DRAFT
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM
March 29, 2005
TO:
Dawson F. Lasseter, Chief Engineer, Permits Section
THROUGH:
Richard Kienlen, P. E., Engr. Mgr. II, New Source Permits Section
THROUGH:
Peer Review, Judy Cupples
FROM:
Herb Neumann
Regional Office at Tulsa
SUBJECT:
Evaluation of Permit Application No. 2004-162-TVR
Baker Petrolite Corporation
Synthetic Polymer Manufacturing Facility
820 Birch Lake Road, Barnsdall, Osage County
SE/4 18, T 24 N, R 11 E
West on OK 11 approximately one mile from its intersection with OK 123;
turn left (south) as 11 bends to the north entering Barnsdall.
I.
FACILITY DESCRIPTION
This facility started operations as a petroleum refinery in 1907. By the 1950s, the facility had
specialized in microcrystalline waxes and most other activities were discontinued. A production
unit for the manufacture of synthetic waxes was built in 1970 and a second unit was constructed in
1989. All microcrystalline wax manufacture was ended in 1996. Before issuance of the current
(and original) Part 70 Permit No. 98-107-TV on December 3, 1999, the facility had been permitted
to manufacture copolymers often described as synthetic waxes (SIC 2869) under Permit No. 88017-O (M-2), issued July 7, 1993. The two production units, referred to as EP Units (for Ethylene
Polywax) or just Polywax Units, are identified as Unit A for the older area and Unit B for the newer
area. Construction projects authorized under Permit No. 98-107-C and a request to use certain
alternate fuels in two boilers are included in this Part 70 renewal permit.
II.
PROCESS DESCRIPTIONS
The Barnsdall Plant manufactures organic chemicals in three primary production units and
support operations. The three production units are Synthetic Wax Production Unit, Resin Unit,
and Oxidation Unit, and they will be discussed in the order listed. Miscellaneous Sources are
listed following discussion of the production units.
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2
SYNTHETIC WAX PRODUCTION UNIT
BPC manufactures low molecular weight synthetic waxes, designated as ethylene polywax (EP)
products. The synthetic waxes are produced by polymerizing organic monomers, principally
ethylene and propylene. EP finished products are solids at ambient temperature and have
negligible volatility. Raw materials used in the EP process are organic monomers (principally
ethylene and propylene), reaction initiators, reaction catalyst, and carrier solvent. With the
exception of the reaction catalyst, all these raw materials are received and stored in bulk tanks.
The plant operates two ethylene bulk tanks that are nominally sized at approximately 30,000
gallons capacity, and one propylene bulk tank nominally sized at 15,000 gallons capacity. The
reaction initiators and carrier solvent are stored and dispensed from three separate bulk tanks.
The reaction catalyst is received and dispensed from 55-gallon drums. Major processing steps
employed to produce synthetic waxes follow.
Polymerization Reaction
The polymerization reaction is conducted in water-cooled agitated reactor vessels. In this
process, the carrier solvent (toluene, the principal HAP), initiator, and catalyst are fed to the
reactor, and then the monomer is added. Polymerization occurs, converting the monomer into a
long-chain synthetic wax. The reaction mass is fed to a surge tank or directly to a wash tank for
further processing. The facility can also route the reaction mass to an oxidization vessel to
produce high molecular weight alcohols (Unilin®). These alcohols are very similar to the
synthetic waxes, having negligible volatility.
Hydrolysis and Aqueous Washing
The reaction mass is fed to a hydrolysis and washing system. The purpose of this step is to
hydrolyze the wax product and to remove the water-soluble initiator and catalyst compounds
from the reaction mass. Washing consists of sequential water washes followed by phase
separation, with the aqueous phase discharging to solvent recovery and the organic phase routed
to polymer recovery.
Polymer Recovery
The organic phase discharged from the washing step is initially transferred to a flash
evaporator/condenser system. This removes the majority of carrier solvent from the polymer
product. A steam stripping process then removes the residual carrier solvent. Overheads from
the stripping process are condensed and collected. The solvent with entrained water content
mixture from both condensing systems discharges to “wet” solvent collection tanks. Polymer
from the steam stripping unit discharges to accumulation/storage tanks where it is tested and then
pumped to liquid product storage tanks or to the facility’s prilling tower, where wax beads are
formed as the final product.
Aqueous Phase Solvent Recovery
The aqueous phase material discharged from the washing system and from the phase separation
of the wet solvent is fed to a flash tank/condenser system or to a steam stripping
column/condenser to remove and recover the carrier solvent. The condensers discharge to the
wet solvent collection tanks. The stripped aqueous phase discharges to a solid/liquid separator
PERMIT MEMORANDUM 2004-162-TVR
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3
and lagoon system, and is ultimately pumped to a deep well injection system. The well is a Class
1 non-hazardous injection well permitted by the EPA.
Solvent Purification/Drying
The recovered carrier solvent accumulated in the wet solvent collection system is allowed to
phase separate with the aqueous phase fed to the aqueous solvent recovery systems, and the
organic phase fed to a distillation column for purification. Overheads from the distillation
column are condensed and returned to the column as reflux. Water that is condensed is drawn
off to the plant effluent system. Purification residuals from the distillation column are
accumulated in a tank system and eventually sold to customers as Solvent 250. A side draw of
the purified solvent is routed to an accumulation tank. This tank feeds a second distillation
column for removal of any residual water. Solvent from this second drying column is fed to a
molecular sieve bed that further reduces the water content. Dried purified solvent is then routed
to another accumulation tank that recycles the solvent back to the initial polymerization reaction
step.
Reactor Wash Processing
Off-specification product, line flushings, raw samples and material from reactor-cleaning are
recycled in the reactor wash processing system. This system recovers solvents from the abovelisted material using a flash evaporator and condenser. The condenser discharges recovered
solvent back to the wet solvent collection tanks. Other material recovered from the system is
collected, allowed to solidify, and stored prior to landfill disposal off-site.
RESIN UNIT
The resin unit is a batch operation that manufactures various waxes through chemical reactions.
These reactions require catalysts and elevated temperature and/or pressure, will usually generate
heat, and generally use cooling water to maintain control of the reactions. The cooling water
from this process is recirculated to the facility’s non-contact cooling water tower. This system
consists of four reactors; one 750-gallon (Equipment ID No. C-6001), one 1,500-gallon (C6003), and two 8,500-gallon (C-6005 and C-6006). Volatile organic vapors are generated during
the chemical addition and reaction processes. These vapors are condensed and collected in
storage tanks as a co-product. Vapors from these storage tanks are routed to a vent condenser (E6026). The vent condensers are cooled with chilled water at approximately 40 F in a closedloop system, resulting in a high removal efficiency (> 70%) of organic compounds vented
through the system. The product waxes from the resin unit are shipped in bulk, packaged into
drums or pails, or transferred to the packaging unit systems. The primary condenser vent is 2 in
diameter and vents a maximum 15 scfm at 70 F, exhausting at 22 above grade. The condenser
vent from the storage tanks is 2 in diameter and vents a maximum 11 scfm at 70 F, exhausting at
21 3 above grade.
Cold Flow Description
A new product line being manufactured at the Resin Unit is a Cold Flow Improver (CFI) used for
depressing the pour points of crude oil. These CFIs are produced in existing equipment in the
Resin Unit and use reactions similar to those for other current products. Production of the CFIs
required minor changes to the existing system. The changes include the addition of a small
PERMIT MEMORANDUM 2004-162-TVR
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4
reflux condenser on reactor C-6005 and an associated decanter that collects liquid and returns it
to the reactor while venting any vapors to existing condenser E-6005. This condenser is installed
prior to the vacuum receiver leading to condenser E-6010, where some emissions from the resin
process are vented to the atmosphere through emission point EP-6010. The new product also
requires use of a new solvent referred to as Solvent 14 or Aromatic 100 Solvent, which is stored
in a new 8,000-gallon tank before being added to the process. This tank is vented to condenser
E-6026, which controls emissions from the existing co-product storage tanks. Products from this
process are transferred directly to a tank truck for shipment or to totes for storage. The changes
to the Resin Unit do not increase the overall production capacity of the unit and when combined
with the existing production, do not exceed the limits specified in the current Title V permit.
OXIDATION UNIT
The oxidation unit consists of two approximately 7,500-gallon vessels (C-6101 and C-6105),
which are equipped to treat wax by forcing air through spargers at the bottom of each oxidizer.
The air is supplied from two 2,000-scfm blowers (G-6111A and G-6111B) and is used as the
source of oxygen for agitation of the wax during the oxidation process and to maintain control of
the oxidation rates at specific temperatures. The excess air exits the oxidation units through a
knockout pot and is then burned in a catalytic oxidizer, Emission Point V-6101. Steam and
cooling water are also used to assist in temperature control for the oxidation units. The steam
condensate is returned to the facility feed water system and the cooling water is routed to the
non-contact cooling water tower. One of the oxidation units is outfitted as a pressure vessel (C6105) and contains a vacuum jet that removes vapors. This vacuum jet operates approximately
12 hours per month and results in discharges containing an aromatic substitute of urea through
the catalytic oxidizer. The oxidizer vents to the atmosphere through a 1.5 diameter stack,
exhausting a maximum 4,000 scfm at 1,000 F at 58 above grade. The product waxes (oxidized
waxes) can be transferred directly to the packaging unit systems or to storage tanks, pending final
packaging.
MISCELLANEOUS SOURCES
Emulsions Production
Emulsions are produced by dispersing wax products in water. The generic materials for the
process are wax, water, surfactant, and biocide, which is optional. Emulsion processing uses
several different procedures, namely wax to water, water to wax, heat/mix, and finally
blend/homogenize.
Wax to water and water to wax processes are very similar. The two components start in separate
vessels at elevated temperatures, with the surfactant mixed in one of them. To form the
emulsion, one of the components is slowly added to the other component while mixing. After
the emulsion is formed, the product is cooled and packaged. When biocide is used, it is added
just before packaging.
Heat/mix operations are very basic. All of the raw materials are put into a single vessel and
heated. The material is agitated to disperse the components. The product is then cooled, and
finally packaged.
Blend/homogenize operations are more complex. First, the materials are blended together in one
vessel. Then they are heated and mixed using the coils and agitator in the vessel. Next, they are
transferred through a homogenizer to a second vessel. The homogenizer is a very high-pressure
PERMIT MEMORANDUM 2004-162-TVR
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5
pump with a very small orifice. It causes extreme mixing in the liquid being pumped. Numerous
processing steps are required to accomplish this due to the high pressure involved, and the need
to protect the homogenizer equipment from physical damage. The liquid may be passed back
and forth through the homogenizer between the two vessels several times to achieve the desired
product characteristics. After homogenizing, the product is cooled and packaged.
Equipment for the emulsion system consists of two stainless steel vessels with approximately
2,000-gallon working capacity. The vessels are pressure rated to 150 psi, with internal coils and
agitators. The homogenizer pumps approximately 15 gpm, and is rated for about 15,000 psi. A
small gear pump is installed before the homogenizer to maintain positive suction pressure. Deionized water is produced using an off-the-shelf ion exchange system. Because the water-based
emulsions are non-hazardous, packaging is accomplished by simply transferring the product to a
container through a bag type filter and a hose. The container may be a drum, pail or tote. The
proper amount of product is weighed as it is added to the container, and then sealed for shipment.
The emissions from this process are negligible, so this process has been added to the insignificant
activity list.
Microcrystalline Wax Blending and Packaging
Microcrystalline waxes are produced by simply blending different waxes together, and
packaging, or shipping out as liquid bulk product. Some of the waxes are purchased from
outside sources and brought in by tank truck. Other components of the blends are waxes made at
the Barnsdall plant, which may be obtained from liquid bulk stock, or from packaged product
stock. The blending may be done in any available tank, and agitation may be provided by rolling
with nitrogen if no mechanical agitator is present. “Rolling” is equivalent to fluidized bed
action.
Packaging of microcrystalline waxes is accomplished by prilling, mini-prilling, pastilling,
micronizing, or slabbing. “Slabbing” is the production of wax in large blocks, and is currently done
off-site.
Packaging and Shipping
Both liquid and solid products are shipped from BPC to customers. Liquids are shipped via
tanker truck, or in packages such as drums, bulk bags, and pails. Solid waxes are sized and
packaged into various bags, totes, and drums for shipment.
Spray Micronizer
This is a process that atomizes wax into extremely fine particles. Molten wax and steam are
injected into a “micronizing” nozzle. The exiting wax particles are air cooled and captured in a
baghouse, from which they are removed with compressed air. They are sorted through a sizing
shaker screen and drummed or bagged as a product. Oversized particles are melted and returned to
feedstock. Moisture content and particle size are partially controlled with elevated temperatures
and occasional use of nitrogen. A 2,500-scfm blower induces heated air through the ductwork and
baghouse. The baghouse is integral to production, and applicant does not consider it to be a piece
of pollution control equipment. It has an efficiency of 99.99%. The baghouse exhausts 2,500 scfm
at 120 F through a 10 diameter stack, venting at 39 above grade.
PERMIT MEMORANDUM 2004-162-TVR
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6
Sandvik Belt Unit
This process produces small wax beads called pastilles. Molten wax is pumped through pastillating
heads to produce small drops of wax, which fall onto a stainless steel conveyor belt. Chilled and/or
cooling water is sprayed on the underside of the belt, causing the drops to solidify upon contacting
the belt surface. A scraper blade separates the pastilles from the belt; they are sorted on a screen
shaker, and packaged as product. Oversized drops are returned to feedstock. There are two lines,
identical in operation and length, but with different widths.
Air Attrition Unit
In this process solid wax is tumbled by compressed air, fracturing the pieces of wax into smaller
particles. Particles are carried into a cyclone by the exhaust air stream. Fine particles collect in the
center of the cyclone and pass to a baghouse. Particles are removed from the baghouses using
compressed air, and the products are packaged. One difference from the micronizer system is that a
flexible hose is attached to the exhaust system only during start-up, and a filter sack is placed over
the end of the hose. Once the system is operating properly, air is routed through the baghouse and
the hose is disconnected. This prevents emissions during the start-up process. As with the
micronizer system, the baghouse is integral to production, and applicant does not consider it to be a
piece of pollution control equipment. It has an efficiency of 99%. The baghouse exhausts 105
scfm at 100 F through a 4 diameter stack, venting at grade.
Prilling Tower
Molten synthetic wax is pumped from storage to the top of the prilling tower and sprayed
downward. Ambient air is pulled upwards through the tower and the resulting countercurrent heat
transfer allows the droplets of copolymer to form into hard beads. The beads are screened for size,
with the larger beads being returned to the heated storage tanks. The reverse air is fed to cyclones
for recovery of copolymer fines, which are also returned to the heated storage tanks. Although the
cyclones act as pollution control devices, they are integral to the process and recover valuable
material for processing. As noted below, this process is to be phased out.
Mini-Prill Description
Mini-Prilling (MP) is very similar to prilling. The primary differences between prilling and MP
are: that MP produces a much smaller bead; that MP uses different geometry, spraying the liquid
up into the air, and allowing it to fall back down into the bed; that MP allows the potential to
recirculate air back into the MP system; that MP uses a cooling exchanger and a filter cloth to
prepare the cooling air before re-using it; and that a refrigeration unit is used to help chill the air
that flows through the unit. Liquid wax is fed from existing wax storage tanks to a booster pump
which forces wax through heated spray bars. As it is forced through the nozzles it is sprayed up
into a spray chamber. As the wax is sprayed up, most of it forms spherical particles that descend
onto a perforated plate. Air is forced through the holes of the perforated plate causing the wax
particles to hover in a layer above the perforated plate. As the particles hover, they are
continuously moving and being cooled by air, which is being cooled itself in an exchanger by a
chilled water system. A blower forces this air through a cooler into an air box with the
perforated plate on top. After going through the perforated plate, the forced air continues
upward, also cooling and slowing down the descending wax particles. Very small wax dust
particles that do not agglomerate onto the larger spherical particles rise to the top of the spray
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7
chamber. At the top of the spray chamber, the air is sucked through a cotton cloth by a fan with
an adjustable shutter, which regulates the air velocity in the spray chamber. As the air goes
through the cotton cloth, wax dust is collected and the filtered air is either released through
shutters in the ductwork or recirculated through the air cooler. The device in which the fluidized
bed and air separation system are contained is called a granulator. The wax particles exit the
granulator by overflowing a dam above the perforated plate. A pneumatic conveyor moves the
particles to a large hopper that feeds a standard bagger.
The Mini-Prill process will replace the Prill Tower and will not exceed the existing Prill Tower
production limitations listed in the original Title V permit. The Mini-Prill emission rates are
much lower than the Prill Tower emission rates. As customers are converted to the Mini-Prill
product, the Prill Tower will be phased out and shut down. With the exception of the prilling
tower, emissions from the packaging operations are negligible, so these have been added to the
insignificant activity list.
SUPPORT OPERATIONS
Support operations at the facility include utilities, packaging and shipping (including wax
prilling), wastewater collection and treatment, other maintenance activities, and a staging area for
oil well field treatment activities.
Utilities
The plant operates three boilers to generate steam used in the production areas. Boilers #1 and
#2 have maximum design firing rates of 72.2 MMBTUH and Boiler #3 has a maximum design
firing rate of 52.5 MMBTUH. The primary fuel for the boilers is pipeline grade natural gas.
Boilers #1 and #2 are also capable of burning No. 2 fuel oil, but are limited to 480,000 gallons
(total in both boilers) each calendar year. Oil use is intended for periods of gas curtailment. Coproducts may be used as fuel, as might other materials, if approved by DEQ. A discussion of
alternate fuels is found in the following Emissions section and at other appropriate locations in
this Memorandum. Other utilities described at this point in the application have been moved to
the Insignificant Activities listed at the end of Section V below.
III.
EQUIPMENT
There are many process vessels in this facility, but only those vessels capable of emitting to the
atmosphere through a vent or control device are listed.
PERMIT MEMORANDUM 2004-162-TVR
EUG 1
DRAFT
Polywax Units (EP A & B)
Point
Service
Capacity
Const Date
C-1005
Reaction Initiator Tank & Weigh Cell
10,000 gal
1970
C-3020
Reaction Initiator Tank & Weigh Cell
12,000 gal
1993
C-1002
Carrier Solvent Storage Tank
10,000 gal
1970
E-4351
Oxidation Vessel Condenser (Plant A)
N/A
1993
E-4350
Final Vent Condenser (Plant A)
N/A
1993
E-4310
Final Vent Condenser (Plant B)
N/A
1989
F-0000
Fugitives (Plants A & B)
N/A
1989
Fugitives include storage tanks, wastewater basin and lagoons, as well as piping, flanges, etc.
EUG 2
Prilling Tower
CYVENT
Buffalo Type L-39
1975
Note that the mini-prill equipment is treated as Insignificant.
EUG 3
Boilers
Point
BLR1
BLR2
BLR3
EUG 4
Make/Model
Trane/Coen
Trane/Coen
Trane/Coen
Service
Condenser vent
Co-product storage tanks condenser vent
Const Date
1978
1978
1978
Const Date
2004
1989
Oxidation Unit
Point
V-6101
EUG 6
Capacity
72.2 MMBTUH
72.2 MMBTUH
52.5 MMBTUH
Resin Unit
Point
E-6010
E-6026
EUG 5
Serial #
10837
10835
10659
Service
Catalytic oxidizer exhaust
Const Date
1999
Packaging Units
Point
G-6303
AAM
Service
Micronizer baghouse exhaust
Air attrition cyclone/baghouse exhaust
Const Date
1999
1999
8
PERMIT MEMORANDUM 2004-162-TVR
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9
EUG ALL Facility Wide
This EUG is established to consider all rules and regulations that apply to the entire facility.
The following table shows pertinent information about each of the stacks. Note that all flow and
temperature data reflect maximum conditions. For instance, vents flow only under certain
pressure conditions and the point identified as E-4351 has flow only when the polymer oxidizer
is processing material.
Point
C-1005*
C-3020*
C-1002
E-4351
E-4350
E-4310
CYVENT
BLR1
BLR2
BLR3
E-6010
E-6026
V-6101
G-6303
AAM
STACK PARAMETERS
Height
Diameter
Flow
(Feet)
(Inches)
(ACFM)
0
1
240
0
1
240
22
4
25
48
2
116
43
3
116
59
6
66
28
47
80,000
30
42
7,392
30
42
8,477
30
36
5,207
22
2
15
21
2
11
58
18
4,000
39
10
2,500
-04
105
Temperature
(F)
Ambient
Ambient
Ambient
100
100
100
100
290
290
270
70
70
1000
120
100
* Emissions from tank C-1005 flow through a seal pot (D-1002) and are emitted
there. Similarly, emissions from C-3020 actually vent through D-3022.
IV.
AIR EMISSIONS
Copolymer Production
Calculation of emissions from the various units involved in producing the synthetic waxes
require the use of proprietary data that the permittee requests be kept confidential. The process
used by permittee is in the public domain, but stating actual amounts of solvent and raw
materials used could reveal the specific techniques used. Only a description of the calculation
technique will be presented in this public document. The actual calculations may be found in the
confidential permit application package and will be required under a Specific Condition of the
permit for compliance demonstrations.
Emissions of solvent to atmosphere are based on material balance. The conservatively high
assumption is that the difference between purchases of solvent and all known outputs is assumed
to represent emissions. Following is a list of outputs.
PERMIT MEMORANDUM 2004-162-TVR
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10
Synthetic waxes have been analyzed to determine the amount of solvent present. This
amount is multiplied by the quantity of product manufactured.
Wastes injected at the disposal well are analyzed for solvent content in ppm. A simple
calculation yields the total amount of solvent disposed.
Some material is also shipped off-site and is considered by the permittee to be a coproduct. This material is analyzed for solvent content per barrel. Solvent disposed is the
sum of solvent content of each barrel.
Other waste solvent is collected in drums, analyzed for solvent content, and then shipped
off-site for disposal.
Emissions of raw materials are also based on material balance. Since ethylene is the principal
raw material, the calculation process analyzes the other components first. Calculating the ratio of
all waste (which may be off-spec product or material washed out of reactors) solids to total
production forms an approximation of solid losses. This ratio is assumed to apply equally to
each raw material. Each propylene co-polymer manufactured has a known theoretical content of
propylene. Total quantity of each propylene co-polymer is multiplied by this theoretical value to
generate the total amount of propylene actually present. This number is then multiplied by the
solid loss ratio discussed earlier. Both numbers are subtracted from the quantity of propylene
consumed and this result represents emissions. The process performed for propylene is
duplicated for hexene and the stage is set for calculating ethylene emissions.
Ethylene emissions are considered to be the difference between total consumption of raw
materials (ethylene, propylene and hexene) and the sum of total production, propylene and
hexene emissions, and solid losses. Calculation of propylene and hexene emissions has been
described. Solid losses include solids accumulating in the “1017 Pit,” wax picked up from the
ground, spilled, leaked, or recovered in any other way, and solids collected in the weir section of
the 1017 Pit. These various solids have ethylene content estimated by using the ratio of
propylene co-polymers manufactured combined with estimates of their rate of accumulation.
Permittee has requested a Plantwide Applicability Limit (PAL) of 550 TPY for VOC, which
would include, but is not limited to, toluene, ethylene, propylene and hexene. Specific
Conditions #1 and #4 shall be used to demonstrate compliance with the PAL.
Prilling Tower
There are no emissions of VOC from this source. Particulate emissions are calculated based on
material balance and assume a conservatively low cyclone collection efficiency of 91%. These
assumptions allow the calculation of an emission factor of 2.50 pounds of PM10 per ton of liquid
wax throughput. Maximum production is 3.45 TPH. As the tower is phased out, and prilling
operations assumed by the MP process, the significance of this emission source will decline.
3.45 TPH  2.50 lbs/ton = 8.63 lbs/hr or 37.78 TPY
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11
Mini-Prill Process
The MP process does not use cyclones for product recovery, as is the case with the tower operation,
and the fabric filters are much more efficient at product recovery. Assuming the filters to be at least
99.9% efficient and using the engineering calculations for the tower operation yields an estimated
rate  0.42 TPY. Air from the unit is filtered and emissions are expected to be below the significant
activity threshold of 5 TPY. The MP process will be added to the Insignificant category and will
require sufficient recordkeeping to demonstrate that it is (and remains) in that category.
Boilers
All emission factors are taken from AP-42. Tables 1.4-1 & 2 (3/98) are used for natural gas and
Tables 1.3-1, 2 & 3 (9/98) are used for #2 fuel oil. Filterable and condensable PM factors are
combined. Heat content of natural gas is assumed to be 1,050 BTU/CF, the firing rate of oil is the
manufacturer’s specification of 480 gallons per hour, and #2 sulfur content is taken to be 0.5% by
weight. The original Part 70 permit assumed that #2 use would not exceed combined use of 1,000
hours for all boilers. The facility wants the ability to use the total quantity of liquid fuel used in this
analysis, or 480,000 gallons per year, noting that some of the operating conditions may be at less
than full load. For that reason, the third table following shows “total” boiler emissions. It is
constructed by taking the highest value from each table, and combining results to create a table
representing maximum values for each pollutant’s emissions. For example, the highest lb/hr value
for NOX comes when burning liquid fuel, so the “total” table shows 9.60 lbs/hr  2 for Units 1&2
plus 5.00 lbs/hr for Unit 3, or 24.2 lbs/hr. The TPY figure for NOX Unit 1 and/or 2 is calculated by
taking 1,000 hours (combined) on liquid fuel, and then assuming continuous operations for both
units less 1,000 hours on NG, plus continuous operation of Unit 3 on NG. Thus,
(9.70  1,000) + (6.88  {(8,760  2) – 1,000}) + (5.00  8,760) = 167,058 lbs/yr = 83.6 TPY,
and similarly for the other values.
Two alternate liquid fuels have been proposed for use, and their emissions are included in the
second table, assuming two restrictions on their use. First, the alternates analyzed for this purpose
are “Solvent 250” and “Solvent 125.” Solvent 250 is a co-product consisting of primarily toluene,
with toluene alkylates, synthetic wax, and water. Solvent 125 is primarily tert-butyl alcohol, with
acetone and water. These two co-products have heat content of 18,000 – 22,000 BTU per pound,
which is close to the heat content of #2 Oil. Analyses of these materials indicates that emissions
will be similar to those of #2, except that NOX is expected to be elevated by 20%. Second, no more
than 5% of the liquid stream will consist of alternate fuels. Thus, the 20% per gallon boost caused
by the alternate fuel is offset by the restriction on use, leading to a net increase of only 1%. This
approach will facilitate the addition of alternate fuels to this permit, if the facility requests such
ability.
PERMIT MEMORANDUM 2004-162-TVR
Pollutant
PM10
NOX
CO
VOC
SO2
DRAFT
12
BOILERS ON NATURAL GAS
Factor
Emissions (1 & 2, each)
Emissions (3 only)
(Lb/MMCF)
Lb/hr
TPY
Lb/hr
TPY
7.6
0.52
2.29
0.38
1.66
100
6.88
30.12
5.00
21.90
84
5.78
25.30
4.20
18.40
5.5
0.38
1.66
0.28
1.21
0.6
0.04
0.28
0.03
0.13
Pollutant
PM10
NOX
CO
VOC
SO2
BOILERS ON LIQUID FUEL
Factor
Emissions
3
(Lb/10 gal) Lb/hr (1 & 2, each)
TPY (Both)
3.3
1.58
0.79
20
9.70
4.85
5
2.40
1.20
0.20
0.10
0.05
34.08
17.04
142S *
* S = weight percent sulfur
BOILERS - POTENTIAL TO EMIT
Pollutant
Lb/hr
TPY
PM10
3.54
6.77
NOX
24.2
83.6
CO
15.8
69.0
VOC
1.04
4.53
SO2
34.1
17.7
Resin Unit
There are emissions from the resin unit vacuum receiver water tank serving the four tanks in this
process. Another condenser serves the storage tank vents. The applicant has performed an
engineering study of losses in conjunction with the Texas Natural Resources Conservation
Commission (TNRCC). Approximately 3% of all material charged to the reactors is trapped in the
equipment, is flashed overhead and collected as co-products. Evaporative losses (VOC) have been
calculated at 0.25%, but have conservatively been assumed to be 1% losses for this analysis. The
chilled water vapor condensers are estimated to have 70% recovery or removal efficiency.
Although operating hours are typically estimated to be 6,240 hours per year, the following
calculations assume 8,760 hours per year.
10,400,000 lbs/yr  1%  (1 – 70%)  1 ton/2,000 lbs = 15.60 TPY VOC
3,120 lbs/hr  1%  (1 – 70%) = 9.36 lbs/hr VOC
PERMIT MEMORANDUM 2004-162-TVR
DRAFT
13
Emissions from the condenser vent associated with the storage tanks are calculated based on EPAapproved Tanks3.1 computer model and the assumed 70% efficiency of the condenser. Two tanks
are pressure vessels, 7 feet high by 6.5 feet in diameter, with capacity of 2,000 gallons each. The
third tank is a fixed cone roof tank, 15 feet high by 12 feet in diameter, with a capacity of 10,000
gallons. Combined VOC emissions from all tanks are 0.01 lbs/hr and 0.03 TPY.
Oxidation Unit
VOC-laden air emissions from the three vessels are routed through a knockout pot, and then to the
catalytic oxidizer. As in the case of the resin reactors, 3% of the material loaded is trapped in
various parts of the equipment, is flushed out, and ultimately sold as off-spec product. Also as
above, evaporative losses of 0.25% are increased to a conservatively high 1% for these calculations.
The manufacturer of the oxidizer guarantees 95% destruction efficiency, but the applicant assumes
a conservatively low value of 90% for these calculations. Although operating hours are typically
estimated to be 6,240 hours per year, the following calculations assume 8,760 hours per year.
6,240,000 lbs/yr  1%  (1 – 90%)  1 ton/2,000 lbs = 3.12 TPY VOC
3,120 lbs/hr  1%  (1 – 90%) = 3.12 lbs/hr VOC
Packaging Units
1. Spray Micronizer
Fine particles of wax are captured in a baghouse, whose capture efficiency is guaranteed by the
manufacturer at 99.99%. For a maximum production of 1,000 tons per year, emissions are
calculated based on an input of 604.8 lbs/hr or 1,008 TPY, yielding
604.8 lbs/hr  (1 – 99.99%) = 0.06 lbs/hr PM or
1,008 TPY  (1 – 99.99%) = 0.10 TPY PM
No significant VOC emissions are anticipated.
2. Sandvik Belt Unit
This process produces neither VOC nor PM emissions. Maximum annual capacity for this unit is
approximately 12,000 tons of product.
3. Air Attrition Unit
Fine particles of wax are sent through a cyclone with an efficiency of 90%, and are then captured in
a baghouse, whose capture efficiency is guaranteed at 99.99%. For a maximum production of 50
tons per year, emissions are calculated based on an input of 20.2 lbs/hr or 50.5 TPY, yielding
20.2 lbs/hr  (1 – 90%)  (1 – 99.99%) = 0.0002 lbs/hr PM
50.5 TPY  (1 – 90%)  (1 – 99.99%) = 0.0005 TPY
No significant VOC emissions are anticipated.
Storage Tanks
Tanks have been considered as part of the emissions contemplated from the Polywax plants.
PERMIT MEMORANDUM 2004-162-TVR
DRAFT
14
HAP and Oklahoma toxic emissions
The VOC emissions listed in the Resin and Oxidation Units above have been speciated into
component chemicals. Since the percentages attached to each process could reveal proprietary
process information, details may be found in the confidential application packet. A summary of
this list of compounds shows that 13.7 TPY or 3.1 lbs/hr is attributable to t-butyl alcohol, CAS #7565-0. Although the instantaneous hourly rate is approximately 8.2 lbs/hr, such a rate cannot be
sustained through a 24-hour period. Only about 1½ TPY of the entire list are HAPs. With the
exception of the t-butyl alcohol, none of the other compounds approaches any toxic category
threshold under Subchapter 41. Ground level concentration (GLC) of t-butyl alcohol emissions,
calculated using Screen3, was found to reach a maximum value of 1,435 g/m3 at 89 from the
stack. No transform factor was used. The maximum acceptable ambient concentration (MAAC)
for t-butyl alcohol is 30,323 g/m3, significantly higher than the modeled concentration. Using the
instantaneous rate of 8.2 lbs/hr would have yielded a GLC of 3,796 g/m3, still well below the
MAAC.
Modified operating permit 88-017-O (M-2) described the results of ISCST modeling performed for
an expected emission of 399.8 TPY of toluene from Polywax Units A & B. This result showed a
GLC of 4,320 g/m3. Assuming toluene emissions of 550 TPY as a worst case under the PAL
described in Polywax Production (Section III) above yields an extrapolated GLC of 5,943 g/m3.
This value is well below toluene’s MAAC of 37,500 g/m3. Ethylene, propylene and hexene are
not subject to the toxic rules of Subchapter 41, so no MAAC modeling is necessary for them.
V.
INSIGNIFICANT ACTIVITIES
The insignificant activities identified and justified on Part 1b of the forms in the application and
duplicated below were confirmed by the initial operating permit inspection. Records are
available which confirm the insignificance of the activities. Appropriate recordkeeping is
required for those activities indicated below with an asterisk.
* Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel
that are either used exclusively for emergency power generation or for peaking power service not
exceeding 500 hours/year. There is a 743-hp diesel-fueled emergency generator that is not
utilized in excess of 500 hours per year. A 200-hp diesel-fueled fire water pump is similarly
limited.
Space heaters, boilers, process heaters, and emergency flares less than or equal to 5
MMBTUH heat input (commercial natural gas).
* Emissions from fuel storage/dispensing equipment operated solely for facility-owned
vehicles if fuel throughput is not more than 2,175 gallons/day (gpd), averaged over a 30-day
period. Actual usage for 2004 was 22.0 gpd. Even if all gasoline had been pumped in a single
month, average use would have been 268 gpd, well below the 2,175-gpd threshold.
* Emissions from storage tanks constructed with a capacity less than 39,894 gallons which
store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. Permittee
PERMIT MEMORANDUM 2004-162-TVR
DRAFT
15
has 564-gallon, 1,034-gallon and 11,382-gallon #2 fuel oil tanks. None of these tanks is subject
to NSPS or to State permitting rules, and all store liquids with vapor pressure well below the 1.5
psia threshold.
* Non-commercial water washing operations (less than 2,250 barrels/year) and drum
crushing operations of empty barrels less than or equal to 55 gallons with less than 3% by
volume of residual material. Less than 150 drums per year are crushed.
Hazardous waste and hazardous materials drum staging areas. Up to six drums of hazardous
waste are stored at any time. Hazardous materials are staged routinely.
Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including
hazardous waste satellite (accumulation) areas.
Hand wiping and spraying of solvents from containers with less than 1-liter capacity used for spot cleaning
and/or degreasing in ozone attainment areas.
A number of sources may be considered as insignificant because their emissions are below the 5
TPY State de minimis and they are not subject to NSPS, NESHAP, or State rules.
a)
b)
c)
d)
f)
g)
h)
i)
j)
k)
Less than 14 laboratory hoods and vents.
Pyrolysis of laboratory glassware.
Particulate emissions from bagging units.
Emissions from an asphalt pit.
Cooling water is provided by three sets of cooling towers. One set provides cooling water in
a continuous loop for A-Side and B-Side condensers in the Synthetic Wax Unit. The cooling
water loop operates at approximately 60 psig. The process side of each condenser is operated
at a much lower pressure. A second cooling tower provides cooling water to the reactors in
the Synthetic Wax Unit. Heat is exchanged via an intermediate closed loop (water
recirculated within the reactor vessel); therefore, the cooling water is never in proximity to
the process fluids. A third cooling tower provides cooling water for use in the Resin Unit
condensers and the Sandvik belt. Cooling towers are considered to be Trivial activities for
Part 70 permitting.
A refrigeration unit provides chilled water for use in the Resin and Mini-prill Units.
A "treater truck" is staged at the Barnsdall facility and used to support oil field operations for
another BPC business unit. This operation includes storage and transfer of friction reducers,
descalers, etc., some of which are flammable or corrosive. The largest storage container at
the location is 550 gallons.
The Miniprill process.
The Emulsion process.
Microcrystalline blending.
PERMIT MEMORANDUM 2004-162-TVR
VI.
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16
OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252:100-1 (General Provisions)
Subchapter 1 includes definitions but there are no regulatory requirements.
[Applicable]
OAC 252:100-3 (Air Quality Standards and Increments)
[Applicable]
Subchapter 3 enumerates the primary and secondary ambient air quality standards and the
significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these
standards.
OAC 252:100-4 (New Source Performance Standards)
[Not Applicable]
Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on July 1, 2002,
except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart
C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix
G. These requirements are covered in the “Federal Regulations” section.
OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees)
[Applicable]
Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission
inventories annually, and pay annual operating fees based upon total annual emissions of
regulated pollutants. Emission inventories were submitted and fees paid for previous years as
required.
OAC 252:100-8 (Permits for Part 70 Sources)
[Applicable]
Part 5 includes the general administrative requirements for Part 70 permits. Any planned
changes in the operation of the facility that result in emissions not authorized in the permit and
that exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior
notification to AQD and may require a permit modification. Insignificant activities refer to those
individual emission units either listed in Appendix I or whose actual calendar year emissions do
not exceed the following limits.





5 TPY of any one criteria pollutant
2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20%
of any threshold less than 10 TPY for a HAP that the EPA may establish by rule
0.6 TPY of any one Category A toxic substance
1.2 TPY of any one Category B toxic substance
6.0 TPY of any one Category C toxic substance
Emission limitations and operational requirements necessary to assure compliance with all
applicable requirements for all sources are taken from the original Part 70 operating permit, the
Part 70 renewal application, or developed from the applicable requirement.
OAC 252:100-9 (Excess Emissions Reporting Requirements)
[Applicable]
In the event of any release which results in excess emissions, the owner or operator of such
facility shall notify the Air Quality Division as soon as the owner or operator of the facility has
knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10)
PERMIT MEMORANDUM 2004-162-TVR
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17
working days after the immediate notice is given, the owner or operator shall submit a written
report describing the extent of the excess emissions and response actions taken by the facility.
Part 70/Title V sources must report any exceedance that poses an imminent and substantial
danger to public health, safety, or the environment as soon as is practicable. Under no
circumstances shall notification be more than 24 hours after the exceedance.
OAC 252:100-13 (Open Burning)
[Applicable]
Open burning of refuse and other combustible material is prohibited except as authorized in the
specific examples and under the conditions listed in this subchapter.
OAC 252:100-19 (Particulate Matter (PM))
[Applicable]
Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with
emission limits based on maximum design heat input rating. Appendix C specifies a PM
emission limitation of 0.60 lbs/MMBTU for all equipment at this facility with a heat input rating
of 10 Million BTU per hour (MMBTUH) or less. Fuel-burning equipment is defined in OAC
252:100-1 as “combustion devices used to convert fuel or wastes to usable heat or power.” Thus,
the three boilers are subject to the requirements of this subchapter. AP-42 (7/98) Table 1.4-2 lists
natural gas TPM emissions to be 7.6 lbs/million scf or about 0.0076 lbs/MMBTU, which is in
compliance. AP-42 (9/98) Tables 1.3-1 and 1.3-2 list #2 fuel oil TPM emissions to be 3.3 lbs/1,000
gallons or about 0.02 lbs/MMBTU, which is in compliance.
Equipment
BLR1
BLR2
BLR3
Maximum Heat
Input
72.2 MMBTUH
72.2 MMBTUH
52.5 MMBTUH
Appendix C Emission
Limit, (lbs/MMBTU)
0.38
0.38
0.41
Potential Emission
Rate, (lbs/MMBTU)
0.025 (oil)
0.025 (oil)
0.025 (oil)
Section 19-12 limits particulate emissions from emission points in an industrial process based on
process weight rate, as specified in Appendix G. As shown in the following table, all emission
points are in compliance with Subchapter 19.
Equipment
Micronizer
Air attrition
Prilling tower
Mini-prill
Process
Appendix G Emission
Rate, TPH
Limit, lbs/hr
0.302
1.84
0.01
0.19
3.45
9.40
3.45
9.40
Potential Emission
Rate, lbs/hr
0.06
0.02
8.63
0.10
OAC 252:100-25 (Visible Emissions and Particulates)
[Applicable]
No discharge of greater than 20% opacity is allowed except for short-term occurrences that
consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed
three such periods in any consecutive 24 hours. In no case shall the average of any six-minute
period exceed 60% opacity. When burning natural gas there is very little possibility of exceeding
these standards.
PERMIT MEMORANDUM 2004-162-TVR
DRAFT
18
OAC 252:100-29 (Fugitive Dust)
[Applicable]
No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the
property line on which the emissions originated in such a manner as to damage or to interfere
with the use of adjacent properties, or cause air quality standards to be exceeded, or to interfere
with the maintenance of air quality standards. Under normal operating conditions, this facility has
negligible potential to violate this requirement; therefore it is not necessary to require specific
precautions to be taken.
OAC 252:100-31 (Sulfur Compounds)
[Applicable]
Part 5 The new (constructed after July 1, 1972) equipment standard for emissions of oxides of
sulfur measured as sulfur dioxide from gas-fired fuel-burning equipment is 0.2 pounds per
MMBTU heat input, maximum three-hour average. The three boilers were installed in 1978 and
are new equipment. AP-42, Table 1.4-2 (3/98), lists natural gas SO2 emissions to be 0.6 lbs/MMft3
or about 0.0006 lbs/MMBTU, which is in compliance. The standard for liquid fuel is 0.8
lbs/MMBTU, and the AP-42 factor for #2 fuel oil equates to approximately 0.48 lbs/MMBTU,
which is also in compliance.
OAC 252:100-33 (Nitrogen Oxides)
[Applicable]
This subchapter limits new (constructed after July 1, 1972) gas-fired or liquid-fired fuel-burning
equipment with rated heat input greater than or equal to 50 MMBTUH to emissions of 0.20 or
0.30 lbs of NOx per MMBTU, three-hour average, respectively. The three boilers were installed
in 1978 and are new sources. Their rated heat inputs of 72.2, 72.2 and 52.5 MMBTUH all
exceed the 50 MMBTUH threshold and they are affected sources. The AP-42 factor for natural
gas is approximately 0.1 lb/MMBTU and the factor for #2 fuel oil equates to approximately 0.13
lbs/MMBTU, both of which are in compliance.
OAC 252:100-35 (Carbon Monoxide)
[Not Applicable]
None of the following affected processes are located at this facility: gray iron cupola, blast
furnace, basic oxygen furnace, petroleum catalytic cracking unit, or petroleum catalytic
reforming unit.
OAC 252:100-37 (Volatile Organic Compounds)
[Applicable]
Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons
or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system. The vapor pressures of
diesel, kerosene, and toluene are all less than 1.5 psia; therefore, Part 3 does not apply to the
storage of these liquids. The 564-gallon gasoline tanks are properly equipped.
Part 5 limits the VOC content of coating used in coating lines or operations. This facility will not
normally conduct coating or painting operations except for routine maintenance of the facility
and equipment, which is exempt.
Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize
emissions. Temperature and available air must be sufficient to provide essentially complete
combustion.
PERMIT MEMORANDUM 2004-162-TVR
DRAFT
19
OAC 252:100-41 (Hazardous Air Pollutants and Toxic Air Contaminants)
[Applicable]
Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted
by reference as they exist on July 1, 2003, with the exception of Subparts B, H, I, K, Q, R, T, W
and Appendices D and E, all of which address radionuclides. In addition, General Provisions as
found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control Technology
(MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, J, L, M, N, O, Q, R, S, T, U,
W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS, TT, UU,
VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO, PPP,
QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, GGGG, HHHH, JJJJ, NNNN, OOOO,
QQQQ, RRRR, SSSS, TTTT, UUUU, VVVV, WWWW, XXXX, BBBBB, CCCCC, FFFFF,
JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP, QQQQQ, and SSSSS are hereby adopted
by reference as they exist on July 1, 2003. These standards apply to both existing and new
sources of HAPs. These requirements are covered in the “Federal Regulations” section.
Part 5 is a state-only requirement governing toxic air contaminants. New sources (constructed
after March 9, 1987) emitting any category “A” pollutant above de minimis levels must perform
a BACT analysis, and if necessary, install BACT. All sources are required to demonstrate that
emissions of any toxic air contaminant that exceed the de minimis level do not cause or
contribute to a violation of the maximum acceptable ambient concentration (MAAC). All
sources at Polywax Unit A may be considered as “existing,” and are not affected by the BACT
portion of the rule. Sources at Polywax Unit B were addressed under the terms of Permit No. 88017-O and its modifications. A nitrogen blanket in certain vessels was part of the consideration
for decreased emissions authorized in that permit. Certain new toxics were discussed in
construction Permit No. 98-107-C. The facility does not emit Category A toxics. Section 43
provides exemptions for those emissions that fall below their respective Category de minimis
thresholds. As noted in the “HAP and Oklahoma toxic emissions” portion of Section IV above, a
complete discussion of all toxic emissions shows that only Category C toxics t-butyl alcohol
(TBA), with emissions of 13.7 TPY, and toluene, with worst case emissions of 550 TPY, exceed
their de minimis of 6 TPY. Screen3 modeling for TBA showed a maximum ground level
concentration (GLC) of 1,435 g/m3, well below the MAAC of 30,323 g/m3. ISCST modeling for
toluene, scaled from 400 TPY up to 550 TPY, showed a GLC of 5,943 g/m3, well below the
MAAC of 37,500 g/m3.
Oklahoma has incorporated many subparts of federal NESHAPs in this subchapter. A complete
discussion of each subpart for which this facility is, in whole or in part, an affected source is
found in Section VII (Federal Regulations) below.
OAC 252:100-43 (Testing, Monitoring, and Recordkeeping)
[Applicable]
This subchapter provides general requirements for testing, monitoring and recordkeeping and
applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.
To determine compliance with emissions limitations or standards, the Air Quality Director may
require the owner or operator of any source in the state of Oklahoma to install, maintain and
operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant
source. All required testing must be conducted by methods approved by the Air Quality Director
and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol
shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.
PERMIT MEMORANDUM 2004-162-TVR
DRAFT
20
Emissions and other data required to demonstrate compliance with any federal or state emission
limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and
submitted as required by this subchapter, an applicable rule, or permit requirement. Data from
any required testing or monitoring not conducted in accordance with the provisions of this
subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive
use, of any credible evidence or information relevant to whether a source would have been in
compliance with applicable requirements if the appropriate performance or compliance test or
procedure had been performed.
The following Oklahoma Air Quality Rules are not applicable to this facility.
OAC 252:100-11
Alternative Reduction
not requested
OAC 252:100-15
Mobile Sources
not in source category
OAC 252:100-17
Incinerators
not type of emission unit
OAC 252:100-23
Cotton Gins
not type of emission unit
OAC 252:100-24
Feed & Grain Facility
not in source category
OAC 252:100-39
Organic Materials Nonattainment
not in control area
OAC 252:100-47
Landfills
not in source category
VII.
FEDERAL REGULATIONS
PSD, 40 CFR 52
[Applicable]
This facility is a PSD-major stationary source and future increases of any emissions above the
significance level for each pollutant will require PSD review.
NSPS, 40 CFR 60
[Not Applicable]
Subpart Dc (Small Industrial-Commercial-Institutional Steam Generating Units) affects steamgenerating units constructed after June 9, 1989, and with capacity between 10 and 100 MMBTUH.
The existing boilers were all constructed before the effective date, and have not been modified.
Subpart Kb (VOL Storage Vessels) regulates volatile organic liquid storage tanks larger than
19,812 gallons capacity and built after July 23, 1984. Facility tanks were either built before 1984
or are too small to be affected facilities.
Subpart VV (VOC Leaks from SOCMI) Not an affected source per 40 CFR 60.480.
Subpart DDD (VOC from Polymer Manufacturing) Not an affected source per 40 CFR 60.560.
Subpart III (VOC from SOCMI) Not an affected source per 40 CFR 60.610.
Subpart NNN (VOC from SOCMI) Not an affected source per 40 CFR 60.660.
NESHAP, 40 CFR 61
[Not Applicable]
There are no emissions of any of the regulated pollutants: arsenic, asbestos, beryllium, coke oven
emissions, mercury, radionuclides, or vinyl chloride, except for a trace of benzene.
Subpart J (Equipment Leaks of Benzene) This facility is not an affected source because none of
the equipment is in benzene service, as that term is defined in 40 CFR 61.111.
Subpart V (Equipment Leaks of Volatile HAPs) This facility is not an affected source because
none of the equipment is in VHAP service, as that term is defined in 40 CFR 61.241.
NESHAP, 40 CFR 63
[Only FFFF is Applicable]
PERMIT MEMORANDUM 2004-162-TVR
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21
Subpart F (SOCMI) Not an affected source per 40 CFR 63.100.
Subpart G (SOCMI) Not an affected source per 40 CFR 63.100 and 110.
Subpart H (SOCMI) Not an affected source per 40 CFR 63.100 and 160.
Subpart I (SOCMI) Not an affected source per 40 CFR 63.100 and 190.
Subpart U (Polymers & Resins, Part I) Not an affected source per 40 CFR 63.480.
Subpart W (Polymers & Resins, Part II) Not an affected source per 40 CFR 63.520.
Subpart JJJ (Polymers & Resins, Part III & IV) Not an affected source per 40 CFR 63.1310.
Subpart FFFF (Miscellaneous Organic Chemical Manufacturing, or MON) was issued on
November 10, 2003, and affects facilities that manufacture miscellaneous organic chemicals and
that are located at major sources of HAP, as that is defined in 40 CFR 63.2. Baker Petrolite is a
major source of HAP and is an affected facility per 40 CFR 63.2435(b)(1)(i). This MACT
applies to MCPUs, or miscellaneous organic chemical manufacturing process units, which
include assigned storage tanks, product transfer racks, open systems conveying wastewater-like
material, and components, such as valves, connectors, etc. Work practice standards and limits
are described for continuous process vents, batch process vents, storage tanks, transfer racks,
equipment leaks, and wastewater streams, inter alia. Various monitoring methods are allowed,
including CEMs and parametric monitoring. Standards generally include percentage reductions,
requiring performance testing to establish baselines and reduction efficiencies, but design
evaluations may also be acceptable. Since the facility is an existing source, compliance with the
MACT standards is not required until November 11, 2006. Certain notifications required by
§2520 are due before the compliance date, including initial notification and performance testing
notices. The facility shall provide proper notices, perform testing as required, and submit its
compliance plan before the existing source compliance date.
CAM, 40 CFR Part 64
[Not Applicable]
This part applies to any pollutant-specific emission unit at a major source that is required to
obtain an operating permit, for any application for an initial operating permit submitted after
April 18, 1998, that addresses “large emissions units,” or any application that addresses “large
emissions units” as a significant modification to an operating permit, or for any application for
renewal of an operating permit, if it meets all of the following criteria.



It is subject to an emission limit or standard for an applicable regulated air pollutant
It uses a control device to achieve compliance with the applicable emission limit or standard
It has potential emissions, prior to the control device, of the applicable regulated air pollutant
of 100 TPY or 10/25 TPY of a HAP
The particulate control devices in use are considered integral pieces of production equipment
since they return collected particles to the production process streams. Therefore, CAM does not
apply. In addition, the requirements of MACT FFFF, affecting the facility after November 11,
2006, would satisfy any unrecognized requirement of CAM.
Chemical Accident Prevention Provisions, 40 CFR Part 68
[Applicable]
The facility does process or store more than the threshold quantity of ethylene and propylene
(Section 112r of the Clean Air Act 1990 Amendments). A Risk Management Plan was
PERMIT MEMORANDUM 2004-162-TVR
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submitted to EPA Region 6 on June 18, 1999, and deemed to be complete on June 24, 1999.
More information on this federal program is available on the web page: www.epa.gov/ceppo.
Stratospheric Ozone Protection, 40 CFR Part 82
[Applicable]
This facility does not produce, consume, recycle, import, or export any controlled substances or
controlled products as defined in this part, nor does this facility perform service on motor (fleet)
vehicles, which involves ozone-depleting substances. Therefore, as currently proposed, this
facility is not subject to these requirements. To the extent that the facility has air-conditioning
units that apply, the permit requires compliance with Part 82.
VIII. COMPLIANCE
Inspection
Full compliance evaluations are performed at this facility, usually annually, with the most recent
having been performed by Robert Eddington, ROAT Environmental Specialist, on January 10,
2005. The inspection found all equipment as described in the original TV permit and subsequent
construction permits and determinations. All emissions and recordkeeping were in compliance
with limits or standards set in the permits. No equipment has been added since the latest
inspection, so an initial compliance evaluation for this renewal permit is not necessary. Among
other things, emission inventory data for 2003 showed the following information. Toluene had
emissions of 183 TPY, ethylene 87 TPY, propylene and hexene each less than 1 TPY, and tertbutyl alcohol less than 8 TPY. These values, and total VOC emissions of 280 TPY, are well
below permit-authorized amounts. Throughputs of the various particulate emission-producing
activities were all below authorized limits. The prilling tower, for example, had only 8,305 TPY
of throughput. The boilers, with a combined heat input of 196.9 MMBTUH, had total natural gas
consumption of 307,525 MMBTU, equating to a capacity factor of approximately 18%. Records
for insignificant activities confirmed their status.
Testing
MACT FFFF may require testing. Protocols concerning such testing will be discussed in the
Specific Conditions.
Tier Classification and Public Review
This application has been classified as Tier II based on the request for a Title V Operating permit
renewal for an existing major source. Public notice of filing of this application was published in
the August 5, 2004, issue of the Barnsdall Times. A review copy was available at the facility’s
office in Barnsdall. Public notice of the 30-day public review opportunity for the draft permit
will be published in a local newspaper of general circulation when the draft is available. This
facility is located within 50 miles of the border with a contiguous state. Notice of the draft
permit will be provided to the state of Kansas.
The applicant has submitted an affidavit that they are not seeking a permit for land use or for any
operation upon land owned by others without their knowledge. The affidavit certifies that the
applicant owns the real property.
PERMIT MEMORANDUM 2004-162-TVR
DRAFT
23
Fee Paid
Renewal Title V operating permit fee of $1,000.
IX. SUMMARY
This facility was constructed as described in the application. There are no active Air Quality
compliance or enforcement issues that would affect the issuance of this permit. Issuance of the
operating permit is recommended, contingent on public and EPA review.
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
Baker Petrolite Polymers Division
Synthetic Wax Manufacturing Facility
Permit No. 2004-162-TVR
The permittee is authorized to operate in conformity with the specifications submitted to Air
Quality on June 7, 2004. The Evaluation Memorandum dated March 29, 2005, explains the
derivation of applicable permit requirements and estimates of emissions; however, it does not
contain operating limitations or permit requirements. Continuing operations under this permit
constitutes acceptance of, and consent to, the conditions contained herein.
1. Emission points and authorized emissions are tabulated as follows.
EUG 1
Polywax Units (EP A & B)
Point
Service
C-1005
Reaction Initiator Tank & Weigh Cell
C-3020
Reaction Initiator Tank & Weigh Cell
C-1002
Carrier Solvent Storage Tank
E-4351
Oxidation Vessel Condenser (Plant A)
E-4350
Final Vent Condenser (Plant A)
E-4310
Final Vent Condenser (Plant B)
F-0000
*Fugitives (Plants A & B)
*Fugitives include storage tanks, wastewater basin and
flanges, etc.
EUG 2
[OAC 252:100-8-6(a)]
Capacity
Const Date
10,000 gal
1970
12,000 gal
1993
10,000 gal
1970
N/A
1993
N/A
1993
N/A
1989
N/A
1989
lagoons, as well as piping,
Prilling Operation
The only point is the cyclone vent, CYVENT, constructed in 1975. This point is for the prilling
tower, which is to be phased out. Its replacement, the mini-prill, is an insignificant activity.
EUG 3
Boilers
Point
BLR1
BLR2
BLR3
Make/Model
Trane/Coen
Trane/Coen
Trane/Coen
Serial Number
10837
10835
10659
Capacity
72.2 MMBTUH
72.2 MMBTUH
52.5 MMBTUH
Const Date
1978
1978
1978
The following table authorizes emissions for all three units based on continuous operation,
allowing the use of liquid fuel in units #1 and #2 for a combined annual total of 480,000 gallons.
Liquid fuels authorized include #2 fuel oil and co-products known as Solvent 250 and Solvent
125. Compliance with the limits shall be demonstrated by monthly and 12-month rolling
SPECIFIC CONDITIONS 2004-162-TVR
DRAFT
2
calculations of emissions, based on current AP-42 factors. Any additional alternate fuels
proposed by the facility and approved by DEQ shall adhere to these limits.
Pollutant
PM10
NOX
CO
VOC
SO2
EUG 4
Lb/hr
3.54
24.2
15.8
1.04
34.1
TPY
6.77
83.6
69.0
4.53
17.7
Resin Unit
Point
E-6010
E-6026
EUG 5
Service
Condenser vent
Co-product storage tanks condenser vent
Const Date
2004
1989
Oxidation Unit
Point
V-6101
EUG 6
Service
Catalytic oxidizer exhaust
Const Date
1999
Packaging Unit
Point
G-6303
AAM
Unit
Prilling tower
Micronizer
Air attrition
Service
Micronizer baghouse exhaust
Air attrition cyclone/baghouse exhaust
Source
Pollutant
Cyclone
Baghouse filter
Baghouse filter
PM
PM
PM
Const Date
1999
1999
Emissions
Lb/hr
TPY
8.63
37.78
0.06
0.10
0.02
0.05
A Plantwide Applicability Limit (PAL) of 550 TPY (12-month rolling) of VOC applies to all
sources in the facility, regardless of their having been specifically named elsewhere in this Specific
Condition. Toluene, ethylene, propylene, hexene, and tert-butyl alcohol are included as VOC for
the purposes of determining compliance with this limit.
With the exception of toluene and tert-butyl alcohol, no toxics included in the VOC totals listed
above shall be emitted at levels exceeding their respective OAC 252:100-41 Category de minimis
thresholds. Toluene may be emitted in any amount less than or equal to 550 TPY, providing that
the PAL of 550 TPY is not exceeded. Tert-butyl alcohol, CAS #75-65-0, is authorized not to
exceed 13.7 TPY.
SPECIFIC CONDITIONS 2004-162-TVR
DRAFT
3
2. Compliance with the PM limits established in Specific Condition 1 (SC #1) shall be
demonstrated by production, with limits of 5,000 TPY of on-spec product from the resin unit
(excluding the emulsions process), 3,120 TPY of on-spec product from the oxidation unit
(excluding microcrystalline blending), 1,000 TPY from the micronizer, 50 TPY from the air
attrition unit, and throughput of 30,222 TPY at the prilling tower. No production limit is set for the
Sandvik belt unit, because it has insignificant emissions. Emulsions produce negligible VOC and
PM emissions, and shall not be considered in any of these throughput limits. Additionally, when
the prilling tower is taken out of service, its throughput limit will be discontinued, because the
mini-prill replacement operation is an insignificant activity.
[OAC 252:100-8-6(a)]
3. The cyclone and baghouse controlling particulate emissions from the air attrition unit may be
replaced only by devices with equivalent or superior capture efficiency (90% & 99.99% =
99.999%). The baghouse controlling particulate emissions from the micronizer may be replaced
only by a device of equal or greater capture efficiency (99.99%). Cyclones controlling emissions
from the prilling tower may be replaced only by devices of equal or greater efficiency. The nitrogen
blanket used in controlling vapor emissions from various equipment on the Polywax units may be
replaced only by a method of equal or greater efficiency.
[OAC 252:100-8-6(a)(1)]
4. Compliance with the VOC limits established in SC #1 shall be demonstrated by material
balance calculations as performed in the confidential permit application package, mirrored in the
annual emission inventory (Turnaround Document) analysis, and described as follows.
Emissions of solvent to atmosphere are based on material balance, which is the difference
between purchases of solvent and all measurable outputs. These outputs include solvent bound
in the synthetic wax product, solvent content of wastes injected underground at the disposal well,
and solvent contained in waste or co-product shipped off-site.
In addition, volatile HAP emissions from units affected by the MON (see SC #11 below) shall be
calculated using the procedures specified in 40 CFR 63.127(d)(2), beginning no later than
November 10, 2006.
[OAC 252:100-43 and 100-5, 40 CFR 63 Subpart FFFF]
5. Emissions of raw materials are also based on material balance. Propylene and hexene
emissions shall be calculated by taking the difference between consumption of each material and
the amount of each contained in measurable outputs. One output is the theoretical amount of
propylene or hexene included in the various products. Another is the proportion of each included
in waste, such as off-spec product or material flushed out of production lines. Ethylene
emissions are considered to be the difference between total consumption of raw materials
(ethylene, propylene and hexene) and the sum of total production, propylene and hexene
emissions, and solid losses. Additional outputs considered in this calculation include solids
accumulating in the “1017 Pit,” wax picked up from the ground, spilled, leaked, or recovered in
any way, and solids collected in the weir section of the 1017 Pit.
[OAC 252:100-43]
6. All pollution control equipment shall be maintained in proper working order per the
manufacturers’ specifications. Inlet temperature set point of the catalytic oxidizer shall be
maintained at or above 600 F and the process shall be shut down if the actual temperature drops
SPECIFIC CONDITIONS 2004-162-TVR
DRAFT
4
below 550 F when oxidation is occurring. The catalyst shall be sampled and tested at intervals no
longer than three years. Temperature records shall be maintained on circular or strip charts.
Additional requirements may apply commencing November 10, 2006, if the oxidizer is used for
MON (see SC #11 below) compliance.
[OAC 252:100-43, 40 CFR 63 Subpart FFFF]
7. The permittee shall use only commercial-quality natural gas in boilers #1, #2, and #3, and/or
liquid fuels in boilers #1 and #2. Liquid fuels include #2 fuel oil and co-products identified as
Solvent 250 and Solvent 125. Sulfur content of the oil shall not exceed 0.5% by weight.
Consumption of liquid fuels shall not exceed 480,000 gallons per year. Alternate liquid fuels may
be approved by DEQ upon submittal of information adequate to demonstrate that none of the limits
set in SC #1 will be breached through use of the new fuel and that no new pollutants will be
emitted.
[OAC 252:100-31]
8. The following records shall be maintained on-site. All such records shall be made available
to regulatory personnel upon request. These records shall be maintained for a period of at least
five years after the time they are made.
[OAC 252:100-43]
a) Production records for the Polywax, resin, oxidation, micronizer and air attrition units
(monthly and 12-month rolling total)
b) Quantities of raw materials used (monthly and 12-month rolling total)
c) Emission calculations as described in SC #4
d) Pollution control equipment maintenance records required by SC #6
e) Boiler fuel use, including natural gas and each liquid fuel (monthly and 12-month rolling
total)
f) Sulfur content of #2 fuel oil (each delivery or as burned)
g) Data and analyses submitted for additional alternate liquid fuels, per SC #7.
9. The following records shall be maintained on-site to verify insignificant activities.
[OAC 252:100-43]
a) Throughput for fuel storage/dispensing equipment operated solely for facility owned
vehicles, if throughput is less than 2,175 gallons per day, averaged over a 30-day period.
b) Records of capacity of all storage tanks with a capacity of 39,894 gallons or less storing a
fluid with a true vapor pressure less than 1.5 psia, and for each delivery of fluid, the type
and quantity.
c) Hours of operation for each stationary reciprocating engine burning natural gas, gasoline,
aircraft fuels, or oil, used for emergency power generation less than 500 hours per year.
d) Gallons of coatings, thinners and clean-up solvents used (annual)
e) Amount of cold flow improver product(s) manufactured and the associated amount of
Solvent 14 used (monthly)
SPECIFIC CONDITIONS 2004-162-TVR
DRAFT
5
10. No later than 30 days after each anniversary date of the issuance of the original Title V
permit (December 3, 1999), the permittee shall submit to Air Quality Division of DEQ, with a
copy to the US EPA, Region 6, certification of compliance with the terms and conditions of this
permit. The following specific information is required to be included.
[OAC 252:100-8-6 (c)(5)(A) & (D)]
a. A tabulation of annual emissions as partially described in Specific Condition 4
b. Production records for the Polywax, resin, oxidation, micronizer and air attrition units
(total annual)
c. Quantities of raw materials used (total annual)
11. The facility is subject to the MACT standard for Miscellaneous Organic Chemical
Manufacturing (FFFF), and shall demonstrate compliance by November 10, 2006. Initial
notifications required by §63.2515 shall be submitted on a timely basis. Test protocols and plans
shall be submitted in accordance with §63.7.
[40 CFR 63, Subpart FFFF]
12. The Permit Shield (Standard Conditions, Section VI) is extended to the following
requirements that have been determined to be inapplicable to this facility.
[OAC 252:100-8-6(d)(2)]
OAC 252:100-7
OAC 252:100-10
OAC 252:100-11
OAC 252:100-15
OAC 252:100-17
OAC 252:100-23
OAC 252:100-24
OAC 252:100-39
OAC 252:100-47
Permits for Minor Facilities
General Operating Permit
Alternative Reduction
Mobile Sources
Incinerators
Cotton Gins
Feed & Grain Facility
Organic Materials Nonattainment
Landfills
not in source category
not in source category
not requested
not in source category
not type of emission unit
not type of emission unit
not in source category
not in control area
not in source category
13. This permit supersedes all previous air quality permits for this facility, which are null and
void.
TITLE V (PART 70) PERMIT TO OPERATE / CONSTRUCT
STANDARD CONDITIONS
(March 9, 2005)
SECTION I.
DUTY TO COMPLY
A. This is a permit to operate / construct this specific facility in accordance with Title V of the
federal Clean Air Act (42 U.S.C. 7401, et seq.) and under the authority of the Oklahoma Clean
Air Act and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]
B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ). The permit does not relieve the holder of the
obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or
ordinances.
[Oklahoma Clean Air Act, 27A O.S. § 2-5-112]
C. The permittee shall comply with all conditions of this permit. Any permit noncompliance
shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement
action, for revocation of the approval to operate under the terms of this permit, or for denial of an
application to renew this permit. All terms and conditions (excluding state-only requirements)
are enforceable by the DEQ, by EPA, and by citizens under section 304 of the Clean Air Act.
This permit is valid for operations only at the specific location listed.
[40 CFR §70.6(b), OAC 252:100-8-1.3 and 8-6 (a)(7)(A) and (b)(1)]
D. It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of the permit.
[OAC 252:100-8-6 (a)(7)(B)]
SECTION II.
REPORTING OF DEVIATIONS FROM PERMIT TERMS
A. Any exceedance resulting from emergency conditions and/or posing an imminent and
substantial danger to public health, safety, or the environment shall be reported in accordance
with Section XIV.
[OAC 252:100-8-6 (a)(3)(C)(iii)]
B. Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.
[OAC 252:100-8-6 (a)(3)(C)(iv)]
C. Oral notifications (fax is also acceptable) shall be made to the AQD central office as soon as
the owner or operator of the facility has knowledge of such emissions but no later than 4:30 p.m.
the next working day the permittee becomes aware of the exceedance. Within ten (10) working
days after the immediate notice is given, the owner operator shall submit a written report
describing the extent of the excess emissions and response actions taken by the facility. Every
written report submitted under OAC 252:100-8-6 (a)(3)(C)(iii) shall be certified by a responsible
official.
[OAC 252:100-8-6 (a)(3)(C)(iii)]
MAJOR SOURCE STANDARD CONDITIONS
SECTION III.
March 9, 2005
2
MONITORING, TESTING, RECORDKEEPING & REPORTING
A. The permittee shall keep records as specified in this permit. Unless a different retention
period or retention conditions are set forth by a specific term in this permit, these records,
including monitoring data and necessary support information, shall be retained on-site or at a
nearby field office for a period of at least five years from the date of the monitoring sample,
measurement, report, or application, and shall be made available for inspection by regulatory
personnel upon request. Support information includes all original strip-chart recordings for
continuous monitoring instrumentation, and copies of all reports required by this permit. Where
appropriate, the permit may specify that records may be maintained in computerized form.
[OAC 252:100-8-6 (a)(3)(B)(ii), 8-6 (c)(1), and 8-6 (c)(2)(B)]
B. Records of required monitoring shall include:
(1) the date, place and time of sampling or measurement;
(2) the date or dates analyses were performed;
(3) the company or entity which performed the analyses;
(4) the analytical techniques or methods used;
(5) the results of such analyses; and
(6) the operating conditions as existing at the time of sampling or measurement.
[OAC 252:100-8-6 (a)(3)(B)(i)]
C. No later than 30 days after each six (6) month period, after the date of the issuance of the
original Part 70 operating permit, the permittee shall submit to AQD a report of the results of any
required monitoring. All instances of deviations from permit requirements since the previous
report shall be clearly identified in the report.
[OAC 252:100-8-6 (a)(3)(C)(i) and (ii)]
D. If any testing shows emissions in excess of limitations specified in this permit, the owner or
operator shall comply with the provisions of Section II of these standard conditions.
[OAC 252:100-8-6 (a)(3)(C)(iii)]
E. In addition to any monitoring, recordkeeping or reporting requirement specified in this
permit, monitoring and reporting may be required under the provisions of OAC 252:100-43,
Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean
Air Act or Oklahoma Clean Air Act.
F. Submission of quarterly or semi-annual reports required by any applicable requirement that
are duplicative of the reporting required in the previous paragraph will satisfy the reporting
requirements of the previous paragraph if noted on the submitted report.
G. Every report submitted under OAC 252:100-8-6 and OAC 252:100-43 shall be certified by a
responsible official.
[OAC 252:100-8-6 (a)(3)(C)(iv)]
H. Any owner or operator subject to the 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 60.7 (b)]
MAJOR SOURCE STANDARD CONDITIONS
March 9, 2005
3
I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by the subpart recorded in a permanent file suitable
for inspection. This file shall be retained for at least two years following the date of such
measurements, maintenance, and records.
[40 CFR 60.7 (d)]
J. The permittee of a facility that is operating subject to a schedule of compliance shall submit
to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for
achieving the activities, milestones or compliance required in the schedule of compliance and the
dates when such activities, milestones or compliance was achieved. The progress reports shall
also contain an explanation of why any dates in the schedule of compliance were not or will not
be met, and any preventative or corrective measures adopted.
[OAC 252:100-8-6 (c)(4)]
K. All testing must be conducted by methods approved by the Division Director under the
direction of qualified personnel. All tests shall be made and the results calculated in accordance
with standard test procedures. The use of alternative test procedures must be approved by EPA.
When a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated
in accordance with the manufacturer’s instructions and in accordance with a protocol meeting the
requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method
approved by Air Quality. [40 CFR §70.6(a), 40 CFR §51.212(c)(2), 40 CFR § 70.7(d), 40 CFR
§70.7(e)(2), OAC 252:100-8-6 (a)(3)(A)(iv), and OAC 252:100-43]
L. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required
by 40 CFR Part 60, 61, and 63, for all equipment constructed or operated under this permit
subject to such standards.
[OAC 252:100-4-5 and OAC 252:100-41-15]
SECTION IV.
COMPLIANCE CERTIFICATIONS
A. No later than 30 days after each anniversary date of the issuance of the original Part 70
operating permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a
certification of compliance with the terms and conditions of this permit and of any other
applicable requirements which have become effective since the issuance of this permit. The
compliance certification shall also include such other facts as the permitting authority may
require to determine the compliance status of the source.
[OAC 252:100-8-6 (c)(5)(A), (C)(v), and (D)]
B. The certification shall describe the operating permit term or condition that is the basis of the
certification; the current compliance status; whether compliance was continuous or intermittent;
the methods used for determining compliance, currently and over the reporting period; and a
statement that the facility will continue to comply with all applicable requirements.
[OAC 252:100-8-6 (c)(5)(C)(i)-(iv)]
C. Any document required to be submitted in accordance with this permit shall be certified as
being true, accurate, and complete by a responsible official. This certification shall state that,
based on information and belief formed after reasonable inquiry, the statements and information
in the certification are true, accurate, and complete.
[OAC 252:100-8-5 (f) and OAC 252:100-8-6 (c)(1)]
MAJOR SOURCE STANDARD CONDITIONS
March 9, 2005
4
D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions
units or stationary sources that are not in compliance with all applicable requirements. This
schedule shall include a schedule of remedial measures, including an enforceable sequence of
actions with milestones, leading to compliance with any applicable requirements for which the
emissions unit or stationary source is in noncompliance. This compliance schedule shall
resemble and be at least as stringent as that contained in any judicial consent decree or
administrative order to which the emissions unit or stationary source is subject. Any such
schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the
applicable requirements on which it is based, except that a compliance plan shall not be required
for any noncompliance condition which is corrected within 24 hours of discovery.
[OAC 252:100-8-5 (e)(8)(B) and OAC 252:100-8-6 (c)(3)]
SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE
PERMIT TERM
The permittee shall comply with any additional requirements that become effective during the
permit term and that are applicable to the facility. Compliance with all new requirements shall
be certified in the next annual certification.
[OAC 252:100-8-6 (c)(6)]
SECTION VI.
PERMIT SHIELD
A. Compliance with the terms and conditions of this permit (including terms and conditions
established for alternate operating scenarios, emissions trading, and emissions averaging, but
excluding terms and conditions for which the permit shield is expressly prohibited under OAC
252:100-8) shall be deemed compliance with the applicable requirements identified and included
in this permit.
[OAC 252:100-8-6 (d)(1)]
B. Those requirements that are applicable are listed in the Standard Conditions and the Specific
Conditions of this permit. Those requirements that the applicant requested be determined as not
applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6 (d)(2)]
SECTION VII.
ANNUAL EMISSIONS INVENTORY & FEE PAYMENT
The permittee shall file with the AQD an annual emission inventory and shall pay annual fees
based on emissions inventories. The methods used to calculate emissions for inventory purposes
shall be based on the best available information accepted by AQD.
[OAC 252:100-5-2.1, -5-2.2, and OAC 252:100-8-6 (a)(8)]
SECTION VIII.
TERM OF PERMIT
A. Unless specified otherwise, the term of an operating permit shall be five years from the date
of issuance.
[OAC 252:100-8-6 (a)(2)(A)]
MAJOR SOURCE STANDARD CONDITIONS
March 9, 2005
5
B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely
and complete renewal application has been submitted at least 180 days before the date of
expiration.
[OAC 252:100-8-7.1 (d)(1)]
C. A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction
is not commenced within 18 months after the date the permit or authorization was issued, or if
work is suspended for more than 18 months after it is commenced.
[OAC 252:100-8-1.4(a)]
D. The recipient of a construction permit shall apply for a permit to operate (or modified
operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]
SECTION IX.
SEVERABILITY
The provisions of this permit are severable and if any provision of this permit, or the application
of any provision of this permit to any circumstance, is held invalid, the application of such
provision to other circumstances, and the remainder of this permit, shall not be affected thereby.
[OAC 252:100-8-6 (a)(6)]
SECTION X.
PROPERTY RIGHTS
A. This permit does not convey any property rights of any sort, or any exclusive privilege.
[OAC 252:100-8-6 (a)(7)(D)]
B. This permit shall not be considered in any manner affecting the title of the premises upon
which the equipment is located and does not release the permittee from any liability for damage
to persons or property caused by or resulting from the maintenance or operation of the equipment
for which the permit is issued.
[OAC 252:100-8-6 (c)(6)]
SECTION XI.
DUTY TO PROVIDE INFORMATION
A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty
(60) days of the request unless the DEQ specifies another time period, any information that the
DEQ may request to determine whether cause exists for modifying, reopening, revoking,
reissuing, terminating the permit or to determine compliance with the permit. Upon request, the
permittee shall also furnish to the DEQ copies of records required to be kept by the permit.
[OAC 252:100-8-6 (a)(7)(E)]
B. The permittee may make a claim of confidentiality for any information or records submitted
pursuant to 27A O.S. 2-5-105(18). Confidential information shall be clearly labeled as such and
shall be separable from the main body of the document such as in an attachment.
[OAC 252:100-8-6 (a)(7)(E)]
MAJOR SOURCE STANDARD CONDITIONS
March 9, 2005
6
C. Notification to the AQD of the sale or transfer of ownership of this facility is required and
shall be made in writing within 10 days after such date.
[Oklahoma Clean Air Act, 27A O.S. § 2-5-112 (G)]
SECTION XII.
REOPENING, MODIFICATION & REVOCATION
A. The permit may be modified, revoked, reopened and reissued, or terminated for cause.
Except as provided for minor permit modifications, the filing of a request by the permittee for a
permit modification, revocation, reissuance, termination, notification of planned changes, or
anticipated noncompliance does not stay any permit condition.
[OAC 252:100-8-6 (a)(7)(C) and OAC 252:100-8-7.2 (b)]
B. The DEQ will reopen and revise or revoke this permit as necessary to remedy deficiencies in
the following circumstances:
[OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]
(1)
Additional requirements under the Clean Air Act become applicable to a major source
category three or more years prior to the expiration date of this permit. No such
reopening is required if the effective date of the requirement is later than the expiration
date of this permit.
(2) The DEQ or the EPA determines that this permit contains a material mistake or that the
permit must be revised or revoked to assure compliance with the applicable requirements.
(3) The DEQ or the EPA determines that inaccurate information was used in establishing
the emission standards, limitations, or other conditions of this permit. The DEQ may
revoke and not reissue this permit if it determines that the permittee has submitted false
or misleading information to the DEQ.
C. If “grandfathered” status is claimed and granted for any equipment covered by this permit, it
shall only apply under the following circumstances:
[OAC 252:100-5-1.1]
(1)
It only applies to that specific item by serial number or some other permanent
identification.
(2) Grandfathered status is lost if the item is significantly modified or if it is relocated
outside the boundaries of the facility.
D. To make changes other than (1) those described in Section XVIII (Operational Flexibility),
(2) administrative permit amendments, and (3) those not defined as an Insignificant Activity
(Section XVI) or Trivial Activity (Section XVII), the permittee shall notify AQD. Such changes
may require a permit modification.
[OAC 252:100-8-7.2 (b)]
E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that
are not specifically approved by this permit are prohibited.
[OAC 252:100-8-6 (c)(6)]
MAJOR SOURCE STANDARD CONDITIONS
SECTION XIII.
March 9, 2005
7
INSPECTION & ENTRY
A. Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow authorized regulatory officials to perform the following (subject to the
permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18)
for confidential information submitted to or obtained by the DEQ under this section):
(1)
enter upon the permittee's premises during reasonable/normal working hours where a
source is located or emissions-related activity is conducted, or where records must be
kept under the conditions of the permit;
(2) have access to and copy, at reasonable times, any records that must be kept under the
conditions of the permit;
(3) inspect, at reasonable times and using reasonable safety practices, any facilities,
equipment (including monitoring and air pollution control equipment), practices, or
operations regulated or required under the permit; and
(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times
substances or parameters for the purpose of assuring compliance with the permit.
[OAC 252:100-8-6 (c)(2)]
SECTION XIV.
EMERGENCIES
A. Any emergency and/or exceedance that poses an imminent and substantial danger to public
health, safety, or the environment shall be reported to AQD as soon as is practicable; but under
no circumstance shall notification be more than 24 hours after the exceedance.
[OAC 252:100-8-6 (a)(3)(C)(iii)(II)]
B. An "emergency" means any situation arising from sudden and reasonably unforeseeable
events beyond the control of the source, including acts of God, which situation requires
immediate corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency.
[OAC 252:100-8-2]
C. An emergency shall constitute an affirmative defense to an action brought for noncompliance
with such technology-based emission limitation if the conditions of paragraph D below are met.
[OAC 252:100-8-6 (e)(1)]
D. The affirmative defense of emergency shall be demonstrated through properly signed,
contemporaneous operating logs or other relevant evidence that:
(1)
an emergency occurred and the permittee can identify the cause or causes of the
emergency;
(2) the permitted facility was at the time being properly operated;
(3) during the period of the emergency the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emission standards or other requirements in this
permit;
MAJOR SOURCE STANDARD CONDITIONS
March 9, 2005
8
(4)
the permittee submitted timely notice of the emergency to AQD, pursuant to the
applicable regulations (i.e., for emergencies that pose an “imminent and substantial
danger,” within 24 hours of the time when emission limitations were exceeded due to the
emergency; 4:30 p.m. the next business day for all other emergency exceedances). See
OAC 252:100-8-6(a)(3)(C)(iii)(I) and (II). This notice shall contain a description of the
emergency, the probable cause of the exceedance, any steps taken to mitigate emissions,
and corrective actions taken; and
(5) the permittee submitted a follow up written report within 10 working days of first
becoming aware of the exceedance.
[OAC 252:100-8-6 (e)(2), (a)(3)(C)(iii)(I) and (IV)]
E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency shall have the burden of proof.
[OAC 252:100-8-6 (e)(3)]
SECTION XV.
RISK MANAGEMENT PLAN
The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop
and register with the appropriate agency a risk management plan by June 20, 1999, or the
applicable effective date.
[OAC 252:100-8-6 (a)(4)]
SECTION XVI.
INSIGNIFICANT ACTIVITIES
Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to
operate individual emissions units that are either on the list in Appendix I to OAC Title 252,
Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.
Any activity to which a State or federal applicable requirement applies is not insignificant even if
it meets the criteria below or is included on the insignificant activities list. [OAC 252:100-8-2]
(1) 5 tons per year of any one criteria pollutant.
(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an
aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year
for single HAP that the EPA may establish by rule.
(3) 0.6 tons per year for any one category A substance, 1.2 tons per year for any one category
B substance or 6 tons per year for any one category C substance as defined in 252:100-4140.
SECTION XVII.
TRIVIAL ACTIVITIES
Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to
operate any individual or combination of air emissions units that are considered inconsequential
and are on the list in Appendix J. Any activity to which a State or federal applicable requirement
applies is not trivial even if included on the trivial activities list.
[OAC 252:100-8-2]
MAJOR SOURCE STANDARD CONDITIONS
SECTION XVIII.
March 9, 2005
9
OPERATIONAL FLEXIBILITY
A. A facility may implement any operating scenario allowed for in its Part 70 permit without the
need for any permit revision or any notification to the DEQ (unless specified otherwise in the
permit). When an operating scenario is changed, the permittee shall record in a log at the facility
the scenario under which it is operating.
[OAC 252:100-8-6 (a)(10) and (f)(1)]
B. The permittee may make changes within the facility that:
(1)
(2)
(3)
result in no net emissions increases,
are not modifications under any provision of Title I of the federal Clean Air Act, and
do not cause any hourly or annual permitted emission rate of any existing emissions unit
to be exceeded;
provided that the facility provides the EPA and the DEQ with written notification as required
below in advance of the proposed changes, which shall be a minimum of 7 days, or 24 hours for
emergencies as defined in OAC 252:100-8-6 (e). The permittee, the DEQ, and the EPA shall
attach each such notice to their copy of the permit. For each such change, the written notification
required above shall include a brief description of the change within the permitted facility, the
date on which the change will occur, any change in emissions, and any permit term or condition
that is no longer applicable as a result of the change. The permit shield provided by this permit
does not apply to any change made pursuant to this subsection.
[OAC 252:100-8-6 (f)(2)]
SECTION XIX.
OTHER APPLICABLE & STATE-ONLY REQUIREMENTS
A. The following applicable requirements and state-only requirements apply to the facility
unless elsewhere covered by a more restrictive requirement:
(1) 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 252:100-3]
(2) Open burning of refuse and other combustible material is prohibited except as authorized
in the specific examples and under the conditions listed in the Open Burning Subchapter.
[OAC 252:100-13]
(3) No particulate emissions from any fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 0.6 lb/MMBTU.
[OAC 252:100-19]
(4) For all emissions units not subject to an opacity limit promulgated under 40 CFR, Part 60,
NSPS, 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 252:100-25]
(5) No visible fugitive dust emissions shall be discharged beyond the property line on which
the emissions originate in such a manner as to damage or to interfere with the use of
adjacent properties, or cause air quality standards to be exceeded, or interfere with the
maintenance of air quality standards.
[OAC 252:100-29]
MAJOR SOURCE STANDARD CONDITIONS
March 9, 2005
10
(6) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2
lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur
dioxide.
[OAC 252:100-31]
(7) Volatile Organic Compound (VOC) storage tanks built after December28, 1974, and with
a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or
greater under actual conditions shall be equipped with a permanent submerged fill pipe or
with a vapor-recovery system.
[OAC 252:100-37-15(b)]
(8) All fuel-burning equipment shall at all times be properly operated and maintained in a
manner that will minimize emissions of VOCs.
[OAC 252:100-37-36]
(9) Except as otherwise provided, no person shall cause or permit the emissions of any toxic
air contaminant in such concentration as to cause or to contribute to a violation of the
MAAC.
(State only)
[OAC 252:100-41]
SECTION XX.
STRATOSPHERIC OZONE PROTECTION
A. The permittee shall comply with the following standards for production and consumption of
ozone-depleting substances.
[40 CFR 82, Subpart A]
1. Persons producing, importing, or placing an order for production or importation of certain
class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the
requirements of §82.4.
2. Producers, importers, exporters, purchasers, and persons who transform or destroy certain
class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping
requirements at §82.13.
3. Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,
HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane
(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include
HCFCs.
B. If the permittee performs a service on motor (fleet) vehicles when this service involves an
ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air
conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term
“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the
vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the
air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger
buses using HCFC-22 refrigerant.
[40 CFR 82, Subpart B]
C. The permittee shall comply with the following standards for recycling and emissions
reduction except as provided for MVACs in Subpart B.
[40 CFR 82, Subpart F]
(1)
Persons opening appliances for maintenance, service, repair, or disposal must comply
with the required practices pursuant to § 82.156.
(2) Equipment used during the maintenance, service, repair, or disposal of appliances must
comply with the standards for recycling and recovery equipment pursuant to § 82.158.
(3) Persons performing maintenance, service, repair, or disposal of appliances must be
MAJOR SOURCE STANDARD CONDITIONS
March 9, 2005
11
certified by an approved technician certification program pursuant to § 82.161.
Persons disposing of small appliances, MVACs, and MVAC-like appliances must
comply with record-keeping requirements pursuant to § 82.166.
(5) Persons owning commercial or industrial process refrigeration equipment must comply
with leak repair requirements pursuant to § 82.158.
(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant
must keep records of refrigerant purchased and added to such appliances pursuant to §
82.166.
(4)
SECTION XXI.
TITLE V APPROVAL LANGUAGE
A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is
not inconsistent with Federal requirements, to provide for incorporation of requirements
established through construction permitting into the Sources’ Title V permit without causing
redundant review. Requirements from construction permits may be incorporated into the Title V
permit through the administrative amendment process set forth in Oklahoma Administrative
Code 252:100-8-7.2(a) only if the following procedures are followed:
(1) The construction permit goes out for a 30-day public notice and comment using the
procedures set forth in 40 Code of Federal Regulations (CFR) § 70.7 (h)(1). This public notice
shall include notice to the public that this permit is subject to Environmental Protection Agency
(EPA) review, EPA objection, and petition to EPA, as provided by 40 CFR § 70.8; that the
requirements of the construction permit will be incorporated into the Title V permit through the
administrative amendment process; that the public will not receive another opportunity to
provide comments when the requirements are incorporated into the Title V permit; and that EPA
review, EPA objection, and petitions to EPA will not be available to the public when
requirements from the construction permit are incorporated into the Title V permit.
(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR §
70.8(a)(1).
(3) A copy of the draft construction permit is sent to any affected State, as provided by 40 CFR §
70.8(b).
(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period as
provided by 40 CFR § 70.8(a) and (c).
(5) The DEQ complies with 40 CFR § 70.8 (c) upon the written receipt within the 45-day
comment period of any EPA objection to the construction permit. The DEQ shall not issue the
permit until EPA’s objections are resolved to the satisfaction of EPA.
(6) The DEQ complies with 40 CFR § 70.8 (d).
(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8 (a).
(8) The DEQ shall not issue the proposed construction permit until any affected State and EPA
have had an opportunity to review the proposed permit, as provided by these permit conditions.
(9) Any requirements of the construction permit may be reopened for cause after incorporation
into the Title V permit by the administrative amendment process, by DEQ as provided in OAC
252:100-8-7.3 (a), (b), and (c), and by EPA as provided in 40 CFR § 70.7 (f) and (g).
(10) The DEQ shall not issue the administrative permit amendment if performance tests fail to
demonstrate that the source is operating in substantial compliance with all permit requirements.
MAJOR SOURCE STANDARD CONDITIONS
March 9, 2005
12
B. To the extent that these conditions are not followed, the Title V permit must go through the
Title V review process.
SECTION XXII.
CREDIBLE EVIDENCE
For the purpose of submitting compliance certifications or establishing whether or not a person
has violated or is in violation of any provision of the Oklahoma implementation plan, nothing
shall preclude the use, including the exclusive use, of any credible evidence or information,
relevant to whether a source would have been in compliance with applicable requirements if the
appropriate performance or compliance test or procedure had been performed.
[OAC 252:100-43-6]
PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 N. ROBINSON, SUITE 4100
P.O. BOX 1677
OKLAHOMA CITY, OKLAHOMA 73101-1677
Permit No. 2004-162-TVR
Baker Petrolite Corporation,
having complied with the requirements of the law, is hereby granted permission to operate
a synthetic wax manufacturing facility at 820 Birch Lake Road, Barnsdall, Osage County,
OK,
subject to the following conditions, attached:
[x] Standard Conditions Dated March 9, 2005
[x] Specific Conditions
This permit shall expire five (5) years from the issuance date below, except as Authorized
under Section VIII of the Standard Conditions.
_________________________________
Director, Air Quality Division
Date
Claud Rosendale, Environmental Manager
Baker Petrolite Corporation
P.O. Box 660
Barnsdall, OK 74002
Re:
Title V Renewal Operating Permit No. 2004-162-TVR
Synthetic Wax Manufacturing Facility
Dear Mr. Rosendale:
Air Quality Division has completed the initial review of your permit application referenced
above. This application has been determined to be a Tier II. In accordance with 27A O.S. § 214-302 and OAC 252:004-7-13, the enclosed draft construction permit is now ready for public
review. The requirements for public review include the following steps that you must
accomplish:
1. Publish at least one legal notice (one day) in at least one newspaper of general circulation
within the county where the facility is located. (Instructions enclosed)
2. Provide for public review (for a period of 30 days following the date of the newspaper
announcement) a copy of this draft permit and a copy of the application at a convenient location
within the county of the facility. Your facility or corporate office is not an appropriate site.
3. Send to AQD a copy of the proof of publication notice from Item #1 above together with any
additional comments or requested changes, which you may have on the draft permit.
Thank you for your cooperation. If you have any questions, please refer to the permit number
above and contact me at (918) 293-1624.
Sincerely,
Herb Neumann
Air Quality Division
Encl.
Department of Health and Environment
Bureau of Air and Radiation
Forbes Field, Building 283
Topeka, KS 66620-0001
SUBJECT:
Permit Number: 2004-162-TVR
Facility: Synthetic Wax Manufacturing Facility
Location: Barnsdall, OK
Permit Writer: Herb Neumann
Dear Sir / Madame:
The subject facility has requested a renewal Title V operating permit under 40 CFR Part 70. Air
Quality Division has completed the initial review of the application and prepared a draft permit
for public review. Since this facility is within 50 miles of the Oklahoma - Kansas border, a
copy of the proposed permit will be provided to you upon request. A copy of the draft permit is
also posted on the Air Quality section of the DEQ web page: www.deq.state.ok.us
Thank you for your cooperation. If you have any questions, please refer to the permit number
above and contact me at (405) 702-4100, or the permit writer at (918) 293-1624.
Sincerely,
Dawson Lasseter, Chief Engineer
AIR QUALITY DIVISION
Claud Rosendale, Environmental Manager
Baker Petrolite Corporation
P.O. Box 660
Barnsdall, OK 74002
Re:
Title V Renewal Operating Permit No. 2004-162-TVR
Synthetic Wax Manufacturing Facility
Dear Mr. Rosendale:
Enclosed is the permit authorizing operation of the referenced facility. Please note that this
permit is issued subject to certain standard and specific conditions, which are attached. These
conditions must be carefully followed since they define the limits of the permit and will be
confirmed by periodic inspections.
Also note that you are required to annually submit an emissions inventory for this facility. An
emissions inventory must be completed on approved AQD forms and submitted (hardcopy or
electronically) by March 1st of every year. Any questions concerning the form or submittal
process should be referred to the Emissions Inventory Staff at 405-702-4100.
Thank you for your cooperation. If you have any questions, please refer to the permit number
above and contact me at (918) 293-1600. Air Quality personnel are located in the Regional
Office at Tulsa, 3105 E. Skelly Drive, Suite 200, Tulsa, OK, 74105.
Sincerely,
Herb Neumann
Air Quality Division
Encl.