section i. introduction - the Oklahoma Department of Environmental

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OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM

TO:

September 18, 2007

Phillip Fielder, P.E., Permits and Engineering Group Manager, Air Quality

Division

THROUGH: Matt Paque, Supervising Attorney, Air Quality Division

THROUGH: Kendal Stegmann, Senior Environmental Manager, Compliance and

Enforcement

THROUGH: David Schutz, P.E., New Source Permit Section

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

THROUGH: Peer Review

FROM: Grover R. Campbell, P.E., Existing Source Permit Section

SUBJECT: Evaluation of Permit Application No.

ConocoPhillips Company

98-104-TV

Ponca City Refinery (Latitude 36.700°, Longitude -97.087°)

Sections 33 & 34, Township 26 N, Range 2 E

Sections 3 & 4, Township 25N, Range 2E

1000 South Pine, Ponca City, Kay County, Oklahoma

SECTION I. INTRODUCTION

ConocoPhillips Company owns and operates the Ponca City Refinery (PCR) (SIC 2911).

The refinery is an existing PSD major stationary source and a source category regulated by 40 CFR

Part 63 Subpart CC (MACT I) and Subpart UUU (MACT II). The refinery is also subject to the emissions reduction agreements of Consent Decree No. H-01-4430 (the Consent Decree) entered in the Southern District Court for Texas on April 30, 2002; amended on August 5, 2003; and amended on October 24, 2006.

The applicant has applied for a Part 70 permit that will combine all the applicable requirements from existing permits for this facility under one permit. Emission limits, tank throughput limits, process unit throughput limits, or maximum heater firing rates that were taken to avoid or net out of PSD review, that were based on BACT requirements, or that were taken to comply with consent orders were maintained. Current active permits include Permit No. 88-102-O (M-1), 88-

115-O (M-3), 89-029-O (M-1), 89-047-O (M-2), 90-011-O (M-4), 90-066-O, 91-008-O, 91-043-

O (M-7), 91-081-O (M-3), 91-094-O (M-3), 91-129-O (M-2), 91-143-O (M-2) (PSD), 92-018-O

PERMIT MEMORANDUM 98-104-TV

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2

(M-1), 92-034-O, 95-130-O, 95-158-O (M-6), 97-269-O (M-2), 97-286-C (M-3), 97-485-C, 98-

104-C, 98-169-C (M-6), 2000-117-C, 2000-206-C (M-4), 2000-210-O, 2000-173-C, 2001-189-

C, 2001-194-C (M-3) (PSD), 2001-195-O, 2001-212-O (M-1), 2001-305-C, 2002-115-C (M-2),

2002-476-C (M-2) (PSD), 2003-336-C (M-3) (PSD), and 2007-050-O. The applicant requests that the following permits be voided for inactive or dismantled equipment or equipment that was never constructed: 89-047B-O, 90-076-O (M-1), 90-077-C, 91-124-O, 91-142-O, 92-028-C, 98-

287-C and 2002-138-C.

ConocoPhillips Pipeline Company owns and operates three adjacent facilities that support the transportation of non-processed petroleum into and finished products out of the refinery. These

“Pipeline Activities” consist of the Ponca City South Tank Farm, the Ponca City Products

Terminal, and the Cherokee Pump Station. These facilities are considered collocated and part of a single facility site for the purpose of emissions evaluation and regulatory applicability (see

Section II); however, they are operated under a separate Part 70 permit, Permit No. 2006-206-

TV. Future permitting and modifications of the PCR and associated permits need to be based on the combined emissions from both the PCR and the Pipeline Activities and need to be considered prior to making a determination for each permitting action. Applicability of Part 70 requirements or New Source Review (NSR) requirements should also be based on the combined emissions of the PCR and the Pipeline Activities.

Total facility site emissions, excluding trivial and insignificant activities, are shown in the following table.

EUG

PCR

Pipeline

Total (1)

NO

X

TPY

1,520

2

1,520

CO

TPY

1,240

5

1240

1. Shown to a precision of 10 TPY.

SO

2

TPY

1,210

-

1,210

VOC

TPY

4,790

190

4,980

PM

10

TPY

640

-

640

SECTION II. APPLICABILITY OF OTHER FACILITIES ADJACENT TO THE PCR

The PCR complex and adjacent areas contain other facilities with activities that may or may not be related to the operation of the refinery. The applicant supplied an analysis of these facilities to determine if any need to be included in the site emissions for this permit. AQD has reviewed and agrees with the following analyses.

Global Facilities Management

Global Real Estate and Facilities Services (GRFS) is a business unit of ConocoPhillips Company that manages general systems and services at facilities in which the company conducts business.

At the Ponca City Refinery, GRFS is responsible for facility building and building complex grounds maintenance. This includes operation of non-process boilers, emergency generators, fuel storage tanks, and cooling towers located within the building complex where refinery employees work. Steam produced in the refinery is used for heating buildings. Fuel storage tanks are used for grounds keeping and building complex maintenance activities. Cooling towers are used to


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3 provide cooling for buildings and for boiler feed water. Since these activities support or are supported by the refinery, the GRFS equipment is considered to be associated with the operation of the Ponca City Refinery and is included in the refinery’s Title V permit application.

Technology Facility

SIC Code 8731 - Commercial, Physical and Biological Research (Major Group 87: Engineering,

Accounting, Research, Management, and Related Services). The ConocoPhillips Technology

Facility is a research and development facility located on the northwest edge of the refinery outside of the refinery fenceline. The refinery handles wastewater streams from the R&D facility and the refinery lab is located within the R&D facility. However, the primary activities of the

R&D facility are not associated with refinery operations. The personnel, management, and fiscal decision-making relative to the R&D facility are separate from those same functions at the refinery. The employees responsible for the R&D facility are not refinery employees and cannot be disciplined by the refinery manager. In summary, this facility is not associated with, is not under common control with, and belongs to a different SIC Code Major Grouping than the refinery. Therefore the R&D facility is not included in the refinery’s Title V permit application.

OSU-University Multi-Spectral Laboratory

SIC Code 8733 – Noncommercial Research Organizations (Major Group 87: Engineering,

Accounting, Research, Management, and Related Services). The Oklahoma State University

Multi-Spectral Laboratory (OSU-UML) is an Oklahoma Not-for-Profit, Limited Liability

Company created as a wholly owned subsidiary of OSU. The OSU-UML is located in the building formerly known as the Research & Development East facility on the Ponca City

Refinery complex. Operation of the facility is contracted by OSU to American Manufacturing and Technologies, Inc. (AMTI). The personnel, management, and fiscal decision-making relative to the UML are separate from those same functions at the refinery. The employees responsible for the facility are not refinery employees and cannot be disciplined by the refinery manager. In summary, this facility is not under common control with and does not belong to the same SIC

Code Major Grouping as the refinery. Therefore the UML is not included in the refinery’s Title

V permit application.

Jupiter Sulfur LLC (JSLLC)

SIC Code 2873 - Nitrogenous Fertilizers (Major Group 28: Chemicals and Allied Projects).

The Jupiter facility is located on the southeast edge of the refinery outside of the refinery fenceline. This facility produces ammonium thiosulfate and elemental sulfur and is presently permitted separately from the refinery. The facility receives acid gas from the refinery as one of its feedstocks. ConocoPhillips owns a 50 percent interest in JSLLC. JSLLC employs

Tessenderlo Kerly, Inc. (TKI) as the operator of the facility. TKI is responsible for management, operation, and maintenance of the facility. The structure and operation of the Jupiter facility are independent of the refinery, since there is outside ownership and operation.

Consent Order No. 00-196, which was filed on July 11, 2000, contains the following language in

Attachment C, Section VIII.D for compliance measures dealing with NSR/PSD Analysis

Methodology: “Based upon DEQ’s review of information provided by Conoco related to the

Jupiter Facility, Jupiter shall be excluded from this methodology description as a separate


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4 stationary source”. Based on the consent order, emissions from the Jupiter facility will not be aggregated with the refinery’s emissions for NSR/PSD or NESHAP applicability. The Jupiter facility will continue to be permitted separately and is not included in the refinery’s Title V permit application.

South Tank Farm

SIC Code 4612 – Crude Petroleum Pipelines (Major Group 46 – Pipelines, Except Natural Gas).

The South Tank Farm is comprised of eighteen (18) tanks, most of which are separated from the refinery by fencing, although three (T-629, T-630, and T-631) are located just within the refinery side of the fenceline. These tanks receive crude oil via pipeline from Cushing, OK. The tanks are dedicated to the refinery (they do not act as “terminal” tanks to ship crude to other locations), and some South Tank Farm tanks feed directly to refinery process units. However, all of this tankage is owned and operated by ConocoPhillips’ transportation company, ConocoPhillips

Pipeline Company. The personnel, management, and fiscal decision-making relative to these tanks are separate from those same functions at the refinery. The employees responsible for the tanks are not refinery employees and cannot be disciplined by the refinery manager. Although the South Tank Farm is not under common control with and belongs to a different SIC Code

Major Grouping than the refinery, operation of the tankage is contiguous with the refinery. The

South Tank Farm is not included in the refinery’s Title V permit application, but emissions from the facility will be aggregated for NSR/PSD and NESHAP applicability purposes. However, the

South Tank Farm will be operated under Permit No. 2006-206-TV.

Ponca City Truck Rack

SIC Code 5171 - Gasoline & Oil Bulk Stations (Wholesale) (Major Grouping 51: Wholesale

Trade – non-durable goods). The Ponca City Truck Rack is located southwest of the main refinery operations and generally south of the refinery tank farm. This facility serves to load refinery products out to tanker trucks which then make deliveries to commercial or retail customers. The truck rack consists of tanks, pumps, and truck loading equipment. All of this equipment is operated by personnel of ConocoPhillips’ transportation company, ConocoPhillips

Pipeline Company. The personnel, management, and fiscal decision-making relative to these tanks are separate from those same functions at the refinery. The employees responsible for the tanks are not refinery employees and cannot be disciplined by the refinery manager. Although the truck rack is not under common control with and belongs to a different SIC Code Major

Grouping than the refinery, operation of the truck rack is contiguous with the refinery. The Ponca

City Truck Rack is not included in the refinery’s Title V permit application, but emissions from the facility will be aggregated for NSR/PSD and NESHAP applicability purposes. However, the

Ponca City Truck Rack will be operated under Permit No. 2006-206-TV.

Cherokee Pump Station

SIC Code 4612 – Crude Petroleum Pipelines (Major Group 46 – Pipelines, Except Natural Gas).

The Cherokee Pump Station (CPS) is a pipeline pumping station that ships finished products, including gasoline, out of the refinery through pipelines to various terminals. Most of the equipment related to the operations is located outside of the refinery fenceline, and within a discrete area dedicated to these operations, located to the southwest of the main refinery operations. There are approximately five pumps that are located on the refinery side of the


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5 fenceline near the product tanks. All of this equipment is operated by personnel of

ConocoPhillips’ transportation company, ConocoPhillips Pipeline Company. The personnel, management, and fiscal decision-making relative to these tanks are separate from those same functions at the refinery. The employees responsible for the tanks are not refinery employees and cannot be disciplined by the refinery manager. Although the CPS is not under common control with and belongs to a different SIC Code Major Grouping than the refinery, operation of the CPS is contiguous with the refinery. The CPS is not included in the refinery’s Title V permit application, but emissions from the facility will be aggregated for NSR/PSD and NESHAP applicability purposes. However, the CPS will be operated under Permit No. 2006-206-TV.

Warren Petroleum Company Lease

SIC Code 1311 – Crude Petroleum and Natural Gas (Major Group 13 – Oil & Gas Extraction).

The Warren Petroleum Company lease consists of 2 crude tanks, 2 salt water tanks, and associated crude oil pumping equipment. This equipment is physically located within the refinery fenceline but the equipment is not associated with refinery operations. Warren Petroleum

Company owns, operates, and maintains the equipment. In summary, this equipment is not associated with, is not under common control with, and does not belong to the same SIC Code

Major Grouping as the refinery. Therefore the Warren Petroleum Company Lease is not included in the refinery’s Title V permit application.

Groundwater Recovery/Containment Wellfield

The Groundwater Recovery/Containment Wellfield, located inside and outside the fenceline of the refinery, consists of groundwater pumping and containment equipment. Recovered groundwater and product are pumped to the refinery’s slop recovery and wastewater treatment systems. Emissions from the operation of groundwater remediation wells are considered to be an insignificant activity under OAC 252:100 Appendix I. This equipment is operated and maintained by refinery personnel, however, management, and fiscal decision-making relative to this equipment are handled by ConocoPhillips’ Corporate Health, Safety, and Environment

Business Unit, which is separate from those same functions at the refinery. It is unclear whether these activities should be aggregated with the refinery for the purposes of Title V permitting.

This remedial activity is exempt from NESHAP Supbart GGGGG since it is permitted under

RCRA. There are no regulatory obligations associated with these activities so their inclusion in the refinery’s Title permit will not be of issue. Therefore, the Groundwater

Recovery/Containment Wellfield activities will be considered to be included the refinery’s Title

V permit application as “Insignificant Activities”.

4 th Street Clubhouse SVE System

The 4 th

Street Clubhouse Soil Vapor Extractor (SVE) System is a remediation activity located on the east edge and outside the fenceline of the refinery. The SVE system is an insignificant activity under OAC 252:100 Appendix I since emissions are less than 5 TPY of any criteria pollutant. This equipment is operated and maintained by refinery personnel, however, management, and fiscal decision-making relative to this equipment are handled by

ConocoPhillips’ Corporate Health, Safety, and Environment Business Unit, which is separate from those same functions at the refinery. The SVE system is independent of refinery operations.

This remedial activity is exempt from NESHAP Supbart GGGGG since it is permitted under


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RCRA. It is unclear whether these activities should be aggregated with the refinery for the purposes of Title V permitting. The only regulatory obligation associated with this equipment is to maintain a record that emissions are insignificant, so their inclusion in the refinery’s Title permit will not be of issue. Therefore, the 4 th Street Clubhouse SVE System activities will be considered to be included the refinery’s Title V permit application as “Insignificant Activities”.

SECTION III. EXISTING PERMIT CHANGES INCORPORATED INTO TV PERMIT

The PCR is presently operated under many construction and operating permits issued over a 20 year period. The applicant has requested changes for some specific conditions contained in these permits because of outdated applicability requirements, correction of overlapping conditions, equipment removed from service, etc. The following table summarizes the changes requested in the application that were reviewed by AQD and made in the Part 70 permit.

Permit

General Changes

General Changes –

Storage Tanks

Description and Reason for Specific Condition Change

1. Did not include requirements to update Title V application, conduct onetime performance testing, remove equipment, install control technology, or restrictions on using emission reduction credits if these activities had already been completed.

2. Did not include the specific conditions that nullified and/or voided previous versions of the permits.

3. TPY, lb/hr, fired duty, and throughput limits were designated as either

12-month rolling or 365-day rolling values where feasible.

4. Equipment identification numbering was modified to bring a consistent format to the Title V permit.

5. Specific conditions that are identical to or overlap with federal and state regulatory requirements were removed since applicable state and federal requirements are included in the Title V permit

6. Specific conditions identical to or covered by those in the Title V

Standard Conditions were removed since the Standard Conditions will be included with the Title V permit.

7. Ponca City Truck Rack, South Tank Farm, and Cherokee Pump Station equipment were removed from the application, while Global Real Estate and

Facilities Services equipment was added to the application.

1. Tank capacities were updated to reflect recently verified physical volumes versus working volumes.

2. Many of the existing state permits indicated applicability or negative applicability for storage tank regulations such as 40 CFR Part 60 Subpart Kb and QQQ and 40 CFR Part 61 Subpart FF. Since issuance of some permits,

40 CFR Part 60 Subpart Kb was modified to reduce recordkeeping requirements for certain storage vessels and the refinery MACT standards

(40 CFR Part 63 Subpart CC) were promulgated. The refinery MACT standards include storage tank overlap provisions covering 40 CFR Part 60

Subpart Kb and QQQ and 40 CFR Part 61 Subpart FF. Due to these regulatory changes and as an effort to correct and streamline regulatory applicability for the Ponca City Refinery storage tanks, the applicability of


Permit

General Changes –

Heaters & Boilers

General Changes –

Fugitive Equipment

Leaks

88-102-O (M-1)

88-115- O (M-3)

88-117-O

89-029-O (M-1)

89-047-O (M-2)

89-047B-O

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7


40 CFR Part 60 Subparts Kb and QQQ, 40 CFR Part 61 Subpart FF, and/or

40 CFR Part 63 Subpart CC for some storage tanks was revised.

3. Many of the existing state permits included vapor pressure limitations.

Where the vapor pressure limitations are based on the cutoff levels above which controls are required under 40 CFR Part 60 Subpart Kb or 40 CFR

Part 63 Subpart CC, the vapor pressure limitations have been designated as such. Where vapor pressure limitations are more restrictive than allowed by these regulations, the relevant averaging time has been designated. 40 CFR

Part 60 Subpart Kb and 40 CFR Part 63 Subpart CC reference vapor pressure cutoffs in units of kilopascals. This permit specifies the vapor pressure cutoff level in units of psia derived as follows: psia = kilopascals

/ 6.89478. For example, 5.2 kPa and 76.6 kPa equal 0.75 psia and 11.1 psia, respectively.

4. Tank throughput limits were rounded up or down to a precision of 1,000 gallons per day by AQD.

1. For consistency, all permitted SO

2

emission limits were recalculated based on the same SO

2

emission factor. The basis for SO

2

emission limitations in existing permits ranged from 0.031 lb/MMBtu to 0.041 lb/MMBtu depending on the molar volume and fuel gas heating values used.

The recalculated SO

2

emission limits are based on an SO

2

emission factor of

0.031 lb/MMBtu derived from the NSPS Subpart J limit of 160 ppmv, a molar volume at 60 °F, and a fuel gas higher heating value (HHV) of 867

Btu/scf. A heating value of 867 represents the average HHV in the West

Plant over the past year, which is the area with the lowest HHV average in the refinery.

2. For VOC and PM

10

emission limitations, demonstration of compliance is specified as operation of the equipment using good combustion practices.

3. NSPS Subpart J permit citations, as they apply to gas-fired equipment, reference the refinery fuel gas limit of 0.10 grains H

2

S/dscf. Conversion of this limit to ppmvd H

2

S requires use of a gas molar volume and the molar volume varies based on the standard temperature used. For compliance demonstration purposes, the facility will use a molar volume of 0.02406 cubic meters/g-mol based on a standard temperature of 60°F and, using metric units, will convert 0.10 grains H

2

S/dscf to 160 ppmvd H

2

S.

1. Removed VOC emission limitations, specified that equipment counts are estimates solely for the purpose of documenting regulatory applicability, and that exact counts are not to be construed as operating limitations.

No changes.

No changes.

Nullified by Permit No. 91-043-O (M-1).

SC1: T-0147 limits have been superceded by those in Permit No. 2001-194-

C (M-2).

SC3: Removed T-0147 requirements because they have been superceded by those in Permit No. 2001-194-C (M-2).

Limits and references to T-160 nullified by Permit No. 2007-050-O.

Soil remediation air stripping equipment and activated sludge unit in this permit is permanently inactive. Requested that this permit be voided.


90-011-O (M-4)

90-066-O

90-076-O (M-1)

90-077-C

Permit

91-008-O

91-042-O

91-043-O (M-7)

91-060-O (M-2)

91-081-O (M-3)

91-094-O (M-3)

91-124-O

91-129-O (M-2)

91-142-O

91-143-O (M-2) (PSD)

92-018-O (M-1)

92-028-C

92-034-O

93-003-O (M-3)

95-130-O

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SC1: Updated T-0120, T-0143 and T-0163 VOC emission limits using latest version of EPA TANKS program.

SC1: Updated H-0023 and H-0029 NO

X

, CO, VOC, & PM emission limits to reflect the latest version of AP-42. Updated H-0023 and H-0029 SO

2 emission limits to reflect latest fuel gas heating value basis and molar volume basis.

Soil/groundwater remediation equipment in this permit is permanently inactive. Requested that this permit be voided.

Permit voided because soil vapor extraction pilot unit was never constructed.

SC1: Removed limits for toxics formerly regulated under Subchapter 41.

SC3: Removed since this equipment is no longer in MTBE service and 40

CFR Part 60 Subpart NNN no longer applies.

Permit voided by Applicability Determination 91-042-AD (M-1).

SC1: Removed limits for H-0047 and H-0015 since heaters are no longer in service. Changed H-7501 CO lb/hr limit to 1.23 lb/hr. An error was made in transferring the limits over from Permit No. 91-043-O (M-4). Removed

SRU limits because equipment has been permanently shut down.

SC3: Removed because SRU has been permanently shut down.

SC5: Removed because SRU has been permanently shut down.

SC10: Changed SO

2

emission compliance demonstration method.

SC14.b: Removed requirement to monitor and record 365-day average fuel gas H

2

S concentration. There is no regulatory basis for this requirement.

SC14.c: Changed fuel gas monitoring and recordkeeping to monthly.

Nullified by Permit No. 2007-050-O.

SC1.A.vi.b: Changed fuel gas monitoring and recordkeeping to monthly.

SC9.a: Removed condition to provide the facility the flexibility to determine throughputs from any type of operational data available.

Soil/groundwater remediation equipment in this permit is permanently inactive. Requested that this permit be voided.

SC 1.A.iii: Removed the methods specified for determining monthly throughput to provide the facility the flexibility to determine throughputs from any type of operational data available.

Voided. Biomedical waste incinerator was dismantled.

No changes.

No changes.

Permit voided because permitted T-0115 reconstruction activities were not conducted.

SC1: Removed limits for toxics formerly regulated under Subchapter 41.

SC7: Removed. There is no regulatory basis for this requirement. If pressure relief devices were not routed to flare, it only means they would not be exempt from the requirements of 40 CFR 60 Subpart GGG, which is already an applicable requirement for other equipment covered under the permit.

Nullified by Permit No. 2007-050-O.

SC1: Updates emission limits using latest version of EPA TANKS program.

SC12: Removed. T-0122E and T-0525 that were demolished.


Permit

95-158-O (M-6)

96-280-O (M-1)

97-269-O (M-2)

97-286-C (M-3)

97-485-C

1998-104-C

98-169-O (M-1)

98-169-C (M-6)

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9


SC14: Added a qualifier that testing is required once during the term of the

Title V operating permit if the boiler is operated, other than on hot standby, during that period.

Nullified by Permit No. 2000-206-C.

No changes.

SC1: Lb/hr emission limits were lowered to make them equivalent to the

TPY limits.

SC1: Removed references to the storage tanks because they were never constructed.

SC3: Removed 30,000 gallon per hour loading rate limit because there is no basis for hourly limitations.

SC4: Removed references to the storage tanks because they were never constructed.

SC3: Removed. Using MDEA as the amine solution would require compliance with NSPS Subpart GGG and 40 CFR 63 Subpart CC, which are already an applicable requirement for other equipment in the permit.

Removing the restriction on MDEA use and applying 40 CFR 63 Subpart

CC to the amine system would not have affected the analysis of the Tier II permitting project at that time.

Superceded by Permit No. 98-169-C (M-2).

SC1: SO

2

and PM

10

emission limits superceded by Permit No. 2003-336-C

(M-1) (PSD).

SC2: Removed. This method of measurement is unsuitable for the No. 5

FCCU after a wet gas scrubber is installed. An alternative method of compliance has been requested from EPA and is pending approval.

SC3: Removed. Process rate limit no longer applies after installation of the wet gas scrubber per Permit No. 2003-336-C (M-1) (PSD).

SC5: SO

2

limits superceded by Permit No. 2003-336-C (M-1) (PSD).

Removed control additive reference to allow flexibility to maintain compliance with emission limits using other controls available.

SC6: Removed. This methodology is unsuitable for the No. 5 FCCU after a wet gas scrubber is installed. The No. 5 FCCU is already subject to other

PM limitations through the provisions of 40 CFR 60 Subpart J and Consent

Decree C.A. H-01-4430 requirements.

SC7: Removed. There is no regulatory driver for using alternative monitoring methods when a CEMS is down.

SC8: Reworded to clarify that use of alternative monitoring methods are not mandatory when flow monitors are down and that they may be used in lieu of a flow monitor to demonstrate compliance with the mass emission rate limits.

SC14: Removed. The requirement to obtain CEMS data for 18 hours per day in at least 22 out of 30 consecutive days comes from NSPS J and

NESHAP 63 Subpart UUU standards, which are already included as applicable requirements elsewhere in the Title V permit.

SC15: Removed to allow facility the flexibility to maintain compliance with emission limits using other controls available.

SC20: Removed recordkeeping requirements for fresh feed which is no longer a requirement per Permit No. 2003-336-C (M-1) (PSD), sulfur


98-287-C

Permit

2000-117-C

2000-206-C (M-4)

2000-210-O

2001-173-C

2001-189-C

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Description and Reason for Specific Condition Change content of feed (not necessary because using CEMS to measure SO

2 emission rate), additive composition (not necessary because using CEMS to measure NO

X

and SO

2

emission rates), opacity readings (unsuitable method of measurement after wet gas scrubber installed), and SO

2

emissions

(superceded by Permit No. 2003-336-C (M-1) (PSD)).

Permit voided because permitted decant storage tankage upgrade project was not conducted.

No changes.

SC1: NO

X

, SO

2

& PM

10

emission limits superceded by Permit No. 2003-

336-C (M-1) (PSD).

SC2: Removed reference to Alternate Opacity Approval and replaced with the actual opacity limitation and other ongoing obligations from the

Approval. Added allowance to use an alternate opacity monitoring method after installation of a wet gas scrubber.

SC4: Removed. Superceded by Permit No. 2002-276-C (PSD).

SC5: Removed to allow facility the flexibility to maintain compliance with emission limits using other controls available.



SC8: Reworded to clarify that use of alternative monitoring methods are not mandatory when flow monitors are down and that they may be used in lieu of a flow monitor to demonstrate compliance with the mass emission rate limits.

SC12: Removed. PM

10

compliance demonstration methodology superceded by Permit No. 2003-336-C (M-1) (PSD).

SC14: Removed recordkeeping requirements for SO

2

& NO

X

control additive addition (not necessary because using CEMS to measure SO

2

and

NO

X

emission rates), sulfur content of feed (not necessary because using

CEMS to measure SO

X

emission rate).

SC18: Removed. The requirement to obtain CEMS data for 18 hours per day in at least 22 out of 30 consecutive days comes from NSPS J and

NESHAP 63 Subpart UUU standards, which are already included as applicable requirements elsewhere in the Title V permit.

SC3: Changed to require the temporary flare to utilize the same NSPS

Subpart J-compliant technology utilized by the flare it is temporarily replacing.

SC4: Removed. The most recent version of OAC 252:100-31-26 does not apply to flares.

SC5: Removed. The most recent version of OAC 252:100-31-26 does not apply to flares.

SC6: Changed to require only the same records necessary to demonstrate

NSPS Subpart J compliance as the flare it temporarily replaces. Removed reference to SC4 because it is no longer applicable.

No changes.

No changes.


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11

Permit

2001-194-C (M-3) (PSD)

2001-195-O

2001-212-O (M-1)

2001-252-O

2001-305-C

2001-311-C

2002-115-C (M-2)


SC1.F.ii: Removed. Not necessary to place design restrictions on the flare since it is already required to comply with NSPS Subpart J.

SC6: Removed. There is no requirement to submit operational data with the annual Title V compliance certification, only a requirement to provide details for deviations from permit obligations.

SC4: Removed reference to T-0254 because NSPS Subpart Kb changed and no longer requires records for tanks of this size.

SC6: This condition only applies to T-0253 since NSPS Subpart Kb changed and no longer applies to T-0254.



No changes.

Voided. The East Plant Flare limits and specific conditions were previously voided by Permit No. 2003-336-C (M-3) (PSD).

SC1: H-6007 limits superceded by Permit No. 2003-336-C (M-1) (PSD).

SC4: H-6007 limits superceded by Permit No. 2003-336-C (M-1) (PSD).

SC5: H-6007 compliance demonstration methods superceded by Permit No.

2003-336-C (M-1) (PSD).

SC6: H-6007 compliance demonstration methods superceded by Permit No.

2003-336-C (M-1) (PSD).

SC10: H-6007 recordkeeping requirements superceded by Permit No. 2003-

336-C (M-1) (PSD).

Voided. All permit conditions referring to heater H-0001 in Permit No.

2001-311-C were previously voided by 2002-476-C (PSD).

SC1: Removed maximum heat input limits because there is no regulatory basis and no compliance demonstration specified for these limits.

2002-138-C Permit voided because temporary boiler was never constructed.

SC1.A.H-0048.i: Removed because this heater was not modified as to increase the emissions of NO

X

since its original construction date of 1957.

2002-476-C (M-2) (PSD)

SC6: Removed. This is already a requirement in the standard conditions of the Title V permit.

2003-336-C (M-3) (PSD) No changes.

2007-042-C (PSD) No changes.

2007-050-O No changes.

SECTION IV. FACILITY DESCRIPTION

In 1911, E. W. Marland purchased land south of the Ponca City town-site and built the Marland

Refining Company refinery, which is now ConocoPhillips Company Ponca City Refinery. A small skimming plant began operating in 1914, which was designed to process oil into gasoline, kerosene, and naphtha. Marland Refining Company merged with Continental Oil Company in

1929 and the merged company became known as the Continental Oil Company. By this time more complex equipment had been added to the refinery and the plant was capable of processing

30,000 barrels of crude oil per day. In 1943, the aviation gasoline facility was built by the


DRAFT

12

Defense Plant Corporation of the U.S. government and was operated during World War II by

Continental Oil Company. After the war, Continental Oil Company purchased and integrated the aviation gasoline facility into the refinery, which is the present-day South Plant area. The

Sequoia (former Cities Services until 1966) refinery was purchased in 1970, which is the presentday East Plant area. In 1979, the company name was changed to Conoco Inc. Conoco Inc. merged with and became a wholly owned subsidiary of E. I. DuPont de Nemours Company, Inc. in 1981, but became an independent company again in 1999. In 2003, Conoco Inc. merged with

Phillips Petroleum Company to form ConocoPhillips Company. The facility’s refining capacity at the time of this permit application is approximately 195,000 barrels per day of crude oil.

The facility is divided into six main areas based on the layout of the operations: East Plant, West

Plant, North Plant, South Plant, Coker Combo/Alky, and Oil Movements. The facility converts crude oil into a variety of saleable products such as liquid fuels, LP gas, and feedstocks for other industries.

Primary process units include crude distillation units, a saturate gas plant, catalytic reforming units, an isomerization unit, hydrodesulfurization units, hydrotreating units, merox units, a bender unit, amine units, fluid catalytic cracking units, a coker unit, an alkylation unit, and catalytic polymerization unit. Saleable products are blended in the gasoline blending, diesel blending, and jet fuel blending processes. Auxiliary equipment includes emergency flares, steam boilers, hydrogen plants, fuel gas recovery systems, cooling towers, sour water treatment units, activated sludge and other wastewater treatment systems, intermediate and product storage, coke loading, and liquid hydrocarbon loading.

The following is a general explanation of unit operations at the PCR.

Crude Oil

Approximately 99 percent of the crude oil to be processed at the Ponca City Refinery arrives via pipelines.

Distillation

Distillation is the process of boiling a liquid and collecting the condensed vapor. In petroleum refining, distillation is used to separate crude oil into more useful components. A tall tower called a fractionating column is used to distill the crude oil. As crude enters the column, the lighter, lower boiling point components vaporize and rise to a level where the surrounding temperature and pressure correspond to their boiling point. Meanwhile, heavier, higher boiling point components descend in a liquid stream to a level where conditions match their boiling point. The column is filled with trays containing holes, which allow the ascending vapor to bubble through the descending liquid, increasing contact between the two phases. The vapors are cooled, condensed and drawn off as distillates at various points up the column – gas oil first, then diesel, kerosene, naphtha and finally, petroleum gases such as propane and butane. The heavy oils that are not vaporized because of their very high boiling points are piped off from the bottom of the tower.


DRAFT

13

Cracking

Cracking is used to convert the heavier gas oils into more valuable products. This is done by breaking down the complex molecule chains which make up the heavier hydrocarbon compounds into simpler, lighter ones. There are three different types of cracking:



Thermal cracking using heat alone.



Fluid catalytic cracking using heat in the presence of a catalyst, which enhances the chemical conversion without itself being changed. This has certain advantages over thermal cracking in giving higher gasoline yields, while the lighter gases produced can be used as feed for alkylation.



Hydrocracking using heat and catalyst plus hydrogen. This has an advantage when there is a need to produce diesel rather than gasoline.

Alkylation

Alkylation is the opposite of cracking. Instead of breaking down larger hydrocarbon molecules into smaller ones, alkylation units convert two smaller molecules into one larger one to produce alkylate, a high-octane gasoline-blending component.

Desulfurization

Increased processing of high-sulfur crudes, coupled with the need for greater product blending flexibility and ever tighter fuel specifications (largely due to environmental considerations) has driven the development of treating technology to remove sulfur compounds and other impurities from oil feedstock and petroleum products.

Hydrodesulfurization uses hydrogen to remove sulfur compounds by converting them into hydrogen sulfide in the presence of a catalyst. The hydrogen sulfide produced is removed from the product gas stream by an amine wash and converted into elemental sulfur for sale to the chemical industry.

Reforming

Naphtha produced by some refinery processes, such as crude distillation or thermal cracking, does not have a high enough octane rating for direct use. However, it can be modified in a catalytic reformer to convert low-octane molecules into high-octane molecules.

Coking

The PCR utilizes delayed coking to upgrade heavy oil to petroleum coke and more valuable lighter products. Heavy oil feedstock from the bottom of the coker fractionator is heated in a furnace where it begins to crack into liquid and vapor mixture. This flows to the coke drums where solid petroleum coke forms and hydrocarbon vapors are released. The coke remains in the drum, solidifies and gradually fills the vessel. The vapors are returned to the fractionator where high-value products are recovered. When the coke drum is full, it is taken out of service and the other drum is put on. The full drum is taken out of service and a pilot hole is drilled in the coke bed. A horizontal water cutting tool is inserted through the pilot hole and breaks the coke into large chunks, which fall into rail cars. The empty drum is sealed, steamed and put into service again.


DRAFT

14

Products

Petroleum products are delivered to customers by pipeline, rail, and road (trucks). The vast majority of products from the PCR are delivered by pipeline to distribution terminals in the midcontinent region of the United States. Intermediate and finished products are stored in more than

150 tanks, bullets, and spheres. Some finished products are produced directly from the process units, such as propane and jet fuels. However, gasoline and diesel fuel products are blended to the required specifications before being stored in product tanks and subsequently distributed to customers. Green anode petroleum coke is stored on a small pad in the refinery and delivered to customers by truck.

SECTION V. EQUIPMENT

Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) as shown below.

EUs with no applicable federal or state standards, recordkeeping, or reporting requirements are not included in the TV permit.

TANKS

EUG TNK-1: Storage Vessels Subject to 40 CFR Part 63 Subpart CC (Refinery MACT I)

EUG TNK-2: Storage Vessels Subject to 40 CFR Part 60 Subpart Kb and 40 CFR Part 63

Subpart CC (MACT I)

EUG TNK-3: Storage Vessels Subject to 40 CFR Part 63 Subpart CC (Refinery MACT I)

Recordkeeping Only

EUG TNK-4: 40 CFR Part 63 Subpart CC (Refinery MACT I) Group 1 Wastewater Streams

Handled by Either Storage Tanks or Oil Water Separators

EUG TNK-5: 40 CFR Part 63 Subpart CC (Refinery MACT I) Group 2 Wastewater Streams

Handled by Storage Tanks

EUG TNK-6: 40 CFR Part 63 Subpart EEEE (OLD MACT) Fixed Roof Storage Tanks

EUG TNK-7: Storage Tanks Subject to Oklahoma Rules or Permit Requirements Only

EUG TNK-8: Insignificant Activity Storage Tanks

HEATERS & BOILERS

EUG HTR-1: 40 CFR Part 60 Subparts J & Db, and 40 CFR Part 63 Subpart DDDDD

(Heater/Boiler MACT) Boilers

EUG HTR-2: 40 CFR Part 60 Subpart J and 40 CFR Part 63 Subpart DDDDD (Heater/Boiler

MACT) Heaters & Boilers

EUG HTR-3: Heaters & Boilers Subject to Oklahoma Rules, Permit Limits, or 40 CFR Part 63

Subpart DDDDD (Heater/Boiler MACT)

EUG HTR-4: Insignificant Activity Heaters & Boilers


DRAFT

15

MISCELLANEOUS

EUG ENG-1: Fuel-Fired Engines Subject to Oklahoma Rules Only

EUG ENG-2: Insignificant Activity Engines

EUG ENG-3: Emergency Fuel-Fired Engines Subject to 40 CFR Part 60 Subpart IIII

EUG FCC-1: Fluid Catalytic Cracking Unit Catalyst Regenerators Subject to 40 CFR Part 60

Subpart J and 40 CFR Part 63 Subpart UUU (Refinery MACT II)

EUG CRU-1: Catalytic Reforming Unit Catalyst Regenerator Vents Subject to 40 CFR Part 63

Subpart UUU (Refinery MACT II)

EUG FLR-1: Flares Subject to 40 CFR Part 60 Subpart J

EUG LOD-1: Loading Racks Subject to 40 CFR Part 63 Subpart CC (Refinery MACT I)

EUG LOD-2: Loading Racks Subject to Oklahoma Rules or Permit Requirements Only

EUG LOD-3: Insignificant Activity Loading Racks

EUG VNT-1: 40 CFR Part 63 Subpart CC (Refinery MACT I) Group 1 Miscellaneous Process

Vents

EUG VNT-2: 40 CFR Part 63 Subpart CC (Refinery MACT I) Group 2 Miscellaneous Process

Vents

EUG VNT-3: Atmospheric Process Vents Subject to Oklahoma Rules Only

EUG VNT-4: Atmospheric Process Vents with No Applicable Requirements

EUG VNT-5: Insignificant Activity Atmospheric Process Vents

FUGITIVE EMISSION EQUIPMENT

EUG FUG-1: Fugitive Equipment Leaks Subject to 40 CFR Part 63 Subpart CC (Refinery

MACT I) and/or 40 CFR Part 60 Subpart GGG

EUG FUG-2: Fugitive Oily Water Sewer System Component Leaks Subject to 40 CFR Part 63

Subpart CC (Refinery MACT I) and 40 CFR Part 61 Subpart FF (BWON)

EUG FUG-3: Fugitive Oily Water Sewer System Component Leaks Subject to 40 CFR Part 60

Subpart QQQ

EUG FUG-4: Fugitive Oily Water Sewer System Component Leaks Subject Only to 40 CFR

Part 61 Subpart FF (BWON) Exemption Recordkeeping Requirements

EUG FUG-5: Fugitive Storm Sewer System Component Leaks with No Applicable

Requirements

EUG FUG-6: Cooling Tower Fugitive Sources Subject to Oklahoma Rules or Permit

Requirements Only

EUG FUG-7: Materials Handling Fugitive Sources Subject to Oklahoma Rules or Permit

Requirements Only

EUG FUG-8: Insignificant Activity Fugitive Sources

FACILITY-WIDE

EUG FW: Facility-Wide Applicable Requirements


DRAFT

16

TANKS

Tank contents will vary depending upon refinery requirements, but will be limited by the suitability of a particular tank for a particular hydrocarbon. Roof types noted are external floating roof (EFR), internal floating roof (IFR), vertical fixed roof (VFR), horizontal fixed roof (HFR), open top (OT), and sphere. The capacities listed represent the physical tank volumes using the internal cross sectional area and tank shell heights (not taking into consideration safe fill levels).

EUG TNK-1: Storage Vessels Subject to 40 CFR Part 63 Subpart CC (Refinery MACT I)

EU ID Point ID

Normal

Contents

Physical

Capacity

(gallons)

Roof

Type

Construction/

Modification

Date

T-0021E

T-0101

T-0114

T-0148

T-0149

T-0150

T-0151

T-0153

T-0154

T-0155

T-0158

T-0159

T-0160

T-0021E

T-0101

T-0114

T-0148

T-0149

T-0150

T-0151

T-0153

T-0154

T-0155

T-0158

T-0159

T-0160

Naphtha

Alkylate

Gasoline

Gasoline

Gasoline

Gasoline

Gasoline

Reformate

Reformate

Gasoline

Gasoline

Gasoline

Gasoline

3,348,342

440,608

439,433

3,377,633

3,377,633

3,377,633

3,377,633

3,357,528

6,344,761

3,377,633

3,351,095

3,391,305

3,343,857

IFR

IFR

EFR

IFR

IFR

IFR

IFR

EFR

IFR

IFR

IFR

IFR

IFR

1954

1919

1919

1923

1923

1923

1923

1923

1977

1923

1924

1923

1924

T-0162

T-0163

T-0164

T-0167

T-0170

T-0901

T-0162

T-0163

T-0164

T-0167

T-0170

T-0901

Gasoline

LSR Gasoline

LSR Gasoline

Gasoline

Gasoline

Gasoline

3,310,885

3,330,990

3,351,095

1,363,316

1,078,341

3,330,990

IFR

IFR

IFR

IFR

IFR

IFR

1924

1924

1924

1976

1920

1924

T-0902

T-0953

T-0902

T-0953

Naphtha

Gasoline

3,357,528

2,339,924

IFR

IFR

1971

1944

EUG TNK-2: Storage Vessels Subject to 40 CFR Part 60 Subpart Kb and 40 CFR Part 63

Subpart CC (Refinery MACT I)

EU ID

T-0014E

T-0015

Point ID

T-0014E

T-0015

Normal

Contents

Naphtha

Naphtha

Physical

Capacity

(gallons)

258,678

541,420

Roof

Type

EFR

EFR

Construction/

Modification

Date

1995

1995


DRAFT

17

EU ID Point ID

Normal

Contents

Physical

Capacity

(gallons)

Roof

Type

Construction/

Modification

Date

T-0017E

T-0117

T-0119

T-0121

T-0141

T-0147

T-0156

T-0165

T-0166

T-0176

T-0177

T-0017E

T-0117

T-0119

T-0121

T-0141

T-0147

T-0156

T-0165

T-0166

T-0176

T-0177

Crude Oil

Naphtha

Naphtha

Diesel

Slop Oil

Naphtha

Gasoline

Alkylate

Gasoline

Toluene

Toluene

485,310

9,340,615

9,340,615

4,964,188

30,455

3,383,872

3,826,376

3,405,021

4,060,647

1,355,859

116,512

EFR

EFR

EFR

IFR

EFR

EFR

EFR

EFR

EFR

IFR

IFR

1987

1990

1990

2005

1990

1989

1993

1991

1991

1988

1988

T-0178

T-0357

T-0402

T-0540

T-0690

T-0178

T-0357

T-0402

T-0540

T-0690

Aviation

Gasoline

Slop Oil

Slop Oil

Methanol

Slop Oil

454,087

8,812

11,844

170,040

13,324

IFR

EFR

EFR

IFR

EFR

1988

1993

1993

1987

1992

EUG TNK-3 Storage Vessels Subject to 40 CFR Part 63 Subpart CC (Refinery MACT I)

Recordkeeping Only

EU ID

D-0924

T-0002

T-0003

T-0038

T-0041E

T-0051

T-0059

T-0063

T-0064

T-0070

T-0077

T-0103

T-0105

T-0106

T-0106E

T-0107E

Point ID

D-0924

T-0002

T-0003

T-0038

T-0041E

T-0051

T-0059

T-0063

T-0064

T-0070

T-0077

T-0103

T-0105

T-0106

T-0106E

T-0107E

Normal

Contents

MDEA

Tetraethyl Lead

Dye

Crude Oil

Distillate

Residuum

Diesel

Residuum

Diesel

Spent Caustic

Spent Caustic

Diesel

Residuum

Gas Oil

Gas Oil

Gas Oil

Physical

Capacity

(gallons)

27,900

22,428

48,661

Roof

Type

HFR

HFR

VFR

424,453 EFR

1,650,789 Sphere

1,063,329

495,122

VFR

EFR

431,772

369,089

425,921

215,898

436,937

2,814,694

2,278,246

1,143,749

1,143,749

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

Construction/

Modification

Date

2004

1974

Post-1984

1950

1957

1921

1926

1926

1926

1921

1921

1919

1922

1918

1991

1990


EU ID

T-0133

T-0135

T-0136

T-0138

T-0142

T-0143

T-0144

T-0152

T-0161

T-0168

T-0169

T-0116

T-0120

T-0122

T-0123

T-0124

T-0125

T-0126

T-0127

T-0128

T-0129

T-0130

T-0131

T-0171

T-0179

T-0253

T-0254

T-0260

T-0500

T-0501

T-0536

T-0561

T-0633

T-0636

T-0639

T-0640

Point ID

T-0116

T-0120

T-0122

T-0123

T-0124

T-0125

T-0126

T-0127

T-0128

T-0129

T-0130

T-0131

T-0133

T-0135

T-0136

T-0138

T-0142

T-0143

T-0144

T-0152

T-0161

T-0168

T-0169

T-0171

T-0179

T-0253

T-0254

T-0260

T-0500

T-0501

T-0536

T-0561

T-0633

T-0636

T-0639

T-0640

Normal

Contents

Diesel

Diesel

Diesel

Diesel

Residuum

Residuum

Residuum

Gas Oil

Gas Oil

Jet Fuel

Jet Fuel

Vendor

Chemical

Jet Fuel

Spent

Caustic/HC

Diesel

Gas Oil

Gas Oil

Diesel

Diesel

Diesel

Diesel

Gas Oil

Jet Fuel

Diesel

Diesel

Diesel

Spent

Caustic/HC

Caustic/HC

Gas Oil

Coker Fines

Water/HC

Seal Oil

Hydrocarbon

Jet Fuel

Jet Fuel

Jet Fuel

Jet Fuel

Physical

Capacity

(gallons)

435,762

11,088,636

2,695,693

3,684,661

3,684,661

3,684,661

3,684,661

2,814,694

3,619,157

3,619,157

6,831,266

6,831,266

2,772,713

4,586,000

4,586,000

2,788,156

3,398,254

6,644,304

6,644,304

3,377,633

3,363,962

424,453

424,453

20,000

46,998

31,724

13,535

26,437

2,819,894

229,213

16,919

26,418

3,383,872

3,349,806

2,298,399

2,298,399

DRAFT

18

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

Roof

Type

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

1992

1992

1992

1921

1992

1992

1920

1989

1990

1991

1974

1974

1950

1950

Construction/

Modification

Date

1919

1990

1922

1992

1992

1992

1992

1921

1992

1943

1988

1994

1994

1987

1983

1990

1983

1971

1985

1929

1926

1926

D-5292

T-0037

T-0201

T-0202

T-0203

T-0204

T-0205

T-0551

T-0552

T-0553

T-0554

T-0555

T-0651

T-0652

T-0654

T-0665

T-0667


DRAFT

19

EU ID

T-0641

T-0904

T-0905

T-0906

T-0913

T-0914

T-0916

T-0946

T-0947

Point ID

T-0641

T-0904

T-0905

T-0906

T-0913

T-0914

T-0916

T-0946

T-0947

Normal

Contents

Jet Fuel

Gas Oil

Gas Oil

Gas Oil

Gas Oil

Gas Oil

Gas Oil

Gas Oil

Gas Oil

Physical

Capacity

(gallons)

2,298,399

3,317,318

3,317,318

1,047,993

1,050,262

1,054,295

66,091

3,323,752

3,307,668

Roof

Type

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

Construction/

Modification

Date

1926

1924

1924

1944

1943

1943

1944

1924

1924

T-0948

T-0970

T-0971

T-0972

T-0948

T-0970

T-0971

T-0972

Gas Oil

Residuum

Residuum

Residuum

1,050,000

1,903,428

1,903,428

1,903,428

VFR

VFR

VFR

VFR

1944

2000

2000

2000

EUG TNK-4: 40 CFR Part 63 Subpart CC (Refinery MACT I) Group 1 Wastewater

Streams Handled by Either Storage Tanks or Oil Water Separators

EU ID

D-0777

D-0779

Point ID

D-0777

D-0779

Normal

Contents

Construction/

Modification

Date

Pre-1991

Pre-1991

D-5292

T-0037

T-0201

T-0202

T-0203

T-0204

T-0205

T-0551

T-0552

T-0553

T-0554

T-0555

T-0651

T-0652

T-0654

T-0665

T-0667

Wastewater

Wastewater

Spent

Caustic/HC

Slop Oil

Slop Oil

Slop Oil

Slop Oil

Wastewater

Wastewater

Wastewater

Wastewater

Slop Oil

Slop Oil

Slop Oil

Wastewater

Wastewater

Wastewater

Wastewater

Slop Oil

Physical

Capacity

(gallons)

Roof

Type

564 HFR

10,403

HFR

1,900

HFR

586,200

EFR

490,573

EFR

490,573

EFR

21,995

IFR

490,573

EFR

490,573

EFR

490,573 EFR

490,573

EFR

256,651

EFR

256,651 EFR

21,995

IFR

3,363,962

VFR

3,377,423 VFR

3,077,933

EFR

3,752,617

EFR

21,995 IFR

1943

1993

1991

1991

1991

1991

1991

1991

1992

1991

1992

1993

1923

1923

1923

1991

1991


DRAFT

20

EU ID

EU ID

Point ID

Point ID

Normal

Contents

Normal

Contents

Physical

Capacity

(gallons)

Roof

Type

Roof

Type

Construction/

Modification

Date

T-0669 T-0669

Spent

Caustic/HC

270,401

EFR 1991

T-0701

T-0702

T-0703

T-0704

T-0705

T-0706

T-0701

T-0702

T-0703

T-0704

T-0705

T-0706

Slop Oil

Slop Oil

Slop Oil

Wastewater

Wastewater

Wastewater

256,651

EFR

256,651

EFR

22,068 IFR

270,401

EFR

270,401

EFR

270,401 EFR

1991

1991

1991

1991

1991

1991

T-0909

T-0910

T-0909

T-0910

Spent

Caustic/HC

Slop Oil

661,945 IFR

663,215

IFR

1943

1943

D-0777, D-0779, D-5292, T-0651, and T-0652 were or are currently in MACT Group 2 wastewater service. However, the vessels can be operated with carbon canister controls such that they could store a Group 1 material, and the facility prefers to list the tanks with Group 1 wastewater tanks.


Streams Handled by Storage Tanks

Physical

Capacity

(gallons)

Construction/

Modification

Date

D-0232

D-0774

D-0775

D-0776

D-0780

D-0783

D-0786-1

D-0787

D-6801

D-6812

T-0016 E

T-0055

T-0069

T-0071

T-0080

T-0140

D-0232

D-0774

D-0775

D-0776

D-0780

D-0783

D-0786-1

D-0787

D-6801

D-6812

T-0016 E

T-0055

T-0069

T-0071

T-0080

T-0140

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Spent

Caustic/HC

Slop Oil

Slop Oil

Wastewater

Slop Oil

Wastewater

924

10,300

10,300

10,300

10,403

3,475

564

564

5,000

16,044

104,351

433,871

443,105

428,494

105,000

4,053

HFR

HFR

HFR

HFR

HFR

HFR

HFR

HFR

VFR

HFR

VFR

VFR

VFR

VFR

VFR

VFR

1989

1990

1990

1990

1990

1990

Est. 1990

1990

1964

1991

1939

1926

1921

1926

1941

1990


DRAFT

21

EU ID Point ID

Normal

Contents

Physical

Capacity

(gallons)

Roof

Type

Construction/

Modification

Date

T-0173

T-0648

T-0680

T-0173

T-0648

T-0680

Brine

Water/HC

Wastewater

ASU Lift

Station overflow

Sour Water

Sour Water

5,558

4,576

250,000

VFR

VFR

OT

1992

1992

1993

T-0907

T-0908

T-0944

T-0966

T-0973

T-0907

T-0908

T-0944

T-0966

T-0973

Sour Water

Slop Oil

Spent

Caustic/HC

1,056,563

1,052,278

1,043,961

14,161

213,523

IFR

IFR

IFR

VFR

VFR

1943

1943

1944

1945

1960

T-0974

T-6601

T-0974

T-6601

Spent

Caustic/HC

Caustic/HC

110,446

14,687

VFR

VFR

1960

1951

EUG TNK-6: 40 CFR Part 63 Subpart EEEE (OLD MACT) Fixed Roof Storage Tanks

The facility is an existing source for the purposes of 40 CFR Part 63 Subpart EEEE. The compliance date for existing sources was February 5, 2007.

EU ID

D-5250

EP Methanol

Tote

T-0017

T-0018

T-0018 E

T-0027

T-0057

T-0058

T-0104

T-0212 E

T-0230

T-0542

TNK-Misc.

Vendor

Point ID Normal Contents

D-5250

Physical

Capacity

(gallons)

Vendor Chemical 2,100

EP Methanol

Tote

T-0017

T-0018

T-0018 E

T-0027

T-0057

T-0058

T-0104

T-0212 E

T-0230

T-0542

TNK-Misc.

Vendor

Methanol

Perchloroethylene

Per-

Methanol

Methanol

Methanol

Methanol

Vendor Chemical

Glycol Water

Methanol

Vendor Chemical

400

350

550 chloroethylene

Vendor Chemical 2,153

550

550

550

1,680

564

4,230

550

< 5,000

Roof

Type

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

VFR

Construction/

Modification

Date

Pre-2004

2006

1994

1994

1990

2006

2005

2005

1922

1971

Pre-2004

Pre-2000

Any


DRAFT

22

EU ID Point ID Normal Contents

Physical

Capacity

(gallons)

Roof

Type

Construction/

Modification

Date

Tanks/ Totes Tanks/ Totes

EUG TNK-7: Storage Tanks Subject to Oklahoma Rules or Permit Requirements Only

EU ID Point ID

Normal

Contents

Physical

Capacity

(gallons)

2,016

2,016

Roof

Type

VFR

VFR

Construction/

Modification

Date

1986

2005

T-0024

T-0186

T-0024

T-0186

Gasoline

Dye

TNK-MP

Gasoline

TNK-MP

Gasoline

Gasoline

EUG TNK-8: Insignificant Activity Storage Tanks

1,000 VFR 2002

EU ID Point ID Normal Contents Insignificant Activity Reason (1)

D-0060

D-0062

D-0066

D-0067

D-0077

D-0078

D-0079

D-0234

D-0409

D-0669

D-0700

T-0005

D-0060

D-0062

D-0066

D-0067

D-0077

D-0078

D-0079

D-0234

D-0409

D-0669

D-0700

T-0006 T-0006

T-0006 E T-0006 E

T-0007

T-0005

T-0007

Liquids Recovery

(gasoline)

App. I: Miscellaneous - < 5

TPY

Proto Tank 3B – Gasoline App. I: Miscellaneous - < 5

TPY


TPY

Proto Tank 3A – Gasoline App. I: Miscellaneous - < 5

TPY

Proto Tank 2A – Gasoline App. I: Miscellaneous - < 5

TPY


TPY

Proto Tank 1A – Gasoline App. I: Miscellaneous - < 5 TPY

Dye

App. I: Storage Tanks/Distribution

- < 40,000 gal / < 1.5 psia

Corrosion Inhibitor

Spent Caustic


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia

Spent Caustic

Fuel Stabilizer (Day Pot, T-

973267)

Antioxidant

Diesel fuel

Manganese Additive


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


DRAFT

23

EU ID

T-0085

T-0086

T-0087

T-0221

T-0224

T-0247

T-0265

T-0266

T-0267

T-0513

T-0530

T-0534

T-0008

T-0011

T-0012

T-0014

T-0008

T-0011

T-0012

T-0014

T-0015 E T-0015 E

T-0023

T-0028

T-0031

T-0084

T-0023

T-0028

T-0031

T-0084

T-0085

T-0086

T-0087

T-0221

T-0224

T-0247

T-0265

T-0266

T-0267

T-0513

T-0530

T-0534

Point ID Normal Contents Insignificant Activity Reason (1)

Kerosene wash tank

Pressed Alky Sludge Mix

Tank

Jet Water Pump Surge,

Fines Filtering

Diesel fuel

Fuel oil additive

Diesel Storage at Fuel

Pump

Reclaimed Oil

Spent Naphthenic Caustic

Emulsion Breaker (T-

980190)

Emulsion Breaker (T-

930269)

Filmer (T-930272)

Corrosion Inhibitor (T-

930270)

Diesel fuel

Diesel Fuel

Training Tank (Salvage yard)

Antifoam tote

Antifoam tote

Antifoam tote

Pour Point Depressant (T-

960590)

Antifreeze (ethylene glycol)

Diesel fuel


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal/ < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia



EU ID Point ID

T-0535

T-0603

T-0604

T-0535

T-0603

T-0604

T-0649

T-0922

T-0649

T-0922

T-0923 T-0923

T-890848 T-890848

T-900670 T-900670

T-900671 T-900671

T-942232 T-942232

T-951509 T-951509

T-960590 T-960590

T-970228 T-970228

T-970244 T-970244

T-970245 T-970245

T-970246 T-970246

T-971286 T-971286

T-972868 T-972868

T-982607 T-982607

T-BETZ

SBC

T-BETZ

SBC

DRAFT

24

Normal Contents

Diesel fuel

Diesel fuel

Diesel fuel

Polymer Additive for

Lagoon

Diesel fuel

Diesel fuel

Neutralizer

Corrosion Inhibitor

Emulsion Breaker

Antioxidant

Metal Passivator

Pour Point Depressant

Antioxidant

Biocide

Corrosion Inhibitor

Deposit Control Agent

Metal Passivator

Fuel Stabilizer

Red dye

Pour Point Depressant

Insignificant Activity Reason (1)

- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


DRAFT

25

EU ID Point ID Normal Contents Insignificant Activity Reason (1)

8Q506

TNK-Fire

Training #1

TNK-Fire

Training #2

TNK-

GFMHL #1

TNK-

GFMHL #2

TNK-

GFMST

TNK-Misc.

Vendor

Totes /

Tanks

TNK-MP

Diesel

8Q506

TNK-Fire

Training

#1

TNK-Fire

Training

#2

TNK-

GFMHL

#1

TNK-

GFMHL

#2

TNK-

GFMST

TNK-

Misc.

Vendor

Totes /

Tanks

TNK-MP

Diesel

Kerosene storage at Fire

Training Grounds

Kerosene Storage at Fire

Training Grounds

Gasoline fuel

Diesel fuel

Diesel fuel

Vendor chemicals with

TVP < 1.0 psia and containing < 4% RM1

HAPs, < 5% OLD MACT

HAPs, or inorganic

Diesel fuel


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


TPY


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia

1. Tanks that are insignificant due to emissions being less than 5 TPY require recordkeeping.

HEATERS & BOILERS

EUG HTR-1: 40 CFR Part 60 Subparts J & Db, and 40 CFR Part 63 Subpart DDDDD

Boilers

EU ID Point ID Equipment

Fired Duty

MMBtu/hr

Construction/

Modification Date

B-0008 B-0008

B-0009/0010 B-0009/0010

Steam Boiler

Steam Boiler

483

734

(1)

1. The boilers share a common stack. The fired duty shown is a total for both boilers.

2003

2005

EUG HTR-2: 40 CFR Part 60 Subpart J and 40 CFR Part 63 Subpart DDDDD

(Heater/Boiler MACT) Heaters & Boilers

Note: The Consent Decree requires all of the facility’s heaters and boilers that combust refinery fuel gas to be subject to Subpart J, regardless of the construction or modification date.


EU ID

B-0006

B-0007

B-5004

H-0001

H-0003

H-0004

H-0005

H-0010

H-0011

H-0016

H-0023

H-0028

H-0029

H-0046

H-0048

H-0057

H-0058

H-0059

H-1001

H-5001

H-5002

H-6005

H-6007

H-6008

H-6012

H-6013

(5)

Point ID

B-0006

B-0007

No. 5 FCCU/B-

5004

H-0001

H-0003

H-0004

H-0005

H-0010

H-0011

H-0016

H-0023

H-0028/0029

H-0028/0029

H-0046

H-0048

H-0057/58/59

H-0057/58/59

H-0057/58/59

H-1001

H-5001

H-5002

H-6005

H-6007

H-6008

H-6012

H-6013

DRAFT

26

Equipment

Steam Boiler

Steam Boiler

Waste Heat Boiler

No. 1 CTU Atm

Tower Feed Heater

No. 4 CVU Feed

Heater

No. 4 CTU Feed

Heater

No. 1 CTU Tar

Stripper Feed Heater

Saturate Gas Plant

Naphtha Reboiler

No. 7 HDT Heater

No. 1 CVU Feed

Heater

No. 5 HDT Heater

No. 7 Coker Heater

No. 7 Coker Heater

No. 2 HDS Feed

Heater

No. 2 CRU Heater

Alky Depropanizer

Heater

Alky Depropanizer

Heater

Alky Depropanizer

Heater

No. 4 HDT Heater

No. 5 FCCU Feed

Preheater

No. 5 FCCU Feed

Preheater

No. 2 CTU Preflash

Reboiler Heater

No. 3 CRU Heater

Butane Dryers

Regenerator Heater

No. 3 HDS Heater

No. 3 CRU Heater

Fired Duty

MMBtu/hr

>250

>250

Construction/


1953

Pre-8/17/71

>250 1977 / 2002

(1,2)

175

28.0

106

85.0

55.0

15

107

52.4

129

75.0

48.0

241

70.0

49.0

70.0

30.0

104

120

157

150

2.0

25.0

75.8

1949 / 1987

1929/2002

1945/2002

1940

1972

1988

2004

1984

1954

1983

1964

1957

1974

1974

1974

2005

1944

Construction planned for 2007

1997

1956 / 1990

(1,2)

1955

1971

2002

(1,2)

(1,2,3)

(1,2,3)


DRAFT

27

EU ID

EU ID

Point ID

Point ID

Equipment

Equipment

Fired Duty

MMBtu/hr

Construction/


H-6014

H-6015

H-6151

H-7501

H-6014

H-6015

H-6151

H-7501

No. 2 CVU Feed

Heater

No. 2 CTU Feed

Heater

No. 4 FCCU Feed

Preheater

No. 6 HDT Heater

80.0

95.0

80.0

41.0

1978

1980

1958

1991

H-8601

H-8602

H-8601

H-8602

No. 8 HDT Splitter

Reboiler Heater

No. 8 HDT Heater

No. 1 Hydrogen Plant

120

36.0

2003 (Pre-12/13/03)

2003 (Pre-12/13/03)

H-8801/8802 H-8801/8802

H-9851

H-9901

H-9851

H-9901

Reformer Heater


Reformer Heater

No. 9 HDT Heater

123

282

40.0

2003 (Pre-12/13/03)

2005

2005

H-9902

NH-0057

(4)

H-9902

NH-0057

No. 9 HDT Stripper

Reboiler Heater

Alky Depropanizer

Heater

50.0

128

2005

Construction planned for 2007

1. Subchapter 31 modification.

2. Subchapter 33 modification.

3. NSPS modification or reconstruction.

4. Will replace H-0057, H-0058, and H-0059.

5. Will replace H-5001.

EUG HTR-3: Heaters & Boilers Subject to Oklahoma Rules, Permit Limits, or 40 CFR

Part 63 Subpart DDDDD (Heater/Boiler MACT)

Fired Duty

MMBtu/hr

Construction/


BLR-GFMST1 BLR-GFMST1

H-6037A/

6037B

HTR-5FCC

Converter Air

Preheater

No. 4 FCCU

No. 5

FCCU/B-5004

South Tower

Emergency Boiler

No. 4 FCCU Startup

Preheater

No. 5 FCCU

Converter Startup

Preheater

6.3

23.4

<50

Est. Post-1974

1988

1971


EUG HTR-4: Insignificant Activity Heaters & Boilers

DRAFT

28

EU ID Point ID Equipment Insignificant Activity Reason

BLR-

GFMNT1

BLR-GFMNT1

BLR-GFMPB1 BLR-GFMPB1


North Tower

Emergency Boiler

Park Bldg Boiler

#1

Park Bldg Boiler

#2

App. I: Combustion Equipment-

Commercial Nat. Gas < 5 MMBtu/hr





MISCELLANEOUS

EUG ENG-1: Fuel-Fired Engines Subject to Oklahoma Rules Only


Horse power

Construction/

Modification

Date

E-0036

E-0068

E-0036

E-0068

Maintenance portable power generator engine

Sat Gas Unit engine

308

550

600

Est. 2002

1950’s

1941 E-0072

ENG-ASU

Portable

E-0072

ENG-ASU

Portable

Sat Gas Unit engine

ASU portable backup air compressor engine

213 1987

ENG-EP

Portable

ENG-MPP

Portable #1

ENG-MPP

Portable #2

ENG-EP

Portable

ENG-MPP

Portable #1

ENG-MPP

Portable #2

East Plant portable backup air compressor engine

Main Power Plant portable backup air compressor engine

Main Power Plant portable backup air compressor engine

213

450

450

1989

Est. Post-1974

Est. Post-1974

ENG-SP

Portable #1

ENG-SP

Portable #2

ENG-SP

Portable #1

ENG-SP

Portable #2

South Plant portable backup air compressor engine


425

425

Pre-12/19/02

Pre-12/19/02


EUG ENG-2: Insignificant Activity Engines

EU ID

E-0049

E-0050

E-0051

E-0075

E-0110

E-0111

ENG-Alky

ENG-GFMCB

ENG-GFMSB

ENG-GFMST

ENG-GFMPB

Point ID

E-0049

E-0050

E-0051

E-0075

E-0110

E-0111

ENG-Alky

ENG-GFMCB

ENG-GFMSB

ENG-GFMST

ENG-GFMPB

DRAFT

29

Equipment

Gasoline fuel research engine






Emergency power generator engine

Continental Bldg generator engine for emergency backup power

Security Bldg generator engine for emergency backup power

South Tower generator engine for emergency backup power

Park Building generator engine for emergency backup power

Insignificant Activity

Reason

App. I: Combustion Equip. –

Internal combustion engines

<50 hp



<50 hp



<50 hp



<50 hp



<50 hp



<50 hp

App. I: Combustion

Equipment – Emerg. Power

Generation < 500 hr/yr

App. I: Combustion



App. I: Combustion



App. I: Combustion



App. I: Combustion




DRAFT

30

EUG ENG-3: Emergency Fuel-Fired Engines Subject to 40 CFR Part 60 Subpart IIII

EU ID Point ID Equipment HP

Displacement

(L/cylinder)

Construction/

Modification

Date

ENG-

GFMMB

ENG-

E5017

ENG-

GFMMB

ENG-

E5017

Microwave building generator for emergency backup power

SP Firewater Pump

Engine

135

484

<10

<30

Mfr’d 9/06

Mfr’d 2007

ENG-

E5018

EU ID

ENG-

E5018

SP Firewater Pump

Engine

Point ID

484

Equipment

<30

Mfr’d 2007

EUG FCC-1: Fluid Catalytic Cracking Unit Catalyst Regenerators Subject to 40 CFR Part

60 Subpart J and 40 CFR Part 63 Subpart UUU (Refinery MACT II)

Construction/


No. 4 FCCU No. 4 FCCU

No. 4 Fluidized Bed Catalytic

Cracking Unit Catalyst Regenerator

1951

No. 5 FCCU/

B-5004

No. 5 FCCU/

B-5004

No. 5 Fluidized Bed Catalytic

Cracking Unit Catalyst Regenerator

1952 / 1972 (SC 35 mod)

EUG CRU-1: Catalytic Reforming Unit Catalyst Regenerator Vents Subject to 40 CFR

Part 63 Subpart UUU (Refinery MACT II)


Construction/


No. 2 CRU

No. 3 CRU

No. 2 CRU

No. 3 CRU

No. 2 Catalytic Reforming Unit

Catalyst Regenerator Vent



EUG FLR-1: Flares Subject to 40 CFR Part 60 Subpart J

1957

1956

EU ID

Flare-CC

Flare-CF

Flare-EP

Flare-SF

Flare-SP

Flare-Temp

Point ID

Flare-CC

Flare-CF

Flare-EP

Flare-SF

Flare-SP

Flare-Temp

Equipment

Coker/Combo Alky Flare

Clean Fuels and West Plant Flare

East Plant Flare

Santa Fe Loading Rack Flare

South Plant Flare

Temporary Flare

Construction/


1970

2003

1990

2002

1972

1994


DRAFT

31

EUG LOD-1: Loading Racks Subject to 40 CFR Part 63 Subpart CC (Refinery MACT I)


Construction/


Load-SF

EU ID

Flare-SF

Point ID

Santa Fe Loading Rack (Gasoline)

Equipment

1997

EUG LOD-2: Loading Racks Subject to Oklahoma Rules or Permit Requirements Only

Construction/


Load-SP Load-SP

South Plant Loading Rack

(Distillates)

EUG LOD-3: Insignificant Activity Loading Racks

Est. 1930’s


Load-Refuel Load-Refuel

Load-Refuel#2 Load-Refuel#2

Load-SF Load-SF

Refinery Vehicle

Refueling

Motor Pool Vehicle

Refueling

Santa Fe Loading

Rack (Distillates)




TPY

TPY

TPY

EUG VNT-1: 40 CFR Part 63 Subpart CC (Refinery MACT I) Group 1 Miscellaneous

Process Vents


Construction/


VNT-D0749

VNT-T0039E

VNT-SFLR

VNT-D6004

Flare-CC

Flare-EP

Flare-SF

Flare-EP

D-749 Merox disulfide separator drum

T-39E sour water tank

Gasoline loading rack vapor collection system

D-6004 No. 2 CTU desalter water surge drum

2001

1932

1997

1990


DRAFT

32


Process Vents


Construction/


VNT-6015 Flare-EP

VNT-D0565 Flare-EP

VNT-D0701 VNT-D0701

VNT-D0702 VNT-D0702

VNT-D0704 VNT-D0704

VNT-D0714 VNT-D0714

VNT-D0717 Flare-CC

VNT-D0741 Flare-CC

VNT-D0748 Flare-CC

VNT-D5173 VNT-D5173

VNT-D5209 Flare-EP

VNT-D6201 Flare-EP

VNT-D6903 Flare-EP

VNT-D6933 Flare-EP

VNT-Load SF

LPG

VNT-Load SF

VNT-Load SF

Toluene

VNT-Load SP

LPG

VNT-Load SF

Toluene

VNT-Load SP

VNT-T0256 Flare-CC

VNT-W0193 Flare-CC

No. 3 Reformer hydrogen recycle compressor seal oil pot vent

D-565 No. 3 CRU chloride trap

D-701 vent/drain

D-702 vent/drain

D-704 vent/drain

D-714 vent/drain

D-717 depropanizer overhead reflux

D-741 ASO/KOH separator

D-748 fuel gas drum

D-5173 vent/drain

D-5209 Fuel gas drum liquid

D-6201 No. 4 FCC dry drum

D-6903 No. 3 HDS sep drum

D-6933 H2S stripping pot

Loading vent line purge to atmosphere

Toluene unloading vent to atmosphere

Loading and vent line purge to atmosphere

Alky flare slop tank vent

W-193 overhead non-condensables

EUG VNT-3: Atmospheric Process Vents Subject to Oklahoma Rules Only

1971

Est. 1930’s

Est. 1930’s

1997

1932

1970

1959

1970

1970

1970

1970

1997

1985

1971

1944

1944

1971

1959

1968


Construction/


VNT-C0008

VNT-C5017

VNT-C0008

VNT-C5017

Sat Gas Plant Compressor Distance

Piece Vent

Sat Gas Plant Compressor Distance

Piece Vent

1968

1941

EUG VNT-4: Atmospheric Process Vents with No Applicable Requirements


Construction/


VNT-D9857 VNT-D9857

No. 2 Hydrogen Plant Deaerator

Vent

2005


DRAFT

33

EUG VNT-5: Insignificant Activity Atmospheric Process Vents


VNT-C0024

VNT-C0060

VNT-C0061

VNT-C0125

VNT-C5037

VNT-C0024

VNT-C0060

VNT-C0061

VNT-C0125

VNT-C5037

No. 5 HDT Hydrogen

Compressor Distance Piece

Vent

No. 7 HDT Compressor

Distance Piece Vent


Distance Piece Vent

No. 3HDS Compressor

Distance Piece Vent

Butamer Hydrogen


Vent

App. I: Miscellaneous –

< 5 TPY


< 5 TPY


< 5 TPY


< 5 TPY


< 5 TPY

VNT-D0809

VNT-D8806

VNT-D0809

VNT-D8806

Hydrogen Makeup Vent


Deaerator Vent


< 5 TPY


< 5 TPY


EUG FUG-1: Fugitive Equipment Leaks Subject to 40 CFR Part 63 Subpart CC (Refinery

MACT I) and/or 40 CFR Part 60 Subpart GGG

EU ID

Refinery-Wide

Piping

Equipment

Fugitive Leaks

Point ID

Refinery-Wide

Piping

Equipment

Fugitive Leaks

Equipment

LL = Light Liquid

HL = Heavy Liquid

Gas Valves

LL Valves

HL Valves

Flanges

LL Pump Seals

HL Pump Seals

Gas Compressors

Gas Relief Valves to Atm

Gas Relief Valves to Flare

Sample Stations


Reason

Approx.

Number of Items

Construction/

Modification

Date

18,661 Various

23,270

14,482

27,856

Various

Various

Various

370 Various

289 Various

19 Various

539 Various

13 Various

587 Various


DRAFT

EUG FUG-2: Fugitive Oily Water Sewer System Component Leaks Subject to 40 CFR

Part 63 Subpart CC (Refinery MACT I) and 40 CFR Part 61 Subpart FF (BWON)

EU ID

FUG-Coker

ORU

Point ID

FUG-CC

Equipment

WDB = water draw box

Process drains

Junction boxes/sumps/WDB

Approx.

Number of Items

27

6

Construction/

Modification

Date

1991

1991

FUG-1HP,

2HP, 2Isom,

8HDT, 9HDT

& FGRU

FUG-2CTU,

3CRU, 4FCC &

ORU

FUG-CF

FUG-EP

Process drains


Process drains


145

52

177

33

2003

2003

Various

Various

FUG-WP ORU FUG-WP

FUG-OM Tank

Farm &

WWTS

FUG-SP Tank

Farm

FUG-OM

FUG-SP

Process drains


Process drains


Process drains


19

8

0

27

0

3

1991

1991

NA

Various

NA

Various


Part 60 Subpart QQQ

EU ID

FUG-6HDT

Point ID

FUG-CC

Equipment

(WDB = water draw box)

Process drains


Approx.

Number of Items

13

12

Construction/

Modification

Date

1991

1991

50 2005

FUG-2H2

Plant & 9HDT

FUG-7HDT

FUG-2SWS

FUG-CF

FUG-WP

FUG-SP

Process drains


Process drains


Process drains


15

29

13

11

0

2005

1988

1988

2005

2005

34


DRAFT

35

EUG FUG-4: Fugitive Oily Water Sewer System Component Leaks Subject Only to 40

CFR Part 61 Subpart FF (BWON) Exemption Recordkeeping Requirements


Approx.

Number of Items

78

Construction/

Modification

Date

Various

Refinery-Wide

Oily Water

Sewer

Component

Fugitive Leaks

Refinery-Wide

Oily Water

Sewer

Component

Fugitive Leaks

Process drains (controlled)

Process drains

(uncontrolled)

Junction boxes/sumps

(controlled)

Closed drains


(uncontrolled)

2,118

0

243

303

Various

Various

Various

Various

EUG FUG-5: Fugitive Storm Sewer System Component Leaks with No Applicable

Requirements



Approx.

Number of Items

0

Construction/

Modification

Date

Various

Refinery-Wide

Storm Sewer

Equipment

Fugitive Leaks

Refinery-Wide

Storm Sewer

Equipment

Fugitive Leaks

Process drains

(uncontrolled)


(controlled)


(uncontrolled)

108

0

33

Various

Various

Various

EUG FUG-6: Cooling Tower Fugitive Sources Subject to Oklahoma Rules or Permit

Requirements Only


Construction/


Y-0002

Y-0002A

Y-0003

Y-0005

Y-0006

Y-0007

Y-0009

Y-0002

Y-0002A

Y-0003

Y-0005

Y-0006

Y-0007

Y-0009

West Plant Marley EPHCC01

Cooling Tower

West Plant Marley 6615302 Cooling

Tower

Coker Cooling Tower

South Plant North & South Loop

Cooling Tower

Combo Cooling Tower

Main Power Plant Cooling Tower

ASU Cooling Tower

1953

1973

1946

1943

1956

1959

1992


DRAFT

36

EU ID

EU ID

Point ID

Point ID

Equipment

Equipment

Construction/


Y-0010

Y-6026

Y-0010

Y-6026

Alky Cooling Tower

East Plant Marley Cooling Tower

1971

1953

Y-6027

Y-8000

Y-6027

Y-8000

East Plant Pritchard Cooling Tower

Clean Gasoline Unit Cooling Tower

1956

2003

EUG FUG-7: Materials Handling Fugitive Sources Subject to Oklahoma Rules or Permit


Construction/


Coke Handling

Facility

Coke

Handling

Facility

Railcar Unloading, Truck Loading,

Coke Crushing, Drop Points, Wind

Erosion, Coke Truck Traffic

EUG FUG-8: Insignificant Activity Fugitive Sources


1998


Reason

Landfarm Landfarm

Application of ASU biosludge to landfarm

FACILITY-WIDE

EUG FW: Facility-Wide Applicable Requirements

Source-specific equipment information is not necessary for this EUG.

App. I: Fugitives – Land farms

SECTION VI. STACK PARAMETERS

The following stack parameters, used for SO

2

air impacts modeling, were obtained from the PSD permit applications for Permit No. 2003-336-C (M-2) PSD and Permit No. 2007-042-C PSD.

Description

B-0006

B-0007

B-0008

B-0009/B-0010

Flare-CC

Flare-CF

Flare-EP

Flare-SF

UTM E

(m)

UTM N

(m)

670905 4061746

670918 4061768

670873 4061768

670858 4061862

670848 4061096

670607 4061868

671224 4062055

670958 4061568

Elevation

(m)

302

303

303

301

300

302

294

302

Height

(m)

48.77

48.77

45.72

22.86

45.72

60.96

68.58

15.24

Temp

(°K)

403

480

422

422

1273

1273

1273

1273

Velocity

(m/s)

16.31

9.36

3.84

5.50

20.00

20.00

20.00

20.00

Diameter

(m)

1.83

2.29

2.59

1.83

0.06

1.00

0.09

1.00


DRAFT

37

Description

Flare-SP

H-0001

H-0003

H-0004

H-0005

H-0010

H-0011

H-0016

H-0023

H-0028/0029

H-0046

H-0048

H-0057/58/59

H-1001

H-5001

H-6005

H-6007

H-6008

H-6012

H-6013

H-6014

H-6015

H-6151

H-7501

H-8601

H-8602

H-8801/8802

H-9851

H-9901

H-9902

No. 4 FCCU

No. 5FCCU/B-5004

UTM E

(m)

UTM N

(m)

671403 4060473

670830 4061654

670902 4061656

670883 4061668

670862 4061655

670817 4061570

670843 4061564

670834 4061570

671165 4061409

671058 4061508

671012 4061195

671011 4061181

670825 4061299

671043 4061253

671245 4060905

671173 4062213

671148 4062239

671300 4060911

671157 4062232

671171 4062232

671162 4062209

671239 4062183

671255 4062243

671120 4061398

670756 4061848

670757 4061821

670797 4061893

670696 4061896

670719 4061983

670713 4061952

671245 4062237

671200 4060859

SECTION VII. EMISSIONS

Criteria Pollutants

Temp

(°K)

829

783

661

728

580

691

501

650

644

642

1273

589

695

612

675

544

651

450

628

668

821

450

650

650

650

493

523

639

660

671

589

644

Height

(m)

28.96

53.34

30.50

38.10

43.59

36.58

10.67

27.49

27.46

45.72

60.35

30.48

30.48

35.66

36.58

30.48

30.48

30.48

30.48

50.60

18.29

45.72

40.54

22.40

39.62

39.62

39.62

30.50

30.50

30.50

53.34

53.34

Elevation

(m)

300

305

300

299

299

308

300

304

305

299

298

302

302

302

302

302

302

302

304

302

304

304

304

304

304

296

305

296

299

304

302

302

Emissions estimates are based on the refinery operating 24 hours per day, every day of the year.

Emission estimates are the potential to emit (PTE) and were either calculated using the maximum inherent refinery process unit throughputs or permit-limited process unit/individual source throughputs.

For heaters and boilers, the firing rates shown are based on the higher heating value (HHV) of the fuel combusted. Emission estimates are based on emission factors (converted to lb/MMBtu) from either AP-42 Chapter 1.4 (7/98), vendor data, stack test data, or permitted limits.

SO

2

Velocity

(m/s)

64.55

4.35

10.00

18.78

13.51

28.48

4.92

4.64

7.95

4.04

20.00

7.99

3.76

7.28

6.24

5.70

4.72

17.37

20.79

22.87

14.58

11.15

9.84

12.63

6.15

6.07

17.37

10.00

10.00

10.00

24.79

14.10

Diameter

(m)

1.46

2.99

0.91

1.83

1.98

1.62

0.76

1.28

1.74

2.10

0.08

2.07

1.52

1.92

1.83

1.43

0.91

1.83

0.91

2.29

1.01

1.80

1.46

0.91

2.36

1.45

1.83

1.22

1.22

1.22

1.37

2.59


DRAFT

38 emissions from heaters and boilers fired with refinery fuel gas (RFG) are based on a hydrogen sulfide content of 0.10 gr/dscf (160 ppmvd @ 60˚F) and a higher heating value of 867 Btu/scf.

SO

2

emissions from heaters and boilers fired with commercial grade natural gas (<0.25 gr

H

2

S/100 scf, or < 4 ppmv H

2

S) are based on the AP-42 Chapter 1.4 (7/98) emission factor.

Emission estimates for gasoline, diesel, and natural gas-fired engines are based on AP-42

Chapter 3.3 (10/96) or manufacturer’s data where available.

Emission estimates for the fluid catalytic cracking units were taken from current permit limits or based on stack test data.

Catalytic reforming unit catalyst depressuring and purging operation emissions are vented to flare and are included in flare emissions.

VOC emissions from storage tanks were calculated using the EPA program TANKS 4.09 and are based on either permitted limits or historic values multiplied by the ratio of current yearly average refinery target crude rate of 184,000 barrels over historic crude rates. For out-of-service tanks where historic data was unavailable, throughputs were estimated based on 12 turnovers per year.

VOC emissions from fugitive components (valves, flanges, pump seals, etc.) were estimated using emission factors that were developed specifically for the Ponca City Refinery. The factors are given in Table 2-1 in a March 1, 1991 letter from Conoco to DEQ titled “Refinery Specific

Fugitive Emission Factors – Ponca City Refinery.”

VOC emissions from sewer and API separator fugitive sources were estimated using factors from

AP-42 Table 9.1-2 (1/95) and “VOC Emissions from Petroleum Refinery Wastewater Systems -

Background Information for Proposed Standards”, EPA-450/3-85-001a, Feb. 1985, which is the

Background Information Document (BID) for NSPS Subpart QQQ .

VOC emissions from the gasoline loading flare were based on the 40 CFR Part 63 Subpart R limitation of 10 mg/L of gasoline loaded. VOC emissions from other flares were based on a factor from AP-42 Table 13.5-1 (1/95). NO

X

and CO emissions from flares were based on published Texas Commission on Environmental Quality (TCEQ) factors (October 2000). SO

2 emissions from flares were calculated based on a stoichiometric conversion of all H

2

S to SO

2

.

There are no published emission factors for PM emissions from flares. The flares are steam assisted and steam is continually injected to improve air and gas mixing which eliminates the formation of particulates during normal operations.

VOC emissions from non-gasoline loading were estimated using the techniques of “Gasoline

Distribution Industry (Stage I) – Background Information for Promulgated Standards” (EPA-

453/R-94-002b). VOC emissions from LPG loading hose purging was estimated using process knowledge.

VOC emissions from Miscellaneous Process Vents were estimated based on process knowledge.


DRAFT

39

Fugitive VOC emissions from cooling towers were estimated using factors from AP-42 Table

5.1-2 (1/95). Fugitive PM

10

emissions were based on AP-42 Section 13.4 (1/95) methodology for induced draft wet cooling towers.

Coke Handling Facility emission points include those from coke handling, coke processing, wind erosion, and truck traffic. Various sections of AP-42 were used to estimate PM emissions: 13.2.2

Unpaved Roads (12/03), 13.2.4 Aggregate Handling and Storage Piles (1/95), 13.2.5 Industrial

Wind Erosion (1/95), and 11.19.2.2 Construction Aggregate Processing (9/85).

Emissions are shown to a precision of 0.1 lb/hr and 0.1 TPY. Emissions from a source that are less than 0.05 lb/hr or less than 0.05 TPY are shown as zero, but are included in the total emissions for that particular EUG.


EU ID Point ID

T-0021E T-0021E

T-0101 T-0101

T-0114 T-0114

T-0148

T-0149

T-0150

T-0151

T-0148

T-0149

T-0150

T-0151

T-0153

T-0154

T-0155

T-0158

T-0159

T-0160

T-0162

T-0163

T-0153

T-0154

T-0155

T-0158

T-0159

T-0160

T-0162

T-0163

T-0164

T-0167

T-0170

T-0901

T-0902

T-0953

T-0164

T-0167

T-0170

T-0901

T-0902

T-0953

Normal Contents

Naphtha

Alkylate

Gasoline

Gasoline

Gasoline

Gasoline

Gasoline

Reformate

Reformate

Gasoline

Gasoline

Gasoline

Gasoline

Gasoline

LSR Gasoline

LSR Gasoline

Gasoline

Gasoline

Gasoline

Naphtha

Gasoline

SUBTOTAL

Throughput (gal/yr)

8,326,551

3,650,000

3,650,000

77,186,187

80,559,454

217,296,246

286,395,515

218,099,452

341,066,578

274,511,807

221,086,345

96,937,991

159,612,600

454,757,898

343,980,00

27,886,000

4,251,920

96,690,329

252,000,000

252,000,000

252,000,000

0.7

4.7

4.7

3.5

41.4

2.0

1.0

1.1

1.4

1.1

1.8

4.8

0.0

VOC Emissions lb/hr

0.5

1.9

TPY

2.3

8.4

1.9

2.1

1.2

1.3

1.3

0.5

3.8

8.4

9.1

5.4

5.5

5.7

2.4

16.7

8.6

4.4

4.8

6.1

5.0

7.8

21.2

0.1

3.2

20.5

20.5

15.3

181.2


DRAFT

40



EU ID

T-0014E

T-0017E

T-0015

T-0117

T-0119

T-0121

T-0141

T-0147

T-0156

T-0165

T-0166

T-0176

T-0177

T-0178

T-0357

T-0402

T-0540

T-0690

Point ID

T-0014E

T-0017E

T-0015

T-0117

T-0119

T-0121

T-0141

T-0147

T-0156

T-0165

T-0166

T-0176

T-0177

T-0178

T-0357

T-0402

T-0540

T-0690

Normal Contents

Naphtha

Crude Oil

Naphtha

Naphtha

Naphtha

Diesel

Slop Oil

Naphtha

Gasoline

Alkylate

Gasoline

Toluene

Toluene

Aviation Gasoline

Slop Oil

Slop Oil

Methanol

Slop Oil

SUBTOTAL


2,001,300

40,214,016

2,001,300

636,384,000

630,000,000

168,000,000

1,500,000

252,000,000

504,000,000

229,950,000

630,000,000

191,625,000

2,636,812

191,625,000

436,800

218,400

132,842

840,000

VOC lb/hr

0.7

TPY

3.3

0.8

0.8

3.6

7.6

3.6

3.3

15.8

33.5

2.6

5.1

2.3

4.0

8.0

6.4

1.3

0.8

1.1

0.7

0.7

0.0

0.7

47.3

4.8

3.1

3.1

0.2

3.1

207.3

11.5

22.3

10.1

17.5

35.2

27.8

5.6

3.7



EU ID Point ID

D-0924

T-0002

T-0003

D-0924

T-0002

T-0003

T-0038 T-0038

T-0041E T-0041E

T-0051

T-0059

T-0051

T-0059

T-0063

T-0064

T-0070

T-0077

T-0102

T-0103

T-0105

T-0106

T-0063

T-0064

T-0070

T-0077

T-0102

T-0103

T-0105

T-0106

T-0106E T-0106E

T-0107E T-0107E

Normal Contents

MDEA

Tetraethyl Lead

Dye

Crude Oil

Distillate

Residuum

Diesel

Residuum

Diesel

Spent Caustic

Spent Caustic

Diesel

Diesel

Residuum

Gas Oil

Gas Oil

Gas Oil


334,800

19,104

117,600

1,115,589,966

10,793,460

893,188

4,562,248

5,181,264

1,644,895

1,839,179

646,680

26,000,802

26,016,306

296,901

4,557,495

16,992,842

291,270,000


0.6

TPY

2.7

0.0

0.0

2.9

0.1

0.2

0.0

12.8

0.3

0.0

0.0

0.0

0.0

0.0

0.0

0.1

0.1

0.0

0.0

8.9

4.7

0.0

0.1

39.2

20.6

0.0

0.1

0.0

0.0

0.1

0.0

0.2

0.2


EU ID

T-0136

T-0138

T-0142

T-0143

T-0144

T-0152

T-0161

T-0168

T-0169

T-0171

T-0179

T-0253

T-0254

T-0260

T-0500

T-0501

T-0536

T-0116

T-0120

T-0122

T-0123

T-0124

T-0125

T-0126

T-0127

T-0128

T-0129

T-0130

T-0131

T-0133

T-0135

T-0561

T-0633

T-0636

T-0639

T-0640

T-0641

T-0904

T-0905

T-0906

T-0913

T-0914

T-0916

T-0946

T-0947

Point ID

T-0136

T-0138

T-0142

T-0143

T-0144

T-0152

T-0161

T-0168

T-0169

T-0171

T-0179

T-0253

T-0254

T-0260

T-0500

T-0501

T-0536

T-0116

T-0120

T-0122

T-0123

T-0124

T-0125

T-0126

T-0127

T-0128

T-0129

T-0130

T-0131

T-0133

T-0135

T-0561

T-0633

T-0636

T-0639

T-0640

T-0641

T-0904

T-0905

T-0906

T-0913

T-0914

T-0916

T-0946

T-0947

Normal Contents

Diesel

Gas Oil

Gas Oil

Diesel

Diesel

Diesel

Diesel

Gas Oil

Jet Fuel

Diesel

Diesel

Diesel

Diesel

Diesel

Diesel

Diesel

Residuum

Residuum

Residuum

Gas Oil

Gas Oil

Jet Fuel

Jet Fuel

Vendor Chemical

Jet Fuel

Spent Caustic/HC

Spent Caustic/HC

Caustic/HC

Gas Oil

Coker Fines Water/HC

Seal Oil

Hydrocarbon

Jet Fuel

Jet Fuel

Jet Fuel

Jet Fuel

Jet Fuel

Gas Oil

Gas Oil

Gas Oil

Gas Oil

Gas Oil

Gas Oil

Gas Oil

Gas Oil

DRAFT

41


9,495,362

919,800,000

4,968,188

588,000,000

588,000,000

588,000,000

588,000,000

1,757,721

420,000,000

420,000,000

630,000,000

630,000,000

12,616,403

588,000,000

588,000,000

7,289,573

7,702,851

306,600,000

12,906,295

8,137,124

1,881,944

7,259,810

7,899,245

2,478,372

40,000,000

26,280,000

26,280,000

317,244

31,399,064

121,257,581

5,518,240

24,418

48,037,352

53,830,803

52,413,635

52,733,006

45,639,919

26,731,512

140,794,902

9,286,419

5,345,380

12,262,607

297,717,911

160,493

126,534,666

0.2

0.2

0.1

12.7

0.0

0.0

0.0

1.1

0.0

2.0

0.5

2.7

0.0

0.0

0.2

0.5

0.2

0.1

0.0

0.1

0.0

1.1

2.2

2.0

0.0

0.1

3.7

3.6

0.1

0.0

3.0

8.5

0.1

VOC Emissions lb/hr TPY

0.0 0.2

5.4

0.1

3.2

3.2

3.2

3.2

0.1

2.8

2.8

4.9

4.9

23.7

0.3

14.0

14.0

14.0

14.0

0.4

12.2

12.2

21.4

21.4

0.3

0.2

0.2

0.0

5.0

9.6

8.6

0.0

0.3

16.0

16.0

0.3

0.2

13.1

37.1

0.3

1.1

0.9

0.6

55.6

0.2

0.1

0.2

4.6

0.0

8.9

2.4

11.7

0.1

0.0

1.0

2.1

1.0


DRAFT

42

EU ID

T-0948

T-0970

T-0971

T-0972

Point ID

T-0948

T-0970

T-0971

T-0972

Normal Contents

Gas Oil

Residuum

Residuum

Residuum

SUBTOTAL


58,835

12,643,582

13,565,104

14,047,738


0.0 0.0

0.1

0.2

0.2

96.8

0.5

0.7

0.8

423.8



EU ID Point ID

T-0652

T-0654

T-0665

T-0667

T-0669

T-0701

T-0702

T-0703

T-0704

T-0705

T-0706

T-0909

T-0910

D-0777

D-0779

D-5292

T-0037

T-0201

T-0202

T-0203

T-0204

T-0205

T-0551

T-0552

T-0553

T-0554

T-0555

T-0651

T-0652

T-0654

T-0665

T-0667

T-0669

T-0701

T-0702

T-0703

T-0704

T-0705

T-0706

T-0909

T-0910

D-0777

D-0779

D-5292

T-0037

T-0201

T-0202

T-0203

T-0204

T-0205

T-0551

T-0552

T-0553

T-0554

T-0555

T-0651

Normal Contents

Wastewater

Wastewater

Spent Caustic/HC

Slop Oil

Slop Oil

Slop Oil

Slop Oil

Wastewater

Wastewater

Wastewater

Wastewater

Slop Oil

Slop Oil

Slop Oil

Wastewater

Wastewater

Wastewater

Wastewater

Slop Oil

Spent Caustic/HC

Slop Oil

Slop Oil

Slop Oil

Wastewater

Wastewater

Wastewater

Spent Caustic/HC

Slop Oil

SUBTOTAL


6,768

124,836

22,800

1,522,500,000

7,364,056,518

7,591,350,396

165,868,584

7,359,192,246

7,342,830,600

4,733,568

4,985,946

744,030

1,797,978

691,152

6,458,543

5,705,544

20,103,196,764

19,009,124,946

3,599,963

2,128,714

5,212,589,634

5,212,589,634

335,882,820

5,208,070,098

5,208,070,098

26,279,266

2,520,000

6,300,000

4.7

0.9

4.8

4.8

0.2

0.9

83.5

0.5

0.1

0.1

6.2

6.1

0.5

4.8

0.5

4.7


0.0

TPY

0.0

0.0

0.0

4.1

4.9

0.0

0.0

17.8

21.6

5.1

0.5

4.9

4.9

4.9

4.9

4.9

4.8

22.2

2.0

21.5

21.5

21.5

21.5

21.5

21.0

20.8

3.8

20.8

20.8

0.9

4.0

365.8

2.0

0.3

0.5

27.4

26.6

2.0

21.0

2.1

20.8


DRAFT

43



EU ID

D-0232

D-0774

D-0775

D-0232

D-0774

D-0775

D-0776

D-0780

D-0776

D-0780

D-0783 D-0783

D-0786-1 D-0786-1

D-0787

D-6801

D-0787

D-6801

D-6812 D-6812

T-0016 E T-0016 E

T-0055

T-0069

T-0071

T-0080

T-0055

T-0069

T-0071

T-0080

T-0140

T-0173

T-0648

T-0140

T-0173

T-0648

T-0680

T-0907

T-0908

T-0944

T-0966

T-0973

T-0974

T-6601

Point ID

T-0680

T-0907

T-0908

T-0944

T-0966

T-0973

T-0974

T-6601

Normal Contents

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Wastewater

Spent Caustic/HC

Slop Oil

Slop Oil

Wastewater

Slop Oil

Wastewater

Brine Water/HC

Wastewater

ASU Lift Station overflow

Sour Water

Sour Water

Sour Water

Slop Oil

Spent Caustic/HC

Spent Caustic/HC

Caustic/HC

SUBTOTAL


11,088

123,600

29,498,062

29,498,062

124,836

74,710,999

6,768

6,768

121,727,109

121,727,109

1,252,212

5,206,452

5,317,206

3,810,408

124,592

46,356

2,573,760

54,912

95,045,625

3,037,330

12,600,000

18,593,161

64,603

2,729,033

461,453

176,244


0.0

TPY

0.0

0.1

0.3

0.3

0.1

0.3

1.3

1.3

0.4

0.7

0.0

0.0

1.5

1.2

0.0

0.0

0.0

0.3

0.1

0.0

0.0

0.0

1.1

0.5

0.1

0.0

0.1

3.1

0.0

0.0

6.5

5.2

0.0

0.1

0.1

1.0

0.2

0.7

0.3

0.0

2.7

0.8

0.0

10.4

4.2

1.0

3.2

1.4

0.1

12.0

3.4

0.0

45.5


EU ID Point ID

D-5250 D-5250

EP Methanol Tote EP Methanol Tote

T-0017 T-0017

T-0018

T-0018 E

T-0027

T-0057

T-0058

T-0104

T-0018

T-0018 E

T-0027

T-0057

T-0058

T-0104

Normal Contents

Vendor Chemical

Methanol

Perchloroethylene

Perchloroethylene

Vendor Chemical

Methanol

Methanol

Methanol

Methanol

Throughput

(gal/yr)

25,200

6,600

4,200

4,200

25,848

6,600

6,600

6,600

20,160


0.0

TPY

0.1

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.1

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0


DRAFT

44

EU ID

T-0212 E

T-0230

Point ID

T-0212 E

T-0230

Normal Contents

Vendor Chemical

Glycol Water

Throughput

(gal/yr)

6,552

120,000


0.0

0.0

TPY

0.1

0.0

T-0542

TNK-Misc. Vendor

Tanks/ Totes (1)

T-0542

TNK-Misc. Vendor

Tanks/ Totes

Methanol

Vendor Chemical

6,600

1,200,000

0.0

0.0

0.0

0.0

SUBTOTAL

1. Emissions based on 50 vendor tanks combined.

0.1


0.3

EU ID

T-0024

T-0186

TNK-MP

Gasoline

Point ID

T-0024

T-0186

TNK-MP

Gasoline

Normal Contents

Gasoline

Dye

Gasoline


113,509

117,600

22,234


0.1

0.0

TPY

0.6

0.0

0.0 0.2

SUBTOTAL 0.2 0.8


Emissions estimates for individual insignificant activities are not necessary since the facility is already a Part 70 major source.


(Heater/Boiler MACT) Boilers

EU ID

B-0008

B-0009/0010

Point ID

B-0008

B-0009/0010

Fired Duty

(MMBtu/hr)

483

734 *

Pollutant

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

EF

(lb/MMBtu)

0.035

0.0824

0.031

0.0054

0.0075

0.0500

0.0400

0.031

0.0054

0.0075

SUBTOTAL

NO

X

CO

SO

2

VOC

-

-

-

-

PM

10

-

* The boilers share a common stack. The fired duty shown is a total for both boilers.

Emissions lb/hr TPY

16.9 74.0

39.8 174.0

15.0 65.6

2.6 11.4

3.6 15.9

36.6

29.4

161

129

22.8 99.7

3.96 17.4

5.52 24.2

53.5 235.0

69.2 303.0

37.7 165.3

6.6 28.8

9.1 40.1


DRAFT

45

EUG HTR-2: 40 CFR Part 60 Subpart J and 40 CFR Part 63 Subpart DDDDD

(Heater/Boiler MACT) Heaters & Boilers

EU ID Point ID

Fired Duty

(MMBtu/hr)

Pollutant


B-0006

B-0007

B-5004 (1)

H-0001

H-0003

H-0004

H-0005

H-0010

B-0006

B-0007

No. 5 FCCU/B-

5004

H-0001

H-0003

H-0004

H-0005

H-0010

26.1

31.5

>250

175

28

106

85

55

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

EF

(lb/MMBtu)

-

-

-

-

0.06

0.04

0.031

0.0054

0.0075

0.1

0.039

0.031

0.28

0.12

0.031

0.0014

0.027

0.28

0.12

0.031

0.0014

0.018

-

0.0054

0.0075

0.15

0.039

0.031

0.0054

0.0075

0.098

0.0824

0.031

0.0054

0.0075

0.098

0.0824

0.031

0.0054

0.0075

5.4

1.0

1.3

2.8

1.1

0.9

0.0

0.0

0.0

0.0

10.6

7.0

8.8

3.8

1.0

0.0

0.6

0.0

7.3

3.1

0.8

0.0

0.7

0.8

8.3

7.0

2.6

0.5

0.6

0.2

0.2

16.4

4.4

3.3

0.6

5.4

4.5

1.7

0.3

0.4

23.8

4.1

5.8

12.1

4.8

3.8

0.0

0.0

0.0

0.0

46.0

30.7

32.0

13.7

3.5

0.2

3.1

38.6

16.6

4.3

0.2

2.5

0.0

3.5

37.0

31.0

11.5

2.0

3.0

0.7

0.9

69.6

18.1

14.4

2.5

23.6

19.9

7.5

1.3

1.8


EU ID Point ID

Fired Duty

(MMBtu/hr)

H-0011

H-0016

H-0023

H-0028

H-0029

H-0046

H-0048

H-0057 (2)

H-0058 (2)

H-0011

H-0016

H-0023

H-0028/0029

H-0028/0029

H-0046

H-0048

H-0057/58/59

H-0057/58/59

15

107

52.4

129

75

48.0

241

68.5

48.6

DRAFT

46

Pollutant

EF

(lb/MMBtu)

0.12

0.0824

0.031

0.0054

0.0075

0.035

0.04

0.031

0.0054

0.0075

0.137

0.0824

0.031

0.0054

0.0075

0.137

0.0824

0.031

0.0054

0.0075

0.098

0.0824

0.031

0.0054

0.0075

0.098

0.0824

0.031

0.0054

0.0075

0.07

0.04

0.031

0.0054

0.0075

0.098

0.082

0.031

0.0054

0.007

0.098

0.082

0.031

0.0054

0.007

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10


0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

9.7

7.5

1.3

1.8

0.0

0.0

0.6

4.7

4.0

1.5

0.3

0.4

16.9

0.7

1.0

7.4

6.2

2.3

0.4

1.6

0.3

0.4

17.7

10.6

4.0

4.3

3.3

0.6

0.8

7.2

4.3

1.8

1.2

0.5

0.1

0.1

3.7

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

42.3

32.7

5.7

7.9

0.0

0.0

2.4

21.0

18.0

6.5

1.1

2.0

74.0

3.0

5.0

32.2

27.1

10.2

1.8

7.1

1.2

1.7

78.0

47.0

17.5

18.7

14.5

2.5

3.5

31.4

18.9

7.9

5.4

2.0

0.4

0.5

16.4


EU ID Point ID

Fired Duty

(MMBtu/hr)

H-0059 (2)

H-1001

H-5001 (2)

H-5002

H-6005

H-6007

H-6008

H-6012

H-6013

H-0057/58/59

H-1001

H-5001

H-5002

H-6005

H-6007

H-6008

H-6012

H-6013

70.0

30

104

120

157

150

2

25

75.8

DRAFT

47

Pollutant

EF

(lb/MMBtu)

0.098

0.082

0.031

0.0054

0.007

0.05

0.04

0.031

0.0054

0.0075

0.275

0.082

0.031

0.007

0.0054

0.044

0.04

0.031

0.0054

0.0075

0.075

0.082

0.031

0.005

0.007

0.07

0.04

0.031

0.0054

0.0075

0.098

0.0824

0.031

0.0054

0.0075

0.098

0.0824

0.031

0.0054

0.0075

0.06

0.04

0.031

0.0054

0.0075

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10


0.8

0.1

0.2

4.6

3.0

2.3

0.4

0.6

0.2

0.1

0.0

0.0

2.5

2.1

1.1

10.5

6.0

4.7

0.8

1.1

0.2

0.7

0.9

11.8

12.9

4.9

0.8

0.0

0.0

0.0

5.3

4.8

3.7

1.2

0.9

0.2

0.2

0.0

0.0

0.0

0.0

0.0

0.0

0.0

1.5

3.4

0.6

1.0

19.9

13.3

10.3

1.8

2.5

1.0

0.3

0.1

1.0

11.0

9.0

4.8

46.0

26.3

20.4

3.5

4.9

1.0

2.9

3.9

51.6

56.4

21.3

3.5

0.0

0.0

0.0

23.1

21.0

16.3

5.3

4.1

0.7

1.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

6.6


EU ID Point ID

Fired Duty

(MMBtu/hr)

H-6014

H-6015

H-6151

H-7501

H-8601

H-8602

H-8801/8802

H-9851

H-9901

H-6014

H-6015

H-6151

H-7501

H-8601

H-8602

H-8801/8802

H-9851

H-9901

80

79

80

36.6

120

36

123

282

40

DRAFT

48

Pollutant

EF

(lb/MMBtu)

0.05

0.04

0.031

0.0054

0.0075

0.06

0.04

0.031

0.0054

0.0075

0.098

0.0824

0.031

0.0054

0.0075

0.11

0.0824

0.031

0.0054

0.0075

0.035

0.0824

0.031

0.0054

0.0075

0.035

0.0824

0.031

0.0054

0.0075

0.035

0.0824

0.0006

0.0054

0.0075

0.075

0.04

0.031

0.0054

0.0075

0.05

0.04

0.031

0.0054

0.0075

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10


8.7

1.5

2.1

2.0

1.6

1.2

0.2

0.3

10.1

0.1

0.7

0.9

21.2

11.3

0.9

1.3

3.0

1.1

0.2

0.3

4.3

0.2

0.3

4.2

9.9

3.7

0.7

2.5

0.4

0.6

4.1

1.2

1.1

3.2

2.4

0.4

0.6

7.8

6.6

4.0

3.2

2.5

0.4

0.6

4.8

38.3

6.7

9.3

8.8

7.0

5.4

1.0

1.3

44.2

0.3

2.9

4.0

92.8

49.5

3.9

5.5

13.0

4.9

0.8

1.2

18.9

1.0

1.3

18.4

43.3

16.3

2.9

10.9

1.9

2.6

18.0

5.4

5.0

13.8

10.7

1.8

2.6

34.3

28.9

17.5

14.0

10.9

1.9

2.6

20.8


DRAFT

49

EU ID Point ID

Fired Duty

(MMBtu/hr)

Pollutant

EF

(lb/MMBtu)


H-9902

NH-0057

H-9902

NH-0057

SUBTOTAL

50

128

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

CO

SO

2

X

0.05

0.04

-

-

-

-

-

0.031

0.0054

0.0075

0.05

0.04

0.031

0.0054

0.0075

2.5

2.0

1.6

0.3

0.4

6.4

5.1

4.0

0.7

1.0

VOC

PM

10

1. B-5004 emissions are included in EUG FCC-1, Point ID No. 5 FCCU/B5004 emission totals.

2. Emissions for these heaters are shown under their future replacements NH-0057 and H-5002.

11.0

8.8

6.8

1.2

1.6

28.0

22.4

17.4

3.0

4.2

218.0 953.0

158.6 694.8

82.6 362.3

15.0 64.8

21.8 97.3

EUG HTR-3 Heaters & Boilers Subject to Oklahoma Rules, Permit Limits, or 40 CFR Part

63 Subpart DDDDD (Heater/Boiler MACT) Only

EU ID Point ID

Fired Duty

(MMBtu/hr)

Pollutant

EF

(lb/MMBtu)


BLR-GFMST1 BLR-GFMST1

H-6037A/

6037B

(1)

No. 4FCCU

6.3

23.4

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

HTR-5FCC

Converter Air

Preheater

(1)

No. 5 FCCU/B-

5004

Est. > 10 but

<50

PM

10

NO

X

CO

SO

2

-

-

-

-

SUBTOTAL

VOC -

PM

10

-

1. Emissions from H-6037A/6037B and HTR-5FCC are included in EUG-FCC.

-

-

-

-

-

-

0.14

0.036

0.014

0.0024

0.014

-

-

-

0.0

0.0

0.0

0.0

0.0

0.0

0.9

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.9

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.1

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.1

0.0

0.0

0.0

0.0


DRAFT

50

EUG HTR-4 Insignificant Activity Heaters & Boilers

Emissions estimates for individual insignificant activities are not necessary since facility is already a Title V major source.


Note: Not all engines operate continuously. TPY emissions are based on actual hours of operation. These engines have no emissions limits.

EU ID Point ID Horsepower Pollutant

EF (lb/hphr)


E-0036

E-0068

E-0072

ENG-ASU

Portable

ENG-EP

Portable

ENG-MPP

Portable #1

ENG-MPP

Portable #2

E-0036

E-0068

E-0072

ENG-ASU

Portable

ENG-EP

Portable

ENG-MPP

Portable #1

ENG-MPP

Portable #2

308

550

600

213

213

450

450

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

0.031

0.00668

0.00205

0.00251

0.0022

0.031

0.00668

0.00205

0.00251

0.0022

0.00084

0.00027

0.031

0.00668

0.00205

0.00251

0.0022

0.031

0.00668

0.00205

0.00251

0.0022

0.031

0.00668

0.00205

0.00251

0.0022

0.0222

0.0027

4.12E-06

0.00084

0.00027

0.0222

0.0027

4.12E-06

0.5

6.6

1.4

0.4

0.5

0.5

0.5

0.2

6.6

1.4

0.4

0.5

0.0

0.5

0.2

13.3

1.62

0.0

9.5

2.1

0.6

0.8

0.7

12.2

1.5

14.0

3.0

0.9

1.1

1.0

14.0

3.0

0.9

1.1

1.0

0.0

0.6

0.1

0.0

0.1

0.0

2.2

0.7

0.6

0.1

0.0

0.1

0.0

2.0

0.7

58.3

7.1

0.0

0.9

0.2

0.1

0.1

0.1

53.5

6.5

1.4

0.3

0.1

0.1

0.1

1.4

0.3

0.1

0.1

0.1


DRAFT

51


EF (lb/hphr)


ENG-SP

Portable #1

ENG-SP

Portable #2

ENG-SP

Portable #1

ENG-SP

Portable #2

SUBTOTAL

425

425

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

-

-

-

-

-

0.031

0.00668

0.00205

0.00251

0.0022

0.031

0.00668

0.00205

0.00251

0.0022

13.2

2.8

0.9

1.1

0.9

13.2

2.8

0.9

1.1

0.9

102.5 119.2

19.7 15.2

5.1 0.5

7.2

5.8

4.8

1.9

1.3

0.3

0.1

0.1

0.1

1.3

0.3

0.1

0.1

0.1





EF (lb/hphr)


ENG-GFMMB ENG-GFMMB

ENG-E5017

ENG-E5018

ENG-E5017

ENG-E5018

135

484

484

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

0.015

0.0046

0.00205

0.000048

0.000926

0.01714

0.00573

0.00205

0.000055

0.000882

0.0171

0.00573

0.00205

0.000055

0.000882

0.0

0.4

8.3

2.8

1.0

0.0

0.4

2.0

0.6

0.3

0.0

0.1

8.3

2.8

1.0

0.0

0.0

0.8

0.3

0.1

0.0

0.0

0.2

0.1

0.0

0.0

0.0

0.8

0.3

0.1


DRAFT

52


EF (lb/hphr)


SUBTOTAL

NO

X

CO

SO

2

VOC

PM

10

-

-

-

-

-

18.6

6.2

2.3

0.1

1.0

1.8

0.6

0.2

0.0

0.1



EU ID

No. 4 FCCU

Point ID

No. 4 FCCU

Process Rate (bpd) Pollutant

26,000

NO

X

CO

SO

2

VOC

Emissions (1) lb/hr

19.9

TPY

87.0

83.7

76.0

1.9

110.0

333.0

8.3

PM

10

NO

X

33.1

26.4

145.0

116.0

No. 5 FCCU/ B-

5004

No. 5 FCCU/ B-5004 44,000

CO

SO

2

160.0

58.7

46.1

257.0

VOC - -

SUBTOTAL

PM

NO

CO

SO

2

10

X

VOC

PM

10

30.0

46.3

243.7

134.7

1.9

63.1

131.0

203.0

156.1

590.0

8.3

276.0

1. Emissions are based on previous permit limits. No. 5 FCCU emissions shown are for post-control installations (wet gas scrubber and enhanced non-selective catalytic reduction). B-5004 and HTR-5FCC

Converter Startup Preheater emissions are included in No. 5 FCCU/B-5004 emissions. H-6037A/6037B emissions are included in the No. 4 FCCU emissions.



EU ID Point ID Process

Emissions (1) lb/hr TPY

No. 2 CRU Flare-CC

Initial catalyst depresssuring and catalyst purging

0.0 0.0

No. 3 CRU Flare-EP

Initial catalyst depresssuring and catalyst purging

SUBTOTAL

0.0 0.0

0.0 0.0

1. Emissions from No. 3 CRU Regenerator Vent are included in EUG FLR-1. There are no emissions from the No. 2 CRU Regenerator Vent because they are routed back to process by the Flare-CC flare gas recovery unit.



DRAFT

53

EU ID

Flare-CC

Flare-CF

Flare-EP

(4)

(4)

Point ID

Flare-CC

Flare-CF

Flare-EP

Process Rate

(MMBtu/hr)

26.3

3.9

10.7

Pollutant

NO

CO

SO

2

X

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

EF

(lb/MMBtu)

0.0485

0.350

(2)

0.063

-

0.0485

0.350

(2)

0.063

-

0.0485

0.350

(2)

0.063

-

Emissions (1) lb/hr TPY

1.3 5.6

9.2 40.4

18.1 79.1

1.7

0.0

0.2

1.4

0.0

0.2

0.0

0.5

0.7

0.0

7.3

0.0

0.8

6.0

0.0

1.1

0.0

2.3

3.8 16.5

2.9 12.7

3.0

0.0

Flare-SF Flare-SF 0.0004

NO

CO

SO

2

X

VOC

0.0485

0.350

(2)

(3)

0.0

0.0

0.0

0.3

0.0

0.0

0.0

1.3

Flare-SP (4) Flare-SP

SUBTOTAL

0.5

PM

NO

CO

SO

PM

NO

SO

2

CO

10

X

2

10

X

VOC

VOC

-

0.0485

0.350

(2)

0.063

-

-

-

-

-

0.0

0.0

0.2

0.0

0.0

0.0

0.1

0.7

0.0

0.1

0.0

2.0

0.0

8.8

14.5 63.6

21.0 91.8

2.9 12.7

0.0 0.0 PM

10

-

1. Does not include process upset and other non-routine flaring emissions. VOC emissions from

EUG VNT-1, EUG VNT-2, and EUG CRU-1 are included.

2. Flare SO

2

emissions are calculated using a stoichiometric conversion of all H

2

S to SO

2

.

3. Flare-SF VOC emissions are based on NESHAP Part 63 Subpart R limit of 10 mg/L of gasoline loaded.

4. Flare gas recovery units (FGRU) have been installed to recover waste streams routed to the

Flare-CF, Flare-CC, and Flare-SP.


DRAFT

54


EU ID

Point

ID

Process Throughput (gal/yr)

VOC Emissions (1) lb/hr TPY

Load-SF Flare-SF

Santa Fe Loading Rack

(Gasoline)

30,000,000

1. Emissions from gasoline loading are included in Flare-SF emissions.

0.0 0.0


EU ID

Point

ID

Process Throughput (gal/yr)


Load-SP Load-SP

South Plant Loading

Rack (Distillates)

175,200,000 3.0 8.8




Process Vents

VOC Emissions (1)


VNT-D749 Flare-CC

VNT-T0039E Flare-EP


T-39E sour water tank lb/hr

0.0

0.0

TPY

0.0

0.0

VNT-SFLR Flare-SF

VNT-D6004 Flare-EP

Gasoline loading rack vapor collection system

D-6004 No. 2 CTU desalter water surge drum

SUBTOTAL

1. Emissions are included in EUG FLR-1.

0.0

0.0

0.0

0.0

0.0

0.0


Process Vents



VNT-C6015 (1) Flare-EP

VNT-D0565 (1) Flare-EP

VNT-D0701 VNT-D0701

VNT-D0702

VNT-D0704

VNT-D0702

VNT-D0704

VNT-D0714 VNT-D0714

VNT-D0717 (1) Flare-CC


No. 3 Reformer Hydrogen Recycle

Compressor Vent


D-701 vent/drain to atmosphere




D-717 depropanizer overhead reflux


0.0

0.0

3.0

3.0

3.0

3.0

0.0

0.0

0.0

0.0

13.1

13.1

13.1

13.1

0.0

0.0


DRAFT

55



VNT-D5173 VNT-D5173





D-748 fuel gas drum






VNT-Load SF

LPG

VNT-Load SF

Toluene

VNT-Load SF

VNT-Load SF

Toluene

VNT-Load SP

LPG VNT-Load SP

VNT-T0256 (1) Flare-CC

VNT-W0193 (1) Flare-CC


Toluene unloading line vent to atmosphere




SUBTOTAL

1. Emissions are included in EUG FLR-1.


0.0

3.0

TPY

0.0

13.1

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

25.8 112.9



Pollutant Emissions lb/hr TPY

VNT-C0008 VNT-C0008

Sat Gas Plant Compressor

Distance Piece Vent

Sat Gas Plant Compressor

VNT-C5017 VNT-C5017

Distance Piece Vent

SUBTOTAL

VOC

VOC

VOC

3.6

3.0

4.2

3.5

3.5

7.0

16.0

13.1

18.3

15.5

15.5

31.0

EUG VNT-4: Atmospheric Process Vents with No Applicable Requirements

Pollutant

EU ID Point ID

VNT-D9857 VNT-D9857

Process

No. 2 Hydrogen Plant Deaerator

Vent

SUBTOTAL

VOC

CO

VOC

CO

Emissions lb/hr

5.7

0.7

5.7

0.7

TPY

25.0

3.0

25.0

3.0




DRAFT

56

EUG FUG-1: Fugitive Piping Equipment Leaks Subject to 40 CFR Part 63 Subpart CC

(Refinery MACT I) and/or 40 CFR Part 60 Subpart GGG

VOC Emissions

EU ID

Refinery-

Wide Piping

Equipment

Fugitive

Leaks

Point ID

Refinery-

Wide Piping

Equipment

Fugitive

Leaks

Equipment



Gas Valves

LL Valves

HL Valves

Flanges

LL Pump Seals

HL Pump Seals

Gas Compressors



Sample Stations

SUBTOTAL

Approx.

Number of Items

Emission

Factor, lb/hrsource

18,661 0.00253

23,270 0.00468

14,482 0.00051

27,856 0.00013

370 0.04509

289 0.04718

19 0.50265

539 0.22928

13 0.00459

587 0.03307 lb/hr

47.2

108.9

7.4

3.6

16.7

13.6

9.6

123.6

0.1

19.4

350.0

TPY

206.8

477.0

32.3

15.9

73.1

59.7

41.8

541.3

0.3

85.0

1,533.2



EU ID

FUG-6HDT

FUG-Coker

ORU

FUG-1HP, 2HP,

2Isom, 8HDT,

9HDT & FGRU

FUG-2CTU,

3CRU, 4FCC &

ORU

FUG-7HDT

FUG-WP ORU

Point ID

FUG-CC

FUG-CC

FUG-CF

FUG-EP

FUG-WP

FUG-WP

Equipment

Process drains


Process drains


Process drains


Process drains


Process drains


Process drains


Approx.

Number of Items

13

12

27

6

145

52

177

33

29

13

19

8

Emission

Factor, lb/hrsource

0.035

0.07

0.035

0.07

0.035

0.07

0.035

0.07

0.035

0.07

0.035

0.07


0.5

0.8

0.9

0.4

2.0

3.7

4.1

1.8

5.1 22.2

3.6 15.9

6.2 27.1

2.3 10.1

1.0

0.9

0.7

0.6

4.4

4.0

2.9

2.5


DRAFT

57

EU ID

FUG-OM Tank

Farm & WWTS

FUG-SP Tank

Farm

Point ID

FUG-OM

FUG-SP

Equipment

Process drains


Process drains


SUBTOTAL

Approx.

Number of Items

0

27

0

3

Emission


0.035

0.07

0.035

0.07


0.0 0.0

1.9

0.0

0.2

8.3

0.0

0.9

21.9 96.0




Approx.

Number of Items

Emission


VOC Emissions

(1) lb/hr TPY

FUG-6HDT

FUG-2H2 Plant

& 9HDT

FUG-7HDT

FUG-2SWS

FUG-CC

FUG-CF

FUG-WP

FUG-SP

Process drains


Process drains


Process drains


Process drains


13

12

50

15

29

13

11

0

0.035

0.07

0.035

0.07

0.035

0.07

0.035

0.07

-

-

-

-

-

-

0.4

0.0

-

-

-

-

-

-

1.7

0.0

SUBTOTAL 0.4 1.7

1. Emissions from certain units have already been included in EUG FUG-2 so they are not shown in this table.

EUG FUG-4: Fugitive Oily Water Sewer System Component Leaks Subject Only to 40



Approx.

Number of Items

Emission



Refinery-Wide

Oily Water

Sewer

Component

Fugitive Leaks

Refinery-Wide

Oily Water Sewer

Component

Fugitive Leaks

Process drains

(controlled)

Process drains

(uncontrolled)

Closed drains


(controlled)

78

2,118

243

0

0.035

0.07

0.0

0.07

2.7 12.0

148.3 649.4

0.0

0.0

0.0

0.0


DRAFT

58


Approx.

Number of Items

Emission




(uncontrolled)

SUBTOTAL

303 0.47 142.4 623.8

293.4 1,285.1

EUG FUG-5: Fugitive Storm Sewer System Component Leaks with No Applicable

Requirements


Approx.

Number of Items

Emission



Refinery-Wide

Storm Sewer

Equipment

Fugitive Leaks

Refinery-Wide

Storm Sewer

Equipment

Fugitive Leaks

Process drains

(controlled)

Process drains

(uncontrolled)


(controlled)


(uncontrolled)

SUBTOTAL

0

108

0

33

0.035

0.07

0.07

0.47

0.0 0.0

7.6 33.1

0.0 0.0

15.5 67.9

23.1 101.0



EU ID

Y-0002

Y-0002 A

Y-0003

Y-0005

Y-0006

Y-0007

Y-0009

Y-0010

Point ID

Y-0002

Y-0002 A

Y-0003

Y-0005

Y-0006

Y-0007

Y-0009

Y-0010

Recirculation Rate

(gpm)

15,600

15,000

19,000

34,000

11,406

10,000

500

22,282

Pollutant

VOC

PM

10

VOC

PM

10

VOC

PM

10

VOC

PM

10

VOC

PM

10

VOC

PM

10

VOC

PM

10

VOC

PM

10

EF

(lb/MMgal)

6

-

6

-

6

-

6

-

6

-

6

-

6

-

6

-


5.6

24.6

6.4

28.0

5.4

23.7

6.2

27.0

6.8 30.0

5.9 25.8

12.2

53.6

10.9

47.9

4.1

18.0

6.1 26.8

4.3 18.9

3.6 15.8

0.2 0.8

0.2 0.8

8.0

35.1

3.1

13.8


DRAFT

59

EU ID

Y-6026

Y-6027

Y-8000

Point ID

Y-6026

Y-6027

Y-8000

Recirculation Rate

(gpm)

SUBTOTAL

14,000

14,000

7,500

Pollutant

VOC

PM

10

VOC

PM

10

VOC

PM

10

VOC

PM

10

EF

(lb/MMgal)

6

-

6

-

0.7

-

-

-


4.3 18.9

4.4 19.1

5.0

22.1

3.7

16.0

0.3

1.4

2.6

11.6

56.9

249.1

48.4

212.0



EU ID Point ID Process Rate (TPY)

PM

10


Coke Handling

Facility

Coke Handling

Facility

475,000 2.7 8.8

EUG FUG-8: Insignificant Activity Fugitive Sources



Summary of Potential Emissions

EUG

EUG TNK-1

EUG TNK-2

EUG TNK-3

EUG TNK-4

EUG TNK-5

EUG TNK-6

EUG TNK-7

EUG TNK-8

EUG HTR-1

EUG HTR-2

EUG HTR-3

EUG HTR-4

EUG ENG-1

EUG ENG-2

EUG ENG-3

EUG FCC-1

EUG CRU-1

EUG FLR-1

EUG LOD-1

NO

X

CO SO

2

VOC PM

10 lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY

- - - - - - 41.4 181.2 -

-

-

-

-

-

-

-

-

-

-

-

-

47.3

96.8

207.3

423.8

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

- 83.5 365.8

- 10.4 45.5

-

-

-

0.1

0.2

-

0.3

0.8

-

-

-

-

-

-

53.5 235.0 69.2 303.0 37.7 165.3 6.6 28.8 9.1 40.1

218.0 953.0 158.6 694.8 82.6 362.3 15.0 64.8 21.8 97.3

0.9

-

0.1

-

0.0

-

0.0

-

0.0

-

0.0

-

0.0

-

0.0

-

0.0

-

0.0

-

-

-

-

-

-

-

-

-

102.5 119.2 19.7 15.2

- - - -

5.1

-

0.5

-

18.6 1.8 6.2 0.6 2.3 0.2

46.3 203.0 243.7 156.1 134.7 590.0

- - - - - -

2.0

-

8.8 14.5 63.6 21.0 91.8

- - - - -

7.2

-

0.1

1.9

-

4.8

-

0.0

8.3

-

2.9 12.7

- -

5.8

-

1.0

63.1

-

-

-

1.9

-

0.1

276.0

-

-

-


DRAFT

60

EUG

EUG LOD-2

EUG LOD-3

EUG VNT-1

EUG VNT-2

EUG VNT-3

EUG VNT-4

EUG VNT-5

EUG FUG-1

EUG FUG-2

EUG FUG-3

EUG FUG-4

EUG FUG-5

EUG FUG-6

EUG FUG-7

EUG FUG-8

EUG FW

TOTAL (1)

NO

X

CO SO

2

VOC PM

10 lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY

- - - - - - 3.0 8.8 -

- - - - - - - - -

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

25.8

7.0

-

112.9

31.1

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

442 1,520

0.7

-

-

-

-

-

-

-

-

-

-

3.0

-

-

-

-

-

-

-

-

-

-

513 1,240

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

5.7

-

0.4

25.0

-

- 350.0 1,533.2

- 21.9 96.0

1.7

293.4 1,285.1

-

-

-

-

-

-

- 23.1 101.0 - -

- 56.9 249.1 48.4 212.0

-

-

-

-

-

-

-

-

-

283 1,210 1,101 4,790

2.7

-

-

152

8.8

-

-

-

-

-

-

-

640

-

-

-

-

-

-

1. Lb/hr emissions shown to a precision of 1 lb/hr. TPY emissions shown to a precision of 10 TPY.

Hazardous Air Pollutants (HAP)

Total emissions of HAP from the PCR as reported in the 2005 annual emissions inventory are shown below. Sources of HAP include storage tanks, piping component fugitive leaks, loading racks, sewer component fugitive leaks, API separators, toluene unloading, cooling towers, atmospheric vents, combustion of fuel, and the land farm. HAP emission calculations are based on sample data, AP-42 factors, process knowledge, or engineering calculations.

HAP Name

2,2,4-Trimethylpentane

Antimony Compounds

Benzene

Biphenyl

Cumene

Ethyl Benzene

Hydrogen Fluoride

Methyl Alcohol

Naphthalene n-Hexane

Tetrachloroethylene

Toluene

Xylenes

TPY

4.0

0.2

11.2

0.2

8.1

6.4

0.9

1.4

1.5

24.2

0.2

31.5

25.7

TOTAL 122.7


DRAFT

61

SECTION VIII. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application and listed in OAC 252:100-

8, Appendix I, are shown below. Recordkeeping for activities indicated with “*” is listed in the

Specific Conditions. Some insignificant activities listed below were not operational at the time of the application. Other future activities that qualify as insignificant activities per OAC 252:100-8

Appendix I, which are not specifically listed below, may be conducted in the future without notification to DEQ. Any activity subject to an NSPS or NESHAP standard or state requirement is not insignificant. The permittee will be required to maintain records that demonstrate the activity is an insignificant activity.

* Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel, which are either used exclusively for emergency power generations or for peaking power service not exceeding 500 hours per year.

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

MMBtu/hr heat input (commercial natural gas). The facility currently operates three natural gas-fired boilers that meet these criteria.

Emissions from stationary internal combustion engines rated less than 50 HP output. The gasoline “knock” test engines E-0049, E-0050, E-0051, and E-0110 are in this category.

- Emissions from fuel storage/dispensing equipment operated solely for facility owned vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period.

* Emissions from storage tanks constructed with a capacity less than 39,894 gallons which store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature.

Additions or upgrades of instrumentation or control systems that result in emissions increases less than the pollutant quantities specified in OAC 252:100-8-3(e)(1).

Cold degreasing operations utilizing solvents that are denser than air. These are part of facility maintenance operations, which is a “trivial activity”; therefore no recordkeeping is required.

Welding and soldering operations utilizing less than 100 pounds of solder and 53 tons per year of electrodes. These are conducted as part of facility maintenance including turnarounds and new construction, which is a “trivial activity”; therefore, no recordkeeping is required.

Torch cutting and welding of less than 200,000 tons of steel fabricated. These are conducted as part of facility maintenance including turnarounds and new construction, which is a

“trivial activity”; therefore, no recordkeeping is required.


DRAFT

62

Site restoration and/or bioremediation activities of <5 years expected duration. The

Groundwater Recovery/Containment Wellfield and the 4 th

Street Clubhouse Soil Vapor

Extractor (SVE) System are in this category.

Hydrocarbon-contaminated soil aeration pads utilized for soils excavated at the facility only.

Emissions from operation of groundwater remediation wells including but not limited to emissions from venting, pumping, and collecting activities subject to de minimis limits for air toxics (OAC 252:100-41-43) and Haps (Section 112(b) of CAAA90).

Hazardous waste and hazardous materials drum staging areas. The facility includes a staging area for drummed hazardous wastes.

Sanitary sewage collection and treatment facilities other than incinerators and Publicly

Owned Treatment Works (POTW). Stacks or vents for sanitary sewer plumbing traps are also included (i.e., lift station).

Emissions from landfills and land farms unless otherwise regulated by an applicable state or federal regulation.

Surface coating operations that do not exceed a combined total usage of more than 60 gallons/month of coatings/thinners, and clean-up solvents at any one emission unit. These are conducted as part of facility maintenance, which is a “trivial activity”; therefore, no recordkeeping is required.

Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous waste satellite (accumulation) areas.

Hand wiping and spraying of solvents from containers with less than 1-liter capacity used for spot cleaning and/or degreasing in ozone attainment areas. This is conducted as part of facility maintenance, which is a “trivial activity”; therefore, no recordkeeping is required.

* Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant.

SECTION IX. AMBIENT AIR IMPACT MODELING

The following SO

2

air impact analysis results, which demonstrate compliance with OAC

252:100-31-7, were obtained from PSD permit application for Permit No. 2003-336-C (M-2)

PSD.


DRAFT

63

Averaging

Period

5-minute

1-hour

3-hour

24-hour

Maximum Modeled

Concentration

(ug/m 3 )

303.4

185.0

119.5

56.5

Location of Maximum

UTM East (m)

-

670,400

670,700

670,985

UTM North (m)

-

4,063,100

4,062,700

4,062,040

Standard

(ug/m

3

)

1,300

1,200

650

130

SECTION X. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable]

Subchapter 1 includes definitions but there are no regulatory obligations to incorporate into the permit.

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]

Primary Standards are in Appendix E and Secondary Standards are in Appendix F of the Air

Pollution Control Rules. At this time, all of Oklahoma is in attainment of these standards. This subchapter applies to EUG-FW for facility-wide applicable requirements; however there are no obligations to incorporate into the permit.

OAC 252:100-5 (Registration, Emission Inventory, and Annual Fees) [Applicable]

The owner or operator of any facility that is a source of air emissions shall submit a complete emission inventory annually on forms obtained from the Air Quality Division. An emission inventory was submitted and fees paid for previous years as required. The requirements from this subchapter have been incorporated into the Standard Conditions of the permit and apply to

EUG-FW for facility-wide applicable requirements.

OAC 252:100-7 (Permits for Minor Facilities) [Not Applicable]

Subchapter 7 sets forth the permit application fees and the basic substantive requirements for permits for minor facilities. However, Subchapter 7 previously contained the requirements for construction and operation of major sources also. The facility has been issued numerous permits since promulgation of the permitting rule (October, 1972). The requirements of the several permits will be incorporated into the Title V permit (see listing under Subchapter 8).

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


DRAFT

64 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 Haps or 20% of any threshold less than 10 TPY for single HAP that the EPA may establish by rule

Emission and operating limitations have been established from previous construction and operating permits. Emission limitations from permits issued during the period in which this Title

V was under consideration have been incorporated into this permit. The requirements of

Subchapter 8 have been incorporated into the Standard Conditions of the permit and apply to

EUG-FW for facility-wide applicable requirements .

Permit Number

88-102-O (M-1)

88-115-O (M-3)

88-117-O

EXISTING PERMIT REQUIREMENTS

Equipment Involved

Aviation gasoline production, blending and storage facility (including tanks T-0176, T-

0177, T-0178, & T-0179)

No. 7 Hydrotreater Unit (No. 7 HDT, heater

H-0011 and fugitives)

Gas sweetening and sulfur recovery

Status

Incorporated into Title

V permit


V permit

Nullified by Permit

No. 91-043-O (M-1)

89-029-O (M-1)

89-047-O (M-2)

89-047B-O

90-011-O (M-4)

90-066-O

90-076-O (M-1)

90-077-C

Tanks T-0147 and T-0141

Tank T-0165

Air stripping/carbon adsorption system, stripper vent (AS/CAS), ASU fugitives, drain fugitives)

Tanks T-0107E, T-0117, T-0119, T-0143, T-

0120, and T-0163

Change in fuel to H-0023 and H-0029

Soil/Groundwater Remediation Unit

Soil vapor extraction pilot


V permit


V permit

Equipment is permanently inactive.

Permit will be voided.


V permit


V permit



Equipment was never constructed. Permit will be voided.

91-008-O

91-042-O

Modification to MTBE process unit

(distillation tower, fugitives) Note:

Permitted equipment is no longer in MTBE service.

Closed coker blowdown system


V permit

Permit voided.


Permit Number

91-043-O (M-7)

91-060-O (M-2)

91-081-O (M-3)

91-094-O (M-3)

91-124-O

91-129-O (M-2)

91-142-O


No. 6 HDT and increased sulfur recovery project (includes H-7501, SRU, H-6005, H-

6012, H-6013, H-6007, H-6006, H-6151, H-

6008, H-0046, H-0047, H-0057, H-0058, H-

0048, H-0028, H-5001, and fugitives)

Tank T-0166 reconstruction

Shenandoah model P9-2G-M1 biomedical waste incinerator.

DRAFT

65

Status

All terms and conditions were incorporated into Title

V permit except for references to the SRU.

Voided by Permit No.

2007-050-O

Modifications to the alky debutanizer, alky defluorinator, No. 4 FCCU, saturate gas plant, and butane-butene feed units (H-0010,

HFAU, No. 4 FCC, SGP, BBU, and fugitives)

West Plant Oil Recovery Unit (WORU), East

Plant Oil Recovery Unit (EORU), and

Wastewater Treatment Plant (WWTP) Tanks

(includes tanks T-0201, T-0202, T-0203, T-

0204, T-0205, T-0701, T-0702, T-0703, T-

0704, T-0705, T-0665, and T-0654).

Pilot soil remediation vent system controlled by a thermal oxidizer in the East Plant

(SGRU-TO)

Coker Oil Recovery Unit (CORU),

Wastewater Treatment Plant (WWTP), and

East Plant Oil Recovery Unit (EORU) Tanks

(includes tanks T-0706, T-0551, T-0552, T-

0553, T-0554, T-0555, T-0667, and T-0669)


V permit


V permit




V permit

Equipment was dismantled. Permit will be voided.

91-143-O (M-2)

(PSD)

Distillates storage tanks (includes tanks T-

0123, T-0124, T-0125, T-0126, T-0128, T-

0129, T-0130, T-0131, T-0135, T-0136, T-

0173, T-0003, T-0004, and fugitives)


V permit

91-154-O (M-1) No. 5FCCU Waste Heat Boiler

Superceded by Permit

No. 98-169-C (M-2)

92-018-O (M-1)

West/South Plant wastewater treatment system and associated waste minimization projects (includes T-0037, T-0357E, T-0402,

T-0690, T-0909, T-0910, and fugitives)


V permit

92-028-C T-0115 Reconstruction

Equipment was not constructed within 18 months of permit issuance. Permit is null and void.


Permit Number

92-034-O


Alkylation feed treatment unit (HFAU, SHP

Unit, Merox Unit, No. 5 FCCU

Depropanizer, and Process Units Tie-Ins fugitives)

93-003-O (M-3)

95-130-O

95-158-O (M-6)

96-280-O (M-1)

97-269-O (M-2)

97-286-C (M-3)

97-485-C

1998-104-C

98-169-O (M-1)

98-169-C (M-6)

98-287-C

2000-117-C

2000-206-C (M-4)

2000-210-O

2001-173-C

2001-189-C

2001-194-C (M-3)

(PSD)

DRAFT

Status

66


V permit

Tank T-0156 and associated fugitives

Tanks T-0014E and T-0015 to store sweetened naphtha

Cogeneration Facility Realignment B-0006,

B-0007, T-0101, and T-0164

Construction Permit for No. 4 FCC Unit

New coke handling facility (Coke Pad)

Nullified by Permit

No. 2007-050-O


V permit


V permit

Nullified by Permit

No. 2000-206-C


V permit


V permit

No. 2 CTU Naphtha Debottlenecking Project

(H-6005)

South Plant JP-8 railcar loading facility (T-

0901, T-0902, T-0953, NTJP-1, NTJP-2, and

JFRL (Load-SP) fugitives)

Amine regenerator and sour water stripper expansion project

South Plant Flare Header Project (No. 5

FCCU/B-5004)

No. 5 FCCU VRU Expansion/Coker Gas

Plant (No. 5 FCC/B-5004)

Decant oil tankage upgrade (NT-1 and NT-2)

Floating roof installation for T-0908

Vapor recovery unit expansion, including the

No. 4 FCCU and heater H-0048

Temporary Flare at Ponca City Refinery

(Flare-Temp)

No. 7 Coker Flare Gas Recovery Project (No.

7 CU)

Santa Fe Aviation Gasoline Rail Car Loading

Rack Flare (Load-SF and Flare-01)

Gasoline Clean Fuels Project (H-8601, H-

8602, H-8801/H-8802, B-0008, CT-11,

Flare-CF, T-0119, T-0147, T-0901, T-0902, and T-0953)


V permit


V permit

Superceded by Permit

No. 98-169-C (M-2)


V permit

Equipment was not constructed within 18 months of permit issuance. Permit is null and void.


V permit


V permit


V permit


V permit


V permit


V permit


DRAFT

67

Permit Number

2001-195-O

2001-212-O (M-1)

2001-252-O

2001-305-C

2001-311-C


Caustic regeneration (neutralization process) tanks alkylation unit (T-0253 and T-0254)

Petroleum distillate liquid storage tanks (T-

0106E and T-0144).

East plant flare (Flare-EP).

No. 3 catalytic reformer expansion (H-6007,

H-6012, and H-6013)

Heater H-0001 construction permit

Status


V permit


V permit


2003-336-C (M-3)

(PSD)


V permit


2002-476-C (PSD)

2002-115-C (M-2)

No. 4 CTU/CVU Expansion Project

Construction Permit (H-0003, H-0004, H-

0010 and H-0059)


V permit

2002-138-C

2002-476-C (M-2)

(PSD)

2003-336-C (M-3)

(PSD)

Temporary Boiler

No. 1 Crude Topping Unit Upgrade (H-0001,

H-0016, H-0048)

ULSD Project (H-1001, H-9901, H-9902, H-

9851, H-6007, H-6014, H-6015, H-5002, H-

0057, H-0058, H-0059, B-0009, B-0010, No.

4 FCCU, No. 5 FCCU, T-0121)

Equipment never constructed. Permit is null and void.


V permit


V permit

2007-050-O

Gasoline Tank Permit Consolidation (T-114,

T-156, T-160, T-166)


V permit

In addition to construction and operating permits, the facility has been granted various approvals, or is awaiting approval, for alternate methods of compliance and limits as summarized below:

Approval Description

Alternate Opacity Limitation EH-93-

014 (2/09/93)


No. 5 FCCU/B-5004

Status


2003-336-C (M-3)

(PSD). Alternative opacity monitoring approval request submitted to EPA

Region VI on July 18,

2006. Provisions of the proposed alternative opacity monitoring request incorporated into

Title V permit.


DRAFT

68

Approval Description

Alternate Opacity Limitation

(2/18/98)

Alternate Monitoring Plan for NSPS

Subpart J (6/20/03)

Alternate Monitoring Method for

NSPS Subpart J (6-04-04)


Subpart J (12/01/04, Revised

1/11/06)

Alternate Sulfur Oxides Monitoring

Method Approval (submitted

7/31/03)


No. 4 FCCU

Flare-SF

Flare-EP

Flare-CC

No. 4 FCCU

Status

Incorporated into

Title V permit

Incorporated into

Title V permit

Incorporated into

Title V permit

Incorporated into

Title V permit

Incorporated into

Title V permit

Alternate Sulfur Oxides Monitoring

Method Approval and Alternate

Coke Burn-Off Calculation Method

Approval for NSPS Subpart J

(submitted 1/27/04 & 2/11/05)

No. 5 FCCU/B-5004

Incorporated into

Title V permit except that sulfur oxides

AMM approval is not needed after installation of WGS.

Incorporated into

Title V permit

Flare Upset Gas Monitoring Waiver

(4/16/04 & 3/23/05)

Alternate Opacity Monitoring Plan for NSPS Subpart J (submitted

4/18/07)

Flare Upset Gas Monitoring Waiver

(submitted 2/2/07)


Subpart J (submitted 2/16/06 and amended 2/28/07)

Alternate Opacity Monitoring Plan for NSPS Subpart J (submitted

5/16/07)

Flare-CF and Flare-CC

No. 5FCCU/B-5004

Flare-SP

H-8801/8802 and H-9851

No. 4FCCU

Incorporated into

Title V permit

Incorporated into

Title V Permit

Incorporated into

Title V permit

Incorporated into

Title V permit

OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable]

In the event of any release which results in excess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day following the malfunction or release. Within ten (10) working days after the immediate notice is given, the owner or operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. In addition, if the owner or operator wishes to be considered for the exemption established in 252:100-9-3.3, a Demonstration of Cause must be submitted within 30 calendar days after the occurrence has ended. For technological limitations,

Section 9-3.1(b)(2) allows the owner or operator to file quarterly excess emission reports in place of the 10-day written report, as long as the DEQ is provided with written documentation of such conditions in an initial 10-day written report.


DRAFT

69

The requirements from this subchapter have been incorporated into the Standard Conditions of the permit and apply to EUG-FW for facility-wide applicable requirements.

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. The requirements from this subchapter have been incorporated into the Standard Conditions of the permit and apply to EUG-

FW for facility-wide applicable requirements.

OAC 252:100-19 (Particulate Matter) [Applicable]

This subchapter specifies particulate emission limits for fuel-burning equipment and industrial processes. Indirect-fired equipment includes process heaters and steam boilers. Direct-fired equipment includes the sulfur recovery unit acid gas furnace, which shares a combined stack with the tail gas unit. Industrial processes at the facility are fluid catalytic cracking unit regenerators, cooling towers, and coke loading facility. The following table compares allowable PM emissions to actual or calculated emissions. All units are in compliance with Subchapter 19. Applicable limitations from this subchapter are incorporated into the permit under individual EUGs.

COMPARISON OF PM EMISSIONS TO ALLOWABLE EMISSION RATES UNDER

OAC 252:100 APPENDIX G

Unit

No. 5 FCCU/B-5004

No. 4 FCCU

Process Weight,

TPH (1)

1,944

833

Allowable PM

Emissions, lb/hr

86.5

75.3

Actual PM Emission

Rate, lb/hr

58.6

63.2

Cooling Towers, each <6,255 104 1.30

Coke Loading Facility 120 53.1 9.9

1. The process weights for FCCUs are the catalyst circulation rates measured during stack testing.

COMPARISON OF PM EMISSION RATES TO ALLOWABLE EMISSION RATES

UNDER OAC 252:100 APPENDIX C

Process Unit

Maximum Heat

Input, MMBtu/hr

(1), (3)

Allowable PM

Emission Rate, lb/MMBtu

AP-42-based PM

Emission Rate, lb/MMBtu (2)

Natural Gas-Fired Heaters and Boilers, each

Diesel-Fired Boilers, each

<1,000

<10

0.20

0.60

0.007

0.015

Gasoline-Fired Engines, each

Diesel-Fired Engines, each

<5

<5

0.60

0.60

0.31

0.10


DRAFT

70

1. All facility natural gas-fired heaters and boilers are less than 1,000 MMBtu. Diesel-fired boilers are less than 10 MMBtu/hr. Gasoline and diesel-fired engines are less than 5 MMBtu/hr.

2. For diesel-fired boilers, a fuel heating value of 0.137 MMBtu/gal was used to convert gallons to

BTUs.

3. For engines, an average brake-specific fuel consumption of 7,000 Btu/hp-hr was used to convert from horsepower to MMBtu/hr.

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

No discharge of greater than 20% opacity is allowed except for short-term occurrences, which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. The No. 4 FCCU has a DEQ-approved alternate opacity limit of 33% in lieu of the 20% allowed by this subchapter. This alternate opacity limitation has been incorporated into the Title V permit. After installation of a wet gas scrubber, the No. 4 FCCU will demonstrate compliance using an alternate monitoring method approval request submitted to

EPA on May 18, 2007. An alternate monitoring method approval request was submitted to EPA on April 18, 2007 for the No. 5 FCCU in lieu of opacity monitoring, due to the installation of a wet gas scrubber. This alternate method has been incorporated into the Title V permit. For other equipment, the requirements from this subchapter have been incorporated into the Standard

Conditions of the permit and apply to EUG-FW for facility-wide applicable requirements.

OAC 252:100-29 (Fugitive Dust) [Applicable]

Subchapter 29 prohibits the handling, transportation, or disposition of any substance likely to become airborne or windborne without taking “reasonable precautions” to minimize emissions of fugitive dust. 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 to interfere with the maintenance of air quality standards. Measures that may be taken at the facility as necessary to reduce dust is watering of dirt roads, stockpiles, and transport loads, and planting of vegetation. These measures achieve compliance with the “reasonable precautions” requirement. The requirements from this subchapter have been incorporated into the Standard


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

Part 2 limits emissions of sulfur dioxide from any one existing source or any one new petroleum and natural gas process source subject to OAC 252:100-31-26(a)(1). Ambient air concentration of sulfur dioxide at any given point shall not be greater than 1,300

 g/m

3

in a 5-minute period of any hour, 1,200

 g/m

3

for a 1-hour average, 650

 g/m

3 for a 3-hour average, or 130

 g/m

3 for a

24-hour average. The ambient standards for sulfur dioxide are incorporated into the Standard


Results of facility ambient modeling for a recent permitting project are shown in Section VI of the permit memorandum and demonstrate compliance with Part 2.

Part 2 also 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/m

3

). The facility operates tank vents from the storage of sour crude oil, naphtha, distillates, and wastewater that potentially


DRAFT

71 generate H

2

S emissions. Based on Appendix B of the Permit Memorandum for the Minor Source

General Permit for Oil and Gas Facilities, the emissions of H

2

S from Ponca City Refinery crude oil storage tanks and floating roof storage tanks are compliant with this regulation. The vapor pressures of naphtha and distillates are similar to or lower than crude oil, so it can be assumed that H

2

S emissions from storage of these products are also compliant with this regulation.

VNT-

C0008 and VNT-C5017 vent streams are known to contain H

2

S; however, the vent rates do not exceed 0.3 lb/hr of H

2

S for a two-hour average. SCREEN3 modeling for these vents shows that the ambient H

2

S concentration at the facility fenceline does not exceed 0.2 ppm (280 ug/m3) for a 24-hour average period.

Part 5 limits sulfur dioxide emissions from new petroleum or natural gas process equipment

(constructed or modified after July 1, 1972). For gaseous fuels the limit is 0.2 lb/MMBtu heat input averaged over 3 hours. All gas-fired equipment at the PCR combusts fuel gas that meets the fuel gas sulfur standards of NSPS Subpart J. Subpart J specifies a more stringent limit of 0.1 grains/dscf (160 ppm at 60 o

F). A limit of 0.1 grains/dscf of H

2

S in the fuel gas is equivalent to a maximum SO

2

emission rate of 0.031 lb/MMBtu using a fuel higher heating value of 867

Btu/scf. For liquid fuel-fired equipment, the limit is 0.8 lb/MMBtu heat input averaged over 3 hours. EPA’s AP-42 factor for diesel-fired engines is 0.29 lb/MMBtu. The factor for dieselfired heaters and boilers is 0.0016 lb/MMBtu; using a conversion of 0.137 MMBtu/gal of diesel and a typical maximum sulfur specification of 0.0015 weight percent. Both factors are less than the limit in this subchapter. The sulfur dioxide limitations for gas-fired equipment are incorporated into the Standard Conditions of the permit. Other applicable limitations from this

Part are incorporated into the permit under individual EUGs.

Part 5 also limits hydrogen sulfide emissions from new petroleum or natural gas process equipment (constructed or modified 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. Nearly 100% of the facility’s produced H

2

S is recovered in the refinery amine regenerator acid gas streams and then sent to the Jupiter facility neighboring the refinery. The remaining H

2

S is recovered in the Sour Water Stripper overhead gas, which is sent to the Jupiter facility.

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

This subchapter applies to fuel burning equipment, constructed or modified after February 14,

1972, with a rated heat input greater than or equal to 50 MMBtu/hr. Gas-fired equipment is limited to emissions of 0.20 lbs of NO

X

per MMBtu, 3-hour average. The gas-fired heaters and boilers at the facility with heat inputs greater than or equal to 50 MMBtu/hr that were constructed or modified after February 14, 1972 are subject to this subchapter. Compliance with the limit is demonstrated by using continuous emission monitors, stack testing, or AP-42 factors. All gasfired refinery heaters and boilers subject to this subchapter have an anticipated NO

X

emission rate of less than or equal to 0.20 lb/MMBtu during normal operations. Liquid fuel-fired equipment is limited to emissions of 0.30 lb of NO

X

per MMBtu, 3-hour average. EPA’s AP-42


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72 factors are used to estimate emissions from liquid fuel-fired engines, boilers and heaters. The

AP-42 factor for diesel-fired engines is 0.29 lb/MMBtu and the factor for diesel-fired heaters and boilers is 0.15 lb/MMBtu (using a conversion of 0.137 MMBtu/gal of diesel). Both factors are less than the limit in this subchapter. The facility does not operate liquid fuel-fired heaters, boilers, or engines with a heat input greater than or equal to 50 MMBtu/hr. The applicable limitations from this subchapter are incorporated into the permit under individual EUGs.

OAC 252:100-35 (Carbon Monoxide) [Applicable]

Subchapter 35 affects petroleum catalytic cracking units and catalytic reforming units installed or modified on or after July 1, 1972. The No. 4 FCCU was built in 1951 and not modified as to increase the CO emissions thereafter. The No. 5 FCCU was built in 1952, but modifications occurring between 1972 and 1973 increased CO emissions; therefore, Subchapter 35 applies to the No. 5 FCCU. Subchapter 35 requires “complete” secondary combustion, which is defined in the rule as removal of 93% or more of the CO generated. AP-42 Table 5.1-1 (01/95) specifies uncontrolled FCCU CO emissions of 13,700 lb/Mbbl. No. 5 FCCU/B-5004 stack testing (Feb.

1998) showed CO emissions of 2.9 lb/Mbbl, or a 99.9% reduction in CO. The catalytic reforming units (CRUs) located at the facility were in operation prior to the effective date of this rule and have not been modified so as to increase the CO emissions. Therefore this subpart does not apply to the CRUs. Applicable requirements from this subchapter are incorporated into the permit for the No. 5 FCCU.

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. Part 3 also requires storage tanks constructed after December 28, 1974, with a capacity of more than 40,000 gallons and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a either an external floating roof, a fixed roof with an internal floating cover, a vapor recovery system, or other equally effective control methods approved by the DEQ. Tanks subject to the equipment standards of

NSPS, Subparts K, Ka, or Kb are exempt from these requirements.

The facility operates tanks that were constructed after 1974, have a capacity of 400 gallons or more, store a VOC with a vapor pressure greater than 1.5 psia, and are not subject to the equipment standards of NSPS Subparts K, Ka, or Kb. These tanks comply with Subchapter 37 by having submerged fill piping. Applicable requirements from this subchapter are incorporated into the Specific Conditions of the permit and apply to tanks meeting the applicability criteria under individual EUGs.

Part 3 applies to VOC loading facilities constructed after December 24, 1974. Facilities with a throughput greater than 40,000 gallons/day are required to be equipped with a vapor-collection and disposal system unless all loading is accomplished by bottom loading with the hatches of the tank truck or trailer closed. LOAD-SF has the potential to load more than 40,000 gallons per day but is exempt from these requirements because it is subject to NSPS Subpart XX per 40 CFR 63

Subpart CC.


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73

Part 5 limits the VOC content of coating operations. This facility does not normally conduct coating or painting operations except for routine maintenance of the facility and equipment, which is exempt.

Part 7 requires all VOC gases from a vapor recovery blowdown system to be burned by a smokeless flare or equally effective control device unless it is inconsistent with the “Minimum

Federal Safety Standards for the Transportation of Natural and Other Gas by Pipeline” or any

State of Oklahoma regulatory agency. Unless it is unreasonable to do so, VOC gases from vapor blowdown systems during non-routine maintenance, startups, shutdowns or malfunctions are burned by refinery flares designed to be smokeless. The requirements from Part 7 are incorporated into the permit under EUG-FW for facility-wide applicable requirements.

Part 7 also requires fuel-burning and refuse-burning equipment is to be operated and maintained so as to minimize emissions of VOCs. Temperature and available air must be sufficient to provide essentially complete combustion. This rule applies to facility heaters and boilers in constructed or modified after December 24, 1974. The facility operates equipment that was constructed or modified after December 24, 1974 which is subject to this rule. The equipment is operated and maintained according to standard operating procedures or according to manufacturer’s recommendations . The requirements from this part are incorporated into the permit under individual EUGs for heaters, boilers and engines.

Effluent water separators openings or floating roofs are to be sealed or equipped with an organic vapor recovery system. The open API traps at the facility were constructed or modified prior to the effective date for existing equipment, so this part does not apply to the open API traps.

All reciprocating pumps and compressors are to be equipped with packing glands that are properly installed and maintained in good working order and rotating pumps and compressors to be equipped with mechanical seals. Equipment that is subject to NSPS Subpart GGG is exempt from these requirements. For other affected equipment not subject to NSPS Subpart GGG, the requirements from this part are incorporated in the permit under EUG-FW for facility-wide applicable requirements.

OAC 252:100-40 (Friable Asbestos) [Applicable]

This rule contains friable asbestos requirements (in addition to the asbestos requirements of 40

CFR Part 61). The facility is subject to this requirement since it handles and stores friable asbestos from demolition/renovation activities. The requirements from this subchapter are incorporated into the permit.

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.


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74

The following Oklahoma Air Pollution Control Rules are not applicable to this facility:

OAC 252:100-11

OAC 252:100-15

OAC 252:100-17

Alternative Emissions Reduction

Mobile Sources

Incinerators not requested not in source category not type of emission unit

OAC 252:100-23

OAC 252:100-24

OAC 252:100-39

Cotton Gins

Grain, Feed, or Seed Operations

Nonattainment Areas not type of emission unit not in source category not in area category

OAC 252:100-47 Landfills not in source category

SECTION XI. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable]

The facility has been issued three PSD permits. The facility is a major stationary source for NO

X

,

CO, SO

2

, VOC, and PM

10

. Any future increases must be evaluated in the context of PSD significance levels: 40 TPY NO

X

, 100 TPY CO, 40 TPY SO

2

, 40 TPY VOC, 15 TPY PM

10

, 10

TPY Total Reduced Sulfur, or 0.6 TPY lead.

NSPS, 40 CFR Part 60 [Subparts A, Db, J, Kb, XX, GGG, QQQ, and IIII Are Applicable]

Subpart A, General Provisions. This subpart requires submittal of notifications for NSPS-affected sources related to commencement of construction, initial startup, and initial performance testing.

This subpart also contains general recordkeeping, monitoring and testing requirements. These requirements apply to equipment subject to NSPS regulations, unless otherwise specified by those subparts. These requirements are incorporated into the permit under EUG-FW for facility-wide applicable requirements.

Subpart A also specifies general control device requirements for control devices used to comply with applicable subparts. Standards for flares used to comply with emissions limitations are stated in 40 CFR 60.18. Subpart GGG requires compliance with 40 CFR 60.482-10, and 60.482-10 requires compliance with 60.18 for flares used to comply with the standards. 40 CFR 60.18(f)(5) states that the maximum steam-assisted flare exit velocity, V max

, shall be determined by the following equation:

Log

10

(V max

) = (H t

+ 28.8)/31.7 where H t

= the net heating value of the flared gas, MJ/SCM. The section further requires that the flare be monitored for the presence of a pilot flame and that the flare be operated with no visible emissions.

The facility operates flares that are subject to this subpart since they control VOC streams from

NSPS Subpart GGG-affected equipment. Each flare’s pilot flame is monitored either by thermocouples or infrared cameras and each flare meets the design criteria specified.


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75

The permittee has calculated that under a worst case scenario, Flare-Temp would meet the requirements of performance testing under this part. EPA notified Oklahoma Air Quality on

September 12, 2000 that the calculations were sufficient to demonstrate that the flare would meet the requirements of this part and granted a waiver of performance testing.

Subpart D, Steam Generating Units. This subpart affects steam generating units with a rated heat input above 250 MMBtu/hr that were constructed after August 17, 1971. The refinery operates steam boilers which meet the applicability criteria. Since these boilers also meet the applicability criteria for Subpart Db, they are subject only to Subpart Db according to 40 CFR 60.41b(j).

The refinery operates waste heat boiler B-5004 (also known as a carbon monoxide (CO) boiler).

B-5004 recovers thermal energy from the No. 5FCC flue gas to produce steam. Although capable but not routinely done, it can also be fired with refinery fuel gas to produce additional steam. B-5004 had a design fired duty of less than 250 MMBtu/hr when it was installed in 1977, and was not subject to Subpart D. Since then B-5004 has been expanded and fired duty increased to more than 250 MMBtu/hr. However the increase was accomplished without triggering an NSPS modification or reconstruction, so B-5004 is not subject to Subparts D or Db.

Subpart Da, Electric Utility Steam Generating Units. This subpart affects electric utility steam generating boilers with a rated heat input greater than 250 MMBtu/hr and that were constructed after September 18, 1978. The refinery does not operate any electric utility steam generating boilers.

Subpart Db, Steam Generating Units. This subpart affects boilers with a rated heat input above

100 MMBtu/hr that commenced construction, reconstruction, or modification after June 19,

1984. The facility operates equipment that is subject to this subpart. The requirements of this subpart are incorporated into the permit under individual EUGs.

Subpart Dc, Small Steam Generating Units. This subpart affects boilers with a rated heat input between 10 and 100 MMBtu/hr that commenced construction, reconstruction, or modification after June 9, 1989. Subpart Dc specifically excludes process heaters. The refinery does not operate boilers meeting the applicability criteria of this subpart.

Subpart J, Petroleum Refineries. This subpart applies to the following affected facilities in petroleum refineries: fluid catalytic cracking unit catalyst regenerators, fuel gas combustion devices, and Claus sulfur recovery plants. All fluid catalytic cracking unit catalyst regenerators, which commence construction or modification after June 11, 1973, but before January 17, 1984, are subject to the following limitations:

 a PM emission limitation of 1.0 lb/1,000 lbs of coke burn-off, which is required to be continuously monitored and recorded;

 a CO emission limitation of 500 ppm by volume on a dry basis which is required to be continuously monitored and recorded; and

 a SO

X

emission limitation of 20 lb/ton coke burn-off


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76

The EPA has published proposed changes to Subpart J in the Federal Register. The No. 4 and

No. 5 FCCU specific conditions will be revised should more stringent requirements be finalized before issuance of the Part 70 permit.

As specified by the Consent Decree, the No. 5 FCCU/B-5004 regenerator became subject to the

PM limitations of NSPS Subpart J on December 31, 2006 and the No. 4 FCCU regenerator will become subject on December 31, 2008. These requirements are incorporated into the permit for the FCCUs.

As specified by the Consent Decree, the No. 4 FCCU and No. 5 FCCU/B-5004 regenerators became subject to the CO emission limitations of NSPS Subpart J on June 30, 2003. These requirements are incorporated into the permit for the FCCUs.

The SO

X

limitations became applicable to the No. 4 FCCU and No. 5 FCCU/B-5004 on August

1, 2003 and February 1, 2004, respectively. A request to use SO

2

stack CEMS as an alternate monitoring method for the No. 4 FCCU was submitted to EPA on July 31, 2003. The Consent

Decree allows for immediate use of proposed alternative monitoring methods after submittal of the request to EPA for requirements of the Consent Decree. The alternative monitoring request is pending EPA approval and the alternate method has been incorporated into the Title V permit.

A request for approval of an Alternative Monitoring Plan for calculating coke burn-off for the

No. 5 FCCU was submitted to EPA on February 11, 2005. Calculation of coke burn-off is required to demonstrate compliance with the PM requirements of 40 CFR 60.102(a)(1) and

60.104(b)(2). The Consent Decree allows for immediate use of proposed alternative monitoring methods after submittal of the request to EPA for requirements of the Consent Decree. The alternate methods are incorporated into the Title V permit.

All fuel combustion devices which commence construction or modification after June 11, 1973, are subject to a fuel gas H

2

S limitation of 0.10 grains/dscf (160 ppmvd at 60°F) which is required to be continuously monitored and recorded. The Consent Decree requires all of the facility’s heaters, boilers, and flares that combust refinery fuel gas to be subject to this subpart, regardless of construction or modification date.

All refinery fuel gas (RFG) combusted by affected heaters and boilers is monitored by H

2

S

CEMS or by methods specified in agency-approved alternate monitoring plans.

These requirements are incorporated into the permit for heaters and boilers.

RFG combusted in refinery flares complies with the continuous monitoring requirement provisions of this subpart by utilizing either a flare gas recovery system as allowed by the

Consent Decree, an H

2

S CEMS, or by methods specified in agency-approved alternate monitoring plans. These requirements are incorporated into the permit for flares.

Subpart K, Storage Vessels for Petroleum Liquids. This subpart affects storage vessels for petroleum liquids which have a storage capacity greater than 40,000 gallons but less than 65,000 gallons and which commenced construction, reconstruction, or modification after March 8, 1974,


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77 or which have a capacity greater than 65,000 gallons which commenced construction, reconstruction, or modification after June 11, 1973, and prior to May 19, 1978. The facility operates tanks that meet these criteria, but 40 CFR Part 63 Subpart CC overlap provisions specify compliance with 40 CFR Part 63 Subpart G instead of NSPS Subpart K standards.

Subpart Ka, Storage Vessels for Petroleum Liquids. This subpart affects storage vessels for petroleum liquids that have a storage capacity greater than 40,000 gallons and which commenced construction, reconstruction, or modification after May 18, 1978, and prior to July 23, 1984. The facility does not operate any tanks subject to this subpart.

Subpart Kb, VOL Storage Vessels. This subpart affects storage vessels for volatile organic liquids (VOLs) which have a storage capacity greater than or equal to 19,813 gallons and which commenced construction, reconstruction, or modification after July 23, 1984. The facility operates storage vessels subject to this subpart. 40 CFR Part 63 Subpart CC overlap provisions for storage vessels specify compliance with the inspection requirements of 40 CFR Part 60

Subpart Kb except as noted in 40 CFR 63.640(n)(8). The applicable requirements from 40 CFR

Part 60 Subpart Kb and 40 CFR Part 63 Subpart CC are incorporated into the permit for tanks.

The refinery operates many process tanks within its process units for blending, reactions, surge control, bottoms receivers, or other similar purposes. Generally these tanks collect discharged raw or intermediate materials from equipment within the process before it is transferred to other equipment within the process. Process tanks are specifically exempt from the definition of storage vessel under Subpart Kb.

Subpart GG, Stationary Gas Turbines. There are no stationary gas turbines at this facility.

Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing

Industry. This subpart affects each valve, pump, compressor, pressure relief device, sampling connection system, open-ended valve or line, and flange or other connector in VOC service and any devices or systems required by this subpart which commenced construction or modification after January 5, 1981, and which is located at a synthetic organic manufacturing facility. The refinery is not a synthetic organic manufacturing facility and is not subject to this regulation.

However, certain portions of this regulation are referenced for compliance with 40 CFR Part 63

Subpart CC and 40 CFR Part 60 Subpart GGG. See details in the Subpart GGG regulatory applicability.

Subpart XX, Bulk Gasoline Terminals. This subpart affects loading racks at bulk gasoline terminals, which deliver liquid product into gasoline tank trucks and that commenced construction or modification after December 17, 1980. Subpart XX affects the total of all the loading racks at a bulk gasoline terminal. “Loading rack” is defined as “the loading arms, pumps, meters, shutoff valves, relief valves, and other piping and valves necessary to fill delivery tanks trucks.” The gasoline rail loading rack Load-SF is subject to this subpart, but is required to comply only with the requirements of 40 CFR Part 63 Subpart CC (Refinery MACT I). Subpart CC specifies compliance using requirements from 40 CFR Part 63 Subpart R. Subpart R specifies compliance using some requirements from 40 CFR 60 Subpart XX. The applicable requirements


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78 from 40 CFR Part 63 Subpart CC, 40 CFR Part 63 Subpart R, and 40 CFR Part 60 Subpart XX are incorporated into the permit for the gasoline loading rack.

Subpart GGG, Equipment Leaks of VOC in Petroleum Refineries. This subpart affects each valve, pump, pressure relief device, sampling connection system, open-ended valve or line, and flange or other connector in a process unit and each compressor in VOC service which commenced construction or modification after January 4, 1983, and which is located at a petroleum refinery. This regulation specifies using portions of NSPS Subpart VV. For any affected equipment in >5 wt% organic HAP service, 40 CFR Part 63 Subpart CC requires affected equipment to comply only with the requirements from 40 CFR Part 63 Subpart CC.

Subpart CC specifies compliance using requirements from 40 CFR Part 60 Subpart VV. The applicable requirements from 40 CFR Part 63 Subpart CC, 40 CFR Part 60 Subpart VV, and 40

CFR Part 60 Subpart GGG are incorporated into the permit for piping component fugitive leaks.

The facility has voluntarily agreed that all existing affected equipment was modified after

January 4, 1983 under the provisions of 40 CFR 60.14 or 60.15, regardless of construction date.

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. The distillation units constructed, reconstructed, or modified after December 30, 1983 currently do not produce NSPS Subpart

NNN-listed chemicals that are sold as feedstocks to a SOCMI unit or used within the refinery as feedstocks to SOCMI units.

Subpart OOO, Standards of Performance for Nonmetallic Mineral Processing Plants. The coke processed at the Coke Handling Facility is not considered a mineral and, therefore, is not subject to this subpart.

Subpart QQQ, VOC Emission from Petroleum Refinery Wastewater Systems. This subpart applies to individual drain systems, oil-water separators, and aggregate facilities located in a petroleum refinery and which commenced construction, modification, or reconstruction after

May 4, 1987. Drains are required to be equipped with water seal controls. Junction boxes are required to be equipped with a cover and may have an open vent pipe. Sewer lines shall not be open to the atmosphere and shall be covered or enclosed in a manner so as to have no visual gaps or cracks in joints, seals, or other emission interfaces.

The facility operates sewer components that are subject to this subpart. The overlap provisions for wastewater in 40 CFR Part 63 Subpart CC specify that Group 1 wastewater streams managed in a piece of equipment that is also subject to Subpart QQQ are required only to comply with

Subpart CC. Subpart CC specifies compliance in accordance with 40 CFR Part 61 Subpart FF.

The applicable requirements from 40 CFR Part 63 Subpart CC, 40 CFR Part 60 Subpart QQQ,


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79 and 40 CFR Part 61 Subpart FF are incorporated into the permit under the EUG for process sewer component fugitive leaks.

Storage vessels subject to the standards and associated requirements of NSPS Subparts K, Ka or

Kb are not subject to Subpart QQQ. However, for oil-water separators also subject to 40 CFR

Part 61 Subpart FF (or subject to 40 CFR Part 63 Subpart CC which requires compliance with

Subpart FF), the Subpart FF alternate standards for oil-water separators specify compliance with the alternate standards for oil-water separators in Subpart QQQ, which lists the standards for floating roofs in Subpart Kb along with a few requirements specific to Subpart QQQ. The applicable requirements from 40 CFR Part 63 Subpart CC, 40 CFR Part 61 Subpart FF, and 40

CFR Part 60 Subpart QQQ and Subpart Kb are incorporated into the permit for tanks considered oil-water separators.

Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion

Engines. This subpart 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 owns and operates emergency CI ICE that are subject to Subpart IIII. The refinery may temporarily rent and operate CI ICE on-site that are subject to Subpart IIII. However, due to the temporary nature of their operation and because they are not owned by the refinery, rental CI ICE providers are responsible for proper operation and maintenance, emission standard compliance demonstrations, initial notifications, and recordkeeping.

Subpart JJJJ, Stationary Spark Ignition (SI) Internal Combustion Engines (ICE). This subpart was proposed on June 12, 2006. For the purposes of this subpart, the date of construction is the date the engine is ordered by the owner or operator. All owners or operators of SI ICE will be required to keep records of all maintenance conducted on an engine per 40 CFR 60.4245(a)(2).

The facility does not presently have any engines subject that would be subject to this subpart.

NESHAP, 40 CFR Part 61 [Subparts A, M, and FF are Applicable]

Subpart A, General Provisions. This subpart requires submittal of notifications for NESHAPaffected sources related to commencement of construction, initial startup, and initial performance testing. This subpart also contains general recordkeeping, monitoring and testing requirements.

These requirements apply to equipment subject to NESHAP Part 61 regulations, unless otherwise specified by those subparts. These requirements are incorporated into the permit under EUG-FW for facility-wide applicable requirements.

Subpart J, Equipment Leaks of Benzene. This subpart applies to pumps, compressors, pressure relief devices, sampling connections, open-ended lines, valves, or flanges and other connectors, product accumulator vessels, and control devices or systems that are intended to operate in benzene service, which is defined as having more than 10% benzene by weight. The benzene concentration for each affected unit at the facility is less than 10% by weight and is not intended to operate in benzene service. Therefore, Subpart J is not applicable to this facility.


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80

Subpart M, Asbestos. This subpart applies to certain activities involving asbestos. The facility engages in asbestos removal, demolition and disposal and is subject to the applicable standards in this subpart. These requirements are incorporated into the permit under EUG-FW for facilitywide applicable requirements.

Subpart FF, Benzene Waste Operations. This subpart applies to waste streams at chemical manufacturing plants, coke-byproduct recovery plants, and petroleum refineries that have benzene-containing hazardous waste treatment, storage, and disposal facilities. Affected equipment at the facility includes tanks, containers, and individual drain systems. Affected equipment handling waste streams where the benzene content is less than 10 ppmw is exempted.

The stormwater collection system is segregated from the process sewer system and, therefore, is not subject to this subpart. The facility operates equipment that is subject to this subpart. The requirements from this subpart are incorporated into the permit under EUGs for process sewer equipment leaks and for tanks handling wastewater.

NESHAP, 40 CFR Part 63 [Subparts A, Q, CC, DD, UUU, and EEEE are Applicable]

Subpart A, General Provisions. This subpart requires submittal of notifications for NESHAPaffected sources related to commencement of construction, initial startup, and initial performance testing. This subpart also includes general provisions for operation and maintenance of affected equipment, startup, shutdown and malfunction plans, monitoring, recordkeeping and reporting.

These requirements apply to equipment subject to NESHAP Part 63 regulations, unless otherwise specified by those subparts. These requirements are incorporated into the permit under EUG-FW for facility-wide applicable requirements.

Subpart A also specifies general control device requirements for control devices used to comply with applicable subparts. Standards for flares used to comply with emissions limitations are stated in 40 CFR 63.11. 40 CFR 63.11(b)(7) states that the maximum steam-assisted flare exit velocity,

V max

, shall be determined by the following equation:

Log

10

(V max

) = (H t

+ 28.8)/31.7 where H t

= the net heating value of the flared gas, MJ/SCM. 63.11(b) also requires that the flare be monitored for the presence of a pilot flame and that the flare be operated with no visible emissions.

The facility operates flares that are subject to this subpart since they control HAP streams from

Subpart CC and UUU affected equipment. Each flare’s pilot flame is monitored by either by thermocouples or infrared cameras and each flare meets the design criteria specified.

The permittee has calculated that under a worst case scenario, Flare-Temp would meet the requirements of performance testing under NSPS Subpart A. EPA notified Oklahoma Air Quality on September 12, 2000 that the calculations were sufficient to demonstrate that the flare would meet the requirements of NSPS Subpart A and granted a waiver of performance testing. This waiver can be extended to flare performance testing under this part because the criteria are identical to those specified in NSPS Subpart A.


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Subpart Q, Industrial Process Cooling Towers. This subpart applies to all new or existing industrial process cooling towers (IPCTs) that utilize chromium–based water treatment chemicals on or after the rule effective date of September 8, 1994. The facility operates two IPCTs, Y-0002 and Y-0002A, that were operated with chromium-based water treatment chemicals after

September 8, 1994. Chromium-based water treatment chemicals were eliminated from use before the compliance date of March 8, 1996. Therefore, the only requirements from this subpart that applied to Y-0002 and Y-0002A was the initial notification and notification of compliance status.

Subpart R, Bulk Gasoline Terminals and Pipeline Breakout Stations. This subpart applies to bulk gasoline terminals with a throughput greater than 75,700 liters per day. Bulk gasoline terminals or pipeline breakout stations with an SIC code 2911 located within a contiguous area and under common control with a refinery complying with 40 CFR Part 63 Subpart CC are not subject to

Subpart R standards, except as specified in Subpart CC, §63.650.

Subpart CC, Petroleum Refineries (Refinery MACT I). This subpart establishes standards for control of HAP from petroleum refineries. Subpart CC affects process vents (except FCCUs and catalyst regenerators), storage vessels, wastewater streams and treatment, equipment leaks, gasoline loading racks, marine vessel loading system, and pipeline breakout stations. Of the affected equipment, storage tanks, equipment leaks, process vents, wastewater streams and treatment, and a gasoline loading rack are present at this refinery.

Storage tanks: existing storage tanks equal to or larger than 10,567 gallons containing any listed HAP are subject. If the tanks are greater than or equal to 46,579 gallons, have a true vapor pressure of greater than 1.2 psia annual average or greater than 1.5 psia maximum, and contain more than 4 wt% HAP, the tanks are subject to controls. Applicable requirements for storage tanks are incorporated into the permit under the EUGs for storage vessels.

Process Vents: existing refinery unit process vents with greater than 20 ppm HAP and which emit more than 33 kg/day VOC are subject to control requirements. Subpart CC requires affected vents to be equipped with 98% efficient controls, to be vented to a flare, to be vented to a combustion unit firebox, or to be reduced to 20 ppm HAP or less. All Group 1 process vents at this refinery are vented to flares. These requirements are incorporated into the permit under the

EUG for Group 1 miscellaneous process vents.

Equipment Leaks: these standards affect valves, flanges, pumps, and compressors except for compressors in hydrogen service. Process streams with 5 wt% or more HAP are subject to standards. These requirements are incorporated into the permit under the EUG for piping component fugitive equipment leaks.

Gasoline Loading Terminal: Subpart CC, §63.650 requires compliance with certain standards of 40 CFR Part 63 Subpart R. Subpart R limits total VOC emissions to 10 mg per liter gasoline loaded, requires a leak detection and repair program on meters, arms, and other components which may leak, and requires that tank trucks loaded be vapor-tight. Load-SF is subject to these requirements. These requirements are incorporated into the permit for the gasoline loading rack.

Wastewater Streams and Treatment: For Group 1 wastewater streams, Subpart CC specifies compliance with the standards, monitoring, recordkeeping, and reporting requirements of 40 CFR Part 61 Subpart FF. These requirements are incorporated into the permit under the

EUG for process sewer fugitive equipment leaks and tanks handling wastewater streams.


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Subpart DD, Off-Site Waste and Recovery Operations. This subpart established standards for control of air emissions from off-site waste that contains listed HAP. The refinery receives less than 1 megagram per year of any one HAP from off-site waste and meets the exemption requirements in 40 CFR 63.680(d). Therefore the facility is exempted from the requirements in

§§ 63.682 through 63.699. The recordkeeping requirements of §63.680(d)(1), (2), and (3) still apply, which require an initial determination of the amount of off-site HAP and whenever it changes enough that to possibly exceed the 1 Mg/year limitation. Documentation must also be kept demonstrating the calculation for the amount of HAP received. These requirements are incorporated into the permit under as facility-wide applicable requirements.

Subpart UUU, Petroleum Refineries: Catalytic Cracking Units, Catalytic Reforming Units, and

Sulfur Plants (Refinery MACT II). This subpart affects the following:



Process vents on each catalytic cracking unit that is associated with regeneration of the catalyst.



Process vents on each catalytic reforming unit that is associated with regeneration of the catalyst.



Process vents that vent from a Claus or other type of sulfur recovery plant unit or the tail gas treatment unit.

This subpart does not apply to a gaseous stream routed to a fuel gas system (§63.1562(f)(5)).

Fluidized-bed catalytic cracking unit catalyst regenerators (FCCUs) are to comply with the requirements of this subpart by no later than April 11, 2005 for control of metal and organic HAP emissions. FCCUs that are in compliance with NSPS Subpart J for PM (§60.102) are in compliance with this subpart for metal HAP emissions (§63.1564(a)(1)). FCCUs not subject to

NSPS Subpart J for PM can comply with the metal HAP emission requirements of this subpart through one of the four options in paragraphs §§63.1564(a)(1)(i) through (iv). FCCUs that are in compliance with NSPS Subpart J for CO (§60.103) are in compliance with this subpart for organic HAP emissions (§63.1565(a)(1)). FCCUs not subject to NSPS Subpart J for CO can comply with the organic HAP emission requirements of this subpart through one of the two options in paragraphs §§63.1565(a)(1)(i) or (ii). Both the No. 4 and No. 5 FCCU are subject to

Subpart UUU. The No. 4 FCCU regenerator is currently not subject to NSPS Subpart J for PM, but will be subject by December 31, 2008 under the Consent Decree. The No. 5 FCCU regenerator became subject to NSPS Subpart J for PM on December 31, 2006 under the Consent

Decree. Both FCCUs are currently subject to NSPS Subpart J for CO under the Consent Decree and will, therefore, be in compliance with Subpart UUU for organic HAP emissions.

Subpart EEEE, Organic Liquids Distribution (OLD MACT). This subpart affects storage tanks, transfer racks, equipment leak components, and transport vehicles in organic liquid service that are not covered by another MACT. The definition of organic liquid for applicability to this subpart excludes gasoline, kerosene, and distillate oils and fuel oils, and any liquid with a true vapor pressure less than 0.1 psia. Controls are not required for storage tanks with a capacity of less than 5,000 gallons. The facility is an existing source for the purposes of compliance with this subpart. These requirements are incorporated into the permit under the EUG for tanks subject to

Subpart EEEE.


DRAFT

83

Subpart FFFF, Miscellaneous Organic Chemical Manufacturing (MON MACT). This subpart established requirements for chemical manufacturing process units that meet the criteria specified. The refinery is not subject to this regulation since it is subject to 40 CFR Part 63

Subpart CC.

Subpart YYYY, Stationary Combustion Turbines. This subpart affects new and reconstructed stationary turbines constructed after January 14, 2003. The refinery does not operate any combustion turbines.

Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart affects RICE with a site-rating greater than 500 brake horsepower that are located at a major source of HAP emissions. A proposed rule was published on June 12, 2006 that would revise Subpart ZZZZ to apply to RICE at both major and area sources of HAP. This facility does not presently have any

RICE that are subject to the existing subpart or that would be subject to specific requirements under the proposed revisions. However, in accordance with §63.1(b)(3) and 63.10(b)(3) of 40

CFR Part 63 Subpart A, the facility must keep a record of MACT applicability determination for

5 years for engines that do not meet the applicability criteria of this subpart.

Subpart DDDDD, Industrial Boilers and Process Heaters. Subpart DDDDD regulated HAP emissions from industrial boilers and process heaters. In March, 2007, the EPA filed a motion to vacate and remand this rule back to the agency. The rule was vacated by court order, subject to appeal, on June 8, 2007. No appeals were made and the rule was vacated on July 30, 2007.

The facility has existing and proposed boilers and process heaters that are large units under

Subpart DDDDD, defined as watertube boilers and process heaters with heat input capacities greater than 10 million British thermal units per hour (MMBtu/hr). All these boilers and process heaters will be fired with natural gas, refinery fuel gas, and/or PSA offgas. Therefore, these boilers and process heaters were required under the vacated MACT to meet the CO concentration standard of 400 ppmdv corrected to 3% oxygen. Process heaters H-0016, H-9851, NH-5001, and

NH-0057, and boilers B-0008, B-0009, and B-0010, have heat input capacities greater than 100

MMBtu/hr and were required under the vacated MACT to use CO continuous emission monitors

(CEMS) to demonstrate that average CO emissions, on a 30-day rolling average, are equal to or less than the CO standard. The heat input capacities of process heaters, H-1001, H-9901, and H-

9902 are less than 100 MMBtu/hr and they were required under the vacated MACT to conduct initial and annual compliance tests to demonstrate compliance with the CO standard. The permittee was also required to meet the testing, monitoring, and recordkeeping requirements of this subpart. None of the requirements of Subpart DDDDD now exist and previous Specific

Conditions requiring compliance with Subpart DDDDD from previous permits will not be included in this permit.

EPA is planning on issuing guidance (or a rule) on what actions applicants and permitting authorities should take regarding MACT determinations under either Section112(g) or Section

112(j) for sources that were affected sources under Subpart DDDDD and other vacated MACTs.

It is expected that the guidance (or rule) will establish a new timeline for submission of section

112(j) applications for vacated MACT standards. At this time, AQD has determined that a 112(j)


DRAFT

84 determination is not needed for sources potentially subject to a vacated MACT, including

Subpart DDDDD. This permit may be reopened to address Section 112(j) when necessary.

Subpart GGGGG, Site Remediation. This subpart established emission limitations and work practice standards from site remediation activities. Site remediation activities can be exempt from this regulation if certain criteria are met. The facility conducts groundwater recovery and remediation of contaminated soils. The groundwater recovery is presently exempt from compliance with the standards of the regulation because it is being performed under a RCRA Part

B Permit #007233836. Remediation of contaminated soils is exempt from compliance with the standards of the regulation if it is completed within 30 consecutive calendar days.

Subpart PPPPP, Engine Test Cells/Stands. This subpart regulates equipment and activities associated with engine test cells/stands used for testing uninstalled stationary or uninstalled mobile (motive) engines. The preamble to the final rule and the Background Information

Document both clarify that test cells that are operated to test or evaluate fuels (such as knock engines), transmissions, electronics, etc. are not part of the source category and are not subject this regulation. The refinery operates knock engines to evaluate fuels and, therefore, is not covered by this regulation.

Compliance Assurance Monitoring, 40 CFR Part 64 [Applicable]

Compliance Assurance Monitoring (CAM), as published in the Federal Register on October 22,

1997, applies to any pollutant specific emission unit at a major source that is required to obtain a

Title V permit, if it meets all the following criteria:



It is subject to an emission limit or standard for an applicable regulated air pollutant.



It uses a control device to achieve compliance with the applicable emission limit or standard.



It has potential emissions, prior to the control device, of the applicable regulated air pollutant of 100 TPY.

Facilities that submit Title V Permit applications prior to April 20, 1998 are not subject to CAM until the next Title V Permit renewal or Title V Permit significant modification. The facility’s original application was received on March 24, 1998.

The No. 4 FCCU and No. 5 FCCU NO

X

and SO

2

emissions meet CAM applicability criteria at the time of this writing, but are exempt from CAM until such time that the Title V permit is due for renewal. However, because this Title V permit specifies NO

X

and SO

2

monitoring provisions meeting the definition of continuous compliance determination methods in 40 CFR 64.1, the No.

4 FCCU and No. 5 FCCU NO

X

and SO

2

emissions are exempt from the CAM rule upon issuance of this permit per 40 CFR 64.2(b)(vi).

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

Toxic and flammable substances subject to this regulation are present in the facility in quantities greater than the threshold quantities. The most recent revision of the Risk Management Plan was submitted to EPA on August 17, 2006. More information on this federal program is available on


DRAFT

85 the web page: www.epa.gov/ceppo . These requirements are incorporated into the Standard


Stratospheric Ozone Protection, 40 CFR Part 82 [Subparts B, E, F and H are Applicable]

Subpart B identifies requirements for facilities that maintain, service and repair motor vehicle air conditioner (MVAC) and MVAC-like equipment.

Subpart E specifies container labeling requirements.

Subpart F contains standards and required practices for appliance maintenance, service and repair. It includes standards for equipment used during maintenance, service and repair of appliances and certification requirements for persons performing maintenance, service and repair.

Owners and operators of commercial or industrial process refrigeration equipment must comply with leak repair requirements. Owners and operators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant added.

The facility maintains, services, and repairs MVAC and MVAC-like equipment subject to

Subpart B. The facility owns or operates commercial and industrial process refrigeration equipment including equipment containing more than 50 pounds of refrigerant subject to Subpart

F. Facility employees perform maintenance, service, and repairs for commercial and industrial process refrigeration. The facility owns halon-containing equipment that is subject to the provisions of Subpart H. The applicable requirements of this regulation are incorporated into the

Standard Conditions of the permit and apply to EUG-FW for facility-wide applicable requirements.

SECTION XII. COMPLIANCE

Inspection/Testing

The facility is inspected on a regular basis by AQD Compliance personnel. No specific inspection or testing is necessary for this Part 70 permit application.

Compliance Plans

1. The facility has entered into Consent Orders with DEQ to resolve various issues of noncompliance. Requirements of the Consent Orders are summarized below.

Consent Order

Description

Equipment Involved Status

NSPS Subpart J

Equipment

Consent Decree C-IV-

88-517-A (6/3/88)

H-0059, H-6014, H-6015

Obligations of the Consent Order were met and the Consent Order was closed as of

12/31/91. Ongoing obligations were included in subsequent permitting action, and those permits will be incorporated into the Title V permit.


Consent Order

Description


No. 4 FCCU Opacity

Consent Order Case

No. 97-282 (9/17/97)

Consent Order Case

No. 98-094 (6/26/98)

NSPS Subparts A, J,

GGG & QQQ

Equipment

Consent Order Case

No. 99-373 (1/12/00)

EPA Storage Tank

Emission Reduction

Partnership Program

(STERPP) (2/14/01)

NSPS and NSR/PSD

Issues

Consent Order Case

No. 00-196 & 00-

196(A) (7/11/00 &

4/12/02)

Status

DRAFT

86

No. 4 FCCU

No. 5 FCCU

Obligations of the Consent Order were met and the Consent Order was closed as of

9/12/03. Ongoing obligations were included in the Air Quality Council approved alternate opacity limit (AOL) issued 2/18/98. The obligations of the AOL will be incorporated into the Title V permit.

Obligations of Consent Order were met and

Consent Order was terminated upon issuance of Permit No. 98-169-O on 10/30/98. There are no ongoing obligations to be incorporated into the Title V permit.

Flare-EP, Flare-WP, Flare-

SP, Flare-CC, NSPS

Subpart GGG affected equipment, and NSPS

Subpart QQQ affected equipment.

Obligations of Consent Order were met and the Consent Order was closed as of 10/02/03.

There are no ongoing obligations to be incorporated into the Title V permit.

T-0015, T-0141, T-0147, T-

0165, T-0166, T-0176, T-

0177, and T-0178

Agreement is active. Remaining requirements to be completed by April 13, 2010 are to replace/retrofit slotted guidepoles on T-0177 and T-0178 or remove from regulated service.

Ongoing obligations include proper operation and maintenance of slotted guidepole controls, if installed. These obligations will be incorporated into the Title V permit.

Supplemental

Environmental Projects

(SEPs), NSPS Subpart

GGG affected equipment,

NESHAP 61 Subpart FF affected equipment, tank inspection program, tank permit modifications, flare valve monitoring, H-0001

H2S CEMS, EIS corrections, Title V

Application update, Flare-

Temp, Flare-EP, Load-SF,

Flare-CC FGRU project,

Clean Fuels PSD permit application, BACT analysis for H-29, and H-6014 & H-

6015 NO

X

Reduction

Technology

Obligations of Consent Order were met and the Consent Order was closed as of 7/11/03.

The only ongoing obligation is the Flare

Upset Gas Monitoring Plan provisions. For flare systems not equipped with flare gas recovery, the Flare Upset Gas Monitoring

Plan provisions from this Consent Order will be incorporated into the Title V permit.


DRAFT

87

Consent Order

Description

Equipment Involved Status

Consent Order Case

No. 01-395 (1/10/02)

Refinery 114 Consent

Decree resolving

Civil Action No. H-01-

4430 (12/20/01)

Temporary

Construction of SGP

Consent Order Case

No. 03-254 (8/1/03)

T-0041 E, T-0069, T-0184,

T-0915, NESHAP 61

Subpart FF affected equipment, and #3 Amine

Unit Permitting

NSPS Subpart GGG affected equipment,

NESHAP 61 Subpart FF affected equipment,

Heaters, Boilers, FCCUs, and Flares

Sat Gas Plant


Consent Order was closed as of 12/29/03.


Consent Decree is active. The facility has incorporated into the Title V permit certain obligations as required per the Consent

Decree and certain requirements that that facility wishes to survive the closure of the

Consent Decree.




Consent Order Case

No. 06-106 (5/10/06)

Tank inspections, NSPS

Subpart J monitoring for

No. 4 FCCU and No. 5

FCCU/B-5004, tank VOC records, and fugitive equipment leak monitoring




Consent Order Case

No. 06-322 (10/30/06, as amended)

MACT II compliance for

No. 5 FCCU

Obligations of Consent Order will be incorporated into the Title V permit.

Consent Order Case

No. 06-357 (11/28/06)

No. 5 FCCU CO Emissions




2. The No. 1 Hydrogen Plant pressure swing absorber (PSA) off-gas stream combusted by heater

H-8801/8802 and the No. 2 Hydrogen Plant pressure swing absorber (PSA) off-gas stream combusted by heater H-9851 are not continuously monitored as per the methods specified in 40

CFR 60.105(a)(3). The PSA off-gas meets the NSPS Subpart J definition of refinery fuel gas.

By nature of the process, the PSA off-gas contains no sulfur. The facility has submitted an alternative monitoring request to EPA for these heaters as allowed under 40 CFR 60.13 and is awaiting EPA’s response.

Milestone of Progress Compliance Deadline

H-8801/8802 and H-9851: Obtain alternative monitoring approval from EPA for the continuous monitoring requirements of 40 CFR 60.105(a)(3) for the PSA off-gas streams combusted by the heaters.

Alternative monitoring request submitted to EPA

Region VI on February 16, 2006 for H-8801/8802 and was amended on February 28, 2007 to include

H-9851. Facility is awaiting approval. Until the alternative monitoring request is acted on by EPA, the facility will comply with the proposed provisions of the alternative monitoring request.


DRAFT

88

3. 40 CFR Part 60 Subpart J requires that a facility demonstrate continuous compliance with the sulfur emission limitations of §60.104(b)(2) using Reference Method 8 (RM-8), which is a manual, wet chemistry-based test conducted during each 24-hour period that the unit is operating.

The facility has requested approval from EPA for an alternate measurement method of using SO

X

CEMS in lieu of RM-8 monitoring for the No. 4 FCCU. Subpart J also requires calculation of coke burn-off rate to demonstrate compliance with §60.102(a)(1) and §60.104(b)(2). The facility has requested approval from EPA for an alternative monitoring method for calculating coke burn-off for the No. 5 FCCU/B-5004. The facility is awaiting EPA’s response for these requests.

Milestone of Progress

No. 4 FCCU: Obtain alternative SO

2

measurement method approval from EPA Region VI for determining compliance with SO

X

emissions in 40

CFR 60.104(b)(2).

No. 5 FCCU/B-5004: Obtain alternative coke burnoff calculation method approval from EPA Region

VI for determining compliance with PM emissions in 40 CFR 60.102(a)(1).

Compliance Deadline

Alternative measurement method approval request submitted to EPA Region VI on July 31, 2003.

Facility is awaiting EPA approval. In the interim, the facility will comply with the proposed provisions of the alternative monitoring request.

Alternative measurement method approval request submitted to EPA Region VI on February 11, 2005.

Facility is awaiting EPA approval. In the interim, the facility will comply with the proposed provisions of the alternative monitoring request.

4. A wet gas scrubber (WGS) was installed in 2006 on the No. 5 FCCU/B-5004 stack and will be installed on the No. 4FCCU stack to control sulfur dioxide and particulate matter emissions.

However, the water vapor in a WGS stack interferes with opacity readings measured by a COMS and renders the method unsuitable. The facility has requested EPA approval of an alternative opacity monitoring plans and is awaiting approval.


No. 5 FCCU/B-5004: Obtain alternative opacity monitoring approval from EPA Region VI for determining compliance with opacity requirements specified in 40 CFR Part 60 Subpart J.

No. 4FCCU: Obtain alternative opacity monitoring approval from EPA Region VI for determining compliance with opacity requirements specified in

40 CFR Part 60 Subpart J.


Alternative monitoring approval request submitted to EPA Region VI on April 18, 2007. Facility is awaiting approval. In the interim, the facility will comply with the proposed provisions of the alternative monitoring request.

Alternative monitoring approval request submitted to EPA Region VI on May 16, 2007. Facility is awaiting approval. In the interim, the facility will comply with the proposed provisions of the alternative monitoring request.

5. The EPA Storage Tank Emission Reduction Partnership Program (STERPP) is an agreement between the facility and EPA to retrofit or replace slotted guidepoles on floating roof tanks. The remaining tanks with slotted guidepoles to be retrofitted or replaced at the facility are T-0177 and

T-0178. The compliance deadlines are based on the next scheduled internal inspections, during which the tanks will be taken out of service and the guidepoles retrofitted or replaced.


DRAFT

89


T-0177 and T-0178: Replace/retrofit slotted guidepole or remove from regulated service.

Submit Certification of Compliance with STERPP

Agreement to EPA.

April 13, 2010


No mandatory deadline. Will be submitted upon completion of all obligations under STERPP

Agreement.

Tier Classification and Public Review

This application has been determined to be Tier II based on the request for an initial Title V operating permit for a major facility. The applicant published the “Notice of Filing a Tier II

Application” in The Ponca City News on March 30, 1998, a daily newspaper of general circulation in Kay County. The notice stated that the application was available for public review at the Ponca City Refinery Continental Building, 1000 S. Pine, Ponca City, Oklahoma. A draft of this permit will also be made available for public review for a period of thirty days. The facility is located within 50 miles of the border with the state of Kansas and that state will be notified of the draft permit.

The applicant has requested concurrent public and EPA review. If no comments are received from the public, the draft permit will be considered the “proposed” permit for EPA review.

The applicant has submitted an affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without their knowledge. The affidavit certifies that the applicant owns the property.

Information on all permit actions is available for review by the public in the Air Quality section of the DEQ Web page: http://www.deq.state.ok.us/

Fees Paid

A major source initial operating permit fee of $2,000 has been paid.

SECTION XIII. SUMMARY

The facility was constructed and is operating as described in the application. Ambient air quality standards are not threatened at this site. Except as noted in Section XII, there are no active compliance or enforcement Air Quality issues that would affect the issuance of this permit. AQD

Compliance and Legal agree with the issuance of the permit. Issuance of the operating permit is recommended, contingent on public, the state of Kansas, and EPA review.

DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

ConocoPhillips Company

Ponca City Refinery Permit No. 98-104-TV

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

Quality on March 5, 1998, with supplemental information dated March 13, 1998, December 19,

2001, November 8, 2002, July 31, 2003, August 14, 2003, October 15, 2004, and October 20,

2004. Updates were also received between 1998 and 2007 to incorporate new and modified permits. The Evaluation Memorandum dated September 18, 2007 explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain limitations or permit requirements. Continuing operations under this permit constitutes acceptance of, and consent to the conditions contained herein:

1. Points of emissions, emission limitations, and standards. [OAC 252:100-8-6(a)]

Note: tank capacity, roof type, and construction/modification dates are provided solely for the purposes of documenting regulatory applicability and are not to be construed as operating limitations. The capacities listed represent the physical tank volumes using the internal cross sectional area and tank shell heights (not taking into consideration safe fill levels).


EU ID Point ID

Physical

Capacity

(gallon)

Roof

Type

T-0021E T-0021E

3,348,342

EFR

T-0101 T-0101 440,608 IFR

T-0114 T-0114

T-0148

T-0149 T-0149

T-0150

T-0151 T-0151

T-0153

T-0154 T-0154

T-0155

T-0158 T-0158

T-0159

T-0160 T-0160

T-0162

T-0163 T-0163

T-0164

T-0148

T-0150

T-0153

T-0155

T-0159

T-0162

T-0164

439,433

IFR

3,377,633 IFR

3,377,633

3,377,633 IFR

3,377,633

IFR

3,357,528 IFR

6,344,761

3,377,633 IFR

3,351,095

IFR

3,391,305 IFR

3,343,857

3,310,885 IFR

3,330,990

IFR

EFR

IFR

IFR

3,351,095 IFR

T-0167 T-0167 1,363,316 IFR

Construction/

Modification

Date

1923

1977

1923

1924

1923

1924

1924

1924

1924

1976

1954

1919

1919

1923

1923

1923

1923

Vapor

Pressure

Limit

(psia) (3)

Throughput

Limit

(gal/yr) (1)

<11.1

<11.1

<11.1

<11.1

<11.1

<11.1

<11.1

<11.1

<11.1

(5)

<11.1

<11.1

<11.1

<11.1

(5)

<11.1

-

<11.1

343,980,000

-

-

-

-

-

-

-

-

-

-

-

<11.1

<11.1

-

-

VOC

Limit

(TPY) (2)

-

(4)

(5)

(5)

(4)

-

7.8

-

-

-

-

-

-

-

-

-

-

SPECIFIC CONDITIONS PERMIT NO. 98-104-TV

DRAFT

2

EU ID Point ID

Physical

Capacity

(gallon)

Roof

Type

Construction/

Modification

Date

Vapor

Pressure

Limit

(psia) (3)

Throughput

Limit

(gal/yr) (1)

VOC

Limit

(TPY) (2)

T-0170

T-0901

T-0902

T-0953

T-0170

T-0901

T-0902

T-0953

1920

1924

1971

1944

<11.1

-

<11.1

252,000,000

<11.1

252,000,000

<11.1

252,000,000

-

-

-

-

1. 12-month rolling total.

2. Calendar year total unless otherwise specified.

3. Maximum calendar month average above which 40 CFR Part 60 Subpart G requires a closed vent system with control device or equivalent control device.

4. T-0101 and T-0164 combined VOC emission limit is 30 TPY.

5. T-0114, T-0156, T-0160, and T-0166 are limited to a combined throughput of 1,450,000,000 gallons per year (12-month rolling total) and a combined VOC limit of 60 TPY (calendar year total).

1,078,341 IFR

3,330,990

IFR

3,357,528 IFR

2,339,924

IFR a. The listed tanks are Group 1 storage vessels and are subject to the control standards of 40

CFR Part 63 Subpart CC. 40 CFR 63.646(a) specifies that Group 1 storage vessels subject to

Subpart CC shall comply with the requirements of 40 CFR Part 63, Subpart G ( §§ 63.119 through 63.121), except as provided in

§

63.646(b) through (l). For these tanks, the permittee shall comply with all applicable requirements of Subpart CC including, but not limited to the following: [40 CFR Part 63 Subpart CC] i.

The mechanical design and operating specifications for internal floating roof tanks of 40

CFR 63.119(b) and 63.646(f). ii.

The mechanical design and operating specifications for external floating roof tanks of 40

CFR 63.119(c) and 63.646(f). iii.

The compliance procedures for internal floating roof tanks of 40 CFR 63.120(a) and

63.646(e). iv.

The compliance procedures for external floating roof tanks of 40 CFR 63.120(b) and

63.646(e). v.

The reporting requirements of 63.654(e). vi.

The recordkeeping requirements of 40 CFR 63.123 and 63.654(i). b. For the listed tanks with throughput limits, the permittee shall keep monthly records of the

12-month rolling total throughput for months when the tanks are in VOL service.

[OAC 252:100-43]


DRAFT

3 c. For the listed tanks with calendar year total VOC emission limits, the permittee shall keep records of annual total VOC emissions when the tanks are in VOL service. Annual VOC emissions shall be determined from VOC emissions correlations based on emission equations used in the latest version of EPA TANKS program or the permittee may use the latest version of the EPA TANKS program. [OAC 252:100-43]



EU ID

T-0014E

T-0017E

T-0015

T-0117

T-0119

T-0121

Point ID

T-0014E

T-0017E

T-0015

T-0117

T-0119

T-0121

Physical

Capacity

(gallons)

258,678

485,310

541,420

9,340,615

9,340,615

4,694,188

Roof

Type

EFR

EFR

EFR

EFR

EFR

IFR

Construction/

Modification

Date

1995

1987

1995

1990

1990

2005

Vapor

Pressure

Limit

(psia) (4)

Throughput

Limit

(gal/yr) (1)

<0.5 (4) and (3)

168,000,000

<11.1

1,500,000

<11.1 252,000,000

<11.1 (5)

<11.1 229,950,000

<11.1 (5)

<11.1 191,625,000

<11.1 2,640,000

<11.1 191,625,000

<11.1

436,800

<11.1

<11.1

218,400

-

<11.1 840,000

VOC

Limit

(TPY)

(2)

4.2 (6)

& <11.1

<11.1

4.2 (6)

& <11.1

4.2 (6)

& <11.1

(3)

(3)

-

636,384,000

<11.1 630,000,000

(3)

(3)

-

15.8

-

-

T-0141

T-0147

T-0156

T-0165

T-0166

T-0176

T-0177

T-0178

T-0357

T-0402

T-0540

T-0690

T-0141

T-0147

T-0156

T-0165

T-0166

T-0176

T-0177

T-0178

T-0357

T-0402

T-0540

T-0690

30,455 EFR

3,383,872 EFR

3,826,376

EFR

3,405,021 EFR

4,060,647 EFR

1,355,859 IFR

116,512

IFR

454,087 IFR

8,812 EFR

11,844 EFR

170,040

IFR

13,324 EFR

1990

1989

1993

1991

1991

1988

1988

1988

1993

1993

1987

1992



3. T-0014E and T-0015 are limited to a combined throughput of 4,003,000 gallons per year (12-month rolling total) and a combined VOC limit of 6.6 TPY (calendar year total).

4. Maximum calendar month average above which 40 CFR Part 60 Subpart Kb requires a closed vent system with control device or equivalent control device.

5. T-0114, T-0156, T-0160, and T-0166 are limited to a combined throughput of 1,450,000,000 gallons per year (12-month rolling total) and a combined VOC limit of 60 TPY (calendar year total).

6. Annual average.

(5)

-

(5)

-

3.1

-

-

3.1

-

3.1

-

-


DRAFT

4 a. Except for T-0141, T-0357, T-0402, and T-0690, the listed tanks are subject to 40 CFR Part

60 Subpart Kb and 40 CFR Part 63 Subpart CC for Group 1 storage vessels. The “overlap” provisions of 40 CFR 63.640(n)(1) state that Group 1 storage vessels are required to comply only with the provisions of Subpart Kb, except as noted in 40 CFR 63.640(n)(8)(i)-(viii). For these tanks, the permittee shall comply with all applicable requirements of Subpart Kb and

Subpart CC including, but not limited to, the following:

[40 CFR Part 60 Subpart Kb and Part 63 Subpart CC] i.

The mechanical design and operating specifications for internal floating roof tanks of 40

CFR 60.112(a)(1). ii. The mechanical design and operating specifications for external floating roof tanks of 40

CFR 60.112b(a)(2). iii. The testing and procedures for internal floating roof tanks of 40 CFR 60.113b(a) & 40

CFR 63.640(n)(8). iv. The testing and procedures for external floating roof tanks of 40 CFR 60.113b(b) & 40

CFR 63.640(n)(8) v. The reporting and recordkeeping requirements of 40 CFR 60.115b and 40 CFR 63.654(e) and (i). b. T-0141, T-0357, T-0402, and T-0690 are subject to 40 CFR Part 61 Subpart FF and 40 CFR

Part 63 Subpart CC for wastewater streams. These storage vessels do not store a Group 1 wastewater stream as defined in Subpart CC; therefore, only the general Subpart CC storage vessel recordkeeping provisions apply. The storage tank standards of Subpart FF are applicable. Subpart FF alternate standards for storage tanks specify compliance with 40 CFR

Part 60 Subpart Kb. For these tanks, the permittee shall comply with all applicable requirements of Subpart FF and Subpart CC including, but not limited to, the following:

[40 CFR Part 61 Subpart FF and Part 63 Subpart CC] i. The mechanical design and operating specifications for external floating roof tanks of 40

CFR 60.112b(a)(2). ii. The testing and procedures for external floating roof tanks of 40 CFR 60.113b(b) and 40

CFR 63.640(n)(8). iii. The reporting and recordkeeping requirements of 40 CFR 60.115b, 40 CFR 61.356 and

357, and 40 CFR 63.654(e) & (i). c. For the listed tanks with throughput limits, the permittee shall keep monthly records of the


[OAC 252:100-43]

D-0924

T-0002

T-0003

T-0038

T-0041E

T-0051

T-0059

T-0063

T-0064

T-0070

T-0077


DRAFT

5 d. For listed tanks with calendar year total VOC emission limits, the permittee shall keep records of annual total VOC emissions when the tanks are in VOL service. Annual VOC emissions shall be determined from VOC emissions correlations based on emission equations used in the latest version of EPA TANKS program or the permittee may use the latest version of the EPA TANKS program. [OAC 252:100-43] e. The permittee shall maintain records of the annual average vapor pressure for materials stored in tanks T-0014E, T-0015, and T-0117. [OAC 252:100-43] f. While in hydrocarbon service, T-0165 must be operated with either a solid guidepole or with slotted guidepole controls which meet the following specifications and requirements:

[STERPP Agreement (2/14/01)] i. The sliding cover shall be in place over the slotted guidepole opening through the floating roof at all times except when the sliding cover must be removed for access. If the control technology includes a float, the float shall be floating within the guidepole at all times except when it must be removed for access to the stored liquid or when the tank is empty. ii. The permittee shall visually inspect the deck fitting for the slotted guidepole at least once every 10 years and each time the vessel is emptied and degassed. If the slotted guidepole deck fitting or control devices have defects, or if a gap of more than 1/8 inch exists between any gasket required for control of the slotted guidepole deck fitting and any surface that it is intended to seal, such items shall be repaired before filling or refilling the storage vessel with regulated material.



EU ID Point ID

Physical

Capacity

(gallons)

Roof

Type

Construct ion/Mod

Date

Vapor

Pressure

Limit

(psia)

Throughput

Limit

(gal/yr) (1)

VOC

Limit

(TPY)

(2)

D-0924

T-0002

T-0003

T-0038

T-0041E

T-0051

T-0059

T-0063

T-0064

T-0070

T-0077

27,900

22,428

HFR 2004

HFR 1974

48,661 VFR Post-1984

424,453 EFR 1950

1,650,789 Sphere 1957

1,063,329

495,122

431,772

369,089

425,921

215,898

VFR 1921

EFR 1926

VFR

VFR

VFR

VFR

1926

1926

1921

1921

(3)

(3)

<0.5 (4) and (3)

(3)

(3)

(3)

(3)

(3)

(3)

(3)

(3)

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-


EU ID Point ID

T-0102

T-0103

T-0105

T-0106

T-0106E

T-0107E

T-0116

T-0120

T-0122

T-0123

T-0124

T-0125

T-0126

T-0127

T-0128

T-0129

T-0130

T-0131

T-0133

T-0135

T-0136

T-0138

T-0142

T-0143

T-0144

T-0102

T-0103

T-0105

T-0106

T-0106E

T-0107E

T-0116

T-0120

T-0122

T-0123

T-0124

T-0125

T-0126

T-0127

T-0128

T-0129

T-0130

T-0131

T-0133

T-0135

T-0136

T-0138

T-0142

T-0143

T-0144

Physical

Capacity

(gallons)

435,762

436,937

2,814,694

2,278,246

1,143,749

1,143,749

2,695,693

11,088,636

2,814,694

3,684,661

3,684,661

3,684,661

3,684,661

2,772,713

3,619,157

3,619,157

6,831,266

6,831,266

2,788,156

4,586,000

4,586,000

2,278,246

3,398,254

6,644,304

6,644,304

DRAFT

6

Roof

Type


Date

VFR 1919

VFR 1919

VFR 1922

VFR 1918

VFR 1991

VFR 1990

VFR 1919

VFR 1990

VFR 1922

VFR 1992

VFR 1992

VFR 1992

VFR 1992

VFR 1921

VFR 1992

VFR 1992

VFR 1992

VFR 1992

VFR 1921

VFR 1992

VFR 1992

VFR 1920

VFR 1989

VFR 1990

VFR 1991

Vapor

Pressure

Limit

(psia)

(3)

(3)

(3)

(3)

<0.5 (4) and (3)

0.16

(6) ,

0.5 (4)

(3)

and

(3)

0.10

(6) and (3)

(3)

0.039 (6) and (3)

0.039 (6) and (3)

0.039 (6) and (3)

0.039 (6) and (3)

(3)

0.039 (6) and (3)

0.039 (6) and (3)

0.039 (6) and (3)

0.039 (6) and (3)

(3)

0.039 (6) and (3)

0.039 (6) and (3)

(3)

<0.5 and

(4)

(3)

0.10 and

(6)

(3)

<0.5 and

(4)

(3)

Throughput

Limit

(gal/yr) (1)

VOC

Limit

(TPY)

(2)

-

-

-

-

-

-

-

-

-

39.2

(1)

291,270,000 20.6

- -

919,800,000 23.7

(5)

- -

(5)

(5)

(5)

(5)

(5)

(5)

(5)

(5)

(5)

(5)

-

-

-

-

(5)

(5)

(5)

(5)

(5)

-

(5)

(5)

-

-

(5)

-

(5)

306,600,000 13.1

-

37.1

(1)


EU ID Point ID

T-0152

T-0161

T-0168

T-0169

T-0171

T-0179

T-0253

T-0254

T-0260

T-0500

T-0501

T-0536

T-0561

T-0633

T-0636

T-0639

T-0640

T-0641

T-0904

T-0905

T-0906

T-0913

T-0914

T-0916

T-0946

T-0947

T-0948

T-0970

T-0971

T-0972

T-0152

T-0161

T-0168

T-0169

T-0171

T-0179

T-0253

T-0254

T-0260

T-0500

T-0501

T-0536

T-0561

T-0633

T-0636

T-0639

T-0640

T-0641

T-0904

T-0905

T-0906

T-0913

T-0914

T-0916

T-0946

T-0947

T-0948

T-0970

T-0971

T-0972

Physical

Capacity

(gallons)

3,377,633

3,363,962

424,453

424,453

20,000

46,998

31,724

13,535

26,437

2,819,894

229,213

16,919

24,418

3,383,872

3,349,806

2,298,399

2,298,399

2,298,399

3,317,318

3,317,318

1,047,993

1,050,262

1,054,295

66,091

3,323,752

3,307,668

1,050,000

1,903.428

1,903.428

1,903.428

DRAFT

7

VFR 1990

VFR 1983

VFR 1971

VFR 1985

VFR 1929

VFR 1926

VFR 1926

VFR 1926

VFR 1924

VFR 1924

VFR 1944

VFR 1943

VFR 1943

VFR 1944

VFR 1924

VFR 1924

VFR 1944

VFR 2000

Roof

Type


Date

VFR 1974

VFR 1974

VFR 1950

VFR 1950

VFR 1943

VFR 1988

VFR 1994

VFR 1994

VFR 1987

VFR 1983

VFR 2000

VFR 2000

Vapor

Pressure

Limit

(psia)

< 1.5 (4) and (3)

<1.5

(4) and (3)

(3)

(3)

(3)

<0.5 and

(4)

(3)

2.2 (6), (4) and (3)

2.2 (6)

(3)

and

<0.5 and

(4)

(3)

<1.5

(4) and (3)

<0.5 (4) and (3)

(3)

(3)

<0.5 (4) and (3)

(3)

(3)

(3)

(3)

(3)

(3)

(3)

(3)

(3)

(3)

(3)

(3)

(3)

<0.5 (4) and (3)

<0.5 (4) and (3)

<0.5 (4)

Throughput

Limit

(gal/yr) (1)

VOC

Limit

(TPY)

(2)

-

-

-

-

-

40,000,000

26,280,000

26,280,000

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-


DRAFT

8

EU ID Point ID

Physical

Capacity

(gallons)

Roof

Type


Date

Vapor

Pressure

Limit

(psia)

Throughput

Limit

(gal/yr) (1)

VOC

Limit

(TPY)

(2) and (3)



3. Vapor pressure is limited to <1.5 psia (maximum) and <1.2 psia (annual average) only if the annual average

HAP content is >4 wt% under 40 CFR Part 63 Subpart CC. If annual average HAP content is <4wt%, vapor pressure is not limited under Subpart CC.

4. Maximum calendar month average above which 40 CFR Part 60 Subparts K, Ka, or Kb applies.

5. Combined throughput limit for T-0123, T-0124, T-0125, T-0126, T-0128, T-0129, T-0130, T-0131, T-

0135, T-0136, T-0173 and T-0186 is 5,631,000,000 gallons per year (12-month rolling total) and the combined VOC limit is 155 TPY (calendar year total).

6. Annual average. a.

The listed tanks are Group 2 storage vessels subject to 40 CFR Part 63 Subpart CC, but must only comply with recordkeeping requirements. The permittee shall maintain records of dimension, analysis showing capacity, and group determination for the life of the storage tanks.

[40 CFR 63.654(i)] b. For the listed tanks with throughput limits, the permittee shall keep monthly records of the


[OAC 252:100-43] c. For the listed tanks with calendar year total VOC emission limits, the permittee shall keep records of annual total VOC emissions when the tanks are in VOL service. Annual VOC emissions shall be determined from VOC emissions correlations based on emission equations used in the latest version of EPA TANKS program or the permittee may use the latest version of the EPA TANKS program. [OAC 252:100-43] d. The permittee shall maintain records of annual average vapor pressure for materials stored in

T-0107E, T-0120, T-0123, T-0124, T-0125, T-0126, T-0128, T-0129, T-0130, T-0131, T-

0135, T-0136, T-0143, T-0253, and T-0254. [OAC 252:100-43]



EU ID (3) Point ID

Physical

Capacity

(gallons)

Roof

Type

Construction/

Modification

Date

Vapor

Pressure

Limit

(psia) (4)

Throughput

Limit (gal/yr)

(1)

VOC

Limit

(TPY)

(2)

D-0777

D-0779

D-5292

D-0777

D-0779

D-5292

564 HFR

10,403 HFR

1,900 HFR

Pre-1991

Pre-1991

1943

-

-

-

-

-

-

-

-

-


DRAFT

9

EU ID (3) Point ID

Physical

Capacity

(gallons)

Roof

Type

Construction/

Modification

Date

Vapor

Pressure

Limit

(psia) (4)

Throughput

Limit (gal/yr)

(1)

VOC

Limit

(TPY)

(2)

T-0037

T-0201

T-0202

T-0203

T-0204

T-0205

T-0551

T-0552

T-0553

T-0554

T-0555

T-0651

T-0652

T-0654

T-0665

T-0667

T-0669

T-0701

T-0702

T-0703

T-0704

T-0705

T-0706

T-0909

T-0910

T-0037

T-0201

T-0202

T-0203

T-0204

T-0205

T-0551

T-0552

T-0553

T-0554

T-0555 21,995 IFR

T-0651 3,363,962 VFR

T-0652 3,377,423 VFR

T-0654 3,077,933 EFR

T-0665 3,752,617 EFR

T-0667 21,995 IFR

T-0669

T-0701

T-0702

T-0703

T-0704

T-0705

T-0706

T-0909

T-0910

586,200 EFR

490,573 EFR

490,573 EFR

21,995 IFR

490,573 EFR

490,573 EFR

490,573 EFR

490,573 EFR

256,651 EFR

256,651 EFR

270,401 EFR

256,651 EFR

256,651

22,068 IFR

270,401 EFR

270,401 EFR

270,401 EFR

661,945

663,215

EFR

IFR

IFR

1993

1991

1991

1991

1991

1991

1991

1992

1991

1992

1993

1923

1923

1923

1991

1991

1991

1991

1991

1991

1991

1991

1991

1943

1943

<11.1

-

-

-

<11.1

-

<11.1

<11.1

<11.1

<11.1 1,522,500,000 17.8

<11.1 - 21.6 (1)

<11.1

<11.1

- 22.2 (1)

- 2.0 (1)

<11.1

<11.1

- 21.5 (1)

- 21.5 (1)

<11.1

<11.1

<11.1

<11.1

4,734,000

4,986,000

744,000

1,798,000

-

-

-

-

<11.1

<11.1

<11.1

<11.1

-

-

691,000

-

-

-

- -

- 27.4 (1)

- 26.6 (1)

3,600,000

-

2,129,000 -

-

20.8 (1)

- 20.8 (1)

- 3.8 (1)

-

20.8 (1)

- 20.8 (1)

26,280,000

-

2,520,000 0.9

6,300,000

4.0



3. T-0037, T-0201, T-0202, T-0203, T-0204, T-0205, T-0551, T-0552, T-0553, T-0554, T-0555, T-0665, T-

0669, T-0701, T-0702, T-0703, T-0704, T-0705, and T-0706 are considered oil-water separators for the purposes of 40 CFR Part 61 Subpart FF and 40 CFR Part 60 Subpart QQQ compliance. T-0654, T-0667, and T-0910 are considered oil-water separators for the purposes of compliance with Subpart FF, but not for

Subpart QQQ. T-0909 is not an oil-water separator but handles a wastewater stream and is subject to

Subpart FF. D-0777, D0779, D-5292, T-0651, and T-0652 handle wastewater streams and are subject to

Subpart FF.

4. Maximum calendar month average above which 40 CFR Part 60 Subpart Kb requires a closed vent system with control device or equivalent control device.

a. All the listed IFR and EFR tanks, except T-0909, T-0910, T0654, and T-0667 are oil-water separators and subject to 40 CFR Part 60 Subpart Kb and Subpart QQQ, 40 CFR Part 61

Subpart FF, and 40 CFR Part 63 Subpart CC. The “overlap” provisions of Subpart CC

§63.640(o)(1) state that a Group 1 wastewater stream managed in a piece of equipment that is also subject to the provisions of

Subpart QQQ is required to comply only with Subpart CC.

Subpart CC §63.647(a) states that equipment handling a Group 1 wastewater stream shall


DRAFT

10 comply with the requirements of §§61.340 through 61.355 of Subpart FF.

The facility is complying with the alternative oil-water separator standards of Subpart FF by complying with

Subpart Kb and the additional alternative standards for oil-water separators in Subpart QQQ.

For these tanks, the permittee shall comply with all applicable requirements of Subpart Kb,

Subpart QQQ, Subpart FF, and Subpart CC including, but not limited to, the following:

[40 CFR Part 60 Subpart QQQ, Part 61 Subpart FF, and Part 63 Subpart CC] i. The mechanical design and operating specifications for internal floating roof tanks of 40

CFR 112b(a)(1). ii. The mechanical design and operating specifications for external floating roof tanks of 40

CFR 112b(a)(2). iii. The testing and procedures for internal floating roof tanks of 40 CFR 60.113b(a) and 40

CFR 60.692-6 and 693-2. iv. The testing and procedures for external floating roof tanks of 40 CFR 60.113b(b) and 40

CFR 60.692-6 and 693-2. v. The reporting and recordkeeping requirements of 40 CFR 60.115b, 40 CFR 61.356 and

357, 40 CFR 60.693-2, 697, and 698(b) and (c), and 40 CFR 63.654(e) and (i). b. Tanks T-0654, T-0667, and T-0910 are oil-water separators subject to 40 CFR Part 61

Subpart FF and 40 CFR Part 63 Subpart CC. Subpart CC

§63.647(a) states that equipment handling a Group 1 wastewater stream shall comply with the requirements of §§61.340 through 61.355 of Subpart FF.

The facility is complying with the alternative oil-water separator standards of Subpart FF by complying with Subpart Kb. For these tanks, the permittee shall comply with all applicable requirements of Subpart FF and Subpart CC including, but not limited to, the following:

[40 CFR Part 61 Subpart FF, and Part 63 Subpart CC] i. The mechanical design and operating specifications for internal floating roof tanks of 40

CFR 112b(a)(1). ii. The mechanical design and operating specifications for external floating roof tanks of 40

CFR 112b(a)(2). iii. The testing and procedures for internal floating roof tanks of 40 CFR 60.113b(a). iv. The testing and procedures for external floating roof tanks of 40 CFR 60.113b(b). v. The reporting and recordkeeping requirements of 40 CFR 60.115b, 40 CFR 61.356 and

357, and 40 CFR 63.654(e) and (i).


DRAFT

11 c. T-0909 is subject to 40 CFR 61 Subpart FF and 40 CFR 63 Subpart CC for wastewater streams.

Subpart CC

§63.647(a) states that equipment handling a Group 1 wastewater stream shall comply with the requirements of §§61.340 through 61.355 of Subpart FF.

The facility is complying with the alternative standards for tanks of Subpart FF by complying with Subpart

Kb. For this tank, the permittee shall comply with all applicable requirements of Subpart FF and Subpart CC including, but not limited to, the following:

[40 CFR Part 61 Subpart FF and Part 61 Subpart CC] i. The mechanical design and operating specifications for internal floating roof tanks in accordance with 40 CFR 60.112b(a)(1). ii. The testing and procedures for internal floating roofs of 40 CFR 60.113b(a) and 40 CFR

63.640(n)(8). iii. The reporting and recordkeeping requirements of 40 CFR 60.115b, 40 CFR 61.356 and

357, and 40 CFR 63.654(e) and (i). d. The listed HFR and VFR tanks are subject to 40 CFR Part 61 Subpart FF and 40 CFR Part 63

Subpart CC for wastewater streams. Subpart CC

§63.647(a) states that equipment handling a

Group 1 wastewater stream shall comply with the requirements of §§61.340 through 61.355 of Subpart FF. When storing a Group 1 wastewater stream, these tanks shall be operated as a closed-vent system with carbon adsorption system and the permittee shall comply with all applicable requirements of Subpart FF and Subpart CC including, but not limited to, the following:

[40 CFR Part 61 Subpart FF and 40 CFR Part 63 Subpart CC] i. The mechanical design and operating specifications of 40 CFR 61.343(a)(1). ii. The standards for closed-vent systems and control devices of 40 CFR 61.349. iii. The standards for delay of repair of 40 CFR 61.351. iv. The requirements for monitoring of operations of 40 CFR 61.354. v. The reporting and recordkeeping requirements of 40 CFR 61.356 and 357 and 40 CFR

63.654(e). e.

For the listed tanks with throughput limits, the permittee shall keep monthly records of the 12month rolling total throughput for months when the tanks are in VOL service.

[OAC 252:100-43] f. For the listed tanks with 12-month rolling total VOC emission limits, monthly records of 12month rolling total VOC emissions and the information used to calculate those emissions shall be maintained when the tanks are in VOL service. The following information and methods shall be used to determine monthly emissions:

SPECIFIC CONDITIONS PERMIT NO. 98-104-TV i. Monthly total throughput records.

DRAFT

12 ii. Monthly average true vapor pressure records. iii. VOC emissions correlations based on emission equations used in the latest version of the

EPA TANKS program or the permittee may use the latest version of the EPA TANKS program. [OAC 252:100-43] g. For listed tanks with calendar year total VOC emission limits, the permittee shall keep records of annual total VOC emissions when the tanks are in VOL service. Annual VOC emissions shall be determined from VOC emissions correlations based on emission equations used in the latest version of EPA TANKS program or the permittee may use the latest version of the EPA TANKS program. [OAC 252:100-43]



EU ID

T-0140

T-0173

T-0648

T-0680

T-0907

T-0908

T-0944

T-0966

T-0973

T-0974

D-0232

D-0774

D-0775

D-0776

D-0780

D-0783

D-0786-1

D-0787

D-6801

D-6812

T-0016E

T-0055

T-0069

T-0071

T-0080

Point ID

T-0140

T-0173

T-0648

T-0680

T-0907

T-0908

T-0944

T-0966

T-0973

T-0974

D-0232

D-0774

D-0775

D-0776

D-0780

D-0783

D-0786-1

D-0787

D-6801

D-6812

T-0016E

T-0055

T-0069

T-0071

T-0080

Physical

Capacity

(gallons)

Roof

Type

924 HFR

10,300 VFR

10,300 HFR

10,300 HFR

10,403 HFR

3,475 HFR

564 HFR

564 HFR

5,000 VFR

16,044 HFR

104,351 VFR

433,871 VFR

443,105 VFR

428,494 VFR

105,000 VFR

4,053 VFR

5,558 VFR

4,576 VFR

250,000 OT

1,056,563 IFR

1,052,278 IFR

1,043,961 IFR

14,161 VFR

213,523 VFR

110,446 VFR

Construction/

Modification

Date

1989

1990

1990

1990

1990

1990

Est. 1990

1990

1964

1991

1939

1926

1921

1926

1941

1990

1992

1992

1993

1943

1943

1944

1945

1960

1960

Vapor

Pressure

Limit

(psia)

-

Throughput

Limit

(gal/yr) (1)

-

-

-

-

-

-

-

-

-

-

-

-

0.039

(4)

-

-

-

(3)

- -

-

-

-

- -

- 12,600,000

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

VOC

Limit

(TPY)

(2)

-

-

-

-

-

-

-

-

-

-

-

-

-

(3)

-

-

-

3.3

-

-

-

-

-

-

-


DRAFT

13

EU ID Point ID

Physical

Capacity

(gallons)

Roof

Type

Construction/

Modification

Date

Vapor

Pressure

Limit

(psia)

Throughput

Limit

(gal/yr) (1)

VOC

Limit

(TPY)

(2)

T-6601 T-6601 14,687 VFR 1951 - - -




0131, T-0135, T-0136, T-0173 and T-0186 is 5,631,000,000 gallons per year (12-month rolling total) and the combined VOC limit is 155 TPY (calendar year total).

4. Annual average. a. These tanks are not subject to any NSPS or NESHAP standards. b. For the listed tanks with throughput limits, the permittee shall keep monthly records of the

12-month rolling average throughput for months when the tanks are in VOL service.

[OAC 252:100-43] c. For listed tanks with calendar year total VOC emission limits, the permittee shall keep records of annual total VOC emissions when the tanks are in VOL service. Annual VOC emissions shall be determined from VOC emissions correlations based on emission equations used in the latest version of EPA TANKS program or the permittee may use the latest version of the EPA TANKS program. [OAC 252:100-43] d. The permittee shall maintain records of annual average vapor pressure for materials stored in

T-0173. [OAC 252:100-43]


EU ID Point ID

Physical

Capacity

(gallons)

Roof

Type

2,100 VFR

Construction/

Modification

Date

Pre 2004

Vapor

Pressure

Limit

(psia)

-

Throughput

Limit

(gal/yr)

-

VOC

Limit

(TPY)

- D-5250

EP

Methanol

Tote

T-0017

T-0018

T-0018E

T-0027

T-0057

T-0058

T-0104

T-0212E

T-0230

T-0542

D-5250

EP

Methanol

Tote

T-0017

T-0018

T-0018E

T-0027

T-0057

T-0058

T-0104

T-0212E

T-0230

T-0542

400 VFR

350 VFR

350 Sphere

2,154 VFR

550 VFR

550 VFR

550 VFR

1,680 VFR

564 VFR

4,230 VFR

550 VFR

2006

1994

1994

1990

2006

2005

2005

1922

1971

Pre 2004

Pre 2000

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-


DRAFT

14

EU ID Point ID

Physical

Capacity

(gallons)

Roof

Type

Construction/

Modification

Date

Vapor

Pressure

Limit

(psia)

Throughput

Limit

(gal/yr)

VOC

Limit

(TPY)

Misc.

Vendor

Totes

Misc.

Vendor

Totes

< 5,000 VFR Any - - - a. The listed tanks are subject to 40 CFR Part 63 Subpart EEEE. For these tanks, the permittee shall comply with all applicable requirements of Subpart EEEE for existing storage tanks including, but not limited to, the following: [40 CFR Part 63 Subpart EEEE] i. §63.2382 What notifications must I submit and when and what information should be submitted? ii. §63.2386 What reports must I submit and when and what information is to be submitted in each? iii. §63.2390 What records must I keep? iv. §63.2394 In what form and how long must I keep my records? b. The permittee shall maintain records to demonstrate that the listed storage tanks with a capacity of 5,000 gallons or more have a true vapor pressure of less than 4.0 psia, annual average. [40 CFR 63.2346]


EU ID Point ID

Physical

Capacity

(gallons)

Roof

Type

Construction/

Modification

Date

Vapor

Pressure

Limit

Throughput

Limit

(bbl/yr) (1)

VOC

Limit

TPY (2)

T-0024 T-0024

T-0186 T-0186

2,016 VFR

2,016 VFR

1986

2005

-

0.039 (4)

-

(3)

-

(3)

TNK-

MP

Gasoline

TNK-

MP

Gasoline

1,000 VFR 2002 -




0131, T-0135, T-0136, T-0173 and T-0186 is 5,631,000,000 gallons per year (12-month rolling total) and the combined VOC limit is 155 TPY (calendar year total).

4. Annual average. a. The permittee shall maintain records of the annual average vapor pressure for materials stored in T-0186. [OAC 252:100-43]


DRAFT

15 b. For the listed tanks with calendar year total VOC emission limits, the permittee shall keep records of annual total VOC emissions when the tanks are in VOL service. Annual VOC emissions shall be determined from VOC emissions correlations based on emission equations used in the latest version of EPA TANKS program or the permittee may use the latest version

[OAC 252:100-43] of the EPA TANKS program.


There are no emissions limitations for these tanks.

EU ID Point ID Insignificant Activity Reason

D-0060

D-0062

D-0066

D-0067

D-0077

D-0078

D-0079

D-0234

D-0060

D-0062

D-0066

D-0067

D-0077

D-0078

D-0079

D-0234

Normal Contents

Liquids Recovery

(gasoline)

Proto Tank 3B –

Gasoline

Proto Tank 2B –

Gasoline

Proto Tank 3A –

Gasoline

Proto Tank 2A –

Gasoline

Proto Tank 1B –

Gasoline

Proto Tank 1A –

Gasoline

Dye

App. I: Miscellaneous - < 5 TPY






D-0409

D-0669

D-0700

D-5130

T-0005

T-0006

T-0006 E

D-0409

D-0669

D-0700

D-5130

T-0005

T-0006

T-0006 E

Corrosion Inhibitor

Spent Caustic

Spent Caustic

Caustic Mix Tank

Fuel Stabilizer (Day

Pot, T-973267)

Antioxidant

Diesel fuel



- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


EU ID Point ID

T-0007

T-0008

T-0011

T-0012

T-0014

T-0015 E

T-0023

T-0028

T-0031

T-0084

T-0085

T-0086

T-0087

T-0221

T-0224

T-0247

T-0265

T-0266

T-0267

T-0513

T-0007

T-0008

T-0011

T-0012

T-0014

T-0015 E

T-0023

T-0028

T-0031

T-0084

T-0085

T-0086

T-0087

T-0221

T-0224

T-0247

T-0265

T-0266

T-0267

T-0513

DRAFT

16

Normal Contents Insignificant Activity Reason

Manganese Additive

Kerosene wash tank

Pressed Alky Sludge

Mix Tank

Jet Water Pump

Surge, Fines

Filtering


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia

Diesel fuel

Fuel oil additive

Diesel Storage at

Fuel Pump

Reclaimed Oil

Spent Naphthenic

Caustic

Emulsion Breaker

(T-980190)

Emulsion Breaker

(T-930269)

Filmer (T-930272)

Corrosion Inhibitor

(T-930270)

Diesel fuel

Diesel fuel

Training Tank

(Salvage yard)

Antifoam tote

Antifoam tote

Antifoam tote

Pour Point

Depressant (T-


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal/ < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


EU ID Point ID

T-0530

T-0534

T-0535

T-0603

T-0604

T-0649

T-0922

T-0923

T-890848

T-900670

T-900671

T-942232

T-951509

T-960590

T-970228

T-970244

T-970245

T-970246

T-971286

T-972868

T-982607

T-0530

T-0534

T-0535

T-0603

T-0604

T-0649

T-0922

T-0923

T-890848

T-900670

T-900671

T-942232

T-951509

T-960590

T-970228

T-970244

T-970245

T-970246

T-971286

T-972868

T-982607

DRAFT

17

Normal Contents

960590)

Antifreeze (ethylene glycol)

Diesel fuel

Diesel fuel

Diesel fuel

Diesel fuel

Polymer Additive for Lagoon

Diesel fuel

Diesel fuel

Neutralizer

Corrosion Inhibitor

Emulsion Breaker

Antioxidant

Metal Passivator

Pour Point

Depressant

Antioxidant

Biocide

Corrosion Inhibitor

Deposit Control

Agent

Metal Passivator

Fuel Stabilizer

Red dye

Insignificant Activity Reason


- < 40,000 gal / < 1.5 psia




- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


DRAFT

18

EU ID Point ID Normal Contents Insignificant Activity Reason

T-BETZ SBC

8Q506

TNK-Fire

Training #1

TNK-Fire

Training #2

T-BETZ SBC

8Q506

TNK-Fire

Training #1

TNK-Fire

Training #2

Pour Point

Depressant

Kerosene storage at

Fire Training

Grounds

Kerosene Storage at

Fire Training

Grounds


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia

TNK-GFMHL

#1

TNK-GFMHL

#2

TNK-GFMST

TNK-GFMHL

#1

TNK-GFMHL

#2

TNK-GFMST

Gasoline fuel

Diesel fuel

Diesel fuel



- < 40,000 gal / < 1.5 psia


- < 40,000 gal / < 1.5 psia

TNK-Misc.

Vendor Totes /

Tanks

TNK-Misc.

Vendor Totes /

Tanks

Vendor chemicals with TVP < 1.0 psia and containing < 4%

RM1 HAPs, < 5%

OLD MACT HAPs, or inorganic


- < 40,000 gal / < 1.5 psia

TNK-

Diesel

MP

TNK-MP

Diesel

HEATERS AND BOILERS

Diesel fuel


- < 40,000 gal / < 1.5 psia


Boilers

EU ID

B-0008

B-0009/0010

Point ID

B-0008

B-0009/0010

Const/

Mod

Date

2003

2005

Fired Duty

Limit

(1)

(MMBtu/hr)

483

734 (2)

Pollutant

NO

CO

SO

PM

NO

SO

2

CO

2

X

VOC

10

X

VOC

PM

10

Emission

Rate Limit

(1)

Emission Limit

(1)

(lb/MMBtu)

0.035

--

--

--

--

0.050

--

--

--

-- lb/hr TPY

16.9 74.0

39.8 174.0

15.0 65.6

2.6 11.4

3.6 15.9

36.6 161.0

29.4 129.0

22.8 99.7

4.0 17.4

5.5 24.2

1. 365-day rolling average unless specified otherwise. Time period basis is midnight to midnight.

2. Fired duty is shown for the purposes of regulatory applicability only and is not a permit limit.


DRAFT

19 a. The boilers are subject to 40 CFR Part 60 Subpart Db. The permittee shall comply with all applicable requirements including, but not limited to, the following:

[40 CFR Part 60 Subpart Db] i. §60.44b Standards for nitrogen oxides. The boilers are limited to NO

X

emissions of 0.20 lb/MMBtu, 30-day rolling average. ii. §60.46b Performance test and compliance provisions. An annual performance evaluation of the NO

X

CEMS must be conducted in accordance with the Methods specified in 40

CFR Part 60 Appendix B. iii. §60.48b Monitoring of emissions. A continuous monitoring system shall be operated and maintained to record NO

X

emissions. iv. §60.49b Reporting and recordkeeping requirements. b. The boilers are subject to 40 CFR Part 60 Subpart J. The permittee shall comply with all applicable requirements including, but not limited to, the following:

[40 CFR Part 60 Subpart J] i. §60.104 Standards for sulfur oxides. The boilers shall combust only pipeline grade natural gas, PSA off-gas, or refinery fuel gas with a 3-hour rolling average maximum H

2

S concentration of 0.1 gr/dscf (160 ppmv @ 60 o

F). ii. §60.105 Monitoring of emissions and operations. A continuous monitoring system shall be operated and maintained to record either the H

2

S content of the fuel gas or the SO

2 concentration in the flue gas. If an SO

2

monitor is used, the SO

2

concentration standard is

20 ppmvd @ 0% O

2

, 3-hr rolling average and an oxygen monitor shall also be included for correcting the data for excess air. iii. §60.106 Test methods and procedures. iv. §60.107 Reporting and recordkeeping requirements. v. §60.108 Performance test and compliance provisions. c. Compliance with the firing rate limit for boiler B-0008 shall be based on 365-day rolling average fuel gas usage and heating value and shall be demonstrated monthly using on-line instrumentation and calculations, when available, or the following formula:

[OAC 253: 100-43]

MMBtu/hr = MMSCFD * Btu/Scf (HHV) * (1 day/24 hr) * (MMBtu/10

6

Btu) d. Compliance with the emissions limits for PM and VOC is demonstrated by the use of good combustion practices. [OAC 253: 100-43]


DRAFT

20 e. Compliance with the SO

2

emission limits shall be based on 365-day rolling average fuel gas usage and H

2

S content and shall be demonstrated monthly using on-line instrumentation and calculations, when available, or the following formulas: [OAC 253: 100-43] lb/hr = MMSCFD * ppmvd H

2

S * 64 lb SO

2

/lb-mole

24 hr/day * 379.4 Scf/lb-mole

TPY = MMSCFD * ppmvd H

2

S * 64 lb SO

2

/lb-mole * 365 days/year

2000 lb/ton * 379.4 Scf/lb-mole f. Compliance with the NO

X

and CO emission limits shall be based on 365-day rolling average fuel gas usage and heating value and CEMS data or heater specific (stack test) emission factors, when available, or the most current version emission factors from AP-42 Table 1.4-1.

Compliance shall be demonstrated monthly using on-line instrumentation and calculations, when available, or the following formula: [OAC 253: 100-43] lb/hr = MMSCFD * Btu/Scf (HHV) * EF

24 hr/day

TPY = MMSCFD * Btu/Scf (HHV) * EF * 365 days/year

2000 lb/ton where EF = Emission Factor, lb/MMBtu g. Compliance with the NO

X

lb/MMBtu emission limit shall be based on 365-day rolling average

CEMS data for NO

X

concentration in the flue gas. Compliance shall be demonstrated monthly using on-line instrumentation and calculations, when available, or the following formula:

[OAC 253: 100-43] lb/MMBtu = 8,710 scf/MMBtu * (1/385.3 scf/lb-mole) * ppmvd * (1/10 6 ) *

(20.9/20.9-O

2

%) * 44 lb/lb-mole

EUG HTR-2: 40 CFR Part 60 Subpart J and 40 CFR Part 63 Subpart DDDDD Heaters &

Boilers

Emission Limit

(1)

EU ID Point ID

B-0006 B-0006

B-0007 B-0007

Const/

Mod Date

1953

Pre-

8/17/71

Fired Duty

Limit (1)

(MMBtu/hr)

26.1

31.5

Pollutant

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

Emission

Rate Limit (1)

(lb/MMBtu)

-

-

-

-

-

-

- lb/hr

7.3

3.1

0.8

0.0

0.7

8.8

3.8

TPY

32.0

13.7

3.5

0.2

3.1

38.6

16.6


EU ID Point ID

B-5004

No. 5

FCCU/B-

5004

H-0001 H-0001

H-0003 H-0003

H-0004 H-0004

H-0005 H-0005

H-0010 H-0010

H-0011 H-0011

H-0016 H-0016

Const/

Mod Date

1977 /

2002 (SC

31 & 33 mod)

1977 /

1987 (SC

31, 33 &

NSPS mod)

1929 /

2002 (SC

31, 33 &

NSPS

Mod)

1945 /

2002 (SC

31, 33 &

NSPS mod)

1940

1972

1988

2004

Fired Duty

Limit (1)

(MMBtu/hr)

>250 (3)

175

28

106

85 (3)

55 (3)

15

107 (3)

DRAFT

Pollutant

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

Emission

Rate Limit (1)

-

-

-

-

-

0.035

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

(lb/MMBtu)

-

-

-

-

-

-

-

-

-

-

-

-

-

-

0.060

0.040 (1) /

0.060 (2) /

0.080 (4)

-

-

-

-

-

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC lb/hr

1.0

0.0

0.6

-

-

-

-

-

10.6

7.0

TPY

21

Emission Limit

(1)

4.3

0.2

(6)

2.5

(6)

(6)

(6)

(6)

46.0

30.7

-

5.4

4.5

1.7

0.3

0.4

2.6

-

-

-

-

-

0.9

-

-

16.4

4.4

3.3

5.4

1.0

1.3

2.8

1.1

1.8

1.2

0.5

0.1

0.1

3.7

4.3

3.3

0.6

3.0

23.6

19.9

7.5

1.3

1.8

37.0

31.0

-

-

11.5

-

23.8

4.1

5.8

12.1

4.8

3.8

-

-

69.6

18.1

14.4

7.9

5.4

2.0

0.4

0.5

16.4

18.7

14.5

2.5


EU ID Point ID

H-0023 H-0023

H-0028

H-0029

H-0046 H-0046

H-0048 H-0048

H-0057

H-0058

H-0059

H-0028/

0029

H-0028/

0029

H-

0057/58/

59

H-

0057/58/

59

H-

0057/58/

59

Const/

Mod Date

1984

1954

1983

1964

1957

1974

1974

1974

Fired Duty

Limit (1)

(MMBtu/hr)

52.4

129 (3)

75

48 (3)

241.4

68.5 (3)

48.6 (3)

70 (3)

DRAFT

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

PM

10

NO

X

Pollutant

CO

Emission

Rate Limit (1)

(lb/MMBtu)

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

0.07

0.040 (1) /

0.060 (2) /

0.080 (4) /

400 (5)

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

- lb/hr

Emission Limit

(1)

9.7

TPY

22

42.3

0.4

0.6

-

-

1.5

-

4.0

-

-

7.4

6.2

2.3

-

16.9

0.8

7.2

4.3

1.6

0.3

0.4

-

-

1.8

2.4

21.0

18.0

6.5

-

17.5

-

5.0

32.2

27.1

10.2

2.0

74.0

3.5

31.4

18.9

7.1

1.2

1.7

78.0

47.0

1.5

-

-

-

-

-

-

-

-

-

7.5

1.3

1.8

-

-

2.2

-

-

21.0

18.0

6.7

-

2.0

-

-

-

-

-

32.7

5.7

7.9

30.0

25.0

9.5

-

3.0


EU ID Point ID

H-1001 H-1001

H-5001 H-5001

H-5002 H-5002

H-6005 H-6005

H-6007 H-6007

H-6008 H-6008

H-6012 H-6012

H-6013 H-6013

H-6014 H-6014

Const/

Mod Date

2005

1944

Const.

Planned for 2007

1997

1956 /

1990 (SC

31 & 33 mod)

1955

1971

2002

1978

Fired Duty

Limit (1)

(MMBtu/hr)

30 (3)

104 (3)

120 (3)

157 (3)

150

2.0

25 (3)

75.8 (3)

80

DRAFT

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

Pollutant

CO

Emission

Rate Limit (1)

(lb/MMBtu)

0.050

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

0.044

-

-

-

0.070

0.040 (1) /

0.060 (2) /

0.080 (4) /

400 (5)

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

-

0.050 lb/hr

Emission Limit

(1)

6.0

TPY

23

26.3

0.9

11.8

12.9

4.9

0.8

1.1

5.3

4.8

-

-

3.7

0.7

10.5

1.5

1.2

0.9

0.2

0.2

-

-

3.2

3.9

51.6

56.4

21.3

3.5

4.8

-

4.0

23.1

21.0

16.3

2.9

46.0

6.6

5.3

4.1

0.7

1.0

145.0

44.0

14.1

-

0.8

-

-

4.6

-

2.3

-

-

4.0

4.7

0.8

1.1

-

-

0.1

-

-

-

9.0

3.4

-

1.0

19.9

-

10.3

-

-

17.5

20.4

3.5

4.9

1.0

1.0

0.3

-

1.0

11.0


EU ID Point ID

H-6015 H-6015

H-6151 H-6151

H-7501 H-7501

H-8601 H-8601

H-8602 H-8602

H-8801/

8802

H-8801/

8802

H-9851 H-9851

H-9901 H-9901

Const/

Mod Date

1980

1958

1991

2003

(Pre

12/13/03)

2003

(Pre

12/13/03)

2003

(Pre

12/13/03)

2005

2005

Fired Duty

Limit (1)

(MMBtu/hr)

79

80 (3)

41 (3)

120

36

123

282 (3)

40 (3)

DRAFT

Pollutant

CO

SO

2

CO

VOC

PM

10

NO

X

Emission

Rate Limit (1)

-

-

0.035

-

-

-

-

0.035

-

-

-

-

0.075

-

-

-

-

0.050

-

-

-

0.035

-

-

-

-

-

-

-

-

-

(lb/MMBtu)

0.040 (1) /

0.060 (2) /

0.080 (4)

-

-

-

0.060

0.040 (1) /

0.060 (2) /

0.080 (4)

-

-

-

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

Emission Limit

(1) lb/hr

3.2

2.5

0.4

0.6

4.8

3.2

TPY

24

14.0

10.9

1.9

2.6

20.8

13.8

0.7

0.9

1.3

3.0

1.1

0.2

1.1

0.2

0.3

4.2

9.9

3.7

2.4

0.4

0.6

2.5

-

-

-

-

4.1

1.2

21.2

11.3

8.7

1.5

2.1

2.0

0.3

4.3

10.1

0.1

0.7

0.9

2.9

3.9

5.5

13.0

4.9

0.8

5.0

1.0

1.3

18.4

43.3

16.3

10.7

1.8

2.6

34.3

28.9

10.9

-

2.6

18.0

5.4

92.8

49.5

38.3

6.7

9.3

8.8

1.2

18.9

44.2

0.3

2.9

4.0


DRAFT

25

EU ID

H-9902

NH-

0057

Point ID

H-9902

NH-0057

Const/

Mod Date

2005

Const.

Planned for 2007

Fired Duty

Limit (1)

(MMBtu/hr)

50

128

(3)

(3)

Pollutant

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

Emission

Rate Limit (1)

(lb/MMBtu)

-

-

-

-

0.050

-

-

-

-

0.050

-

-

-

-

Emission Limit lb/hr

1.6

1.2

0.2

0.3

2.5

2.0

1.6

0.3

0.4

6.4

5.1

4.0

0.7

1.0

(1)

TPY

1. 365-day rolling average, except as otherwise specified in the specific conditions. Time period basis is midnight to midnight.

2. 24-hr rolling average limit calculated hourly on the hour. Limit does not apply during low fired duty and catalyst regeneration. Low fired duty is less than 30% of max firing rate and applies to H-0048 and H-6007 only. Catalyst regeneration applies to H-0048 and H-6007 only. CO emissions during startup, shutdown, or malfunction will not be used for determining compliance with the 24-hr rolling average limit provided that the facility implements good air pollution control practices to minimize emissions during such periods.

3. Fired duties are shown for the purposes of regulatory applicability only and are not limits.

4. 7-day rolling average limit during low fired duty only. Time period basis is midnight to midnight. Limit does not apply during catalyst regeneration. Low fired duty is less than 30% of max firing rate. Catalyst regeneration applies to H-0048 and H-6007 only. CO emissions during startup, shutdown, or malfunction will not be used for determining compliance with the 7-day rolling average limit provided that the facility implements good air pollution control practices to minimize emissions during such periods.

5. Ppmvd @ 3% O

2

7-day rolling average limit during catalyst regeneration only. Limit does not apply during startup, shutdown or malfunction. Time period basis is midnight to midnight.

6. B-5004 emissions are included in EUG FCC-1, Point ID No. 5 FCCU/B5004 emission totals.

7.0

5.4

1.0

1.3

11.0

8.8

6.8

1.2

1.6

28.0

22.4

17.4

3.0

4.2 a. The heaters and boilers are subject to 40 CFR Part 60 Subpart J. The permittee shall comply with all applicable requirements including, but not limited to, the following:

[40 CFR Part 60 Subpart J] i. §60.104 Standards for sulfur oxides. The boilers shall combust only pipeline grade natural gas, PSA off-gas, or refinery fuel gas with a 3-hour rolling average maximum H

2

S concentration of 0.1 gr/dscf (160 ppmv @ 60 o F). ii. §60.105 Monitoring of emissions and operations. A continuous monitoring system shall be operated and maintained to record either the H

2

S content of the fuel gas or the SO

2 concentration in the flue gas. If an SO

2

monitor is used, the SO

2

concentration standard is

20 ppmvd @ 0% O

2

, 3-hr rolling average and an oxygen monitor shall also be included for correcting the data for excess air.


DRAFT

26

Compliance with the monitoring requirements for H-8801/8802 and H-9851 shall be in accordance with “Request for Approval – Alternative Monitoring Plan for Fuel Gas

Stream for H-8801/8802” dated February 16, 2006, in lieu of the requirements of 40 CFR

60.105. iii. §60.106 Test methods and procedures. iv. §60.107 Reporting and recordkeeping requirements. v. §60.108 Performance test and compliance provisions b. Compliance with the firing rate limits for B-0006, B-0007, H-0001, H-0003, H-0004, H-

0011, H0023, H-0029, H-0048, H-6007, H-6008, H-6014, H-6015, H-8601, H-8602, and H-

8801/8802 shall be based on 365-day rolling average fuel gas usage and heating value and shall be demonstrated monthly using on-line instrumentation and calculations, when available, or the following formula: [OAC 253: 100-43]

MMBtu/hr = MMSCFD * Btu/Scf (HHV) * (1 day/24 hr) * (MMBtu/10

6

Btu) c. Compliance with the emissions limits for PM and VOC is demonstrated by the use of good combustion practices. [OAC 253: 100-43] d. Compliance with the SO

2

emission limits shall be based on 365-day rolling average fuel gas usage and H

2

S content and shall be demonstrated monthly using on-line instrumentation and calculations, when available, or the following formula: [OAC 253: 100-43] lb/hr = MMSCFD * ppmvd H

2

S * 64 lb SO

2

/lb-mole

24 hr/day * 379.4 Scf/lb-mole

TPY = MMSCFD * ppmvd H

2

S * 64 lb SO

2

/lb-mole * 365 days/year

2000 lb/ton * 379.4 Scf/lb-mole e. Compliance with the NO

X

and CO emission limits shall be based on 365-day rolling average fuel gas usage and heating value and CEMS data or heater specific (stack test) emission factors, when available, or the most current version emission factors from AP-42 Table 1.4-1.

Compliance shall be demonstrated monthly using on-line instrumentation and calculations, when available, or the following formula: [OAC 253: 100-43] lb/hr = MMSCFD * Btu/Scf (HHV) * EF

24 hr/day

TPY = MMSCFD * Btu/Scf (HHV) * EF * 365 days/year

2000 lb/ton where EF = Emission Factor, lb/MMBtu


DRAFT

27 f. For those boilers or heaters equipped with a NO

X

CEMS, compliance with the NO

X

lb/MMBtu emission limit shall be based on 365-day rolling average CEMS data for NO

X

concentration in the flue gas. Compliance shall be demonstrated monthly using on-line instrumentation and calculations, when available, or the following formula: [OAC 253: 100-43] lb/MMBtu = 8,710 scf/MMBtu * (1/385.3 scf/lb-mole) * ppmvd * (1/10

6

) *

(20.9/20.9-O

2

%) * 44 lb/lb-mole

Otherwise, compliance with the NO

X

lb/MMBtu emission limit shall be demonstrated through initial performance testing. g. For those boilers or heaters equipped with a CO CEMS, compliance with the CO lb/MMBtu emission limit or concentration limit shall be based on 365-day rolling average (or 24-hr or 7day rolling average as applicable) CEMS data for CO concentration in the flue gas. Compliance shall be demonstrated monthly using on-line instrumentation and calculations, when available, or the following formula: [OAC 253: 100-43] lb/MMBtu = 8,710 scf/MMBtu * (1/385.3 scf/lb-mole) * ppmvd * (1/10

6

) *

(20.9/20.9-O

2

%) * 28 lb/lb-mole

Otherwise, compliance with the CO lb/MMBtu emission limit shall be demonstrated through initial performance testing. h. For B-0006 and B-0007, compliance with the NO

X

, CO, VOC, and PM

10

TPY emission limits shall be based on the following emission factors and monthly fuel heat input. Monthly fuel heat input shall be based on the total monthly fuel usage and the monthly average higher heating value (HHV). [OAC 252:100-43]

Pollutant

NO

X

CO

VOC

PM

10

Emission Factors, lb/MMBtu

B-0006 B-0007

0.28

0.12

0.0014

0.027

0.28

0.12

0.0014

0.018 i. Compliance with the NO

X

and CO emission factors for B-0006 and B-0007 shall be based on testing per the methods of 40 CFR Part 60. This testing shall be conducted at least once during the term of each Title V operating permit if the boilers are operated, other than being on hot standby, during that period.

[OAC 252:100-43] j. Performance testing for NO

X

and CO shall be conducted for H-6014, H-8602, H-9901, H-9851,

H-5002, and NH-0057 within 60 days of achieving maximum firing rate not to exceed 180 days from initial start-up and at other times as directed by the Air Quality Division (AQD). The permittee shall submit written reports of this performance testing to AQD. The performance


DRAFT

28 testing shall be conducted using the test methods specified in 40 CFR Part 60 and shall be conducted while the heaters or boilers are operating within 10% of the maximum design firing rate, except for those heaters and boilers that cannot be fired within 10% of the maximum design firing rate due to process limitations and/or production limitations. In those cases, the permittee shall conduct an initial performance test at the maximum firing rate possible under the present operating conditions and within the time guidelines given above. The permittee shall include in the written performance test report submitted to the AQD the reasons for testing the heater or boiler at less than 90% of the maximum design firing rate. The permittee shall then conduct testing of the heater or boiler at least once per calendar quarter 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 the AQD. The permittee shall submit the results of quarterly testing to the AQD. Within 60 days of achieving 90% or more of maximum firing rate, the permittee shall conduct performance testing using the test methods specified in 40 CFR Part 60, submit a notice of intent to test and a testing protocol to

AQD at least 30 days prior to conducting this performance test, furnish a written report to AQD documenting compliance with the emission limitations. If this performance test demonstrates that the heater or boiler is in compliance with all emission limitations, no additional quarterly testing will be required. The permittee shall maintain records of all performance testing, reports, and notices required by this specific condition. [OAC 252:100-8-6(a)] k. Within 180 days of commencement of operation of Ultra Low NO

X

burners installed in H-

0001, H-0048, H-6007, and H-6015, the permittee shall certify, calibrate, maintain and operate

NO

X

and CO Continuous Emission Monitoring Systems (CEMS) in accordance with the requirements of 40 CFR 60.11, 60.13, and Part 60 Appendix A, B, and F. With respect to 40

CFR 60, Appendix F, in lieu of the requirements of 40 CFR Appendix F sections 5.1.1, 5.1.3, and 5.1.4, the permittee shall conduct either a Relative Accuracy Audit (RAA) or a Relative

Accuracy Test Audit (RATA) once every twelve calendar quarters, provided that a cylinder gas audit is conducted each calendar quarter. [Consent Decree resolving Civil Action H-01-4430] l. Upon startup of H-5002, existing heater H-5001 shall be removed from service. Upon startup of NH-0057, existing heaters H-0057, H-0058, and H-0059 shall be removed from service.

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

EUG HTR-3: Heaters & Boilers Subject to Oklahoma Rules, Permit Limits, or 40 CFR

Part 63 Subpart DDDDD (Heater/Boiler MACT) Only

EU ID

BLR-

GFMST1

Point ID

BLR-

GFMST1

Const/

Mod

Date

Pre-2004

Fired Duty (1)

MMBtu/hr

Pollutant

6.3

NO

X

CO

SO

2

VOC

PM

10

Emission

Rate Limit

(lb/MMBtu)

-

-

-

-

-

Emission Limit lb/hr TPY

-

-

-

-

-

-

-

-

-

-


DRAFT

29

EU ID Point ID

Const/

Mod

Date

Fired Duty (1)

MMBtu/hr

Pollutant

Emission

Rate Limit

H-6037A/

6037B

HTR-5FCC

Converter Air

Preheater

No. 4

FCCU

No. 5

FCCU/B-

5004

1988

1971

23.4

Est. >10 but

<50

NO

X

CO

SO

2

VOC

PM

10

NO

X

CO

SO

2

VOC

PM

10

(lb/MMBtu)

-

-

-

-

-

-

-

-

-

-

1. Fired duty is shown for the purposes of regulatory applicability only and is not a limit.

Emission Limit lb/hr TPY

(2)

(2)

(2)

(2)

(2)

(3)

(3)

(3)

(3)

(3)

(2)

(3)

(3)

(3)

(3)

(3)

(2)

(2)

(2)

(2)

2. H-6037A/6037B emissions are included in the No. 4 FCCU emission limits.

3. HTR-5FCC Converter Air Preheater emissions are included in the No. 5 FCCU/B-5004 emission limits.

EUG HTR-4: Insignificant Activity Heaters & Boilers

There are no emissions limitations for these heaters or boilers.


BLR-

GFMNT1

BLR-GFMNT1


North Tower

Emergency Boiler

Park Bldg Boiler

#1








MISCELLANEOUS EQUIPMENT

Park Bldg Boiler

#2


There are no emissions limitations for these engines.


Horse

Power

(1)

Construction/

Modification

Date

E-0036

E-0068

E-0072

ENG-ASU

Portable

E-0036

E-0068

E-0072

ENG-ASU

Portable

Maintenance portable power generator engine

Sat Gas Unit engine

Sat Gas Unit engine

ASU portable backup air compressor engine

308

550

600

213

Est. 2002

1950’s

1941

1987


DRAFT

30


Horse

Power

(1)

Construction/

Modification

Date

ENG-EP

Portable

ENG-MPP

Portable #1

ENG-MPP

Portable #2

ENG-EP

Portable

ENG-MPP

Portable #1

ENG-MPP

Portable #2

East Plant portable backup air compressor engine

Main Power Plan portable backup air compressor engine

Main Power Plan portable backup air compressor engine

ENG-SP

Portable #1

ENG-SP

Portable #2

ENG-SP

Portable #1

ENG-SP

Portable #2




There are no emissions limitations for these engines.

EU ID

E-0049

E-0050

E-0051

E-0075

E-0110

ENG-Alky

ENG-GFMCB

Point ID

E-0049

E-0050

E-0051

E-0075

E-0110

ENG-Alky

ENG-GFMCB

213

450

450

425

425

1989

Est. Post-1974

Est. Post-1974

Pre-12/19/02

Pre-12/19/02

Equipment






Emergency power generator engine

Continental Bldg generator engine for emergency backup power


Reason

App. I: Combustion

Equipment -



<50 hp



<50 hp



<50 hp



<50 hp

App. I: Combustion


Generation < 500 hrs/yr

App. I: Combustion




DRAFT

31

EU ID

ENG-GFMSB

ENG-GFMST

Point ID

ENG-GFMSB

ENG-GFMST

Equipment

Security Bldg generator engine for emergency backup power

South Tower generator engine for emergency backup power


Reason

App. I: Combustion



App. I: Combustion



ENG-GFMPB ENG-GFMPB

Park Bldg generator engine for emergency backup power

App. I: Combustion





Horse

Power

(1)

Displacement

(L/cylind er) (1)

Const./

Mod.

Date

Pollutant

Emission

Rate

Limit g/hp-hr

ENG-

GFMMB

ENG-

GFMMB

Microwave

Bldg

Generator for

Emergency

Backup Power

135 <10

Mfr’d 9/06

/ Ordered

Post-

7/11/05

NO

X

6.9

ENG-

E5017

SP Firewater

Pump Engine

Mfr’d 2007

/ Ordered

Post

NMHC +

NO

X

7.8

ENG-

E5017

484 <30

CO 2.6

ENG-

E5018

ENG-

E5018

SP Firewater

Pump Engine

484 <30

7/11/05

Mfr’d 2007

/ Ordered

Post

7/11/05

PM

NMHC +

NO

X

CO

0.40

7.8

2.6

PM 0.40

1. Horsepower and displacement are shown for the purposes of regulatory applicability only and is not to be construed as a limit. a. For the listed engines, the permittee shall comply with all applicable requirements of 40 CFR

Part 60 Subpart IIII, including, but not limited to, the following: i.

§

60.4205 Emission Standards. As listed in the above table.

[40 CFR Part 60 Subpart IIII] ii.

§

60.4206 How long must owner or operator meet the emission standards. iii.

§

60.4207 Fuel Requirements.


DRAFT

32 iv. § 60.4209 Monitoring Requirements. The operator shall install a non-resettable hour meter on each engine prior to startup of the engine. v. §

60.4211 Compliance Requirements. Each engine may be operated up to 100 hours per year for maintenance checks and readiness testing if such tests are recommended by

Federal, State, or local government, the manufacturer, the vendor, or the insurance company associated with the engine. There are no hour limits on operation for emergency situations. vi. § 60.4214 Notification, Reports, and Records for Owners and Operators. Initial notification is not required for emergency stationary CI ICE.



EU ID

No. 4 FCCU w/o WGS

Point ID

No. 4 FCCU

Const / Mod

Date

1951

Pollutant

NO

X

CO ppmvd

Limit

60 (7) /

40 (3)

500 (2) /

150 (3)

-

Emission Limit lb/hr

19.9

TPY

87

(1)

83.7 (4) 110 (5)

SO

2

76.0 333

VOC - 1.9 8.3

No later than

December

31, 2008

1952 / 1972

(SC 35 mod)

PM

10

SO

2

-

50 (7) /

25 (3)

33.1 145

12.6 55

No. 4 FCCU w/WGS (10)

No. 5 FCCU/

B-5004

No. 4 FCCU

No. 5 FCCU/

B-5004

PM

NO

CO

SO

2

10

X

-

90 (7) /

46 (3)

500 (2) /

150 (3)

50 (7) /

25 (3)

-

16.7 (11)

53.6 /

26.4 (9)

160 (4) /

60 (8)

58.7 (1) /

425 (6)

-

73 (11) /

110 (12)

235 /

116 (9)

46.1 (5, 8)

257

VOC -

PM

10

- 30.0 131

1. 365-day rolling average, except as noted.

2. ppmdv @ 0% oxygen, 1-hour average. [CD resolving Civil Action No. H-01-4430]

3. ppmdv @ 0% oxygen, 365-day rolling average.

4.

Corresponds to 500 ppmdv @ 0% oxygen, 1-hr average.

[CD resolving Civil Action No. H-01-4430]

5.

Corresponds to 150 ppmdv @ 0% oxygen, 365-day rolling average.

6. Daily average from midnight to midnight.

7. ppmdv @0% oxygen, 7-day rolling average.

8. Demonstration of compliance with the annual TPY shall not include periods of time when B-5004 is operated by firing only with refinery fuel gas, at which time No. 5 FCCU/B-5004 shall comply with a CO emission limit of 60 lb/hr, on a 7-day rolling average basis. [Consent Order Case No. 06-322]

9. Limits supercede 53.6 lb/hr and 235 TPY following completion of a performance optimization study and performance demonstration of the ESNCR. [CD resolving Civil Action No. H-01-4430]


DRAFT

33

10. These limits on SO

2

and PM

10

apply after startup of the wet gas scrubber on No. 4 FCCU.

11. Non-sulfate PM. Measured using EPA Method 5B.

[CD resolving Civil Action No. H-01-4430]

12. Total PM. Measured using EPA Method 5B and EPA Method 202. a. Until startup of the wet gas scrubber, compliance with the No. 4 FCCU PM

10

emission limits shall be based on a correlation for calculating PM

10

from other measurable process variables, such as, but not limited to, opacity or superficial velocity. The correlation shall be developed from the No. 4 FCCU testing conducted on March 28, 2002, and May 20 and 21, 2003.

[OAC 242:100-8-6(a)] b.

The alternate No. 4 FCCU short-term opacity limit for compliance with OAC 252:100-25 is

33 percent. The permittee shall obtain opacity measurements by using a continuous opacity monitoring system (COMS). Records of compliance with the opacity provisions of OAC

252:100-25 shall be maintained. In addition to the reporting requirements of OAC 252:100-

9, exceedances shall be reported in writing to the DEQ on a quarterly basis, with reports due within thirty (30) days following each calendar quarter.

[OAC 252:100-25 and Air Quality Council Order 2/18/98] c. The permittee shall operate and maintain a cyclone control system for the No. 4 FCCU until the time that a wet gas scrubber is installed. Until a wet gas scrubber is installed, the cyclonic separators shall be inspected for air leakage and for cracks or other irregularities in the walls during each turnaround. Necessary repairs shall be made, and records of inspections and repairs shall be retained for the most recent inspection.

[OAC 252:100-25 and Air Quality Council Order 2/18/98] d. The permittee shall maintain records to demonstrate that the No. 4 FCCU emissions of CO are reduced by the use of complete secondary combustion of the waste gas generated.

Removal of 93 percent or more of the CO generated shall be considered equivalent to secondary combustion. [OAC 252:100-35] e. For the No. 5 FCCU, the permittee shall comply with a PM emission limit of 0.9 lb per 1000 lb coke burned. Compliance with this limit shall be demonstrated by a stack test using Method 5B and Method 202 conducted by no later than December 31, 2007.

[Consent Order Case No. 06-322] f. The permittee shall install and maintain continuous emission monitoring systems (CEMS) for measuring NO

X

, CO, and SO

2

. The permittee shall certify, calibrate, maintain, and operate the NO

X

, CO, and SO

2

CEMS in accordance with the requirements of 40 CFR 60.11, 60.13, and Part 60 Appendix A, B, and F. With respect to 40 CFR 60 Appendix F, in lieu of the requirements of 40 CFR Appendix F sections 5.1.1, 5.1.3, and 5.1.4, the permittee shall conduct either a Relative Accuracy Audit (RAA) or a Relative Accuracy Test Audit (RATA) once every twelve calendar quarters, provided that a cylinder gas audit is conducted each calendar quarter. [CD Resolving Civil Action No. H-01-4430]


DRAFT

34 g. During flow monitor downtime the permittee may calculate daily stack flow based on air blower rate measurements and use this data with CEMS data or alternative monitoring data to determine compliance with mass emission rate limits in the table above. Records of emission and flow calculations shall be maintained when this option is used. [OAC 252:100-43] h. The No. 4 FCCU and No. 5 FCCU/B-5004 are subject to the CO and SO

2

standards of 40

CFR Part 60 Subpart J. The No. 5 FCCU is already subject to the PM requirements and the

No. 4 FCCU will become subject to the PM requirements on December 31, 2008. Beginning on the appropriate date, the permittee shall comply with all applicable requirements for CO,

SO

2

, and PM including, but not limited to, the following:

[CD resolving Civil Action No. H-01-4430 for 40 CFR Part 60 Subpart J] i. § 60.102 Standard for particulate matter. Compliance with the No. 4 FCCU opacity requirements shall be in accordance with “Request for Approval – Alternative Monitoring

Plan for FCCU Opacity Subject to 40 CFR 60 Subpart J” dated May 16, 2007 in lieu of the requirements of 40 CFR 60.102(a)(2) and 40 CFR 60.105(a)(1). Compliance with the

No. 5 FCCU opacity requirements shall be in accordance with “Request for Approval –

Alternative Monitoring Plan for FCCU Opacity Subject to 40 CFR 60 Subpart J” dated

April 18, 2007 in lieu of the requirements of 40 CFR 60.102(a)(2) and 40 CFR

60.105(a)(1). Compliance with the No. 5 FCCU coke burn-off calculation requirements shall be in accordance with “Request for Approval – Alternative Coke Burn-off Rate

Equations for the No. 5 Fluidized Catalytic Cracking Unit” dated February 11, 2005. ii. §

60.103 Standard for carbon monoxide. iii. § 60.104 Standard for sulfur dioxide. SO

2

emissions from the No. 4 FCCU are limited to

20 lb/ton coke burn-off in the catalyst regenerator, 7-day rolling average. SO

2

NSPS

Subpart J emissions limits for the No. 5 FCCU are as shown in the table above. iv. § 60.105 Monitoring of emissions and operations. Compliance with the No. 4 FCCU SO

2 monitoring requirements shall be in accordance with “Request for Alternative

Demonstration of Compliance Method – SO

X

CEMS in Lieu of RM-8 Monitoring” dated

July 31, 2003 in lieu of the requirements of 40 CFR 60.105(a)(1). Compliance with the

No. 5 FCCU coke burn-off calculation requirements shall be in accordance with “Request for Approval – Alternative Coke Burn-off Rate Equations for the No. 5 Fluidized

Catalytic Cracking Unit” dated February 11, 2005. v. § 60.106 Test methods and procedures. Compliance with No. 4 FCCU and No. 5

FCCU/B-5004 PM emission limits shall be demonstrated by a stack test in accordance with paragraph 47 of the Consent Decree resolving Civil Action No. H-01-4430(B). For the No. 4 FCCU, the first stack test shall be conducted by no later than March 31, 2009 and subsequent annual stack tests shall be conducted by December 31 st of the associated year. For the No. 5 FCCU, the first stack test shall be conducted by no later than

December 31, 2007 and subsequent annual stack tests shall be conducted by December

31 st

of the associated year. The permittee may request that stack tests be conducted less


DRAFT

35 frequently following at least three (3) annual tests that demonstrate the PM limit is not being exceeded. vi. §

60.107 Reporting and recordkeeping requirements. Compliance with the No. 5 FCCU coke burn-off calculation requirements shall be in accordance with “Request for Approval

– Alternative Coke Burn-off Rate Equations for the No. 5 Fluidized Catalytic Cracking

Unit” dated February 11, 2005. vii. § 60.108 Performance test and compliance provisions. i. The No. 4 FCCU and No. 5 FCCU/B-5004 are subject to 40 CFR Part 63 Subpart UUU. The permittee shall comply with all applicable requirements including, but not limited to, the following: [40 CFR Part 63 Subpart UUU] i. §

63.1564 Standard for metal HAP. For the No. 5 FCCU/B-5004, compliance with the metal HAP requirements in this section are met by demonstrating compliance with the opacity standard in 40 CFR 60.103. Compliance with the No. 5 FCCU opacity requirements shall be in accordance with “Request for Approval – Alternative Monitoring

Plan for FCCU Subject to 40 CFR 60 Subpart J” dated April 18, 2007 in lieu of the requirements of 40 CFR 60.102(a)(2) and 40 CFR 60.105(a)(1). For the No. 4 FCCU, the permittee is presently complying with the Ni limit of 63.1564(a)(1)(iii). ii. §

63.1565 Standard for organic HAP. For the No. 4 FCCU and the No. 5 FCCU/B-5004, compliance with the organic HAP requirements in this section are met by demonstrating compliance with the CO standard in 40 CFR 60.103. iii. §

63.1569 Bypass line requirements. iv. §

63.1570 General requirements. v. §

63.1571 Test methods and procedures. vi. §

63.1572 Monitoring, installation, operation and maintenance requirements. vii. §

63.1574 Notifications. viii. §

63.1575 Reporting requirements. ix. §

63.1576 Recordkeeping requirements.


DRAFT

36




Construction/


No. 2 CRU

No. 3 CRU

No. 2 CRU

No. 3 CRU





1957

1956 a. The listed equipment is subject to the standards of 40 CFR Part 63 Subpart UUU. The permittee shall comply with all applicable requirements including, but not limited to, the following: [40 CFR Part 63 Subpart UUU] i. §

63.1564 Standard for organic HAPs. ii. § 63.1565 Standard for inorganic HAPs. iii. §

63.1569 Bypass line requirements. iv. §

63.1570 General requirements. v. §

63.1571 Test methods and procedures. vi. §

63.1572 Monitoring, installation, operation and maintenance requirements. vii. §

63.1574 Notifications. viii. §

63.1575 Reporting requirements. ix. §

63.1576 Recordkeeping requirements.



Construction/


Flare-CC

Flare-CF

Flare-EP

Flare-SF

Flare-SP

Flare-Temp

Flare-CC

Flare-CF

Flare-EP

Flare-SF

Flare-SP

Flare-Temp

Coker/Combo Alky Flare

Clean Fuels and West Plant Flare

East Plant Flare

Santa Fe Loading Rack Flare

South Plant Flare

Temporary Flare

1970

2003

1990

2002

1972

1994


DRAFT

37 a. The listed flares are subject to 40 CFR Part 60 Subpart J. The permittee shall comply with all applicable requirements including, but not limited to, the following:

[40 CFR Part 60 Subpart J] i. The flares shall be fueled with refinery fuel gas, PSA off-gas, or natural gas with a maximum sulfur content of 0.1 gr/dscf (160 ppmv @ 60°F). [40 CFR 60.104] ii. A continuous monitoring system shall be operated and maintained to record the H

2

S content of all refinery fuel gas combusted in the flare. [40 CFR 60.105] iii. As an alternative to (i) and (ii) above, Flare-EP may comply with 40 CFR 60.11(d) by doing all of the following:

(1) Installation and operation of an H

2

S Continuous Emissions Monitor (CEMS) and flow monitor to continuously monitor flare flow, H

2

S concentration, and continuous calculation of the corresponding SO

2

emissions.

(2) Maintaining the calculated SO

2

emissions to no greater than 500 lbs of SO

2

per 24hour period.

(3) Implementing maintenance procedures to perform acoustic meter monitoring of the leakage rate for each device routed to Flare-EP. The monitoring will be performed quarterly with provisions for reduction in frequency with demonstrated performance.

[Consent Decree resolving Civil Action H-01-4430]

(4) The permittee shall certify, calibrate, maintain, and operate the H

2

S Continuous

Emission Monitoring System (CEMS) in accordance with the requirements of 40

CFR 60.11, 60.13, and Part 60 Appendix A, B, and F. With respect to 40 CFR 60

Appendix F, in lieu of the requirements of 40 CFR Appendix F sections 5.1.1, 5.1.3, and 5.1.4, the permittee shall conduct either a Relative Accuracy Audit (RAA) or a

Relative Accuracy Test Audit (RATA) once every twelve calendar quarters, provided that a cylinder gas audit is conducted each calendar quarter.

[CD Resolving Civil Action No. H-01-4430]

(5) The permittee shall be allowed to use an alternate span and relative accuracy test method to demonstrate compliance with 40 CFR 60.105(a)(4)(i) and 60.105(a)(4)(iii) in accordance with the “Request for Approval – Alternate Span and Relative

Accuracy Testing Plan for East Plant Flare H

2

S CEMS” dated September 26, 2006. iv. As an alternative to (i) and (ii) above, Flare-SP and Flare-CF may comply with 40 CFR

60.11(d) by installing a flare gas recovery system.

[Consent Decree resolving Civil Action H-01-4430]

(1) Periodic maintenance may be required for properly designed and operated flare gas recovery systems. To the extent that the facility operates flare gas recovery systems, the facility will take all reasonable measures to minimize emissions while such periodic maintenance is being performed.

(2) Under certain conditions, a flare gas recovery system may need to be bypassed in the event of an emergency or in order to ensure safe operation of refinery processes. The


DRAFT

38 facility is allowed to temporarily bypass a flare gas recovery system under such circumstances. v. As an alternative to (i) and (ii) above, waste gases from the coker units routed to the

Flare-CC may comply with 40 CFR 60.11(d) by installing a flare gas recovery system.

[Consent Decree resolving Civil Action No. H-01-4430 and Consent Order 00-196]

(1) Periodic maintenance may be required for properly designed and operated flare gas recovery systems. To the extent that the facility operates flare gas recovery systems, the facility will take all reasonable measures to minimize emissions while such periodic maintenance is being performed.

(2) Under certain conditions, a flare gas recovery system may need to be bypassed in the event of an emergency or in order to ensure safe operation of refinery processes. The facility is allowed to temporarily bypass a flare gas recovery system under such circumstances.

(3) The flare gas recovery system is not designed or required to capture all of the waste gases from coker drum processing. The facility’s work practices and procedures, including operator training, are designed to maximize waste gas recovery during coker drum processing.

(4) Any one of the following will be used to demonstrate that the flare gas recovery system is operating properly: Operating procedures, operator training records, maintenance records, or operating data that indicate the flare gas recovery system is functioning as designed.

(5) The permittee shall implement maintenance procedures to perform acoustic meter monitoring of the leakage rate for each device routed to the Flare-CC downstream of the flare gas recovery system. The monitoring will be performed annually. vi. As an alternative to (i) and (ii) above, Flare-SF and refinery fuel gas streams vented to flare downstream of the Flare-CC flare gas recovery system may comply with 40 CFR

60.11(d) by following EPA-approved alternate monitoring plans.

[EPA-Approved Flare-CC AMP (12-1-04 / Revised 1-11-06) and

EPA-Approved Flare-SF AMP (6-20-03)] vii.

Flare-Temp may comply with NSPS Part 60 Subpart J by using any of the above options.

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


DRAFT

39


Load-SF loads both gasoline and distillates. The following limits and requirements apply only to the gasoline loading portion of the rack.

EU ID

Point

ID

Process

Const /

Mod Date

Throughput

Limit (gal/yr)

(1)

VOC Emissions

Limit (2) lb/hr TPY

Load-SF Flare-SF

Santa Fe Loading

Rack (Gasoline)

1997 30,000,000 - 1.3


2. 12-month rolling total. Compliance with the throughput limit demonstrates compliance with the

VOC emissions limit. a. The listed equipment is subject to both 40 CFR Part 60 Subpart XX and 40 CFR Part 63

Subpart CC. Subpart CC requires an affected loading rack to comply with certain parts of 40

CFR Part 63 Subpart R, which requires compliance with certain parts of Subpart XX. An operator is required to comply only with the provisions in each subpart that contain the most stringent control requirements for the facility. The permittee shall comply with emission limits and applicable requirements including, but not limited to, the following: [40 CFR 63.420(g)] i. The permittee shall comply with the provisions of 40 CFR Part 63, Subpart A – General

[40 CFR 63.420(h)] Provisions as indicated by Table 1 of 40 CFR Part 63, Subpart R. ii. §63.422 Standards: Loading Racks.

(1) The permittee shall comply with the requirements in 40 CFR 60.502 except for paragraphs (b), (c), and (j).

(2) Emissions to the atmosphere from the vapor collection and processing systems due to the loading of gasoline cargo tanks shall not exceed 10 milligrams of total organic compounds per liter of gasoline loaded.

(3) The permittee shall comply with 40 CFR 60.502(e) in accordance with the provisions of 40 CFR 63.422(c). Loadings of liquid product into cargo tanks shall be limited to vapor-tight gasoline tank trucks.

(4) As an alternative to 40 CFR 60.502(h) and (i), the permittee may comply with paragraphs (e)(1) and (e)(2) of 40 CFR 63.422. iii. §63.424 Standards: Equipment Leaks. iv. §

63.425 Test Methods and Procedures.

(1) The permittee shall maintain records of the performance test previously conducted on the vapor processing and collection system in accordance with 40 CFR 63.425(a),(b), and (c).


DRAFT

40

(2) The permittee shall comply with 40 CFR 63.425 (e) through (i). The permittee shall obtain documentation of an annual certification test using Method 27 for gasoline cargo tanks. As an alternative to the requirements of 40 CFR 63.425(e) the permittee may obtain documentation of compliance with 49 CFR 173.3(d), 179.7, 180.509, and

180.511 for the testing of railcar gasoline cargo tanks. v. §

63.427 Continuous Monitoring.

If a flare is used, the flare shall be equipped with a heat-sensing device installed in proximity to the pilot light to indicate the presence of a flame. vi. §

63.428 Reporting and Recordkeeping.

(1)

§

63.428(b) The permittee shall keep records of the test results for each gasoline cargo tank loading at the facility.

(2)

§

63.428(c) The permittee shall maintain continuous monitoring data and records. If a flare is used, the permittee shall keep records of the flare design, and all visible emissions readings, heat content determinations, flow rate measurements, and exit velocity determinations made during the compliance determination required under 40

CFR

§

63.425(a).

(3) §63.428(d) Maintain records.

(4) §63.428(e) Maintain a log book of leaks detected. vii. §63.654 Reporting and recordkeeping requirements.

b.

The permittee shall keep monthly records of the 12-month rolling total throughput for months when the equipment loads gasoline into cargo tanks. [OAC 252:100-43]


EU ID

Point

ID

Process

Const/

Mod

Date

Throughput

Limit (gallons)

VOC Emissions


Load-SP Load-SP

South Plant Loading

Rack (Distillates)

Est.

1930’s

175,200,000

(1)

3.0 8.8

1. Calendar year total.

2. Calendar year total. Compliance with the throughput limit demonstrates compliance with the

VOC emissions limit. a. When loading more than 40,000 gallons per day of products with a vapor pressure of 1.5 psia or more under actual storage conditions, all tank trucks or trailers must be bottom loaded with hatches closed or be equipped with a vapor collection and disposal system that meets the specification of OAC 252: 100-37-16(a)(1). A means shall be provided to prevent VOC drainage from the loading device when it is removed from any tank truck or trailer, or to accomplish complete drainage before removal. [OAC 252:100-37-16(a)]


DRAFT

41 b. When the Load-SP is operated to load distillates, the permittee shall maintain records of daily and cumulative annual throughput for distillate loaded.


There are no emissions limitations for these loading racks.

[OAC 252:100-43]




Refinery Vehicle

Refueling

Motor Pool

Refueling



Load-SF Load-SF

Santa Fe Loading

Rack (Distillates)



Process Vents

There are no emissions limitations for these miscellaneous process vents.


Construction/


VNT-D0749 Flare-CC


2001

VNT-T0039E Flare-EP T-39E sour water tank

Gasoline loading rack vapor

1932

VNT-SFLR Flare-SF

VNT-D6004 Flare-EP collection system

D-6004 #2CTU Desalter water surge drum

1997

1990 a. The listed miscellaneous process vents are subject to 40 CFR Part 63 Subpart CC. The permittee shall comply with all applicable requirements including, but not limited to, the following: [40 CFR Part 63 Subpart CC] i. §61.642 General Standards ii. §61.643 Miscellaneous process vent provisions iii. §61.644 Monitoring provisions for miscellaneous process vents iv. §61.645 Test methods and procedures for miscellaneous process vents v. §61.654 Reporting and recordkeeping requirements.


DRAFT

42


Process Vents

There are no emissions limitations for these miscellaneous process vents.


Construction/


VNT-C6015

Flare-EP

VNT-D0565 Flare-EP

VNT-D0701 VNT-D0701

VNT-D0702 VNT-D0702

VNT-D0704 VNT-D0704

VNT-D0714 VNT-D0714

VNT-D0717 Flare-CC

VNT-D0741 Flare-CC

VNT-D0748 Flare-CC

VNT-D5173 VNT-D5173

VNT-D5209 Flare-EP

VNT-D6201 Flare-EP

VNT-D6903 Flare-EP

VNT-D6933 Flare-EP

VNT-Load SF

LPG

VNT-Load SF

Toluene

VNT-Load SF

VNT-Load SF

Toluene

VNT-Load SP

LPG

VNT-Load SP

VNT-T0256 Flare-CC

VNT-W0193 Flare-CC

No. 3 Reformer Hydrogen Recycle

Compressor Seal Oil Pot Vents


D-701 vent/drain

D-702 vent/drain

D-704 vent/drain

D-714 vent/drain

D-717 depro overhead reflux


D-748 fuel gas drum

D-5173 vent/drain






Toluene unloading vent to atmosphere




1971

1959

1970

1970

1970

1970

1997

1985

1971

1944

1944

1971

1959

1968

Est. 1930’s

Est. 1930’s

1997

1932

1970 a. The listed miscellaneous process vents are subject only to the applicable reporting requirements of 40 CFR Part 63 Subpart CC. The permittee shall comply with the reporting requirements for Group 2 miscellaneous process vents in 40 CFR 63.654(f).

[40 CFR Part 63 Subpart CC]


DRAFT

43


There are no emissions limitations for these atmospheric process vents.


Construction/


VNT-C0008

VNT-C5017


There are no emissions limitations for these atmospheric process vents.

EU ID

VNT-C0008

VNT-C5017

Point ID

Sat Gas Compressor Distance Piece

Vent

Sat Gas Compressor Distance Piece

Vent

Equipment

1968

1941


Reason

VNT-C0024 VNT-C0024

VNT-C0060 VNT-C0060

VNT-C0061 VNT-C0061

VNT-C0125 VNT-C0125

VNT-C5037 VNT-C5037

No. 5 HDT Hydrogen


Vent


Distance Piece Vent


Distance Piece Vent

No. 3HDS Compressor

Distance Piece Vent

Butamer Hydrogen


Vent


TPY


< 5 TPY


< 5 TPY


< 5 TPY


< 5 TPY

VNT-D0809 VNT-D0809

VNT-D8806 VNT-D8806

Hydrogen Makeup Vent


Deaerator Vent


< 5 TPY


< 5 TPY


DRAFT

44


Note: equipment counts are estimates only for the purposes of documenting regulatory applicability and are not to be construed as operating limitations.

EUG FUG-1: Fugitive Piping Equipment Leaks Subject to 40 CFR Part 63 Subpart CC

(Refinery MACT I) and/or 40 CFR Part 60 Subpart GGG

EU ID

Refinery-Wide

Piping

Equipment

Fugitive Leaks

Point ID

Refinery-Wide

Piping Equipment

Fugitive Leaks

Equipment



Gas Valves

LL Valves

HL Valves

Flanges

LL Pump Seals

HL Pump Seals

Gas Compressors



Sample Stations

Number of Items

Construction/

Modification

Date

18,661

23,270

Various

Various

14,482

27,856

Various

Various

370 Various

289 Various

19 Various

539 Various

13 Various

587 Various a. The listed equipment is subject to 40 CFR Part 63 Subpart CC. Subpart CC specifies that compliance shall be met using the standards in 40 CFR Part 60 Subpart VV for existing sources or Subpart H for new sources. The permittee shall comply with all applicable requirements for Subpart CC including, but not limited to, the following:

[40 CFR Part 63 Subpart CC] i. §63.642 Definitions.

“In organic HAP service” means that a piece of equipment either contains or contacts a fluid (liquid or gas) that is at least 5 percent by weight of total organic HAP as determined according to the provisions of 40 CFR 63.180(d) of Subpart H and Table 1 of this subpart. The provisions of 63.180(d) of Subpart H also specify how to determine that a piece of equipment is not in organic HAP service. ii. §63.642 General standards. iii. §63.648 Equipment leak standards.

(1) Each owner or operator of an existing source shall comply with the provisions of 40

CFR Part 60 Subpart VV and paragraph (b) of 40 CFR 63.648 except as provided in paragraph (a)(1), (a)(2), and (c) through (i) of 40 CFR 63.648. Each owner or operator of a new source shall comply with 40 CFR Part 60 Subpart H except as provided in paragraphs (c) through (i) of 40 CFR 63.648.

(2) The provisions of 40 CFR Part 60 Subpart VV apply only to equipment in organic

HAP service as defined in 40 CFR 63.641.


DRAFT

45

(3) Calculation of percentage leaking equipment components for 40 CFR Part 60 Subpart

VV may be done on a process unit basis or a sourcewide basis. Once the owner or operator has decided, all subsequent calculations shall be on the same basis unless a permit change is made. iv. §63.649 Alternative means of emission limitations: Connectors in gas/vapor service and light liquid service. v. §63.654 Reporting and recordkeeping requirements. b. The listed equipment is subject to the requirements of Subpart GGG. Subpart GGG specifies compliance with certain requirements of 40 CFR Part 60 Subpart VV. For the listed equipment that is “in organic HAP service”, the permittee is only required to comply with the requirements for 40 CFR Subpart CC listed above. The permittee shall comply with all applicable requirements of Subpart GGG including, but not limited to, the following:

[40 CFR Part 60 Subpart GGG] i. §60.592 Standards.

(1) An owner or operator shall comply with the requirements of 40 CFR 60.482-1 to

60.482-10.

(2) An owner or operator may elect to comply with the requirements of 40 CFR 60.483-1 and 60.483-2.

(3) Each owner or operator shall comply with the provisions of 40 CFR 60.485 except as provided in 40 CFR 60.593.

(4) Each owner or operator shall comply with the provisions of 40 CFR 60.486 and 60.487. ii. §60.593 Exemptions



EU ID Point ID

Equipment

(WDB = water draw box)

Process drains

Number of Items

27

Construction/

Modification

Date

1991

FUG-Coker

ORU

FUG-1HP,

FUG-CC


Process drains

6

145

1991

2003-2006

2HP, 2Isom,

8HDT, 9HDT

& FGRU

FUG-CF


52 2003-2006


Point ID Equipment EU ID

FUG-2CTU,

3CRU, 4FCC &

ORU

FUG-WP ORU

FUG-EP

FUG-WP


Process drains


FUG-OM Tank

Farm & WWTS

FUG-SP Tank

Farm

FUG-OM

FUG-SP

Process drains


Process drains


DRAFT

Number

33

19

8

0

27

0

3

Date

Various

1991

1991 n/a

Various n/a

Various

46

Construction/ a. The listed equipment is subject to 40 CFR Part 63 Subpart CC.

Listed equipment that was constructed, reconstructed, or modified after May 4, 1987 is also subject to 40 CFR Part 60

Subpart QQQ. The “overlap” provision of 40 CFR 63.640(o) states that a Group 1 wastewater stream managed in a piece of equipment that is also subject to the provisions of Subpart QQQ is only required to comply with Subpart CC.

The permittee shall comply with all applicable requirements for Subpart CC including, but not limited to, the following:

[40 CFR Part 63 Subpart CC] i. §61.642 General Standards. ii. §61.647 Wastewater provisions. Each owner or operator of a Group 1 wastewater stream shall comply with the requirements of 40 CFR 61.340 through 61.355 of 40 CFR Part 61

Subpart FF for each process wastewater stream that meets the definition in 40 CFR

63.641.

(1) §61.342 General standards.

(2) §61.346 Individual drain systems.

(3) §61.350 Standards: Delay of repair.

(4) §61.355 Test methods, procedures and compliance provisions. iii. §61.654 Reporting and recordkeeping requirements. b. The listed equipment is also subject to 40 CFR Part 61 Subpart FF. In addition to the requirements of 40 CFR Part 63, Subpart CC above, the permittee shall comply with the recordkeeping and reporting requirements of Subpart FF including, but not limited to, the following:

[40 CFR Part 61 Subpart FF] i. §61.356 Recordkeeping requirements. ii. §61.357 Reporting requirements.


DRAFT

47 c. Flare-EP and Flare-CC in EUG FLR-1 are 40 CFR Part 61 Subpart FF control devices. The permittee shall comply with all applicable requirements in Subpart FF including, but not limited to, the following: [40 CFR Part 61 Subpart FF] i.

§61.342 General standards. ii.

§61.349 Standards: Closed-vent systems and control devices iii. §61.354 Monitoring of operations. iv. §61.356 Recordkeeping requirements. v. §61.357 Reporting requirements.




Process drains

Number of Items

13

Construction/

Modification

Date

1991

FUG-6HDT FUG-CC


Process drains

12

50

1991

2005

FUG-2H2 Plant

& 9HDT

FUG-CF


Process drains

15

29

2005

1988

FUG-7HDT FUG-WP Junction boxes/sumps/WDB

13 1988

FUG-2SWS FUG-SP

Process drains

Junction

11 2005

0 2005 boxes/sumps/WDB a. The permittee shall demonstrate initially and once per year that the flow-weighted annual average benzene concentration in the waste stream(s) is less than 10 ppmw.

[40 CFR 61.342(c)(3)] b. The listed equipment is subject to 40 CFR 60 Subpart QQQ and shall comply with all applicable requirements including, but not limited to, the following:

[40 CFR Part 60 Subpart QQQ] i. §60.691 Definitions. ii. §60.692-1 Standards: General.

SPECIFIC CONDITIONS PERMIT NO. 98-104-TV iii. §60.692-2 Standards: Individual drain systems. iv. §60.692-4 Standards: Aggregate facilities. v. §60.692-6 Standards: Delay of repair.

DRAFT

48 vi. §60.692-7 Standards: Delay of compliance. vii. §60.693-1 Standards: Alternative standards for individual drain systems. viii. §60.696 Performance test methods and procedures and compliance provisions. ix. §60.697 Recordkeeping requirements. x. §60.698 Reporting requirements.

EUG FUG-4: Fugitive Oily Water Sewer System Component Leaks Subject only to 40



Number of Items

Construction/

Modification

Date

Various

Refinery-Wide

Oily Water Sewer

Component

Fugitive Leaks

Refinery-Wide

Oily Water Sewer

Component

Fugitive Leaks


Process drains

(uncontrolled)


(controlled)

78

2,118 Various

0 Various

Closed Drains


243 Various

303 Various

(uncontrolled) a. The permittee shall maintain records that demonstrate initially and once per year that the flow-weighted annual average benzene concentration in the waste stream(s) is less than 10 ppmw. [40 CFR 61.342(c)(3)]


DRAFT

49




Construction/


Y-0002

Y-0002 A

Y-0002

Y-0002 A

West Plant Marley EPHCC01

Cooling Tower

West Plant Marley 6615302 Cooling

Tower

1953

1973

Y-0003

Y-0005

Y-0006

Y-0007

Y-0009

Y-0010

Y-6026

Y-6027

Y-8000

Y-0003

Y-0005

Y-0006

Y-0007

Y-0009

Y-0010

Y-6026

Y-6027

Y-8000

Coker Cooling Tower

South Plant North & South Loop

Cooling Tower

Combo Cooling Tower

Main Power Plant Cooling Tower

ASU Cooling Tower

Alky Cooling Tower

East Plant Marley Cooling Tower

East Plant Pritchard Cooling Tower

Clean Gasoline Unit Cooling Tower

1946

1943

1956

1959

1992

1971

1953

1956

2003 a. Y-8000 shall be constructed with drift eliminators and a flow monitor. [OAC 252:100-8-6(a)] b. Once per month, the permittee shall determine the VOC concentration of Y-8000 cooling tower water. [OAC 252:100-8-6(a)]



EU ID Point ID Process Rate Limit (Dry Tons/yr) (1)

PM

10

Emissions


Coke Loading

Facility

Coke Loading

Facility

475,000 2.7 8.8


2. 12-month rolling total. Compliance with the process rate limit demonstrates compliance with the PM

10

emissions limit.

a. The permittee shall take reasonable precautions to minimize fugitive dust emissions from the

Coke Loading Facility loading and unloading operations, roads, and stockpiles. Water sprays shall be used for the minimization of fugitive dust as deemed necessary. [OAC 252:100-8-6(a)] b. The permittee shall maintain monthly records of the 12-month rolling total dry petroleum coke, or wet petroleum coke assuming 10% moisture, shipped from the Coke Loading Facility.

[OAC 252:100-43]


DRAFT

50

FUG FUG-8: Insignificant Activity Fugitive Sources

There is no emissions limitation for the application of biosludge.

EU ID

Landfarm

Point ID

Landfarm

Equipment

Application of ASU biosludge to landfarm


Reason

App. I: Fugitives – Land farms


There are no facility-wide emissions limitations.

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

[OAC 252:8-6(a)(3)(b)] a. Annual hours of operation of stationary reciprocating engines burning natural, gasoline, aircraft fuels, or diesel fuel which are either used exclusively for emergency power generations or for peaking power service not exceeding 500 hours per year. b. Throughput at fuel storage/dispensing equipment operated solely for facility owned vehicles

(monthly, averaged over a 30-day period). c. True vapor pressure for tanks satisfying the criteria of capacity less than 39,894 gallons and storing a liquid with a vapor pressure less than 1.5 psia maximum. d. Potential to emit of activities having a PTE of no more than 5 TPY of any criteria pollutant.

3. Except where inconsistent with the “minimum Federal Safety Standards for the Transportation of Natural and Other Gas by Pipeline” or any State of Oklahoma regulatory agency, no owner or operator shall allow VOC gases to be emitted from a vapor recovery blowdown system unless these gases are burned by a smokeless flare or equally effective control device as approved by the

Division Director. This requirement does not apply to VOC’s with a vapor pressure of less than 1.5 psia under actual storage conditions or to equipment installed on or prior to December 28, 1974.

[OAC 252:100-37-4(a) & 252:100-37-35(b)]

4. For pumps and compressors installed after December 28, 1974 handling VOCs with a vapor pressure of greater than or equal to 1.5 psia at actual storage conditions and that are not subject to the standards contained in 40 CFR Part 60 Subparts VV or GGG, the permittee shall comply with the following requirements: [OAC 252:100-37-38] a. Rotating type pumps and compressors are equipped with mechanical seals or other equipment of equal efficiency


DRAFT b. Reciprocating type pumps and compressors are equipped with packing glands.

51 c. Emissions from the drain recovery system do not exceed 2 cubic inches of liquid VOC in any

15-minute period per pump or compressor at standard conditions

5. Asbestos demolition, renovation, and disposal activities at the facility are subject to the applicable requirements of 40 CFR Part 61 Subpart M. The permittee shall comply with all applicable requirements of Subpart M including, but not limited to, the following:

[40 CFR Part 61 Subpart M] a. §61.145 Standard for demolition and renovation. b. §61.146 Standard for insulating materials. c. §61.148 Standard for spraying. d. §61.150 Standard for waste disposal for manufacturing, fabricating, demolition, renovation, and spraying operations. e. §61.152 Air cleaning.

6. The permittee shall comply with the following requirements for handling asbestos:

[OAC 252:100-41-16] a. Before being handled, stored or transported in or to the outside air, friable asbestos from demolition/renovation operations shall be double bagged in six-mil plastic bags, or single bagged in one six-mil plastic bag and placed in a disposable drum, or contained in any other manner approved in advance by the AQD Director. b. When demolition/renovation operations must take place in the outdoor air, friable asbestos removed in such operations shall be immediately bagged or contained in accordance with (a) above. c. Friable asbestos materials used on pipes or other outdoor structures shall not be allowed to weather or deteriorate and become exposed to, or dispersed in the outside air. d. Friable asbestos materials shall, in addition to other provisions concerning disposal, be disposed of in a facility approved for asbestos by the Solid Waste Management Division of

DEQ.

7. The permittee is authorized to operate the facility continuously (24 hours per day, every day of the year). [OAC 252:100-8-6(a)]


DRAFT

8. The following applies to VOC storage vessels that meet the stated criteria:

52 a. VOC storage vessels constructed after December 28, 1974 greater than 400 gallons in capacity and storing a liquid with a vapor pressure greater than 1.5 psia shall have a permanent submerged fill pipe or a vapor recovery system. VOC storage vessels that are subject to equipment standards (e.g. a fixed roof in combination with an internal floating cover, an external floating roof, or a closed vent system and control device) in 40 CFR 60

Subparts K, Ka or Kb are exempt from this requirement. [OAC 252:100-37-15(b) & (c)] b. VOC storage vessels constructed after December 28, 1974 greater than 40,000 gallons in capacity and storing a liquid with a vapor pressure greater than 1.5 psia shall be pressure vessels or shall be equipped with a vapor-loss control device as specified in OAC 252:100-

37-15(a). VOC storage vessels that are subject to equipment standards (e.g. a fixed roof in combination with an internal floating cover, an external floating roof, or a closed vent system and control device) in 40 CFR 60 Subparts K, Ka or Kb are exempt from this requirement.

[OAC 252:100-37-15(a) & (c)] c. Records of dimension, capacity, VOL stored, period of storage, and maximum true vapor pressure shall be kept for the following types of storage vessels: i. VOL storage vessels constructed, reconstructed, or modified after July 23, 1984 with a capacity of at least 20,000 gallons but less than 40,000 gallons and storing a VOL with a maximum true vapor pressure of at least 2.2 psia. 40 CFR 60.116b(b) & (c)] ii. VOL storage vessels constructed, reconstructed, or modified after July 23, 1984 with a capacity of 40,000 gallons or more and storing a VOL with a maximum true vapor pressure of at least 0.51 psia. [40 CFR 60.116b(b) & (c)]

9. In accordance with the facility-wide exemption provided under 40 CFR Part 63 Subpart DD in 40 CFR 63.680(d), whenever the total annual HAP contained in the off-site material received is less than 1 Mg/year, the permittee shall only be required to maintain records of the initial determination of the amount of off-site HAP received and an updated record whenever the amount of off-site HAP received changes enough to possibly exceed the 1 Mg/year limitation.

Whenever the facility-wide exemption under 40 CFR 63.680(d) does not apply, the permittee shall comply with all applicable standards, including but not limited to, the following:

[40 CFR Part 63 Subpart DD] a. §63.683 Standards: General. b. §63.684 Standards: Off-site material treatment. c. §63.685 Standards: Tanks. d. §63.686 Standards: Oil-water and organic-water separators. e. §63.687 Standards: Surface impoundments.

SPECIFIC CONDITIONS PERMIT NO. 98-104-TV f. §63.688 Standards: Canisters. g. §63.689 Standards: Transfer systems. h. §63.690 Standards: Process Vents. i. §63.691 Standards: Equipment Leaks. j. §63.693 Standards: Closed-vent systems and control devices.

DRAFT

53 k. §63.694 Test methods and procedures. l. §63.695 Inspection and monitoring requirements. m. §63.696 Recordkeeping requirements. n. §63.697 Reporting requirements.

10. In accordance with the exemption provided under 40 CFR Part 63 Subpart GGGGG in 40

CFR 63.7884(b), when remediation material is transferred off-site within 30 days on the initiation of remediation, the permittee shall only be required to maintain records showing the remediation start and final transfer dates and, if the remediation material contains 10 ppmw or more of Subpart GGGGG HAP, records showing compliance with the transfer provisions of 40

CFR 63.7936. When any remediation material cannot be transferred off-site within 30 days of the initiation of remediation, the permittee shall comply with all applicable standards, including but not limited to, the following: [40 CFR Part 63 Subpart GGGGG] a. §63.7884-7887 General standards. b. §63.7890-63.7893 Standards for process vents. c. §63.7895-63.7898 Standards for tanks. d. §63.7900-63.7903 Standards for containers. e. §63.7905-63.7908 Standards for surface impoundments. f. §63.7910-63.7913 Standards for separators. g. §63.7915-63.7918 Standards for transfer systems. h. §63.7920-63.7922 Standards for equipment leaks. i. §63.7925-63.7928 Standards for closed vent systems and control devices.

SPECIFIC CONDITIONS PERMIT NO. 98-104-TV j. §63.7935-63.7938 General compliance requirements. k. §63.7940-63.7944 Performance tests. o. §63.7945-63.7947 Continuous monitoring systems. p. §63.7950-63.7953 Notifications, reports and records. q. §63.7955-63.7957 Other requirements and information.

DRAFT

54

11. 40 CFR Part 60 Subpart A applies to equipment subject to New Source Performance Standards under Part 60. Unless applicable subparts specify otherwise, the permittee shall comply with all applicable requirements of Subpart A, including but not limited to, the following:

[40 CFR Part 60 Subpart A] a. §60.7 Notification and recordkeeping. b. §60.8 Performance tests. c. §60.11 Compliance with standards and maintenance requirements. d. §60.12 Circumvention. e. §60.13 Monitoring requirements. f. §60.14 Modification. g. §60.15 Reconstruction. h. §60.18 General control device requirements. j. §60.19 General notification and reporting requirements.

12. 40 CFR Part 61 Subpart A applies to equipment subject to National Emissions Standards for

Hazardous Air Pollutants under Part 61. Unless applicable subparts specify otherwise, the permittee shall comply with all applicable standards of Subpart A, including but not limited to, the following:

[40 CFR Part 61 Subpart A] a. §61.07 Application for approval of construction or modification. b. §61.09 Notice of startup. c. §61.10 Source reporting and waiver request. d. §61.12 Compliance with standards and maintenance requirements.

SPECIFIC CONDITIONS PERMIT NO. 98-104-TV e. §61.13 Emission tests and waiver of emission tests.

DRAFT

55 f. §61.14 Monitoring requirements. g. §61.15 Modification.

13. 40 CFR Part 63 Subpart A applies to all equipment subject to National Emissions Standards for

Hazardous Air Pollutants under Part 63. Unless specific applicable subparts specify otherwise, the permittee shall comply with all applicable requirements of Subpart A, including but not limited to

[40 CFR Part 63 Subpart A] the following: a. §63.5 Preconstruction review and notification requirements. b. §63.6 Compliance with standards and maintenance requirements. c. §63.7 Performance testing requirements. d. §63.8 Monitoring requirements. e. §63.9 Notification requirements. f. §63.10 Recordkeeping requirements. g. §63.11 Control device requirements.

14. Startup, Shutdown and Malfunction Plans (SSMP). The permittee shall develop an SSMP for all equipment that is subject to National Emissions Standards for Hazardous Air Pollutants under Part 63 in accordance with 40 CFR Part 63 Subpart A and the applicable NESHAP.

[40 CFR 63.6(e)(3)] a. The current SSMP shall be maintained for the life of the facility or until superceded by a new version. b. 40 CFR 63.10 requires immediate notifications to be made when action is taken by the owner or operator during an SSM event that is not consistent with the procedures specified in the

SSMP and the source exceeds the relevant emission standard. However, for equipment subject to 40 CFR Part 63 Subpart CC and Subpart UUU, the owner or operator may instead report such actions in the next periodic report. c. The permittee shall include records of actions taken during SSM events in the periodic reports required by 40 CFR 63.10. d. The permittee shall maintain records of actions taken during all SSM events which demonstrate whether the SSMP was followed.


DRAFT

56

15. The No. 4 CTU/CVU total production rates shall be limited as indicated below.

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

Final or Intermediate Product

Light Straight Run Gasoline

Naphtha

Kerosene

Heavy oil distillate

Total Gas Oil

Production Rate Limit (BPD)

5,380

5,550

6,050

6,200

12,000

(1)

Resid

1. 365-day rolling average.

4,000 a. The permittee shall maintain monthly records of the 365-day rolling average production rates listed above. [OAC 252:100-43]

16. All gases from the No. 1, No. 2, and No. 3 Amine Recovery Units shall be sent to an on-site sulfur recovery unit (SRU) or off-site sulfur recovery facility. [OAC 252:100-8-6(a)]

17. Tanks T-0078E, T-0304, T-0305, and T-0915 shall not be utilized for hydrocarbon or oily wastewater service. [OAC 252:100-8-6(a)]

18. The permittee shall comply with the obligations specified in the Consent Decree resolving

Civil Action No. H-01-4430, until its termination. Upon termination of the Consent Decree resolving Civil Action No. H-01-4430, all obligations, except those specified elsewhere in this permit, will become null and void. [Consent Decree resolving Civil Action No. H-01-4430]

19. The permittee shall comply with the following compliance plans and deadlines:

Milestone of Progress Compliance Deadline

H-8801/8802 and H-9851: Obtain alternative monitoring approval from EPA for the continuous monitoring requirements of 40 CFR

60.105(a)(3) for the PSA off-gas streams combusted by the heaters.

No. 4 FCCU: Obtain alternative SO

2 measurement method approval from EPA

Region VI for determining compliance with

SO

X

emissions in 40 CFR 60.104(b)(2).

No. 5 FCCU/B-5004: Obtain alternative coke burn-off measurement method approval from

EPA Region VI for determining compliance with PM emissions in 40 CFR 60.102(a)(1).

None. Awaiting approval from EPA.





No. 5 FCCU/B-5004: Obtain alternative opacity monitoring approval from EPA Region

VI for determining compliance with opacity requirements specified in 40 CFR Part 60

Subpart J.

DRAFT



57

No. 4FCCU: Obtain alternative opacity monitoring approval from EPA Region VI for determining compliance with opacity requirements specified in 40 CFR Part 60

Subpart J.

T-0177 and T-0178: Replace or retrofit slotted guidepole.


April 13, 2010

Submit Certification of Compliance with

STERPP Agreement to EPA.

No mandatory deadline. Will be submitted upon completion of all obligations under

STERPP Agreement.

20. Each six month period, 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. The initial semiannual report shall be postmarked no later than April 30 th

, and shall cover the reporting period beginning October 1 st

of the preceding year and ending March 31 st

of the current year. The second semiannual report shall be postmarked no later than October 30 th

, and shall cover the reporting period beginning April 1 st

of the current year and ending September 30 th of the current year.

[252:100-8-6(a)(3)(C)(i), (ii), & (iv)]

21. Each calendar year, the permittee shall submit to the AQD, with a copy to the US EPA,

Region 6, a certification of compliance with the terms and conditions of this permit and of any other applicable requirements which have become effective since issuance of this permit. The compliance certification shall also include such other facts as the permitting authority may require inorder to determine the compliance status of the source. The annual compliance report shall be postmarked no later than October 30 th

, and shall cover the annual compliance period beginning October 1 st

of the preceding year and ending September 30 th

of the current year.

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

22. This permit supersedes all previously issued Air Quality permits for this facility which are now null and void, except for Permit No. 2007-042-C PSD.


DRAFT

58

23. The Permit Shield (Standard Conditions, Section VI) is extended to the following requirements that have been determined to be inapplicable to this facility.

[OAC 252:100-8-6(d)(2)] a. OAC 252:100-11 Alternative Emissions Reduction b. OAC 252:100-15 Mobile Sources c. OAC 252:100-17 Incinerators d. OAC 252:100-23 Cotton Gins e. OAC 252:100-24 Grain Elevators f. OAC 252:100-39 Nonattainment Areas g. OAC 252:100-47 Landfills h. 40 CFR Parts 72, 73, 74, 75, and 76 Acid Rain

Ms. Sara L. King

Environmental Engineer

ConocoPhillips Company Ponca City Refinery

1000 S. Pine

Ponca City, OK 74601

SUBJECT: Permit No. 98-104-TV

Ponca City Refinery

Kay County, Oklahoma

Dear Ms. King:

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 that you may have on the draft permit.

Thank you for your cooperation. If you have any questions, please refer to the permit number above and contact me at (405) 702-4200.

Sincerely,

Grover R. Campbell, P.E.

Existing Source Permit Section


Enclosure

PART 70 PERMIT


STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON STREET, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2006-206-TV

ConocoPhillips, having complied with the requirements of the law, is hereby granted permission to operate the Ponca City Refinery located in Ponca City, Kay County, Oklahoma, subject to

Standard Conditions dated December 6, 2006 and Specific Conditions, both attached.

This permit shall expire five (5) years from the date below, except as authorized under

Section VIII of the Standard Conditions.

__________________

Director, Air Quality Division Date

DEQ Form #100-890 Revised 2/14/05

TITLE V (PART 70) PERMIT TO OPERATE / CONSTRUCT

STANDARD CONDITIONS

(December 6, 2006)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with Title V of the federal Clean Air Act (42 U.S.C. 7401, et seq.) and under the authority of the Oklahoma Clean

Air Act and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma

Department of Environmental Quality (DEQ). The permit does not relieve the holder of the obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or ordinances. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement action, for revocation of the approval to operate under the terms of this permit, or for denial of an application to renew this permit. All terms and conditions (excluding state-only requirements) are enforceable by the DEQ, by EPA, and by citizens under section 304 of the Clean Air Act.

This permit is valid for operations only at the specific location listed.

[40 CFR §70.6(b), OAC 252:100-8-1.3 and 8-6 (a)(7)(A) and (b)(1)]

D. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. [OAC 252:100-8-6 (a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from emergency conditions and/or posing an imminent and substantial danger to public health, safety, or the environment shall be reported in accordance with Section XIV. [OAC 252:100-8-6 (a)(3)(C)(iii)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

[OAC 252:100-8-6 (a)(3)(C)(iv)]

C. Oral notifications (fax is also acceptable) shall be made to the AQD central office as soon as the owner or operator of the facility has knowledge of such emissions but no later than 4:30 p.m. the next working day the permittee becomes aware of the exceedance. Within ten (10) working days after the immediate notice is given, the owner operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. Every written report submitted under OAC 252:100-8-6 (a)(3)(C)(iii) shall be certified by a responsible official. [OAC 252:100-8-6 (a)(3)(C)(iii)]

MAJOR SOURCE STANDARD CONDITIONS December 6, 2006 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. Unless a different retention period or retention conditions are set forth by a specific term in this permit, these records, including monitoring data and necessary support information, shall be retained on-site or at a nearby field office for a period of at least five years from the date of the monitoring sample, measurement, report, or application, and shall be made available for inspection by regulatory personnel upon request. Support information includes all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Where appropriate, the permit may specify that records may be maintained in computerized form.

[OAC 252:100-8-6 (a)(3)(B)(ii), 8-6 (c)(1), and 8-6 (c)(2)(B)]

B. Records of required monitoring shall include:

(1) the date, place and time of sampling or measurement;

(2) the date or dates analyses were performed;

(3) the company or entity which performed the analyses;

(4) the analytical techniques or methods used;

(5) the results of such analyses; and

(6) the operating conditions as existing at the time of sampling or measurement.

[OAC 252:100-8-6 (a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the original Part 70 operating permit, the permittee shall submit to AQD a report of the results of any required monitoring. All instances of deviations from permit requirements since the previous report shall be clearly identified in the report. [OAC 252:100-8-6 (a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or operator shall comply with the provisions of Section II of these standard conditions.

[OAC 252:100-8-6 (a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this permit, monitoring and reporting may be required under the provisions of OAC 252:100-43,

Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean

Air Act or Oklahoma Clean Air Act.

F. Submission of quarterly or semi-annual reports required by any applicable requirement that are duplicative of the reporting required in the previous paragraph will satisfy the reporting requirements of the previous paragraph if noted on the submitted report.

G. Every report submitted under OAC 252:100-8-6 and OAC 252:100-43 shall be certified by a responsible official. [OAC 252:100-8-6 (a)(3)(C)(iv)]

H. Any owner or operator subject to the provisions of NSPS shall maintain records of the occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected facility or any malfunction of the air pollution control equipment. [40 CFR 60.7 (b)]


I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all measurements and other information required by the subpart recorded in a permanent file suitable for inspection. This file shall be retained for at least two years following the date of such measurements, maintenance, and records. [40 CFR 60.7 (d)]

J. The permittee of a facility that is operating subject to a schedule of compliance shall submit to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for achieving the activities, milestones or compliance required in the schedule of compliance and the dates when such activities, milestones or compliance was achieved. The progress reports shall also contain an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventative or corrective measures adopted. [OAC 252:100-8-6 (c)(4)]

K. All testing must be conducted by methods approved by the Division Director under the direction of qualified personnel. All tests shall be made and the results calculated in accordance with standard test procedures. The use of alternative test procedures must be approved by EPA.

When a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated in accordance with the manufacturer’s instructions and in accordance with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method approved by Air Quality. [40 CFR §70.6(a), 40 CFR §51.212(c)(2), 40 CFR § 70.7(d), 40 CFR

§70.7(e)(2), OAC 252:100-8-6 (a)(3)(A)(iv), and OAC 252:100-43]

The reporting of total particulate matter emissions as required in Part 70, PSD, OAC 252:100-19, and 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 PM

10

. NSPS may allow reporting of only particulate matter emissions caught in the filter (obtained using Reference Method 5). [US EPA Publication

(September 1994). PM

10

Emission Inventory Requirements - Final Report. Emission Inventory

Branch: RTP, N.C.]; [Federal Register: Volume 55, Number 74, 4/17/90, pp.14246-14249. 40

CFR Part 51: Preparation, Adoption, and Submittal of State Implementation Plans; Methods for

Measurement of PM

10

Emissions from Stationary Sources]; [Letter from Thompson G. Pace,

EPA OAQPS to Sean Fitzsimmons, Iowa DNR, March 31, 1994 (regarding PM

10

Condensables)]

L. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required by 40 CFR Part 60, 61, and 63, for all equipment constructed or operated under this permit subject to such standards. [OAC 252:100-4-5 and OAC 252:100-41-15]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70 operating permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of this permit and of any other applicable requirements which have become effective since the issuance of this permit. The compliance certification shall also include such other facts as the permitting authority may require to determine the compliance status of the source.

[OAC 252:100-8-6 (c)(5)(A), (C)(v), and (D)]


B. The certification shall describe the operating permit term or condition that is the basis of the certification; the current compliance status; whether compliance was continuous or intermittent; the methods used for determining compliance, currently and over the reporting period; and a statement that the facility will continue to comply with all applicable requirements.

[OAC 252:100-8-6 (c)(5)(C)(i)-(iv)]

C. Any document required to be submitted in accordance with this permit shall be certified as being true, accurate, and complete by a responsible official. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the certification are true, accurate, and complete.

[OAC 252:100-8-5 (f) and OAC 252:100-8-6 (c)(1)]

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

[OAC 252:100-8-6 (c)(6)] be certified in the next annual certification.

SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions established for alternate operating scenarios, emissions trading, and emissions averaging, but excluding terms and conditions for which the permit shield is expressly prohibited under OAC

252:100-8) shall be deemed compliance with the applicable requirements identified and included in this permit. [OAC 252:100-8-6 (d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific

Conditions of this permit. Those requirements that the applicant requested be determined as not applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6 (d)(2)]


SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees based on emissions inventories. The methods used to calculate emissions for inventory purposes shall be based on the best available information accepted by AQD.

[OAC 252:100-5-2.1, -5-2.2, and OAC 252:100-8-6 (a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date of issuance. [OAC 252:100-8-6 (a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely and complete renewal application has been submitted at least 180 days before the date of expiration. [OAC 252:100-8-7.1 (d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction is not commenced within 18 months after the date the permit or authorization was issued, or if work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

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

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege.

[OAC 252:100-8-6 (a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon which the equipment is located and does not release the permittee from any liability for damage to persons or property caused by or resulting from the maintenance or operation of the equipment for which the permit is issued. [OAC 252:100-8-6 (c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty

(60) days of the request unless the DEQ specifies another time period, any information that the


DEQ may request to determine whether cause exists for modifying, reopening, revoking, reissuing, terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the DEQ copies of records required to be kept by the permit.

[OAC 252:100-8-6 (a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted pursuant to 27A O.S. 2-5-105(18). Confidential information shall be clearly labeled as such and shall be separable from the main body of the document such as in an attachment.

[OAC 252:100-8-6 (a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and shall be made in writing within 10 days after such date.

[Oklahoma Clean Air Act, 27A O.S. § 2-5-112 (G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause.

Except as provided for minor permit modifications, the filing of a request by the permittee for a permit modification, revocation, reissuance, termination, notification of planned changes, or anticipated noncompliance does not stay any permit condition.

[OAC 252:100-8-6 (a)(7)(C) and OAC 252:100-8-7.2 (b)]

B. The DEQ will reopen and revise or revoke this permit as necessary to remedy deficiencies in the following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source category three or more years prior to the expiration date of this permit. No such reopening is required if the effective date of the requirement is later than the expiration date of this permit.

(2) The DEQ or the EPA determines that this permit contains a material mistake or that the permit must be revised or revoked to assure compliance with the applicable requirements.

(3) The DEQ or the EPA determines that inaccurate information was used in establishing the emission standards, limitations, or other conditions of this permit. The DEQ may revoke and not reissue this permit if it determines that the permittee has submitted false or misleading information to the DEQ.

C. If “grandfathered” status is claimed and granted for any equipment covered by this permit, it shall only apply under the following circumstances: [OAC 252:100-5-1.1]

(1) It only applies to that specific item by serial number or some other permanent identification.

(2) Grandfathered status is lost if the item is significantly modified or if it is relocated outside the boundaries of the facility.


D. To make changes other than (1) those described in Section XVIII (Operational Flexibility),

(2) administrative permit amendments, and (3) those not defined as an Insignificant Activity

(Section XVI) or Trivial Activity (Section XVII), the permittee shall notify AQD. Such changes may require a permit modification. [OAC 252:100-8-7.2 (b)]

E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that are not specifically approved by this permit are prohibited. [OAC 252:100-8-6 (c)(6)]

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):

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

(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.

SECTION XIV. EMERGENCIES

A. Any emergency and/or exceedance that poses an imminent and substantial danger to public health, safety, or the environment shall be reported to AQD as soon as is practicable; but under no circumstance shall notification be more than 24 hours after the exceedance.

[OAC 252:100-8-6 (a)(3)(C)(iii)(II)]

B. An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under this permit, due to unavoidable increases in emissions attributable to the emergency. [OAC 252:100-8-2]

C. An emergency shall constitute an affirmative defense to an action brought for noncompliance with such technology-based emission limitation if the conditions of paragraph D below are met.

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


D. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs or other relevant evidence that:

[OAC 252:100-8-6 (e)(2), (a)(3)(C)(iii)(I) and (IV)]

(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;

(4) the permittee submitted timely notice of the emergency to AQD, pursuant to the applicable regulations (i.e., for emergencies that pose an “imminent and substantial danger,” within 24 hours of the time when emission limitations were exceeded due to the emergency; 4:30 p.m. the next business day for all other emergency exceedances). See

OAC 252:100-8-6(a)(3)(C)(iii)(I) and (II).

This notice shall contain a description of the emergency, the probable cause of the exceedance, any steps taken to mitigate emissions, and corrective actions taken; and

(5) the permittee submitted a follow up written report within 10 working days of first becoming aware of the exceedance.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency shall have the burden of proof. [OAC 252:100-8-6 (e)(3)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop and register with the appropriate agency a risk management plan by June 20, 1999, or the applicable effective date. [OAC 252:100-8-6 (a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate individual emissions units that are either on the list in Appendix I to OAC Title 252,

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.

Any activity to which a State or federal applicable requirement applies is not insignificant even if it meets the criteria below or is included on the insignificant activities list. [OAC 252:100-8-2]

(1) 5 tons per year of any one criteria pollutant.

(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year for single HAP that the EPA may establish by rule.


SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate any individual or combination of air emissions units that are considered inconsequential and are on the list in Appendix J. Any activity to which a State or federal applicable requirement applies is not trivial even if included on the trivial activities list. [OAC 252:100-8-2]

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 7 days, or 24 hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such change, the written notification required above shall include a brief description of the change within the permitted facility, the date on which the change will occur, any change in emissions, and any permit term or condition that is no longer applicable as a result of the change. The permit shield provided by this permit does not apply to any change made pursuant to this subsection. [OAC 252:100-8-6 (f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility unless elsewhere covered by a more restrictive requirement:

(1) No person shall cause or permit the discharge of emissions such that National Ambient

Air Quality Standards (NAAQS) are exceeded on land outside the permitted facility.

[OAC 252:100-3]

(2) Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-13]

(3) No particulate emissions from any fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(4) For all emissions units not subject to an opacity limit promulgated under 40 CFR, Part 60,

NSPS, no discharge of greater than 20% opacity is allowed except for short-term

MAJOR SOURCE STANDARD CONDITIONS December 6, 2006 10 occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. [OAC 252:100-25]

(5) No visible fugitive dust emissions shall be discharged beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. [OAC 252:100-29]

(6) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2 lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur dioxide. [OAC 252:100-31]

(7) Volatile Organic Compound (VOC) storage tanks built after December28, 1974, and with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or greater under actual conditions shall be equipped with a permanent submerged fill pipe or with a vapor-recovery system. [OAC 252:100-37-15(b)]

(8) All fuel-burning equipment shall at all times be properly operated and maintained in a manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A.The permittee shall comply with the following standards for production and consumption of ozone-depleting substances. [40 CFR 82, Subpart A]

1. Persons producing, importing, or placing an order for production or importation of certain class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the requirements of §82.4.

2. Producers, importers, exporters, purchasers, and persons who transform or destroy certain class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping requirements at §82.13.

3. Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,

HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane

(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions reduction except as provided for MVACs in Subpart B. [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply

MAJOR SOURCE STANDARD CONDITIONS December 6, 2006 11 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.

(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 Sources’ Title V permit without causing redundant review. Requirements from construction permits may be incorporated into the Title V permit through the administrative amendment process set forth in Oklahoma Administrative

Code 252:100-8-7.2(a) only if the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the procedures set forth in 40 Code of Federal Regulations (CFR) § 70.7 (h)(1). This public notice shall include notice to the public that this permit is subject to

Environmental Protection Agency (EPA) review, EPA objection, and petition to EPA, as provided by 40 CFR § 70.8; that the requirements of the construction permit will be incorporated into the Title V permit through the administrative amendment process; that the public will not receive another opportunity to provide comments when the requirements are incorporated into the Title V permit; and that EPA review, EPA objection, and petitions to EPA will not be available to the public when requirements from the construction permit are incorporated into the Title V permit.

(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR §

70.8(a)(1).

(3) A copy of the draft construction permit is sent to any affected State, as provided by 40

CFR § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period as provided by 40 CFR § 70.8(a) and (c).

(5) The DEQ complies with 40 CFR § 70.8 (c) upon the written receipt within the 45-day comment period of any EPA objection to the construction permit. The DEQ shall not issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 CFR § 70.8 (d).

(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8 (a).


(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these permit conditions.

(9) Any requirements of the construction permit may be reopened for cause after

(10) incorporation into the Title V permit by the administrative amendment process, by DEQ as provided in OAC 252:100-8-7.3 (a), (b), and (c), and by EPA as provided in 40 CFR

§ 70.7 (f) and (g).

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]

section i. introduction - the Oklahoma Department of Environmental

PART 70 PERMIT

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