DRAFT/PROPOSED
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM
October 14, 2013
TO:
Phillip Fielder, P.E., Permits and Engineering Group Manager,
THROUGH:
Kendal Stegmann, Senior Environmental Manager, Compliance and
Enforcement
THROUGH:
Phil Martin, P.E., Existing Source Permit Section
THROUGH:
Peer Review
FROM:
Ellis Fischer, P.E., Existing Source Permit Section
SUBJECT:
Evaluation of Permit Application No. 2011-227-TVR2
ONEOK Field Services Company, L.L.C.
Maysville Gas Plant
Section 18, T4N, R2W, Garvin County
Latitude 34.8171º, Longitude -97.4531º
Located 2 miles west the intersection of Hwy 74 & Hwy 19 in Maysville
SECTION I. INTRODUCTION
ONEOK Field Services Company, L.L.C. (OFS) has submitted an application for the second
renewal of the Title V permit for their Maysville Gas Plant, which currently operates under
Permit No. 2004-163-TVR (M-5) issued on October 8, 2010. The plant is a PSD major source
and is classified as a SIC 1321 facility.
The facility is a cryogenic natural gas liquids (NGL) extraction plant with a gas processing
capacity of 137 MMSCFD. Residue gas is delivered to a sales pipeline after the recovery of
NGL. Current plant gas throughput is approximately 135 MMSCFD. The facility was originally
constructed in 1948 by Warren Petroleum Company and consisted of 24 internal combustion
engines and 5 gas-fired heaters in hot oil, steam generation, and regeneration-gas service. The
plant inlet gas contains a small amount of H2S (up to 13.5 ppm), which is removed in amine units
and flared in the acid gas flare.
From 1985 to 1996, several plant modifications were permitted, in which engines were removed
and added, a new cryogenic skid was constructed, and more furnace capacity was installed. The
present facility consists of 20 grandfathered and 16 permitted internal combustion engines, 3
cryogenic skids, 5 heaters, 4 boilers, 1 glycol regeneration unit, 1 amine regeneration unit, 1
process/emergency flare, 1 VOC flare, 1 acid gas flare, 54 pressurized product storage tanks, 4
pressurized spheroid tanks, 2 methanol storage tanks, 2 scrubber oil tanks, 1 condensate tank, 1
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
2
water/condensate pit tank, 1 gasoline storage tank, 1 Stoddard solvent tank, and miscellaneous
smaller tanks.
On June 4, 2004, OFS submitted three self-disclosures pertaining to (1) NAAQS for NOX
emissions, (2) MAAC for formaldehyde, (3) NESHAP Subpart HH, (4) NSPS Subpart KKK, and
(5) general control requirements for flares. The TVR application contained compliance plans to
address each of these issues. OFS submitted quarterly progress reports to update the status of
compliance during the Part 70 permit application review period, including the notifications
required by NESHAP Subpart HH and NSPS Subpart KKK. A compliance plan to bring the
facility in compliance with the NAAQS for NOX emissions was submitted to ODEQ and became
a part of Consent Order 06-063. Consent Order 06-063 also placed some additional requirements
on the facility. The TVR was issued with completion of the NAAQS for NOX compliance plan
as a permit specific condition. The facility has made combustion modifications to engines in
EUG-1 and in March of 2007 submitted air dispersion modeling which demonstrates compliance
with the NAAQS for NOX.
For modification (M-1), OFS requested that the procedure for monitoring the amount of H2S
combusted in the acid gas flare be revised to allow calculations using either measurement of the
amount of H2S concentration and flow of inlet gas streams, or using measurement of the amount
of H2S concentration and flow of the total acid gas stream between the amine contactors and the
acid gas flare. OFS also requested a change in the data collection procedures for Indicator No. 1,
flare flame indicator for the CAM plan for the glycol dehydration unit. These proposed changes
were minor and the application was processed under Tier I.
For modification (M-2), OFS requested a federally enforceable condition to limit the horsepower
for five generators so that they will be exempt from emissions and operating limitations under 40
CFR Part 63 Subpart ZZZZ (RICE MACT). OFS requested that emissions factors for engines in
EUG-1 be revised as part of the compliance plan required by Consent Order 06-063 dated April
6, 2006, to demonstrate compliance with the NAAQS for NOX. OFS requested that language be
included in the modified permit to clarify applicability of 40 CFR Part 60 Subpart NNN.
Prior Permit History for the five 1948 vintage Ingersoll-Rand PKVG-6 engines
Permit No. 2004-163-TVR (M-5), issued October 8, 2010
The five generator engines are 1948 vintage Ingersoll-Rand PKVG-6 four-stroke rich-burn
engines that are factory rated at 660-hp. While designated as rich-burn engines, the engines run
with oxygen exhaust concentrations ranging from near 3% down to 1%. It could be argued that
the engines are actually existing lean-burn engines (defined in the RICE MACT as an engine that
has 2% oxygen in the exhaust), which would exempt them from the RICE MACT. Also, the
exhaust temperatures of the engines are typically less than 600°F and OFS has been unable to
find a NSCR catalyst vendor who would guarantee the formaldehyde removal efficiency
necessary to be in compliance with the RICE MACT. In addition, the RICE MACT requires
compliance with a minimum catalyst inlet temperature of 750°F, which the engines do not
obtain. In order to resolve the site specific problems for complying with the RICE MACT for
these 50 year old engines, OFS requested and AQD (Permitting, Compliance, and Legal) agreed
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
3
to allow the source to take federally enforceable limitations on engine horsepower such that the
site-rated horsepower would be considered less than 500-hp. This exempted the existing engines
from the RICE MACT standards. The limit was enforced by placing a generator output limit of
330-KW on each engine. This power output is equivalent to an engine power output of less than
500-hp when considering the mechanical efficiency and shaft losses for the generator sets. AQD
and OFS agreed to issuance of a Consent Order to make these limitations enforceable prior to the
RICE MACT compliance date of June 15, 2007.
All rich-burn engines with a site-rating less than 500 brake horsepower (C-19, G-1, G-2, G-3, G4, G-5, G-6 and G-7) are subject to emission and operating limitations in Subpart ZZZZ and will
be required to comply with the standards by October 19, 2013. OFS now intends to remove
generators G-1, G-2, G-3, G-4, and G-5 from service prior to the October 19, 2013 compliance
date. OFS has contracted for purchase power to supply back up power when needed.
For modification (M-5), OFS requested to:
1.
2.
3.
4.
5.
6.
7.
8.
To install a new Western Oklahoma (WOK*) 16” inlet and condensate handling
system along with,
Installing a high-pressure inlet gas pre-heater in the North Amine System process unit.
To install a vapor recovery system as inherent process equipment, which will recover
working, breathing, and flashing vapors from the condensate tanks and re-compress the
vapors into the inlet, except during downtime.
This project increased the actual throughput by approximately 50 MMSCFD. At the
time of the previous permit action, the daily was running between 80-90 MMSCFD.
The new 16-inch inlet brought daily volumes up to around 115 MMSCFD.
Change serial number of C-21 from 306599 to 306559.
Renumber engine C-25.3 to C-25.
Update Oklahoma Air Pollution Control Rules.
Update Federal Regulations.
*WOK is an acronym used to identify the Custer and Woodward operating areas as one. A
portion of the WOK gas will be routed from the Custer area to Maysville Plant
The three existing cryo skids remained unchanged. Therefore, no increase of plant capacity. The
WOK 16” inlet and condensate handling process is subject to NSPS Subpart KKK and the North
Amine System is currently subject to NSPS Subpart KKK. This application has been classified
as Tier II based on the request for the second renewal of the Title V operating permit.
SECTION II. PROCESS DESCRIPTION
Maysville is a cryogenic natural gas liquids (NGL) extraction plant with a gas processing
capacity of 137 MMSCFD. Residue gas is delivered to a sales pipeline after recovery of natural
gas liquids (NGL). The facility currently consists of 20 grandfathered and 16 permitted internal
combustion engines, three cryogenic process skids, five process heaters, four boilers, one glycol
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
4
dehydration unit, one amine regeneration unit, one process/emergency flare, one VOC flare, one
acid gas flare, 54 pressurized product storage tanks, four pressurized spheroid tanks, two
methanol storage tanks, two scrubber oil tanks, one condensate/bottom sediment (BS&W) tanks,
one BS&W/condensate pit tank, one gasoline storage tank, one Stoddard solvent tank, and
miscellaneous support tanks.
Plant inlet wet gas consists of multiple low-pressure (LP) (~5 psig) and HP (~200 psig) streams.
Inlet wet gas from the 16” WOK inlet has a pressure of ~700-800 psig. Therefore, the inlet wet
gas does not require pre-compression for further processing.
With the 16” WOK inlet, the wet gas flows through a HP separator, where condensate and water
are removed. The wet gas is directed to the Anadarko HP inlet for further processing. The
separated condensate and water flow to the HP condensate flash separator. From there, the
condensate is separated from the water and flows to the condensate storage tanks (TK-9, -10, -11,
and -12). The produced water flows to the water storage tanks. Flash gas from the HP flash tank
separator is routed to the Anadarko HP inlet of the plant.
All working, breathing, and flash vapors from the condensate storage and loading vapors are
recovered by the VRU system, and then recompressed into the LP inlet of the plant. The VRU
system consists of a primary VRU and a secondary VRU, which ascertains 100% vapor recovery
during operation. The condensate tanks and VRU system comprise a closed system, with no
emissions vented to atmosphere, except during downtime (maintenance, utility power outage,
etc.). Water is separated from the condensate and stored in wastewater tanks until it is
transported off site for disposal. Condensate will remain in the condensate tanks until
transported by truck for sales.
Three process skids operate in parallel. Approximately 30% of incoming gas flows through Skid
#1, 10% through Skid #2, and 60% through Skid #3. Each of the three skids processes wet inlet
gas for acid gas removal (sweetening), dehydration, and NGL removal.
LP inlet scrubbers remove condensate/liquid oil and water from inlet wet gas before
compression. LP scrubber fluids flow to condensate tank #19 (TK-1), which vents to the
process/emergency flare. Liquid condensates in TK-1 are transported by truck to two scrubber
oil tanks (TK-2, TK-3) for oil-water separation. Scrubber oils and drips collected from remote
field sources also are transported to tanks TK-2 and TK-3 by truck. Separated scrubber oils and
condensate are transported offsite by truck for sales. Overflow from tanks TK-2 and TK-3 is
stored temporarily in wastewater open-top pit tank TK-4. BS&W from tank TK-4 and other
open pits is emptied by vacuum truck for off-site disposal.
Scrubbed LP wet inlet gas is compressed to approximately 730 psig before further processing.
Compressor inter-stage scrubbers produce a condensate liquid that is lighter than that produced
by LP inlet scrubbers. This lighter condensate flows to a condensate stabilizer system where
light-end hydrocarbons are recovered and returned to the plant inlet. The stabilized heavier
hydrocarbon liquids are stored in four pressurized bullet tanks awaiting transport off-site via
pipeline.
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
5
Compressed wet inlet gas flows to the amine contactor towers (north amine unit and south amine
unit) for removal of hydrogen sulfide (H2S) and partial removal of carbon dioxide (CO2). Rich
amine from the contactors flows to rich amine flash tanks, which are vented to the acid gas flare.
Rich amine from the flash tanks and from the amine contactor without a flash tank flows to the
amine regeneration stills where acid gas is removed overhead and vented to the acid gas flare for
incineration of H2S. The amine regenerator reboiler for Skid #3 is heated by a natural gas-fired
furnace. Skids #1 and #2 share a reboiler heated by hot oil.
The sweetened gas at Skid #1 and Skid #2 flows through molecular sieve beds for dehydration.
Gas-fired heaters supply the heat for molecular sieve regeneration. Sweetened gas in Skid #3
flows through a glycol contactor for dehydration. Rich glycol from the contactor flows to the
rich glycol flash tank, which vents to the low-pressure inlet gas stream. Rich glycol from the
flash tank flows to the glycol regeneration still for removal of absorbed water. Vapors from the
glycol still flow through a condenser. Any remaining vapors are recycled to the LP inlet gas
stream, or vented to the process/emergency flare (PFL-1).
Following dehydration, the sweetened and dried gas is processed through a cryogenic unit
(demethanizer tower) on each skid. This process lowers the temperature sufficiently to condense
ethane and heavier hydrocarbons, while leaving the methane fraction in gaseous form. The
overhead methane stream (the residue gas) is recompressed to 650 psig and directed to the
natural gas pipeline for distribution.
The liquefied demethanizer bottoms are the raw natural gas liquids (NGL), and include ethane
and heavier hydrocarbons. All of the raw NGL flows to a single NGL fractionation train for
separation of NGL products. The fractionation train includes deethanizer, depropanizer,
debutanizer, and deisobutanizer columns.
The deethanizer column removes an ethane-propane mix (C2-C3), which leaves the plant via
pipeline. The depropanizer removes the remaining propane. The debutanizer and deisobutanizer
columns separate normal butane and iso-butane products (C4s), respectively. The remaining
C5+ hydrocarbons are known as 14# gasoline. The propane, butane, and 14# gasoline products
are stored in pressurized bullet and spheroid tanks awaiting outbound shipment via tank truck or
pipeline. The bullet and spheroid tanks operate with working pressures between 5 and 200 psig.
SECTION III. EQUIPMENT
Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) as follow. All fuelburning units at the station use pipeline-quality natural gas or field gas with a sulfur content of
less than 343-ppmv. The engines operate continuously.
DRAFT/PROPOSED
PERMIT MEMORANDUM 2011-227-TVR2
6
EUG-1. Grandfathered Engines
EU
C-1
C-2
C-3(2)
C-4(2)
C-5(2)
C-6(2)
C-7
C-8(2)
C-9(2)
C-10(2)
C-11(2)
C-12
C-13(2)
C-14
C-15
G-1(3)
G-2(3)
G-3(3)
G-4(3)
G-5(3)
Point
P-1
P-2
P-3
P-4
P-5
P-6
P-7
P-8
P-9
P-10
P-11
P-12
P-13
P-14
P-15
P-30
P-31
P-32
P-33
P-34
Make/Model
Clark RA-8
Clark RA-8
Clark RA-8
Clark RA-6
Clark RA-6
Clark RA-8
Clark RA-8
Clark HRA-8
Clark HRA-8
Clark HRA-8
Clark HBA-8
Clark HBA-8
Clark HBA-8
Clark HBA-5
Clark HBA-5
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
HP
800
800
800
600
600
800
800
880
880
880
1,760
--1,760
1,100
--<500
<500
<500
<500
<500
Serial #
25938
25937
25936
21133
21132
25927
25928
A25567
A25568
A25572
30269
--30271
35601
--6HZ131
6HZ132
6HZ134
6HZ136
6NZ182
Construction Date
1948
1948
1948
1948
1948
1948
1948
1948
1948
1948
1948
(1)
1948
1948
(1)
1948
1948
1948
1948
1948
1. Engine C-12 was permanently shutdown on July 19, 2003 per C.O. 03-165. Engine C-15
has been permanently removed from service.
2. These engines have modified pressure fuel systems installed per Consent Order 06-063,
but are considered “existing engines” for purposes of MACT Subpart ZZZZ and
permitting. See AD # 97-222-AD (M-3) dated June 20, 2005.
3. Factory rating is 660-hp, but the engines are limited to <500-hp by limiting actual KW
power production from each engine to 330-KW based on a 30-day rolling average.
These engines will be removed from service prior to October 19, 2013
EUG-2. Permitted Engines
EU
C-16.2(1)
C-17(1)
C-18(1)
C-19(1)
C-20
C-21(2)
C-22
C-23(1)
C-24(1)
C-25
Point
P-16
P-17
P-18
P-19
P-20
P-21
P-22
P-23
P-24
P-25
Make/Model
Waukesha L7042 GSIU
Waukesha L7042 GSIU
Waukesha L7042 GSIU
Waukesha L5108 GU
Superior 16GTLA
Superior 16GTLA
Superior 16GTLA
Superior 8G825
Superior 6G825
Superior 8GTLA
HP
922
922
922
492
2,078
2,078
2,078
800
600
1,039
Serial #
365714A
387563
387652
387653
306999
306559
291649
282349
292229
293109
Construction Date
12/13/84
12/14/84
12/15/84
1/11/85
~12/12/85
~10/12/85
~7/91
~12/91-1/92
12/82
03/05
DRAFT/PROPOSED
PERMIT MEMORANDUM 2011-227-TVR2
EU
Point
Make/Model
C-26.2
P-26
Superior 12GTLA
C-27
P-27
Superior 12GTLA
C-28
P-28
Superior 12GTLA
C-29
P-29
Superior 12GTLA
G-6(1)
P-35
Waukesha L3711
(1)
G-7
P-36
Waukesha L3711
1. With NSCR and AFRC.
2. Overhauled in 2003 per C.O. 03-165.
HP
1,558
1,558
1,558
1,558
335
335
Serial #
310529
304979
304989
295909
48027
48028
7
Construction Date
~6/86
~6/86
~6/86
2/12/90
1990
1990
EUG-3. Tanks
EU
TK-1
TK-2
TK-3
TK-4
TK-5
TK-6
TK-7
TK-8
Point
P-50
P-51
P-52
P-53
P-54
P-55
P-56
P-57
Contents
Condensate / BS&W
Scrubber Oil, North
Scrubber Oil, South
BS&W / Condensate
Methanol
Methanol
Gasoline
Solvent < 1.5 psia vapor pressure
Gallons
23,400
23,200
22,000
4,200
8,820
1,730
3,000
580
Construction Date
pre 1974
pre 1974
pre 1974
post 1974
pre 1974
post 1974
post 1974
post 1974
EUG-4. Fugitive Components (Not Subject to NSPS Subpart KKK, OOOO or MACT
Subpart HH)
EU
FUG-1
Type of Equipment
Connectors
Valves
Open Ended Lines
Flanges
Compressor Seals
Pump Seals
Relief Valves
Estimated Number of Items
7,000
3,500
280
4,378
56
113
38
EUG-5. Fugitive Components (Subject to NSPS Subpart KKK)
EU
FUG-2
Type of Equipment
Connectors
Valves
Open Ended Lines
Flanges
Compressor Seals
Pump Seals
Relief Valves
Estimated Number Of Items
6,522
3,091
282
4,006
5
28
5
DRAFT/PROPOSED
PERMIT MEMORANDUM 2011-227-TVR2
EUG-6. Heaters & Boilers
EU
H-1
H-2
H-3
H-4
H-5
H-6
H-7
B-1
B-2
Point
Equipment
P-37
P-38
P-39
P-40
P-41
P-42
P-43
P-44
P-45
MMBtu/hr
Hot Oil Heater (West)
Hot Oil Heater (East)
Regen. Gas Heater (Plant #1)
Regen. Gas Heater (Plant #2)
Glycol Reboiler
Amine Reboiler
Regen. Gas Heater (Plant #3)
Boiler #1 (North, OK36454)
Boiler #2 (South, OK43476)
49.8
41.5
5.0
1.5
1.5
5.25
7.5
2.0
2.0
Serial#
617
620
75122
41593
0132
5991
1276
1740
9777
Construction
Date
1997(1)
1948
1976
1985
1985
1985
1985
1976
1988
1. Modified in October 1997 with more efficient burners.
EUG-7. Process/Emergency Flare
EU
Point
MMBtu/hr
PFL-1
FL-1
27,000
Diameter
inches
24
Height
feet
110
Construction
Date
1948
Diameter
inches
24
Height
feet
110
Construction
Date
1985
EUG-8. Acid Gas Flare
EU
Point
MMBtu/hr
AU-1
FL-1
1.5
Note: The acid gas flare runs up the side of the process/emergency flare.
Equipment vented to the acid gas flare includes the DGA north amine
treater (Plants 1 and 2) and the DEA south amine treater (Plant 3).
EUG-9. VOC Flare
EU
Point
MMBtu/hr
FL-2
FL-2
40
Diameter
inches
12
Height
feet
15
Construction
Date
1986
EUG-10. Glycol Dehydration Unit
EU
D-1
Point
FL-1
Equipment
Still Overhead Vent
Construction Date
1986
8
DRAFT/PROPOSED
PERMIT MEMORANDUM 2011-227-TVR2
9
EUG-11. Condensate/Scrubber Oil Truck Loading
EU
TL-1
Point
TL-1
Equipment
Truck Loading
Construction Date
1948
EUG 12. Fugitive Components (Subject to NESHAP Subpart HH)
EU
FUG-3
Type of Equipment
Connectors
Valves
Pressure Relief Valves
Pump Seals
Estimated Number of
Items
Natural
Condensate
Gasoline
2,187
10
625
325
19
19
5
4
EUG-13. Miscellaneous Venting Activities
EU ID #
VENT
Point #
VENT
Emission Units
Miscellaneous Process Vents
Date Constructed
1948
EUG-14. WOK Condensate/Methanol Storage Tanks
EU
TK-9
TK-10
TK-11
TK-12
TK-13
Point
P-58
P-59
P-60
P-61
P-62
Contents
400-bbl Condensate
400-bbl Condensate
400-bbl Condensate
400-bbl Condensate
210-bbl Methanol
Gallons
16,800
16,800
16,800
16,800
8,820
Construction Date
March 2010
March 2010
March 2010
March 2010
March 2010
EUG-15. WOK Condensate Truck Loading from EUG-14
EU
TL-2
Point
TL-2
Equipment
Truck Loading
Construction Date
March 2010
EUG-FW. Facility-Wide Emissions
Engine Stack Parameters
EU
C-1A, B*
C-2A, B*
C-3A, B*
Source
Clark RA-8
Clark RA-8
Clark RA-8
Height
feet
40
40
40
Diameter
inches
10
10
10
Flow
ACFM
3,540
3,540
3,540
Temp
F
725
725
725
DRAFT/PROPOSED
PERMIT MEMORANDUM 2011-227-TVR2
EU
C-4A, B*
C-5A, B*
C-6
C-7A, B*
C-8
C-9
C-10
C-11
C-12
C-13
C-14
C-15
C-16
C-17
C-18
C-19
C-20
C-21
C-22
C-23
C-24
C-25
C-26
C-27
C-28
C-29
G-1**
G-2**
G-3**
G-4**
G-5**
G-6
G-7
Source
Clark RA-6
Clark RA-6
Clark RA-8
Clark RA-8
Clark HRA-8
Clark HRA-8
Clark HRA-8
Clark HBA-8
Clark HBA-8 (removed)
Clark HBA-8
Clark HBA-5
Clark HBA-5 (removed)
Waukesha L7042 GSIU
Waukesha L7042 GSIU
Waukesha L7042 GSIU
Waukesha L5108 GU
Superior 16GTLA
Superior 16GTLA
Superior 16GTLA
Superior 8G825
Superior 6G825
Superior 8GTLA
Superior 12GTLA
Superior 12GTLA
Superior 12GTLA
Superior 12GTLA
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Waukesha L3711
Waukesha L3711
Height
feet
41
41
43
42
45
45
45
56
--56
24
--20
20
20
26
28
28
28
18
22
16
19
19
19
21
37
37
37
37
37
27
27
Diameter
inches
10
10
10
10
14
14
14
18
--18
16
--8
8
8
8
16
16
16
12
12
14
18
18
18
18
10
10
10
10
10
8
8
* Dual stacks
** To be removed from service prior to October 19, 2013.
SECTION IV. EMISSIONS
All emission estimates are based on continuous operation.
Flow
ACFM
2,598
2,598
3,539
3,540
3,763
3,763
3,763
11,335
--11,335
6,917
--4,085
4,085
4,085
2,135
12,007
12,007
12,007
5,359
4,437
6,654
7,921
7,921
7,921
7,921
2,889
2,889
2,889
2,889
2,889
1,500
1,500
10
Temp
F
700
700
725
725
675
675
675
875
--875
800
--1007
1007
1007
800
808
808
808
1,330
1,250
934
801
801
801
801
975
975
975
975
975
850
850
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
11
A. Criteria Emissions
NOX and CO emission factors for the Clark engines are based on stack tests and operating
experience after combustion modifications. NOX and CO emission factors for the Ingersoll Rand
engines are based on AP-42 (7/00) Table 3.2-3 and a horsepower of 499. VOC emission factors
for all engines are based on AP-42 (7/00) Tables 3.2-1 and 3.2-3.
Source
Type
Clark RA-8 and RA-6
Clark RA-8 and RA-6 (modified)
Clark HRA-8 (modified)
Clark HBA-8 (modified)
Clark HBA-5
Ingersoll-Rand PKVG-6
2SLB
2SLB
2SLB
2SLB
2SLB
4SRB
Emission Factor, g/hp-hr
NOX
CO
VOC
22
3.5
0.49
14
3.5
0.49
14
2.0
0.49
14
6.0
0.49
22
6.0
0.49
8.0
13.5
0.11
Fuel
HP
Btu/hp-hr
9,000
800
9,000
600
9,000
880
9,000
1,760
9,000
1,100
8,000
<500
NOX, CO, and VOC emission factors for the permitted engines in EUG-2 are based on the permit
limits of Permit No. 97-222-TV.
Source
Type
Waukesha L7042 GSIU*
Waukesha L5108 GU*
Superior 16GTLA
Superior 8G825*
Superior 6G825*
Superior 8GTLA
Superior 12GTLA
Waukesha L3711*
4SRB
4SRB
4SLB
4SRB
4SRB
4SLB
4SLB
4SRB
*
Fuel,
HP
Btu/hp-hr
8,000
922
8,000
492
8,500
2,080
8,000
800
8,000
600
8,500
1,040
8,500
1,560
8,000
335
Emission Factor, g/hp-hr
NOX
CO
VOC
2.0
5.65
1.0
2.0
4.80
1.0
2.0
3.0
1.0
2.0
3.0
1.0
2.0
3.0
1.0
2.0
3.0
1.0
2.0
3.0
1.0
2.0
5.65
1.0
Equipped with NSCR and AFRC.
EUG-1. Grandfathered Engines
EU
C-1
C-2
C-3
C-4
C-5
C-6
C-7
C-8
Engine
Clark RA-8
Clark RA-8
Clark RA-8
Clark RA-6
Clark RA-6
Clark RA-8
Clark RA-8
Clark HRA-8
Criteria Emissions
NOX
lb/hr
TPY
24.69
108.15
24.69
108.15
24.69
108.15
18.52
81.11
18.52
81.11
24.69
108.15
38.80
169.95
27.16
118.96
CO
lb/hr
6.17
6.17
6.17
4.63
4.63
6.17
6.17
3.88
TPY
27.04
27.04
27.04
20.28
20.28
27.04
27.04
16.99
VOC
lb/hr
TPY
0.86
3.79
0.86
3.79
0.86
3.79
0.65
2.84
0.65
2.84
0.86
3.79
0.86
3.79
0.95
4.16
PERMIT MEMORANDUM 2011-227-TVR2
EU
Engine
C-9
C-10
C-11
C-12*
C-13
C-14
C-15*
G-1*
G-2*
G-3*
G-4*
G-5*
*
Clark HRA-8
Clark HRA-8
Clark HBA-8
Clark HBA-8
Clark HBA-8
Clark HBA-5
Clark HBA-5
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Total
lb/hr
27.16
27.16
54.32
0
54.32
53.35
0
8.8
8.8
8.8
8.8
8.8
462.07
DRAFT/PROPOSED
NOX
TPY
118.96
118.96
237.93
0
237.93
233.68
0
39
39
39
39
39
2026.19
CO
lb/hr
TPY
3.88
16.99
3.88
16.99
23.28 101.97
0
0
23.28 101.97
15.55
63.73
0
0
15
66
15
66
15
66
15
66
15
66
188.86 824.40
12
VOC
lb/hr
TPY
0.95
4.16
0.95
4.16
1.90
8.33
0
0
1.90
8.33
1.19
5.20
0
0
0.12
0.60
0.12
0.60
0.12
0.60
0.12
0.60
0.12
0.60
14.04 61.97
C-12 was shutdown per Consent Order No. 03-165. Emissions decrease is not to be used for
future PSD netting purposes. C-15 has been permanently removed from service. Generators
G-1, G-2, G-3, G-4, and G-5 will be removed from service prior to October 19, 2013.
Emissions decrease from removal of C-15 and generators may be used for PSD netting
purposes.
There are no catalytic converters for emission controls on grandfathered engines.
EUG-2. Permitted Engines
EU
C-16(1)
C-17(1)
C-18(1)
C-19(1)(2)
C-20
C-21
C-22
C-23(1)
C-24(1)
C-25
C-26
C-27
C-28
C-29
G-6(1)(2)
G-7(1)(2)
Engine
Waukesha L7042 GSIU
Waukesha L7042 GSIU
Waukesha L7042 GSIU
Waukesha L5108 GU
Superior 16GTLA
Superior 16GTLA
Superior 16GTLA
Superior 8G825
Superior 6G825
Superior 8GTLA
Superior 12GTLA
Superior 12GTLA
Superior 12GTLA
Superior 12GTLA
Waukesha L3711
Waukesha L3711
Criteria Emissions
NOX
lb/hr
TPY
4.07
17.81
4.07
17.81
4.07
17.81
2.17
9.50
9.16
40.13
9.16
40.13
9.16
40.13
3.53
15.45
2.65
11.59
4.58
20.07
6.87
30.09
6.87
30.09
6.87
30.09
6.87
30.09
1.48
6.47
1.48
6.47
CO
lb/hr
11.48
11.48
11.48
5.21
13.74
13.74
13.74
5.29
3.97
6.87
10.30
10.30
10.30
10.30
4.17
4.17
TPY
50.30
50.30
50.30
22.80
60.20
60.20
60.20
23.17
17.38
30.10
45.13
45.13
45.13
45.13
18.28
18.28
VOC
lb/hr
TPY
2.03
8.90
2.03
8.90
2.03
8.90
1.08
4.75
4.58
20.07
4.58
20.07
4.58
20.07
1.76
7.72
1.32
5.79
2.29
10.03
3.43
15.04
3.43
15.04
3.43
15.04
3.43
15.04
0.74
3.23
0.74
3.23
DRAFT/PROPOSED
PERMIT MEMORANDUM 2011-227-TVR2
EU
NOX
lb/hr
TPY
83.06 363.73
Engine
Total
CO
lb/hr
146.54
TPY
642.03
13
VOC
lb/hr
TPY
41.48 181.82
(1) Equipped with NSCR and AFRC.
(2) Subject to 40 CFR Part 64, CAM rule until October 19, 2013 when new requirements under 40
CFR 63, Subpart ZZZZ go into effect.
EUG-3. Tanks
Tank TK-1 is vented to the plant/emergency flare. All other tank emissions in EUG-3 are
considered insignificant activities.
EU
Point
Contents
TK-1
TK-2
TK-3
TK-4
TK-5
TK-6
TK-7
TK-8
P-50
P-51
P-52
P-53
P-54
P-55
P-56
P-57
Condensate / BS&W
Scrubber Oil, North
Scrubber Oil, South
BS&W / Condensate, Open Pit
Methanol
Methanol
Gasoline, Unleaded
Solvent < 1.5 psia vapor pressure
Estimated throughput,
gallons per year
5,735,000
487,200
462,630
218,400
---------
EUG-4 (Exempt from NSPS Subpart KKK, OOOO and MACT Subpart HH), EUG-5 (Subject to
NSPS Subpart KKK), and EUG-12 (Subject to MACT Subpart HH) Fugitive Components
Potential fugitive VOC emissions are estimated based on EPA’s 1995 Protocol for Equipment
Leak Estimates (EPA-453/R-95-017), component count for each fugitive type, and VOC content
of the process streams. Fugitive emissions from components monitored under an LDAR
program are calculated with appropriate reduction credits claimed.
Equipment
Wet Gas
[24 wt% VOC]
Components
VOC
2,496
12.80
3,203
2.90
5,172
2.40
Valves
Flanges
Connectors
Open
Ended
Lines
Compressor
Seals
Relief
Valves
Pump Seals
Subtotal (TPY)
*
Fugitive Emissions, TPY (Component Count)*
Residue Gas
Light Liquids
Propane
[10 wt% VOC]
[100 wt% VOC]
[100 wt% VOC]
Components
VOC
Components
VOC
Components
VOC
250
1.09
3,611
66.82
235
7.44313
0.12
4,574
4.86
294
1.11
500
0.10
7,382
14.97
470
0.91
226
0.42
2115
1.91
298
45
0.91
10
0.08
--38
5
0.10
---
---
---
--19.53
---
--68
3.30
Total = 133.10 TPY
2.81
Heavy Liquids
[100 wt% VOC]
Components
VOC
-------------
19
0.23
---
---
6
0.51
---
---
2.75
---
---
73
0.36
7.50
99.71
---
--10.20
---
--0.36
---
Fugitive emissions and component counts are best estimates
DRAFT/PROPOSED
PERMIT MEMORANDUM 2011-227-TVR2
14
EUG-6. Heaters & Boilers
Estimated NOX, CO, and VOC emissions for the heaters and boilers are based on AP-42 (7/98),
Tables 1.4-1 and 1.4-2 and a fuel gas HHV of 1,000 Btu/scf.
EU
Equipment
H-1
H-2
H-3
H-4
H-5
H-6
H-7
B-1
B-2
Hot Oil Heater (West)
Hot Oil Heater (East)
Regen. Gas Heater (Plant #1)
Regen. Gas Heater (Plant #2)
Glycol Reboiler
Amine Reboiler
Regen. Gas Heater (Plant #3)
Boiler #1 (North, OK36454)
Boiler #2 (South, OK43476)
Total
NOX
lb/hr TPY
4.98
21.8
4.15
18.2
0.50
2.19
0.15
0.66
0.25
1.10
0.60
2.63
0.75
3.29
0.20
0.86
0.20
0.86
11.78
51.6
CO
lb/hr
TPY
4.18
18.3
3.49
15.3
0.42
1.84
0.13
0.55
0.21
0.92
0.50
2.21
0.63
2.76
0.16
0.72
0.16
0.72
9.88
43.3
VOC
lb/hr TPY
0.28
1.2
0.23
1.0
0.03
0.13
0.01
0.04
0.02
0.09
0.03
0.13
0.04
0.18
0.02
0.09
0.02
0.09
0.70
3.0
EUG-7. Process/Emergency Flare (Subject to NSPS Subpart A)
Short-term emission estimates are based on a main plant upset where 90 MMscf of gas would be
released in 4 to 6 hours. The maximum per hour rate would be about 22.5 MMscf, diminishing
as valves are closed and gas is routed elsewhere. Emission estimates of SO2 and H2S are based
on an H2S maximum concentration of 13.5 ppm in the inlet gas, a mass balance, and a
conversion rate of 98%. NOX, CO, and VOC emission estimates are based on AP-42 (9/91),
Table 13.5-1, the gas rate of 22.5 MMscf/hr, and a heating value of 1,200 Btu/scf.
EUG-7
Process / Emergency Flare
Unit
lb/hr
NOX
1,840
CO
9,990
VOC
3,860
SO2
50.3
H2 S
0.55
Annual emission estimates of NOX, CO, and VOC from process flaring are based on AP-42
(9/91), Table 13.5-1, an estimated flare throughput of 16.2 MMscf/yr for the glycol regeneration
overhead vent stream, propane refrigerant compressor blowdowns, and Tank #19 vent, and
propane properties. Flare pilot emissions are based on a pilot gas rate of 0.1 MMBtu/hr and a
heating value of 1,000 Btu/scf.
EUG-7
Process / Emergency Flare
Unit
TPY
NOX
1.31
CO
7.12
VOC
19.3
EUG-8. Acid Gas Flare (Subject to NSPS Subpart A)
Acid gases from the rich amine flash tank and the amine regeneration still are vented to the acid
gas flare for conversion of H2S to SO2. Emission estimates of SO2 and H2S are based on an inlet
DRAFT/PROPOSED
PERMIT MEMORANDUM 2011-227-TVR2
15
gas rate of 137 MMSCFD, an H2S concentration of 13.5 ppmv in the inlet gas, a mass balance,
and a conversion rate of 98%. NOX, CO, and VOC emission estimates are based on AP-42
(9/91), Table 13.5-1, and a flare heat rate of 1.5 MMBtu/hr.
EUG-8
Acid Gas Flare
Unit
lb/hr
TPY
NOX
0.10
0.45
CO
0.56
2.45
VOC
1.70
7.45
SO2
12.8
55.9
H2 S
0.14
0.61
EUG-9. VOC Flare (Subject to NSPS Subpart A)
NOX, CO, and VOC emission estimates are based on AP-42 (9/91), Table 13.5-1 and Table 13.52 and a maximum flare heat rate of 40 MMBtu/hr.
EUG-9
Unit
lb/hr
TPY
VOC Flare
NOX
2.7
12
CO
15
66
VOC
2.5
11
EUG-10. Glycol Dehydration Unit
Emissions from the dehydration regenerator still are vented through a condenser and any
remaining vapors are either recycled to the low-pressure inlet gas stream or vented to the
process/emergency flare. Flash vapors from the rich glycol flash tank are recycled to the lowpressure inlet gas stream. Therefore, there are no significant pollutant emissions.
EUG-11. Condensate/Scrubber Oil Truck Loading
Emissions from the loading of condensate are based on AP-42 (1/95), Section 5.2-5, Equation 1.
ID#
TL-1
Throughput
Loading Loss, lb/1000
VOC
bbl/yr
164,363
gallons
5.11
TPY
17.7
EUG-13. Miscellaneous Venting Activities
Emissions from miscellaneous venting activities (i.e., compressor blowdowns) are based on
1,200,000 scf/yr of blowdown volume and VOC content of the inlet gas.
EU ID#
Blowdown Volume (scf/yr)
VENT
1,200,000
VOC
(TPY)
7.8
DRAFT/PROPOSED
PERMIT MEMORANDUM 2011-227-TVR2
16
EUG-14. WOK Condensate/Methanol Storage Tanks
Emission from the WOK condensate tanks are based on EPA TANKS 4.0.9d software. Rather
than an individual limit on each condensate storage tank, OFS requests a combined throughput
limit for tanks TK-9 through TK-12. The condensate tanks have a closed vapor recovery system
(VRU) that collects 100% of emissions when operating. However, OFS requests to permit 100
hours of VOC working, breathing and flashing emissions to occur when VRU equipment is not
operating.
EU
Point
Estimated throughput
gallons per year
383,250
383,250
383,250
383,250
1,533,000
210,000
Contents
TK-9
P-58
Condensate
TK-10
P-59
Condensate
TK-11
P-60
Condensate
TK-12
P-61
Condensate
Combined Condensate Throughput
TK-13
P-62
Methanol
VOC Emissions
EU
Point
Emission Type
TK-9 – TK-12
P-58 – P-61
Working and Breathing
Flashing
TOTAL
Pre-VRU
TPY
22.92
534.91
557.83
Post-VRU
TPY
0.28
6.11
6.39
EUG-15. WOK Condensate Truck Loading from EUG-14
Emissions from the loading of condensate are based on AP-42 (1/95), Section 5.2-5, Equation 1.
Loading loss (lb/1000 gal loaded) = 12.46*S*P*M/T, where:
S (Saturation factor, submerged fill
P (True vapor pressure of liquid loaded, average psia)
M (Molecular weight of vapor, lb/lb-mol)
T (Temperature of bulk liquid, average °F + 460 = °R)
ID #
TL-2
0.6
11.3345
54.1086
59.96
Throughput
Loading Loss, lb/1000
VOC
gal/yr
1,533,000
gallons
8.82
TPY
6.76
DRAFT/PROPOSED
PERMIT MEMORANDUM 2011-227-TVR2
17
EUG-FW. Facility-Wide Emissions
Total Criteria Pollutant Emissions
Source
EUG
NOX
lb/hr
Engines-1 (4)
462.07
(4)
Engines-2
83.06
Tanks(1)
Fugitives Not Subject to
4 & 12
NSPS Subpart KKK
Fugitives Subject to NSPS
5(6)
Subpart KKK
6
Heaters/Boilers
11.38
7
Process/Emergency Flare (2)
8
Acid Gas Flare
0.10
9
VOC Flare
2.74
(3)
10
Glycol Unit
11
Truck Loading
13
Misc. Venting
(6)
14
Condensate Tanks
14(6) Methanol Tank
Condensate Truck Loading
15(6)
from EUG-14
Total (5)
559.35
1
2
3
1.
2.
3.
4.
5.
6.
SO2
lb/hr TPY
2026.19 188.86 824.40 14.04 61.97 0.08 0.34
363.73 146.54 642.03 41.48 181.82 0.09 0.41
0
TPY
lb/hr
CO
TPY
VOC
lb/hr TPY
23.99 105.07
-
-
-
6.38
27.95
-
-
49.83
1.31
0.45
12.02
-
9.56
0.52
14.93
-
41.86
7.12
2.45
65.39
-
0.63
1.70
2.54
-
2.74
19.31
7.45 12.75 55.85
11.13
0
17.65
7.79
6.37
0.17
6.76
2453.53 360.41 1583.25 90.76 456.18 12.92 56.60
Tank emissions are either 100% controlled or insignificant.
The process/emergency flare is for process and emergency use and its short-term emissions
estimates are for ambient air modeling purposes only and are not counted for facility emission
estimates.
Glycol regenerator still vent is controlled by the process/emergency flare. Rich glycol flash
tank off-gases are recycled back to the low-pressure inlet gas stream.
SO2 emissions added for engines by applicant.
After fuel system modifications to grandfathered engines and shutdown of engine C-12 and removal of
engine C-15.
Modifications associated with WOK 16” line installation.
B. HAP Emissions
Engines
The internal combustion engines have emissions of HAP, the most significant being
formaldehyde and acrolein. The following table presents emission factors for formaldehyde and
acrolein. Emission factors for formaldehyde are based as noted. Emission factors for acrolein
are based on AP-42 (7/00) Tables 3.2-1 and 3.2-3, except as noted.
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
Formaldehyde and Acrolein Emission Factors
Fuel,
EF, lb/MMBtu
Source
Type
HP
Btu/hp-hr
Formaldehyde
Acrolein
Clark RA-8
2SLB
9,000
800 0.24 (g/hp-hr)(1)
0.00778
Clark RA-6
2SLB
9,000
600 0.24 (g/hp-hr)(1)
0.00778
(1)
Clark HRA-8
2SLB
9,000
880 0.27 (g/hp-hr)
0.00778
(1)
Clark HBA-8
2SLB
9,000
1,760 0.38 (g/hp-hr)
0.00778
Clark HBA-5
2SLB
9,000
1,100 0.24 (g/hp-hr)(1)
0.00778
(2)
Waukesha L7042 GSIU
4SRB
8,000
922 0.0103
0.00132(2)
(2)
Waukesha L5108 GU
4SRB
8,000
492 0.0103
0.00132(2)
Superior 16GTLA
4SLB
8,500
2,078 0.1 (g/hp-hr)(3)
0.00514
(2)
Superior 8G825
4SRB
8,000
800 0.0103
0.00132(2)
Superior 6G825
4SRB
8,000
600 0.0103(2)
0.00132(2)
(3)
Superior 8GTLA
4SLB
8,500
1,039 0.1 (g/hp-hr)
0.00514
Superior 12GTLA
4SLB
8,500
1,558 0.1 (g/hp-hr)(3)
0.00514
(4)
Ingersoll-Rand PKVG-6
4SRB
8,000
660 0.0205
0.00263
(2)
Waukesha L3711
4SRB
8,000
335 0.0103
0.00132(2)
1.
2.
3.
4.
Based on stack tests for Clark 2SLB engines, factors shown in g/hp-hr.
Based on AP-42 (7/00), Table 3.2-3 with 50% catalytic reduction.
Based on stack tests for White Superior 4SLB engines, factors shown in g/hp-hr.
Based on AP-42, Table 3.2-3.
EU
C-1A, B
C-2A, B
C-3A, B
C-4A, B
C-5A, B
C-6
C-7A, B
C-8
C-9
C-10
C-11
C-12
C-13
C-14
C-15
C-16
C-17
C-18
C-19
Formaldehyde and Acrolein Emissions
Formaldehyde
Source
lb/hr
TPY
Clark RA-8
0.42
1.86
Clark RA-8
0.42
1.86
Clark RA-8
0.42
1.86
Clark RA-6
0.32
1.39
Clark RA-6
0.32
1.39
Clark RA-8
0.42
1.86
Clark RA-8
0.42
1.86
Clark HRA-8
0.52
2.29
Clark HRA-8
0.52
2.29
Clark HRA-8
0.52
2.29
Clark HBA-8
1.47
6.46
Clark HBA-8 (removed)
0
0
Clark HBA-8
1.47
6.46
Clark HBA-5
0.58
2.55
Clark HBA-5 (removed)
0
0
Waukesha L7042 GSIU
0.08
0.33
Waukesha L7042 GSIU
0.08
0.33
Waukesha L7042 GSIU
0.08
0.33
Waukesha L5108 GU
0.04
0.18
Acrolein
lb/hr
TPY
0.056
0.25
0.056
0.25
0.056
0.25
0.042
0.18
0.042
0.18
0.056
0.25
0.056
0.25
0.062
0.27
0.062
0.27
0.062
0.27
0.123
0.54
0
0
0.123
0.54
0.077
0.34
0
0
0.01
0.04
0.01
0.04
0.01
0.04
0.005
0.02
18
DRAFT/PROPOSED
PERMIT MEMORANDUM 2011-227-TVR2
EU
C-20
C-21
C-22
C-23
C-24
C-25
C-26
C-27
C-28
C-29
G-1*
G-2*
G-3*
G-4*
G-5*
G-6
G-7
Source
Superior 16GTLA
Superior 16GTLA
Superior 16GTLA
Superior 8G825
Superior 6G825
Superior 8GTLA
Superior 12GTLA
Superior 12GTLA
Superior 12GTLA
Superior 12GTLA
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Ingersoll-Rand PKVG-6
Waukesha L3711
Waukesha L3711
Total
Formaldehyde
lb/hr
TPY
0.46
2.01
0.46
2.01
0.46
2.01
0.07
0.29
0.05
0.22
0.23
1.00
0.34
1.50
0.34
1.50
0.34
1.50
0.34
1.50
0.11
0.47
0.11
0.47
0.11
0.47
0.11
0.47
0.11
0.47
0.03
0.12
0.03
0.12
11.82
51.72
19
Acrolein
lb/hr
TPY
0.091
0.40
0.091
0.40
0.091
0.40
0.008
0.04
0.006
0.03
0.045
0.20
0.068
0.30
0.068
0.30
0.068
0.30
0.068
0.30
0.014
0.06
0.014
0.06
0.014
0.06
0.014
0.06
0.014
0.06
0.0035 0.02
0.0035 0.02
1.589
6.99
* To be removed from service prior to October 19, 2013.
The facility is a major source of formaldehyde emissions.
Glycol Dehydration Unit
Glycol dehydration units in natural gas service typically emit benzene, toluene, ethyl benzene,
xylene, and n-hexane from the rich glycol flash tank and the regenerator still vent. These
compounds are regulated as HAP. Emission estimates for the glycol unit are based on GRIGLYCalc 3.0, a wet gas extended analysis dated December 17, 2004, a lean glycol circulation
rate of 13 gpm, and a dry gas rate of 70 MMSCFD. Vapors from the rich glycol flash tank are
recycled back to the low-pressure inlet gas stream. Uncontrolled emissions from the glycol
regenerator still vent are listed in the table below.
Pollutant
Benzene
Toluene
Ethyl benzene
Xylene
n-Hexane
Total
Uncontrolled HAP
CAS
Emissions
Number
lb/hr
TPY
71432
4.04
17.7
108883
4.06
17.8
100414
0.21
0.93
1330207
2.15
9.40
110543
1.83
8.0
12.29
53.8
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
20
The glycol regenerator still vent emissions are vented to a condenser. Any uncondensed vapors
are then vented to the plant’s process/emergency flare or are recycled to the low-pressure inlet
gas stream. Controlled emissions are listed in the table below.
Pollutant
Benzene
Toluene
Ethyl benzene
Xylene
n-Hexane
Total
Controlled HAP
CAS
Emissions
Number
lb/hr
TPY
71432
0.08
0.35
108883
0.08
0.36
100414
<0.01
0.02
1330207
0.04
0.19
110543
0.04
0.16
0.25
1.08
Greenhouse Gases
The applicant has presented estimates of PTE for greenhouse gases (CO2-equivalent) at this site,
demonstrating that the facility is above the PSD-major source threshold (100,000 TPY CO2e, 250
TPY mass basis) for this pollutant. Therefore the facility is an existing PSD source for
greenhouse gases. Potential GHG Emission Summary Table follows.
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
21
Potential GHG Emission Summary Table
EUG#
Source
EUG-1
EUG-2
EUG-3
EUG-4
EUG-5
EUG-6
EUG-7
EUG-8
EUG-9
EUG-10
EUG-11
EUG-13
EUG-14
EUG-14
EUG-15
TOTAL
Grandfathered Engines and Generators (18)
Permitted Engines and Generators (16)
Tanks (8)
Fugitive Components Not Subject to NSPS Subpart KKK
Fugitive Components Subject to NSPA Subpart KKK
Heaters and Boilers (9)
Process/Emergency Flare
Gas Sweetening Units/Acid Gas Flaring
VOC Flare
Glycol Dehydration Unit
Condensate/Scrubber Oil Truck Loading (TL-1)
Miscellaneous Venting Activities
New (4) Condensate Tanks (TK-8, TK-10, TK-11, TK-12)
New Methanol Storage Tank (TK-13)
Condensate Truck Loading from EUG-14 (TL-2)
Carbon Dioxide
(CO2)
lb/hr
TPY
15,441.03
67,631.71
18,400.25
80,593.09
----0.01
0.01
0.01
0.04
12,590.21
55,145.12
513.28
2,248.15
176.37
772.52
30.84
135.08
----------0.01
0.07
0.31
--------47,152.06
206,526.04
Methane (CH4)
as CO2 Eq.
lb/hr
TPY
6.12
26.79
7.29
31.92
----111.82
489.77
383.30 1,678.85
4.99
21.84
0.20
0.89
0.07
0.31
0.01
0.05
------1.04
--402.01
30.78
134.82
------0.23
544.58 2,788.62
Nitrous Oxide (N2O)
as CO2 Eq.
lb/hr
TPY
9.03
39.54
10.76
47.12
------------7.36
32.24
0.30
1.31
0.10
0.45
0.02
0.08
------------------------27.57
120.75
Total CO2 + CO2 Eq.
lb/hr
15,456.17
18,418.30
--111.82
383.31
12,602.56
513.78
176.55
30.87
------30.85
----47,724.21
TPY
67,698.04
80,672.14
--489.78
1,678.89
55,199.20
2,250.36
773.28
135.22
--1.04
402.01
135.13
--0.23
209,435.32
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
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SECTION V. INSIGNIFICANT ACTIVITIES
The insignificant activities identified and justified in the application are duplicated below.
Records are available to confirm the insignificance of the activities. Appropriate recordkeeping
of activities indicated below with “*” is specified in the Specific Conditions.
1. Space heaters, boilers, process heaters and emergency flares less than or equal to 5
MMBtu/hr heat input fired by commercial natural gas. The facility has several portable space
heaters for the office buildings and various plant buildings. All are rated less than 5
MMBtu/hr. The 2.0 MMBtu/hr boilers (B-1 and B-2) are also in this category.
2. * Emissions from condensate tanks with a design capacity of 400 gallons or less in ozone
attainment areas. None identified, but may be added in the future.
3. Surface coating operations which do not exceed a combined total usage of more than 60
gallons/month of coatings, thinners, and clean-up solvents at any one emissions unit. The
facility conducts painting operations and engine cleaning exclusively for maintenance
purposes, which is a trivial activity; therefore, no records are required.
4. * Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant.
The methanol and ethylene glycol tanks and compressor blowdowns fit in this category. Also
included are the three regeneration-gas heaters (H-3, H-4, and H-7), the glycol reboiler (H-5),
and the amine reboiler (H-6).
SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252:100-1 (General Provisions)
Subchapter 1 includes definitions but there are no regulatory requirements.
[Applicable]
OAC 252:100-2 (Incorporation by Reference)
[Applicable]
This subchapter incorporates by reference applicable provisions of Title 40 of the Code of
Federal Regulations. These requirements are addressed in the “Federal Regulations” section.
OAC 252:100-3 (Air Quality Standards and Increments)
[Applicable]
Subchapter 3 enumerates the primary and secondary ambient air quality standards and the
significant deterioration increments. At this time, all of Oklahoma is in attainment of these
standards.
OAC 252:100-5 (Registration, Emission Inventory, and Annual Operating Fees)
[Applicable]
Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission
inventories annually, and pay annual operating fees based upon total annual emissions of
regulated pollutants. An emissions inventory has been submitted and fees paid for prior years as
required.
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
23
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 which result in emissions not authorized in the permit and
which exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior
notification to AQD and may require a permit modification. Insignificant activities mean
individual emission units that either are on the list in Appendix I (OAC 252:100), 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 HAP or 20% of
any threshold less than 10 TPY for single HAP that the EPA may establish by rule
Emission limitations and operational requirements necessary to assure compliance with all
applicable requirements for all sources are taken from the operating permit application, or
developed from the applicable requirements.
Part 7 summarizes Prevention of Significant Deterioration (PSD) requirements. See the “Federal
Regulations” section for a discussion of PSD regulations.
OAC 252:100-9 (Excess Emission Reporting Requirements)
[Applicable]
Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess
emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following
working day of the first occurrence of excess emissions in each excess emission event. No later
than thirty (30) calendar days after the start of any excess emission event, the owner or operator
of an air contaminant source from which excess emissions have occurred shall submit a report
for each excess emission event describing the extent of the event and the actions taken by the
owner or operator of the facility in response to this event. Request for affirmative defense, as
described in OAC 252:100-9-8, shall be included in the excess emission event report. Additional
reporting may be required in the case of ongoing emission events and in the case of excess
emissions reporting required by 40 CFR Parts 60, 61, or 63.
OAC 252:100-13 (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 (Control of Emission of Particulate Matter)
[Applicable]
Section 19-4 regulates emissions of particulate matter (PM) from new and existing fuel-burning
equipment, with emission limits based on maximum design heat input rating. Fuel-burning
equipment is defined in OAC 252:100-1 as “combustion devices used to convert fuel or wastes to
usable heat or power.” Thus, the gas-fired heaters and reboilers and engines are subject to the
requirements of this subchapter. The facility’s flares are not subject since they do not produce
any “usable heat or power.” Appendix C specifies a PM emission limitation range of 0.6
lb/MMBtu to 0.35 for fuel-burning equipment with a rated heat input range of 10 MMBtu/hr or
less up to 100 MMBtu/hr. AP-42 (7/98) Table 1.4-2 lists total PM emissions as 0.0076
lb/MMBtu for natural gas combustion. AP-42 (7/00) Section 3.2 lists total PM emissions from
natural gas-fired reciprocating internal combustion engines as about 0.01 lb/MMBtu. This
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
24
permit requires the use of natural gas for all fuel-burning units to ensure compliance with
Subchapter 19.
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. There is little possibility of exceeding these standards when burning
natural gas. This permit requires the use of natural gas for all fuel-burning units to ensure
compliance with Subchapter 25.
OAC 252:100-29 (Control of Fugitive Dust)
[Applicable]
No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the
property line on which the emissions originate in such a manner as to damage or 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. 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 2 limits the ambient air impact of hydrogen sulfide emissions from any new or existing
source to 0.2 ppm for a 24-hour average (equivalent to 280 g/m3). For the acid gas flare, EPA
SCREEN3 dispersion modeling was conducted based on the stack parameters listed below and
emissions rates of 0.14 lb/hr of H2S. The SCREEN3 results are tabulated in the following table.
Acid Gas Flare
Stack Height:
Stack Diameter:
Heat Release:
110 ft
24 inch
0.50 MMBtu/hr
(A lower heat release than the 1.5 MMBtu/hr maximum rate was
used for a conservative estimate)
Ambient Impacts of H2S (0.14 lb/hr)
Standard
Ground Level Concentration
Averaging Time
3
g/m
g/m3
24-hour
280
0.41
For the process/emergency flare, EPA SCREEN3 dispersion modeling was conducted based on
the stack parameters listed below and emissions rates of 0.55 lb/hr of H2S. The SCREEN3
results are tabulated in the following table.
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
25
Process/Emergency Flare
Stack Height:
Stack Diameter:
Heat Release:
110 ft
24 inches
40 MMBtu/hr (a lower heat release than the 27,000 MMBtu/hr
maximum rate was used for a conservative estimate)
Ambient Impacts of H2S (0.55 lb/hr)
Standard
Ground Level Concentration
Averaging Time
3
g/m
g/m3
24-hour
280
0.1
Part 5 limits sulfur dioxide emissions from new equipment (constructed after July 1, 1972). For
gaseous fuels, the limit is 0.2 lb/MMBtu heat input. This is equivalent to approximately 0.2weight percent sulfur in the fuel gas, which is equivalent to 2,000-ppmw sulfur. Thus, a
limitation of 343-ppmv sulfur in a field gas supply will be in compliance. The permit requires
the use of pipeline-grade natural gas or field gas with a maximum sulfur content of 343-ppmv for
all fuel-burning equipment to ensure compliance with Subchapter 31.
Part 5 also limits hydrogen sulfide emissions from new equipment (constructed after July 1,
1972). Removal of hydrogen sulfide in the exhaust stream, or oxidation to sulfur dioxide, is
required unless hydrogen sulfide emissions would be less than 0.3 lb/hr for a two-hour average.
Hydrogen sulfide emissions shall be reduced by a minimum of 95% of the hydrogen sulfide in
the exhaust gas. Direct oxidation of hydrogen sulfide is allowed for units whose emissions
would be less than 100 lb/hr of sulfur dioxide for a two-hour average. Acid gas from the amine
treater rich amine flash tanks and the amine regenerator still vents are vented to the acid gas flare,
which has a conversion efficiency of 98%.
OAC 252:100-33 (Nitrogen Oxides)
[Not Applicable]
This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or
equal to 50 MMBtu/hr to emissions of 0.2 lb of NOX per MMBtu, three-hour average. There are
no equipment items that equal or exceed the 50 MMBtu/hr threshold.
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. Tanks TK-1, TK-2, TK3, and TK-5 were constructed prior to 1974 and are exempt from this requirement. Tanks TK-4,
TK-6, and TK-7 are subject to this requirement and are equipped with submerged fill pipes. Tank
TK-8 stores material with a vapor pressure less than 1.5 psia and is exempt from this requirement.
Tanks TK-9, TK-10, TK-11, and TK-12 are subject to this requirement.
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
26
Part 3 requires loading facilities with a throughput equal to or less than 40,000 gallons per day to
be equipped with a system for submerged filling of tank trucks or trailers if the capacity of the
vehicle is greater than 200 gallons. This facility does not have the physical equipment (loading
arm and pump) to conduct this type of loading. Therefore, this requirement is not applicable.
Part 7 requires fuel-burning equipment to be operated and maintained to minimize emissions of
VOC. All fuel-burning equipment at this location is subject to this requirement.
Part 7 regulates VOC/water separators that receive water containing more than 200 gallons per
day of VOC. There is no VOC/water separator at this location. Tank T-4 and five open pits
recover water from the condensate tank area, rainwater runoff, and the plant drain system. Most
of the oil/water mixtures captured by these units are removed by vacuum truck for off-site
disposal. A small amount of the skimmed oil is sold occasionally.
OAC 252:100-42 (Toxic Air Contaminants (TAC))
[Applicable]
This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in
areas of concern (AOC). Any work practice, material substitution, or control equipment required
by the Department prior to June 11, 2004, to control a TAC, shall be retained unless a
modification is approved by the Director. Since no AOC has been designated anywhere in the
state, there are no specific requirements for this facility at this time.
OAC 252:100-43 (Testing, Monitoring, and Recordkeeping)
[Applicable]
This subchapter provides general requirements for testing, monitoring and recordkeeping and
applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.
To determine compliance with emissions limitations or standards, the Air Quality Director may
require the owner or operator of any source in the state of Oklahoma to install, maintain and
operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant
source. All required testing must be conducted by methods approved by the Air Quality Director
and under the direction of qualified personnel. A notice of intent to test and a testing protocol
shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.
Emissions and other data required to demonstrate compliance with any federal or state emission
limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and
submitted as required by this subchapter, an applicable rule, or permit requirement. Data from
any required testing or monitoring not conducted in accordance with the provisions of this
subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive
use, of any credible evidence or information relevant to whether a source would have been in
compliance with applicable requirements if the appropriate performance or compliance test or
procedure had been performed.
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
27
The following Oklahoma Air Quality Rules are not applicable to this facility:
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
Alternative Emissions Reduction
Mobile Sources
Incinerators
Cotton Gins
Grain, Feed, or Seed Facility
Non-attainment Areas
Municipal Solid Waste Landfills
not eligible
not in source category
not type of emission unit
not type of emission unit
not in source category
not in a subject area
not type of source category
SECTION VII. FEDERAL REGULATIONS
PSD, 40 CFR Part 52
[Not Applicable]
Total potential emissions of NOX, CO, and VOC are greater than the threshold level of 250 TPY.
Any future increases of emissions must be evaluated for PSD if they exceed a significance level
(100 TPY CO, 40 TPY NOX, 40 TPY SO2, 40 TPY VOC, 15 TPY PM10, 10 TPY H2S).
NSPS, 40 CFR Part 60
[Subparts A, Dc, KKK, OOOO and LLL Applicable]
Subpart A, General Provisions. The VOC flare (FL-2) is used to control emissions from relief
valves within the gas liquids extraction equipment that are subject to NSPS Subpart KKK and to
control emissions from the seal degassing systems of compressors C-19, C-24 and C-25. The
plant process/emergency flare (FL-1) is used to control emissions from the TEG dehydration still
vent and from relief valves that are subject to NSPS Subpart KKK. The VOC flare and the plant
process/emergency flare are subject to Subpart A and shall comply with all applicable
requirements for flares in §60.18. The acid gas flare is used to control the acid gas from the DGA
and DEA units. However, it is not used to comply with NSPS Subpart LLL even though the DGA
and DEA are both subject to NSPS Subpart LLL because the H2S design capacity of both amine
units is less than 2 LT/D. Therefore, the control requirements of Subpart LLL are not applicable.
Subpart Dc, Small Industrial-Commercial-Institutional Steam Generating Units. This subpart
affects steam generating units constructed after June 9, 1989, and with capacity between 10 and 100
MMBtu/hr. Hot oil heaters H-1 and H-2 are “Steam Generating Units” as that term is defined in
this subpart. The heaters were constructed prior to June 9, 1989; however, new burners were
installed in H-1 in 1997 that would reduce NOX and CO emissions, but allowed for a very slight
increase in SO2 emissions that triggered Subpart Dc. Since H-1 is fired with natural gas, only initial
notification and records of the type of fuel and amount combusted each day is required.
Subparts K, Ka, Kb, Volatile Organic Liquid (VOL) Storage Vessels. All tanks were either
constructed prior to the effective date of these subparts or are below the 19, 813 gallon threshold
for Subpart Kb.
Subpart GG, Stationary Gas Turbines. There are no stationary gas turbines at this facility.
Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants
PERMIT MEMORANDUM 2011-227-TVR2
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constructed, reconstructed, or modified after January 20, 1984. This subpart sets standards for
natural gas processing plants, which are defined as any site engaged in the extraction of natural
gas liquids from field gas, fractionation of natural gas liquids, or both. Compressors C-16
through C-23 and C-25 through C-29 are affected facilities since they were constructed/modified
after January 20, 1984. Subpart KKK specifically exempts reciprocating compressors in wet gas
service, and compressors that are not in VOC service, from all but notification and recordkeeping
requirements. Compressors C-20, C-21, C-22, and C-23 are in wet gas service and all must meet
the notificationand recordkeeping requirements of §60.486(j) and §60.635(a) and (c). Compressors
C-16, C-17, C-18, C-26, C-27, C-28 and C-29 are in wet gas/residue gas service. Compressors C19, C-24 and C-25 are in propane refrigeration service and subject to §60.482-3 control
requirements. The permittee will be required to maintain a leak detection and repair (LDAR)
program for C-19, C-24, C-25, and associated equipment. EUG-5 includes the WOK 16” inlet and
condensate handling process and will be subject to this subpart.
The TEG dehydrator unit (Plant 3 TEG System) was constructed in 1986 and is an affected facility.
The amine units (Plants 1 & 2 DGA North Amine Treater and Plant 3 DEQ South Amine Treater)
were constructed/reconstructed after 1984 and are affected facilities. Multiple inlet gas streams
(Inlet Gas South Low, Inlet Gas South High, Anadarko Inlet and Waukesha Inlet) are affected
facilities. Other process units have some equipment components constructed or modified after
January 20, 1984. EUG-5 contains those equipment components subject to Subpart KKK. The
permittee will be required to maintain an LDAR program for those components.
Subpart LLL sets standards for natural gas sweetening units, and sweetening units followed by a
sulfur recovery unit, which commenced construction or modification after January 20, 1984. The
north amine unit (DGA) was reconstructed after the applicability date of Subpart LLL. The south
amine unit (DEA) was constructed in 1985. Both are subject to this subpart. However, facilities
with a design capacity of less than 2 long tons per day (LT/D) of H2S in the acid gas, expressed
as sulfur, are exempted from the control requirements of the standard. The applicant has
provided an analysis demonstrating that the amine units at this facility have a design capacity of
less than 2 LT/D of sulfur. Therefore, the north and south amine units are subject only to
§60.647 (c), which requires the facility to keep, for the life of the facility, an analysis
demonstrating that the amine units’ design capacities are less than 2 LT/D of H2S, expressed as
sulfur.
Subpart NNN, VOC Emissions from SOCMI Distillation Operations. This subpart applies to each
affected facility (distillation units and recovery systems) that is part of a process unit that produces
any of the chemicals listed in §60.667 as a product, co-product, by-product, or intermediate. The
affected facilities are (1) each distillation unit not discharging its vent stream into a recovery
system, (2) each combination of distillation unit and the recovery system into which its vent
stream is discharged, or (3) each combination of two or more distillation units and the common
recovery system into which their vent streams are discharged. The definition of “vent stream”
excludes relief valves and fugitive equipment leaks. Propane, butane, and isobutane are listed
chemicals in §60.667 and an Applicability Determination from EPA Region VI dated December
14, 2006 states that Subpart NNN applied to distillation operations at a natural gas processing
plant operated by ConocoPhillips Company. However, OFS has determined that only relief
PERMIT MEMORANDUM 2011-227-TVR2
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valves and fugitive leaks are vented to the atmosphere at this facility’s depropanizer and
debutanizer columns; therefore, there are no applicable requirements under Subpart NNN.
Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines, affects stationary compression ignition (CI) internal combustion engines (ICE) based on
power and displacement ratings, depending on date of construction, beginning with those
constructed after July 11, 2005. For the purposes of this subpart, the date that construction
commences is the date the engine is ordered by the owner or operator. The facility does not
presently operate any engines subject to this subpart since all engines were constructed prior to
July 11, 2005.
Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion
Engines, was proposed in the Federal Register on June 12, 2006. It will affect all new engines
and those modified or reconstructed after June 6, 2006. It will impose categories of standards for
NOX, CO, NMHC, based on engine power rating, lean-burn or rich-burn, fuel type, and
manufacture date. The facility does not presently operate any engines subject to this subpart
since all engines were constructed prior to June 12, 2006.
Subpart KKKK, Standards of Performance for Stationary Combustion Turbines, establishes
emission standards and compliance schedules for the control of emissions from stationary
combustion turbines with a heat input at peak load equal to or greater than 10 MMBtu per hour,
based on the higher heating value of the fuel, which commenced construction, modification, or
reconstruction after February 18, 2005. Stationary combustion turbines regulated under this
subpart are exempt from the requirements of Subpart GG of this part. Heat recovery steam
generators and duct burners regulated under this subpart are exempted from the requirements of
subparts Da, Db, and Dc of this part. There are no turbines at this facility.
Subpart OOOO, Crude Oil and Natural Gas Production, Transmission, and Distribution. This
subpart was promulgated on August 16, 2012, and affects the following sources that commence
construction, reconstruction, or modification after August 23, 2011:
1. Each single gas well;
2. Single centrifugal compressors using wet seals that are located between the wellhead and
the point of custody transfer to the natural gas transmission and storage segment;
3. Reciprocating compressors which are single reciprocating compressors located between the
wellhead and the point of custody transfer to the natural gas transmission and storage
segment;
4. Single continuous bleed natural gas driven pneumatic controllers with a natural gas bleed
rate greater than 6 SCFH, which commenced construction after August 23, 2011, located
between the wellhead and the point of custody transfer to the natural gas transmission and
storage segment and not located at a natural gas processing plant;
5. Single continuous bleed natural gas driven pneumatic controllers which commenced
construction after August 23, 2011, and is located at a natural gas processing plant;
6. Single storage vessels located in the oil and natural gas production segment, natural gas
processing segment, or natural gas transmission and storage segment;
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
30
7. All equipment, except compressors, within a process unit at an onshore natural gas
processing plant;
8. Sweetening units located at onshore natural gas processing plants.
The only affected facilities at this time are reciprocating compressors added, modified or
reconstructed after August 23, 2011.
NESHAP, 40 CFR Part 61
[Not Applicable]
There are no emissions of any of the regulated pollutants: arsenic, asbestos, beryllium, benzene,
coke oven emissions, mercury, radionuclides, or vinyl chloride except for trace amounts of
benzene. Subpart J (Equipment Leaks of Benzene) concerns only process streams, which contain
more than 10% benzene by weight. All process streams at this facility are below this threshold.
NESHAP, 40 CFR Part 63
[Subparts A, HH, ZZZZ, and DDDDD are Applicable]
Subpart A, General Provisions. The facility is subject to the reporting requirements of 40 CFR
§60.9, but is not subject to the flare requirements of 40 CFR §63.11. Neither of the two flares
(FL-1 nor FL-2) at the plant is used to comply with MACT Subpart HH. The General Standards
require compliance with 40 CFR §63.771 or 40 CFR §63.11 for “flares that are used to comply
with Subpart HH.” GLYCOL UNITS: The process/emergency flare (FL-1) was used to control
emissions from the TEG dehydration still vent prior to June 17, 2002 and the requirement to
recycle or flare the glycol vent gas was a federally enforceable permit limit prior to June 17, 2002.
Because the benzene from that flare is < 0.90 megagrams per year, the glycol unit and flare are
exempt under 40 CFR §63.764(e)(1)(ii). ANCILLARY EQUIPMENT: 40 CFR §63.769(b)
exempts sources “meeting the requirements specified in 40 CFR Part 60, subpart KKK” from 40
CFR §63.769, which includes 40 CFR §63.11(b).
Subpart HH, Oil and Natural Gas Production Facilities. This subpart applies to affected emission
points that are located at facilities which are major sources of HAP, or TEG dehydration units
only located at an area source, and either process, upgrade, or store hydrocarbons prior to the
point of custody transfer or prior to the point at which the natural gas enters the natural gas
transmission and storage source category. Subpart HH affects glycol dehydration unit process
vents, storage vessels with potential for flash emissions, and compressors and ancillary
equipment (valves, flanges, etc.) in VHAP service (i.e., more than 10% by weight HAP) that are
located at gas processing plants. This facility is a major source of HAP and must meet the
compliance, reporting, and recordkeeping requirements of Subpart HH.
Emissions from the glycol dehydrator still vent are controlled by a condenser and by recycle or
combustion in the plant’s process/emergency flare. The applicant has stated and demonstrated
that the glycol unit is subject to the control requirements of §63.764 and §63.765.
The natural gasoline system, equipment handling condensate, and the engine jacket cooling water
systems (using ethylene glycol) have ancillary equipment components in VHAP service. The
facility has implemented and will maintain a leak detection and repair program (LDAR) for those
equipment components in VHAP service.
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
31
All condensate and scrubber oil storage tanks are exempt from the standards of this subpart as
none have a throughput above 21,000 gallons per day. None of the facility’s compressors are in
VHAP service.
Recordkeeping is required for notifications required by 40 CFR §63.9, for the LDAR monitoring,
for the records required by 40 CFR §63.772(a) that demonstrate which streams are in VHAP
service and which streams are not in VHAP service, and for the exemptions documented
according to 40 CFR §63.764(e)(1)(ii), §63.774(d)(1)(ii) and §63.774(d)(2).
Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart previously
affected only RICE with a site-rating greater than 500 brake horsepower located at a major
source of HAP emissions. On January 18, 2008, the EPA published a final rule that promulgates
standards for new and reconstructed engines (after June 12, 2006) with a site-rating less than or
equal to 500 HP located at major sources, and for new and reconstructed engines (after June 12,
2006) located at area sources.
The existing lean-burn engines are exempt from any standards in Subpart ZZZZ. All existing
rich-burn engines with a site-rating greater than 500 brake horsepower are subject to emission
and operating limitations in Subpart ZZZZ and were required to comply with the standards by
June 15, 2007. The permit will require compliance with this subpart. As previously explained,
OFS took a federally enforceable limit on the horsepower output for the engines driving
generators G-1, G-2, G-3, G-4, and G-5 in order to delay applicability to the RICE MACT. OFS
has now decided to remove these units from service prior to the October 19, 2013 compliance
deadline. All remaining rich-burn engines with a site-rating less than 500 brake horsepower (C19, G-6 and G-7) are subject to emission and operating limitations in Subpart ZZZZ and will be
required to comply with the standards by October 19, 2013.
Subpart DDDDD, Industrial, Commercial and Institutional Boilers and Process Heaters at major
sources of HAP. On January 31, 2013, the EPA took final action on its reconsideration of certain
issues in the emission standards for the control of HAP from new and existing industrial,
commercial, and institutional boilers and process heaters at major sources of HAP. The
compliance dates for the rule are January 31, 2016, for existing sources and, January 31, 2013, or
upon startup, whichever is later, for new sources. New sources are defined as sources that began
operation on or after June 4, 2010. Hot oil heaters H-1 and H-2 are process heaters are affected
units. Both of these units are existing sources in the unit designed to burn gas 1 subcategory and
are rated greater than 10 MMBTUH. Units with a continuous oxygen trim system that maintains
an optimum air to fuel ratio are required to conduct a tune-up of the boiler initially and then
every 5 years thereafter as specified in § 63.7540. Units without a continuous oxygen trim
system are required to conduct a tune-up of the boiler initially and then every 5 years thereafter as
specified in § 63.7540. Units greater than 10 MMBTUH without a continuous oxygen trim
system will conduct this tune-up as a work practice for all regulated emissions under this subpart.
These affected units must conduct the required initial tune-up by January 31, 2016.
Heaters H-3, H-4, H-5, H-6, H-7, B-1, and B-2 were considered small gaseous fuel heaters (less
than 10 MMBtu/hr heat rating) that were not subject to any standards, recordkeeping, or
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
32
notifications under Subpart DDDDD.
CAM, 40 CFR Part 64
[Applicable]
Compliance Assurance Monitoring (CAM) applies to any pollutant specific emission unit at a
major source that is required to obtain a Title V permit, if it meets all of the following criteria:
1. It is subject to an emission limit or standard for an applicable regulated air pollutant.
2. It uses a control device to achieve compliance with the applicable emission limit or
standard.
3. It has potential emissions, prior to the control device, of the applicable regulated air
pollutant of 100 TPY for a criteria pollutant, 10 TPY for an individual HAP, or 25 TPY
for all HAP.
Pre-control emissions from the glycol regenerator still vent are above 100 TPY for VOC and a
control device is used to meet the permit emission limits. Therefore, since the glycol dehydration
unit is subject to the control standards of Subpart HH, the unit and its controls are not subject to
CAM. Engines C-16, C-17, C-18, and C-23, have pre-control emissions above major source
levels and are equipped with catalytic converters (NSCR) to meet permit emission limits.
Therefore, all these engines and their control components were previously determined to be
subject to CAM. All of these engines became subject to emission limitations in 40 CFR Part 63,
Subpart ZZZZ and were required to demonstrate compliance with those MACT standards by
June 15, 2007. Therefore, the monitoring required by Subpart ZZZZ is presumptively acceptable
as monitoring for CAM.
Chemical Accident Prevention Provisions, 40 CFR Part 68
[Applicable]
This facility handles naturally occurring hydrocarbon mixtures at a natural gas processing plant
and is subject to this Subpart (Section 112r of the Clean Air Act 1990 Amendments). A Risk
Management Plan was submitted to EPA Region 6 on June 14, 1999 and deemed complete on
June 16, 1999. An update to the RMP was received on September 23, 1999 and judged complete
on September 28, 1999. Renewals to the RMP were submitted on September 16, 2004 and
September 16, 2009. EPA Notice of Confirmation was dated September 24, 2004. More
information on this federal program is available on the web page: www.epa.gov/ceppo
Stratospheric Ozone Protection, 40 CFR Part 82
[Subpart A and F Applicable]
These standards require phase out of Class I & II substances, reductions of emissions of Class I
& II substances to the lowest achievable level in all use sectors, and banning use of nonessential
products containing ozone-depleting substances (Subparts A & C); control servicing of motor
vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D); require warning labels on products made with or
containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon
disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons
(Subpart H).
PERMIT MEMORANDUM 2011-227-TVR2
33
DRAFT/PROPOSED
Subpart A identifies ozone-depleting substances and divides them into two classes. Class I
controlled substances are divided into seven groups; the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform
(Class I, Group V). A complete phase-out of production of Class I substances is required by
January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are
hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.
Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances,
scheduled in phases starting by 2002, is required by January 1, 2030.
This facility does not produce, consume, recycle, import, or export any controlled substances or
controlled products as defined in this part, nor does this facility perform service on motor (fleet)
vehicles that involves ozone-depleting substances. Therefore, as currently operated, this facility
is not subject to these requirements. To the extent that the facility has air-conditioning units that
apply, the permit requires compliance with Part 82.
SECTION VIII. COMPLIANCE
Inspection
On May 30, 2012, from 10:00 hours to 13:00 hours, an announced air quality FCE was
conducted at ONEOK Maysville Gas Plant. Austin Hawkins and Patrick Frisby, Environmental
Programs Specialists for the Oklahoma Department of Environmental Quality, Air Quality
Division (“Department”) conducted the evaluation. Berry Mantooth, Environmental Specialist,
represented ONEOK. The Exit Interview/Summary states: The Facility appears to be in
compliance with the requirements and conditions of Permit No. 2004-163-TVR (M-5) as well as
state and federal regulations. However, the missing plate on the generator engine designated G5 should be considered an area of concern. As previously stated, the plate is missing, and is
apparently lost. ONEOK personnel state that they would like to find the original plate since the
unit is an antique but will fabricate a new plate if the original cannot be found.
Since the May 30, 2012 FCE, there are no open compliance/enforcement issues involving this
facility.
A facility inspection is not needed for this permit renewal.
Testing
EU
C-16
C-17
C-18
Permitted Engine Testing
NOX
CO
Engine
Limit
Test
Limit
Test
lb/hr
lb/hr
lb/hr
lb/hr
Waukesha L7042 GSIU
4.06
3.87 11.5
5.02
Waukesha L7042 GSIU
4.06
1.01 11.5
0.25
Waukesha L7042 GSIU
4.06
1.97 11.5
2.89
Testing
Date
07/16/2013
08/28/2013
07/16/2013
PERMIT MEMORANDUM 2011-227-TVR2
EU
C-19
C-20
C-21
C-22
C-23
C-24
C-25
C-26
C-27
C-28
C-29
G-6
G-7
Engine
Waukesha L5108 GU
Superior 16GTLA
Superior 16GTLA
Superior 16GTLA
Superior 8G825
Superior 6G825
Superior 8GTLA
Superior 12GTLA
Superior 12GTLA
Superior 12GTLA
Superior 12GTLA
Waukesha L3711
Waukesha L3711
NOX
Limit
Test
lb/hr
lb/hr
2.17
0.09
9.15
4.90
9.15
7.75
9.15
1.76
3.52
0.30
2.64
0.01
4.58
0.48
6.86
6.27
6.86
6.66
6.86
4.54
6.86
0.75
1.48
0.60
1.48
0.08
34
DRAFT/PROPOSED
CO
Limit
Test
lb/hr
lb/hr
5.23
1.11
13.7
7.81
13.7
6.02
13.7
8.75
5.29
0.79
3.96
0.68
6.87
2.70
10.3
5.08
10.3
6.35
10.3
5.51
10.3
6.54
4.17
0.35
4.17
0.28
Testing
Date
07/16/2013
07/16/2013
04/03/2013
07/16/2013
07/18/2013
08/28/2013
07/16/2013
08/28/2013
07/16/2013
07/16/2013
09/17/2013
08/28/2013
08/28/2013
Tier Classification and Public Review
This application has been classified as Tier II based on the request for the second renewal of the
Title V operating permit. Public and EPA review of the application and permit are required.
The permit will be reviewed by EPA Region VI for review for a period of 45 days which will be
concurrent with the 30 day public review required by Tier II permits.
The applicant has submitted a signed affidavit from Garvin County News Star, a weekly
publication that is a “legal newspaper” for the City of Maysville, in Garvin county, that a “Notice
of Filing a Tier II Application” was published on April 28, 2011. The Notice stated that the
application was available for public review at the Elliott Lasater Maysville library or at the Air
Quality Division’s main office. No comments were received from the public.
The applicant will be required to publish a “Notice of Tier II Draft Permit” when this draft permit
is issued.
The facility is not located within 50 miles of the Oklahoma State border.
The permittee has submitted an affidavit that they are not seeking a permit for land use or for any
operation upon land owned by others without their knowledge. The affidavit certifies that the
applicant owns the land.
Information on all permit actions is available for review by the public in the Air Quality section
of the DEQ Web Page: www.deq.state.ok.us.
PERMIT MEMORANDUM 2011-227-TVR2
DRAFT/PROPOSED
35
Fees Paid
A renewal to a Part 70 permit application fee of $1,000 has been paid.
SECTION IX. SUMMARY
The facility is constructed and operated as described in the permit application. Ambient air
quality standards are not threatened at this site and OFS has submitted modeling demonstrating
that the facility is in compliance with the NAAQS for NO2, There are no active compliance or
enforcement Air Quality issues that affect the issuance of this permit. Issuance of this permit is
recommended, contingent on public and EPA review.
DRAFT/PROPOSED
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
ONOEK Field Services Company, L.L.C.
Maysville Gas Plant
Permit Number 2011-227-TVR2
The permittee is authorized to operate in conformity with the specifications submitted to Air
Quality on February 23, 2010, and at various other times as requested. The Evaluation
Memorandum dated October 14, 2013 explains the derivation of applicable permit requirements
and estimates of emissions; however, it does not contain operating limitations or permit
requirements. Operating under this permit constitutes acceptance of, and consent to, the
conditions contained herein:
1.
Points of emissions and emissions limitations for each point:
[OAC 252:100-8-6(a)(1)]
EUG 1 and EUG 2. Grandfathered Engines and Permitted Engines
EUG 1. Grandfathered Engines - no emission limits are applied to these engines under Title V,
but emissions are limited to the existing equipment as it is.
EU
C-1
C-2
C-3
C-4
C-5
C-6
C-7
C-8
C-9
C-10
C-11
C-13
C-14
Engine
Clark RA-8
Clark RA-8
Clark RA-8
Clark RA-6
Clark RA-6
Clark RA-8
Clark RA-8
Clark HRA-8
Clark HRA-8
Clark HRA-8
Clark HBA-8
Clark HBA-8
Clark HBA-5
Hp
800
800
800
600
600
800
800
880
880
880
1,760
1,760
1,100
Serial #
25938
25937
25936
21133
21132
25927
25928
A25567
A25568
A25572
30269
30271
35601
SPECIFIC CONDITIONS 2011-227-TVR2
DRAFT/PROPOSED
2
EUG 2. Permitted engines - emissions for these units are limited as follows.
EU
Engine
Serial #
C-16.2
C-17
C-18
C-19
C-20
C-21
C-22
C-23
C-24
C-25
C-26.2
C-27
C-28
C-29
G-6
G-7
Waukesha L7042 GSIU
Waukesha L7042 GSIU
Waukesha L7042 GSIU
Waukesha L5108 GU
Superior 16GTLA
Superior 16GTLA
Superior 16GTLA
Superior 8G825
Superior 6G825
Superior 8GTLA
Superior 12GTLA
Superior 12GTLA
Superior 12GTLA
Superior 12GTLA
Waukesha L3711
Waukesha L3711
365714A
387563
387652
387653
306999
306599
291649
282349
292229
293109
310529
304979
304989
295909
48027
48028
NOX
lb/hr TPY
4.07 17.8
4.07 17.8
4.07 17.8
2.17 9.5
9.16 40.1
9.16 40.1
9.16 40.1
3.53 15.5
2.65 11.6
4.58 20.1
6.87 30.1
6.87 30.1
6.87 30.1
6.87 30.1
1.48 6.47
1.48 6.47
CO
lb/hr
11.5
11.48
11.48
5.21
13.7
13.7
13.7
5.29
3.97
6.87
10.3
10.3
10.3
10.3
4.17
4.17
TPY
50.3
50.3
50.3
22.8
60.0
60.0
60.0
23.2
17.4
30.1
45.1
45.1
45.1
45.1
18.3
18.3
VOC
lb/hr
TPY
2.03
8.90
2.03
8.90
2.03
8.90
1.08
4.75
4.58
20.1
4.58
20.1
4.58
20.1
1.76
7.72
1.32
5.79
2.29
10.0
3.43
15.0
3.43
15.0
3.43
15.0
3.43
15.0
0.74
3.2
0.74
3.2
2.
Each engine at the facility shall have a permanent identification plate attached, which shows
the make, model number, and serial number.
[OAC 252:100-43]
3.
The permittee shall at all times properly operate and maintain all engines in a manner that
will minimize emissions of hydrocarbons or other organic materials.
[OAC 252:100-37-36]
4.
The permittee shall keep operation and maintenance (O&M) records for the grandfathered
engines (EUG 1) and for each permitted engine (EUG 2) that is not tested in a quarter.
Such records shall at a minimum include the dates of operation and maintenance, type of
work performed, and the increase, if any, in emissions as a result.
[OAC 252:100-8-6 (a)(3)(B)]
5.
At least once per calendar quarter, the permittee shall conduct tests of NOX and CO
emissions in exhaust gases from each engine in EUG 2 and from each replacement
engine/turbine when operating under representative conditions for that period. Testing is
required for each engine in EUG 2 or any replacement engine/turbine that runs for more
than 220 hours during that calendar quarter. A quarterly test may be conducted no sooner
than 20 calendar days after the most recent test. Testing shall be conducted using a portable
analyzer in accordance with a protocol meeting the requirements of the latest AQD Portable
Analyzer Guidance document, or an equivalent method approved by Air Quality. When
four consecutive quarterly tests show the engine/turbine to be in compliance with the
emissions limitations shown in the permit, then the testing frequency may be reduced to
semi-annual testing. A semi-annual test may be conducted no sooner than 60 calendar days
SPECIFIC CONDITIONS 2011-227-TVR2
DRAFT/PROPOSED
3
nor later than 180 calendar days after the most recent test. Likewise, when the following
two consecutive semi-annual tests show compliance, the testing frequency may be reduced
to annual testing. An annual test may be conducted no sooner than 120 calendar days nor
later than 365 calendar days after the most recent test. Upon any showing of noncompliance with emissions limitations or testing that indicates that emissions are within
10% of the emission limitations, the testing frequency shall revert to quarterly. Reduced
testing frequency does not apply to engines with catalytic converters. Any reduction in the
testing frequency shall be noted in the next required compliance certification.
[OAC 252:100-8-6 (a)(3)(A)]
6.
When periodic compliance testing shows exhaust emissions from the engines in excess of
the lb/hr limits in Specific Condition No. 1, the permittee shall comply with the provisions
of OAC 252:100-9. Requirements of OAC 252:100-9 include immediate notification and
written notification of Air Quality and demonstrations that the excess emissions meet the
criteria specified in OAC 252:100-9.
[OAC 252:100-9]
7.
Replacement (including temporary periods of 6 months or less for maintenance purposes), of
the internal combustion engines with emissions specified in this permit with engines/turbines
of lesser or equal emissions of each pollutant (in lbs/hr and TPY) is authorized under the
following conditions.
a.
b.
c.
d.
8.
The permittee shall notify AQD in writing no later than 7 days in advance of the start-up
of the replacement engine(s)/turbine(s). Said notice shall identify the equipment
removed and shall include the new engine/turbine make, model, and horsepower; date
of the change, and any change in emissions.
Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to
confirm continued compliance with NOX and CO emissions limitations. A copy of the
first quarter testing shall be provided to AQD within 60 days of start-up of each
replacement or additional engine/turbine.
The test report shall include the
engine/turbine fuel usage, stack flow (ACFM), stack temperature (oF), stack height
(feet), stack diameter (inches), and pollutant emissions rates (g/hp-hr, lbs/hr, and TPY)
at maximum rated horsepower for the altitude/location.
Replacement equipment and emissions are limited to equipment and emissions that
are not a modification under NSPS, NESHAP, or a significant modification under
PSD.
[OAC 252:100-8-6(f)]
Engines installed as allowed under the replacement allowance in this Specific
Condition that are subject to 40 CFR Part 63, Subpart ZZZZ and/or 40 CFR Part 60,
Subpart JJJJ shall comply with all applicable requirements.
By the initial compliance date of October 19, 2013, the owner/operator shall comply with
all applicable requirements of the NESHAP: Reciprocating Internal Combustion Engines,
Subpart ZZZZ, for each affected facility including but not limited to the provisions listed
below.
[40 CFR 63 Subpart ZZZZ]
SPECIFIC CONDITIONS 2011-227-TVR2
DRAFT/PROPOSED
4
What This Subpart Covers
a.
§ 63.6580 What is the purpose of subpart ZZZZ?
b.
§ 63.6585 Am I subject to this subpart?
c.
§ 63.6590 What parts of my plant does this subpart cover?
d.
§ 63.6595 When do I have to comply with this subpart?
Emission and Operating Limitations
e.
§ 63.6603 What emission limitations and operating limitations must I meet if I own
or operate an existing stationary RICE located at an area source of HAP emissions?
General Compliance Requirements
f.
§ 63.6605 What are my general requirements for complying with this subpart?
Testing and Initial Compliance Requirements
g.
§ 63.6625 What are my monitoring, installation, operation, and maintenance
requirements?
h.
§ 63.6630 How do I demonstrate initial compliance with the emission limitations
and operating limitations?
Continuous Compliance Requirements
i.
§ 63.6640 How do I demonstrate continuous compliance with the emission
limitations and operating limitations?
Notifications, Reports, and Records
j.
§ 63.6650 What reports must I submit and when?
k.
§ 63.6655 What records must I keep?
l.
§ 63.6660 In what form and how long must I keep my records?
Other Requirements and Information
m. § 63.6665 What parts of the General Provisions apply to me?
n.
§ 63.6670 Who implements and enforces this subpart?
o.
§ 63.6675 What definitions apply to this subpart?
9.
The permittee shall comply with the Standards of Performance for Equipment Leaks of VOC
from Onshore Natural Gas Processing Plants, NSPS 40 CFR Part 60, Subpart KKK
including, but not limited to, the following:
[40 CFR §60.630 to §60.636]
a.
b.
c.
d.
Information and data used to demonstrate that a reciprocating compressor is in wet gas
service to apply for the exemption in §60.633(f) shall be recorded in a log that is kept in
a readily accessible location as per §60.635(c).
Information and data used to demonstrate that a reciprocating compressor is not in VOC
service shall be recorded in a log that is kept in a readily accessible location as per
§60.486(j).
C-19, C-24, and C-25 shall be equipped with a VOC leakage capture system operated
and maintained in proper working order per §60.482-3 (h).
As an alternative to iii above, for each compressor subject to the control standards of
40 CFR §§60.482-3(a) thru (h), the permittee may choose to apply the exemption of 40
CFR §60.482-3(i) (no detectable emissions, as indicated by an instrument reading of
less than 500 ppm above background) by monitoring the compressor initially,
annually, and at any other time requested by AQD. The permittee shall keep records as
DRAFT/PROPOSED
SPECIFIC CONDITIONS 2011-227-TVR2
5
required by 40 CFR §60.486(e) (1) and (2).
10.
While in service the engines for generators G-1, G-2, G-3, G-4, and G-5 are each limited to
an output of less than 500-hp. The permittee shall demonstrate compliance by limiting the
power output from each generator to no more than 330-KW based on the average KW
generated for the hours that each generator operates during a calendar month. Once each
day, the permittee shall record the KW output from each generator during normal operation.
EUG 3. Tanks
11.
Total throughput is limited as follows:
EU
TK-1
Content
Condensate / BS&W
[OAC 252:100-8-6(a)(1)]
Throughput, gallons per day
19,000
12. The throughput limit shall be based on a daily average calculated by dividing a rolling 12month total by 365 days.
13.
Emissions from TK-1 shall be vented to the plant process/emergency flare.
14.
Emissions from the tanks listed below are considered insignificant because emissions are
less than 5 TPY; therefore, these units do not have any specific emission limitations.
EU
TK-2
TK-3
TK-4
TK-5
TK-6
TK-7
TK-8
15.
Contents
Scrubber Oil, North
Scrubber Oil, South
BS&W / Condensate
Methanol
Methanol
Gasoline
Solvent < 1.5 psia vapor pressure
Gallons
23,200
22,000
4,200
8,820
1,730
3,000
580
Tanks TK-4, TK-5, TK-6, and TK-7 shall be equipped with a submerged fill pipe.
[OAC 252:100-37-15(b)]
EUG-4. Fugitive Components (Not subject to NSPS Subpart KKK or MACT Subpart HH)
16.
No emission limits are applied to this EUG under Title V, but emissions are limited to the
existing equipment as it is.
EU
FUG-1
Type of Equipment
Connectors
Valves
Open Ended Lines
Estimated Number of
Items
7,000
3,500
280
SPECIFIC CONDITIONS 2011-227-TVR2
DRAFT/PROPOSED
Flanges
Compressor Seals
Pump Seals
Relief Valves
*
6
4,378
56
113
38
Estimated only, not a permit limit.
EUG-5. Fugitive Components (Subject to NSPS Subpart KKK)
17.
No emission limits are applied to this EUG under Title V, but emissions are limited to the
existing equipment as it is.
EU
Type of Equipment
Connectors
Valves
Open Ended Lines
Flanges
Compressor Seals
Pump Seals
Relief Valves
FUG-2
*
18.
Estimated Number of
Items
6,522
3,091
282
4,006
5
28
5
Estimated only, not a permit limit.
New, modified or reconstructed Process Units at the Maysville Gas Plant are subject to NSPS
40 CFR Part 60, Subpart KKK. These include, but are not limited to, the two liquids
extraction units (Plant 3 cryo and South Refrigeration System), four inlet headers (Inlet Gas
South Low and High, Anadarko Inlet, and Waukesha Inlet), the glycol dehydration unit (TEG
System), the demethanizer system, Plant 3 regeneration system, the two amine units that are
in VOC service (DGA North Amine Treater and DEA South Amine Treater), compressors C19, C-24 and C-25, and the WOK 16” inlet and condensate handling process. The permittee
shall comply with this subpart including, but not limited to, the following requirements:
[40 CFR 60.630-636]
a.
b.
c.
d.
e.
§60.632: Standards.
§60.635: Recordkeeping requirements.
§60.636: Reporting requirements.
Information and data used to demonstrate that ancillary equipment is not in VOC
service shall be recorded in a log that is kept in a readily accessible location as per
§60.486(j).
Any new construction, reconstruction or modification will be subject to 40 CFR Part
60, Subpart KKK for affected components in VOC service.
EUG 6. Heaters & Boilers
19.
No emission limits are applied to the grandfathered heater H-2 under Title V, but emissions
are limited to the existing equipment as it is. Emissions from heater H-1 are limited as
DRAFT/PROPOSED
SPECIFIC CONDITIONS 2011-227-TVR2
7
follows.
EU
H-1
H-2
NOX
lb/hr TPY
4.98
21.8
-
Equipment
Hot Oil Heater (West)
Hot Oil Heater (East)
CO
lb/hr
TPY
4.18
18.3
-
VOC
lb/hr TPY
0.28
1.2
-
20.
Compliance with the emissions limits for H-1 is demonstrated by the heater’s design heat
input rating of 50 MMBtu/hr and by firing natural gas.
[OAC 252:100-43]
21.
Heater H-1 is subject to NSPS Subpart Dc, but must comply only with the initial
notification requirements of 40 CFR §60.48c (a)(1) and the recordkeeping requirements of
40 CFR §60.48c (g).
[40 CFR Part 60 Subpart Dc]
22.
Emissions from the units listed below are considered insignificant because emissions are
less than 5 TPY; therefore, these units do not have any specific emission limitations.
EU
H-3
H-4
H-5
H-6
H-7
B-1
B-2
23.
Equipment
Regen. Gas Heater (Plant #1)
Regen. Gas Heater (Plant #2)
Glycol Reboiler
Amine Reboiler
Regen. Gas Heater (Plant #3)
Boiler #1 (North, OK36454)
Boiler #2 (South, OK43476)
MMBtu/hr
5.0
1.5
2.5
6.0
7.5
2.0
2.0
Serial #
75122
41593
0132
5991
1276
1740
9777
The heaters and boilers in EUG6 are subject to 40 CFR 63, Subpart DDDDD. The affected
source under Subpart DDDDD is the collection of all existing industrial, commercial and
institutional boilers and process heaters within a subcategory as defined in §63.7575. All
heaters and boilers in EUG6 are existing units in the subcategory designed to burn gas 1
fuel. As such the affected units in EUG6 will be subject only to the work practice standards
in Table 3 of Subpart DDDDD and other applicable monitoring recordkeeping, and
reporting requirements.
EUG-7. Process/Emergency Flare
24.
25.
No emission limits are applied to this unit under Title V, but emissions are limited to the
existing equipment as it is.
EU
MMBtu/hr
PFL-1
27,000
Diameter,
inches
24
Height,
feet
110
The process/emergency flare is subject to 40 CFR §60.18 General Control Requirements
and the permittee shall comply with all requirements, including, but not limited to, the
SPECIFIC CONDITIONS 2011-227-TVR2
DRAFT/PROPOSED
following:
a.
b.
8
[40 CFR §60.18]
The flare shall be operated at all times when emissions may be vented to it.
The presence of a pilot flame shall be monitored using a thermocouple or any other
equivalent device to detect the presence of a flame.
EUG-8. Acid Gas Flare
26.
Emissions are limited as follows:
EUG-8
Acid Gas Flare
Unit
lb/hr
TPY
NOX
0.10
0.45
CO
0.56
2.45
VOC
1.70
7.45
SO2
12.8
55.9
H2 S
0.14
0.61
27.
Emissions of NOX, CO, and VOC are limited by the Acid Gas Flare’s design heat rating of
1.5 MMBtu/hr.
[OAC 252:100-43]
28.
H2S concentration and/or the flow rate of the plant inlet gas streams or the acid gas
stream(s) shall be limited to ensure that the emission limits for SO2 are not exceeded.
[OAC 252:100-31-7 (a) and (b)]
a.
b.
29.
The daily sulfur feed rate from the north amine unit and the south amine unit (i.e., the
H2S in the acid gas), expressed as sulfur, shall be no more than 0.071 LT/D. H2S
concentration and/or the flow rate of the plant inlet gas streams or the acid gas stream(s)
shall be limited to ensure compliance with this daily sulfur feed rate limit. The daily
rate shall be calculated based on daily gas flow rate(s) and a quarterly measured H2S
concentration. Flow and H2S concentration shall be measured at one of the following
locations: (1) plant inlet gas streams, or (2) total acid gas stream prior to the acid gas
flare.
Compliance with the annual emission limits of SO2 shall be based on a 12-month
rolling total. The permittee shall calculate the total SO2 emissions from the acid gas
flare stack based on 98% conversion of H2S. The calculations shall be based on a
quarterly tested H2S concentration and the daily average gas flow rate for that month
measured at one of the following locations: (1) plant inlet gas streams, or (2) total acid
gas stream prior to the acid gas flare. These calculations will be submitted with the
semiannual monitoring and deviation report.
The flare shall have installed, calibrated, maintained, and operated an alarm system that
will signal non-combustion of the gas.
[OAC 252:100-31-26(c)]
EUG-9. VOC Flare
30.
Emissions are limited as follows:
SPECIFIC CONDITIONS 2011-227-TVR2
EUG-9
VOC Flare
Unit
lb/hr
TPY
DRAFT/PROPOSED
NOX
2.7
12
CO
15
66
9
VOC
2.5
11
31.
Emissions of NOX, CO, and VOC are limited by the flare’s design heat rating of 40
MMBtu/hr.
[OAC 252:100-43]
32.
The VOC flare is subject to 40 CFR §60.18 General Control Requirements and the
permittee shall comply with all requirements, including, but not limited to, the following:
[40 CFR §60.18]
a.
b.
The flare shall be operated at all times when emissions may be vented to it.
The presence of a pilot flame shall be monitored using a thermocouple or any other
equivalent device to detect the presence of a flame.
EUG-10. Glycol Dehydration Unit
33.
The dehydration unit shall be operated in such a way that benzene emissions are less than
1.0 tpy.
34.
Vapors from the rich glycol flash tank shall be vented to the plant inlet gas stream.
35.
The glycol dehydration unit in EUG-10 shall be equipped with a condenser and
uncondensed regenerator vent vapors shall be routed either to the plant inlet gas stream or
to the process/emergency flare for combustion. The unit is subject to NESHAP Subpart
HH and must meet the compliance, reporting, and recordkeeping requirements of Subpart
HH. [40 CFR §63 Subpart HH]
36.
The permittee shall determine actual average benzene emissions using the model GRIGLYCalc™ Version 3.0 or higher, as required by MACT Subpart HH. Inputs to the model
shall be representative of actual operating conditions. The permittee shall also maintain
records as required by MACT Subpart HH to document compliance with the benzene limit.
37.
The glycol dehydrator is subject to NESHAP, 40 CFR Part 63, Subpart HH and all affected
equipment shall comply with all applicable requirements.
[40 CFR 63, NESHAP, Subpart HH]
a.
§ 63.760 Applicability and designation of affected source.
b. § 63.761 Definitions.
c.
§ 63.762 Startups, shutdowns, and malfunctions.
d. § 63.764 General standards.
e.
§ 63.765 Glycol dehydration unit process vent standards.
f.
§ 63.766 Storage vessel standards.
g.
§ 63.769 Equipment leak standards.
h. § 63.771 Control equipment requirements.
i.
§ 63.772 Test methods, compliance procedures, and compliance determinations.
SPECIFIC CONDITIONS 2011-227-TVR2
j.
k.
l.
m.
n.
DRAFT/PROPOSED
10
§ 63.773 Inspection and monitoring requirements.
§ 63.774 Recordkeeping requirements.
§ 63.775 Reporting requirements.
§ 63.776 Delegation of authority.
§ 63.777 Alternative means of emission limitation.
EUG-11. Condensate/Scrubber Oil Truck Loading
38.
Emissions and throughput are limited as follows.
ID #
TL-1
39.
Throughput
VOC
bbl/yr
164,363
TPY
17.7
The throughput limit is based on a 12-month rolling total. Compliance with the throughput
limit demonstrates compliance with the emissions limit.
EUG-12. Fugitive Components (subject to NESHAP Subpart HH)
40.
No emission limits are applied to this EUG under Title V, but emissions are limited to the
existing equipment as it is.
EU
Type of Equipment
FUG-1
Connectors
Valves
Pressure Relief Valves
Pump Seals
*
Number of
Components *
2,197
950
38
9
Estimated only, not a permit limit.
EUG 13. Miscellaneous Process Vent
41.
VOC emissions are estimated based on existing equipment items but do not have a specific
limitation.
EU ID #
VENT
Point #
VENT
Emission Units
Miscellaneous Process Vents
Date Constructed
1948
EUG 14. WOK Condensate Tanks
42.
Total throughput is limited as follows:
[OAC 252:100-8-6(a)(1)]
SPECIFIC CONDITIONS 2011-227-TVR2
43.
EU
Content
TK-9, TK-10, TK-11, TK-12
Condensate
EU
Content
TK-9, TK-10, TK-11, TK-12
Condensate
DRAFT/PROPOSED
Throughput during normal
operation, gallons per yr
1,533,000
Throughput during VRU
downtime, gallons per yr
17,500
Condensate tanks shall have the following operating conditions:
a.
b.
c.
11
[OAC 252:100-37-15(b)]
The throughput limits shall be based on a rolling 12-month total.
Emissions from EUG-14 shall be vented to a closed vapor recovery system with
100% efficiency, except during VRU downtime.
Tanks in EUG-14 shall be equipped with a submerged fill pipe.
EUG-15. WOK Condensate Truck Loading from EUG-14
44.
Emissions and throughput are limited as follows.
EU
TL-2
45.
Throughput
VOC
gal/yr
1,533,000
TPY
6.76
The throughput limit is based on a 12-month rolling total. Compliance with the throughput
limit demonstrates compliance with the emissions limit.
Facility-Wide General Specific Conditons
46.
The fuel-burning equipment shall be fired with pipeline grade natural gas or other gaseous
fuel with a sulfur content less than 343 ppmv. Compliance can be shown by the following
methods: for gaseous fuel, a current gas company bill, a current lab analysis, stain-tube
analysis, gas contract, tariff sheet, or other approved methods. Compliance shall be
demonstrated at least once annually.
47.
The permittee shall be authorized to operate this facility continuously (24 hours per day, every
day of the year).
[OAC 252:100-8-6(a)]
48.
Fugitive components:
a.
The fugitive components of EUG 12 and the glycol dehydrator of EUG 10 are subject
to CFR 40 Part 63, Subpart HH provided that they are affected components in VHAP
service (defined as HAP content greater than 10% by weight) and shall comply with
all applicable requirements including, but not limited to, the following.
[40 CFR §63.760 to §63.779]
SPECIFIC CONDITIONS 2011-227-TVR2
i.
ii.
iii.
iv.
v.
vi.
vii.
viii.
ix.
x.
DRAFT/PROPOSED
12
40 CFR 63.762: Startup, shutdowns, and malfunctions.
40 CFR 63.764: General standards.
40 CFR 63.765: Glycol dehydration unit process vents standards. Emissions
from the rich glycol flash tank and the glycol regenerator still vent are subject to
Subpart HH, but are exempt from the standards per §63.764(e)(1)(ii). The
permittee shall maintain records per §63.774(d)(1) demonstrating that actual
benzene emissions are below 0.90 megagram (1.0 TPY) using the methods
outlined in §63.772(b)(2).
40 CFR 63.766: Storage vessel standards. Tank TK-1 is not an affected source
since it has a federally enforceable throughput limit of 19,000 gallons per day
based on a daily average.
40 CFR 63.769: Equipment leak standards. All components in vapor service
and light liquid service are below the 10% by weight threshold except those
components in natural gasoline service, condensate service, and the engine
jacket water systems, which use ethylene glycol. Documentation of those
components exempt from the standards must be made per §63.764(e)(2) and
records kept per §63.774(d)(1).
40 CFR 63.772: Test methods, compliance procedures, and compliance
demonstrations.
40 CFR 63.774: Recordkeeping requirements.
40 CFR 63.775: Reporting requirements.
40 CFR 63.776: Delegation of authority.
40 CFR 63.777: Alternate means of emission limitation.
49.
Quarterly visual inspections of equipment in ethylene glycol VHAP service may be used as
a monitoring alternative to Method 21. [40 CFR §63.8(b)(ii)]
50.
Ancillary equipment and compressors that are subject to this subpart (40 CFR Part 63,
Subpart HH) and are also subject to 40 CFR Part 60, Subpart KKK, are only required to
comply with the requirements of 40 CFR Part 60, Subpart KKK as an approved monitoring
alternative. The permittee shall document that they are complying with 40 CFR Part 60,
Subpart KKK by keeping the records specified in 40 CFR 63.774(b)(9).
51.
The north (DGA) and south (DEA) amine units are subject to 40 CFR Part 60, Subpart
LLL, but are exempt from any control standards. The permittee shall comply with §60.647
(c), which requires the facility to keep, for the life of the facility, an analysis demonstrating
that the facility’s design capacity is less than 2 long tons per day (LT/D) of H2S in the acid gas
(expressed as sulfur).
[40 CFR §60.40 to §60.648]
52.
The following records shall be maintained on-site to verify Insignificant Activities. No
recordkeeping is required for those operations that qualify as Trivial Activities.
[OAC 252:100-8-6 (a)(3)(B)]
a.
For emissions from condensate tanks with a design capacity of 400 gallons or less in
SPECIFIC CONDITIONS 2011-227-TVR2
b.
c.
53.
DRAFT/PROPOSED
13
ozone attainment areas: the tank capacity and contents.
For surface coating operations which do not exceed a combined total usage of more
than 60 gallons/month of coatings, thinners, and clean-up solvents at any one
emissions unit: the total gallons used (monthly).
For activities having the potential to emit no more than 5 TPY (actual) of any criteria
pollutant: the type of activity and the amount of emissions from that activity (annual).
The permittee shall maintain records of operations as listed below. These records shall be
maintained on-site for at least five years after the date of recording and shall be provided to
regulatory personnel upon request.
[OAC 252:100-43]
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
n.
o.
For the fuel burned, the appropriate document(s) as described in Specific Condition No.
2.
O&M records for each “grandfathered” engine in EUG-1.
O&M records for any engine in EUG-2, if operated less than 220 hours per quarter
and not tested.
Periodic testing for NOX and CO for each engine in EUG-2.
Monthly records of the average KW output from generators G-1, G-2, G-3, G-4, and
G-5.
Records required by 40 CFR §60.647 (c) demonstrating that both the north (DGA) and
south (DEA) amine units have a design capacity less than 2 long tons per day (LT/D) of
H2S in the acid gas (expressed as sulfur).
Throughput of tank TK-1 (rolling 12-month total).
Throughput of EUG-14 condensate tanks for normal operation and for VRU
downtime (rolling 12-month total).
Records of quarterly tested H2S concentration and the daily average gas flow rate(s)
measured at one of the following locations: (1) plant inlet gas streams, or (2) total acid
gas stream prior to the acid gas flare. And calculations of SO2 emissions from the acid
gas flare (12-month rolling total).
Records required by 40 CFR §60, Subpart KKK.
Records required by 40 CFR §60, Subpart JJJJ.
Records required by 40 CFR §63, Subpart HH.
Records required by 40 CFR §63, Subpart ZZZZ.
Records required by 40 CFR §64, CAM.
Records required by 40 CFR §60, Subpart OOOO.
54.
No later than 30 days after each anniversary date of the issuance of the original Part 70
permit (December 8, 1999), the permittee shall submit to Air Quality Division of DEQ,
with a copy to the US EPA, Region 6, a certification of compliance with the terms and
conditions of this permit. For this permit, the semiannual reporting periods are defined as
May 30 through November 29 and November 30 through May 29.
[OAC 252:100-8-6 (c)(5)(A), (C) & (D)]
55.
This permit supersedes all previous air quality operating permits for this facility, which are
now null and void.
MAJOR SOURCE AIR QUALITY PERMIT
STANDARD CONDITIONS
(July 21, 2009)
SECTION I.
DUTY TO COMPLY
A. This is a permit to operate / construct this specific facility in accordance with the federal
Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act
and the rules promulgated there under.
[Oklahoma Clean Air Act, 27A O.S. § 2-5-112]
B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma
Department of Environmental Quality (DEQ). The permit does not relieve the holder of the
obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or
ordinances.
[Oklahoma Clean Air Act, 27A O.S. § 2-5-112]
C. The permittee shall comply with all conditions of this permit. Any permit noncompliance
shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement
action, permit termination, revocation and reissuance, or modification, or for denial of a permit
renewal application. All terms and conditions are enforceable by the DEQ, by the Environmental
Protection Agency (EPA), and by citizens under section 304 of the Federal Clean Air Act
(excluding state-only requirements). This permit is valid for operations only at the specific
location listed.
[40 C.F.R. §70.6(b), OAC 252:100-8-1.3 and OAC 252:100-8-6(a)(7)(A) and (b)(1)]
D. It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of the permit. However, nothing in this paragraph shall be construed as precluding
consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for
noncompliance if the health, safety, or environmental impacts of halting or reducing operations
would be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)]
SECTION II.
REPORTING OF DEVIATIONS FROM PERMIT TERMS
A. Any exceedance resulting from an emergency and/or posing an imminent and substantial
danger to public health, safety, or the environment shall be reported in accordance with Section
XIV (Emergencies).
[OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]
B. Deviations that result in emissions exceeding those allowed in this permit shall be reported
consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.
[OAC 252:100-8-6(a)(3)(C)(iv)]
C. Every written report submitted under this section shall be certified as required by Section III
(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.
[OAC 252:100-8-6(a)(3)(C)(iv)]
TITLE V PERMIT STANDARD CONDITIONS
SECTION III.
July 21, 2009
2
MONITORING, TESTING, RECORDKEEPING & REPORTING
A. The permittee shall keep records as specified in this permit. These records, including
monitoring data and necessary support information, shall be retained on-site or at a nearby field
office for a period of at least five years from the date of the monitoring sample, measurement,
report, or application, and shall be made available for inspection by regulatory personnel upon
request. Support information includes all original strip-chart recordings for continuous
monitoring instrumentation, and copies of all reports required by this permit. Where appropriate,
the permit may specify that records may be maintained in computerized form.
[OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:100-8-6(c)(1), and OAC 252:100-8-6(c)(2)(B)]
B. Records of required monitoring shall include:
(1) the date, place and time of sampling or measurement;
(2) the date or dates analyses were performed;
(3) the company or entity which performed the analyses;
(4) the analytical techniques or methods used;
(5) the results of such analyses; and
(6) the operating conditions existing at the time of sampling or measurement.
[OAC 252:100-8-6(a)(3)(B)(i)]
C. No later than 30 days after each six (6) month period, after the date of the issuance of the
original Part 70 operating permit or alternative date as specifically identified in a subsequent Part
70 operating permit, the permittee shall submit to AQD a report of the results of any required
monitoring. All instances of deviations from permit requirements since the previous report shall
be clearly identified in the report. Submission of these periodic reports will satisfy any reporting
requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the
submitted report.
[OAC 252:100-8-6(a)(3)(C)(i) and (ii)]
D. If any testing shows emissions in excess of limitations specified in this permit, the owner or
operator shall comply with the provisions of Section II (Reporting Of Deviations From Permit
Terms) of these standard conditions.
[OAC 252:100-8-6(a)(3)(C)(iii)]
E. In addition to any monitoring, recordkeeping or reporting requirement specified in this
permit, monitoring and reporting may be required under the provisions of OAC 252:100-43,
Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean
Air Act or Oklahoma Clean Air Act.
[OAC 252:100-43]
F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report,
Excess Emission Report, and Annual Emission Inventory submitted in accordance with this
permit shall be certified by a responsible official. This certification shall be signed by a
responsible official, and shall contain the following language: “I certify, based on information
and belief formed after reasonable inquiry, the statements and information in the document are
true, accurate, and complete.”
[OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC
TITLE V PERMIT STANDARD CONDITIONS
July 21, 2009
3
252:100-9-7(e), and OAC 252:100-5-2.1(f)]
G. Any owner or operator subject to the provisions of New Source Performance Standards
(“NSPS”) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants
(“NESHAPs”) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other
information required by the applicable general provisions and subpart(s). These records shall be
maintained in a permanent file suitable for inspection, shall be retained for a period of at least
five years as required by Paragraph A of this Section, and shall include records of the occurrence
and duration of any start-up, shutdown, or malfunction in the operation of an affected facility,
any malfunction of the air pollution control equipment; and any periods during which a
continuous monitoring system or monitoring device is inoperative.
[40 C.F.R. §§60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q]
H. The permittee of a facility that is operating subject to a schedule of compliance shall submit
to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for
achieving the activities, milestones or compliance required in the schedule of compliance and the
dates when such activities, milestones or compliance was achieved. The progress reports shall
also contain an explanation of why any dates in the schedule of compliance were not or will not
be met, and any preventive or corrective measures adopted.
[OAC 252:100-8-6(c)(4)]
I. All testing must be conducted under the direction of qualified personnel by methods
approved by the Division Director. All tests shall be made and the results calculated in
accordance with standard test procedures. The use of alternative test procedures must be
approved by EPA. When a portable analyzer is used to measure emissions it shall be setup,
calibrated, and operated in accordance with the manufacturer’s instructions and in accordance
with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document
or an equivalent method approved by Air Quality.
[OAC 252:100-8-6(a)(3)(A)(iv), and OAC 252:100-43]
J. The reporting of total particulate matter emissions as required in Part 7 of OAC 252:100-8
(Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and
OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing
or calculation procedures, modified to include back-half condensables, for the concentration of
particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of only
particulate matter emissions caught in the filter (obtained using Reference Method 5).
K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required
by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit
subject to such standards.
[OAC 252:100-8-6(c)(1) and OAC 252:100, Appendix Q]
SECTION IV.
COMPLIANCE CERTIFICATIONS
A. No later than 30 days after each anniversary date of the issuance of the original Part 70
operating permit or alternative date as specifically identified in a subsequent Part 70 operating
permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a
certification of compliance with the terms and conditions of this permit and of any other
TITLE V PERMIT STANDARD CONDITIONS
July 21, 2009
4
applicable requirements which have become effective since the issuance of this permit.
[OAC 252:100-8-6(c)(5)(A), and (D)]
B. The compliance certification shall describe the operating permit term or condition that is the
basis of the certification; the current compliance status; whether compliance was continuous or
intermittent; the methods used for determining compliance, currently and over the reporting
period. The compliance certification shall also include such other facts as the permitting
authority may require to determine the compliance status of the source.
[OAC 252:100-8-6(c)(5)(C)(i)-(v)]
C. The compliance certification shall contain a certification by a responsible official as to the
results of the required monitoring. This certification shall be signed by a responsible official, and
shall contain the following language: “I certify, based on information and belief formed after
reasonable inquiry, the statements and information in the document are true, accurate, and
complete.”
[OAC 252:100-8-5(f) and OAC 252:100-8-6(c)(1)]
D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions
units or stationary sources that are not in compliance with all applicable requirements. This
schedule shall include a schedule of remedial measures, including an enforceable sequence of
actions with milestones, leading to compliance with any applicable requirements for which the
emissions unit or stationary source is in noncompliance. This compliance schedule shall
resemble and be at least as stringent as that contained in any judicial consent decree or
administrative order to which the emissions unit or stationary source is subject. Any such
schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the
applicable requirements on which it is based, except that a compliance plan shall not be required
for any noncompliance condition which is corrected within 24 hours of discovery.
[OAC 252:100-8-5(e)(8)(B) and OAC 252:100-8-6(c)(3)]
SECTION V.
REQUIREMENTS THAT BECOME APPLICABLE DURING THE
PERMIT TERM
The permittee shall comply with any additional requirements that become effective during the
permit term and that are applicable to the facility. Compliance with all new requirements shall
be certified in the next annual certification.
[OAC 252:100-8-6(c)(6)]
SECTION VI.
PERMIT SHIELD
A. Compliance with the terms and conditions of this permit (including terms and conditions
established for alternate operating scenarios, emissions trading, and emissions averaging, but
excluding terms and conditions for which the permit shield is expressly prohibited under OAC
252:100-8) shall be deemed compliance with the applicable requirements identified and included
in this permit.
[OAC 252:100-8-6(d)(1)]
B. Those requirements that are applicable are listed in the Standard Conditions and the Specific
Conditions of this permit. Those requirements that the applicant requested be determined as not
TITLE V PERMIT STANDARD CONDITIONS
July 21, 2009
applicable are summarized in the Specific Conditions of this permit.
SECTION VII.
5
[OAC 252:100-8-6(d)(2)]
ANNUAL EMISSIONS INVENTORY & FEE PAYMENT
The permittee shall file with the AQD an annual emission inventory and shall pay annual fees
based on emissions inventories. The methods used to calculate emissions for inventory purposes
shall be based on the best available information accepted by AQD.
[OAC 252:100-5-2.1, OAC 252:100-5-2.2, and OAC 252:100-8-6(a)(8)]
SECTION VIII.
TERM OF PERMIT
A. Unless specified otherwise, the term of an operating permit shall be five years from the date
of issuance.
[OAC 252:100-8-6(a)(2)(A)]
B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely
and complete renewal application has been submitted at least 180 days before the date of
expiration.
[OAC 252:100-8-7.1(d)(1)]
C. A duly issued construction permit or authorization to construct or modify will terminate and
become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction
is not commenced within 18 months after the date the permit or authorization was issued, or if
work is suspended for more than 18 months after it is commenced.
[OAC 252:100-8-1.4(a)]
D. The recipient of a construction permit shall apply for a permit to operate (or modified
operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]
SECTION IX.
SEVERABILITY
The provisions of this permit are severable and if any provision of this permit, or the application
of any provision of this permit to any circumstance, is held invalid, the application of such
provision to other circumstances, and the remainder of this permit, shall not be affected thereby.
[OAC 252:100-8-6 (a)(6)]
SECTION X.
PROPERTY RIGHTS
A. This permit does not convey any property rights of any sort, or any exclusive privilege.
[OAC 252:100-8-6(a)(7)(D)]
B. This permit shall not be considered in any manner affecting the title of the premises upon
which the equipment is located and does not release the permittee from any liability for damage
to persons or property caused by or resulting from the maintenance or operation of the equipment
for which the permit is issued.
[OAC 252:100-8-6(c)(6)]
TITLE V PERMIT STANDARD CONDITIONS
SECTION XI.
July 21, 2009
6
DUTY TO PROVIDE INFORMATION
A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty
(60) days of the request unless the DEQ specifies another time period, any information that the
DEQ may request to determine whether cause exists for modifying, reopening, revoking,
reissuing, terminating the permit or to determine compliance with the permit. Upon request, the
permittee shall also furnish to the DEQ copies of records required to be kept by the permit.
[OAC 252:100-8-6(a)(7)(E)]
B. The permittee may make a claim of confidentiality for any information or records submitted
pursuant to 27A O.S. § 2-5-105(18). Confidential information shall be clearly labeled as such
and shall be separable from the main body of the document such as in an attachment.
[OAC 252:100-8-6(a)(7)(E)]
C. Notification to the AQD of the sale or transfer of ownership of this facility is required and
shall be made in writing within thirty (30) days after such sale or transfer.
[Oklahoma Clean Air Act, 27A O.S. § 2-5-112(G)]
SECTION XII.
REOPENING, MODIFICATION & REVOCATION
A. The permit may be modified, revoked, reopened and reissued, or terminated for cause.
Except as provided for minor permit modifications, the filing of a request by the permittee for a
permit modification, revocation and reissuance, termination, notification of planned changes, or
anticipated noncompliance does not stay any permit condition.
[OAC 252:100-8-6(a)(7)(C) and OAC 252:100-8-7.2(b)]
B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the
following circumstances:
[OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]
(1) Additional requirements under the Clean Air Act become applicable to a major source
category three or more years prior to the expiration date of this permit. No such
reopening is required if the effective date of the requirement is later than the expiration
date of this permit.
(2) The DEQ or the EPA determines that this permit contains a material mistake or that the
permit must be revised or revoked to assure compliance with the applicable requirements.
(3) The DEQ or the EPA determines that inaccurate information was used in establishing the
emission standards, limitations, or other conditions of this permit. The DEQ may revoke
and not reissue this permit if it determines that the permittee has submitted false or
misleading information to the DEQ.
(4) DEQ determines that the permit should be amended under the discretionary reopening
provisions of OAC 252:100-8-7.3(b).
C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-87.3(d).
[OAC 100-8-7.3(d)]
TITLE V PERMIT STANDARD CONDITIONS
July 21, 2009
7
D. The permittee shall notify AQD before making changes other than those described in Section
XVIII (Operational Flexibility), those qualifying for administrative permit amendments, or those
defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The
notification should include any changes which may alter the status of a “grandfathered source,”
as defined under AQD rules. Such changes may require a permit modification.
[OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]
E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that
are not specifically approved by this permit are prohibited.
[OAC 252:100-8-6(c)(6)]
SECTION XIII.
INSPECTION & ENTRY
A. Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow authorized regulatory officials to perform the following (subject to the
permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18)
for confidential information submitted to or obtained by the DEQ under this section):
(1) enter upon the permittee's premises during reasonable/normal working hours where a
source is located or emissions-related activity is conducted, or where records must be
kept under the conditions of the permit;
(2) have access to and copy, at reasonable times, any records that must be kept under the
conditions of the permit;
(3) inspect, at reasonable times and using reasonable safety practices, any facilities,
equipment (including monitoring and air pollution control equipment), practices, or
operations regulated or required under the permit; and
(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times
substances or parameters for the purpose of assuring compliance with the permit.
[OAC 252:100-8-6(c)(2)]
SECTION XIV.
EMERGENCIES
A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later
than 4:30 p.m. on the next working day after the permittee first becomes aware of the
exceedance. This notice shall contain a description of the emergency, the probable cause of the
exceedance, any steps taken to mitigate emissions, and corrective actions taken.
[OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)]
B. Any exceedance that poses an imminent and substantial danger to public health, safety, or the
environment shall be reported to AQD as soon as is practicable; but under no circumstance shall
notification be more than 24 hours after the exceedance.
[OAC 252:100-8-6(a)(3)(C)(iii)(II)]
C. An "emergency" means any situation arising from sudden and reasonably unforeseeable
events beyond the control of the source, including acts of God, which situation requires
immediate corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
TITLE V PERMIT STANDARD CONDITIONS
July 21, 2009
8
emissions attributable to the emergency. An emergency shall not include noncompliance to the
extent caused by improperly designed equipment, lack of preventive maintenance, careless or
improper operation, or operator error.
[OAC 252:100-8-2]
D. The affirmative defense of emergency shall be demonstrated through properly signed,
contemporaneous operating logs or other relevant evidence that:
[OAC 252:100-8-6 (e)(2)]
(1) an emergency occurred and the permittee can identify the cause or causes of the
emergency;
(2) the permitted facility was at the time being properly operated;
(3) during the period of the emergency the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emission standards or other requirements in this
permit.
E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency shall have the burden of proof.
[OAC 252:100-8-6(e)(3)]
F. Every written report or document submitted under this section shall be certified as required
by Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.
[OAC 252:100-8-6(a)(3)(C)(iv)]
SECTION XV.
RISK MANAGEMENT PLAN
The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop
and register with the appropriate agency a risk management plan by June 20, 1999, or the
applicable effective date.
[OAC 252:100-8-6(a)(4)]
SECTION XVI.
INSIGNIFICANT ACTIVITIES
Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to
operate individual emissions units that are either on the list in Appendix I to OAC Title 252,
Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.
Any activity to which a State or Federal applicable requirement applies is not insignificant even
if it meets the criteria below or is included on the insignificant activities list.
(1) 5 tons per year of any one criteria pollutant.
(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an
aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year
for single HAP that the EPA may establish by rule.
[OAC 252:100-8-2 and OAC 252:100, Appendix I]
SECTION XVII.
TRIVIAL ACTIVITIES
Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to
operate any individual or combination of air emissions units that are considered inconsequential
and are on the list in Appendix J. Any activity to which a State or Federal applicable
TITLE V PERMIT STANDARD CONDITIONS
July 21, 2009
9
requirement applies is not trivial even if included on the trivial activities list.
[OAC 252:100-8-2 and OAC 252:100, Appendix J]
SECTION XVIII.
OPERATIONAL FLEXIBILITY
A. A facility may implement any operating scenario allowed for in its Part 70 permit without the
need for any permit revision or any notification to the DEQ (unless specified otherwise in the
permit). When an operating scenario is changed, the permittee shall record in a log at the facility
the scenario under which it is operating.
[OAC 252:100-8-6(a)(10) and (f)(1)]
B. The permittee may make changes within the facility that:
(1) result in no net emissions increases,
(2) are not modifications under any provision of Title I of the federal Clean Air Act, and
(3) do not cause any hourly or annual permitted emission rate of any existing emissions unit
to be exceeded;
provided that the facility provides the EPA and the DEQ with written notification as required
below in advance of the proposed changes, which shall be a minimum of seven (7) days, or
twenty four (24) hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the
DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such
change, the written notification required above shall include a brief description of the change
within the permitted facility, the date on which the change will occur, any change in emissions,
and any permit term or condition that is no longer applicable as a result of the change. The
permit shield provided by this permit does not apply to any change made pursuant to this
paragraph.
[OAC 252:100-8-6(f)(2)]
SECTION XIX.
OTHER APPLICABLE & STATE-ONLY REQUIREMENTS
A. The following applicable requirements and state-only requirements apply to the facility
unless elsewhere covered by a more restrictive requirement:
(1) Open burning of refuse and other combustible material is prohibited except as authorized
in the specific examples and under the conditions listed in the Open Burning Subchapter.
[OAC 252:100-13]
(2) No particulate emissions from any fuel-burning equipment with a rated heat input of 10
MMBTUH or less shall exceed 0.6 lb/MMBTU.
[OAC 252:100-19]
(3) For all emissions units not subject to an opacity limit promulgated under 40 C.F.R., Part
60, NSPS, no discharge of greater than 20% opacity is allowed except for:
[OAC 252:100-25]
(a) Short-term occurrences which consist of not more than one six-minute period in any
consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours.
In no case shall the average of any six-minute period exceed 60% opacity;
TITLE V PERMIT STANDARD CONDITIONS
July 21, 2009
10
(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7;
(c) An emission, where the presence of uncombined water is the only reason for failure to
meet the requirements of OAC 252:100-25-3(a); or
(d) Smoke generated due to a malfunction in a facility, when the source of the fuel
producing the smoke is not under the direct and immediate control of the facility and
the immediate constriction of the fuel flow at the facility would produce a hazard to
life and/or property.
(4) No visible fugitive dust emissions shall be discharged beyond the property line on which
the emissions originate in such a manner as to damage or to interfere with the use of
adjacent properties, or cause air quality standards to be exceeded, or interfere with the
maintenance of air quality standards.
[OAC 252:100-29]
(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2
lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur
dioxide.
[OAC 252:100-31]
(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and
with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or
greater under actual conditions shall be equipped with a permanent submerged fill pipe or
with a vapor-recovery system.
[OAC 252:100-37-15(b)]
(7) All fuel-burning equipment shall at all times be properly operated and maintained in a
manner that will minimize emissions of VOCs.
[OAC 252:100-37-36]
SECTION XX.
STRATOSPHERIC OZONE PROTECTION
A. The permittee shall comply with the following standards for production and consumption of
ozone-depleting substances:
[40 CFR 82, Subpart A]
(1) Persons producing, importing, or placing an order for production or importation of certain
class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the
requirements of §82.4;
(2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain
class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping
requirements at §82.13; and
(3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,
HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane
(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include
HCFCs.
B. If the permittee performs a service on motor (fleet) vehicles when this service involves an
ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air
conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term
“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the
TITLE V PERMIT STANDARD CONDITIONS
July 21, 2009
11
vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the
air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger
buses using HCFC-22 refrigerant.
[40 CFR 82, Subpart B]
C. The permittee shall comply with the following standards for recycling and emissions
reduction except as provided for MVACs in Subpart B:
[40 CFR 82, Subpart F]
(1) Persons opening appliances for maintenance, service, repair, or disposal must comply
with the required practices pursuant to § 82.156;
(2) Equipment used during the maintenance, service, repair, or disposal of appliances must
comply with the standards for recycling and recovery equipment pursuant to § 82.158;
(3) Persons performing maintenance, service, repair, or disposal of appliances must be
certified by an approved technician certification program pursuant to § 82.161;
(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply
with record-keeping requirements pursuant to § 82.166;
(5) Persons owning commercial or industrial process refrigeration equipment must comply
with leak repair requirements pursuant to § 82.158; and
(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant
must keep records of refrigerant purchased and added to such appliances pursuant to §
82.166.
SECTION XXI.
TITLE V APPROVAL LANGUAGE
A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is
not inconsistent with Federal requirements, to provide for incorporation of requirements
established through construction permitting into the Source’s Title V permit without causing
redundant review. Requirements from construction permits may be incorporated into the Title V
permit through the administrative amendment process set forth in OAC 252:100-8-7.2(a) only if
the following procedures are followed:
(1)
(2)
(3)
(4)
(5)
The construction permit goes out for a 30-day public notice and comment using the
procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to
the public that this permit is subject to EPA review, EPA objection, and petition to
EPA, as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit
will be incorporated into the Title V permit through the administrative amendment
process; that the public will not receive another opportunity to provide comments when
the requirements are incorporated into the Title V permit; and that EPA review, EPA
objection, and petitions to EPA will not be available to the public when requirements
from the construction permit are incorporated into the Title V permit.
A copy of the construction permit application is sent to EPA, as provided by 40 CFR §
70.8(a)(1).
A copy of the draft construction permit is sent to any affected State, as provided by 40
C.F.R. § 70.8(b).
A copy of the proposed construction permit is sent to EPA for a 45-day review period
as provided by 40 C.F.R.§ 70.8(a) and (c).
The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day
TITLE V PERMIT STANDARD CONDITIONS
July 21, 2009
12
comment period of any EPA objection to the construction permit. The DEQ shall not
issue the permit until EPA’s objections are resolved to the satisfaction of EPA.
(6) The DEQ complies with 40 C.F.R. § 70.8(d).
(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).
(8) The DEQ shall not issue the proposed construction permit until any affected State and
EPA have had an opportunity to review the proposed permit, as provided by these
permit conditions.
(9) Any requirements of the construction permit may be reopened for cause after
incorporation into the Title V permit by the administrative amendment process, by DEQ
as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40
C.F.R. § 70.7(f) and (g).
(10) The DEQ shall not issue the administrative permit amendment if performance tests fail
to demonstrate that the source is operating in substantial compliance with all permit
requirements.
B. To the extent that these conditions are not followed, the Title V permit must go through the
Title V review process.
SECTION XXII.
CREDIBLE EVIDENCE
For the purpose of submitting compliance certifications or establishing whether or not a person
has violated or is in violation of any provision of the Oklahoma implementation plan, nothing
shall preclude the use, including the exclusive use, of any credible evidence or information,
relevant to whether a source would have been in compliance with applicable requirements if the
appropriate performance or compliance test or procedure had been performed.
[OAC 252:100-43-6]
DRAFT/PROPOSED
ONEOK Field Services Company, L.L.C.
Ms. Deborah Perry
Senior Environmental Engineer
100 West Fifth Street
P.O. Box 871
Tulsa, OK 74102-0871
SUBJECT:
Facility: Maysville Gas Plant
Location: Garvin County
Permit No. 2011-227-TVR2
Date Received: April 25, 2011
Dear Ms. Perry:
Air Quality Division has completed the initial review of your permit application referenced above. This
application has been determined to be a Tier II. In accordance with 27A O.S. § 2-14-302 and OAC
252:002-4-7-13(c) the enclosed draft permit is now ready for public review. The requirements for public
review include the following steps which you must accomplish:
1. Publish at least one legal notice (one day) in at least one newspaper of general circulation within the
county where the facility is located. (Instructions enclosed)
2. Provide for public review (for a period of 30 days following the date of the newspaper announcement)
a copy of this draft permit and a copy of the application at a convenient public location within the county
of the facility such as the public library in the county seat.
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 or the permit writer at (405) 702-4100.
Sincerely,
Phillip Fielder, P.E.
Permits and Engineering Group Manager
AIR QUALITY DIVISION
DRAFT/PROPOSED
NOTICE OF DRAFT PERMIT
TIER II or TIER III AIR QUALITY PERMIT APPLICATION
APPLICANT RESPONSIBILITIES
Permit applicants are required to give public notice that a Tier II or Tier III draft permit has been
prepared by DEQ. The notice must be published in one newspaper local to the site or facility. Upon
publication, a signed affidavit of publication must be obtained from the newspaper and sent to AQD.
Note that if a public meeting is requested by either the applicant or the public, this must be arranged
through the Customer Services Division of the DEQ.
REQUIRED CONTENT (27A O.S. § 2-14-302 and OAC 252:4-7-13(c))
1.
2.
3.
4.
5.
6.
A statement that a Tier II or Tier III draft permit has been prepared by DEQ;
Name and address of the applicant;
Name, address, driving directions, legal description and county of the site or facility;
The type of permit or permit action being sought;
A description of activities to be regulated, including an estimate of emissions from the facility;
Location(s) where the application and draft permit may be reviewed (a location in the county
where the site/facility is located must be included);
7. Name, address, and telephone number of the applicant and DEQ contacts;
8. Any additional information required by DEQ rules or deemed relevant by applicant;
9. A 30-day opportunity to request a formal public meeting on the draft permit.
SAMPLE NOTICE on page 2.
DEQ FORM # 100-822
REVISED NOVEMBER 4, 2004
DRAFT/PROPOSED
SAMPLE NOTICE (Italicized print is to be filled in by the applicant.):
DEQ NOTICE OF TIER …II or III… DRAFT PERMIT
A Tier …II or III… application for an air quality …type of permit or permit action being
sought [e.g., Construction Permit for a Major Facility]… has been filed with the Oklahoma
Department of Environmental Quality (DEQ) by applicant, …name and address.
The applicant requests approval to …brief description of purpose of application… at the
…site/facility name … …[proposed to be]… located at …physical address (if any), driving
directions, and legal description including county…..
In response to the application, DEQ has prepared a draft permit [modification] (Permit
Number: …xx-xxx-x…), which may be reviewed at …locations (one must be in the county
where the site/facility is located)… or at the Air Quality Division's main office (see address
below). The draft permit is also available for review in the Air Quality Section of DEQ's
Web Page: http://www.deq.state.ok.us/
This draft permit would authorize the facility to emit the following regulated pollutants
(list each pollutant and amounts in tons per year (TPY)).
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.
The public comment period ends 30 days after the date of publication of this notice. Any
person may submit written comments concerning the draft permit to the Air Quality
Division contact listed below. [Modifications only, add: Only those issues relevant to the
proposed modification(s) are open for comment.] A public meeting on the draft permit
[modification] may also be requested in writing at the same address. Note that all public
meetings are to be arranged and conducted by DEQ/CSD staff.
For additional information, contact …names, addresses and telephone numbers of contact
persons for the applicant, or contact DEQ at: Chief Engineer, Permits Section, Air Quality
Division, 707 N. Robinson, Suite 4100, P.O. Box 1677, Oklahoma City, OK, 73101-1677,
(405) 702-4100.
DEQ FORM # 100-822
REVISED NOVEMBER 4, 2004
DRAFT/PROPOSED
PART 70 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. 2011-227-TVR2
ONEOK Field Service Company, L.L.C.,
having complied with the requirements of the law, is hereby granted permission to operate
the Maysville Gas Plant, Section 18, T4N, R2W, Garvin County, Oklahoma subject to the
Standard Conditions dated July 21, 2009 and Specific Conditions, both attached.
This permit shall expire five years from the date of issuance, except as authorized under
Section VIII of the Standard Conditions.
_____________________________
Director
Date
Air Quality Division
DEQ Form #100-890
Revised 10/20/06