by this theoretical value to

generate the total amount of propylene actually present. This number is then multiplied by the

solid loss ratio discussed earlier. Both numbers are subtracted from the quantity of propylene

consumed and this result represents emissions. The process performed for propylene is

duplicated for hexene and the stage is set for calculating ethylene emissions.

Ethylene emissions are considered to be the difference between total consumption of raw

materials (ethylene, propylene and hexene) and the sum of total production, propylene and

hexene emissions, and solid losses. Calculation of propylene and hexene emissions has been

described. Solid losses include solids accumulating in the “1017 Pit,” wax picked up from the

ground, spilled, leaked, or recovered in any other way, and solids collected in the weir section of

the 1017 Pit. These various solids have ethylene content estimated by using the ratio of

propylene co-polymers manufactured combined with estimates of their rate of accumulation.

Permittee has requested a Plantwide Applicability Limit (PAL) of 550 TPY for VOC, which

would include, but is not limited to, toluene, ethylene, propylene and hexene. Specific

Conditions #1 and #4 shall be used to demonstrate compliance with the PAL.

Prilling Tower

There are no emissions of VOC from this source. Particulate emissions are calculated based on

material balance and assume a conservatively low cyclone collection efficiency of 91%. These

assumptions allow the calculation of an emission factor of 2.50 pounds of PM10 per ton of liquid

wax throughput. Maximum production is 3.45 TPH.

3.45 TPH 2.50 lbs/ton = 8.63 lbs/hr or 37.78 TPY

Mini-Prill Process

The MP process does not use cyclones for product recovery, as is the case with the tower

operation, and the fabric filters are much more efficient at product recovery. Assuming the filters

to be at least 99.9% efficient and using the engineering calculations for the tower operation yields

an estimated rate 0.42 TPY. Air from the unit is filtered and emissions are expected to be below

the significant activity threshold of 5 TPY. Sufficient recordkeeping is required to demonstrate

that it remains an Insignificant Activity.


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Boilers

All emission factors are taken from AP-42. Tables 1.4-1 & 2 (3/98) are used for natural gas and

Tables 1.3-1, 2 & 3 (9/98) are used for #2 fuel oil. Filterable and condensable PM factors are

combined. Heat content of natural gas is assumed to be 1,050 BTU/CF, the firing rate of oil is the

manufacturer’s specification of 480 gallons per hour, and #2 sulfur content is taken to be 0.5% by

weight. The original Part 70 permit assumed that #2 use would not exceed combined use of 1,000

hours for all boilers. The facility wants the ability to use the total quantity of liquid fuel used in

this analysis, or 480,000 gallons per year, noting that some of the operating conditions may be at

less than full load. For that reason, the third table following shows “total” boiler emissions. It is

constructed by taking the highest value from each table, and combining results to create a table

representing maximum values for each pollutant’s emissions. For example, the highest lb/hr value

for NOX comes when burning liquid fuel, so the “total” table shows 9.60 lbs/hr 2 for Units 1&2

plus 5.00 lbs/hr for Unit 3, or 24.2 lbs/hr. The TPY figure for NOX Unit 1 and/or 2 is calculated by

taking 1,000 hours (combined) on liquid fuel, and then assuming continuous operations for both

units less 1,000 hours on NG, plus continuous operation of Unit 3 on NG. Thus,

(9.70 1,000) + (6.88 {(8,760 2) – 1,000}) + (5.00 8,760) = 167,058 lbs/yr = 83.6 TPY,

and similarly for the other values.

Two alternate liquid fuels may be used, and their emissions are included in the second table,

assuming two restrictions on their use. First, the alternates analyzed for this purpose are “Solvent

250” and “Solvent 125.” Solvent 250 is a co-product consisting of primarily toluene, with toluene

alkylates, synthetic wax, and water. Solvent 125 is primarily tert-butyl alcohol, with acetone and

water. These two co-products have heat content of 18,000 – 22,000 BTU per pound, which is

close to the heat content of #2 Oil. Analyses of these materials indicates that emissions will be

similar to those of #2, except that NOX is expected to be elevated by 20%. Second, the restriction

of liquid fuels to 480,000 gallons per year assures that the BTU contribution by liquid fuels is

less than 5% of the potential annual BTUs combusted. Thus, the 20% per gallon boost caused by

the alternate fuel is offset by the restriction on use, leading to a net increase of only 1%. This

approach facilitates the addition of alternate fuels to this permit, if the facility requests such ability.

BOILERS ON NATURAL GAS

Factor Emissions (1 & 2, each) Emissions (3 only)

Pollutant (Lb/MMCF) Lb/hr TPY Lb/hr TPY

PM10 7.6 0.52 2.29 0.38 1.66

NOX 100 6.88 30.12 5.00 21.90

CO 84 5.78 25.30 4.20 18.40

VOC 5.5 0.38 1.66 0.28 1.21

SO2 0.6 0.04 0.28 0.03 0.13


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BOILERS ON LIQUID FUEL

Factor Emissions

Pollutant (Lb/103 gal) Lb/hr (1 & 2, each) TPY (Both)

PM10 3.3 1.58 0.79

NOX 20 9.70 4.85

CO 5 2.40 1.20

VOC 0.20 0.10 0.05

SO2 142 S * 34.08 17.04

* S = weight percent sulfur

BOILERS - POTENTIAL TO EMIT

Pollutant Lb/hr TPY

PM10 3.54 6.77

NOX 24.2 83.6

CO 15.8 69.0

VOC 1.04 4.53

SO2 34.1 17.7

Resin Unit

There are emissions from the resin unit vacuum receiver water tank serving the four tanks in this

process. Another condenser serves the storage tank vents. The applicant has performed an

engineering study of losses in conjunction with the Texas Natural Resources Conservation

Commission (TNRCC). Approximately 3% of all material charged to the reactors is trapped in the

equipment, is flashed overhead and collected as co-products. Evaporative losses (VOC) have been

calculated at 0.25%, but have conservatively been assumed to be 1% losses for this analysis. The

chilled water vapor condensers are estimated to have 70% recovery or removal efficiency.

Although operating hours are typically estimated to be 6,240 hours per year, the following

calculations assume 8,760 hours per year.

10,400,000 lbs/yr 1% (1 – 70%) 1 ton/2,000 lbs = 15.60 TPY VOC

3,120 lbs/hr 1% (1 – 70%) = 9.36 lbs/hr VOC

Emissions from the condenser vent associated with the storage tanks are calculated based on EPA-

approved Tanks3.1 computer model and the assumed 70% efficiency of the condenser. Two tanks

are pressure vessels, 7 feet high by 6.5 feet in diameter, with capacity of 2,000 gallons each. The

third tank is a fixed cone roof tank, 15 feet high by 12 feet in diameter, with a capacity of 10,000

gallons. Combined VOC emissions from all tanks are 0.01 lbs/hr and 0.03 TPY.

Oxidation Unit

VOC-laden air emissions from the three vessels are routed through a knockout pot, and then to the

catalytic oxidizer. As in the case of the resin reactors, 3% of the material loaded is trapped in

various parts of the equipment, is flushed out, and ultimately sold as off-spec product. Also as

above, evaporative losses of 0.25% are increased to a conservatively high 1% for these

calculations. The manufacturer of the oxidizer guarantees 95% destruction efficiency, but the

applicant assumes a conservatively low value of 90% for these calculations. Although operating


13

hours are typically estimated to be 6,240 hours per year, the following calculations assume 8,760

hours per year.

6,240,000 lbs/yr 1% (1 – 90%) 1 ton/2,000 lbs = 3.12 TPY VOC

3,120 lbs/hr 1% (1 – 90%) = 3.12 lbs/hr VOC

Packaging Units

1. Spray Micronizer

Fine particles of wax are captured in a baghouse, whose capture efficiency is guaranteed by the

manufacturer at 99.99%. For a maximum production of 1,000 tons per year, emissions are

calculated based on an input of 604.8 lbs/hr or 1,008 TPY, yielding

604.8 lbs/hr (1 – 99.99%) = 0.06 lbs/hr PM or 1,008 TPY (1 – 99.99%) = 0.10 TPY PM

No significant VOC emissions are anticipated.

2. Sandvik Belt Unit

This process produces neither VOC nor PM emissions. Maximum annual capacity for this unit is

approximately 12,000 tons of product.

3. Air Attrition Unit

Fine particles of wax are sent through a cyclone with an efficiency of 90%, and are then captured

in a baghouse, whose capture efficiency is guaranteed at 99.99%. For a maximum production of

50 tons per year, emissions are calculated based on an input of 20.2 lbs/hr or 50.5 TPY, yielding

20.2 lbs/hr (1 – 90%) (1 – 99.99%) = 0.0002 lbs/hr PM

50.5 TPY (1 – 90%) (1 – 99.99%) = 0.0005 TPY

No significant VOC emissions are anticipated.

Storage Tanks

Tanks have been considered as part of the emissions contemplated from the Polywax plants.

HAP emissions

The VOC emissions listed in the Resin and Oxidation Units above have been speciated into

component chemicals. Since the percentages attached to each process could reveal proprietary

process information, details may be found in the confidential application packet. A summary of

this list of compounds shows that 13.7 TPY or 3.1 lbs/hr is attributable to t-butyl alcohol, CAS

#75-65-0. Although the instantaneous hourly rate is approximately 8.2 lbs/hr, such a rate cannot be

sustained through a 24-hour period. Only about 1½ TPY of the entire list are HAPs.

V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified on Part 1b of the forms in the application and

duplicated below were confirmed by the initial operating permit inspection. Records are

available which confirm the insignificance of the activities. Appropriate recordkeeping is

required for those activities indicated below with an asterisk.


14

* Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel

that are either used exclusively for emergency power generation or for peaking power service not

exceeding 500 hours/year. There is a 743-hp diesel-fueled emergency generator that is not

utilized in excess of 500 hours per year. A 200-hp diesel-fueled fire water pump is similarly

limited.

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

MMBTUH heat input (commercial natural gas). The Unicid® process includes a 1.0 MMBTUH

oil heater. Other equipment of this sort may be added in the future.

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

vehicles if fuel throughput is not more than 2,175 gallons/day (gpd), averaged over a 30-day

period. The facility has two 564-gallon gasoline storage tanks. According to a full compliance

evaluation performed May 5, 2009, the maximum monthly fuel purchase in the preceding year

was 1,871 gallons in October of 2008, well below the threshold.

* 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. Permittee

has two 564-gallon, one 1,034-gallon and one 9,800-gallon #2 fuel oil tanks. None of these

tanks is subject to NSPS or to State permitting rules, and all store liquids with vapor pressure

well below the 1.5 psia threshold. Other tanks may be added in the future.

* Non-commercial water washing operations (less than 2,250 barrels/year) and drum

crushing operations of empty barrels less than or equal to 55 gallons with less than 3% by

volume of residual material. Less than 150 drums per year are crushed.

Hazardous waste and hazardous materials drum staging areas. Up to six drums of

hazardous waste are stored at any time. Hazardous materials are staged routinely.

Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including

hazardous waste satellite (accumulation) areas. The facility has such sources and may add others

in the future.

Hand wiping and spraying of solvents from containers with less than 1-liter capacity used for spot

cleaning and/or degreasing in ozone attainment areas.

A number of sources may be considered as insignificant because their emissions are below 5

TPY and they are not subject to NSPS, NESHAP, or State rules.

a) Less than 14 laboratory hoods and vents.

b) Pyrolysis of laboratory glassware.

c) Particulate emissions from bagging units.

d) The Miniprill process.

e) The Emulsion process.

f) Microcrystalline blending.

g) Unicid® process


15

h) As noted in previous discussion, emissions from the micronizer unit are extremely low.

i) As noted in previous discussion, emissions from the air attrition unit are extremely low.

VI. 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 listed in OAC 252:100, Appendix Q. 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, Emissions 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. Emission inventories were submitted and fees paid for previous years as

required.

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 existing Part 70 operating permit, from

the Part 70 renewal application, or are 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


16

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 (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 (PM)) [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, as shown in Appendix C. 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 three boilers are subject to the requirements of this subchapter. AP-42 (7/98) Table

1.4-2 lists natural gas TPM emissions to be 7.6 lbs/MMSCF or about 0.0076 lbs/MMBTU, which

is in compliance. AP-42 (9/98) Tables 1.3-1 and 1.3-2 list #2 fuel oil TPM emissions to be 3.3

lbs/1,000 gallons or about 0.02 lbs/MMBTU, which is in compliance.

Equipment

Maximum Heat

Input

Appendix C Emission

Limit, (lbs/MMBTU)

Potential Emission

Rate, (lbs/MMBTU)

BLR1 72.2 MMBTUH 0.38 0.025 (oil)

BLR2 72.2 MMBTUH 0.38 0.025 (oil)

BLR3 52.5 MMBTUH 0.41 0.025 (oil)

Section 19-12 limits particulate emissions from emission points in an industrial process based on

process weight rate, as specified in Appendix G. As shown in the following table, all emission

points are in compliance with Subchapter 19.

Equipment Process

Rate, TPH

Appendix G Emission

Limit, lbs/hr

Potential Emission

Rate, lbs/hr

Micronizer 0.302 1.84 0.06

Air attrition 0.01 0.19 0.02

Prilling tower 3.45 9.40 8.63

Mini-prill 3.45 9.40 0.10

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

No discharge of greater than 20% opacity is allowed except for short-term occurrences that

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. Filters used to conserve product prevent most PM emissions. When

burning natural gas there is very little possibility of exceeding these standards.


17

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 originated 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 to interfere

with the maintenance of air quality standards. Under normal operating conditions, this facility has

negligible potential to violate this requirement; therefore it is not necessary to require specific

precautions to be taken.

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

Part 5 The new (constructed after July 1, 1972) equipment standard for emissions of oxides of

sulfur measured as sulfur dioxide from gas-fired fuel-burning equipment is 0.2 lbs/MMBTU heat

input, maximum three-hour average. The three boilers were installed in 1978 and are new

equipment. AP-42, Table 1.4-2 (3/98), lists natural gas SO2 emissions to be 0.6 lbs/MMft3 or

about 0.0006 lbs/MMBTU, which is in compliance. The standard for liquid fuel is 0.8

lbs/MMBTU, and the AP-42 factor for #2 fuel oil equates to approximately 0.48 lbs/MMBTU,

which is also in compliance.

OAC 252:100-33 (Nitrogen Oxides) [Applicable]

This subchapter limits new (constructed after July 1, 1972) gas-fired or liquid-fired fuel-burning

equipment with rated heat input greater than or equal to 50 MMBTUH to emissions of 0.20 or

0.30 lbs of NOx per MMBTU, three-hour average, respectively. The three boilers were installed

in 1978 and are new sources. Their rated heat inputs of 72.2, 72.2 and 52.5 MMBTUH all

exceed the 50 MMBTUH threshold and they are affected sources. The AP-42 factor for natural

gas is approximately 0.1 lb/MMBTU and the factor for #2 fuel oil equates to approximately 0.13

lbs/MMBTU, both of which are in compliance.

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

None of the following affected processes are located at this facility: gray iron cupola, 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 vapor pressures of

diesel, kerosene, and toluene are all less than 1.5 psia; therefore, Part 3 does not apply to the

storage of these liquids. The two 564-gallon gasoline tanks are properly equipped.

Part 5 limits the VOC content of coating used in coating lines or operations. This facility will not

normally conduct coating or painting operations except for routine maintenance of the facility

and equipment, which is not an affected operation.

Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize

emissions. Temperature and available air must be sufficient to provide essentially complete

combustion.


18

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 required 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 Quality 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 Organic Materials Nonattainment not in control area

OAC 252:100-47 Landfills not in source category


19

VII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Applicable]

This facility is a PSD-major stationary source and future increases of any emissions above the

significance level for each pollutant will require PSD review.

NSPS, 40 CFR Part 60 [Not Applicable]

Subpart Dc (Small Industrial-Commercial-Institutional Steam Generating Units) affects steam-

generating units constructed after June 9, 1989, and with capacity between 10 and 100 MMBTUH.

The three existing boilers in EUG 3 were all constructed before the effective date, and have not

been modified or reconstructed.

Subpart Kb (VOL Storage Vessels) regulates volatile organic liquid storage tanks larger than

75m3 capacity for which construction, modification or reconstruction occurred after July 23,

1984. The facility has no tanks above the threshold capacity, so there are no affected facilities.

Subpart VV (VOC Leaks from SOCMI) affects synthetic organic chemical manufacturing

operations that commenced construction, reconstruction, or modification after January 5, 1981

and on or before November 7, 2006. The facility does not produce, as intermediates or final

products, any of the chemicals listed in 40 CFR 60.489, and is not an affected source.

Subpart VVa (VOC Leaks from SOCMI) affects synthetic organic chemical manufacturing

operations that commenced construction, reconstruction, or modification after November 7,

2006. The facility does not produce, as intermediates or final products, any of the chemicals

listed in 40 CFR 60.489, and is not an affected source.

Subpart DDD (VOC from Polymer Manufacturing) affects facilities involved in the manufacture

of polypropylene, polyethylene, polystyrene, or ethylene terephthalate. Effective dates depend

on the material and process being used, however standards for process equipment apply to

continuous processes only, per 40 CFR 60.560(a)(1). This facility manufactures polyethylene as

part of the ethylene polywax production process, but it does so in a batch process, so process

equipment is not affected by Subpart DDD. Requirements for leak detection and repair (LDAR)

identified in §560(a)(4) are not restricted to continuous operations and may be applicable. The

facility is also subject to NESHAP Subpart FFFF, which addresses “overlap” conditions with

other federal rules. In particular, 40 CFR 63.2535(h) allows the facility to elect to demonstrate

compliance with NSPS Subpart DDD by complying with the MACT, including the specific

language of §2535(h).

Subpart III (VOC from SOCMI Air Oxidation Processes) affects facilities that produce any of the

chemicals listed in §60.617 as a product, co-product, or intermediate and that were constructed,

modified, or reconstructed after October 31, 1983. The facility does not produce any of the

listed chemicals and is not an affected source.

Subpart NNN (VOC from SOCMI Distillation Units) affects distillation units in the synthetic

organic chemical manufacturing industry that commenced construction, reconstruction, or

modification after December 30, 1983. The facility does not produce any of the chemicals listed

in §60.667 and is not an affected source.

Subpart IIII, Stationary Compression Ignition Internal Combustion Engines, affects stationary

compression ignition (CI) internal combustion engines (ICE) based on power and displacement

ratings, depending on date of construction, beginning with those constructed after July 11, 2005.

The fire pump engine and the emergency generator identified as insignificant activities were

constructed before July 11. 2005 and are not affected facilities.


20

NESHAP, 40 CFR Part 61 [Not Applicable]

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

oven emissions, mercury, radionuclides, or vinyl chloride, except for a trace of benzene.

Subpart J (Equipment Leaks of Benzene) This facility is not an affected source because none of

the equipment is in benzene service, as that term is defined in 40 CFR 61.111.

Subpart V (Equipment Leaks of Volatile HAPs) This facility is not an affected source because

none of the equipment is in VHAP service, as that term is defined in 40 CFR 61.241.

NESHAP, 40 CFR Part 63 [Only FFFF is Applicable]

Subpart F (SOCMI) applies to chemical manufacturing process units that meet the applicability

criteria of §63.100(b)(1)(i) or (1)(ii) and are located at major sources of HAP emissions. The

facility does not manufacture as a primary product any of the chemicals listed in Table 1 of the

subpart, nor does it use as a reactant or manufacture as a product or co-product any of the

chemicals listed in Table 2 of the subpart. Therefore, the facility is not an affected source.

Subpart G (SOCMI) Not an affected source per 40 CFR 63.100 and 110.

Subpart H (SOCMI) Not an affected source per 40 CFR 63.100 and 160.

Subpart I (SOCMI) Not an affected source per 40 CFR 63.100 and 190.

Subpart U (Polymers & Resins, Part I) affects new and existing elastomer product process units

located at major sources of HAP emissions. The facility does not own or operate any such units

and is not an affected source.

Subpart W (Polymers & Resins, Part II) affects existing, new, and reconstructed manufacturers

of wet strength resins located at major sources of HAP emissions. The facility does not

manufacture basic liquid epoxy resins or wet strength resins and is not an affected source.

Subpart EEE (Hazardous Waste Combustors) affects hazardous waste combustors, inter alia, at

major and area sources of HAP emissions. The term “hazardous waste combustor” has a broad

definition, including many combustion devices physically capable of burning hazardous waste.

As noted previously, the facility uses Solvent 125 and Solvent 250 as alternative fuels. A Notice

of Violation was issued concerning this matter, focusing on the status of the solvents as product

or hazardous waste. The Land Protection Division reviewed the matter, and found both materials

to be product. The determination was issued December 14, 2010. Therefore, the solvents are not

hazardous wastes and the facility is not affected under Subpart EEE.

Subpart JJJ (Polymers & Resins, Part III & IV) affects new and existing thermoplastic product

process units located at major sources of HAP emissions. The facility does not own or operate

any such units and is not an affected source.

Subpart FFFF (Miscellaneous Organic Chemical Manufacturing, or MON) affects facilities that

manufacture miscellaneous organic chemicals and that are located at major sources of HAP, as

that is defined in 40 CFR 63.2. Baker Petrolite is a major source of HAP and is an affected

facility per 40 CFR 63.2435(b)(1)(i). This MACT applies to MCPUs, or miscellaneous organic

chemical manufacturing process units, which include assigned storage tanks, product transfer

racks, open systems conveying wastewater-like material, and components, such as valves,

connectors, etc. Work practice standards and limits are described for continuous process vents,

batch process vents, storage tanks, transfer racks, equipment leaks, and wastewater streams, inter

alia. Various monitoring methods are allowed, including CEMs and parametric monitoring.

Standards generally include percentage reductions, requiring performance testing to establish

baselines and reduction efficiencies, but design evaluations may also be acceptable. Since the


21

facility is an existing source, compliance with the MACT standards was required by May 10,

2008.

Equipment leak standards can be met by utilizing the standards described in either 40 CFR 65

Subpart F or 40 CFR 63 Subpart UU. The facility has chosen Subpart UU and has established a

leak detection and repair (LDAR) program. All other sources that might require control under

the subpart have been reviewed. No tanks, racks, or open conveying systems are affected. All

process vents were determined to be Group 2 vents, requiring no control, with the exception of

Unilin System vent EP-E-4351 in EUG 1. This Group 1 vent was already controlled by a

condenser, but engineering studies indicated that emissions were not sufficiently controlled.

Subpart FFFF requires 95% control, so an additional condenser was added in series. Design

criteria require that the exhaust temperature of this second condenser not exceed 48°F. An initial

compliance report documenting all of these activities was submitted October 7, 2008.

Subpart ZZZZ, (Reciprocating Internal Combustion Engines (RICE)) affects new and existing

RICE located at major and area sources of HAP emissions. The fire pump engine and the

emergency generator engine are affected facilities. The 743-hp generator engine and the 200-hp

fire pump engine were constructed before December 19, 2002, and are existing sources.

According to 40 CFR 63.6590(b)(3), “an existing emergency stationary RICE, does not have to

meet the requirements of this subpart and of subpart A of this part. No initial notification is

necessary.”

CAM, 40 CFR Part 64 [Not Applicable]

This part applies to any pollutant-specific emission unit at a major source that is required to

obtain an operating permit, for any application for an initial operating permit submitted after

April 18, 1998, that addresses “large emissions units,” or any application that addresses “large

emissions units” as a significant modification to an operating permit, or for any application for

renewal of an operating 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 or 10/25 TPY of a HAP

The particulate control devices in use are considered integral pieces of production equipment

since they return collected particles to the production process streams. Therefore, CAM does not

apply. In addition, the requirements of MACT FFFF, effective for this facility after May 10,

2008, satisfy CAM.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Applicable]

The facility does process or store more than the threshold quantity of ethylene and propylene

(Section 112r of the Clean Air Act 1990 Amendments). A Risk Management Plan (RMP) was

submitted to EPA Region 6 on June 18, 1999, and deemed to be complete on June 24, 1999. An

updated RMP was submitted to Region 6 on June 9, 2009. More information on this federal

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


22

Stratospheric Ozone Protection, 40 CFR Part 82 [Not Applicable]

This facility does not produce, consume, recycle, import, or export any controlled substances or

controlled products as defined in this part, nor does this facility perform service on motor (fleet)

vehicles, which involves ozone-depleting substances. Therefore, as currently operated, this

facility is not subject to these requirements. To the extent that the facility has air-conditioning

units that apply, the permit requires compliance with Part 82.

VIII. COMPLIANCE

Inspection

Full compliance evaluations are performed at this facility, usually annually, with the most recent

having been performed by David Youngman, ROAT Environmental Specialist, on May 5, 2009.

The inspection found that all equipment was constructed as described in the TV renewal permit.

All emissions and recordkeeping were in compliance with limits or standards set in the permits.

Only equipment for insignificant activities has been added since the latest inspection, so an

additional compliance evaluation for this permit modification is not necessary. Records for

insignificant activities confirmed their status.

Tier Classification and Public Review

This application has been classified as Tier II based on the request for renewal of a Title V

Operating permit for an existing major source. Public notice of filing of this application was

published in the Bigheart Times on January 14, 2010. The application was available for review

at the Ethel Briggs Memorial Library, 410 S. 5th

Street in Barnsdall, OK, and at the AQD office

in Oklahoma City. Notice of the 30-day public review opportunity for the draft permit will be

published in a newspaper of general circulation in Osage County. Information on all permit

actions is available for review by the public in the Air Quality section of the DEQ Web page:

www.deq.state.ok.us/.

The facility is within 50 miles of the Oklahoma border with the state of Kansas. That state will

be notified of the draft permit. The applicant 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.

Fee Paid

Renewal of a Title V operating permit fee of $1,000.

IX. SUMMARY

This facility was constructed as described in the application. There are no active Air Quality

compliance or enforcement issues that would affect the issuance of this permit. Issuance of the

renewal Title V operating permit is recommended, contingent upon public comment and EPA

review.

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

DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Baker Petrolite Polymers Division Permit No. 2010-002-TVR2

Synthetic Wax Manufacturing Facility

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

Quality on January 8, 2010. The Evaluation Memorandum dated December 20, 2010, 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. Emission points and authorized emissions are tabulated as follows. [OAC 252:100-8-6(a)]

EUG 1 Polywax Units (EP A & B)

Point Service Capacity Const Date



C-1002 Carrier Solvent Storage Tank 9,800 gal 1970

C-1003 Dry Solvent Storage Tank 2,000 gal 1970

C-1029 Dry Solvent Storage Tank 5,000 gal 2009

C-4303 Solvent 250 Storage Tank 6,800 gal 1987



E-4351 Oxidation Vessel Condenser (Plant A) N/A 1993

E-4350 Final Vent Condenser (Plant A) N/A 1993

E-4310 Final Vent Condenser (Plant B) N/A 1989

C-4120,C-4160 Wastewater Vessels N/A 1987

Solvent 125 Transfer Rack N/A 1999

F-0000 *Fugitives (Plants A & B) N/A 1989

*Fugitives include storage tanks, wastewater basin and lagoons, as well as piping,

flanges, etc.

Various items in the preceding table are subject to 40 CFR 63 Subpart FFFF.

a) C-1002, C-1003, C-4303, C-4304, and C-433 are existing Group 2 storage tanks, C-1029

is a new Group 2 storage tank, E-4351 is a Group 1 vent condenser, E-4350 and E-4310

are Group 2 vent condensers, C-4120 and C-4169 are Group 2 wastewater vessels, and

Solvent 125 is a Group 2 transfer rack.

b) Group 2 items must maintain sufficient records to demonstrate that they are not eligible

for Group 1.

c) The outlet temperature of E-4351 shall be monitored continuously. The daily average

recorded temperature shall not exceed 48°F.

SPECIFIC CONDITIONS 2010-002-TVR2 DRAFT

2

d) Fugitives are subject to leak detection and repair (LDAR) monitoring, Permittee has

elected to use the standards of 40 CFR 63 Subpart UU to demonstrate compliance, as

allowed by 40 CFR 63.2480(a).

e) Generic statements concerning FFFF compliance are listed in Specific Condition #8.

EUG 2 Prilling Operation

The only point is the cyclone vent, CYVENT, constructed in 1975. This point is for the prilling

tower.

Unit Source Pollutant Emissions

Lb/hr TPY

Prilling tower Cyclone PM 8.63 37.78

EUG 3 Boilers

Point Make/Model Serial Number Capacity Const Date




The following table authorizes emissions for all three units based on continuous operation,

allowing the use of liquid fuel in units #1 and #2 for a combined annual total of 480,000 gallons.

Liquid fuels authorized include #2 fuel oil and co-products known as Solvent 250 and Solvent

125. Compliance with the limits shall be demonstrated by monthly and 12-month rolling

calculations of emissions, based on current AP-42 factors. Any additional alternate fuels

proposed by the facility and approved by DEQ shall adhere to these limits.

Pollutant Lb/hr TPY

PM10 3.54 6.77

NOX 24.2 83.6

CO 15.8 69.0

VOC 1.04 4.53

SO2 34.1 17.7

EUG 4 Resin Unit


E-6010 Condenser vent 2004

E-6026A Co-product storage tank condenser vent 1989

E-6026B Co-product storage tank condenser vent 2004



Cold Flow

Decanter

Wastewater Vessel 2004

FUG Fugitives 2004


3

Various items in the preceding table are subject to 40 CFR 63 Subpart FFFF.

a) C-6026A, C-6026B, C-6027, C-6028 are existing Group 2 storage tanks, E-6010, E-

6026A, E-6026B, E-6027, and E-6028 are Group 2 vent condensers, and Cold Flow

Decanter is a Group 2 wastewater vessel.

b) Group 2 items must maintain sufficient records to demonstrate that they are not eligible

for Group 1.

c) Fugitives are subject to leak detection and repair (LDAR) monitoring, Permittee has



d) Generic statements concerning FFFF compliance are listed in Specific Condition #8.

EUG 5 Oxidation Unit


V-6101 Catalytic oxidizer exhaust 1999

FUG Fugitives 1999

All items in the preceding table are subject to 40 CFR 63 Subpart FFFF.

a) V-6101 is a Group 2 batch process vent and must maintain sufficient records to

demonstrate that it is not eligible for Group 1.

b) Fugitives are subject to leak detection and repair (LDAR) monitoring, Permittee has



c) Generic statements concerning FFFF compliance are listed in Specific Condition #8.

EUG 6 Packaging Units

All points originally listed under this EUG are Insignificant activities, so this EUG is currently

empty.

A Plantwide Applicability Limit (PAL) of 550 TPY (12-month rolling) of VOC applies to all

sources in the facility, regardless of their having been specifically named elsewhere in this Specific

Condition. Toluene, ethylene, propylene, hexene, and tert-butyl alcohol are included as VOC for

the purposes of determining compliance with this limit.

Toluene may be emitted in any amount less than or equal to 550 TPY, providing that the PAL of

550 TPY of VOC is not exceeded.

2. Compliance with the PM limits established in Specific Condition 1 (SC #1) shall be

demonstrated by production, with limits of 5,000 TPY of on-spec product from the resin unit

(excluding the emulsions process), 3,120 TPY of on-spec product from the oxidation unit

(excluding microcrystalline blending), and throughput of 30,222 TPY at the prilling tower. No

production limit is set for the Micronizer, the Air Attrition Unit, or the Sandvik belt unit, because

they have insignificant emissions. Emulsions produce negligible VOC and PM emissions, and

shall not be considered in any of these throughput limits. Additionally, when the prilling tower is


4

taken out of service, its throughput limit will be discontinued, because the mini-prill replacement

operation is an insignificant activity. [OAC 252:100-8-6(a)]

3. Cyclones controlling emissions from the prilling tower may be replaced only by devices of

equal or greater efficiency. The nitrogen blanket used in controlling vapor emissions from various

equipment on the Polywax units may be replaced only by a method of equal or greater efficiency.

[OAC 252:100-8-6(a)(1)]

4. Compliance with the VOC limits established in SC #1 shall be demonstrated by material

balance calculations as performed in the confidential permit application package, mirrored in the

annual emission inventory (Turnaround Document) analysis, and described as follows.

Emissions of solvent to atmosphere are based on material balance, which is the difference

between purchases of solvent and all measurable outputs. These outputs include solvent bound

in the synthetic wax product, solvent content of wastes injected underground at the disposal well,

and solvent contained in waste or co-product shipped off-site.

In addition, volatile HAP emissions from units affected by MACT FFFF (see SC #8 below) shall

be calculated using the procedures specified in 40 CFR 63.127(d)(2).

[OAC 252:100-43 and 100-5, 40 CFR 63 Subpart FFFF]

5. Emissions of raw materials are also based on material balance. Propylene and hexene

emissions shall be calculated by taking the difference between consumption of each material and

the amount of each contained in measurable outputs. One output is the theoretical amount of

propylene or hexene included in the various products. Another is the proportion of each included

in waste, such as off-spec product or material flushed out of production lines. Ethylene

emissions are considered to be the difference between total consumption of raw materials

(ethylene, propylene and hexene) and the sum of total production, propylene and hexene

emissions, and solid losses. Additional outputs considered in this calculation include solids

accumulating in the “1017 Pit,” wax picked up from the ground, spilled, leaked, or recovered in

any way, and solids collected in the weir section of the 1017 Pit. [OAC 252:100-43]

6. All pollution control equipment shall be maintained in proper working order per the

manufacturers’ specifications. Inlet temperature set point of the catalytic oxidizer shall be

maintained at or above 600 F and the process shall be shut down if the actual temperature drops

below 550 F when oxidation is occurring. The catalyst shall be sampled and tested at intervals no

longer than three years. Temperature records shall be maintained on circular or strip charts.

[OAC 252:100-43, 40 CFR 63 Subpart FFFF]

7. The permittee shall use only commercial-quality natural gas in boilers #1, #2, and #3, and/or

liquid fuels in boilers #1 and #2. Liquid fuels include #2 fuel oil and co-products identified as

Solvent 250 and Solvent 125. Sulfur content of the oil shall not exceed 0.5% by weight.

Consumption of liquid fuels shall not exceed 480,000 gallons per year. Alternate liquid fuels may

be approved by DEQ upon submittal of information adequate to demonstrate that none of the limits

set in SC #1 will be breached through use of the new fuel and that no new pollutants will be

emitted. [OAC 252:100-31]


5

8. The facility is subject to federal NESHAP for Miscellaneous Organic Chemical Manufacturing

(FFFF), and shall comply with the following requirements. [40 CFR 63, Subpart FFFF]

§63.2430 Purpose of this subpart

§63.2435 Am I subject to the requirements in this subpart?

§63.2440 What parts of my plant does this subpart cover?

§63.2445 Compliance dates

§63.2450 General compliance requirements

§63.2455, 2460,

2465, 2470, 2475,

2480, 2485, & 2490

Requirements for: continuous process vents; batch process

vents; process vents that emit hydrogen halide and halogen

HAP or HAP metals; storage tanks; transfer racks; equipment

leaks; wastewater streams and liquid streams in open systems

within an MCPU; heat exchange systems.

§63.2495, 2500, & 2505 Compliance with: the pollution prevention standard;

emissions averaging; the alternative standard.

§63.2515, 2520, & 2525 Notifications, reports, and recordkeeping

§63.2535 Overlap options

§63.2540 General Provisions

§63.2545 Implementation and enforcement

§63.2550 Definitions

Appendices Tables 1 - 12

9. The following records shall be maintained on-site. All such records shall be made available

to regulatory personnel upon request. These records shall be maintained for a period of at least

five years after the time they are made. [OAC 252:100-43]

a) Production records for the Polywax, resin, oxidation, micronizer and air attrition units

(monthly and 12-month rolling total)

b) Quantities of raw materials used (monthly and 12-month rolling total)

c) Emission calculations as described in SC #4

d) Pollution control equipment maintenance records required by SC #6

e) Boiler fuel use, including natural gas and each liquid fuel (monthly and 12-month rolling

total)

f) Sulfur content of #2 fuel oil (each delivery or as burned)

g) Data and analyses submitted for additional alternate liquid fuels, per SC #7.

h) LDAR records required by 40 CFR 63 Subpart FFFF, per SC #8.

i) Records of exhaust temperature for the second condenser (EP-E-4351) in the Unilin

process at MCPU-1, as required by 40 CFR 63 Subpart FFFF, per SC #8.

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=8f6b2d9e7a4f787c3a3f05ed38d5cc99&rgn=div8&view=text&node=40:12.0.1.1.1.13.251.1&idno=40












http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=8f6b2d9e7a4f787c3a3f05ed38d5cc99&rgn=div9&view=text&node=40:12.0.1.1.1.13.257.24.96&idno=40


6

10. The following records shall be maintained on-site to verify insignificant activities.

[OAC 252:100-43]

a) Throughput for fuel storage/dispensing equipment operated solely for facility owned

vehicles, if throughput is less than 2,175 gallons per day, averaged over a 30-day period.

b) Records of capacity of all storage tanks with a capacity of 39,894 gallons or less storing a

fluid with a true vapor pressure less than 1.5 psia, and for each delivery of fluid, the type

and quantity.

c) Hours of operation for each stationary reciprocating engine burning natural gas, gasoline,

aircraft fuels, or oil, used for emergency power generation less than 500 hours per year.

d) Gallons of coatings, thinners and clean-up solvents used (annual)

e) Amount of cold flow improver product(s) manufactured and the associated amount of

Solvent 14 used (monthly)

f) Records sufficient to demonstrate the continued insignificance of any other activity,

including, but not necessarily limited to, the micronizer, mini-prill, and air attrition units.

11. No later than 30 days after each anniversary date of the issuance of the original Title V

permit (December 3, 1999), the permittee shall submit to Air Quality Division of DEQ, with a

copy to the US EPA, Region 6, certification of compliance with the terms and conditions of this

permit. [OAC 252:100-8-6 (c)(5)(A) & (D)]

12. The Permit Shield (Standard Conditions, Section VI) is extended to the following

requirements that have been determined to be inapplicable to this facility.

[OAC 252:100-8-6(d)(2)]

OAC 252:100-7 Permits for Minor Facilities not in source category

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 Organic Materials Nonattainment not in control area

OAC 252:100-47 Landfills not in source category

13. This permit supersedes all previous air quality permits for this facility, which are null and

void.

TITLE V (PART 70) PERMIT TO OPERATE / CONSTRUCT

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)]


3

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)]


4

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)]


5

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,


6

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]


7

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)]


8

(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


9

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.


10

(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


11

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


12

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]

PERMIT


STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2010-002-TVR2

Baker Petrolite Corporation,

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

a synthetic wax manufacturing facility at 820 Birch Lake Road, Barnsdall, Osage County,

OK,

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

This permit shall expire five years from the date of issuance.

_________________________________

Chief Engineer, Air Quality Division Date

Guido Hagedorn, Plant Director Permit Number: 2010-002-TVR2

Baker Petrolite Corporation Permit Writer: Herb Neumann

P.O. Box 669 Date: January 13, 2010

Barnsdall, OK 74002

SUBJECT: Facility: Barnsdall Plant

Location: 820 Birch Lake Road, Barnsdall, OK

Dear Mr. Hagedorn:

Air Quality Division has completed the initial review of your permit application referenced

above. This application has been determined to be a Tier II. In accordance with 27A O.S. § 2-

14-302 and OAC 252:004-7-13, the enclosed draft permit is now ready for public review. The

requirements for public review include the following steps that you must accomplish.

1. Publish at least one legal notice (one day) in at least one newspaper of general circulation

within the county where the facility is located. (Instructions enclosed)

2. Provide for public review (for a period of 30 days following the date of the newspaper

announcement) a copy of this draft permit and a copy of the application at a convenient public

location within the county of the facility. Facility offices are not acceptable locations.

3. Send to AQD a copy of the proof of publication notice from Item #1 above together with any

additional comments or requested changes that you may have on the draft permit.

Thank you for your cooperation. If you have any questions, please refer to the permit number

above and contact me at (918) 293-1600.

Sincerely,

Herb Neumann


Enclosures

Guido Hagedorn, Plant Director

Baker Petrolite Corporation

P.O. Box 660

Barnsdall, OK 74002

Re: Title V Renewal Operating Permit No. 2010-002-TVR2

Synthetic Wax Manufacturing Facility

Dear Mr. Hagedorn:

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

permit is issued subject to certain standard 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 emission inventory for this facility. An

emission 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 Emission Inventory Staff at 405-702-4100.

Thank you for your cooperation. If you have any questions, please refer to the permit number

above and contact me at (918) 293-1600. Air Quality personnel are located in the Regional

Office at Tulsa, 3105 E. Skelly Drive, Suite 200, Tulsa, OK, 74105.

Sincerely,

Herb Neumann

Air Quality Division

Documents

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL · PDF fileOKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY ... separation, with the aqueous ... condenser on reactor C-6005 and an associated decanter