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DRAFT
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM October 21 2019
TO Phillip Fielder PE Chief Engineer
THROUGH Rick Groshong Environmental Manager Compliance and Enforcement
THROUGH Eric L Milligan PE Manager Engineering Section
THROUGH Amalia Talty PE New Source Permits Section
FROM David Schutz P E New Source Permits Section
SUBJECT Evaluation of Permit Application No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
Facility ID 2113
2700 South 25th West Avenue Tulsa County Tulsa OK
Lat 3612219deg Long-9602085deg
SECTION I INTRODUCTION
US Ecology Tulsa Inc (US Ecology) has requested a ldquosignificantrdquo modification of their operating
permit for a commercial treatment storage and disposal facility (SIC 4953 NAICS 562211) The
facility is currently operating under Permit No 2014-0804-TVR2 (M-1) issued May 29 2018
Effective January 2018 EPA abandoned the ldquoonce in always inrdquo policy for major source
Maximum Achievable Control Technology (MACT) standards The facility will cease to be
subject to National Emissions Standards for Hazardous Air Pollutants (NESHAP) Subparts DD
OO and PP and will cease to have potential volatile organic compound (VOC) emissions above
100 TPY and Hazardous Air Pollutants (HAP) above the 10 25 TPY thresholds thus it can also
cease to be subject to Title V permitting requirements This permitting action will make the facility
an ldquoareardquo source of HAPs and a ldquosynthetic minorrdquo source no longer subject to Title V permitting
However for taking a limit to avoid otherwise-applicable requirements the transition must be
processed using Tier II procedures
SECTION II EQUIPMENTPROCESS DESCRIPTIONS
The facility is located in an industrial area west of Tulsa Oklahoma in Tulsa County outside the
Tulsa city limits The facility was first in operation in 1996 as a RCRA (Resource Conservation
and Recovery Act) waste treatment storage and disposal facility for liquid hazardous and non-
hazardous wastes owned and operated by Perma-Fix Treatment Services Inc (PFTS) The
facility was then owned by A Clean Environment Inc (ACE) and then EQ Oklahoma
PERMIT MEMORANDUM 2019-0826-O 2 DRAFT
The facility consists of waste treatment areas storage buildingareas laboratory facilities tank
storagestagingtreatment areas container storagetreatment areas truck unloading areas pump(s)
surface piping and ancillary equipment There are offices for employees and record storage truck
parking employee parking and there is a separate laboratory for performing profile analyses on
incoming and onsite process waste streams
The facility has the ability to receive both hazardous and non-hazardous wastes containing VOC
and volatile organic hazardous air pollutants (VOHAP) In addition to wastes received from off-
site generators the facility manages waste generated onsite This includes neutralized wastewaters
and wastes that have been accumulated into larger containers Waste management onsite may
include transfer facility activities such as storage prior to shipment offsite as well as transfer station
activities such as bulking decanting etc Liquid wastes are treated to remove the hazardous waste
code filtered and disposed via the sanitary sewer
Solids were removed from both hazardous and non-hazardous wastes by means of dissolved air
flotation (DAF) clarifier units and filter presses The DAF was removed but the clarifier units
were replaced with Tanks T301 T302 and T303 which are press water receiving tanks and
secondary treatment The facility currently utilizes bag (or sock) type filters and filter presses to
remove solids from the liquids Bag filters are enclosed but filter presses are not totally enclosed
and as such cannot be controlled through a vent When ACE took ownership of the facility from
Perma-Fix they removed the filter presses except one and discontinued aeration of wastes Under
ownership of EQ the filter press was placed back into service and a second filter press was
installed The presses are located downstream of Tanks T203 and T204 which are now the
receivingaccumulation tanks downstream of treatment tanks T101 T102 T103 and T107 Roll-
off boxes collect the solids removed by the filter presses Solids both non-hazardous and de-
characterized are shipped off-site to a local solid waste landfill Listed hazardous wastes are
transported to other disposal sites that are authorized to receive the waste and may be stabilized in
containers prior to shipment
Free-phase oils are separated from wastes in a tank and then transported to an offsite
disposalrecycling facility The tank is not a separator as defined in 40 CFR Part 63 Subpart DD
Fuels blending was conducted under PFTS which entailed accumulation of organic liquids in
various containers and tanks bulking into larger containers and tanks and shipping offsite ACE
discontinued fuels blending and it was prohibited by their permit US Ecology conducts what they
refer to as ldquofuels bulkingrdquo or involving transloadingtransshipment of waste fuels or hydrocarbons
destined to become waste fuels into tanker trucks This can be done by transferring the contents
from drums or containers to larger containers or from containers to tanker trucks in either event
for shipment offsite Liquids are transferred from containers through the bung hole and then closed
upon completion of the transfer US Ecology requests that the term ldquofuels blendingrdquo not be
associated with their operations or permit on the premises that they donrsquot combine the materials to
meet specifications for waste fuels and requested that the prohibition on fuels blending be removed
from the permit Following is a description of the equipment and the processes conducted at the
facility organized by Emissions Unit Group (EUG)
PERMIT MEMORANDUM 2019-0826-O 3 DRAFT
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EUG A consists of a tank system for the accumulation storage transfer and treatment of offsite
and onsite generated RCRA wastewaters Equipment andor emissions units included in this EUG
are listed in the following table Tanks T108 and T109 have been removed from the facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Piping Transfer Pumps Connections and appurtenances
included in the TF1 tank system 1996-2007
Tanks included in the TF1 tank system 1996-2007
A waste can be designated as ldquobeneficial reuserdquo and no longer a waste when it can be used directly as a reagent or
product
The acid treatment process is basically a pH adjustment process for acidic wastewaters that carry
the hazardous characteristic of Corrosivity (EPA Waste Code D002) under Title 40 CFR Part 261
Subpart C Metal contaminants (waste codes D004 through D011) may also be removed via
precipitation Waste materials are received into the hazardous waste storage and treatment tanks
in Tank Farm 1 (TF1) including tanks T101 T102 T103 or T107 The wastes are received from
bulk tankers tote tanks and drums all of which the contents are transferred to the tanks by pump
The wastes are predominantly acidic from industries such as galvanizing facilities but wastes with
a pH greater than 7 (caustics) may also be received The acids are primarily hydrochloric acid or
sulfuric acid but may also include chromic acid nitric acid plus other inorganic and organic acids
The waste acids may also contain volatile organic chemicals in limited quantities but with
VOHAP less than 500 ppmw The EUG A treatment area includes pumps valves flanges
PERMIT MEMORANDUM 2019-0826-O 4 DRAFT
connectors and ancillary equipment (EU-A8) that may contain VOC with total VOHAP
constituents less than 500 ppmw
The neutralization treatment reaction occurs in tanks T101 T102 T103 or T107 These tanks
include top-mounted mixers Sodium hydroxide (caustic) is added to the treatment tanks causing
an exothermic reaction that causes the temperature of the mixed waste to rise from ambient
temperature up to as high as 180degF The caustic is added from the product caustic tank P001
This tank may contain virgin off-specification or beneficial reuse caustic products The reuse
caustic product may contain limited amounts of VOC andor VOHAP but less than 500 ppmw total
VOHAP (The 500 ppmw threshold for VOHAP was derived from NESHAP DD which is ceasing
to be applicable and because of the emissions accounting method which assumes 100
evaporation) After the wastes are reacted and the resulting mixture is found to have been de-
characterized of its hazardous waste characteristics the wastes are transferred to tanks T203 or
T204 for accumulation storage and subsequent filtration Waste is filtered using bag (or sock)
type filters and two filter presses Vapor emissions from tanks T101 T102 T103 and T107 are
vented to the atmosphere
The treatment process of acidic wastewaters containing metals (EPA Waste Codes D002 and
D004-D011) is similar to that for the acidic wastewaters (EPA Waste Code D002) It is basically
a pH adjustment to raise the pH to within the range of 100 to 110 where precipitation and filtering
of metals brings the water to the required standards for disposal in the public owned treatment
works (POTW) sanitary sewer
EUG B ndash Treatment of Neutralized Non-Hazardous Wastewater from EUG A
EUG B was dismantled and removed in its entirety from the facility
EUG C - Treatment of Non-Hazardous Wastewater
EUG C consists of tank systems TF4 and TF2 and filters that are used in the final step to prepare
onsite neutralized wastewaters and offsite non-hazardous wastewaters pumped directly from
tanker trucks for disposal in the POTW TF4 includes an oil separation tank T404 Equipment
andor emissions units included in this EUG are listed in the following table
EU
ID
Point
ID EU Description and Service
Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
PERMIT MEMORANDUM 2019-0826-O 5 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C21 P002 10rsquo L x 8rsquoW x 8rsquoH square 5330-gallon Flocculant addition
tank 1996
PERMIT MEMORANDUM 2019-0826-O 6 DRAFT
Wastewater is filtered through C1 a 100-micron bag filter as it is pumped into TF4 Non-oily
non-hazardous low-solids wastewater received directly from offsite sources in tank trucks or
containers is filtered through C8 a 100-micron bag filter as it is pumped directly into Tank T402
(TF4) which has an overflow line to Tank T403 Oily non-hazardous wastewater containing
insoluble oils received directly from offsite sources in tank trucks and containers are unloaded
directly into Tank T406 where oil is removed by gravity segregation Chemicals to facilitate
separation may be added Bottom water is sampled Water containing metals is pumped to TF1
Water meeting POTW standards is pumped to TF4 The separated oil is transferred to a transport
truck for transporting to an offsite disposalrecycling facility Final solids removal for
wastewaters accumulated or separated in tanks T301 T302 T303 T402 T403 or T404 (TF4)
occurs when the wastewaters are pumped through C7 a 25-micron bag filter for disposal in the
POTW These tanks are press water receiving tanks and secondary treatment and replaced the
clarifier and T201 and T202 Tank T205 can only be used to collect storm water
EUG D ndash Treatment of Containerized Waste Liquids and Solids
Equipment andor emissions units included in this EUG are listed in the following table
EU
ID
Point
ID EU Description and Service
Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
PERMIT MEMORANDUM 2019-0826-O 7 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Drummed wastes are also processed and treated at the facility Liquids from containers may be
pumped (EU-D1) into bulk containers prior to transfer to a tank at TF1 TF2 TF4 or prior to
shipment to an offsite facility
Containers of solid wastes may also be received at the facility for consolidation (EU-D2) into
larger containers (eg roll-off boxes) If required solids and liquids that have been neutralized or
decharacterized may be stabilized in EU-D3 containers roll-off boxes and the stabilization box
prior to transportation to an off-site disposal facility Solids can be treated in the drums by
solidification using a hydraulic drum mixer and an excavator similar to a backhoe with tracks
Treatment reagents include but are not limited to sodium sulfide ferrous sulfide cement kiln dust
fly ash and Portland cement to solidify and remove the hazardous characteristics of the contents
of the drums Containers are closed or covered when waste is not being added or removed from
the container Containers of liquid or solid wastes may also be temporarily stored at the facility
without repackaging prior to shipment to an offsite disposal facility
PERMIT MEMORANDUM 2019-0826-O 8 DRAFT
EUG E ndash POTW Disposal
Equipment andor emissions units included in this EUG and remaining at the facility are listed in
the following table
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
This operation has two stationary storage tanks POTW1 and POTW2 These tanks are for
wastewaters that meet the City of Tulsa - Industrial Wastewater Discharge Permit (POTW)
standards for discharge to the sanitary sewer after treatment at the facility and also for wastewater
received directly from offsite for disposal to the sewer if the material as received meets the sitersquos
discharge permit standards All wastewaters managed in this manner are tested to ensure
compliance with the permit prior to discharge into the sewer Tank POTW1 amp POTW2 will be
utilized for storm water storage No other operations for this waste treatment process are in place
at this time
SECTION III EMISSIONS
The facility has requested the following emissions limits based on an annual facility throughput of
44148 TPY of wastes
- 72 TPY VOC
- 72 TPY total HAP
- 58 TPY any one HAP
The treatment system at this facility consists of numerous tank systems (TF1 TF2 and TF4)
serving purposes of treatment (neutralization) accumulation separation temporary storage
filtering and discharge to the POTW or a tanker truck Storage tanks T101 T102 T103 and T107
are used as reactors to neutralize corrosive wastes The tanks are routinely filled with acidic wastes
at ambient temperatures and when an adequate inventory is achieved caustic is introduced to
neutralize the acid Each tankreactor has a top-mounted agitator installed to ensure complete
mixing of the reactants The shaft entrance is sealed to prevent emissions from this location The
neutralization is an exothermic reaction causing the mixture temperature to rise as high as 180deg
Fahrenheit
PERMIT MEMORANDUM 2019-0826-O 9 DRAFT
The tanks are connected by piping that provides various transferring scenarios and possibly re-
circulations between the tank systems For example one purpose of transferring wastes tofrom
tanks is to pass the wastes through filters for solids removal This is done by rolling the tanks ie
pumping wastes from one tank system into another allowing the waste to pass through in-line
filters installed in the transfer piping The tracking becomes more complex as volumes and VOC
content change to a new blend This makes the use of EPA TANKS a laborious method for
tracking emissions Note that this is not an implication that the facility is allowed to dilute
hazardous waste to meet a treatment standard A previous owner ACE committed to limiting
receipt of wastewaters containing less than 500 ppmw of VOC US Ecology agrees to the mass
balance described herein but with the exception that although VOC (not VOHAP) content may be
500 ppmw or greater the levels will be documented for emissions calculations VOHAP
concentrations are limited to less than 500 ppmw
An emissions calculation based on a VOC content of 500 ppmw assumes that 100 of all VOC in
the wastewaters ultimately evaporate as a result of physical changes that could affect the volatility
of the organics such as rolling the tanks temperature rises and agitation Based on the operations
at the facility under prevous owner ACE the maximum VOC-laden liquid waste throughput was
assumed to be the sum of the projected throughput rates of tanks P001 T101 T102 T103 and
T107 all in EUG A These tanks handle the main throughput of incoming wastewaters having
VOC andor VOHAP Immediately downstream of these tanks Tanks T203 and T204 are the
receivingaccumulation tanks Although emissions from the tanks in EUG A were controlled by
the carbon adsorber emissions from EUG B were not nor are emissions from the tanks now
receiving the treated wastes It was further assumed that the tanks did not treat or store wastes
containing VOC or VOHAP and that neither POTW1 nor POTW2 received VOC-containing
wastes Based on the rates submitted by the applicant the total liquid waste throughput would be
43589219 gallons per year Assuming an average wastewater density of 100 lbsgallon the
calculated emissions were approximately 109 tons-VOC per year Calculations using EPA
TANKS were based on a waste treatmentdisposal volume of 27000000 gallons per year emitting
269 tons per year of VOHAP with a PTE of 65 tons per year The mass balance approach would
be simpler and safer for all considering that the only data required for this calculation is incoming
waste volumes densities and VOC concentrations US Ecology has agreed to carry this method
forward with a limit of 72 TPY except that total VOC content may range higher than the VOHAP
limit provided that the facility will document the actual VOC content of the waste
FuelsHydrocarbon Bulking
The facility does bulking of liquid hydrocarbons and fuels Emissions of VOC are calculated using
Equation 1-29 AP-42 (1106) Section 7-111 The operator submitted calculations for a similar
operation at a facility in Detroit Michigan which they state is a bigger operation than the Tulsa
facility Based on an annual throughput of about 458000 gallons emissions were 1400 pounds
of VOC The equations and input parameters for calculating emissions are specified in the permit
PERMIT MEMORANDUM 2019-0826-O 10 DRAFT
Solids Bulking
The facility bulks solids materials Hazardous Non Hazardous and some Flammable Solids The
following formula is used to calculate emissions (Note VP for methanol is used)
W = Emissions (lbyr)
W = Qw X (1359) X 27315Tamb X VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3lb-mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
SECTION IV FEDERAL REGULATIONS
PSD 40 CFR Part 52 [Not Applicable]
PSD does not apply Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant and the facility is not one of the listed stationary sources with an emission
threshold of 100 TPY
NSPS 40 CFR Part 60 [Not Applicable]
Subpart Kb Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage
Vessels) for Which Construction Reconstruction or Modification Commenced After July 23
1984 This subpart does not apply to storage vessels with a capacity greater than or equal to 151
m3 (39890 US gallons) storing a liquid with a maximum true vapor pressure less than 35
kilopascals (05 psi) or with a capacity greater than or equal to 75 m3 (19813 US gallons) but less
than 151 m3 storing a liquid with a maximum true vapor pressure less than 150 kilopascals (2175
psi) There are no tanks meeting the 39890-gallon threshold The following tanks exceed the
19813-gallon threshold but will not store hydrocarbon liquids having a maximum true vapor
pressure of 150 kilopascals (2175 psi) or more Therefore there are no affected tanks at this
facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construct
Date
C2 T402 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C3 T403 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C14 T204 38000 gal (144 m3) Dish bottom and roof Wastewater 1996
E4 POTW1 25700 gal (97 m3) Flat bottom dome roof Wastewater 1996
E5 POTW2 22000 gal (83 m3) Flat bottom dome roof Wastewater 1996
PERMIT MEMORANDUM 2019-0826-O 11 DRAFT
NESHAP 40 CFR Part 61 [Not Applicable]
Subpart V National Emission Standard for Equipment Leaks (Fugitive Emission Sources) applies
to each of the following sources that are intended to operate in volatile hazardous air pollutant
(VHAP) service pumps compressors pressure relief devices sampling connection systems open-
ended valves or lines valves connectors surge control vessels bottoms receivers and control
devices or systems required by this subpart There are no affected sources having HAP
concentration equal to or greater than 10 by weight
NESHAP 40 CFR Part 63 [No Longer Applicable]
Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment
Leaks applies to pumps compressors agitators pressure relief devices sampling connection
systems open-ended valves or lines valves connectors surge control vessels bottoms receivers
instrumentation systems and control devices or closed vent systems required by this subpart that
are intended to operate in organic hazardous air pollutant service 300 hours or more during the
calendar year within a source subject to the provisions of a specific subpart in 40 CFR Part 63 that
references this subpart None of the affected sources contain or contact at least 5 percent by weight
of total organic HAP and the facility is becoming an ldquoareardquo source of HAP
Subpart DD National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations applies to any owner or operator of a plant that is a major source of
hazardous air pollutant (HAP) emissions as defined in 40 CFR sect632 having waste management
or recovery operations specified in sect63680(a)(2)(i) through (a)(2)(vi) that receive an offsite
material as specified in sectsect63680(b) The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart OO National Emission Standards for Tanks-Level 1 applies to the control of air
emissions from tanks for which another subpart of 40 CFR Parts 60 61 or 63 references the use
of this subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP
and will cease to be subject to this major source MACT
Subpart PP National Emission Standards for Containers applies to the control of air emissions
from containers for which another subpart of 40 CFR Parts 60 61 or 63 references the use of this
subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart RR National Emission Standards for Individual Drain Systems applies to the control of
air emissions from individual drain systems for which another subpart of 40 CFR Parts 60 61 or
63 references the use of this subpart for such air emission control At this time there are no transfer
systems that appear to meet the definition of an individual drain system as defined in this subpart
or in Subpart DD However as noted earlier this is contingent on the POTW not handling any
hazardous waste
Chemical Accident Prevention Provisions 40 CFR Part 68 [Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments) More information on this federal program
is available on the web page wwwepagovrmp
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 2 DRAFT
The facility consists of waste treatment areas storage buildingareas laboratory facilities tank
storagestagingtreatment areas container storagetreatment areas truck unloading areas pump(s)
surface piping and ancillary equipment There are offices for employees and record storage truck
parking employee parking and there is a separate laboratory for performing profile analyses on
incoming and onsite process waste streams
The facility has the ability to receive both hazardous and non-hazardous wastes containing VOC
and volatile organic hazardous air pollutants (VOHAP) In addition to wastes received from off-
site generators the facility manages waste generated onsite This includes neutralized wastewaters
and wastes that have been accumulated into larger containers Waste management onsite may
include transfer facility activities such as storage prior to shipment offsite as well as transfer station
activities such as bulking decanting etc Liquid wastes are treated to remove the hazardous waste
code filtered and disposed via the sanitary sewer
Solids were removed from both hazardous and non-hazardous wastes by means of dissolved air
flotation (DAF) clarifier units and filter presses The DAF was removed but the clarifier units
were replaced with Tanks T301 T302 and T303 which are press water receiving tanks and
secondary treatment The facility currently utilizes bag (or sock) type filters and filter presses to
remove solids from the liquids Bag filters are enclosed but filter presses are not totally enclosed
and as such cannot be controlled through a vent When ACE took ownership of the facility from
Perma-Fix they removed the filter presses except one and discontinued aeration of wastes Under
ownership of EQ the filter press was placed back into service and a second filter press was
installed The presses are located downstream of Tanks T203 and T204 which are now the
receivingaccumulation tanks downstream of treatment tanks T101 T102 T103 and T107 Roll-
off boxes collect the solids removed by the filter presses Solids both non-hazardous and de-
characterized are shipped off-site to a local solid waste landfill Listed hazardous wastes are
transported to other disposal sites that are authorized to receive the waste and may be stabilized in
containers prior to shipment
Free-phase oils are separated from wastes in a tank and then transported to an offsite
disposalrecycling facility The tank is not a separator as defined in 40 CFR Part 63 Subpart DD
Fuels blending was conducted under PFTS which entailed accumulation of organic liquids in
various containers and tanks bulking into larger containers and tanks and shipping offsite ACE
discontinued fuels blending and it was prohibited by their permit US Ecology conducts what they
refer to as ldquofuels bulkingrdquo or involving transloadingtransshipment of waste fuels or hydrocarbons
destined to become waste fuels into tanker trucks This can be done by transferring the contents
from drums or containers to larger containers or from containers to tanker trucks in either event
for shipment offsite Liquids are transferred from containers through the bung hole and then closed
upon completion of the transfer US Ecology requests that the term ldquofuels blendingrdquo not be
associated with their operations or permit on the premises that they donrsquot combine the materials to
meet specifications for waste fuels and requested that the prohibition on fuels blending be removed
from the permit Following is a description of the equipment and the processes conducted at the
facility organized by Emissions Unit Group (EUG)
PERMIT MEMORANDUM 2019-0826-O 3 DRAFT
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EUG A consists of a tank system for the accumulation storage transfer and treatment of offsite
and onsite generated RCRA wastewaters Equipment andor emissions units included in this EUG
are listed in the following table Tanks T108 and T109 have been removed from the facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Piping Transfer Pumps Connections and appurtenances
included in the TF1 tank system 1996-2007
Tanks included in the TF1 tank system 1996-2007
A waste can be designated as ldquobeneficial reuserdquo and no longer a waste when it can be used directly as a reagent or
product
The acid treatment process is basically a pH adjustment process for acidic wastewaters that carry
the hazardous characteristic of Corrosivity (EPA Waste Code D002) under Title 40 CFR Part 261
Subpart C Metal contaminants (waste codes D004 through D011) may also be removed via
precipitation Waste materials are received into the hazardous waste storage and treatment tanks
in Tank Farm 1 (TF1) including tanks T101 T102 T103 or T107 The wastes are received from
bulk tankers tote tanks and drums all of which the contents are transferred to the tanks by pump
The wastes are predominantly acidic from industries such as galvanizing facilities but wastes with
a pH greater than 7 (caustics) may also be received The acids are primarily hydrochloric acid or
sulfuric acid but may also include chromic acid nitric acid plus other inorganic and organic acids
The waste acids may also contain volatile organic chemicals in limited quantities but with
VOHAP less than 500 ppmw The EUG A treatment area includes pumps valves flanges
PERMIT MEMORANDUM 2019-0826-O 4 DRAFT
connectors and ancillary equipment (EU-A8) that may contain VOC with total VOHAP
constituents less than 500 ppmw
The neutralization treatment reaction occurs in tanks T101 T102 T103 or T107 These tanks
include top-mounted mixers Sodium hydroxide (caustic) is added to the treatment tanks causing
an exothermic reaction that causes the temperature of the mixed waste to rise from ambient
temperature up to as high as 180degF The caustic is added from the product caustic tank P001
This tank may contain virgin off-specification or beneficial reuse caustic products The reuse
caustic product may contain limited amounts of VOC andor VOHAP but less than 500 ppmw total
VOHAP (The 500 ppmw threshold for VOHAP was derived from NESHAP DD which is ceasing
to be applicable and because of the emissions accounting method which assumes 100
evaporation) After the wastes are reacted and the resulting mixture is found to have been de-
characterized of its hazardous waste characteristics the wastes are transferred to tanks T203 or
T204 for accumulation storage and subsequent filtration Waste is filtered using bag (or sock)
type filters and two filter presses Vapor emissions from tanks T101 T102 T103 and T107 are
vented to the atmosphere
The treatment process of acidic wastewaters containing metals (EPA Waste Codes D002 and
D004-D011) is similar to that for the acidic wastewaters (EPA Waste Code D002) It is basically
a pH adjustment to raise the pH to within the range of 100 to 110 where precipitation and filtering
of metals brings the water to the required standards for disposal in the public owned treatment
works (POTW) sanitary sewer
EUG B ndash Treatment of Neutralized Non-Hazardous Wastewater from EUG A
EUG B was dismantled and removed in its entirety from the facility
EUG C - Treatment of Non-Hazardous Wastewater
EUG C consists of tank systems TF4 and TF2 and filters that are used in the final step to prepare
onsite neutralized wastewaters and offsite non-hazardous wastewaters pumped directly from
tanker trucks for disposal in the POTW TF4 includes an oil separation tank T404 Equipment
andor emissions units included in this EUG are listed in the following table
EU
ID
Point
ID EU Description and Service
Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
PERMIT MEMORANDUM 2019-0826-O 5 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C21 P002 10rsquo L x 8rsquoW x 8rsquoH square 5330-gallon Flocculant addition
tank 1996
PERMIT MEMORANDUM 2019-0826-O 6 DRAFT
Wastewater is filtered through C1 a 100-micron bag filter as it is pumped into TF4 Non-oily
non-hazardous low-solids wastewater received directly from offsite sources in tank trucks or
containers is filtered through C8 a 100-micron bag filter as it is pumped directly into Tank T402
(TF4) which has an overflow line to Tank T403 Oily non-hazardous wastewater containing
insoluble oils received directly from offsite sources in tank trucks and containers are unloaded
directly into Tank T406 where oil is removed by gravity segregation Chemicals to facilitate
separation may be added Bottom water is sampled Water containing metals is pumped to TF1
Water meeting POTW standards is pumped to TF4 The separated oil is transferred to a transport
truck for transporting to an offsite disposalrecycling facility Final solids removal for
wastewaters accumulated or separated in tanks T301 T302 T303 T402 T403 or T404 (TF4)
occurs when the wastewaters are pumped through C7 a 25-micron bag filter for disposal in the
POTW These tanks are press water receiving tanks and secondary treatment and replaced the
clarifier and T201 and T202 Tank T205 can only be used to collect storm water
EUG D ndash Treatment of Containerized Waste Liquids and Solids
Equipment andor emissions units included in this EUG are listed in the following table
EU
ID
Point
ID EU Description and Service
Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
PERMIT MEMORANDUM 2019-0826-O 7 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Drummed wastes are also processed and treated at the facility Liquids from containers may be
pumped (EU-D1) into bulk containers prior to transfer to a tank at TF1 TF2 TF4 or prior to
shipment to an offsite facility
Containers of solid wastes may also be received at the facility for consolidation (EU-D2) into
larger containers (eg roll-off boxes) If required solids and liquids that have been neutralized or
decharacterized may be stabilized in EU-D3 containers roll-off boxes and the stabilization box
prior to transportation to an off-site disposal facility Solids can be treated in the drums by
solidification using a hydraulic drum mixer and an excavator similar to a backhoe with tracks
Treatment reagents include but are not limited to sodium sulfide ferrous sulfide cement kiln dust
fly ash and Portland cement to solidify and remove the hazardous characteristics of the contents
of the drums Containers are closed or covered when waste is not being added or removed from
the container Containers of liquid or solid wastes may also be temporarily stored at the facility
without repackaging prior to shipment to an offsite disposal facility
PERMIT MEMORANDUM 2019-0826-O 8 DRAFT
EUG E ndash POTW Disposal
Equipment andor emissions units included in this EUG and remaining at the facility are listed in
the following table
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
This operation has two stationary storage tanks POTW1 and POTW2 These tanks are for
wastewaters that meet the City of Tulsa - Industrial Wastewater Discharge Permit (POTW)
standards for discharge to the sanitary sewer after treatment at the facility and also for wastewater
received directly from offsite for disposal to the sewer if the material as received meets the sitersquos
discharge permit standards All wastewaters managed in this manner are tested to ensure
compliance with the permit prior to discharge into the sewer Tank POTW1 amp POTW2 will be
utilized for storm water storage No other operations for this waste treatment process are in place
at this time
SECTION III EMISSIONS
The facility has requested the following emissions limits based on an annual facility throughput of
44148 TPY of wastes
- 72 TPY VOC
- 72 TPY total HAP
- 58 TPY any one HAP
The treatment system at this facility consists of numerous tank systems (TF1 TF2 and TF4)
serving purposes of treatment (neutralization) accumulation separation temporary storage
filtering and discharge to the POTW or a tanker truck Storage tanks T101 T102 T103 and T107
are used as reactors to neutralize corrosive wastes The tanks are routinely filled with acidic wastes
at ambient temperatures and when an adequate inventory is achieved caustic is introduced to
neutralize the acid Each tankreactor has a top-mounted agitator installed to ensure complete
mixing of the reactants The shaft entrance is sealed to prevent emissions from this location The
neutralization is an exothermic reaction causing the mixture temperature to rise as high as 180deg
Fahrenheit
PERMIT MEMORANDUM 2019-0826-O 9 DRAFT
The tanks are connected by piping that provides various transferring scenarios and possibly re-
circulations between the tank systems For example one purpose of transferring wastes tofrom
tanks is to pass the wastes through filters for solids removal This is done by rolling the tanks ie
pumping wastes from one tank system into another allowing the waste to pass through in-line
filters installed in the transfer piping The tracking becomes more complex as volumes and VOC
content change to a new blend This makes the use of EPA TANKS a laborious method for
tracking emissions Note that this is not an implication that the facility is allowed to dilute
hazardous waste to meet a treatment standard A previous owner ACE committed to limiting
receipt of wastewaters containing less than 500 ppmw of VOC US Ecology agrees to the mass
balance described herein but with the exception that although VOC (not VOHAP) content may be
500 ppmw or greater the levels will be documented for emissions calculations VOHAP
concentrations are limited to less than 500 ppmw
An emissions calculation based on a VOC content of 500 ppmw assumes that 100 of all VOC in
the wastewaters ultimately evaporate as a result of physical changes that could affect the volatility
of the organics such as rolling the tanks temperature rises and agitation Based on the operations
at the facility under prevous owner ACE the maximum VOC-laden liquid waste throughput was
assumed to be the sum of the projected throughput rates of tanks P001 T101 T102 T103 and
T107 all in EUG A These tanks handle the main throughput of incoming wastewaters having
VOC andor VOHAP Immediately downstream of these tanks Tanks T203 and T204 are the
receivingaccumulation tanks Although emissions from the tanks in EUG A were controlled by
the carbon adsorber emissions from EUG B were not nor are emissions from the tanks now
receiving the treated wastes It was further assumed that the tanks did not treat or store wastes
containing VOC or VOHAP and that neither POTW1 nor POTW2 received VOC-containing
wastes Based on the rates submitted by the applicant the total liquid waste throughput would be
43589219 gallons per year Assuming an average wastewater density of 100 lbsgallon the
calculated emissions were approximately 109 tons-VOC per year Calculations using EPA
TANKS were based on a waste treatmentdisposal volume of 27000000 gallons per year emitting
269 tons per year of VOHAP with a PTE of 65 tons per year The mass balance approach would
be simpler and safer for all considering that the only data required for this calculation is incoming
waste volumes densities and VOC concentrations US Ecology has agreed to carry this method
forward with a limit of 72 TPY except that total VOC content may range higher than the VOHAP
limit provided that the facility will document the actual VOC content of the waste
FuelsHydrocarbon Bulking
The facility does bulking of liquid hydrocarbons and fuels Emissions of VOC are calculated using
Equation 1-29 AP-42 (1106) Section 7-111 The operator submitted calculations for a similar
operation at a facility in Detroit Michigan which they state is a bigger operation than the Tulsa
facility Based on an annual throughput of about 458000 gallons emissions were 1400 pounds
of VOC The equations and input parameters for calculating emissions are specified in the permit
PERMIT MEMORANDUM 2019-0826-O 10 DRAFT
Solids Bulking
The facility bulks solids materials Hazardous Non Hazardous and some Flammable Solids The
following formula is used to calculate emissions (Note VP for methanol is used)
W = Emissions (lbyr)
W = Qw X (1359) X 27315Tamb X VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3lb-mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
SECTION IV FEDERAL REGULATIONS
PSD 40 CFR Part 52 [Not Applicable]
PSD does not apply Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant and the facility is not one of the listed stationary sources with an emission
threshold of 100 TPY
NSPS 40 CFR Part 60 [Not Applicable]
Subpart Kb Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage
Vessels) for Which Construction Reconstruction or Modification Commenced After July 23
1984 This subpart does not apply to storage vessels with a capacity greater than or equal to 151
m3 (39890 US gallons) storing a liquid with a maximum true vapor pressure less than 35
kilopascals (05 psi) or with a capacity greater than or equal to 75 m3 (19813 US gallons) but less
than 151 m3 storing a liquid with a maximum true vapor pressure less than 150 kilopascals (2175
psi) There are no tanks meeting the 39890-gallon threshold The following tanks exceed the
19813-gallon threshold but will not store hydrocarbon liquids having a maximum true vapor
pressure of 150 kilopascals (2175 psi) or more Therefore there are no affected tanks at this
facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construct
Date
C2 T402 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C3 T403 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C14 T204 38000 gal (144 m3) Dish bottom and roof Wastewater 1996
E4 POTW1 25700 gal (97 m3) Flat bottom dome roof Wastewater 1996
E5 POTW2 22000 gal (83 m3) Flat bottom dome roof Wastewater 1996
PERMIT MEMORANDUM 2019-0826-O 11 DRAFT
NESHAP 40 CFR Part 61 [Not Applicable]
Subpart V National Emission Standard for Equipment Leaks (Fugitive Emission Sources) applies
to each of the following sources that are intended to operate in volatile hazardous air pollutant
(VHAP) service pumps compressors pressure relief devices sampling connection systems open-
ended valves or lines valves connectors surge control vessels bottoms receivers and control
devices or systems required by this subpart There are no affected sources having HAP
concentration equal to or greater than 10 by weight
NESHAP 40 CFR Part 63 [No Longer Applicable]
Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment
Leaks applies to pumps compressors agitators pressure relief devices sampling connection
systems open-ended valves or lines valves connectors surge control vessels bottoms receivers
instrumentation systems and control devices or closed vent systems required by this subpart that
are intended to operate in organic hazardous air pollutant service 300 hours or more during the
calendar year within a source subject to the provisions of a specific subpart in 40 CFR Part 63 that
references this subpart None of the affected sources contain or contact at least 5 percent by weight
of total organic HAP and the facility is becoming an ldquoareardquo source of HAP
Subpart DD National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations applies to any owner or operator of a plant that is a major source of
hazardous air pollutant (HAP) emissions as defined in 40 CFR sect632 having waste management
or recovery operations specified in sect63680(a)(2)(i) through (a)(2)(vi) that receive an offsite
material as specified in sectsect63680(b) The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart OO National Emission Standards for Tanks-Level 1 applies to the control of air
emissions from tanks for which another subpart of 40 CFR Parts 60 61 or 63 references the use
of this subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP
and will cease to be subject to this major source MACT
Subpart PP National Emission Standards for Containers applies to the control of air emissions
from containers for which another subpart of 40 CFR Parts 60 61 or 63 references the use of this
subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart RR National Emission Standards for Individual Drain Systems applies to the control of
air emissions from individual drain systems for which another subpart of 40 CFR Parts 60 61 or
63 references the use of this subpart for such air emission control At this time there are no transfer
systems that appear to meet the definition of an individual drain system as defined in this subpart
or in Subpart DD However as noted earlier this is contingent on the POTW not handling any
hazardous waste
Chemical Accident Prevention Provisions 40 CFR Part 68 [Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments) More information on this federal program
is available on the web page wwwepagovrmp
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 3 DRAFT
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EUG A consists of a tank system for the accumulation storage transfer and treatment of offsite
and onsite generated RCRA wastewaters Equipment andor emissions units included in this EUG
are listed in the following table Tanks T108 and T109 have been removed from the facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Piping Transfer Pumps Connections and appurtenances
included in the TF1 tank system 1996-2007
Tanks included in the TF1 tank system 1996-2007
A waste can be designated as ldquobeneficial reuserdquo and no longer a waste when it can be used directly as a reagent or
product
The acid treatment process is basically a pH adjustment process for acidic wastewaters that carry
the hazardous characteristic of Corrosivity (EPA Waste Code D002) under Title 40 CFR Part 261
Subpart C Metal contaminants (waste codes D004 through D011) may also be removed via
precipitation Waste materials are received into the hazardous waste storage and treatment tanks
in Tank Farm 1 (TF1) including tanks T101 T102 T103 or T107 The wastes are received from
bulk tankers tote tanks and drums all of which the contents are transferred to the tanks by pump
The wastes are predominantly acidic from industries such as galvanizing facilities but wastes with
a pH greater than 7 (caustics) may also be received The acids are primarily hydrochloric acid or
sulfuric acid but may also include chromic acid nitric acid plus other inorganic and organic acids
The waste acids may also contain volatile organic chemicals in limited quantities but with
VOHAP less than 500 ppmw The EUG A treatment area includes pumps valves flanges
PERMIT MEMORANDUM 2019-0826-O 4 DRAFT
connectors and ancillary equipment (EU-A8) that may contain VOC with total VOHAP
constituents less than 500 ppmw
The neutralization treatment reaction occurs in tanks T101 T102 T103 or T107 These tanks
include top-mounted mixers Sodium hydroxide (caustic) is added to the treatment tanks causing
an exothermic reaction that causes the temperature of the mixed waste to rise from ambient
temperature up to as high as 180degF The caustic is added from the product caustic tank P001
This tank may contain virgin off-specification or beneficial reuse caustic products The reuse
caustic product may contain limited amounts of VOC andor VOHAP but less than 500 ppmw total
VOHAP (The 500 ppmw threshold for VOHAP was derived from NESHAP DD which is ceasing
to be applicable and because of the emissions accounting method which assumes 100
evaporation) After the wastes are reacted and the resulting mixture is found to have been de-
characterized of its hazardous waste characteristics the wastes are transferred to tanks T203 or
T204 for accumulation storage and subsequent filtration Waste is filtered using bag (or sock)
type filters and two filter presses Vapor emissions from tanks T101 T102 T103 and T107 are
vented to the atmosphere
The treatment process of acidic wastewaters containing metals (EPA Waste Codes D002 and
D004-D011) is similar to that for the acidic wastewaters (EPA Waste Code D002) It is basically
a pH adjustment to raise the pH to within the range of 100 to 110 where precipitation and filtering
of metals brings the water to the required standards for disposal in the public owned treatment
works (POTW) sanitary sewer
EUG B ndash Treatment of Neutralized Non-Hazardous Wastewater from EUG A
EUG B was dismantled and removed in its entirety from the facility
EUG C - Treatment of Non-Hazardous Wastewater
EUG C consists of tank systems TF4 and TF2 and filters that are used in the final step to prepare
onsite neutralized wastewaters and offsite non-hazardous wastewaters pumped directly from
tanker trucks for disposal in the POTW TF4 includes an oil separation tank T404 Equipment
andor emissions units included in this EUG are listed in the following table
EU
ID
Point
ID EU Description and Service
Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
PERMIT MEMORANDUM 2019-0826-O 5 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C21 P002 10rsquo L x 8rsquoW x 8rsquoH square 5330-gallon Flocculant addition
tank 1996
PERMIT MEMORANDUM 2019-0826-O 6 DRAFT
Wastewater is filtered through C1 a 100-micron bag filter as it is pumped into TF4 Non-oily
non-hazardous low-solids wastewater received directly from offsite sources in tank trucks or
containers is filtered through C8 a 100-micron bag filter as it is pumped directly into Tank T402
(TF4) which has an overflow line to Tank T403 Oily non-hazardous wastewater containing
insoluble oils received directly from offsite sources in tank trucks and containers are unloaded
directly into Tank T406 where oil is removed by gravity segregation Chemicals to facilitate
separation may be added Bottom water is sampled Water containing metals is pumped to TF1
Water meeting POTW standards is pumped to TF4 The separated oil is transferred to a transport
truck for transporting to an offsite disposalrecycling facility Final solids removal for
wastewaters accumulated or separated in tanks T301 T302 T303 T402 T403 or T404 (TF4)
occurs when the wastewaters are pumped through C7 a 25-micron bag filter for disposal in the
POTW These tanks are press water receiving tanks and secondary treatment and replaced the
clarifier and T201 and T202 Tank T205 can only be used to collect storm water
EUG D ndash Treatment of Containerized Waste Liquids and Solids
Equipment andor emissions units included in this EUG are listed in the following table
EU
ID
Point
ID EU Description and Service
Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
PERMIT MEMORANDUM 2019-0826-O 7 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Drummed wastes are also processed and treated at the facility Liquids from containers may be
pumped (EU-D1) into bulk containers prior to transfer to a tank at TF1 TF2 TF4 or prior to
shipment to an offsite facility
Containers of solid wastes may also be received at the facility for consolidation (EU-D2) into
larger containers (eg roll-off boxes) If required solids and liquids that have been neutralized or
decharacterized may be stabilized in EU-D3 containers roll-off boxes and the stabilization box
prior to transportation to an off-site disposal facility Solids can be treated in the drums by
solidification using a hydraulic drum mixer and an excavator similar to a backhoe with tracks
Treatment reagents include but are not limited to sodium sulfide ferrous sulfide cement kiln dust
fly ash and Portland cement to solidify and remove the hazardous characteristics of the contents
of the drums Containers are closed or covered when waste is not being added or removed from
the container Containers of liquid or solid wastes may also be temporarily stored at the facility
without repackaging prior to shipment to an offsite disposal facility
PERMIT MEMORANDUM 2019-0826-O 8 DRAFT
EUG E ndash POTW Disposal
Equipment andor emissions units included in this EUG and remaining at the facility are listed in
the following table
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
This operation has two stationary storage tanks POTW1 and POTW2 These tanks are for
wastewaters that meet the City of Tulsa - Industrial Wastewater Discharge Permit (POTW)
standards for discharge to the sanitary sewer after treatment at the facility and also for wastewater
received directly from offsite for disposal to the sewer if the material as received meets the sitersquos
discharge permit standards All wastewaters managed in this manner are tested to ensure
compliance with the permit prior to discharge into the sewer Tank POTW1 amp POTW2 will be
utilized for storm water storage No other operations for this waste treatment process are in place
at this time
SECTION III EMISSIONS
The facility has requested the following emissions limits based on an annual facility throughput of
44148 TPY of wastes
- 72 TPY VOC
- 72 TPY total HAP
- 58 TPY any one HAP
The treatment system at this facility consists of numerous tank systems (TF1 TF2 and TF4)
serving purposes of treatment (neutralization) accumulation separation temporary storage
filtering and discharge to the POTW or a tanker truck Storage tanks T101 T102 T103 and T107
are used as reactors to neutralize corrosive wastes The tanks are routinely filled with acidic wastes
at ambient temperatures and when an adequate inventory is achieved caustic is introduced to
neutralize the acid Each tankreactor has a top-mounted agitator installed to ensure complete
mixing of the reactants The shaft entrance is sealed to prevent emissions from this location The
neutralization is an exothermic reaction causing the mixture temperature to rise as high as 180deg
Fahrenheit
PERMIT MEMORANDUM 2019-0826-O 9 DRAFT
The tanks are connected by piping that provides various transferring scenarios and possibly re-
circulations between the tank systems For example one purpose of transferring wastes tofrom
tanks is to pass the wastes through filters for solids removal This is done by rolling the tanks ie
pumping wastes from one tank system into another allowing the waste to pass through in-line
filters installed in the transfer piping The tracking becomes more complex as volumes and VOC
content change to a new blend This makes the use of EPA TANKS a laborious method for
tracking emissions Note that this is not an implication that the facility is allowed to dilute
hazardous waste to meet a treatment standard A previous owner ACE committed to limiting
receipt of wastewaters containing less than 500 ppmw of VOC US Ecology agrees to the mass
balance described herein but with the exception that although VOC (not VOHAP) content may be
500 ppmw or greater the levels will be documented for emissions calculations VOHAP
concentrations are limited to less than 500 ppmw
An emissions calculation based on a VOC content of 500 ppmw assumes that 100 of all VOC in
the wastewaters ultimately evaporate as a result of physical changes that could affect the volatility
of the organics such as rolling the tanks temperature rises and agitation Based on the operations
at the facility under prevous owner ACE the maximum VOC-laden liquid waste throughput was
assumed to be the sum of the projected throughput rates of tanks P001 T101 T102 T103 and
T107 all in EUG A These tanks handle the main throughput of incoming wastewaters having
VOC andor VOHAP Immediately downstream of these tanks Tanks T203 and T204 are the
receivingaccumulation tanks Although emissions from the tanks in EUG A were controlled by
the carbon adsorber emissions from EUG B were not nor are emissions from the tanks now
receiving the treated wastes It was further assumed that the tanks did not treat or store wastes
containing VOC or VOHAP and that neither POTW1 nor POTW2 received VOC-containing
wastes Based on the rates submitted by the applicant the total liquid waste throughput would be
43589219 gallons per year Assuming an average wastewater density of 100 lbsgallon the
calculated emissions were approximately 109 tons-VOC per year Calculations using EPA
TANKS were based on a waste treatmentdisposal volume of 27000000 gallons per year emitting
269 tons per year of VOHAP with a PTE of 65 tons per year The mass balance approach would
be simpler and safer for all considering that the only data required for this calculation is incoming
waste volumes densities and VOC concentrations US Ecology has agreed to carry this method
forward with a limit of 72 TPY except that total VOC content may range higher than the VOHAP
limit provided that the facility will document the actual VOC content of the waste
FuelsHydrocarbon Bulking
The facility does bulking of liquid hydrocarbons and fuels Emissions of VOC are calculated using
Equation 1-29 AP-42 (1106) Section 7-111 The operator submitted calculations for a similar
operation at a facility in Detroit Michigan which they state is a bigger operation than the Tulsa
facility Based on an annual throughput of about 458000 gallons emissions were 1400 pounds
of VOC The equations and input parameters for calculating emissions are specified in the permit
PERMIT MEMORANDUM 2019-0826-O 10 DRAFT
Solids Bulking
The facility bulks solids materials Hazardous Non Hazardous and some Flammable Solids The
following formula is used to calculate emissions (Note VP for methanol is used)
W = Emissions (lbyr)
W = Qw X (1359) X 27315Tamb X VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3lb-mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
SECTION IV FEDERAL REGULATIONS
PSD 40 CFR Part 52 [Not Applicable]
PSD does not apply Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant and the facility is not one of the listed stationary sources with an emission
threshold of 100 TPY
NSPS 40 CFR Part 60 [Not Applicable]
Subpart Kb Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage
Vessels) for Which Construction Reconstruction or Modification Commenced After July 23
1984 This subpart does not apply to storage vessels with a capacity greater than or equal to 151
m3 (39890 US gallons) storing a liquid with a maximum true vapor pressure less than 35
kilopascals (05 psi) or with a capacity greater than or equal to 75 m3 (19813 US gallons) but less
than 151 m3 storing a liquid with a maximum true vapor pressure less than 150 kilopascals (2175
psi) There are no tanks meeting the 39890-gallon threshold The following tanks exceed the
19813-gallon threshold but will not store hydrocarbon liquids having a maximum true vapor
pressure of 150 kilopascals (2175 psi) or more Therefore there are no affected tanks at this
facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construct
Date
C2 T402 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C3 T403 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C14 T204 38000 gal (144 m3) Dish bottom and roof Wastewater 1996
E4 POTW1 25700 gal (97 m3) Flat bottom dome roof Wastewater 1996
E5 POTW2 22000 gal (83 m3) Flat bottom dome roof Wastewater 1996
PERMIT MEMORANDUM 2019-0826-O 11 DRAFT
NESHAP 40 CFR Part 61 [Not Applicable]
Subpart V National Emission Standard for Equipment Leaks (Fugitive Emission Sources) applies
to each of the following sources that are intended to operate in volatile hazardous air pollutant
(VHAP) service pumps compressors pressure relief devices sampling connection systems open-
ended valves or lines valves connectors surge control vessels bottoms receivers and control
devices or systems required by this subpart There are no affected sources having HAP
concentration equal to or greater than 10 by weight
NESHAP 40 CFR Part 63 [No Longer Applicable]
Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment
Leaks applies to pumps compressors agitators pressure relief devices sampling connection
systems open-ended valves or lines valves connectors surge control vessels bottoms receivers
instrumentation systems and control devices or closed vent systems required by this subpart that
are intended to operate in organic hazardous air pollutant service 300 hours or more during the
calendar year within a source subject to the provisions of a specific subpart in 40 CFR Part 63 that
references this subpart None of the affected sources contain or contact at least 5 percent by weight
of total organic HAP and the facility is becoming an ldquoareardquo source of HAP
Subpart DD National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations applies to any owner or operator of a plant that is a major source of
hazardous air pollutant (HAP) emissions as defined in 40 CFR sect632 having waste management
or recovery operations specified in sect63680(a)(2)(i) through (a)(2)(vi) that receive an offsite
material as specified in sectsect63680(b) The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart OO National Emission Standards for Tanks-Level 1 applies to the control of air
emissions from tanks for which another subpart of 40 CFR Parts 60 61 or 63 references the use
of this subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP
and will cease to be subject to this major source MACT
Subpart PP National Emission Standards for Containers applies to the control of air emissions
from containers for which another subpart of 40 CFR Parts 60 61 or 63 references the use of this
subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart RR National Emission Standards for Individual Drain Systems applies to the control of
air emissions from individual drain systems for which another subpart of 40 CFR Parts 60 61 or
63 references the use of this subpart for such air emission control At this time there are no transfer
systems that appear to meet the definition of an individual drain system as defined in this subpart
or in Subpart DD However as noted earlier this is contingent on the POTW not handling any
hazardous waste
Chemical Accident Prevention Provisions 40 CFR Part 68 [Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments) More information on this federal program
is available on the web page wwwepagovrmp
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 4 DRAFT
connectors and ancillary equipment (EU-A8) that may contain VOC with total VOHAP
constituents less than 500 ppmw
The neutralization treatment reaction occurs in tanks T101 T102 T103 or T107 These tanks
include top-mounted mixers Sodium hydroxide (caustic) is added to the treatment tanks causing
an exothermic reaction that causes the temperature of the mixed waste to rise from ambient
temperature up to as high as 180degF The caustic is added from the product caustic tank P001
This tank may contain virgin off-specification or beneficial reuse caustic products The reuse
caustic product may contain limited amounts of VOC andor VOHAP but less than 500 ppmw total
VOHAP (The 500 ppmw threshold for VOHAP was derived from NESHAP DD which is ceasing
to be applicable and because of the emissions accounting method which assumes 100
evaporation) After the wastes are reacted and the resulting mixture is found to have been de-
characterized of its hazardous waste characteristics the wastes are transferred to tanks T203 or
T204 for accumulation storage and subsequent filtration Waste is filtered using bag (or sock)
type filters and two filter presses Vapor emissions from tanks T101 T102 T103 and T107 are
vented to the atmosphere
The treatment process of acidic wastewaters containing metals (EPA Waste Codes D002 and
D004-D011) is similar to that for the acidic wastewaters (EPA Waste Code D002) It is basically
a pH adjustment to raise the pH to within the range of 100 to 110 where precipitation and filtering
of metals brings the water to the required standards for disposal in the public owned treatment
works (POTW) sanitary sewer
EUG B ndash Treatment of Neutralized Non-Hazardous Wastewater from EUG A
EUG B was dismantled and removed in its entirety from the facility
EUG C - Treatment of Non-Hazardous Wastewater
EUG C consists of tank systems TF4 and TF2 and filters that are used in the final step to prepare
onsite neutralized wastewaters and offsite non-hazardous wastewaters pumped directly from
tanker trucks for disposal in the POTW TF4 includes an oil separation tank T404 Equipment
andor emissions units included in this EUG are listed in the following table
EU
ID
Point
ID EU Description and Service
Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
PERMIT MEMORANDUM 2019-0826-O 5 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C21 P002 10rsquo L x 8rsquoW x 8rsquoH square 5330-gallon Flocculant addition
tank 1996
PERMIT MEMORANDUM 2019-0826-O 6 DRAFT
Wastewater is filtered through C1 a 100-micron bag filter as it is pumped into TF4 Non-oily
non-hazardous low-solids wastewater received directly from offsite sources in tank trucks or
containers is filtered through C8 a 100-micron bag filter as it is pumped directly into Tank T402
(TF4) which has an overflow line to Tank T403 Oily non-hazardous wastewater containing
insoluble oils received directly from offsite sources in tank trucks and containers are unloaded
directly into Tank T406 where oil is removed by gravity segregation Chemicals to facilitate
separation may be added Bottom water is sampled Water containing metals is pumped to TF1
Water meeting POTW standards is pumped to TF4 The separated oil is transferred to a transport
truck for transporting to an offsite disposalrecycling facility Final solids removal for
wastewaters accumulated or separated in tanks T301 T302 T303 T402 T403 or T404 (TF4)
occurs when the wastewaters are pumped through C7 a 25-micron bag filter for disposal in the
POTW These tanks are press water receiving tanks and secondary treatment and replaced the
clarifier and T201 and T202 Tank T205 can only be used to collect storm water
EUG D ndash Treatment of Containerized Waste Liquids and Solids
Equipment andor emissions units included in this EUG are listed in the following table
EU
ID
Point
ID EU Description and Service
Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
PERMIT MEMORANDUM 2019-0826-O 7 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Drummed wastes are also processed and treated at the facility Liquids from containers may be
pumped (EU-D1) into bulk containers prior to transfer to a tank at TF1 TF2 TF4 or prior to
shipment to an offsite facility
Containers of solid wastes may also be received at the facility for consolidation (EU-D2) into
larger containers (eg roll-off boxes) If required solids and liquids that have been neutralized or
decharacterized may be stabilized in EU-D3 containers roll-off boxes and the stabilization box
prior to transportation to an off-site disposal facility Solids can be treated in the drums by
solidification using a hydraulic drum mixer and an excavator similar to a backhoe with tracks
Treatment reagents include but are not limited to sodium sulfide ferrous sulfide cement kiln dust
fly ash and Portland cement to solidify and remove the hazardous characteristics of the contents
of the drums Containers are closed or covered when waste is not being added or removed from
the container Containers of liquid or solid wastes may also be temporarily stored at the facility
without repackaging prior to shipment to an offsite disposal facility
PERMIT MEMORANDUM 2019-0826-O 8 DRAFT
EUG E ndash POTW Disposal
Equipment andor emissions units included in this EUG and remaining at the facility are listed in
the following table
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
This operation has two stationary storage tanks POTW1 and POTW2 These tanks are for
wastewaters that meet the City of Tulsa - Industrial Wastewater Discharge Permit (POTW)
standards for discharge to the sanitary sewer after treatment at the facility and also for wastewater
received directly from offsite for disposal to the sewer if the material as received meets the sitersquos
discharge permit standards All wastewaters managed in this manner are tested to ensure
compliance with the permit prior to discharge into the sewer Tank POTW1 amp POTW2 will be
utilized for storm water storage No other operations for this waste treatment process are in place
at this time
SECTION III EMISSIONS
The facility has requested the following emissions limits based on an annual facility throughput of
44148 TPY of wastes
- 72 TPY VOC
- 72 TPY total HAP
- 58 TPY any one HAP
The treatment system at this facility consists of numerous tank systems (TF1 TF2 and TF4)
serving purposes of treatment (neutralization) accumulation separation temporary storage
filtering and discharge to the POTW or a tanker truck Storage tanks T101 T102 T103 and T107
are used as reactors to neutralize corrosive wastes The tanks are routinely filled with acidic wastes
at ambient temperatures and when an adequate inventory is achieved caustic is introduced to
neutralize the acid Each tankreactor has a top-mounted agitator installed to ensure complete
mixing of the reactants The shaft entrance is sealed to prevent emissions from this location The
neutralization is an exothermic reaction causing the mixture temperature to rise as high as 180deg
Fahrenheit
PERMIT MEMORANDUM 2019-0826-O 9 DRAFT
The tanks are connected by piping that provides various transferring scenarios and possibly re-
circulations between the tank systems For example one purpose of transferring wastes tofrom
tanks is to pass the wastes through filters for solids removal This is done by rolling the tanks ie
pumping wastes from one tank system into another allowing the waste to pass through in-line
filters installed in the transfer piping The tracking becomes more complex as volumes and VOC
content change to a new blend This makes the use of EPA TANKS a laborious method for
tracking emissions Note that this is not an implication that the facility is allowed to dilute
hazardous waste to meet a treatment standard A previous owner ACE committed to limiting
receipt of wastewaters containing less than 500 ppmw of VOC US Ecology agrees to the mass
balance described herein but with the exception that although VOC (not VOHAP) content may be
500 ppmw or greater the levels will be documented for emissions calculations VOHAP
concentrations are limited to less than 500 ppmw
An emissions calculation based on a VOC content of 500 ppmw assumes that 100 of all VOC in
the wastewaters ultimately evaporate as a result of physical changes that could affect the volatility
of the organics such as rolling the tanks temperature rises and agitation Based on the operations
at the facility under prevous owner ACE the maximum VOC-laden liquid waste throughput was
assumed to be the sum of the projected throughput rates of tanks P001 T101 T102 T103 and
T107 all in EUG A These tanks handle the main throughput of incoming wastewaters having
VOC andor VOHAP Immediately downstream of these tanks Tanks T203 and T204 are the
receivingaccumulation tanks Although emissions from the tanks in EUG A were controlled by
the carbon adsorber emissions from EUG B were not nor are emissions from the tanks now
receiving the treated wastes It was further assumed that the tanks did not treat or store wastes
containing VOC or VOHAP and that neither POTW1 nor POTW2 received VOC-containing
wastes Based on the rates submitted by the applicant the total liquid waste throughput would be
43589219 gallons per year Assuming an average wastewater density of 100 lbsgallon the
calculated emissions were approximately 109 tons-VOC per year Calculations using EPA
TANKS were based on a waste treatmentdisposal volume of 27000000 gallons per year emitting
269 tons per year of VOHAP with a PTE of 65 tons per year The mass balance approach would
be simpler and safer for all considering that the only data required for this calculation is incoming
waste volumes densities and VOC concentrations US Ecology has agreed to carry this method
forward with a limit of 72 TPY except that total VOC content may range higher than the VOHAP
limit provided that the facility will document the actual VOC content of the waste
FuelsHydrocarbon Bulking
The facility does bulking of liquid hydrocarbons and fuels Emissions of VOC are calculated using
Equation 1-29 AP-42 (1106) Section 7-111 The operator submitted calculations for a similar
operation at a facility in Detroit Michigan which they state is a bigger operation than the Tulsa
facility Based on an annual throughput of about 458000 gallons emissions were 1400 pounds
of VOC The equations and input parameters for calculating emissions are specified in the permit
PERMIT MEMORANDUM 2019-0826-O 10 DRAFT
Solids Bulking
The facility bulks solids materials Hazardous Non Hazardous and some Flammable Solids The
following formula is used to calculate emissions (Note VP for methanol is used)
W = Emissions (lbyr)
W = Qw X (1359) X 27315Tamb X VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3lb-mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
SECTION IV FEDERAL REGULATIONS
PSD 40 CFR Part 52 [Not Applicable]
PSD does not apply Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant and the facility is not one of the listed stationary sources with an emission
threshold of 100 TPY
NSPS 40 CFR Part 60 [Not Applicable]
Subpart Kb Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage
Vessels) for Which Construction Reconstruction or Modification Commenced After July 23
1984 This subpart does not apply to storage vessels with a capacity greater than or equal to 151
m3 (39890 US gallons) storing a liquid with a maximum true vapor pressure less than 35
kilopascals (05 psi) or with a capacity greater than or equal to 75 m3 (19813 US gallons) but less
than 151 m3 storing a liquid with a maximum true vapor pressure less than 150 kilopascals (2175
psi) There are no tanks meeting the 39890-gallon threshold The following tanks exceed the
19813-gallon threshold but will not store hydrocarbon liquids having a maximum true vapor
pressure of 150 kilopascals (2175 psi) or more Therefore there are no affected tanks at this
facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construct
Date
C2 T402 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C3 T403 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C14 T204 38000 gal (144 m3) Dish bottom and roof Wastewater 1996
E4 POTW1 25700 gal (97 m3) Flat bottom dome roof Wastewater 1996
E5 POTW2 22000 gal (83 m3) Flat bottom dome roof Wastewater 1996
PERMIT MEMORANDUM 2019-0826-O 11 DRAFT
NESHAP 40 CFR Part 61 [Not Applicable]
Subpart V National Emission Standard for Equipment Leaks (Fugitive Emission Sources) applies
to each of the following sources that are intended to operate in volatile hazardous air pollutant
(VHAP) service pumps compressors pressure relief devices sampling connection systems open-
ended valves or lines valves connectors surge control vessels bottoms receivers and control
devices or systems required by this subpart There are no affected sources having HAP
concentration equal to or greater than 10 by weight
NESHAP 40 CFR Part 63 [No Longer Applicable]
Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment
Leaks applies to pumps compressors agitators pressure relief devices sampling connection
systems open-ended valves or lines valves connectors surge control vessels bottoms receivers
instrumentation systems and control devices or closed vent systems required by this subpart that
are intended to operate in organic hazardous air pollutant service 300 hours or more during the
calendar year within a source subject to the provisions of a specific subpart in 40 CFR Part 63 that
references this subpart None of the affected sources contain or contact at least 5 percent by weight
of total organic HAP and the facility is becoming an ldquoareardquo source of HAP
Subpart DD National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations applies to any owner or operator of a plant that is a major source of
hazardous air pollutant (HAP) emissions as defined in 40 CFR sect632 having waste management
or recovery operations specified in sect63680(a)(2)(i) through (a)(2)(vi) that receive an offsite
material as specified in sectsect63680(b) The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart OO National Emission Standards for Tanks-Level 1 applies to the control of air
emissions from tanks for which another subpart of 40 CFR Parts 60 61 or 63 references the use
of this subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP
and will cease to be subject to this major source MACT
Subpart PP National Emission Standards for Containers applies to the control of air emissions
from containers for which another subpart of 40 CFR Parts 60 61 or 63 references the use of this
subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart RR National Emission Standards for Individual Drain Systems applies to the control of
air emissions from individual drain systems for which another subpart of 40 CFR Parts 60 61 or
63 references the use of this subpart for such air emission control At this time there are no transfer
systems that appear to meet the definition of an individual drain system as defined in this subpart
or in Subpart DD However as noted earlier this is contingent on the POTW not handling any
hazardous waste
Chemical Accident Prevention Provisions 40 CFR Part 68 [Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments) More information on this federal program
is available on the web page wwwepagovrmp
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 5 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C21 P002 10rsquo L x 8rsquoW x 8rsquoH square 5330-gallon Flocculant addition
tank 1996
PERMIT MEMORANDUM 2019-0826-O 6 DRAFT
Wastewater is filtered through C1 a 100-micron bag filter as it is pumped into TF4 Non-oily
non-hazardous low-solids wastewater received directly from offsite sources in tank trucks or
containers is filtered through C8 a 100-micron bag filter as it is pumped directly into Tank T402
(TF4) which has an overflow line to Tank T403 Oily non-hazardous wastewater containing
insoluble oils received directly from offsite sources in tank trucks and containers are unloaded
directly into Tank T406 where oil is removed by gravity segregation Chemicals to facilitate
separation may be added Bottom water is sampled Water containing metals is pumped to TF1
Water meeting POTW standards is pumped to TF4 The separated oil is transferred to a transport
truck for transporting to an offsite disposalrecycling facility Final solids removal for
wastewaters accumulated or separated in tanks T301 T302 T303 T402 T403 or T404 (TF4)
occurs when the wastewaters are pumped through C7 a 25-micron bag filter for disposal in the
POTW These tanks are press water receiving tanks and secondary treatment and replaced the
clarifier and T201 and T202 Tank T205 can only be used to collect storm water
EUG D ndash Treatment of Containerized Waste Liquids and Solids
Equipment andor emissions units included in this EUG are listed in the following table
EU
ID
Point
ID EU Description and Service
Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
PERMIT MEMORANDUM 2019-0826-O 7 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Drummed wastes are also processed and treated at the facility Liquids from containers may be
pumped (EU-D1) into bulk containers prior to transfer to a tank at TF1 TF2 TF4 or prior to
shipment to an offsite facility
Containers of solid wastes may also be received at the facility for consolidation (EU-D2) into
larger containers (eg roll-off boxes) If required solids and liquids that have been neutralized or
decharacterized may be stabilized in EU-D3 containers roll-off boxes and the stabilization box
prior to transportation to an off-site disposal facility Solids can be treated in the drums by
solidification using a hydraulic drum mixer and an excavator similar to a backhoe with tracks
Treatment reagents include but are not limited to sodium sulfide ferrous sulfide cement kiln dust
fly ash and Portland cement to solidify and remove the hazardous characteristics of the contents
of the drums Containers are closed or covered when waste is not being added or removed from
the container Containers of liquid or solid wastes may also be temporarily stored at the facility
without repackaging prior to shipment to an offsite disposal facility
PERMIT MEMORANDUM 2019-0826-O 8 DRAFT
EUG E ndash POTW Disposal
Equipment andor emissions units included in this EUG and remaining at the facility are listed in
the following table
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
This operation has two stationary storage tanks POTW1 and POTW2 These tanks are for
wastewaters that meet the City of Tulsa - Industrial Wastewater Discharge Permit (POTW)
standards for discharge to the sanitary sewer after treatment at the facility and also for wastewater
received directly from offsite for disposal to the sewer if the material as received meets the sitersquos
discharge permit standards All wastewaters managed in this manner are tested to ensure
compliance with the permit prior to discharge into the sewer Tank POTW1 amp POTW2 will be
utilized for storm water storage No other operations for this waste treatment process are in place
at this time
SECTION III EMISSIONS
The facility has requested the following emissions limits based on an annual facility throughput of
44148 TPY of wastes
- 72 TPY VOC
- 72 TPY total HAP
- 58 TPY any one HAP
The treatment system at this facility consists of numerous tank systems (TF1 TF2 and TF4)
serving purposes of treatment (neutralization) accumulation separation temporary storage
filtering and discharge to the POTW or a tanker truck Storage tanks T101 T102 T103 and T107
are used as reactors to neutralize corrosive wastes The tanks are routinely filled with acidic wastes
at ambient temperatures and when an adequate inventory is achieved caustic is introduced to
neutralize the acid Each tankreactor has a top-mounted agitator installed to ensure complete
mixing of the reactants The shaft entrance is sealed to prevent emissions from this location The
neutralization is an exothermic reaction causing the mixture temperature to rise as high as 180deg
Fahrenheit
PERMIT MEMORANDUM 2019-0826-O 9 DRAFT
The tanks are connected by piping that provides various transferring scenarios and possibly re-
circulations between the tank systems For example one purpose of transferring wastes tofrom
tanks is to pass the wastes through filters for solids removal This is done by rolling the tanks ie
pumping wastes from one tank system into another allowing the waste to pass through in-line
filters installed in the transfer piping The tracking becomes more complex as volumes and VOC
content change to a new blend This makes the use of EPA TANKS a laborious method for
tracking emissions Note that this is not an implication that the facility is allowed to dilute
hazardous waste to meet a treatment standard A previous owner ACE committed to limiting
receipt of wastewaters containing less than 500 ppmw of VOC US Ecology agrees to the mass
balance described herein but with the exception that although VOC (not VOHAP) content may be
500 ppmw or greater the levels will be documented for emissions calculations VOHAP
concentrations are limited to less than 500 ppmw
An emissions calculation based on a VOC content of 500 ppmw assumes that 100 of all VOC in
the wastewaters ultimately evaporate as a result of physical changes that could affect the volatility
of the organics such as rolling the tanks temperature rises and agitation Based on the operations
at the facility under prevous owner ACE the maximum VOC-laden liquid waste throughput was
assumed to be the sum of the projected throughput rates of tanks P001 T101 T102 T103 and
T107 all in EUG A These tanks handle the main throughput of incoming wastewaters having
VOC andor VOHAP Immediately downstream of these tanks Tanks T203 and T204 are the
receivingaccumulation tanks Although emissions from the tanks in EUG A were controlled by
the carbon adsorber emissions from EUG B were not nor are emissions from the tanks now
receiving the treated wastes It was further assumed that the tanks did not treat or store wastes
containing VOC or VOHAP and that neither POTW1 nor POTW2 received VOC-containing
wastes Based on the rates submitted by the applicant the total liquid waste throughput would be
43589219 gallons per year Assuming an average wastewater density of 100 lbsgallon the
calculated emissions were approximately 109 tons-VOC per year Calculations using EPA
TANKS were based on a waste treatmentdisposal volume of 27000000 gallons per year emitting
269 tons per year of VOHAP with a PTE of 65 tons per year The mass balance approach would
be simpler and safer for all considering that the only data required for this calculation is incoming
waste volumes densities and VOC concentrations US Ecology has agreed to carry this method
forward with a limit of 72 TPY except that total VOC content may range higher than the VOHAP
limit provided that the facility will document the actual VOC content of the waste
FuelsHydrocarbon Bulking
The facility does bulking of liquid hydrocarbons and fuels Emissions of VOC are calculated using
Equation 1-29 AP-42 (1106) Section 7-111 The operator submitted calculations for a similar
operation at a facility in Detroit Michigan which they state is a bigger operation than the Tulsa
facility Based on an annual throughput of about 458000 gallons emissions were 1400 pounds
of VOC The equations and input parameters for calculating emissions are specified in the permit
PERMIT MEMORANDUM 2019-0826-O 10 DRAFT
Solids Bulking
The facility bulks solids materials Hazardous Non Hazardous and some Flammable Solids The
following formula is used to calculate emissions (Note VP for methanol is used)
W = Emissions (lbyr)
W = Qw X (1359) X 27315Tamb X VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3lb-mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
SECTION IV FEDERAL REGULATIONS
PSD 40 CFR Part 52 [Not Applicable]
PSD does not apply Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant and the facility is not one of the listed stationary sources with an emission
threshold of 100 TPY
NSPS 40 CFR Part 60 [Not Applicable]
Subpart Kb Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage
Vessels) for Which Construction Reconstruction or Modification Commenced After July 23
1984 This subpart does not apply to storage vessels with a capacity greater than or equal to 151
m3 (39890 US gallons) storing a liquid with a maximum true vapor pressure less than 35
kilopascals (05 psi) or with a capacity greater than or equal to 75 m3 (19813 US gallons) but less
than 151 m3 storing a liquid with a maximum true vapor pressure less than 150 kilopascals (2175
psi) There are no tanks meeting the 39890-gallon threshold The following tanks exceed the
19813-gallon threshold but will not store hydrocarbon liquids having a maximum true vapor
pressure of 150 kilopascals (2175 psi) or more Therefore there are no affected tanks at this
facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construct
Date
C2 T402 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C3 T403 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C14 T204 38000 gal (144 m3) Dish bottom and roof Wastewater 1996
E4 POTW1 25700 gal (97 m3) Flat bottom dome roof Wastewater 1996
E5 POTW2 22000 gal (83 m3) Flat bottom dome roof Wastewater 1996
PERMIT MEMORANDUM 2019-0826-O 11 DRAFT
NESHAP 40 CFR Part 61 [Not Applicable]
Subpart V National Emission Standard for Equipment Leaks (Fugitive Emission Sources) applies
to each of the following sources that are intended to operate in volatile hazardous air pollutant
(VHAP) service pumps compressors pressure relief devices sampling connection systems open-
ended valves or lines valves connectors surge control vessels bottoms receivers and control
devices or systems required by this subpart There are no affected sources having HAP
concentration equal to or greater than 10 by weight
NESHAP 40 CFR Part 63 [No Longer Applicable]
Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment
Leaks applies to pumps compressors agitators pressure relief devices sampling connection
systems open-ended valves or lines valves connectors surge control vessels bottoms receivers
instrumentation systems and control devices or closed vent systems required by this subpart that
are intended to operate in organic hazardous air pollutant service 300 hours or more during the
calendar year within a source subject to the provisions of a specific subpart in 40 CFR Part 63 that
references this subpart None of the affected sources contain or contact at least 5 percent by weight
of total organic HAP and the facility is becoming an ldquoareardquo source of HAP
Subpart DD National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations applies to any owner or operator of a plant that is a major source of
hazardous air pollutant (HAP) emissions as defined in 40 CFR sect632 having waste management
or recovery operations specified in sect63680(a)(2)(i) through (a)(2)(vi) that receive an offsite
material as specified in sectsect63680(b) The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart OO National Emission Standards for Tanks-Level 1 applies to the control of air
emissions from tanks for which another subpart of 40 CFR Parts 60 61 or 63 references the use
of this subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP
and will cease to be subject to this major source MACT
Subpart PP National Emission Standards for Containers applies to the control of air emissions
from containers for which another subpart of 40 CFR Parts 60 61 or 63 references the use of this
subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart RR National Emission Standards for Individual Drain Systems applies to the control of
air emissions from individual drain systems for which another subpart of 40 CFR Parts 60 61 or
63 references the use of this subpart for such air emission control At this time there are no transfer
systems that appear to meet the definition of an individual drain system as defined in this subpart
or in Subpart DD However as noted earlier this is contingent on the POTW not handling any
hazardous waste
Chemical Accident Prevention Provisions 40 CFR Part 68 [Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments) More information on this federal program
is available on the web page wwwepagovrmp
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 6 DRAFT
Wastewater is filtered through C1 a 100-micron bag filter as it is pumped into TF4 Non-oily
non-hazardous low-solids wastewater received directly from offsite sources in tank trucks or
containers is filtered through C8 a 100-micron bag filter as it is pumped directly into Tank T402
(TF4) which has an overflow line to Tank T403 Oily non-hazardous wastewater containing
insoluble oils received directly from offsite sources in tank trucks and containers are unloaded
directly into Tank T406 where oil is removed by gravity segregation Chemicals to facilitate
separation may be added Bottom water is sampled Water containing metals is pumped to TF1
Water meeting POTW standards is pumped to TF4 The separated oil is transferred to a transport
truck for transporting to an offsite disposalrecycling facility Final solids removal for
wastewaters accumulated or separated in tanks T301 T302 T303 T402 T403 or T404 (TF4)
occurs when the wastewaters are pumped through C7 a 25-micron bag filter for disposal in the
POTW These tanks are press water receiving tanks and secondary treatment and replaced the
clarifier and T201 and T202 Tank T205 can only be used to collect storm water
EUG D ndash Treatment of Containerized Waste Liquids and Solids
Equipment andor emissions units included in this EUG are listed in the following table
EU
ID
Point
ID EU Description and Service
Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
PERMIT MEMORANDUM 2019-0826-O 7 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Drummed wastes are also processed and treated at the facility Liquids from containers may be
pumped (EU-D1) into bulk containers prior to transfer to a tank at TF1 TF2 TF4 or prior to
shipment to an offsite facility
Containers of solid wastes may also be received at the facility for consolidation (EU-D2) into
larger containers (eg roll-off boxes) If required solids and liquids that have been neutralized or
decharacterized may be stabilized in EU-D3 containers roll-off boxes and the stabilization box
prior to transportation to an off-site disposal facility Solids can be treated in the drums by
solidification using a hydraulic drum mixer and an excavator similar to a backhoe with tracks
Treatment reagents include but are not limited to sodium sulfide ferrous sulfide cement kiln dust
fly ash and Portland cement to solidify and remove the hazardous characteristics of the contents
of the drums Containers are closed or covered when waste is not being added or removed from
the container Containers of liquid or solid wastes may also be temporarily stored at the facility
without repackaging prior to shipment to an offsite disposal facility
PERMIT MEMORANDUM 2019-0826-O 8 DRAFT
EUG E ndash POTW Disposal
Equipment andor emissions units included in this EUG and remaining at the facility are listed in
the following table
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
This operation has two stationary storage tanks POTW1 and POTW2 These tanks are for
wastewaters that meet the City of Tulsa - Industrial Wastewater Discharge Permit (POTW)
standards for discharge to the sanitary sewer after treatment at the facility and also for wastewater
received directly from offsite for disposal to the sewer if the material as received meets the sitersquos
discharge permit standards All wastewaters managed in this manner are tested to ensure
compliance with the permit prior to discharge into the sewer Tank POTW1 amp POTW2 will be
utilized for storm water storage No other operations for this waste treatment process are in place
at this time
SECTION III EMISSIONS
The facility has requested the following emissions limits based on an annual facility throughput of
44148 TPY of wastes
- 72 TPY VOC
- 72 TPY total HAP
- 58 TPY any one HAP
The treatment system at this facility consists of numerous tank systems (TF1 TF2 and TF4)
serving purposes of treatment (neutralization) accumulation separation temporary storage
filtering and discharge to the POTW or a tanker truck Storage tanks T101 T102 T103 and T107
are used as reactors to neutralize corrosive wastes The tanks are routinely filled with acidic wastes
at ambient temperatures and when an adequate inventory is achieved caustic is introduced to
neutralize the acid Each tankreactor has a top-mounted agitator installed to ensure complete
mixing of the reactants The shaft entrance is sealed to prevent emissions from this location The
neutralization is an exothermic reaction causing the mixture temperature to rise as high as 180deg
Fahrenheit
PERMIT MEMORANDUM 2019-0826-O 9 DRAFT
The tanks are connected by piping that provides various transferring scenarios and possibly re-
circulations between the tank systems For example one purpose of transferring wastes tofrom
tanks is to pass the wastes through filters for solids removal This is done by rolling the tanks ie
pumping wastes from one tank system into another allowing the waste to pass through in-line
filters installed in the transfer piping The tracking becomes more complex as volumes and VOC
content change to a new blend This makes the use of EPA TANKS a laborious method for
tracking emissions Note that this is not an implication that the facility is allowed to dilute
hazardous waste to meet a treatment standard A previous owner ACE committed to limiting
receipt of wastewaters containing less than 500 ppmw of VOC US Ecology agrees to the mass
balance described herein but with the exception that although VOC (not VOHAP) content may be
500 ppmw or greater the levels will be documented for emissions calculations VOHAP
concentrations are limited to less than 500 ppmw
An emissions calculation based on a VOC content of 500 ppmw assumes that 100 of all VOC in
the wastewaters ultimately evaporate as a result of physical changes that could affect the volatility
of the organics such as rolling the tanks temperature rises and agitation Based on the operations
at the facility under prevous owner ACE the maximum VOC-laden liquid waste throughput was
assumed to be the sum of the projected throughput rates of tanks P001 T101 T102 T103 and
T107 all in EUG A These tanks handle the main throughput of incoming wastewaters having
VOC andor VOHAP Immediately downstream of these tanks Tanks T203 and T204 are the
receivingaccumulation tanks Although emissions from the tanks in EUG A were controlled by
the carbon adsorber emissions from EUG B were not nor are emissions from the tanks now
receiving the treated wastes It was further assumed that the tanks did not treat or store wastes
containing VOC or VOHAP and that neither POTW1 nor POTW2 received VOC-containing
wastes Based on the rates submitted by the applicant the total liquid waste throughput would be
43589219 gallons per year Assuming an average wastewater density of 100 lbsgallon the
calculated emissions were approximately 109 tons-VOC per year Calculations using EPA
TANKS were based on a waste treatmentdisposal volume of 27000000 gallons per year emitting
269 tons per year of VOHAP with a PTE of 65 tons per year The mass balance approach would
be simpler and safer for all considering that the only data required for this calculation is incoming
waste volumes densities and VOC concentrations US Ecology has agreed to carry this method
forward with a limit of 72 TPY except that total VOC content may range higher than the VOHAP
limit provided that the facility will document the actual VOC content of the waste
FuelsHydrocarbon Bulking
The facility does bulking of liquid hydrocarbons and fuels Emissions of VOC are calculated using
Equation 1-29 AP-42 (1106) Section 7-111 The operator submitted calculations for a similar
operation at a facility in Detroit Michigan which they state is a bigger operation than the Tulsa
facility Based on an annual throughput of about 458000 gallons emissions were 1400 pounds
of VOC The equations and input parameters for calculating emissions are specified in the permit
PERMIT MEMORANDUM 2019-0826-O 10 DRAFT
Solids Bulking
The facility bulks solids materials Hazardous Non Hazardous and some Flammable Solids The
following formula is used to calculate emissions (Note VP for methanol is used)
W = Emissions (lbyr)
W = Qw X (1359) X 27315Tamb X VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3lb-mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
SECTION IV FEDERAL REGULATIONS
PSD 40 CFR Part 52 [Not Applicable]
PSD does not apply Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant and the facility is not one of the listed stationary sources with an emission
threshold of 100 TPY
NSPS 40 CFR Part 60 [Not Applicable]
Subpart Kb Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage
Vessels) for Which Construction Reconstruction or Modification Commenced After July 23
1984 This subpart does not apply to storage vessels with a capacity greater than or equal to 151
m3 (39890 US gallons) storing a liquid with a maximum true vapor pressure less than 35
kilopascals (05 psi) or with a capacity greater than or equal to 75 m3 (19813 US gallons) but less
than 151 m3 storing a liquid with a maximum true vapor pressure less than 150 kilopascals (2175
psi) There are no tanks meeting the 39890-gallon threshold The following tanks exceed the
19813-gallon threshold but will not store hydrocarbon liquids having a maximum true vapor
pressure of 150 kilopascals (2175 psi) or more Therefore there are no affected tanks at this
facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construct
Date
C2 T402 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C3 T403 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C14 T204 38000 gal (144 m3) Dish bottom and roof Wastewater 1996
E4 POTW1 25700 gal (97 m3) Flat bottom dome roof Wastewater 1996
E5 POTW2 22000 gal (83 m3) Flat bottom dome roof Wastewater 1996
PERMIT MEMORANDUM 2019-0826-O 11 DRAFT
NESHAP 40 CFR Part 61 [Not Applicable]
Subpart V National Emission Standard for Equipment Leaks (Fugitive Emission Sources) applies
to each of the following sources that are intended to operate in volatile hazardous air pollutant
(VHAP) service pumps compressors pressure relief devices sampling connection systems open-
ended valves or lines valves connectors surge control vessels bottoms receivers and control
devices or systems required by this subpart There are no affected sources having HAP
concentration equal to or greater than 10 by weight
NESHAP 40 CFR Part 63 [No Longer Applicable]
Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment
Leaks applies to pumps compressors agitators pressure relief devices sampling connection
systems open-ended valves or lines valves connectors surge control vessels bottoms receivers
instrumentation systems and control devices or closed vent systems required by this subpart that
are intended to operate in organic hazardous air pollutant service 300 hours or more during the
calendar year within a source subject to the provisions of a specific subpart in 40 CFR Part 63 that
references this subpart None of the affected sources contain or contact at least 5 percent by weight
of total organic HAP and the facility is becoming an ldquoareardquo source of HAP
Subpart DD National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations applies to any owner or operator of a plant that is a major source of
hazardous air pollutant (HAP) emissions as defined in 40 CFR sect632 having waste management
or recovery operations specified in sect63680(a)(2)(i) through (a)(2)(vi) that receive an offsite
material as specified in sectsect63680(b) The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart OO National Emission Standards for Tanks-Level 1 applies to the control of air
emissions from tanks for which another subpart of 40 CFR Parts 60 61 or 63 references the use
of this subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP
and will cease to be subject to this major source MACT
Subpart PP National Emission Standards for Containers applies to the control of air emissions
from containers for which another subpart of 40 CFR Parts 60 61 or 63 references the use of this
subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart RR National Emission Standards for Individual Drain Systems applies to the control of
air emissions from individual drain systems for which another subpart of 40 CFR Parts 60 61 or
63 references the use of this subpart for such air emission control At this time there are no transfer
systems that appear to meet the definition of an individual drain system as defined in this subpart
or in Subpart DD However as noted earlier this is contingent on the POTW not handling any
hazardous waste
Chemical Accident Prevention Provisions 40 CFR Part 68 [Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments) More information on this federal program
is available on the web page wwwepagovrmp
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 7 DRAFT
EU
ID
Point
ID EU Description and Service
Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Drummed wastes are also processed and treated at the facility Liquids from containers may be
pumped (EU-D1) into bulk containers prior to transfer to a tank at TF1 TF2 TF4 or prior to
shipment to an offsite facility
Containers of solid wastes may also be received at the facility for consolidation (EU-D2) into
larger containers (eg roll-off boxes) If required solids and liquids that have been neutralized or
decharacterized may be stabilized in EU-D3 containers roll-off boxes and the stabilization box
prior to transportation to an off-site disposal facility Solids can be treated in the drums by
solidification using a hydraulic drum mixer and an excavator similar to a backhoe with tracks
Treatment reagents include but are not limited to sodium sulfide ferrous sulfide cement kiln dust
fly ash and Portland cement to solidify and remove the hazardous characteristics of the contents
of the drums Containers are closed or covered when waste is not being added or removed from
the container Containers of liquid or solid wastes may also be temporarily stored at the facility
without repackaging prior to shipment to an offsite disposal facility
PERMIT MEMORANDUM 2019-0826-O 8 DRAFT
EUG E ndash POTW Disposal
Equipment andor emissions units included in this EUG and remaining at the facility are listed in
the following table
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
This operation has two stationary storage tanks POTW1 and POTW2 These tanks are for
wastewaters that meet the City of Tulsa - Industrial Wastewater Discharge Permit (POTW)
standards for discharge to the sanitary sewer after treatment at the facility and also for wastewater
received directly from offsite for disposal to the sewer if the material as received meets the sitersquos
discharge permit standards All wastewaters managed in this manner are tested to ensure
compliance with the permit prior to discharge into the sewer Tank POTW1 amp POTW2 will be
utilized for storm water storage No other operations for this waste treatment process are in place
at this time
SECTION III EMISSIONS
The facility has requested the following emissions limits based on an annual facility throughput of
44148 TPY of wastes
- 72 TPY VOC
- 72 TPY total HAP
- 58 TPY any one HAP
The treatment system at this facility consists of numerous tank systems (TF1 TF2 and TF4)
serving purposes of treatment (neutralization) accumulation separation temporary storage
filtering and discharge to the POTW or a tanker truck Storage tanks T101 T102 T103 and T107
are used as reactors to neutralize corrosive wastes The tanks are routinely filled with acidic wastes
at ambient temperatures and when an adequate inventory is achieved caustic is introduced to
neutralize the acid Each tankreactor has a top-mounted agitator installed to ensure complete
mixing of the reactants The shaft entrance is sealed to prevent emissions from this location The
neutralization is an exothermic reaction causing the mixture temperature to rise as high as 180deg
Fahrenheit
PERMIT MEMORANDUM 2019-0826-O 9 DRAFT
The tanks are connected by piping that provides various transferring scenarios and possibly re-
circulations between the tank systems For example one purpose of transferring wastes tofrom
tanks is to pass the wastes through filters for solids removal This is done by rolling the tanks ie
pumping wastes from one tank system into another allowing the waste to pass through in-line
filters installed in the transfer piping The tracking becomes more complex as volumes and VOC
content change to a new blend This makes the use of EPA TANKS a laborious method for
tracking emissions Note that this is not an implication that the facility is allowed to dilute
hazardous waste to meet a treatment standard A previous owner ACE committed to limiting
receipt of wastewaters containing less than 500 ppmw of VOC US Ecology agrees to the mass
balance described herein but with the exception that although VOC (not VOHAP) content may be
500 ppmw or greater the levels will be documented for emissions calculations VOHAP
concentrations are limited to less than 500 ppmw
An emissions calculation based on a VOC content of 500 ppmw assumes that 100 of all VOC in
the wastewaters ultimately evaporate as a result of physical changes that could affect the volatility
of the organics such as rolling the tanks temperature rises and agitation Based on the operations
at the facility under prevous owner ACE the maximum VOC-laden liquid waste throughput was
assumed to be the sum of the projected throughput rates of tanks P001 T101 T102 T103 and
T107 all in EUG A These tanks handle the main throughput of incoming wastewaters having
VOC andor VOHAP Immediately downstream of these tanks Tanks T203 and T204 are the
receivingaccumulation tanks Although emissions from the tanks in EUG A were controlled by
the carbon adsorber emissions from EUG B were not nor are emissions from the tanks now
receiving the treated wastes It was further assumed that the tanks did not treat or store wastes
containing VOC or VOHAP and that neither POTW1 nor POTW2 received VOC-containing
wastes Based on the rates submitted by the applicant the total liquid waste throughput would be
43589219 gallons per year Assuming an average wastewater density of 100 lbsgallon the
calculated emissions were approximately 109 tons-VOC per year Calculations using EPA
TANKS were based on a waste treatmentdisposal volume of 27000000 gallons per year emitting
269 tons per year of VOHAP with a PTE of 65 tons per year The mass balance approach would
be simpler and safer for all considering that the only data required for this calculation is incoming
waste volumes densities and VOC concentrations US Ecology has agreed to carry this method
forward with a limit of 72 TPY except that total VOC content may range higher than the VOHAP
limit provided that the facility will document the actual VOC content of the waste
FuelsHydrocarbon Bulking
The facility does bulking of liquid hydrocarbons and fuels Emissions of VOC are calculated using
Equation 1-29 AP-42 (1106) Section 7-111 The operator submitted calculations for a similar
operation at a facility in Detroit Michigan which they state is a bigger operation than the Tulsa
facility Based on an annual throughput of about 458000 gallons emissions were 1400 pounds
of VOC The equations and input parameters for calculating emissions are specified in the permit
PERMIT MEMORANDUM 2019-0826-O 10 DRAFT
Solids Bulking
The facility bulks solids materials Hazardous Non Hazardous and some Flammable Solids The
following formula is used to calculate emissions (Note VP for methanol is used)
W = Emissions (lbyr)
W = Qw X (1359) X 27315Tamb X VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3lb-mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
SECTION IV FEDERAL REGULATIONS
PSD 40 CFR Part 52 [Not Applicable]
PSD does not apply Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant and the facility is not one of the listed stationary sources with an emission
threshold of 100 TPY
NSPS 40 CFR Part 60 [Not Applicable]
Subpart Kb Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage
Vessels) for Which Construction Reconstruction or Modification Commenced After July 23
1984 This subpart does not apply to storage vessels with a capacity greater than or equal to 151
m3 (39890 US gallons) storing a liquid with a maximum true vapor pressure less than 35
kilopascals (05 psi) or with a capacity greater than or equal to 75 m3 (19813 US gallons) but less
than 151 m3 storing a liquid with a maximum true vapor pressure less than 150 kilopascals (2175
psi) There are no tanks meeting the 39890-gallon threshold The following tanks exceed the
19813-gallon threshold but will not store hydrocarbon liquids having a maximum true vapor
pressure of 150 kilopascals (2175 psi) or more Therefore there are no affected tanks at this
facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construct
Date
C2 T402 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C3 T403 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C14 T204 38000 gal (144 m3) Dish bottom and roof Wastewater 1996
E4 POTW1 25700 gal (97 m3) Flat bottom dome roof Wastewater 1996
E5 POTW2 22000 gal (83 m3) Flat bottom dome roof Wastewater 1996
PERMIT MEMORANDUM 2019-0826-O 11 DRAFT
NESHAP 40 CFR Part 61 [Not Applicable]
Subpart V National Emission Standard for Equipment Leaks (Fugitive Emission Sources) applies
to each of the following sources that are intended to operate in volatile hazardous air pollutant
(VHAP) service pumps compressors pressure relief devices sampling connection systems open-
ended valves or lines valves connectors surge control vessels bottoms receivers and control
devices or systems required by this subpart There are no affected sources having HAP
concentration equal to or greater than 10 by weight
NESHAP 40 CFR Part 63 [No Longer Applicable]
Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment
Leaks applies to pumps compressors agitators pressure relief devices sampling connection
systems open-ended valves or lines valves connectors surge control vessels bottoms receivers
instrumentation systems and control devices or closed vent systems required by this subpart that
are intended to operate in organic hazardous air pollutant service 300 hours or more during the
calendar year within a source subject to the provisions of a specific subpart in 40 CFR Part 63 that
references this subpart None of the affected sources contain or contact at least 5 percent by weight
of total organic HAP and the facility is becoming an ldquoareardquo source of HAP
Subpart DD National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations applies to any owner or operator of a plant that is a major source of
hazardous air pollutant (HAP) emissions as defined in 40 CFR sect632 having waste management
or recovery operations specified in sect63680(a)(2)(i) through (a)(2)(vi) that receive an offsite
material as specified in sectsect63680(b) The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart OO National Emission Standards for Tanks-Level 1 applies to the control of air
emissions from tanks for which another subpart of 40 CFR Parts 60 61 or 63 references the use
of this subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP
and will cease to be subject to this major source MACT
Subpart PP National Emission Standards for Containers applies to the control of air emissions
from containers for which another subpart of 40 CFR Parts 60 61 or 63 references the use of this
subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart RR National Emission Standards for Individual Drain Systems applies to the control of
air emissions from individual drain systems for which another subpart of 40 CFR Parts 60 61 or
63 references the use of this subpart for such air emission control At this time there are no transfer
systems that appear to meet the definition of an individual drain system as defined in this subpart
or in Subpart DD However as noted earlier this is contingent on the POTW not handling any
hazardous waste
Chemical Accident Prevention Provisions 40 CFR Part 68 [Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments) More information on this federal program
is available on the web page wwwepagovrmp
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 8 DRAFT
EUG E ndash POTW Disposal
Equipment andor emissions units included in this EUG and remaining at the facility are listed in
the following table
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
This operation has two stationary storage tanks POTW1 and POTW2 These tanks are for
wastewaters that meet the City of Tulsa - Industrial Wastewater Discharge Permit (POTW)
standards for discharge to the sanitary sewer after treatment at the facility and also for wastewater
received directly from offsite for disposal to the sewer if the material as received meets the sitersquos
discharge permit standards All wastewaters managed in this manner are tested to ensure
compliance with the permit prior to discharge into the sewer Tank POTW1 amp POTW2 will be
utilized for storm water storage No other operations for this waste treatment process are in place
at this time
SECTION III EMISSIONS
The facility has requested the following emissions limits based on an annual facility throughput of
44148 TPY of wastes
- 72 TPY VOC
- 72 TPY total HAP
- 58 TPY any one HAP
The treatment system at this facility consists of numerous tank systems (TF1 TF2 and TF4)
serving purposes of treatment (neutralization) accumulation separation temporary storage
filtering and discharge to the POTW or a tanker truck Storage tanks T101 T102 T103 and T107
are used as reactors to neutralize corrosive wastes The tanks are routinely filled with acidic wastes
at ambient temperatures and when an adequate inventory is achieved caustic is introduced to
neutralize the acid Each tankreactor has a top-mounted agitator installed to ensure complete
mixing of the reactants The shaft entrance is sealed to prevent emissions from this location The
neutralization is an exothermic reaction causing the mixture temperature to rise as high as 180deg
Fahrenheit
PERMIT MEMORANDUM 2019-0826-O 9 DRAFT
The tanks are connected by piping that provides various transferring scenarios and possibly re-
circulations between the tank systems For example one purpose of transferring wastes tofrom
tanks is to pass the wastes through filters for solids removal This is done by rolling the tanks ie
pumping wastes from one tank system into another allowing the waste to pass through in-line
filters installed in the transfer piping The tracking becomes more complex as volumes and VOC
content change to a new blend This makes the use of EPA TANKS a laborious method for
tracking emissions Note that this is not an implication that the facility is allowed to dilute
hazardous waste to meet a treatment standard A previous owner ACE committed to limiting
receipt of wastewaters containing less than 500 ppmw of VOC US Ecology agrees to the mass
balance described herein but with the exception that although VOC (not VOHAP) content may be
500 ppmw or greater the levels will be documented for emissions calculations VOHAP
concentrations are limited to less than 500 ppmw
An emissions calculation based on a VOC content of 500 ppmw assumes that 100 of all VOC in
the wastewaters ultimately evaporate as a result of physical changes that could affect the volatility
of the organics such as rolling the tanks temperature rises and agitation Based on the operations
at the facility under prevous owner ACE the maximum VOC-laden liquid waste throughput was
assumed to be the sum of the projected throughput rates of tanks P001 T101 T102 T103 and
T107 all in EUG A These tanks handle the main throughput of incoming wastewaters having
VOC andor VOHAP Immediately downstream of these tanks Tanks T203 and T204 are the
receivingaccumulation tanks Although emissions from the tanks in EUG A were controlled by
the carbon adsorber emissions from EUG B were not nor are emissions from the tanks now
receiving the treated wastes It was further assumed that the tanks did not treat or store wastes
containing VOC or VOHAP and that neither POTW1 nor POTW2 received VOC-containing
wastes Based on the rates submitted by the applicant the total liquid waste throughput would be
43589219 gallons per year Assuming an average wastewater density of 100 lbsgallon the
calculated emissions were approximately 109 tons-VOC per year Calculations using EPA
TANKS were based on a waste treatmentdisposal volume of 27000000 gallons per year emitting
269 tons per year of VOHAP with a PTE of 65 tons per year The mass balance approach would
be simpler and safer for all considering that the only data required for this calculation is incoming
waste volumes densities and VOC concentrations US Ecology has agreed to carry this method
forward with a limit of 72 TPY except that total VOC content may range higher than the VOHAP
limit provided that the facility will document the actual VOC content of the waste
FuelsHydrocarbon Bulking
The facility does bulking of liquid hydrocarbons and fuels Emissions of VOC are calculated using
Equation 1-29 AP-42 (1106) Section 7-111 The operator submitted calculations for a similar
operation at a facility in Detroit Michigan which they state is a bigger operation than the Tulsa
facility Based on an annual throughput of about 458000 gallons emissions were 1400 pounds
of VOC The equations and input parameters for calculating emissions are specified in the permit
PERMIT MEMORANDUM 2019-0826-O 10 DRAFT
Solids Bulking
The facility bulks solids materials Hazardous Non Hazardous and some Flammable Solids The
following formula is used to calculate emissions (Note VP for methanol is used)
W = Emissions (lbyr)
W = Qw X (1359) X 27315Tamb X VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3lb-mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
SECTION IV FEDERAL REGULATIONS
PSD 40 CFR Part 52 [Not Applicable]
PSD does not apply Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant and the facility is not one of the listed stationary sources with an emission
threshold of 100 TPY
NSPS 40 CFR Part 60 [Not Applicable]
Subpart Kb Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage
Vessels) for Which Construction Reconstruction or Modification Commenced After July 23
1984 This subpart does not apply to storage vessels with a capacity greater than or equal to 151
m3 (39890 US gallons) storing a liquid with a maximum true vapor pressure less than 35
kilopascals (05 psi) or with a capacity greater than or equal to 75 m3 (19813 US gallons) but less
than 151 m3 storing a liquid with a maximum true vapor pressure less than 150 kilopascals (2175
psi) There are no tanks meeting the 39890-gallon threshold The following tanks exceed the
19813-gallon threshold but will not store hydrocarbon liquids having a maximum true vapor
pressure of 150 kilopascals (2175 psi) or more Therefore there are no affected tanks at this
facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construct
Date
C2 T402 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C3 T403 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C14 T204 38000 gal (144 m3) Dish bottom and roof Wastewater 1996
E4 POTW1 25700 gal (97 m3) Flat bottom dome roof Wastewater 1996
E5 POTW2 22000 gal (83 m3) Flat bottom dome roof Wastewater 1996
PERMIT MEMORANDUM 2019-0826-O 11 DRAFT
NESHAP 40 CFR Part 61 [Not Applicable]
Subpart V National Emission Standard for Equipment Leaks (Fugitive Emission Sources) applies
to each of the following sources that are intended to operate in volatile hazardous air pollutant
(VHAP) service pumps compressors pressure relief devices sampling connection systems open-
ended valves or lines valves connectors surge control vessels bottoms receivers and control
devices or systems required by this subpart There are no affected sources having HAP
concentration equal to or greater than 10 by weight
NESHAP 40 CFR Part 63 [No Longer Applicable]
Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment
Leaks applies to pumps compressors agitators pressure relief devices sampling connection
systems open-ended valves or lines valves connectors surge control vessels bottoms receivers
instrumentation systems and control devices or closed vent systems required by this subpart that
are intended to operate in organic hazardous air pollutant service 300 hours or more during the
calendar year within a source subject to the provisions of a specific subpart in 40 CFR Part 63 that
references this subpart None of the affected sources contain or contact at least 5 percent by weight
of total organic HAP and the facility is becoming an ldquoareardquo source of HAP
Subpart DD National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations applies to any owner or operator of a plant that is a major source of
hazardous air pollutant (HAP) emissions as defined in 40 CFR sect632 having waste management
or recovery operations specified in sect63680(a)(2)(i) through (a)(2)(vi) that receive an offsite
material as specified in sectsect63680(b) The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart OO National Emission Standards for Tanks-Level 1 applies to the control of air
emissions from tanks for which another subpart of 40 CFR Parts 60 61 or 63 references the use
of this subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP
and will cease to be subject to this major source MACT
Subpart PP National Emission Standards for Containers applies to the control of air emissions
from containers for which another subpart of 40 CFR Parts 60 61 or 63 references the use of this
subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart RR National Emission Standards for Individual Drain Systems applies to the control of
air emissions from individual drain systems for which another subpart of 40 CFR Parts 60 61 or
63 references the use of this subpart for such air emission control At this time there are no transfer
systems that appear to meet the definition of an individual drain system as defined in this subpart
or in Subpart DD However as noted earlier this is contingent on the POTW not handling any
hazardous waste
Chemical Accident Prevention Provisions 40 CFR Part 68 [Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments) More information on this federal program
is available on the web page wwwepagovrmp
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 9 DRAFT
The tanks are connected by piping that provides various transferring scenarios and possibly re-
circulations between the tank systems For example one purpose of transferring wastes tofrom
tanks is to pass the wastes through filters for solids removal This is done by rolling the tanks ie
pumping wastes from one tank system into another allowing the waste to pass through in-line
filters installed in the transfer piping The tracking becomes more complex as volumes and VOC
content change to a new blend This makes the use of EPA TANKS a laborious method for
tracking emissions Note that this is not an implication that the facility is allowed to dilute
hazardous waste to meet a treatment standard A previous owner ACE committed to limiting
receipt of wastewaters containing less than 500 ppmw of VOC US Ecology agrees to the mass
balance described herein but with the exception that although VOC (not VOHAP) content may be
500 ppmw or greater the levels will be documented for emissions calculations VOHAP
concentrations are limited to less than 500 ppmw
An emissions calculation based on a VOC content of 500 ppmw assumes that 100 of all VOC in
the wastewaters ultimately evaporate as a result of physical changes that could affect the volatility
of the organics such as rolling the tanks temperature rises and agitation Based on the operations
at the facility under prevous owner ACE the maximum VOC-laden liquid waste throughput was
assumed to be the sum of the projected throughput rates of tanks P001 T101 T102 T103 and
T107 all in EUG A These tanks handle the main throughput of incoming wastewaters having
VOC andor VOHAP Immediately downstream of these tanks Tanks T203 and T204 are the
receivingaccumulation tanks Although emissions from the tanks in EUG A were controlled by
the carbon adsorber emissions from EUG B were not nor are emissions from the tanks now
receiving the treated wastes It was further assumed that the tanks did not treat or store wastes
containing VOC or VOHAP and that neither POTW1 nor POTW2 received VOC-containing
wastes Based on the rates submitted by the applicant the total liquid waste throughput would be
43589219 gallons per year Assuming an average wastewater density of 100 lbsgallon the
calculated emissions were approximately 109 tons-VOC per year Calculations using EPA
TANKS were based on a waste treatmentdisposal volume of 27000000 gallons per year emitting
269 tons per year of VOHAP with a PTE of 65 tons per year The mass balance approach would
be simpler and safer for all considering that the only data required for this calculation is incoming
waste volumes densities and VOC concentrations US Ecology has agreed to carry this method
forward with a limit of 72 TPY except that total VOC content may range higher than the VOHAP
limit provided that the facility will document the actual VOC content of the waste
FuelsHydrocarbon Bulking
The facility does bulking of liquid hydrocarbons and fuels Emissions of VOC are calculated using
Equation 1-29 AP-42 (1106) Section 7-111 The operator submitted calculations for a similar
operation at a facility in Detroit Michigan which they state is a bigger operation than the Tulsa
facility Based on an annual throughput of about 458000 gallons emissions were 1400 pounds
of VOC The equations and input parameters for calculating emissions are specified in the permit
PERMIT MEMORANDUM 2019-0826-O 10 DRAFT
Solids Bulking
The facility bulks solids materials Hazardous Non Hazardous and some Flammable Solids The
following formula is used to calculate emissions (Note VP for methanol is used)
W = Emissions (lbyr)
W = Qw X (1359) X 27315Tamb X VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3lb-mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
SECTION IV FEDERAL REGULATIONS
PSD 40 CFR Part 52 [Not Applicable]
PSD does not apply Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant and the facility is not one of the listed stationary sources with an emission
threshold of 100 TPY
NSPS 40 CFR Part 60 [Not Applicable]
Subpart Kb Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage
Vessels) for Which Construction Reconstruction or Modification Commenced After July 23
1984 This subpart does not apply to storage vessels with a capacity greater than or equal to 151
m3 (39890 US gallons) storing a liquid with a maximum true vapor pressure less than 35
kilopascals (05 psi) or with a capacity greater than or equal to 75 m3 (19813 US gallons) but less
than 151 m3 storing a liquid with a maximum true vapor pressure less than 150 kilopascals (2175
psi) There are no tanks meeting the 39890-gallon threshold The following tanks exceed the
19813-gallon threshold but will not store hydrocarbon liquids having a maximum true vapor
pressure of 150 kilopascals (2175 psi) or more Therefore there are no affected tanks at this
facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construct
Date
C2 T402 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C3 T403 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C14 T204 38000 gal (144 m3) Dish bottom and roof Wastewater 1996
E4 POTW1 25700 gal (97 m3) Flat bottom dome roof Wastewater 1996
E5 POTW2 22000 gal (83 m3) Flat bottom dome roof Wastewater 1996
PERMIT MEMORANDUM 2019-0826-O 11 DRAFT
NESHAP 40 CFR Part 61 [Not Applicable]
Subpart V National Emission Standard for Equipment Leaks (Fugitive Emission Sources) applies
to each of the following sources that are intended to operate in volatile hazardous air pollutant
(VHAP) service pumps compressors pressure relief devices sampling connection systems open-
ended valves or lines valves connectors surge control vessels bottoms receivers and control
devices or systems required by this subpart There are no affected sources having HAP
concentration equal to or greater than 10 by weight
NESHAP 40 CFR Part 63 [No Longer Applicable]
Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment
Leaks applies to pumps compressors agitators pressure relief devices sampling connection
systems open-ended valves or lines valves connectors surge control vessels bottoms receivers
instrumentation systems and control devices or closed vent systems required by this subpart that
are intended to operate in organic hazardous air pollutant service 300 hours or more during the
calendar year within a source subject to the provisions of a specific subpart in 40 CFR Part 63 that
references this subpart None of the affected sources contain or contact at least 5 percent by weight
of total organic HAP and the facility is becoming an ldquoareardquo source of HAP
Subpart DD National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations applies to any owner or operator of a plant that is a major source of
hazardous air pollutant (HAP) emissions as defined in 40 CFR sect632 having waste management
or recovery operations specified in sect63680(a)(2)(i) through (a)(2)(vi) that receive an offsite
material as specified in sectsect63680(b) The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart OO National Emission Standards for Tanks-Level 1 applies to the control of air
emissions from tanks for which another subpart of 40 CFR Parts 60 61 or 63 references the use
of this subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP
and will cease to be subject to this major source MACT
Subpart PP National Emission Standards for Containers applies to the control of air emissions
from containers for which another subpart of 40 CFR Parts 60 61 or 63 references the use of this
subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart RR National Emission Standards for Individual Drain Systems applies to the control of
air emissions from individual drain systems for which another subpart of 40 CFR Parts 60 61 or
63 references the use of this subpart for such air emission control At this time there are no transfer
systems that appear to meet the definition of an individual drain system as defined in this subpart
or in Subpart DD However as noted earlier this is contingent on the POTW not handling any
hazardous waste
Chemical Accident Prevention Provisions 40 CFR Part 68 [Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments) More information on this federal program
is available on the web page wwwepagovrmp
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 10 DRAFT
Solids Bulking
The facility bulks solids materials Hazardous Non Hazardous and some Flammable Solids The
following formula is used to calculate emissions (Note VP for methanol is used)
W = Emissions (lbyr)
W = Qw X (1359) X 27315Tamb X VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3lb-mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
SECTION IV FEDERAL REGULATIONS
PSD 40 CFR Part 52 [Not Applicable]
PSD does not apply Final total emissions are less than the threshold of 250 TPY of any single
regulated pollutant and the facility is not one of the listed stationary sources with an emission
threshold of 100 TPY
NSPS 40 CFR Part 60 [Not Applicable]
Subpart Kb Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage
Vessels) for Which Construction Reconstruction or Modification Commenced After July 23
1984 This subpart does not apply to storage vessels with a capacity greater than or equal to 151
m3 (39890 US gallons) storing a liquid with a maximum true vapor pressure less than 35
kilopascals (05 psi) or with a capacity greater than or equal to 75 m3 (19813 US gallons) but less
than 151 m3 storing a liquid with a maximum true vapor pressure less than 150 kilopascals (2175
psi) There are no tanks meeting the 39890-gallon threshold The following tanks exceed the
19813-gallon threshold but will not store hydrocarbon liquids having a maximum true vapor
pressure of 150 kilopascals (2175 psi) or more Therefore there are no affected tanks at this
facility
EU
ID
Point
ID
EU Description
SizeTypeService
Construct
Date
C2 T402 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C3 T403 27800 gal (105 m3) Flat bottom cone roof Wastewater 1996
C14 T204 38000 gal (144 m3) Dish bottom and roof Wastewater 1996
E4 POTW1 25700 gal (97 m3) Flat bottom dome roof Wastewater 1996
E5 POTW2 22000 gal (83 m3) Flat bottom dome roof Wastewater 1996
PERMIT MEMORANDUM 2019-0826-O 11 DRAFT
NESHAP 40 CFR Part 61 [Not Applicable]
Subpart V National Emission Standard for Equipment Leaks (Fugitive Emission Sources) applies
to each of the following sources that are intended to operate in volatile hazardous air pollutant
(VHAP) service pumps compressors pressure relief devices sampling connection systems open-
ended valves or lines valves connectors surge control vessels bottoms receivers and control
devices or systems required by this subpart There are no affected sources having HAP
concentration equal to or greater than 10 by weight
NESHAP 40 CFR Part 63 [No Longer Applicable]
Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment
Leaks applies to pumps compressors agitators pressure relief devices sampling connection
systems open-ended valves or lines valves connectors surge control vessels bottoms receivers
instrumentation systems and control devices or closed vent systems required by this subpart that
are intended to operate in organic hazardous air pollutant service 300 hours or more during the
calendar year within a source subject to the provisions of a specific subpart in 40 CFR Part 63 that
references this subpart None of the affected sources contain or contact at least 5 percent by weight
of total organic HAP and the facility is becoming an ldquoareardquo source of HAP
Subpart DD National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations applies to any owner or operator of a plant that is a major source of
hazardous air pollutant (HAP) emissions as defined in 40 CFR sect632 having waste management
or recovery operations specified in sect63680(a)(2)(i) through (a)(2)(vi) that receive an offsite
material as specified in sectsect63680(b) The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart OO National Emission Standards for Tanks-Level 1 applies to the control of air
emissions from tanks for which another subpart of 40 CFR Parts 60 61 or 63 references the use
of this subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP
and will cease to be subject to this major source MACT
Subpart PP National Emission Standards for Containers applies to the control of air emissions
from containers for which another subpart of 40 CFR Parts 60 61 or 63 references the use of this
subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart RR National Emission Standards for Individual Drain Systems applies to the control of
air emissions from individual drain systems for which another subpart of 40 CFR Parts 60 61 or
63 references the use of this subpart for such air emission control At this time there are no transfer
systems that appear to meet the definition of an individual drain system as defined in this subpart
or in Subpart DD However as noted earlier this is contingent on the POTW not handling any
hazardous waste
Chemical Accident Prevention Provisions 40 CFR Part 68 [Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments) More information on this federal program
is available on the web page wwwepagovrmp
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 11 DRAFT
NESHAP 40 CFR Part 61 [Not Applicable]
Subpart V National Emission Standard for Equipment Leaks (Fugitive Emission Sources) applies
to each of the following sources that are intended to operate in volatile hazardous air pollutant
(VHAP) service pumps compressors pressure relief devices sampling connection systems open-
ended valves or lines valves connectors surge control vessels bottoms receivers and control
devices or systems required by this subpart There are no affected sources having HAP
concentration equal to or greater than 10 by weight
NESHAP 40 CFR Part 63 [No Longer Applicable]
Subpart H National Emission Standards for Organic Hazardous Air Pollutants for Equipment
Leaks applies to pumps compressors agitators pressure relief devices sampling connection
systems open-ended valves or lines valves connectors surge control vessels bottoms receivers
instrumentation systems and control devices or closed vent systems required by this subpart that
are intended to operate in organic hazardous air pollutant service 300 hours or more during the
calendar year within a source subject to the provisions of a specific subpart in 40 CFR Part 63 that
references this subpart None of the affected sources contain or contact at least 5 percent by weight
of total organic HAP and the facility is becoming an ldquoareardquo source of HAP
Subpart DD National Emission Standards for Hazardous Air Pollutants from Off-Site Waste and
Recovery Operations applies to any owner or operator of a plant that is a major source of
hazardous air pollutant (HAP) emissions as defined in 40 CFR sect632 having waste management
or recovery operations specified in sect63680(a)(2)(i) through (a)(2)(vi) that receive an offsite
material as specified in sectsect63680(b) The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart OO National Emission Standards for Tanks-Level 1 applies to the control of air
emissions from tanks for which another subpart of 40 CFR Parts 60 61 or 63 references the use
of this subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP
and will cease to be subject to this major source MACT
Subpart PP National Emission Standards for Containers applies to the control of air emissions
from containers for which another subpart of 40 CFR Parts 60 61 or 63 references the use of this
subpart for such air emission control The facility is becoming an ldquoareardquo source of HAP and will
cease to be subject to this major source MACT
Subpart RR National Emission Standards for Individual Drain Systems applies to the control of
air emissions from individual drain systems for which another subpart of 40 CFR Parts 60 61 or
63 references the use of this subpart for such air emission control At this time there are no transfer
systems that appear to meet the definition of an individual drain system as defined in this subpart
or in Subpart DD However as noted earlier this is contingent on the POTW not handling any
hazardous waste
Chemical Accident Prevention Provisions 40 CFR Part 68 [Not Applicable]
This facility will not process or store more than the threshold quantity of any regulated substance
(Section 112r of the Clean Air Act 1990 Amendments) More information on this federal program
is available on the web page wwwepagovrmp
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 12 DRAFT
Stratospheric Ozone Protection 40 CFR Part 82 [Subparts A and F are Applicable]
These standards require phase out of Class I amp II substances reductions of emissions of Class I amp
II substances to the lowest achievable level in all use sectors and banning use of nonessential
products containing ozone-depleting substances (Subparts A amp C) control servicing of motor
vehicle air conditioners (Subpart B) require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D) require warning labels on products made with or
containing Class I or II substances (Subpart E) maximize the use of recycling and recovery upon
disposal (Subpart F) require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G) and reduce the emissions of halons
(Subpart H)
Subpart A identifies ozone-depleting substances and divides them into two classes Class I
controlled substances are divided into seven groups the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I Group IV) and methyl chloroform
(Class I Group V) A complete phase-out of production of Class I substances is required by
January 1 2000 (January 1 2002 for methyl chloroform) Class II chemicals which are
hydrochlorofluorocarbons (HCFCs) are generally seen as interim substitutes for Class I CFCs
Class II substances consist of 33 HCFCs A complete phase-out of Class II substances scheduled
in phases starting by 2002 is required by January 1 2030
Subpart F requires that any persons servicing maintaining or repairing appliances except for
motor vehicle air conditioners persons disposing of appliances including motor vehicle air
conditioners refrigerant reclaimers appliance owners and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction
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 that 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
SECTION V OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252100-1 (General Provisions) [Applicable]
Subchapter 1 includes definitions but there are no regulatory requirements
OAC 252100-2 (Incorporation by Reference) [Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal
Regulations listed in OAC 252100 Appendix Q These requirements are addressed in the
ldquoFederal Regulationsrdquo section
OAC 252100-3 (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 ldquoattainmentrdquo of these
standards
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 13 DRAFT
OAC 252100-5 (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 252100-7 (Permits for Minor Facilities) [Applicable]
This facility will qualify as a minor source after issuance of this permit because total emissions of
each criteria pollutant do not exceed 100 TPY and HAP emissions do not exceed the 10 TPY for
any one HAP or 25 TPY for any aggregate of HAP
OAC 252100-8 (Permits for Part 70 Sources) [Not Applicable]
This facility is ceasing to meet the definition of a major source since it no longer has the potential
to emit regulated pollutants in excess of 10 TPY of a single HAP As such a Title V (Part 70)
operating permit is no longer required
OAC 252100-9 (Excess Emission Reporting Requirements) [Applicable]
Except as provided in OAC 252100-9-7(a)(1) the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 430 pm the following
working day of the first occurrence of excess emissions in each excess emission event No later
than thirty (30) calendar days after the start of any excess emission event the owner or operator of
an air contaminant source from which excess emissions have occurred shall submit a report for
each excess emission event describing the extent of the event and the actions taken by the owner
or operator of the facility in response to this event Request for mitigation as described in OAC
252100-9-8 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 252100-13 (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 252100-19 (Particulate Matter (PM)) [Not Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment with
emission limits based on maximum design heat input rating Fuel-burning equipment is defined
in OAC 252100-19 as any internal combustion engine or gas turbine or other combustion device
used to convert the combustion of fuel into usable energy There is no fuel-burning equipment at
this facility
Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units
and emission points in an industrial process based on process weight rate as specified in Appendix
G There are no emission points at this facility that are subject to this requirement
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 14 DRAFT
OAC 252100-25 (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 The facility is subject to these requirements but there are no processes at this facility
expected to have emissions at the level that would exhibit opacity
OAC 252100-29 (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 252100-31 (Sulfur Compounds) [Not Applicable]
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1
1972) For gaseous fuels the limit is 02 lbMMBTU heat input averaged over 3 hours There is
no fuel-burning equipment at this facility
Part 5 also limits hydrogen sulfide (H2S) emissions from new petroleum or natural gas process
equipment (constructed after July 1 1972) Removal of H2S in the exhaust stream or oxidation
to sulfur dioxide (SO2) is required unless H2S emissions would be less than 03 lbhr for a two-
hour average H2S emissions shall be reduced by a minimum of 95 of the H2S in the exhaust
gas Direct oxidation of H2S is allowed for units whose emissions would be less than 100 lbhr of
SO2 for a two-hour average There is no petroleum or natural gas process equipment at this facility
Additionally there are no processes that will generate H2S emissions
OAC 252100-33 (Nitrogen Oxides) [Not Applicable]
This subchapter limits new gas-firedliquid-firedsolid fossil fuel-burning equipment with rated
heat input greater than or equal to 50 MMBTUH to emissions of 020030070 lbs of NOX per
MMBTU three-hour average There are no equipment items that exceed the 50 MMBTUH
threshold
OAC 252100-35 (Carbon Monoxide) [Not Applicable]
This subchapter affects gray iron cupolas blast furnaces basic oxygen furnaces petroleum
catalytic cracking units and petroleum catalytic reforming units It requires removal of 93 or
more of CO by ldquocomplete secondary combustionrdquo from new sources and also from existing sources
located in or significantly impacting a non-attainment area for CO There are no affected sources
at this facility
OAC 252100-37 (Volatile Organic Compounds) [Part 3 and Part 7 Applicable]
Part 3 requires storage tanks with a capacity of 400 gallons or more and storing a VOC with a
vapor pressure greater than 15 psia to be equipped with a permanent submerged fill pipe or with
an organic vapor recovery system
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 15 DRAFT
The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater and Tanks T203 T204 T402 T403 and
T404 are all submerged fill
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 VOC
emissions Temperature and available air must be sufficient to provide essentially complete
combustion There is no fuel-burning equipment at this facility
Part 7 also regulates effluent water separators that receive water containing more than 200 gallons
per day of VOC Tank T406 is used for separation of insoluble oils from wastewaters and also
receives wastewaters containing soluble VOC It is exempt from this rule as it does not receive
VOC having a vapor pressure of 15 psia or greater
OAC 252100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]
This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of
organic materials from new and existing facilities in Tulsa and Oklahoma Counties However
sect252100-39-4 exempts all VOCs with less than 15 psia vapor pressure from the sect39-41
requirements
Part 7 covers Specific Operations
sect39-41(b)(1) requires storage tanks with a capacity of 400 gallons or more but less than 40000
gallons and storing a VOC with a vapor pressure greater than 15 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system This is not applicable if
the VOC vapor pressure is less than 15 psia The facility will not accept into tanks for storage
andor treatment any VOC containing waste stream with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(b)(2) requires major sources having an average daily throughput of 30000 gallons to have a
vapor recovery and control system This is not applicable if the VOC vapor pressure is less than 15
psia The facility will not accept any VOC containing waste stream into tanks for storage andor
treatment with a Vapor Pressure of 15 (PSIA) or greater
sect39-41(e) applies only in Tulsa County As noted for Subchapter 37 the same exemptions apply
Additional controls may be needed for VOC transport vessels as well as additional requirements
for testing and certifications sect39-41-1(e) monitoring would apply to affected transport vessels
This is not applicable if the VOC vapor pressure is less than 15 psia The facility will not accept
any VOC containing waste stream into tanks for storage andor treatment with a Vapor Pressure
of 15 (PSIA) or greater
OAC 252100-42 (Toxic Air Contaminants (TAC)) [Applicable]
This subchapter regulates 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
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 16 DRAFT
OAC 252100-43 (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 Pollution Control Rules are not applicable to this facility
Non-applicable Oklahoma Air Pollution Control Rules
OAC 252100-11 Alternative Reduction not eligible
OAC 252100-15 Mobile Sources not in source category
OAC 252100-17 Incinerators not type of emission unit
OAC 252100-23 Cotton Gins not type of emission unit
OAC 252100-24 Feed amp Grain Facility not in source category
OAC 252100-47 Landfills not type of source category
SECTION VI COMPLIANCE
Tier Classification And Public Review
This application has been determined to be a Tier II based on being the request for a ldquosignificantrdquo
modification to a Title V operating permit The ldquoNotice of Filing Tier II Applicationrdquo was
published in the Tulsa World on August 25 2019 The notice stated that the application was
available for review at the facility and at the DEQ Tulsa office The applicant will also publish a
ldquoNotice of Tier II Draft Permitrdquo
The facility is not located within 50 miles of the border between Oklahoma and any other state
The ldquoproposedrdquo permit will be submitted to EPA for a 45-day review period
Information on all permit actions is available for review by the public in the Air Quality section of
the DEQ Web page at httpwwwdeqokgov
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PERMIT MEMORANDUM 2019-0826-O 17 DRAFT
Fee Paid
Part 70 permit ldquosignificantrdquo modification fee of $6000
Inspection
The facility was inspected on October 25 2019 by Corey Gum of the Regional Office at Tulsa
No current Enforcement cases are pending for the facility
SECTION VII SUMMARY
The facility was constructed and operated as described in the permit application Ambient air
quality standards are not threatened at this site There are no active Air Quality compliance or
enforcement issues that would affect the issuance of this permit Issuance of the operating permit
is recommended contingent on public and EPA review
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
US Ecology Tulsa Inc Permit Number 2019-0826-O
Treatment Storage Disposal Facility
The permittee is authorized to operate in conformity with the specifications in the application
submitted to Air Quality on July 17 2019 The Evaluation Memorandum dated October 21 2019
explains the derivation of applicable permit requirements and estimates of emissions however it
does not contain operating limitations or permit requirements Continuing operations under this
permit constitutes acceptance of and consent to the conditions contained herein
1 Points of emission and emission limitations
A Emissions of volatile organic compounds (VOC) including volatile organic hazardous air
pollutants (VOHAP) shall not exceed 72 TPY 12-month rolling cumulative Emissions
of VOHAP shall not exceed 58 TPY of any one VOHAP or 58 TPY total of all VOHAP
12-month rolling cumulative Emissions of VOC and VOHAP shall be based on 100
evaporation of the VOC and VOHAP concentrations in the waste streams except when
amounts of VOC and VOHAP may be demonstrated on any discharge from the facility
(eg to the City of Tulsa POTW) Total waste throughput shall not exceed 44148 tons per
year 12-month rolling total
B For the fuels and liquid hydrocarbon bulking operation and the solids bulking operation
emissions shall be based on the following methods
Fuels and Liquid Hydrocarbon Bulking
LW = 00010 MV PVA Q K N K P
where
LW = working loss lbyr
MV = vapor molecular weight lblb-mole see Note 1 to Equation 1-21
PVA = vapor pressure at daily average liquid surface temperature psia
Q = annual net throughput (tank capacity [bbl] times annual turnover rate) bblyr
KN = working loss turnover (saturation) factor dimensionless
for turnovers gt36 KN = (180 + N)6N
for turnovers le36 KN = 1
N = number of turnovers per year dimensionless
N = 5614 QVLX
where
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
SPECIFIC CONDITIONS 2019-0826-O 2 DRAFT
VLX = tank maximum liquid volume ft3
VLX = π4 D2 HLX
where
D = diameter ft
HLX = maximum liquid height ft
KP = working loss product factor dimensionless
for crude oils KP = 075
for all other organic liquids KP = 1
Solids Bulking
W = Emissions (lbyr)
W = Qw (1359) 27315Tamb x VPamb760 X MW
QW = Waste Throughput (ft3yr) gas
Tamb = Ambient Temperature (K)
VPamb =Ambient Vapor Pressure (mm Hg)
MW = Molecular Weight (lblbmol)
359 = Gas Volume constant at STP (ft3mole)
27315 = Standard Temperature in K
760 = Standard Pressure (mm Hg)
2 Affected Authorized Equipment
EUG A ndash Treatment of Characteristic Hazardous Wastewater
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
Tank Farm 1 (TF1)
A1 Tank
P001
20rsquo H x 14rsquo dia 16000 gal (61 m3)
Flat bottom cone roof
Caustic liquids reagents and beneficial reuse
2014
A2 Tank
T101
18rsquo H x 12rsquo dia +2rsquo dish cone bottom 16900 gal (64 m3)
Flat roof with top mounted mixer
Waste water (acidcaustic neutralization)
2014
A3 Tank
T102
15rsquo H x 14rsquo dia + 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
A4 Tank
T103
15rsquo H x 14rsquo dia plus 5rsquo cone bottom 19190 gal (73 m3)
Flat roof with top-mounted mixer Palmer Tank Co
Wastewater (acidcaustic neutralization)
2007
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
SPECIFIC CONDITIONS 2019-0826-O 3 DRAFT
EU
ID
Point
ID
EU Description
SizeTypeService
Construction
Date
A5 Tank
T107
20rsquo H x 6rsquo dia plus 833rsquo cone bottom 12000 gal(454
m3) Flat roof with top-mounted mixer Wastewater
(acidcaustic neutralization)
1996
A8
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Treatment Tanks
Area
1996-2007
A9
Transfer
System
TF1
Tanks Piping Transfer Pumps Connections and
appurtenances included in the TF1 tank system 1996-2007
EUG C - Treatment Of Non-Hazardous Wastewater
EU
ID
Point
ID
EU Description and Service Construction
Date
C1 BF1 Rosedale Multiple-Bag Filter 2007
Tank Farm TF4 (TF4)
C2 T402
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C3 T403
24rsquo 2rdquo H x 14rsquo dia 27800 gal (105 m3)
Flat bottom cone roof
Wastewater
1996
C4 T404 16rsquo 3rdquo H x 13rsquo dia 16100 gal (61 m3)
Cone bottom with skirt cone roof 1996
C5 T405
17rsquo H x 8rsquo dia 6400 gal (24 m3)
Dish bottom dish head
Virgin diesel fuel
1996
C6 T406
14rsquo 2rdquo H x 8rsquo dia 2rsquo cone bottom 5300 gal (20 m3)
Cone roof
Insoluble Oils
1996
C7 BF2 Rosedale Multiple-Bag Filter 2006
C9 FP3 Filter press 2015
C10 FP4 amp
FP5
Filter press 2011
Tank Farm 2 (TF2)
C11 TL1 Bulk tanker loading 1996
C12 T203
20rsquo H x 12rsquo dia dish bottom 16800 gal (64 m3)
Cone roof
Wastewater
1996
C13
Fugitive emissions from ancillary equipment piping
valves flanges connectors and pumps in Processing Tanks
Area
1996-2007
C14 T204
33rsquo H x 14rsquo dia 38000 gal (144 m3)
Dish bottom and roof
Wastewater
1996
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
SPECIFIC CONDITIONS 2019-0826-O 4 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
C15
Transfer
System
TF4
Tanks Piping Transfer Pumps Filters Connections and
appurtenances and included in the TF4 tank system 1996-2007
C16
Transfer
System
TF2
Tanks Piping Transfer Pumps Connections and
appurtenances and included in the TF2 tank system 1996-2007
C18 T301
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C19 T302
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
C20 T303
16rsquo H x 10rsquo dia dish bottom 8250 gal (31 m3)
Cone Bottom
Press ReceivingSecondary Treatment
2012
EUG D ndash Treatment of Containerized Waste Liquids and Solids
EU
ID
Point
ID
EU Description and Service Construction
Date
D1 CMA1
Storage and Pumping containers of liquids into larger
containers
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
D2 CMA2
Storage and Consolidating solid containers into larger
container
Containers gt 01 m3 and lt 046 m3
NA
Storage and Consolidating solid containers into larger
container
Containers gt 046 m3 not in light liquid service
NA
Storage and Consolidating solid containers into larger
container
Various size containers
NA
D3 CTA2A
Stabilization solidification of solidsliquids in bulk
containers
Various size containers in mixing box 18rsquo x 16rsquo x 4rsquo
2012
D6 CTA2B
De-Characterizationsolidification of solidsliquids in bulk
containers various sized containers in mixing box 14rsquo x
14rsquo x 5rsquo
2015
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
SPECIFIC CONDITIONS 2019-0826-O 5 DRAFT
EU
ID
Point
ID
EU Description and Service Construction
Date
D4
CMA3
Drum
Warehouse
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
Storage and consolidation of flammable solids into other
larger containers NA
D5 CTA3
Storage and consolidation of non hazardous wastes
hazardous wastes flammable solids and flammable
liquids into other larger containers
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 01 m3 and lt 046 m3
NA
CTA3
Storage and Pumping containers of liquids into larger
containers eg tanker trucks
Containers gt 046 m3 not in light liquid service
NA
CTA3
Storage and Pumping containers of liquids into larger
containers
Various size containers
NA
EUG E ndash POTW Disposal
EU
ID
Point
ID
EU Description and Service Construct
Modification
Date
E4 POTW1
24rsquo H x 135rsquo dia 25700 gal (97 m3)
Flat bottom dome roof
Wastewater
1996
E5 POTW2
24rsquo H x 125rsquo diam 22000 gal (83 m3)
Flat bottom dome roof
Wastewater
1996
E6 Ancillary equipment piping valves flanges connectors
and pumps in Sewer Disposal Area 1996 - 2007
E7 BF3 Rosedale Duplex-Bag Filter 2004
A The permittee shall maintain a log documenting the VOC and VOHAP content of each
container and bulk load of waste received at the facility and the method of determining
these parameters in accordance with 40 CFR sect63694(b) the liquid density of each waste
stream emissions for each load of waste and all supportive documentation
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
SPECIFIC CONDITIONS 2019-0826-O 6 DRAFT
B Each Emissions Unit (EU) shall be clearly labeled with the EU number on the unit in a
conspicuous location that can be easily accessed for inspection
3 The permittee shall be authorized to operate the source 24-hours per day every day of the year
4 The permittee shall keep records of facility operations as listed below These records shall be
retained on-site for a period of at least five years following the dates of recording and shall be
made available to regulatory personnel upon request
a Calculations of emissions monthly and 12-month rolling cumulative
b Waste throughput monthly and 12-month rolling cumulative
c Records and logs required by these Specific Conditions
d All documentation required to demonstrate compliance with this permit the emission
limits and all applicable rules
5 No later than 30 days after the issuance of this permit the permittee shall submit to Air Quality
Division of DEQ with a copy to the US EPA Region 6 a final certification of compliance
with the terms and conditions of the previous permit and a final semi-annual monitoring
report
6 Upon issuance Permit No 2019-0826-O replaces and supersedes Permit No 2014-2305-
TVR (M-1) which is cancelled
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N ROBINSON SUITE 4100
PO BOX 1677
OKLAHOMA CITY OKLAHOMA 73101-1677
Permit No 2019-0826-O
US Ecology Tulsa Inc
having complied with the requirements of the law is hereby granted permission to operate
all sources within the boundaries of their facility located at 2700 South 25th West Avenue
Tulsa Tulsa County Oklahoma
_________________________________
Division Director Date
Air Quality Division
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
US Ecology Tulsa Inc
Attn Mr Andrew Nanik EHS Manager
2700 South 25th West Ave
Tulsa OK 74102
Re Operating Permit No 2019-0826-O
Commercial Waste Treatment Storage and Disposal Facility
US Ecology Tulsa Inc
2700 South 25th West Avenue Tulsa County Tulsa OK
Dear Mr Nanik
Enclosed is the permit authorizing operation of the referenced facility Please note that this permit
is issued subject to 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 the standard conditions which have been updated since the last issuance of this
permit have been replaced
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 in this matter If we may be of further service please contact
David Schutz at (405) 792-4198
Sincerely
Phillip Fielder PE
Chief Engineer
AIR QUALITY DIVISION
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
MINOR SOURCE PERMIT TO OPERATE CONSTRUCT
AIR POLLUTION CONTROL FACILITY
STANDARD CONDITIONS
(July 22 2019)
A The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ) in accordance with and under the authority of the
Oklahoma Clean Air Act The permit does not relieve the holder of the obligation to comply with
other applicable federal state or local statutes regulations rules or ordinances This specifically
includes compliance with the rules of the other Divisions of DEQ Land Protection Division and
Water Quality Division
B A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252100-7-15(g)) 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 252100-7-15(f)]
C 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 252100-7-18(a)]
D Unless specified otherwise the term of an operating permit shall be unlimited
E Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this
facility is required and shall be made in writing by the transferor within 30 days after such date A
new permit is not required [OAC 252100-7-2(f)]
F The following limitations apply to the facility unless covered in the Specific Conditions
1 No person shall cause or permit the discharge of emissions such that National Ambient Air
Quality Standards (NAAQS) are exceeded on land outside the permitted facility
[OAC 252100-3]
2 All facilities that emit air contaminants are required to file an emission inventory and pay
annual operating fees based on the inventory Instructions and forms are available on the Air
Quality section of the DEQ web page wwwdeqokgov [OAC 252100-5]
3 Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252100-9 Excess Emission Reporting
Requirements [OAC 252100-9]
4 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 252100-13]
5 No particulate emissions from new fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 06 lbsMMBTU [OAC 252100-19]
6 No discharge of greater than 20 opacity is allowed except for 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 [OAC 252100-25]
7 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
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]
MINOR SOURCE STANDARD CONDITIONS July 22 2019 2
properties or cause air quality standards to be exceeded or interfere with the maintenance of
air quality standards [OAC 252100-29]
8 No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 02
lbsMMBTU No existing source shall exceed the listed ambient air standards for sulfur
dioxide [OAC 252100-31]
9 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 15 psia or greater
under actual conditions shall be equipped with a permanent submerged fill pipe or with an
organic material vapor-recovery system [OAC 252100-37-15(b)]
10 All fuel-burning equipment shall at all times be properly operated and maintained in a manner
that will minimize emissions of VOCs [OAC 252100-37-36]
G Any owner or operator subject to provisions of NSPS shall provide written notification as
follows [40 CFR 607 (a)]
1 A notification of the date construction (or reconstruction as defined under sect6015) of an
affected facility is commenced postmarked no later than 30 days after such date This
requirement shall not apply in the case of mass-produced facilities which are purchased in
completed form
2 A notification of any physical or operational change to an existing facility which may
increase the emission rate of any air pollutant to which a standard applies unless that change
is specifically exempted under an applicable subpart or in sect6014(e) This notice shall be
postmarked 60 days or as soon as practicable before the change is commenced and shall
include information describing the precise nature of the change present and proposed
emission control systems productive capacity of the facility before and after the change and
the expected completion date of the change The Administrator may request additional
relevant information subsequent to this notice
3 A notification of the actual date of initial start-up of an affected facility postmarked within
15 days after such date
4 If a continuous emission monitoring system is included in the construction a notification of
the date upon which the test demonstrating the system performance will commence along
with a pretest plan postmarked no less than 30 days prior to such a date
H Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence
and duration of any start-up shutdown or malfunction in the operation of an affected facility or
any malfunction of the air pollution control equipment [40 CFR 607 (b)]
I Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by this subpart recorded in a permanent file suitable
for inspection This file shall be retained for at least five years following the date of such
measurements maintenance and records [40 CFR 607 (f)]
J Any owner or operator subject to the provisions of NSPS shall conduct performance test(s)
and furnish to AQD a written report of the results of such test(s) Test(s) shall be conducted within
60 days after achieving the maximum production rate at which the facility will be operated but
not later than 180 days after initial start-up [40 CFR 608]