DRAFT
OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY
AIR QUALITY DIVISION
MEMORANDUM
July 10, 2007
TO:
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:
Grover Campbell, P.E., Existing Source Permits Section
THROUGH:
Phil Martin, P.E., New Source Permits Section
THROUGH:
Peer Review
FROM:
Eric L. Milligan, P.E., Engineering Section
SUBJECT:
Evaluation of Permit Application No. 2005-100-TVR
Whiting Oil and Gas Corporation
Dry Trail Gas Plant (SIC 1321)
NE/4 of Section 14, T5N, R13E, Texas County
Latitude: 36.9067°; Longitude: -101.6166°
Directions: From Main Street (US Highway 64) and US Highway 54 in
Guymon, OK, travel north on US Highway 64 approximately 5.2 miles to
the junction of US Highway 64 and State Highway 136, then travel north on
State Highway 136 approximately 7.8 miles to County Highway 7, then
travel west 5 miles to County Road N0800, then travel 3 miles north to
County Road E0070, then travel west approximately 2 miles to the facility.
SECTION I. INTRODUCTION
Whiting Oil and Gas Corporation (Whiting) has submitted an application for renewal of the
current Title V operating permit for the Dry Trail Gas Plant, Permit No. 97-462-TV. Emission
units (EUs) are arranged into Emission Unit Groups (EUGs) in the “Equipment” section.
Pipeline-grade natural gas is the primary fuel with the engines being operated continuously.
Requirements from Consent Order No. 06-139 have been incorporated into this permit.
PERMIT MEMORANDUM NO. 2005-100-TVR
DRAFT
Page 2
SECTION II. PROCESS DESCRIPTION
The facility operates as a carbon dioxide separation and natural gas processing facility. The
facility is designed to recover carbon dioxide (CO2) and natural gas liquids from a 45.0
MMSCFD low sulfur gas stream associated with the enhanced oil recovery activities. The plant
uses a proprietary process technology known as Ryan-Holmes patented by Process Systems
International. The recovered CO2 is delivered back to the production field for re-injection into
the oil producing formation (reservoir). Plant residue gas is used for fuel with the remaining
balance being delivered to a low-pressure pipeline system.
The Ryan-Holmes process utilizes five compressors driven by Superior 2416G engines and one
electric compressor: two for inlet gas compression and four for propane compression. Two Solar
Saturn T-1,300 turbine generator sets provide on-site generation of electrical power. The
Katolite 8163-7405 diesel engine powered generator set is used for standby power generation.
Feed gas enters the plant through a microprocessor controlled metering facility then flows to the
inlet gas filter/separator and subsequently flows to the tri-ethylene glycol (TEG) dehydration
plant contactor. Lean TEG absorbs moisture from the natural gas stream. Rich, moisture laden
TEG, is regenerated using heat supplied by the hot oil heater. Emissions from the dehydration
unit’s still vent and flash tank are routed to a vapor recovery unit (VRU) and then to the facility
inlet. Dry natural gas then flows to the inlet compressors. The hot compressed inlet gas is then
routed to the discharge header and then to the inlet compressor discharge cooler. Cooled gas is
then sent to the propane recovery column (PRC). The PRC marks the beginning of the RyanHolmes CO2 purification unit.
The Ryan-Holmes process consists of three vessels; the PRC, a de-methanizer, and the gas/gas
exchanger. The PRC is a trayed column with inlet gas being introduced in the middle section of
the column. The tower is provided with a partial condenser using propane refrigerant. The
mixed overhead is then sent to the PRC reflux accumulator where liquids and gas are separated.
The vapor from the accumulator is a crude CO2 product that is split into two streams. One
stream is compressed and combined with the liquid CO2 product from the CO2 pipeline pumps.
The second stream is compressed by the de-methanizer. The liquid from the PRC reflux
accumulator is split into two process streams. One stream is used to reflux the PRC and the
other is sent to the CO2 pipeline pumps. Fuel gas for the plant is drawn from the de-methanizer
overhead. The bottom product from the PRC is a heavy product composed mostly of C5+
components that is used as an additive for hydrocarbon removal in the process. This product is
discharged from the PRC to the gas/gas exchanger. The PRC also produces natural gas liquids
(NGL). The NGL are withdrawn from the middle of the PRC. The NGL are cooled to 120 °F
and combined with any excess additive and sent to the NGL product storage tank.
The propane refrigeration system provides low temperature levels necessary in the process.
Propane vapor is compressed by the refrigerant compressors and combined with propane
refrigerant vapors from the refrigerant economizer overhead and then sent to second stage
compression and finally to the refrigerant condenser. After condensation, the propane is
accumulated in the refrigerant surge tank. Liquid propane flows from the surge tank to either the
DRAFT
PERMIT MEMORANDUM NO. 2005-100-TVR
Page 3
PRC condenser or the gas/gas exchanger. Propane vapors from the PRC condenser or the
gas/gas exchanger are sent back to the refrigeration compressors.
The hot oil system for the plant is a closed loop system. Oil is drawn from the heat medium
surge tank and pumped to the waste heat recovery units. Oil exiting the waste heat recovery
units enter the hot oil heater heat exchanger and is heated to 450 °F and is subsequently delivered
to the dehydration plant and the PRC.
The existing flare was historically used by Williams Field Services to control the inlet/propane
compressor blowdowns; flare high CO2 low BTU inlet gas; flare de-methanizer blowdowns and
flare dehydration plant still vent/flash tank emissions. The flare is subject to NSPS. The flare
will also meet the requirements of NESHAP, Subpart HH.
SECTION III. EQUIPMENT
EUG-1
Flare
EU
Point
Description
1
1
Flare
EUG-2
EU
1
2
Flow (MMSCF/yr)
1,209
Construction Date
1996
Rating
(KW)
950
950
Turbine
Serial #
15245
30200
Turbines
Point
2
3
Description
Solar Saturn T-1300
Solar Saturn T-1300
EUG-3
Hot Oil Heater
EU
Point
Description
1
4
Hot Oil Heater
MMBTUH
13.48
EUG-4
Emergency Generator
EU
Point
Description
1
5
Katolight Generator w/
Detroit Diesel Engine
EUG-5
Compressor Engines
EU
Point
Description
1
6
Superior 2416G
2
7
Superior 2416G
3
8
Superior 2416G
4
9
Superior 2416G
6
11
Superior 2416G
1
Generator
Serial #
SE82363
S431040
Construction Date
1996
Rating (KW)
817
Horsepower
3,200
3,200
2,8001
2,8001
2,8001
Construction
Date
1996
1996
Serial #
330409
332469
332479
332489
334649
Construction Date
1996
Construction Date
1996
1996
1996
1996
1999
- The engines’ horsepower is inherently limited by the compressor’s maximum mechanical rpm limitation.
PERMIT MEMORANDUM NO. 2005-100-TVR
EUG-6
Fugitives
EU
Point Type of Equipment
1
24
Valves
Connectors
Flanges
Pump Seals
Other1
1
DRAFT
Type of Service
Gas/Vapor
Light Liquid
Heavy Liquid
Gas/Vapor
Light Liquid
Heavy Liquid
Gas/Vapor
Light Liquid
Heavy Liquid
Light Liquid
Heavy Liquid
Gas/Vapor
Light Liquid
Heavy Liquid
Page 4
Number Items
1,592
837
186
6,368
3,348
744
1,592
837
186
9
6
83
0
0
Others include compressor seals, pressure relief valves, relief valves, diaphragms, drains, dump
arms, hatches, instruments, meters, polished rods, and vents.
EUG-7
Storage Tanks
EU
Point
Description
1
12
Process Drain Sump Tank
2
14
Diesel Tank
3
15
Lube Oil Tank
4
16
Ambitrol Tank
5
17
TEG Tank
6
18
Slop Oil Tank
7
30
Lube Oil (Day) Tank
8
13
Methanol
9
19
Methanol
10
20
Gasoline
11
21
Synthetic Lube Oil
Size (Gal.)
1,000
4,200
8,820
8,814
4,200
19,740
1,000
500
500
500
500
Construction Date
1996
1996
1996
1996
1996
1996
1996
1998
2004
1997
1998
EUG-8
Facility Wide
This emission unit group is facility-wide. It includes all emission units and is established to
discuss the applicability of those rules or compliance demonstrations, which may affect all
sources within the facility.
EUG-10
Dehydration Unit
EU
Point
Description
1
N/A
TEG Dehydration Unit Still Vent/Flash Tank1
1
Vented to a vapor recovery unit and then to the facility inlet.
Construction Date
1996
DRAFT
PERMIT MEMORANDUM NO. 2005-100-TVR
EUG-11
Blowdowns
EU
Point
Description
1
21
Inlet Compressor Blowdowns
Construction Date
1996
EUG-12
Loading Emissions
EU
Point
Description
1
26
Condensate/Produced Water
Construction Date
1996
EUG-13
Condensate Tank Emissions
EU
Point
Description
1
18
Condensate Tank Emissions
Construction Date
1996
Point
2
3
5
6
7
8
9
11
1
Source
(make/model)
Solar Saturn T-1300
Solar Saturn T-1300
Katolight Generator
Superior 2416G W/OC
Superior 2416G W/OC
Superior 2416G W/OC
Superior 2416G W/OC
Superior 2416G W/OC
Page 5
Engine Parameters
Height Diameter
(feet)
(inches)
40
54
40
54
30
12
45
24
45
24
45
24
45
24
45
24
Flow
(ACFM)
19,442
19,442
6,460
18,164
18,164
15,894
15,894
15,894
Temp.
(°F)
465
465
825
728
728
728
728
728
Fuel1
(SCFH)
12,900
12,900
572
23,896
23,896
20,909
20,909
20,909
- Based on a fuel heat rating of 924 BTU/SCF; 2 - gallons per hour; W/OC - with oxidation catalyst.
SECTION IV. EMISSIONS
Emissions estimates for the engines are based on continuous operation and manufacturer’s
emission data shown below. Formaldehyde emission estimates are reduced by 75% to estimate
reductions due to the use of oxidation catalyst. Emission estimates of NOX, CO, and VOC from
the hot oil heater are based on manufacturer’s data (NOX: 0.08 lb/MMBTU, CO: 0.04
lb/MMBTU, and VOC: 0.015 lb/MMBTU), the heat rating, and a fuel heat content of 924
BTU/SCF. Emissions from the emergency diesel generator are based on 960 hours of operation
a year, the emission factors shown below, a fuel heat content of 137 MBTU/gal, and a fuel sulfur
content of 0.5% by weight. Emissions from the flare are based on an estimated combustion
efficiency of 98%, AP-42 (1/95), Chapter 13.5 emissions factors, and combustion of 16.85
MMSCFY of pilot, purge, and residue gas with a heating value of 1,056 BTU/SCF, and 0.33
MMSCFY of propane with a heating value of 2,315 BTU/SCF. Flashing emissions from the
condensate tanks were estimated using the Vasquez-Beggs equation and a slop oil (water + oil)
throughput of 9,400 barrels per year (70% H2O). Emissions from the other tanks are considered
insignificant and have not been quantified. Emissions from loading of condensate into tank
trucks were estimated using a throughput of 9,400 barrels per year of slop oil and an emission
factor of 4.96 lb/1,000 gallons. Fugitive VOC emissions are based on EPA’s 1995 Protocol for
DRAFT
PERMIT MEMORANDUM NO. 2005-100-TVR
Page 6
Equipment Leak Emission Estimates (EPA-453/R-95-017). There are no emissions from the
glycol dehydration unit since it is vented to a VRU. Blowdown emissions are based on 144
blowdowns, 8 MSCF per blowdown, a molecular weight of 41.81 lb/lb-mole, and approximately
3.8% VOC.
Engine Emission Factors
Points
2&3
5
6&7
8, 9, & 11
Name/Model
1,151-hp Solar Saturn T-1300
1,096-hp Katolight Generator
3,200-hp Superior 2416G W/OC
2,800-hp Superior 2416G W/OC
Superior 2416G W/O Controls
NOX
CO
VOC
(g/hp-hr) (g/hp-hr) (g/hp-hr)
2.30
2.60
0.05
10.78
3.42
0.28
1.0
0.27
0.50
1.0
0.27
0.50
1.0
2.10
0.50
W/OC - with oxidation catalyst; W/O – Without.
Facility-Wide Criteria Pollutant Emissions
NOX
CO
VOC
Point
lb/hr
TPY
lb/hr
TPY
lb/hr
TPY
1A
--0.63
--3.43
--1.30
2
5.83
25.55
6.60
28.89
0.13
0.56
3
5.83
25.55
6.60
28.89
0.13
0.56
4
1.08
4.72
0.54
2.39
0.20
0.89
5
26.04
12.50
8.26
3.97
0.68
0.32
6
7.05
30.90
1.90
8.34
3.53
15.45
7
7.05
30.90
1.90
8.34
3.53
15.45
8
6.17
27.04
1.67
7.31
3.09
13.52
9
6.17
27.04
1.67
7.31
3.09
13.52
11
6.17
27.04
1.67
7.31
3.09
13.52
18 Tank
----------30.96
21 Blowdowns ----------2.41
24 Fugitives
----------56.99
26 Loading
----------0.98
lb/hr
--0.74
0.74
0.83
4.01
1.36
1.36
1.19
1.19
1.19
---------
TPY
0.53
3.22
3.22
3.64
1.93
5.97
5.97
5.22
5.22
5.22
---------
Totals
12.61
40.14
1
71.23
211.09
30.59
105.30
17.45
166.43
SO21
- Based on a fuel sulfur content of 343 ppmv (57 lb SO2/MMSCF) except for the diesel engine which is based on
fuel sulfur content of 0.5 %S.
PERMIT MEMORANDUM NO. 2005-100-TVR
EU
2
3
5
6
7
8
9
11
DRAFT
Page 7
Formaldehyde Emissions from the Engines
Factor
Source
MMBTUH lb/MMBTU
1,151-hp Solar Saturn T-1300
13.62
0.00071
1,151-hp Solar Saturn T-1300
13.62
0.00071
1,096-hp Katolight Generator
7.81
0.00118
3,200-hp Superior 2416G W/OC
22.08
0.01329
3,200-hp Superior 2416G W/OC
22.08
0.01329
2,800-hp Superior 2416G W/OC
19.32
0.01329
2,800-hp Superior 2416G W/OC
19.32
0.01329
2,800-hp Superior 2416G W/OC
19.32
0.01329
Est. Emissions
lb/hr
TPY
0.013
0.056
0.013
0.056
0.009
0.004
0.293
1.285
0.293
1.285
0.257
1.125
0.257
1.125
0.257
1.125
Totals
1.392
6.061
W/OC - with oxidation catalyst
SECTION V. INSIGNIFICANT ACTIVITIES
The insignificant activities identified and justified in the application are duplicated below.
Records are available to confirm the insignificance of the activities. Appropriate recordkeeping
of activities indicated below with “*” is specified in the Specific Conditions.
1.
Space heaters, boilers, process heaters, and emergency flares less than or equal to 5
MMBTUH heat input (commercial natural gas). The glycol dehydration unit’s reboiler is
rated less than 5 MMBTUH. Other space heaters, boilers, process heaters, and emergency
flares may be used in the future.
2.
* 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. None identified but may be used in the future.
3.
Emissions from crude oil or condensate marine and truck loading equipment operations at
crude oil and natural gas production sites where the loading rate does not exceed 10,000
gallons per day averaged over a 30-day period. Unloading of the condensate into tank
trucks is less than 10,000 gallons/day.
4.
* Emissions from crude oil and condensate storage tanks with a capacity of less than or
equal to 420,000 gallons that store crude oil and condensate prior to custody transfer as
defined by Subpart Kb. The condensate tank stores condensate prior to custody transfer and
has a capacity less than 420,000 gallons.
5.
* 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. The
amine, glycol, lube oil, and antifreeze tanks have capacities less than 39,894 gallons and
store products having a vapor pressure less than 1.5 psia.
PERMIT MEMORANDUM NO. 2005-100-TVR
DRAFT
Page 8
6.
Cold degreasing operations utilizing solvents that are denser than air. A parts washer is
located onsite and it uses solvents that are denser than air and others may be used in the
future.
7.
* Activities that have the potential to emit no more than 5 TPY (actual) of any criteria
pollutant. No activities were identified at this time but may be in the future.
SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES
OAC 252:100-1 (General Provisions)
Subchapter 1 includes definitions but there are no regulatory requirements.
[Applicable]
OAC 252:100-3 (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.
OAC 252:100-4 (New Source Performance Standards) [Subparts KKK and LLL are Applicable]
Federal regulations in 40 CFR Part 60 are incorporated by reference as they existed on
September 1, 2005, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16),
Subpart B, Subpart C, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, Subpart
BBBB, Subpart DDDD, Subpart HHHH, and Appendix G. NSPS requirements are addressed in
the “Federal Regulations” section.
OAC 252:100-5 (Registration of Air Contaminant Sources)
[Applicable]
Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission
inventories annually, and pay annual operating fees based upon total annual emissions of
regulated pollutants. Emission inventories have been submitted and fees paid for the past years.
OAC 252:100-8 (Permits for Part 70 Sources)
[Applicable]
Part 5 includes the general administrative requirements for part 70 permits. Any planned
changes in the operation of the facility which result in emissions not authorized in the permit and
which exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior
notification to AQD and may require a permit modification. Insignificant activities mean
individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual
calendar year emissions do not exceed the following limits:


5 TPY of any one criteria pollutant
2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20%
of any threshold less than 10 TPY for a HAP that the EPA may establish by rule
Emission limits have been established based on Permit No. 97-462-TV and information in the
permit application.
PERMIT MEMORANDUM NO. 2005-100-TVR
DRAFT
Page 9
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. 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.
OAC 252:100-13 (Open Burning)
[Applicable]
Open burning of refuse and other combustible material is prohibited except as authorized in the
specific examples and under the conditions listed in this subchapter.
OAC 252:100-19 (Particulate Matter)
[Applicable]
This subchapter specifies a particulate matter (PM) emissions limitation of 0.6 lb/MMBTU from
fuel-burning equipment with a rated heat input of 10 MMBTUH or less. For external
combustion units burning natural gas, AP-42, Table 1.4-2 (7/98), lists the total PM emissions for
natural gas to be 7.6 lb/MMft3 or about 0.0076 lb/MMBTU. For 4-cycle rich-burn and lean-burn
engines burning natural gas, AP-42 (7/00), lists the total PM emissions as less than 0.02
lb/MMBTU. The permit requires the use of natural gas for all fuel-burning equipment to ensure
compliance with Subchapter 19.
This subchapter also limits emissions of particulate matter from industrial processes and directfired fuel-burning equipment based on their process weight rates. Since there are no significant
particulate emissions from the non fuel-burning processes at the facility compliance with the
standard is assured without any special monitoring provisions.
OAC 252:100-25 (Visible Emissions and Particulate Matter)
[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. When burning natural gas there is little possibility of exceeding the
opacity standards.
OAC 252:100-29 (Fugitive Dust)
[Applicable]
No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the
property line on which the emissions originate in such a manner as to damage or to interfere with
the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the
maintenance of air quality standards. Under normal operating conditions, this facility will not
cause a problem in this area, therefore it is not necessary to require specific precautions to be
taken.
PERMIT MEMORANDUM NO. 2005-100-TVR
DRAFT
Page 10
OAC 252:100-31 (Sulfur Compounds)
[Applicable]
Part 2 limits the ambient air impact of sulfur dioxide (SO2) emissions from any one existing
source or any one new petroleum and natural gas process source subject to OAC 252:100-3126(a)(1). This part also limits the impact of hydrogen sulfide (H2S) emissions from any new or
existing source. A typical engine burning field gas with a sulfur content of 343 ppm will
produce a maximum ambient air concentration of less than 22 g/m3, which is in compliance.
Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1,
1972). For gaseous fuels the limit is 0.2 lb/MMBTU heat input averaged over 3 hours. For fuel
gas having a gross calorific value of 1,000 BTU/SCF, this limit corresponds to fuel sulfur
content of 1,203 ppmv. The permit requires the use of gaseous fuel with sulfur content less than
343 ppmv to ensure compliance with Subchapter 31.
Part 5 requires removal or oxidation of hydrogen sulfide (H2S) from the exhaust gas of any new
petroleum or natural gas process equipment. This part allows direct oxidation of H2S to sulfur
dioxide (SO2), without sulfur recovery, when the exhaust gas will contain no more than 100
lbs/hr SO2 (2-hour average). Compliance with the 100 lb/hr can be demonstrated by establishing
that the acid gas stream contains 0.54 long tons per day (LTD) of sulfur (S) or less. Oxidation of
the H2S must be conducted in a system that assures at least a 95% reduction of the H2S in the
exhaust gases and that is equipped with an alarm system to signal non-combustion of the exhaust
gases. These requirements do not apply if H2S emissions do not exceed 0.3 lb/hr. There are no
emissions of H2S from the sweetening unit since all of the acid gas is re-injected.
OAC 252:100-33 (Nitrogen Oxides)
[Not Applicable]
This subchapter limits NOX emissions from new fuel-burning equipment with rated heat input
greater than or equal to 50 MMBTUH. None of the engines exceed the 50 MMBTUH threshold.
OAC 252:100-35 (Carbon Monoxide)
[Not Applicable]
None of the following affected processes are located at this facility: gray iron cupola, blast
furnace, basic oxygen furnace, petroleum catalytic cracking unit, or petroleum catalytic
reforming unit.
OAC 252:100-37 (Volatile Organic Compounds)
[Applicable]
Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons
or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a
permanent submerged fill pipe or with an organic vapor recovery system. The condensate tank is
subject to this requirement.
Part 3 requires VOC loading facilities with a throughput equal to or less than 40,000 gallons per
day to be equipped with a system for submerged filling of tank trucks or trailers if the capacity of
the vehicle is greater than 200 gallons. This facility will not be equipped with the physical
equipment (loading arm and pump) to conduct this type of loading and is not subject to this
requirement.
Part 5 limits the VOC content of coatings from any coating line or other coating operation. This
facility does not normally conduct coating or painting operations except for routine maintenance
of the facility and equipment, which is exempt.
PERMIT MEMORANDUM NO. 2005-100-TVR
DRAFT
Page 11
Part 7 requires fuel-burning and refuse-burning equipment to be operated and maintained so as to
minimize VOC emissions. Temperature and available air must be sufficient to provide
essentially complete combustion.
Part 7 requires all effluent water separators openings or floating roofs to be sealed or equipped
with an organic vapor recovery system. There are no effluent water separators located at this
facility.
Part 7 also requires all reciprocating pumps and compressors handling VOCs to be equipped with
packing glands that are properly installed and maintained in good working order and rotating
pumps and compressors handling VOCs to be equipped with mechanical seals. Equipment
subject to NSPS, Subpart KKK is not subject to this rule. The equipment at this facility is either
subject to NSPS, Subpart KKK or to this rule.
OAC 252:100-41 (Hazardous Air Pollutants)
[Applicable]
Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted
by reference as they exist on September 1, 2005, with the exception of Subparts B, H, I, K, Q, R,
T, W and Appendices D and E, all of which address radionuclides. In addition, General
Provisions as found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control
Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, L, M, N, O, Q,
R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS,
TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO,
PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, DDDD, EEEE, FFFF, GGGG,
HHHH, IIII, JJJJ, KKKK, MMMM, NNNN, OOOO, PPPP, QQQQ, RRRR, SSSS, TTTT,
UUUU, VVVV, WWWW, XXXX, YYYY, ZZZZ, AAAAA, BBBBB, CCCCC, EEEEE,
FFFFF, GGGGG, HHHHH, IIIII, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP,
QQQQQ, RRRRR, SSSSS and TTTTT are hereby adopted by reference as they exist on
September 1, 2005. These standards apply to both existing and new sources of HAP. These
requirements are covered in the “Federal Regulations” section.
Part 5 was a state-only requirement governing sources of toxic air contaminants that have
emissions exceeding a de minimis level. However, Part 5 of Subchapter 41 has been superseded
by OAC 252:100-42, effective June 15, 2006.
OAC 252:100-42 (Toxic Air Contaminants (TAC))
[Applicable]
Part 5 of OAC 252:100-41 was superceded by this subchapter. 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 Area of
Concern (AOC) has been designated anywhere in the state, there are no specific requirements for
this facility at this time.
OAC 252:100-43 (Testing, Monitoring, and Recordkeeping)
[Applicable]
This subchapter provides general requirements for testing, monitoring and recordkeeping and
applies to any testing, monitoring or recordkeeping activity conducted at any stationary source.
To determine compliance with emissions limitations or standards, the Air Quality Director may
require the owner or operator of any source in the state of Oklahoma to install, maintain and
operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant
source. All required testing must be conducted by methods approved by the Air Quality Director
PERMIT MEMORANDUM NO. 2005-100-TVR
DRAFT
Page 12
and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol
shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests.
Emissions and other data required to demonstrate compliance with any federal or state emission
limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained,
and submitted as required by this subchapter, an applicable rule, or permit requirement. Data
from any required testing or monitoring not conducted in accordance with the provisions of this
subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive
use, of any credible evidence or information relevant to whether a source would have been in
compliance with applicable requirements if the appropriate performance or compliance test or
procedure had been performed.
The following Oklahoma Air Pollution Control Rules are not applicable to this facility:
OAC 252:100-11 Alternative Emissions Reduction
Not requested
OAC 252:100-15 Mobile Sources
Not in source category
OAC 252:100-17 Incinerators
Not type of emission unit
OAC 252:100-23 Cotton Gins
Not type of emission unit
OAC 252:100-24 Grain Elevators
Not in source category
OAC 252:100-39 Nonattainment Areas
Not in area category
OAC 252:100-47 Municipal Solid Waste Landfills
Not in source category
SECTION VII. FEDERAL REGULATIONS
PSD, 40 CFR Part 52
[Not Applicable]
Final total emissions are less than the threshold of 250 TPY of any single regulated pollutant and
the facility is not one of the 26 specific industries with a threshold of 100 TPY.
NSPS, 40 CFR Part 60
[Subparts A, GG, and KKK are Applicable]
Subpart A, General Requirements. The flare is subject to the requirements of 60.18.
Subpart Dc, Industrial-Commercial-Institutional Steam Generating Units. This subpart affects
industrial-commercial-institutional steam generating units with a design capacity between 10 and
100 MMBTUH heat input and which commenced construction or modification after June 9,
1989. The hot oil heater is subject to the recordkeeping requirements of this subpart.
Subpart K, Ka, Kb, VOL Storage Vessels. The 19,740-gallon condensate tank is not subject
because it is below the threshold level of Subpart Kb of 19,813-gallons and it stores condensate
prior to custody transfer as defined by Subpart Kb. The condensate is produced prior to
processing by the plant.
Subpart GG, Stationary Gas Turbines. This subpart affects all stationary gas turbines which
commenced construction, reconstruction, or modification after October 3, 1977, with heat input
at peak load of greater than or equal to 10 MMBTUH based on the lower heating value of the
fuel. The two turbines each have a heat input capacity at peak load of 17.5 MMBTUH and are
subject to this subpart. NOX emissions are limited to 150 ppmdv @ 15% O2 per § 60.332(a)(2)
and either the SO2 emissions are limited to 150 ppmdv @ 15% O2 per § 60.333(a) or the fuel
sulfur content is limited to 8,000 ppmw S per § 60.333(b). Monitoring of the sulfur and nitrogen
content of the turbine fuel and reporting of excess emissions is required pursuant to § 60.334.
Monitoring of fuel nitrogen content shall not be required as long as the owner or operator does not
PERMIT MEMORANDUM NO. 2005-100-TVR
DRAFT
Page 13
claim an allowance for fuel bound nitrogen. Monitoring of the fuel total sulfur content shall not be
required as long as the gaseous fuel meets the definition of natural gas in § 60.331(u) (20.0 gr
S/100 SCF @ 20C & 70% Methane by Volume or GCV between 950-1100 BTU/SCF).
Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing
Industry. The equipment is not in a SOCMI plant but the facility is applicable to Subpart KKK
which references some of the standards of Subpart VV.
Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. This
subpart applies to natural gas processing plants that commence construction, reconstruction, or
modification after January 20, 1984. The natural gas processing plant is subject to this subpart.
The permit will require all affected units to comply with all applicable requirements.
Subpart LLL, Onshore Natural Gas Processing: SO2 Emissions. This subpart affects sweetening
units and sweetening units followed by a sulfur recover unit which commence construction or
modification after January 20, 1984. This facility has a sweetening unit but this subpart does not
apply to sweetening facilities producing acid gas that is completely re-injected into oil-or-gasbearing geologic strata or that is otherwise not released to the atmosphere. The acid gas
produced by the sweetening facility is completely re-injected into oil-or-gas-bearing geologic
strata.
Subpart IIII, Stationary Compression Ignition (CI) Internal Combustion Engines (ICE). This
subpart affects CI ICE manufactured after 2007. There are no CI ICE manufactured after 2007
at this facility.
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. As proposed, this subpart will affect nonemergency SI ICE, with an engine power greater than or equal to 500-hp, ordered after June 12,
2006 and which are manufactured after July 1, 2007. The SI ICE engines in this permit that are
greater than 500-hp were manufactured prior to July 1, 2007 and will not be subject to this
subpart. As proposed, this subpart will also affect engines that are reconstructed or modified
after June 12, 2006. None of the engines in this permit have been reconstructed or modified and
will not be subject to this subpart. This subpart will require all owners and operators to keep
records of all maintenance conducted on all stationary SI ICE.
Subpart KKKK, Stationary Combustion Turbines. This subpart establishes emission standards
and compliance schedules for the control of emissions from stationary combustion turbines with
a heat input at peak load equal to or greater than 10 MMBTUH, based on the higher heating
value of the fuel, that commenced construction, modification, or reconstruction after February
18, 2005. The turbines at this facility were constructed prior to the applicability date of this
subpart.
NESHAP, 40 CFR Part 61
[Not Applicable]
There are no emissions of any of the regulated pollutants: arsenic, asbestos, beryllium, benzene,
coke oven emissions, mercury, radionuclides or vinyl chloride except for trace amounts of
benzene. Subpart J, Equipment Leaks of Benzene only affects process streams that contain more
than 10% benzene by weight. All process streams at this facility are below this threshold.
PERMIT MEMORANDUM NO. 2005-100-TVR
DRAFT
Page 14
NESHAP, 40 CFR Part 63
[Subpart HH is Applicable]
Subpart HH, Oil and Natural Gas Production Facilities. This subpart applies to affected emission
points that are located at facilities that are major sources of HAP, and either process, upgrade, or
store hydrocarbon liquids prior to custody transfer or that process, upgrade, or store natural gas
prior to entering the natural gas transmission and storage source category.
The existing gas plant was a major source after the initial compliance date of this subpart and is
subject to the requirements of this subpart. The dehydration unit is subject to this subpart. The
storage tank with the potential for flash emissions at the facility has a throughput less than 500
barrels per day and is not subject to the control requirements of this subpart. Ancillary
equipment (as defined in § 63.761) and compressors, that contain or contact a fluid (liquid or
gas) that has a total VHAP concentration greater than or equal to 10 percent by weight and that
operate in VHAP service 300 hours per year or more are subject to this subpart unless they are
meeting the requirements specified in 40 CFR Part 60, Subpart KKK. The permit will require
the gas plant to comply with all applicable requirements.
Subpart YYYY, Stationary Combustion Turbines. This subpart was promulgated on March 5,
2004. This subpart affects stationary combustion turbines located at major sources of HAP. The
subpart establishes emission and operating limitations for each affected source. Based on
emission calculations, this facility will be a minor source of HAP prior to the initial compliance
date of this regulation and will not be subject to this subpart.
Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart was
promulgated on June 15, 2004. This subpart affects RICE with a site-rating greater than 500
brake horsepower and which are located at a major source of HAP emissions. The subpart
establishes emission and operating limitations for each affected source. Based on emission
calculations, this facility will be a minor source of HAP prior to the initial compliance date of
this regulation and will not be subject to this subpart.
As proposed, this subpart will affect new or reconstructed RICE, located at area sources, with a
maximum engine power greater than 500-hp, constructed or reconstructed after June 12, 2006,
and which are manufactured after July 1, 2007. The engines in this permit were manufactured
prior to July 1, 2007 and are not subject to this subpart.
Subpart DDDDD, Industrial, Commercial and Institutional Boilers and Process Heaters. This
subpart was promulgated on September 13, 2004, and affects boilers and process heaters located
at a major source of HAP. Based on emission calculations, this facility will be a minor source of
HAP prior to the initial compliance date of this regulation and will not be subject to this subpart.
Compliance Assurance Monitoring, 40 CFR Part 64
[Not Applicable]
Compliance Assurance Monitoring, 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 of the following criteria:



It is subject to an emission limit or standard for an applicable regulated air pollutant
It uses a control device to achieve compliance with the applicable emission limit or standard
It has potential emissions, prior to the control device, of the applicable regulated air
pollutant greater than major source levels.
PERMIT MEMORANDUM NO. 2005-100-TVR
DRAFT
Page 15
The Superior 2416G compressor engines are equipped with oxidation catalyst and use them to
meet their applicable CO emissions limits but they do not have the potential to emit pre-control
device CO emissions greater than major source levels. Therefore, the engines are not subject to
CAM.
The dehydration unit uses a condenser and a vapor recovery unit to meet the applicable emission
limits but these are considered inherent process equipment. With the inherent process
equipment, the potential emissions from the dehydration unit are less than major source levels
and the dehydration unit is not subject to CAM.
Chemical Accident Prevention Provisions, 40 CFR Part 68
[Applicable]
This facility handles naturally occurring hydrocarbon mixtures at a natural gas processing plant
and the Accidental Release Prevention Provisions are applicable to this facility. The facility is
required to submit the appropriate accidental release emergency response program plan prior to
operation of the facility with more than the . This facility has submitted their plan to EPA. More
information on this federal program is available on the web page: www.epa.gov/ceppo.
Stratospheric Ozone Protection, 40 CFR Part 82
[Subparts A and F are Applicable]
These standards require phase out of Class I & II substances, reductions of emissions of Class I
& II substances to the lowest achievable level in all use sectors, and banning use of nonessential
products containing ozone-depleting substances (Subparts A & C); control servicing of motor
vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations
which meet phase out requirements and which maximize the substitution of safe alternatives to
Class I and Class II substances (Subpart D); require warning labels on products made with or
containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon
disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds
under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons
(Subpart H).
Subpart A identifies ozone-depleting substances and divides them into two classes. Class I
controlled substances are divided into seven groups; the chemicals typically used by the
manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform
(Class I, Group V). A complete phase-out of production of Class I substances is required by
January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are
hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.
Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances,
scheduled in phases starting by 2002, is required by January 1, 2030.
Subpart F requires that any persons servicing, maintaining, or repairing appliances except for
motor vehicle air conditioners; persons disposing of appliances, including motor vehicle air
conditioners; refrigerant reclaimers, appliance owners, and manufacturers of appliances and
recycling and recovery equipment comply with the standards for recycling and emissions
reduction.
DRAFT
PERMIT MEMORANDUM NO. 2005-100-TVR
Page 16
The standard conditions of the permit address the requirements specified at §82.156 for persons
opening appliances for maintenance, service, repair, or disposal; §82.158 for equipment used
during the maintenance, service, repair, or disposal of appliances; §82.161 for certification by an
approved technician certification program of persons performing maintenance, service, repair, or
disposal of appliances; §82.166 for recordkeeping; § 82.158 for leak repair requirements; and
§82.166 for refrigerant purchase records for appliances normally containing 50 or more pounds
of refrigerant.
SECTION VIII. COMPLIANCE
Inspection
An operating inspection was conducted on June 20, 2007. The inspection was conducted by Eric
Milligan of Air Quality. The facility was physically as described in the permit application and
supplemental materials. Identification plates with the make, model, and serial number were
attached to each engine. Copies of the periodic testing are maintained at the site.
Testing
The results of periodic testing for the engines showing compliance with the applicable emission
limitations is shown in the table below.
EUG 2
1,133-hp Solar Saturn T-1300
1,133-hp Solar Saturn T-1300
EUG 5
3,200-hp Superior 2416G, EU 1
3,200-hp Superior 2416G, EU 2
2,800-hp Superior 2416G, EU 3
2,800-hp Superior 2416G, EU 4
2,800-hp Superior 2416G, EU 6
Date
6/19/07
6/19/07
6/19/07
6/19/07
6/19/07
6/19/07
6/19/07
Permit Limitations
NOX
CO
lb/hr
lb/hr
5.83
6.60
5.83
6.60
7.05
7.05
6.17
6.17
6.17
1.90
1.90
1.67
1.67
1.67
Test Results
NOX
CO
lb/hr
lb/hr
1.66
2.71
1.70
1.86
1.88
3.30
3.99
1.46
2.62
0.93
0.55
0.21
0.07
0.49
Tier Classification and Public Review
This application has been determined to be Tier II based on the request for a Part 70 renewal
permit. The permittee has submitted an affidavit that they are not seeking a permit for land use
or for any operation upon land owned by others without their knowledge. The affidavit certifies
that the applicant owns the land.
PERMIT MEMORANDUM NO. 2005-100-TVR
DRAFT
Page 17
The applicant will publish the “Notice of Filing a Tier II Application” and the “Notice of Draft
Permit” in a newspaper, in Texas County. The notice will state that the application and draft
permit will be available for public review at a location in Texas County, Oklahoma and at the
AQD main office. The draft permit will also be made available for public review on the Air
Quality section of the DEQ web page at http://www.deq.state.ok.us. This facility is located
within 50 miles of the Texas-Oklahoma and Kansas-Oklahoma borders. The states of Texas and
Kansas have been notified of the draft permit. The proposed permit will be forwarded to EPA
for a 45-day review period.
Fees Paid
Part 70 source operating permit renewal application fee of $1,000.
SECTION IX. SUMMARY
The facility is operated as stated in the application. Ambient air quality standards are not
threatened at this site. There are no active Air Quality compliance or enforcement issues
concerning this facility. Issuance of the renewal operating permit is recommended, contingent
on public and EPA review.
DRAFT
PERMIT TO OPERATE
AIR POLLUTION CONTROL FACILITY
SPECIFIC CONDITIONS
Whiting Oil and Gas Corporation
The Dry Trails Gas Plant (SIC 1321)
Permit Number 2005-100-TVR
The permittee is authorized to operate in conformity with the specifications submitted to Air
Quality on May 24, 2005, and all supplemental materials. The Evaluation Memorandum dated
July 10, 2007, explains the derivation of applicable permit requirements and estimates of
emissions; however, it does not contain operating limitations or permit requirements. Continuing
operations under this permit constitutes acceptance of, and consent to, the conditions contained
herein:
1.
Points of emissions and emissions limitations for each point:
[OAC 252:100-8-6(a)(1)]
EUG 1
Flare
Emissions from EU E1A are based on an estimated combustion efficiency of 98%, AP-42 (1/95),
Chapter 13.5 emissions factors, and combustion of 16.85 MMSCFY of pilot, purge, and residue
gas with a heating value of 1,056 BTU/SCF, and 0.33 MMSCFY of propane with a heating value
of 2,315 BTU/SCF. Emissions from this activity are considered insignificant.
EU
1
a.
b.
c.
d.
Point
1
Description
Plant Flare
The permittee shall determine and record the amount of gas vented to the flare (monthly
and 12-month rolling totals).
The flare is subject to the NSPS, Subpart A General Provisions for control devices and
shall be designed and operated in accordance with the requirements of 40 CFR Part 60,
Paragraph 60.18.
Records of pilot flame(s) outages shall be maintained along with the time and duration of
all periods during which the pilot flame is absent. Periods of pilot flame outages shall be
an excursion, except during startup, shutdown, or malfunction of the flare and when there
are no gases being vented to the flare, and shall be reported in the semi-annual monitoring
reports.
The permittee shall also record and maintain the following:
i.
The flare design;
ii. All visible emission readings, heat content determinations, flowrate measurements,
and exit velocity determinations made during the compliance demonstration; and
iii. All periods during the compliance determination when the pilot flame was absent.
DRAFT
SPECIFIC CONDITIONS NO. 2005-100-TVR
Page 2
EUG-2
Turbines
Emission limits for the turbines are based on continuous operation and manufacturer’s data
(NOX: 2.3 g/hp-hr, CO 2.6 g/hp-hr, VOC 0.05 g/hp-hr). The emissions limits for EU 1 and 2 are
listed below.
Emission Units
1
858-kW Solar Saturn
T-1300
Units
lb/hr
TPY
2
858-kW Solar Saturn
T-1300
lb/hr
TPY
a.
b.
c.
Permitted Emissions
NOX
CO
5.83
6.60
25.55
28.89
5.83
25.55
6.60
28.89
The permittee shall comply with the Standards of Performance for Stationary Gas Turbines
NSPS Subpart GG, for each of the turbines located onsite.
[40 CFR 60.330 to 60.335]
i.
Each turbine shall not discharge into the atmosphere any gases that contain nitrogen
oxides in excess of the limitation of § 60.332(a)(2) {150 ppmdv @ 15% O2}.
ii. Each turbine shall either comply with the sulfur dioxide emission limitation of §
60.333(a) {150 ppmdv @ 15% O2} or the fuel sulfur content limitation of § 60.333(b)
{8,000 ppmw S}.
iii. Monitoring of the sulfur and nitrogen content of the turbine fuel and reporting of
excess emissions is required pursuant to § 60.334.
A. Monitoring of fuel nitrogen content shall not be required as long as the owner or
operator does not claim an allowance for fuel bound nitrogen.
B. Monitoring of the fuel total sulfur content shall not be required as long as the
gaseous fuel meets the definition of natural gas in § 60.331(u) {20.0 gr/100 SCF,
680 ppmw S, & 338 ppmv S @ 20C} & {70% Methane by Volume or GCV
between 950-1100 BTU/SCF}.
C. For owner’s or operator’s who claim an allowance for fuel bound nitrogen and/or
for owner or operators combusting gaseous fuels that do not meet the definition of
natural gas, the nitrogen content and/or sulfur content of the fuel must be
determined and recorded once a day, respectively.
Each turbine at the facility shall have a permanent identification plate attached that shows the
make, model number, and serial number.
[OAC 252:100-43]
At least once per calendar quarter, the permittee shall conduct tests of NOX and CO
emissions from the turbines(s) and from each replacement engine/turbine when operating
under representative conditions for that period. Testing is required for any engine/turbine
that runs for more than 220 hours during that calendar quarter. A quarterly test may be
conducted no sooner than 20 calendar days after the most recent test. Testing shall be
conducted using a portable analyzer in accordance with a protocol meeting the
requirements of the latest AQD Portable Analyzer Guidance document, or an equivalent
method approved by Air Quality. When four consecutive quarterly tests show the
engine/turbine to be in compliance with the emissions limitations shown in the permit, then
the testing frequency may be reduced to semi-annual testing. A semi-annual test may be
conducted no sooner than 60 calendar days nor later than 180 calendar days after the most
SPECIFIC CONDITIONS NO. 2005-100-TVR
d.
e.
DRAFT
Page 3
recent test. Likewise, when the following two consecutive semi-annual tests show
compliance, the testing frequency may be reduced to annual testing. An annual test may be
conducted no sooner than 120 calendar days nor later than 365 calendar days after the most
recent test. Upon any showing of non-compliance with emissions limitations or testing that
indicates that emissions are within 10% of the emission limitations, the testing frequency
shall revert to quarterly. Reduced testing frequency does not apply to engines with
catalytic converters.
[OAC 252:100-8-6 (a)(3)(A)]
The permittee shall keep operation and maintenance (O&M) records for those turbines that
do not conduct quarterly testing. Such records shall at a minimum include the dates of
operation, and maintenance, type of work performed, and the increase, if any, in emissions
as a result.
[OAC 252:100-8-6 (a)(3)(B)]
Replacement (including temporary periods of 6 months or less for maintenance purposes), of
the turbines with emissions limitations specified in this permit with engines/turbines of lesser
or equal emissions of each pollutant (in lbs/hr and TPY) are authorized under the following
conditions:
[OAC 252:100-8-6(f)(2)]
i.
The permittee shall notify AQD in writing no later than 7 days in advance of the startup of the replacement turbine(s). Said notice shall identify the equipment removed and
shall include the new engine/turbine make, model, serial number, and horsepower; date
of the change, and any change in emissions.
ii. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to
confirm continued compliance with NOX and CO emissions limitations. A copy of the
first quarter testing shall be provided to AQD within 60 days of start-up of each
replacement or additional engine/turbine.
The test report shall include the
engine/turbine fuel usage, stack flow (ACFM), stack temperature (oF), stack height
(feet), stack diameter (inches), and pollutant emissions rates (g/hp-hr, lbs/hr, and TPY)
at maximum rated horsepower for the altitude/location.
iii. Replacement equipment and emissions are limited to equipment and emissions that
are not subject to NSPS, NESHAP, or PSD.
EUG-3
Hot Oil Heater
Emissions from EU 1 are based on the rated heat capacity and manufacturer’s data (NOX: 0.08
lb/MMBTU, CO: 0.04 lb/MMBTU, and VOC: 0.015 lb/MMBTU). Emissions from the hot oil
heater are considered insignificant.
EU
1
a.
Point
4
Description
Hot Oil Heater
MMBTUH
13.48
The permittee shall comply with the Standards of Performance for Small IndustrialCommercial-Institutional Steam Generating Units, NSPS, Subpart Dc, for the Hot Oil
Heater located onsite.
[40 CFR 60.40c to 60.48c]
i.
The owner or operator of each affected facility shall record and maintain records of
the amounts of each fuel combusted during each day. The owner or operator of an
affected facility that only burns very low sulfur fuel oil or other liquid or gaseous
fuels with potential sulfur dioxide emissions rate of 140 ng/J (0.32 lb/MMBtu) heat
input or less shall record and maintain records of the fuels combusted during each
calendar month.
DRAFT
SPECIFIC CONDITIONS NO. 2005-100-TVR
Page 4
EUG-4
Emergency Generator
Emissions from the emergency generator are based on 960 hours of operation a year, a maximum
fuel input of 57 gal/hr, a diesel fuel heating value of 137 MBTU/gal, a fuel sulfur content of
0.5% by weight, and manufacturer’s emission factors (NOx: 10.78 g/hp-hr, CO 3.42 g/hp-hr,
VOC 0.28 g/hp-hr).
EU
1
EU
1
a.
b.
c.
d.
e.
f.
Point
5
Description
Katolight Generator w/
Detroit Diesel Engine
Rating (KW)
817
NOX
lb/hr
TPY
26.05
12.50
EU 1 shall not operate more than 960 hours in any 12-month period.
[OAC 252:100-8-6(a)(1)]
EU 1 shall be fitted with a non-resettable hour-meter.
The permittee shall record the hours of operation of EU 1 (monthly and 12-month rolling
totals).
EU 1 shall only be fired with diesel fuel with a sulfur content of less than 0.5% by weight.
[OAC 252:100-31]
The permittee shall maintain records of the diesel fuel purchase receipts documenting the
sulfur content for each delivery of diesel fuel or shall determine and record the fuel sulfur
content for each delivery of diesel fuel for the generator.
[OAC 252:100-43]
A serial number or another acceptable form of permanent (non-removable) identification
shall be on the generator engine.
EUG-5
Compressor Engines
Emission limits for the compressor engines are based on continuous operation and
manufacturer’s data (NOX: 1.00 g/hp-hr, CO 0.27 g/hp-hr, VOC 0.50 g/hp-hr). The emissions
limits for EU 1 through 6 are listed below.
Emission Units
Permitted Emissions
CO
VOC
1.90
3.53
8.34
15.45
Units
lb/hr
TPY
NOX
7.05
30.90
3,200-hp Superior
2416G engine
w/Oxidation Catalyst
lb/hr
TPY
7.05
30.90
1.90
8.34
3.53
15.45
2,800-hp Superior
2416G engine
w/Oxidation Catalyst
lb/hr
TPY
6.17
27.04
1.67
7.31
3.09
13.52
1
3,200-hp Superior
2416G engine
w/Oxidation Catalyst
2
3
DRAFT
SPECIFIC CONDITIONS NO. 2005-100-TVR
Emission Units
4
2,800-hp Superior
2416G engine
w/Oxidation Catalyst
6
2,800-hp Superior
2416G engine
w/Oxidation Catalyst
a.
b.
c.
d.
e.
Units
lb/hr
TPY
NOX
6.17
27.04
lb/hr
TPY
6.17
27.04
Page 5
Permitted Emissions
CO
VOC
1.67
3.09
7.31
13.52
1.67
7.31
3.09
13.52
Each engine shall be equipped with a properly functioning oxidation catalyst.
[OAC 252:100-8-6(a)(1)]
Each engine at the facility shall have a permanent identification plate attached that shows the
make, model number, and serial number.
[OAC 252:100-43]
At least once per calendar quarter, the permittee shall conduct tests of NOX and CO
emissions from the engines(s) and from each replacement engine/turbine when operating
under representative conditions for that period. Testing is required for any engine/turbine
that runs for more than 220 hours during that calendar quarter. A quarterly test may be
conducted no sooner than 20 calendar days after the most recent test. Testing shall be
conducted using a portable analyzer in accordance with a protocol meeting the
requirements of the latest AQD Portable Analyzer Guidance document, or an equivalent
method approved by Air Quality.
[OAC 252:100-8-6 (a)(3)(A)]
The permittee shall keep operation and maintenance (O&M) records for those engines that
do not conduct quarterly testing. Such records shall at a minimum include the dates of
operation, and maintenance, type of work performed, and the increase, if any, in emissions
as a result.
[OAC 252:100-8-6 (a)(3)(B)]
Replacement (including temporary periods of 6 months or less for maintenance purposes), of
the engines with emissions limitations specified in this permit with engines/turbines of lesser
or equal emissions of each pollutant (in lbs/hr and TPY) are authorized under the following
conditions:
[OAC 252:100-8-6(f)(2)]
i.
The permittee shall notify AQD in writing no later than 7 days in advance of the startup of the replacement engine(s)/turbine(s). Said notice shall identify the equipment
removed and shall include the new engine/turbine make, model, serial number, and
horsepower; date of the change, and any change in emissions.
ii. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to
confirm continued compliance with NOX and CO emissions limitations. A copy of the
first quarter testing shall be provided to AQD within 60 days of start-up of each
replacement or additional engine/turbine.
The test report shall include the
engine/turbine fuel usage, stack flow (ACFM), stack temperature (oF), stack height
(feet), stack diameter (inches), and pollutant emissions rates (g/hp-hr, lbs/hr, and TPY)
at maximum rated horsepower for the altitude/location.
iii. Replacement equipment and emissions are limited to equipment and emissions that
are not subject to NSPS, NESHAP, or PSD.
SPECIFIC CONDITIONS NO. 2005-100-TVR
DRAFT
Page 6
EUG-6
Fugitives
Emissions from the fugitive equipment leaks are based on the equipment type, the number of
components, and the average emission factors for oil and gas facilities. There are no emission
limits applied to these EU but they are required to meet certain work practices.
EU
1
Point
24
Type of Equipment
Valves
Connectors
Flanges
Pump Seals
Other1
Type of Service
Gas/Vapor
Light Liquid
Heavy Liquid
Gas/Vapor
Light Liquid
Heavy Liquid
Gas/Vapor
Light Liquid
Heavy Liquid
Light Liquid
Heavy Liquid
Gas/Vapor
Light Liquid
Heavy Liquid
Number Items
1,592
837
186
6,368
3,348
744
1,592
837
186
9
6
83
0
0
1
Others include compressor seals, pressure relief valves, relief valves, diaphragms, drains, dump
arms, hatches, instruments, meters, polished rods, and vents
a.
The permittee shall maintain, and update annually, an inventory of fugitive emission
sources at the facility. The record shall include the following:
[OAC 252:100-8-6 (a)(3)]
i.
type of service (gas, heavy oil, light oil, and water/light oil),
ii. component type and count, and
iii. VOC content of stream handled.
All ancillary equipment (as defined in § 63.761) and compressors located at the gas plant
are subject to the NESHAP from Oil and Gas Production Facilities, Subpart HH, and shall
comply with the requirements for equipment leaks specified in § 63.769, by the dates
specified in 63.760(f), unless the criteria listed below are met and records of the
determinations are maintained as required in § 63.774(d)(2):
i.
NESHAP, Subpart HH applies to the equipment specified below, that contains or
contacts a fluid (liquid or gas) that has a total VHAP concentration equal to or greater
than 10 percent by weight (determined according to the procedures specified in §
63.772(a)) and that operates in VHAP service 300 hours or more per calendar year
but that is not meeting the requirements specified in 40 CFR part 60, Subpart KKK.
A. Ancillary equipment, as defined in § 63.761; and
B. Compressors.
b.
SPECIFIC CONDITIONS NO. 2005-100-TVR
ii.
c.
DRAFT
Page 7
In all cases where the provisions of this subpart require an owner or operator to repair
leaks by a specified time after the leak is detected, it is a violation of this standard to
fail to take action to repair the leak(s) within the specified time. If action is taken to
repair the leak(s) within the specified time, failure of that action to successfully repair
the leak(s) is not a violation of this standard. However, if the repairs are
unsuccessful, a leak is detected and the owner or operator shall take further action as
required by the applicable provisions of this subpart.
iii. For each piece of ancillary equipment and each compressor subject to NESHAP,
Subpart HH, the owner or operator shall meet the requirements specified in 40 CFR
part 61, subpart V, §§ 61.241 through 61.247, except as specified in § 63.769(c)(1)
through (8).
The permittee shall comply with NSPS, Subpart KKK, Standards of Performance for
Equipment Leaks of VOC from Onshore Natural Gas Processing Plants, for all affected
equipment located at this facility, including but not limited to the following:
[40 CFR 60.630 to 60.636]
i.
The owner/operator shall comply with the requirements of §§ 60.482-1(a), (b), and (d)
and § 60.482-2 through § 60.482-10 except as provided in § 60.633.
[§ 60.632(a)]
ii. The owner/operator shall demonstrate compliance with §§ 60.482-1 to 60.482-10 for all
affected equipment within 180 days of initial startup which shall be determined by
review of records, reports, performance test results, and inspection using methods and
procedures specified in § 60.485 unless the equipment is in vacuum service and is
identified as required by § 60.486(e)(5).
iii. The owner/operator shall comply with the monitoring, inspection, and repair
requirements, for pumps in light liquid service, of §§ 60.482-2(a), (b), and (c) except
as provided in §§ 60.482-2(d), (e), (f), and 60.633(d).
iv. Information and data used to demonstrate that a reciprocating compressor is in wet gas
service or is not in VOC service shall be recorded in a log that is kept in a readily
accessible location.
[§§ 60.633(f), 60.635(c), & § 60.486(j)]
v.
The owner/operator shall comply with the operation and monitoring requirements, for
pressure relief devices in gas/vapor service, of §§ 60.482-4(a) and (b) except as
provided in § 60-482-4(c) and § 60.633(b).
vi. Sampling and connection systems are exempt from the requirements of § 60.482-5.
[§ 60.633(c)]
vii. Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a
second valve, except as provided in § 60.632(c). The cap, blind flange, plug, or
second valve shall seal the open end at all times except during operations requiring
process fluid flow through the open-ended valve or line. Each open-ended valve or
line equipped with a second valve shall be operated in a manner such that the valve
on the process fluid end is closed before the second valve is closed. When a double
block-and-bleed system is being used, the bleed valve or line may remain open during
operations that require venting the line between the block valves but shall be closed at
all other times.
[§ 60.482-6]
SPECIFIC CONDITIONS NO. 2005-100-TVR
d.
e.
f.
g.
h.
i.
DRAFT
Page 8
viii. The owner/operator shall comply with the monitoring, inspection, and repair
requirements, for valves in gas/vapor service and light liquid service, of §§ 60.4827(b) through (e), except as provided in §§ 60.633(d), 60.482-7(f), (g), and (h), §§
60.483-1, 60.483-2, and 60.482-1(c).
[§ 60.482-7(a)]
ix. The owner/operator shall comply with the monitoring and repair requirements, for
pumps and valves in heavy liquid service, pressure relief devices in light liquid or
heavy liquid service, and flanges and other connectors, of §§ 60.482-8(a) through (d).
[§ 60.482-8]
x.
Delay of repair of equipment is allowed if it meets one of the requirements of §§
60.482-9(a) through (e).
xi. The owner/operators using a closed vent system and control device to comply with
these provisions shall comply with the design, operation, monitoring and other
requirements of 60.482-10(b) through (g).
[§ 60.482-10(a)]
An owner/operator may elect to comply with the alternative requirements for valves of §§
60.483-1 and 60.483-2.
[§ 60.632(b) & § 60.482-1(b)]
An owner/operator may apply to the Administrator for permission to use an alternative
means of emission limitation that achieves a reduction in emissions of VOC at least
equivalent to that achieved by the controls required in NSPS Subpart KKK. In doing so,
the owner or operator shall comply with requirements of § 60.634.
[§ 60.632(c)]
The owner/operator shall comply with the test method and procedures of § 60.485 except
as provided in §§ 60.632(f) and 60.633(h).
[§ 60.632(d)]
The owner/operator shall comply with the record-keeping requirements of § 60.486 and the
reporting requirements of § 60.487 except as provided in §§ 60.633, 60.635, and 60.636.
[§ 60.632(e)]
The owner/operator shall comply with the record-keeping requirements of §§ 60.635(b)
and (c) in addition to the requirements of § 60.486.
[§ 60.635(a)]
The owner/operator shall comply with the reporting requirements of §§ 60.636(b) and (c)
in addition to the requirements of § 60.487.
[§ 60.636(a)]
EUG-7
Storage Tanks
Working and breathing emissions from the tanks were based on TANKS4.0 and are considered
insignificant.
EU
1
2
3
4
5
6
7
8
9
10
11
Point
12
14
15
16
17
18
30
13
19
20
21
Description
Process Drain Sump Tank
Diesel Tank
Lube Oil Tank
Ambitrol Tank
TEG Tank
Slop Oil Tank
Lube Oil (Day) Tank
Methanol
Methanol
Gasoline
Synthetic Lube Oil
Size (Gal.)
1,000
4,200
8,820
8,814
4,200
19,740
1,000
500
500
500
500
Construction Date
1996
1996
1996
1996
1996
1996
1996
1998
2004
1997
1998
SPECIFIC CONDITIONS NO. 2005-100-TVR
DRAFT
Page 9
EUG-8
Facility Wide
This emission unit group is facility-wide. It includes all emission units and was established to
discuss the applicability of those rules or compliance demonstrations, which may affect all
sources within the facility.
EUG-10
Dehydration Unit
All emissions from the glycol dehydration unit are vented to a vapor recovery unit and the
facility inlet. The glycol dehydration unit shall be operated and maintained as follows:
EU
1
Point
1A
Description
TEG Dehydration Unit Still Vent/Flash Tank*
*
Vented to a vapor recovery unit and then to the facility inlet.
a.
b.
The glycol dehydration unit shall be equipped with a flash tank on the rich glycol stream.
All emissions from the glycol dehydration unit’s still vent and flash tank shall be vented to
a vapor recovery unit (VRU) or directly to the facility’s inlet.
The glycol dehydration unit is subject to the NESHAP from Oil and Gas Production
Facilities, Subpart HH, and shall comply with all applicable requirements including but not
limited to the following:
[40 CFR 63.760 to 63.779]
i.
The owner/operator shall maintain the actual average benzene emissions (in terms of
benzene emissions per year), at less than 0.90 megagram per year, as determined by
the procedures specified in § 63.772(b)(2). Records of these demonstrations shall be
maintained as required in § 63.774(d)(1).
[§ 63.764(e)(1)]
c.
EUG-11
Blowdowns
Emissions from EU 1 are based on venting approximately 1,152,000 SCF a year, a molecular
weight of 41.81 lb/lb-mole, and approximately 3.8% VOC. Emissions from this activity are
considered insignificant.
EU
1
Point
1
Description
Inlet Compressor Blowdowns
EUG-12
Loading Emissions
Emissions from loading of condensate into tank trucks were estimated using a throughput of
9,400 barrels per year of slop oil and an emission factor of 4.96 lb/1,000 gallons. Emissions
from loading of slop oil are considered insignificant.
EU
1
Point
26
Description
Condensate/Produced Water
SPECIFIC CONDITIONS NO. 2005-100-TVR
DRAFT
Page 10
EUG-13
Condensate Tank Emissions
Flashing emissions from the slop oil tank were estimated using the Vasquez-Beggs equation and
a throughput of 9,400 barrels per year of slop oil (water + oil) (70% H2O). Working and
breathing emissions from the condensate tank were estimated using TANKS4.0.
EU
1
Point
18
VOC
TPY
30.96
EU
1
a.
b.
Description
Condensate Tank Emissions
Slop oil throughput for the facility shall not exceed 9,400 barrels in any 12-month period.
Each month the permittee shall calculate and record the slop oil throughput of the facility
over the past month and the 12-month rolling total slop oil throughput.
2.
All fuel-burning equipment, except for the Emergency Generator (EUG 4, EU 1) shall be
fired with pipeline grade natural gas or other gaseous fuel with a sulfur content less than 343
ppmv. Compliance can be shown by the following methods: for pipeline grade natural gas, a
current gas company bill; for other gaseous fuel, a current lab analysis, stain-tube analysis, gas
contract, tariff sheet, or other approved methods. Compliance shall be demonstrated at least
once annually.
[OAC 252:100-31]
3.
The permittee shall be authorized to operate this facility continuously (24 hours per day,
every day of the year).
[OAC 252:100-8-6(a)]
4.
When periodic compliance testing shows emissions in excess of the lb/hr limits, the
permittee shall comply with the provisions of OAC 252:100-9. Requirements of OAC 252:100-9
include immediate notification and written notification of Air Quality and demonstrations that
the excess emissions meet the criteria specified in OAC 252:100-9.
[OAC 252:100-9]
5.
The following records shall be maintained on-site to verify Insignificant Activities. No
recordkeeping is required for those operations that qualify as Trivial Activities.
[OAC 252:100-8-6 (a)(3)(B)]
a.
b.
c.
For fuel storage/dispensing equipment operated solely for facility owned
vehicles: Records of the type and amount of fuel dispensed (annual).
For crude oil and condensate storage tanks with a capacity of less than or equal
to 420,000 gallons that store crude oil and condensate prior to custody transfer:
Records of capacity of the tanks and the amount of throughput (annual).
For fluid storage tanks with a capacity of less than 39,894 gallons and a true
vapor pressure less than 1.5 psia: Records of capacity of the tanks and contents.
SPECIFIC CONDITIONS NO. 2005-100-TVR
d.
DRAFT
Page 11
For activities that have the potential to emit less than 5 TPY (actual) of any
criteria pollutant: The type of activity and the amount of emissions from that
activity (annual).
6.
The permittee shall maintain records of operations as listed below. These records shall be
maintained on-site or at a local field office for at least five years after the date of recording and
shall be provided to regulatory personnel upon request.
[OAC 252:100-8-6 (a)(3)(B)]
a.
b.
c.
d.
e.
f.
g.
h.
i.
Periodic emission testing for the engines/turbines and each replacement
engine/turbine.
Operating hours for the engines/turbines if less than 220 hours per quarter and not
tested.
O&M records for any engine/turbine if not tested in each 6-month period.
Records of the flare pilot flame outages.
For fuel(s) burned, the appropriate document(s) as described in Specific Condition
No. 2.
Records required by NESHAP, Subpart HH.
Records required by NSPS, Subparts A (fuel gas, design tip velocity, design heating
value), Dc (fuel usage for the hot oil heater as required by Dc), GG (sulfur and
nitrogen content of fuel burned as required by GG), and KKK (maintain semi-annual
reports).
Amount of gas vented to the flare (monthly and 12-month rolling totals).
Hours of operation of EUG 4 Emergency Generator (monthly and 12-month rolling
totals).
7.
No later than 30 days after each anniversary date of the issuance of the original Title V
operating permit (May 25, 2000), the permittee shall submit to Air Quality Division of DEQ,
with a copy to the US EPA, Region 6, a certification of compliance with the terms and
conditions of this permit.
[OAC 252:100-8-6 (c)(5)(A) & (D)]
8.
This permit supercedes all other Air Quality permits for this facility, except Permit no. 97462-C (M-2), which are now null and void.
TITLE
SECTION I.
V (PART 70) PERMIT TO OPERATE / CONSTRUCT
STANDARD CONDITIONS
(December 6, 2006)
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)]
TITLE V PERMIT STANDARD CONDITIONS
SECTION III.
December 6, 2006
Page 2
MONITORING, TESTING, RECORDKEEPING & REPORTING
A. The permittee shall keep records as specified in this permit. Unless a different retention
period or retention conditions are set forth by a specific term in this permit, these records,
including monitoring data and necessary support information, shall be retained on-site or at a
nearby field office for a period of at least five years from the date of the monitoring sample,
measurement, report, or application, and shall be made available for inspection by regulatory
personnel upon request. Support information includes all original strip-chart recordings for
continuous monitoring instrumentation, and copies of all reports required by this permit. Where
appropriate, the permit may specify that records may be maintained in computerized form.
[OAC 252:100-8-6 (a)(3)(B)(ii), 8-6 (c)(1), and 8-6 (c)(2)(B)]
B. Records of required monitoring shall include:
(1) the date, place and time of sampling or measurement;
(2) the date or dates analyses were performed;
(3) the company or entity which performed the analyses;
(4) the analytical techniques or methods used;
(5) the results of such analyses; and
(6) the operating conditions as existing at the time of sampling or measurement.
[OAC 252:100-8-6 (a)(3)(B)(i)]
C. No later than 30 days after each six (6) month period, after the date of the issuance of the
original Part 70 operating permit, the permittee shall submit to AQD a report of the results of any
required monitoring. All instances of deviations from permit requirements since the previous
report shall be clearly identified in the report.
[OAC 252:100-8-6 (a)(3)(C)(i) and (ii)]
D. If any testing shows emissions in excess of limitations specified in this permit, the owner or
operator shall comply with the provisions of Section II of these standard conditions.
[OAC 252:100-8-6 (a)(3)(C)(iii)]
E. In addition to any monitoring, recordkeeping or reporting requirement specified in this
permit, monitoring and reporting may be required under the provisions of OAC 252:100-43,
Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean
Air Act or Oklahoma Clean Air Act.
F. Submission of quarterly or semi-annual reports required by any applicable requirement that
are duplicative of the reporting required in the previous paragraph will satisfy the reporting
requirements of the previous paragraph if noted on the submitted report.
G. Every report submitted under OAC 252:100-8-6 and OAC 252:100-43 shall be certified by a
responsible official.
[OAC 252:100-8-6 (a)(3)(C)(iv)]
H. Any owner or operator subject to the provisions of NSPS shall maintain records of the
occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected
facility or any malfunction of the air pollution control equipment.
[40 CFR 60.7 (b)]
TITLE V PERMIT STANDARD CONDITIONS
December 6, 2006
Page 3
I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all
measurements and other information required by the subpart recorded in a permanent file
suitable for inspection. This file shall be retained for at least two years following the date of
such measurements, maintenance, and records.
[40 CFR 60.7 (d)]
J. The permittee of a facility that is operating subject to a schedule of compliance shall submit
to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for
achieving the activities, milestones or compliance required in the schedule of compliance and the
dates when such activities, milestones or compliance was achieved. The progress reports shall
also contain an explanation of why any dates in the schedule of compliance were not or will not
be met, and any preventative or corrective measures adopted.
[OAC 252:100-8-6 (c)(4)]
K. All testing must be conducted by methods approved by the Division Director under the
direction of qualified personnel. All tests shall be made and the results calculated in accordance
with standard test procedures. The use of alternative test procedures must be approved by EPA.
When a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated
in accordance with the manufacturer’s instructions and in accordance with a protocol meeting the
requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method
approved by Air Quality. [40 CFR §70.6(a), 40 CFR §51.212(c)(2), 40 CFR § 70.7(d), 40 CFR
§70.7(e)(2), OAC 252:100-8-6 (a)(3)(A)(iv), and OAC 252:100-43]
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 PM10. NSPS may allow reporting of only particulate
matter emissions caught in the filter (obtained using Reference Method 5). [US EPA Publication
(September 1994). PM10 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 PM10 Emissions from Stationary Sources]; [Letter from Thompson G. Pace,
EPA OAQPS to Sean Fitzsimmons, Iowa DNR, March 31, 1994 (regarding PM10
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)]
TITLE V PERMIT STANDARD CONDITIONS
December 6, 2006
Page 4
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
be certified in the next annual certification.
[OAC 252:100-8-6 (c)(6)]
SECTION VI.
PERMIT SHIELD
A. Compliance with the terms and conditions of this permit (including terms and conditions
established for alternate operating scenarios, emissions trading, and emissions averaging, but
excluding terms and conditions for which the permit shield is expressly prohibited under OAC
252:100-8) shall be deemed compliance with the applicable requirements identified and included
in this permit.
[OAC 252:100-8-6 (d)(1)]
B. Those requirements that are applicable are listed in the Standard Conditions and the Specific
Conditions of this permit. Those requirements that the applicant requested be determined as not
applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6 (d)(2)]
TITLE V PERMIT STANDARD CONDITIONS
SECTION VII.
December 6, 2006
Page 5
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)]
TITLE V PERMIT STANDARD CONDITIONS
SECTION XI.
December 6, 2006
Page 6
DUTY TO PROVIDE INFORMATION
A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty
(60) days of the request unless the DEQ specifies another time period, any information that the
DEQ may request to determine whether cause exists for modifying, reopening, revoking,
reissuing, terminating the permit or to determine compliance with the permit. Upon request, the
permittee shall also furnish to the DEQ copies of records required to be kept by the permit.
[OAC 252:100-8-6 (a)(7)(E)]
B. The permittee may make a claim of confidentiality for any information or records submitted
pursuant to 27A O.S. 2-5-105(18). Confidential information shall be clearly labeled as such and
shall be separable from the main body of the document such as in an attachment.
[OAC 252:100-8-6 (a)(7)(E)]
C. Notification to the AQD of the sale or transfer of ownership of this facility is required and
shall be made in writing within 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]
TITLE V PERMIT STANDARD CONDITIONS
December 6, 2006
Page 7
(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):
(1) enter upon the permittee's premises during reasonable/normal working hours where a
source is located or emissions-related activity is conducted, or where records must be
kept under the conditions of the permit;
(2) have access to and copy, at reasonable times, any records that must be kept under the
conditions of the permit;
(3) inspect, at reasonable times and using reasonable safety practices, any facilities,
equipment (including monitoring and air pollution control equipment), practices, or
operations regulated or required under the permit; and
(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times
substances or parameters for the purpose of assuring compliance with the permit.
[OAC 252:100-8-6 (c)(2)]
SECTION XIV.
EMERGENCIES
A. Any emergency and/or exceedance that poses an imminent and substantial danger to public
health, safety, or the environment shall be reported to AQD as soon as is practicable; but under
no circumstance shall notification be more than 24 hours after the exceedance.
[OAC 252:100-8-6 (a)(3)(C)(iii)(II)]
B. An "emergency" means any situation arising from sudden and reasonably unforeseeable
events beyond the control of the source, including acts of God, which situation requires
immediate corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency.
[OAC 252:100-8-2]
TITLE V PERMIT STANDARD CONDITIONS
December 6, 2006
Page 8
C. An emergency shall constitute an affirmative defense to an action brought for noncompliance
with such technology-based emission limitation if the conditions of paragraph D below are met.
[OAC 252:100-8-6 (e)(1)]
D. The affirmative defense of emergency shall be demonstrated through properly signed,
contemporaneous operating logs or other relevant evidence that:
(1) an emergency occurred and the permittee can identify the cause or causes of the
emergency;
(2) the permitted facility was at the time being properly operated;
(3) during the period of the emergency the permittee took all reasonable steps to minimize
levels of emissions that exceeded the emission standards or other requirements in this
permit;
(4) the permittee submitted timely notice of the emergency to AQD, pursuant to the
applicable regulations (i.e., for emergencies that pose an “imminent and substantial
danger,” within 24 hours of the time when emission limitations were exceeded due to the
emergency; 4:30 p.m. the next business day for all other emergency exceedances). See
OAC 252:100-8-6(a)(3)(C)(iii)(I) and (II). This notice shall contain a description of the
emergency, the probable cause of the exceedance, any steps taken to mitigate emissions,
and corrective actions taken; and
(5) the permittee submitted a follow up written report within 10 working days of first
becoming aware of the exceedance.
[OAC 252:100-8-6 (e)(2), (a)(3)(C)(iii)(I) and (IV)]
E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency shall have the burden of proof.
[OAC 252:100-8-6 (e)(3)]
SECTION XV.
RISK MANAGEMENT PLAN
The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop
and register with the appropriate agency a risk management plan by June 20, 1999, or the
applicable effective date.
[OAC 252:100-8-6 (a)(4)]
SECTION XVI.
INSIGNIFICANT ACTIVITIES
Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to
operate individual emissions units that are either on the list in Appendix I to OAC Title 252,
Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below. Any
activity to which a State or federal applicable requirement applies is not insignificant even if it
meets the criteria below or is included on the insignificant activities list.
[OAC 252:100-8-2]
(1) 5 tons per year of any one criteria pollutant.
(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an
aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year
for single HAP that the EPA may establish by rule.
TITLE V PERMIT STANDARD CONDITIONS
SECTION XVII.
December 6, 2006
Page 9
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]
TITLE V PERMIT STANDARD CONDITIONS
December 6, 2006
Page 10
(4) For all emissions units not subject to an opacity limit promulgated under 40 CFR, Part
60, NSPS, no discharge of greater than 20% opacity is allowed except for short-term
occurrences which consist of not more than one six-minute period in any consecutive 60
minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall
the average of any six-minute period exceed 60% opacity.
[OAC 252:100-25]
(5) No visible fugitive dust emissions shall be discharged beyond the property line on which
the emissions originate in such a manner as to damage or to interfere with the use of
adjacent properties, or cause air quality standards to be exceeded, or interfere with the
maintenance of air quality standards.
[OAC 252:100-29]
(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 VOC.
[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]
TITLE V PERMIT STANDARD CONDITIONS
December 6, 2006
Page 11
C. The permittee shall comply with the following standards for recycling and emissions
reduction except as provided for MVACs in Subpart B.
[40 CFR 82, Subpart F]
(1) Persons opening appliances for maintenance, service, repair, or disposal must comply
with the required practices pursuant to § 82.156.
(2) Equipment used during the maintenance, service, repair, or disposal of appliances must
comply with the standards for recycling and recovery equipment pursuant to § 82.158.
(3) Persons performing maintenance, service, repair, or disposal of appliances must be
certified by an approved technician certification program pursuant to § 82.161.
(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply
with record-keeping requirements pursuant to § 82.166.
(5) Persons owning commercial or industrial process refrigeration equipment must comply
with leak repair requirements pursuant to § 82.158.
(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)
(2)
(3)
(4)
(5)
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.
A copy of the construction permit application is sent to EPA, as provided by 40 CFR §
70.8(a)(1).
A copy of the draft construction permit is sent to any affected State, as provided by 40
CFR § 70.8(b).
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).
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.
TITLE V PERMIT STANDARD CONDITIONS
December 6, 2006
Page 12
(6)
(7)
(8)
The DEQ complies with 40 CFR § 70.8 (d).
A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8 (a).
The DEQ shall not issue the proposed construction permit until any affected State and
EPA have had an opportunity to review the proposed permit, as provided by these permit
conditions.
(9) Any requirements of the construction permit may be reopened for cause after
incorporation into the Title V permit by the administrative amendment process, by DEQ
as provided in OAC 252:100-8-7.3 (a), (b), and (c), and by EPA as provided in 40 CFR §
70.7 (f) and (g).
(10) The DEQ shall not issue the administrative permit amendment if performance tests fail to
demonstrate that the source is operating in substantial compliance with all permit
requirements.
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]
PART 70 PERMIT
AIR QUALITY DIVISION
STATE OF OKLAHOMA
DEPARTMENT OF ENVIRONMENTAL QUALITY
707 NORTH ROBINSON, SUITE 4100
P.O. BOX 1677
OKLAHOMA CITY, OKLAHOMA 73101-1677
Permit No. 2005-067-TVR
Whiting Oil and Gas Corporation,
having complied with the requirements of the law, is hereby granted permission to operate
The Dry Trail Gas Plant located in Section 14, T5N, R13E, Texas County, Oklahoma,
subject to the Standard Conditions dated December 6, 2006, and the Specific Conditions,
both of which are attached:
This permit shall expire five years from the date of issuance, except as authorized under
Section VIII of the Standard Conditions.
_________________________________
Division Director, Air Quality Division
DEQ Form #100-890
Date
Revised 12/20/06
Whiting Oil and Gas Corporation
Attn: Mr. Jagadeasan Sethuraman
Mile High Center, Suite 2300, 1700 Broadway
Denver, CO 80290-2300
SUBJECT:
Permit No. 2005-100-TVR
Facility: The Dry Trail Gas Plant
Location: S14, T5N, R13E, Texas County, Oklahoma
Dear Mr. Sethuraman:
Air Quality has received the permit application for the referenced facility and completed initial
review. This application is a Tier II application. In accordance with 27A O.S. 2-14-301 and 302
and OAC 252:4-7-13(c) the enclosed draft permit is now ready for public review. The
requirements for public review of the draft permit include the following steps, which you must
accomplish:
1.
2.
3.
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)
Provide for public review (for a period of 30 days following the date of the newspaper
announcement) a copy of the application and draft permit at a convenient location
(preferentially at a public location) within the county of the facility.
Send AQD a written affidavit of publication for the notices from Item #1 above together
with any additional comments or requested changes, which you may have for the permit
application within 20 days of publication.
The permit review time is hereby tolled pending the receipt of the affidavit of publication. Thank
you for your cooperation. If you have any questions, please refer to the permit number above
and contact the permit writer at eric.milligan@deq.state.ok.us or at (405) 702-4217.
Sincerely,
Phillip Fielder, P.E.
Permits and Engineering Group Manager
AIR QUALITY DIVISION
Enclosures