30
DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM October 21, 2019 TO: Phillip Fielder, P.E., Chief Engineer THROUGH: Rick Groshong, Environmental Manager, Compliance and Enforcement THROUGH: Eric L. Milligan, P.E., Manager, Engineering Section THROUGH: Amalia Talty, P.E., 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 25 th West Avenue, Tulsa County, Tulsa, OK Lat. 36.12219°; Long.-96.02085° SECTION I. INTRODUCTION US Ecology Tulsa, Inc. (US Ecology), has requested a “significant” 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 “once in, always in” 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 “area” source of HAPs and a “synthetic minor” 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. EQUIPMENT/PROCESS 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 TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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Page 1: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 2: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 3: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 4: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 5: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 6: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 7: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 8: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 9: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 10: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 11: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 12: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 13: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 14: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 15: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 16: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 17: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 18: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 19: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 20: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 21: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 22: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 23: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 24: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 25: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 26: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]

Page 27: PERMIT TO OPERATEapplications.deq.ok.gov/permitspublic/storedpermits/6743.pdfSystem TF1 Piping, Transfer Pumps, Connections and appurtenances included in the TF1 tank system. 1996-2007

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]