draft oklahoma department of environmental … · aircraft or on a product basis. thus, rework...

DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM March 8, 2019

TO: Phillip Fielder, P.E., Permits and Engineering Group Manager

THROUGH: Rick Groshong, Sr. Environmental Manager, Compliance and Enforcement

THROUGH: Phil Martin, P.E., Existing Source Permits Section Manager

THROUGH: Jian Yue, P.E., New Source Permits Section

FROM: Richard Kienlen, P.E., New Source Permits Section Manager

SUBJECT: Evaluation of Permit Application No. 2014-0382-TVR2

American Airlines, Inc.

Tulsa Maintenance & Engineering Center (DEQ Facility ID: 20)

3800 North Mingo Road

Tulsa, Tulsa County, Oklahoma

Sec. 13 – T 20N – R 13E (36.20655N, 95.87070W at security shack)

SECTION I. INTRODUCTION

American Airlines (American) operates the Tulsa Maintenance & Engineering Center, an

aerospace maintenance and rework facility (SIC 4512). The applicant has requested renewal of its

Title V operating permit No. 2008-008-TVR, which was issued September 3, 2009, and under

which it currently operates. This application requests that the following updates or changes be

made in the renewal permit. At most, these changes are a minor modification, because there is no

physical change and there are no significant changes in monitoring, reporting, or recordkeeping.

Thus, all may be accomplished within this renewal permit.

1. Revise EUG 2 to address the removal of three paint booths, to recognize the addition of a

previously-authorized booth, and to pre-authorize two additional booths to provide operational

flexibility (based on EPA’s Flexible Air Permitting Rule, October 6, 2009).

2. Revise EUG 3 to address the removal of a boiler and a furnace, and to address the

applicability of NESHAP Subpart DDDDD.

3. Add EUG 13 to include previously insignificant emergency generators that are now

affected under NESHAP Subpart ZZZZ.

4. Revise the Insignificant Activities items to update information and to correct an error in

earlier Part 70 permits.

5. Address greenhouse gas (GHG) emissions.

The facility remains a major source.

PERMIT MEMORANDUM No. 2014-0382-TVR2 DRAFT

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SECTION II. PROCESS DESCRIPTION

The facility performs both routine and major (heavy) maintenance on its fleet of commercial

aircraft. Maintenance activities at the facility encompass repairs of more than 250,000 different

mechanical and avionics components. Rework on aircraft is performed based on the fleet type of

aircraft or on a product basis. Thus, rework activities are divided into Airbus 319, Boeing 737,

Boeing 757, Boeing 767, and Boeing 777 aircraft categories. Jet engine rework is performed

separately from airframe and other aircraft components.

Major structures of interest at the facility include seven (7) hangars (H), the Powerplant APU &

Landing Gear Maintenance (PALM) building, the Components Avionics Maintenance (CAM)

building, a warehouse (W), three (3) engine test cells (TC), a Facilities Maintenance Shop, and

Chemical Storage area. A plating shop (PS) is located in the PALM. Each hangar has up to four

docking positions. Numerous other structures, such as administrative offices and storage rooms,

are not considered to be air emission sources and are not listed here. The facility performs both

FAA (Federal Aviation Administration) “B” and “C” checks on the aircraft, and both are

performed in the same hangars. Checks begin with aircraft washing and brightening. The aircraft

is docked in the hangar designated for the product type of aircraft. Specific maintenance is carried

out in accordance with manufacturer, FAA, and company specifications. Components must be

removed and sent to their respective shops for repair. Centralized facilities for coating, stripping

and other activities are not possible because each part/component requires a different process and

has a separate shop. Work that is required on components is performed in shops located in various

hangars throughout the facility. All other work is performed on the aircraft in the hangar.

Maintenance activities begin with defueling and disassembling the aircraft. These activities

include removing jet engines, seats, lavatories, galleys, floorboards, cockpits, landing gear,

aluminum skins, and all instrumentation. Component parts are routed to individual shops where

specialized maintenance functions are performed. Aircraft structural repairs are performed at the

dock. Other dock activities include detailed visual and electronic inspections, X-ray examinations,

exterior paint stripping and repainting, and decal removal and application.

Significant sources of emissions at the facility have been identified and divided into emission unit

groups (“EUGs”) comprised of individual emission units. Where applicable, alternative operating

scenarios associated with specific EUGs are incorporated. The level of detail shown is necessary

when demonstrating compliance with various aspects of specific aerospace Rules and Regulations.

The majority of facility emission sources are located in the CAM and PALM buildings, where the

disassembled aircraft parts are subject to a number of operations including blasting, cleaning,

painting, drying, and machine working. The EUGs are identified below.

EUG 1 Facility-Wide

This EUG is established to consider those rules that apply to the facility as a whole, such as OAC

252:100-29 (Fugitive Dust).

EUG 2 Coating Operations Subject To Aerospace Standards

Certain operations are governed by 40 CFR 63 Subpart GG (aerospace MACT) and/or by OAC

252:100-39-47. Coating operations include the application of primers, topcoats, and specialty


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coatings to aircraft and aircraft parts and assemblies. These operations occur throughout the

facility, including the PALM, CAM, and Engine Test Cell Buildings, as well as Hangars #1-7.

Coatings are applied via brush, roller brush, swab, HVLP spray guns, and aerosol spray (including

jet packs). Painting operations may occur in paint booths or in open areas in the docks of the

hangars. Specialty coatings (as defined in the MACT and described in Appendix N of OAC

252:100), primers, and topcoats may be applied at all coating operation locations depending on the

maintenance work being performed. Certain coating operations are exempted by the MACT,

including aerosol application, coating aircraft parts that are not critical to structural integrity or

flight performance (“non-critical parts”), low volume (use) coating, and the use of coatings

containing very small amounts of VOC and/or HAP. A list of specific exemptions may be found

at 40 CFR 63.741(f). All of these exempt operations may occur at various levels at all coating

operation locations, but some booths perform only exempt coating operations.

The facility has divided its paint booths into three types, based on a comparison of their current

use with the regulatory criteria outlined above. First are those paint booths in which primers and

topcoats that include organic and inorganic HAPs above de minimis levels are applied to aircraft

parts that are critical to an aircraft’s structural integrity or flight performance. These paint booths

are currently EP#s 4, 30, 35, 38, 245, 246, 247, 248, 249, and 253. Second are those paint booths

that apply primers and topcoats to aircraft parts that are critical to an aircraft’s structural integrity

or flight performance and which contain only organic HAPs. Currently, EP# 32 is categorized in

this group. The third group contains those paint booths that apply only specialty coatings or coat

only non-critical parts, or both. These paint booths are currently EP#s 3, 5, 8, 11, 12, 13, 14, 17,

18, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 250, 251, and 252. The last three booths are actually

exempt from the aerospace standards because they involve only aerosol sprays. While these

divisions have historical significance, they do not lead to simple compliance demonstrations under

the Aerospace MACT. A description of the analysis used in structuring this permit may be found

in Section III, “Equipment,” below.

EUG 3 Boilers

The boilers located in the PALM Building (EPs-45 & 46), and Hangar #6 (EPs-48 & 49) generate

steam for space and process heating and cooling. All boilers and furnaces are fueled by natural

gas. The facility also contains several electric ovens/furnaces that are classified as “trivial

activities” under OAC 252:100-8-2 and as further identified in Appendix J of OAC 252:100.

EUG 4 Chrome Plating

Chrome Plating includes “hard chromium electroplating” that occurs in the facility’s Plating Shop.

Hard chromium electroplating is a process by which a thick layer of chromium (typically 1.3 - 760

microns) is electrodeposited on a base material to provide a surface with functional properties such

as wear resistance, a low coefficient of friction, hardness, or corrosion resistance. The aircraft part

serves as the cathode in the electrolytic cell, and the plating solution serves as the electrolyte.

Chrome Plating also includes a chromium anodizing process that is performed in the Plating Shop.

This is an electrolytic process by which an oxide layer is produced on the surface of a base metal

aircraft part for functional purposes (e.g., corrosion resistance or electrical insulation) using a

chromic acid solution. The aircraft part to be anodized acts as the anode in the electrical circuit

and the chromic acid solution serves as the electrolyte.


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Scrubbers #6 and #7 control chromium emissions from all hard chrome tanks and from the single

anodizing tank. Both scrubbers are three-stage, mesh pad, mist eliminators, and both were

installed during a previous upgrade. All hard chrome tanks have two stage separators in their

hoods, adding further control.

EUG 5 Halogenated Vapor Degreasers

The facility employs six batch vapor cleaning machines that utilize halogenated solvents. Four

vapor degreasers (EPs-59, 60, 61 & 62) located in the Plating Shop utilize perchloroethylene, and

the remaining two vapor degreasers (EPs-63 & 64) located in the PALM Building may utilize

trichloroethylene or n-propyl bromide (nPB). Each of the machines is of similar design and has

an idling or downtime cover that covers the machine’s openings when in place. Each machine

has:

(1) a freeboard ratio of 0.75 or greater;

(2) an automated parts handling system that moves parts into and out of the machine at 11 feet

per minute or less;

(3) a sump pump switch that turns off sump heat if sump liquid solvent level drops to the

heating coils;

(4) a vapor level control device that shuts off the sump pump if the vapor level rises above the

primary condenser;

(5) a primary condenser; and

(6) a solvent/air interface area greater than 13 square feet.

EUG 6 Engine Test Cells

The facility currently has three engine test cells, EPs-68, 69, and 70, that are used to test rebuilt

turbine jet engines. Rebuilt jet engines are placed in the test cells, where they are supplied with

Jet-A fuel and operated in three operational stages (i.e., rev-up, take-off, and simulated in-flight).

The emissions from the test cells are the result of combustion of Jet-A fuel, are variable, and of

short duration.

EUG 7 Coating Operations Not Subject To Aerospace Standards

Activities pertaining to the repair and maintenance of facility vehicles, structures, equipment and

buildings that support aircraft maintenance are also conducted at the facility. These activities

include application of coatings on facility vehicles, structures, equipment, and buildings. The

coatings operations occur in a paint booth (EP-71) located in the Facilities Maintenance (FM)

Building and also at fugitive locations (EP-72) throughout the facility.

EUG 8 Spray Gun Cleaning

Spray gun cleaning activities (EPs-75 through 91A) are conducted at each location where spray

guns are used in coating operations. These activities are found in the PALM, CAM, Engine Test

Cell Buildings, and FM Building, as well as Hangars #1-7. There are two types of spray gun

cleaners used at the facility. The first is the enclosed type (EPs-75 through 91) where the unit is

closed at all times except when inserting or removing the spray gun to be cleaned. Cleaning

consists of forcing solvent through the gun. The second type is a vat used to clean a disassembled

spray gun (EP-91A). The spray gun is disassembled, and the components are cleaned by hand in


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a vat. The parts are also soaked in the vat. The vat remains closed during parts soaking and when

not inserting or removing parts.

EUG 9 Hand-wipe Solvent Cleaning

Hand-wipe cleaning (EP-92) occurs where maintenance operations are performed on aircraft parts

throughout the facility. Emissions from hand-wipe cleaning are not associated with individual

point sources. Hand-wipe cleaning involves the removal of contaminants such as dirt, grease, oil

and coatings from an aircraft part by physically rubbing it with a material such as a rag, paper, or

cotton swab that has been moistened with a cleaning solvent.

EUG 10 Flush Cleaning Operations

Flush Cleaning Operations (EPs-74 & 93) are performed anywhere maintenance operations are

performed on aircraft parts. The emissions are not associated with individual point sources. These

operations remove contaminants such as dirt, grease, oil, and coatings from aircraft parts by

passing solvent over, into and through the part being cleaned. Such cleaning operations include

immersion, part washing, mechanical washing, and spray cleaning. This definition can apply to

static cleaning machines, wheeled/portable parts washers, or even a bucket used for cleaning nuts

and bolts. Hand-wipe cleaning operations where wiping, scrubbing, mopping, or other hand action

are used are not included.

EUG 11 Aircraft Depainting

Depainting Operations (EP-95) occur in Hangars #1-6 and include those activities that remove

permanent coatings from the outer surface of the aircraft, except for parts and assemblies that are

removed from the aircraft. A chemical agent and/or mechanical and hand sanding may be used to

remove such coatings.

EUG 12 Fuel Storage

Tank T-4 (EP-99) is used to store unleaded gasoline to fuel facility vehicles. The tank is equipped

with a submerged fill pipe as well as a vapor recovery system. The facility maintains five (5) tanks

(EPs-96, 97, 98, 100, and 102) that store Jet-A fuel for use in the Engine Test Cells, fueling and

de-fueling of completed aircraft, as well as an alternate or backup fuel supply for the facility’s

boilers (EPs-45, 46, 48, and 49). EP-100 is listed as an Insignificant Activity due to small size and

low vapor pressure.

EUG 13 Emergency Engines

The facility contains thirteen (13) stationary reciprocating internal combustion engines (RICE)

that burn natural gas, propane, aircraft fuels, or diesel fuel, and that are used exclusively for

emergency power generation, for fire pumping, and for required testing and maintenance.

Facility operations are 24 hours/day, 7 days/week, and 52 weeks/year (8,760 hours/year).

SECTION III. EQUIPMENT

EUG 1 Facility-Wide

This EUG is designated facility-wide to address those applicable air quality standards such as open

burning or fugitive dust that do not attach to any specific emission unit.


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All booths have dry particulate filter systems, so the number of stages is identified for each, as

well as the standard it must meet under the Aerospace MACT. Booth Nos. 4, 6, 245, 246, 247,

248, 249, and 253 currently use the ATI Aerospace 3000 system and all others use the ATI OSM-

300 system. The PM numbers refer to the facility’s preventive maintenance system, while the

alpha-numeric groups in parentheses are used in a coordinate system for locating and tracking each

piece of equipment throughout the facility. This table does not identify those booths that monitor

pressure drop, a requirement for spraying coatings containing inorganic HAPs. This will be

discussed in Sections V and VI below. The “GG Tables” column refers to the particulate standards

that must be met per 40 CFR 63.745(g). The “in lieu” entry refers to the language of

§63.745(g)(2)(iii) that deals with booths constructed after June 6, 1994, and before October 29,

1996. Booth Nos. 7, 10, and 19 have been removed and Booth No. 253 has been added since the

last renewal permit was issued. This permit authorizes the addition of two more booths to provide

operational flexibility.

EU ID# EP # Booth name Preventive Maintenance

# and location

Const./Mod

Date GG Table

TEO-PB3 3 Hydraulic shop PM7862445 [g4(mez)] 10/25/94 In lieu

TEO-PB4 4 Landing gear shop PM7862447 (c4) 1/17/97 3 & 4

TEO-PB5 5 Metal spray PW PM7862438 (j4) 12/4/91 1 & 2

TEO-PB8 8 Sub-support PM7862413 [c33(mez)] 1987 1 & 2

TEO-PB11 11 CF6-80 cold shop/ LP fan PM7862444 (d44) 11/1/90 1 & 2

TEO-PB12 12 GE metal spray PM7862419 (j45) 1987 1 & 2

CAM-PB13 13 Miscellaneous valves PM7861041 (b2) 1/1/59 1 & 2

CAM-PB14 14 Thrust reverser paint PM7862403 (d3) 1/8/86 1 & 2

CAM-PB17 17 CSD/ Generator PM7862412 (a7) 1988 1 & 2

CAM-PB18 18 WB seat shop PM7861699 (f8) 1988 1 & 2

CAM-PB20 20 WB interiors PM7862401 (f11) 1981 1 & 2


CAM-PB22 22 Pneumatic electrical PM7861426 (a15) 1988 1 & 2


CAM-PB24 24 Auto Pilot, Nav & Radar PM7862453 (c15) 1988 1 & 2

CAM-PB25 25 Auto Pilot, Nav & Radar PM7861033 (f15) 1988 1 & 2

CAM-PB26 26 Auto Pilot, Nav & Radar PM7862454 (f15) 1988 1 & 2

CAM-PB27 27 Elec. & Flt. Instr. PM7861061 (a17) 7/58 1 & 2

CAM-PB28 28 Gyroscope PM7861062 (a17) 1958 1 & 2

CAM-PB29 29 Electric accessories PM7862452 (f18) 1988 1 & 2

TC1/2-PB30 30 NB thrust reverser PM7862436 (b8) 1958 1 & 2

H1/2-PM32 32 NB door & structure PM7862449 (c1) 1990 1 & 2

H3/4-PB35 35 Flight controls PM7860812 (a1) 3/11/85 1 & 2

H6-PB38 38 HGR 6 Paint & fiberglass PM7862437 (b7) 2/15/91 1 & 2

H1-D39 39 Not applicable (N/A) Hangar #1 Dock Area(s) N/A N/A

H2-D40 40 N/A Hangar #2 Dock Area(s) N/A N/A





TEO-PB A 245 Heat treat & paint PM9666974 (g4s) May 2003 3 & 4


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EU ID# EP # Booth name Preventive Maintenance

# and location

Const./Mod

Date GG Table

TEO-PB B 246 Heat treat & paint PM9666973 (g4s) May 2003 3 & 4

TEO-PB C 247 Heat treat & paint PM9666972 (g4s) May 2003 3 & 4

H1/2-PB248 248 HGR 2 Paint & fiberglass PM7865443(a21) 12/13/06 3 & 4

H1/2-PB249 249 HGR 2 Paint & fiberglass PM7865444(a21) 1/11/07 3 & 4

TEO-PB250 250 Tool and Die Touchup PM7861100 2004 Exempt*

TEO-PB251 251 Bearing PM7862460 2004 Exempt*

HE-PB252 252 Tool and Die Touchup PM7865426 2004 Exempt*

TEO-PB253 253 Landing gear small part PM7865753 2/1/09 3 & 4

Proposed TBD TBD TBD TBD TBD

Proposed TBD TBD TBD TBD TBD

* The only spraying done is with aerosol cans.

EUG 3 Boilers/Furnaces

EU ID# EP #

Preventive

Maintenance #

Capacity,

MMBTUH Const./Mod Date

TEO-B1 45 PM2149214 72.8 6/28/88

TEO-B2 46 PM2149215 72.8 6/28/88

H6-B4 48 PM2149216 72.8 1/15/91

H6-B5 49 PM2149217 72.8 1/15/91


Scrubber #6 is identified as EP-57 and Scrubber #7 is EP-58. American is considered a large, hard

chromium electroplating facility because the maximum cumulative potential rectifier capacity is

greater than or equal to 60 million ampere-hours per year (amp-hr/yr).

EU ID# Scrubber # Tank # and service Const./Mod Date

PS-T80 6 80 – Anodize 8/26/93

NCR 105 6 105 – Chromic acid 2002

NT 4 6 4 – Chrome reverse etch 2002

NCR 6 6 6 – Chrome plate 2002













PS 143 6 143 – Chrome supply 2002

PS 143a 6 143a – Out-of-tank chrome pad 2002


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EU ID# Scrubber # Tank # and service Const./Mod Date

PS 143b 6 143b – Out-of-tank chrome pad 2002

PS 143c 6 143c – Out-of-tank chrome pad 2002


PS 144a 6 144a – Out-of-tank chrome cabinet 2002


EU ID# EP # Preventive Maintenance # and Service Const./Mod Date

PS-VD1 59 PM7899882 (T158) (plating shop) 3/89 / 2/98

PS-VD2 60 PM7899879 (T159) (plating shop) 8/94



TEO-VD5 63 PM7899883 (landing gear) 1990 / 2/98

TEO-VD6 64 PM7899884 (blade and vane) 1990 / 2/98

TBD TBD TBD Proposed


The facility has been authorized to install up to two (2) additional batch vapor cleaning machines.

Addition of such cleaning machines is discussed in the review of Subchapters 8 and 39 and

NESHAP Subpart T in Sections V and VI below (State and Federal Rules).


EU ID# EP # EU Name Const./Mod Date

TC-1 68 Test Cell #1 6/58




The facility has been authorized to install an additional engine test cell. Addition of an additional

cell is discussed in the review of Subchapter 8 in Section V below (State Rules).

EUG 7 Coating Operations Not Subject To Aerospace Standards


FM-PB1 71 Paint Booth – PM7860813 May 1989

FUG-1 72 Fugitive coatings throughout the facility N/A


The facility has been authorized to install an additional paint booth. Addition of a paint booth is

discussed in the review of Subchapter 8 in Section V below (State Rules).


EU ID# EP # Preventive Maint. # and Location Const./Mod Date

TEO-PG1 75 PM7867389,PM 7867005 (C3) --

TEO-PG2 76 PM9633125 (C3) --


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EU ID# EP # Preventive Maint. # and Location Const./Mod Date

TEO-PG4 78 PM7867056 (g4S) --

CAM-PG3 81 PM9633117 (f11) --

TC-PG1 82 PM9633120 --

TC-PG2 83 PM9633121 --

H ½-PG1 85 PM9605173 (a21) --

H ½-PG2 86 PM9605174 --

H ¾-PG1 87 PM9605176 (c6mez) --

H6-PG1 91 PM7866863 --

FUG 91A Disassembled Spray Gun Cleaning --

TBD (19) TBD TBD (19) Proposed

The facility has been authorized to install up to 19 additional spray gun cleaners. Installation of

these cleaners is discussed in the review of Subchapters 8 and 39 and NESHAP Subpart T in

Sections V and VI below (State and Federal Rules).


EU ID# Emission Point EU Name Const./Mod Date

FUG-2 EP-92 Hand-wipe Solvent Cleaning N/A

EUG 10 Flush Cleaning Operations


FUG-3 93 Flush Cleaning Operations N/A

CAM-OS2 74 Organic Solvent Cleaning (Isopropyl Alcohol) N/A



The facility has been authorized to install two additional cold metal organic solvent flush cleaning

operations. Installation of same is discussed in the review of Subchapter 8 in Section V below

(State Rules).


EU ID# Emission Point EU Name Const./Mod Date

FUG-5 EP-95 Depainting Operations N/A

EUG 12 Fuel Storage

EP # EU Name/Model Capacity (Gallons) Construction Date

96 Jet-A Fuel UST 1 (T-1) 50,000 1988

97 Jet-A Fuel UST 2 (T-2) 50,000 1988

98 Jet-A Fuel UST 3 (T-3) 50,000 1988

99 Unleaded Gasoline UST 4 (T-4) 10,000 1988

102 Jet-A Fuel UST 8 (T-8) 13,000 1988


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Emission Point Manufacturer HP/MMBTUH Serial Number Construction

Diesel-fueled Emergency Generator Engines

EP-105 Caterpillar 890/2.05 TUL101 1990

EP-106 Onan 390/0.85 TUL084 1989

EP-107 Caterpillar 610/1.20 8576 1987


EP-109 Caterpillar 890/2.05 20723 2000

EP-110 Caterpillar 671/1.71 20880 2000

EP-111 Cummins 168/0.43 10036 1988

EP-112 Waukesha 216/0.55 TUL137 1987

Jet A-fueled Fire Pump Engines

EP-301 Caterpillar 483/1.5* TUL093 1989





*1.5 MMBTUH is a conservatively high estimate of heat input.

Insignificant Activities

An asterisk (*) preceding an item means that appropriate records of hours, quantity, or capacity must

be kept on the activity to verify its insignificance.

Space heaters and emergency flares less than or equal to 5 MMBtu/hr heat input (commercial natural

gas). The facility has numerous space heaters.

* Emissions from fuel storage/dispensing equipment operated solely for facility owned vehicles if

fuel throughput is not more than 2,175 gallons/day (gpd), averaged over a 30-day period. The

facility’s maximum daily average throughput for 2012 was 278 gpd in January. Annual throughput

was 78,763 gallons, or 215 gpd.

* Storage tanks with less than or equal to 10,000 gallons capacity that store volatile organic liquids

with a true vapor pressure less than or equal to 1.0 psia at maximum storage temperature. The facility

has Jet-A (diesel equivalent) tanks and a used oil tank, as follow.


100 UST 6 (T-6) 3,000 1988

101 UST 7 (T-7) 8,000 1988

Used Oil UST (T-5) 2,000 Unknown

Alkaline/phosphate washers and associated burners.

* Welding and soldering operations utilizing less than 100 pounds of solder and 53 tons per year of

electrodes. The facility uses more than 100 pounds of solder per year, so it does not satisfy this


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criterion. Further discussion is found in the category identified below as “Activities having the

potential to emit no more than 5 TPY.”

Wood chipping operations not associated with the primary process operation.

Hazardous waste and hazardous materials drum staging areas.

Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous

waste satellite (accumulation) areas.

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

A plasma arc cutting booth, originally identified as EUG 13, was installed under DEQ Permit

No. 97-021-O. Uncontrolled potential emissions of various metals were calculated to be less

than 0.25 TPY, with a control efficiency in excess of 99%. Therefore, recordkeeping to verify

emissions remain below 5 TPY is not necessary in the permit.

The facility operates several metal spray booths, in which powdered metals are heated to form

alloys that are sprayed using special guns. Assuming a maximum spray rate of 13.5 lbs/hr in

each booth, 5% metal vaporization (a rough equivalent to overspray), and 95% filter

efficiency, combined emissions are 0.07 lbs/hr or 0.30 TPY.

The facility operates a number of tanks containing acid solutions, including nitric, sulfuric,

chromic, and hydrochloric acids. Only chromic acid and hydrochloric acid (HCl) are HAPs;

the other two acids were formerly considered to be toxic air contaminants under the

superseded Part 5 of OAC 252:100-41. Note that the chromic acid tanks are subject to a

MACT, and cannot be classified as Insignificant, leaving only the HCl tanks to be addressed.

The facility calculated emissions for each tank, using

W = (MW K A P) (R T), where

W = evaporation rate,

MW = molecular weight,

K = gas phase mass transfer coefficient,

A = surface area,

P = vapor pressure,

R = ideal gas constant, and

T = absolute temperature of bath.

Two variables affect the use of this equation; concentration of the HCl and vapor pressure.

There are three tanks (86, 141, and 142) that contain 100% HCl and which are incidentally

heated, assuring higher vapor pressure and therefore higher emissions. Using the equation

and applying scrubber efficiency of 99% yields emissions near 1 TPY for the largest tank,

assuring that no tank will have emissions greater than or equal to the Insignificant HAP

threshold of 2 TPY.

Other process tanks in the Plating Shop contain nickel and other materials in solution. The

tanks are at ambient temperatures and contain materials with even less volatility than those

discussed in the preceding sentences. Emissions are insignificant.


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Welding used approximately 2,000 pounds of rod during the preceding year. According to

AP-42 factor SCC 3-09-051 (38.4 lbs of emissions/1,000 lbs of rods used), this equates to

only 77 lbs of PM emissions. The facility notes a lack of emission factors for soldering and

states that the emissions from soldering are negligible. An AQD search for such factors found

indications in major manufacturing code groups that criteria and HAP emissions from

soldering are negligible. The facility shall maintain purchase or use records for both welding

electrodes and solder.

Following is a list of stack parameters for four furnaces, two scrubbers, and three test cells.

EP # Height above grade (ft) Diameter (ft) SCFM Temperature (F)

45 35 2.8 1,128 370

46 35 2.8 1,128 370

48 35 2.8 1,128 370

49 35 2.8 1,128 370

57 51 3.42 3,000 95

58 51 3.42 3,000 97

68 45 21.81 2.94 × 106 980

69 45 21.81 2.94 × 106 980

70 46 38.28 2.94 × 106 980

SECTION IV. EMISSIONS

EUG 1 Facility-Wide

There are no emissions directly associated with this EUG.


Potential emissions from coating operations are difficult to estimate in a facility whose operations

vary in response to external needs and customer requirements. The facility reviewed its actual

emissions for inventory year 1998 supplied with the original TV application and made an

engineering judgment as to the maximum emissions that could reasonably be expected from this

EUG. The following table updates that to show 2012 actuals and future maxima. Only TPY are

shown, as lbs/hr are highly variable.

Pollutant Emissions in TPY

2012 Actual Future Maximum

PM10 4.20 16.5

Non-HAP VOC 16.4 63.1

HAP 2.3 30.6


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EUG 3 Boilers

Under the main operating scenario (1), EPs #45, 46, 48, and 49 combust natural gas and use

emission factors from Tables 1.4-1 and 2 of AP-42 (7/98). Calculations of potential to emit are

shown based on 291.2 MMBtu/hr total heat input of all four, and assuming 1,020 Btu/cf.

NATURAL GAS

Pollutant

Emission

factor, Emissions

Lbs/MMCF Lbs/hr TPY

PM10 7.6 2.21 9.66

SO2 0.6 0.17 0.76

NOX 100 29.0 127

CO 84 24.4 106

VOC 5.5 1.60 6.99

Under alternate operating scenario 2, all four units combust Jet-A fuel. Only for the purpose of

determining maximum-case emissions, Jet-A is assumed to fall somewhere between #1 and #2

fuel oil, with heating content of 129 MMBtu per 1,000 gallons and with sulfur less than or equal

to 0.5%W, so emission factors are taken from Tables 1.3-1 and 3 of AP-42 (9/98), taking the higher

of #1 or #2 values for each pollutant. Calculations of potential to emit are again based on 291.2

MMBtu/hr (2,257 gph) total heat input of all four, but using only 725 hours per year (roughly one

month), as this scenario would be used only in emergency situations.

JET-A

Pollutant Emission factor,

Lbs/1,000 gallons

Emissions

Lbs/hr TPY

PM10 2 4.51 1.64

SO2 142S 160 58.1

NOX 20 45.1 16.4

CO 5 11.3 4.09

NMTOC 0.2 0.45 0.16

Taking the highest emissions from each of the preceding tables and backing out 725 hours of

natural gas emissions where the Jet-A data are larger creates a worst-case scenario.

Pollutant Emissions

Lbs/hr TPY

PM10 4.51 10.52

SO2 160 58.8

NOX 45.1 133

CO 24.4 106

VOC 1.60 6.99


14

Actual emissions from this EUG for 2012 were 2.57 tons of PM10, 0.64 tons of PM2.5, 0.20 tons of

SOX, 33.9 tons of NOX, 28.4 tons of CO, and 1.86 tons of VOC (all non-HAP). Natural gas was

the only fuel consumed.


Given the high efficiency of the collection and destruction systems, overall emissions of chrome

are quite low. Emissions test well below the MACT standard, and annual emissions for 2007 were

calculated to be 0.001 ton. Engineering judgment indicates that future emissions will not exceed

0.01 TPY.


Potential emissions of HAPs were estimated at 76.8 TPY for the original TV permit based on 1998

actual emissions. That is equivalent to 17.5 lbs/hr, assuming continuous operations. Units EP 59-

62 use perchloroethylene, which had 24.4 TPY of 2012 actual emissions, while Units EP-63 and

EP-64 use trichloroethylene, which had 4.05 TPY of actual 2012 emissions.


Emissions of criteria pollutants are estimated based on 1998 calculated actual emissions and

engineering judgment concerning potential to emit. Only for the purpose of these calculations,

Jet-A is assumed to fall somewhere between #1 and #2 fuel oil, with heating content of 129 MMBtu

per 1,000 gallons and with sulfur less than or equal to 0.5%W. Emission factors for NOX, CO, and

TOC are taken from manufacturer’s guarantees or from factors provided by the International Civil

Aviation Organization (ICAO) for the various engines tested. There are eight different engine

types tested (CF6-50C2, CF6-6K2, CF6-80A, CF6-80C2B6, CF6-80C2D1F, CF6-80C2A5, JT8D-

217A, and JT8D-7) and emissions are calculated at four power settings (100%, 85%, 30%, and

7%). Equivalent gallons of fuel are used at each power setting. As might be expected, flow rates

and emissions per flow rate are not direct functions of each other or of power, thus creating many

calculations. Further, different numbers of engines are tested, ranging from a total of only 6,444

gallons for one type up to 384,357 gallons for another type. Because values for PM10 and SO2 were

not given, these factors were estimated using distillate data from Tables 1.3-1 and 3 of AP-42

(9/98), and assuming a sulfur content not exceeding 0.5%W, as was done in calculations for EUG

3 previously. Separate calculations for each engine type are accumulated and presented as TPY

totals for each of NOX, CO, and TOC. PM10 and SO2 TPY calculations are based on 150% of the

total 1,158,832 gallons of Jet-A used in 1998 for all engine types. Lb/hr calculations for each of

the five criteria pollutants represent the worst of all choices for each. An extra column shows

actual emissions for 2012, indicating that sulfur content of Jet-A is significantly less than the worst-

case assumed for the original TV permit.

Pollutant Emission factor,

Lbs/1,000 gallons

Emissions 2012 Actual,

TPY Lbs/hr TPY

PM10 2 6 5 2.58

SO2 142S 217 62 2.33

NOX * 716 93 24.6


15

CO * 105 49 11.2

VOC * 37 12 2.76

*See preceding paragraph for explanation


Potential emissions of 8.91 TPY of combined non-HAP VOC and HAP were estimated for the

original TV permit, using 1998 actual emissions and engineering judgment. Hourly emissions are

highly variable. Actual 2012 emissions were 0.8 tons of non-HAP VOC and 3.14 tons of HAP,

most of which was toluene.


Potential emissions were estimated for the original TV permit at approximately 159 TPY of VOC,

of which 34 TPY was expected to be HAP. Hourly emissions are highly variable. Actual 2012

emissions were 28.5 tons of non-HAP VOC and 0.91 tons of HAP. Toluene was the principle

HAP emitted, at 0.71 tons. Please review the following EUG for further information.

EUG 10 Flush Cleaning

Many solvents used for flush cleaning are also used in hand-wipe solvent cleaning. All solvents

used in this EUG are accounted for with those involved in EUG 9.


Potential emissions were estimated for the original TV permit at approximately 5.7 TPY of

methylene chloride, a volatile HAP (VHAP). No other VOC or HAP was expected to be emitted.

Actual 2012 emissions were 0.32 tons of non-HAP VOC and zero tons of HAP.

EUG 12 Fuel Storage

All tanks were evaluated using EPA Tanks 3.1, but the gasoline tank is the only source with more

than negligible emissions. Actual 2012 emissions of VOC from the gasoline tank are calculated

to be 0.60 tons, all of which is HAP (BTEX).


Emissions from the emergency engines are calculated using emission factors for diesel-fueled

stationary internal combustion engines found in Table 3.3-1 of AP-42 (10/96), and applied to the

17.71 MMBtu/hr combined capacity of all 13 units. TPY is calculated assuming a maximum of

500 hours of operation annually.


16

Pollutant

Emission Factor

(Lbs/MMBtu)

Emissions

Lbs/hr TPY

PM10 0.31 5.49 1.37

SO2 0.29 5.14 1.28

NOX 4.41 78.1 19.5

CO 0.95 16.8 4.21

VOC 0.36 6.38 1.59


Welding/soldering emissions are calculated at a maximum of 1.45 lbs/hr or 0.01 TPY of HAPs.

Particulate emissions from metal spray are estimated at a maximum of 0.06 lbs/hr or 0.29 TPY.

Particulate emissions from blasting, machining, and grinding are estimated at a maximum of 0.05

lbs/hr or 0.19 TPY.

SUMMARY OF POTENTIAL AIR EMISSIONS

PM10 SO2 NOX Non-HAP

VOC

CO HAP

EUG lbs/hr TPY lbs/hr TPY lbs/hr TPY lbs/hr TPY lbs/hr TPY TPY

2 -- 16.5 -- -- -- -- -- 63.1 -- -- 30.6

3 4.51 10.5 160 58.8 45.1 133 1.60 6.99 24.4 106 --

4 -- 0.01 -- -- -- -- -- -- -- -- 0.01

5 -- -- -- -- -- -- -- -- -- -- 76.8

6 6 5 217 62 716 93 37 12 105 49 --

8 -- -- -- -- -- -- -- 8.91* -- -- 8.91*

9 & 10 -- -- -- -- -- -- -- 159 -- -- 34

11 -- -- -- -- -- -- -- -- -- -- 5.7

12 -- -- -- -- -- -- -- 0.77 -- -- 1

13 5.49 1.37 5.14 1.28 78.1 19.5 6.38 1.59 16.8 4.21 --

Insig. Act. 0.11 0.48 -- -- -- -- -- -- -- -- 1.0

TOTALS 16.1 33.9 382 122 839 246 45.0 252 146 159 158

*Not speciated between HAP and non-HAP.

As facility emissions are dependent on the specific maintenance/rework activities conducted and

the number of aircraft on which maintenance is performed, American requested the following

facility-wide TPY emission caps, which were included in Part 70 renewal permit 2008-008-TVR

and will be carried over to this new Permit No. 2014-0382-TVR2.

VOC SO2 PM10 NOx CO

249 148 26 249 178


17

Greenhouse Gasses (GHG)

Estimates of GHG emissions use default combustion factors from 40 CFR 98 Tables C-1 and C-

2, along with global warming potential factors from Table A-1 of 40 CFR 98. Heat input data

shown below are taken from the figures presented earlier for the combustion devices of EUGs 3,

6, and 13, with the same assumptions as those made in calculating criteria pollutant emissions. The

following annual heat input data are converted to kilograms of CO2, CH4, and N2O, then to tons

of each, then to CO2 equivalents (CO2e), and then summed. The total of 42,098 tons of CO2e

indicates that American is not a major source of GHG.

Source MMBtu/year Fuel

EUG 3 2,339,792 Natural gas

211,120 Jet-A

EUG 6 234,663 Jet-A

EUG 13 885 Diesel

SECTION V. OKLAHOMA AIR POLLUTION CONTROL RULES

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

Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-2 (Incorporation by Reference) [Applicable]

This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal

Regulations listed in OAC 252:100, Appendix Q. These requirements are addressed in the

“Federal Regulations” section.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]

Subchapter 3 enumerates the primary and secondary ambient air quality standards and the

significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these

standards.

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

Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission

inventories annually, and pay annual operating fees based upon total annual emissions of regulated

pollutants. Emission inventories were submitted and fees paid for previous years as required.

OAC 252:100-8 (Permits for Part 70 Sources) [Applicable]

Part 5 includes the general administrative requirements for Part 70 permits. Any planned changes

in the operation of the facility which result in emissions not authorized in the permit and that

exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior notification to

AQD and may require a permit modification. Insignificant activities refer to those individual

emission units either listed in Appendix I or whose actual calendar year emissions do not exceed

the following limits.

5 TPY of any one criteria pollutant


18

2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20%

of any threshold less than 10 TPY for single HAP that the EPA may establish by rule

Except as modified herein, the requirements of existing operating permits previously issued by the

DEQ are incorporated into this Title V renewal permit. Authorization for possible future

construction or installation of three new aerospace coating booths, one non-aerospace booth, two

vapor degreasers, one test cell, nineteen spray gun cleaning stations, and two cold cleaning stations

has been granted in previous permits. This permit authorizes two more aerospace booths. The

original list included upgrades and replacements of chromium-related equipment in the Plating

Shop, previously authorized under Permit No. 99-015-C (M-1), which was completed and

recognized in the existing operating permit. The following table indicates the disposition of each

of the previous requests, showing that most of the proposed construction has not occurred. Further

detail may be found in the rules and regulations referenced, as those discussions occur in this

section and in Section VI below. Restrictions or requirements for each authorized item are found

in the Specific Conditions.

Items requested Authorization Citation

Two aerospace booths Yes OAC 252:100-39-47, 40 CFR 63 Subpart GG

One non-aerospace booth Yes Note1

Two vapor degreasers Yes OAC 252:100-39-42, 40 CFR 63 Subpart T

One test cell Yes OAC 252:100-39-8, 40 CFR 63 Subpart PPPPP

19 Spray gun cleaning stations Yes OAC 252:100-39-47, 40 CFR 63 Subpart GG

Two cold solvent cleaning stations Yes OAC 252:100-39-42 1) The existing non-aerospace booth is used for maintenance coating of facility equipment and is not a

permitted activity. A second booth, restricted to similar use, would also be exempt from requiring a

construction permit.

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

Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess

emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following

working day of the first occurrence of excess emissions in each excess emission event. No later

than thirty (30) calendar days after the start of any excess emission event, the owner or operator of

an air contaminant source from which excess emissions have occurred shall submit a report for

each excess emission event describing the extent of the event and the actions taken by the owner

or operator of the facility in response to this event. Request for mitigation, as described in OAC

252:100-9-8, shall be included in the excess emission event report. Additional reporting may be

required in the case of ongoing emission events and in the case of excess emissions reporting

required by 40 CFR Parts 60, 61, or 63.

OAC 252:100-13 (Open Burning) [Applicable]

Open burning of refuse and other combustible material is prohibited except as authorized in the

specific examples and under the conditions listed in this subchapter.

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

Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with

emission limits based on maximum design heat input rating. Fuel-burning equipment is defined

in OAC 252:100-19 as any internal combustion engine or gas turbine, or other combustion device


19

used to convert the combustion of fuel into usable energy. Thus, the boilers in the following table

are subject to the requirements of this subchapter. Appendix C specifies a PM emission limitation

of 0.60 lbs/MMBtu for all equipment at this facility with a heat input rating of 10 MMBtu/hr or

less. Table 1.4-2 of AP-42 (7/98) lists natural gas total PM emissions to be 7.6 lbs/million scf or

about 0.0076 lbs/MMBtu, which is in compliance. Tables 1.3-1 and -2 of AP-42 (9/98) list total PM

emissions as 3.3 lbs/1,000 gallons or about 0.02 lbs/MMBtu, which is in compliance.

COMPARISON OF PM EMISSIONS TO LIMITATIONS OF OAC 252:100-19

Unit

Heat Input Capacity,

MMBtu/hr

Limit per Appendix C,

in lbs/MMBtu

Actual Rate,

lbs/MMBtu*

EP-45 (Boiler) 72.8 0.38 0.016

EP-46 (Boiler) 72.8 0.38 0.016

EP-48 (Boiler) 72.8 0.38 0.016

EP-49 (Boiler) 72.8 0.38 0.016 *Combustion of Jet-A fuel, per Section IV above.

Section 19-12 limits particulate emissions from new and existing directly fired fuel-burning units

and/or emission points in an industrial process. The facility has no directly fired units and those

industrial processes that could cause PM emissions, such as blasting booths, have insignificant

emissions that are in compliance with Subchapter 19.

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

No discharge of greater than 20% opacity is allowed except for short-term occurrences that consist

of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such

periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed

60% opacity. When burning natural gas there is very little possibility of exceeding these standards.

Upon firing Jet-A fuel in EPs-48 and 49, initial performance testing shall be required pursuant to

NSPS Subpart Dc.

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

No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the

property line on which the emissions originated in such a manner as to damage or to interfere with

the use of adjacent properties, or cause air quality standards to be exceeded, or to interfere with

the maintenance of air quality standards. Under normal operating conditions, this facility has

negligible potential to violate this requirement; therefore it is not necessary to require specific

precautions to be taken.

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

Part 5 limits sulfur dioxide emissions from new equipment (constructed after July 1, 1972). This

includes all equipment in EUG 3. For gaseous fuels the limit is 0.2 lbs/MMBtu heat input. The

permit requires the use of pipeline natural gas as defined in Part 72 having 0.5 grains TRS/100 scf

to ensure compliance with Subchapter 31. For liquid fuels such as Jet-A, the limit is 0.8

lbs/MMBtu heat input. This is equivalent to approximately 0.8%W sulfur in the liquid fuel. Thus

a limitation of 0.5%W in the liquid fuel will ensure compliance. The permit requires the use of

liquid fuels with maximum sulfur content of 0.5%W.


20

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

This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or

equal to 50 MMBtu/hr to emissions of 0.2 lbs of NOX per MMBtu, three-hour average. New

liquid-fired fuel-burning equipment is limited to NOX emissions of 0.3 lbs/MMBtu. Boilers EP-

45, 46, 48, and 49 are “new” sources affected by this subchapter. As noted in the emissions

discussion of Section IV above, NOX emissions from natural gas are estimated to be 0.10

lbs/MMBtu, and NOX emissions from Jet-A are estimated to be 0.16 lbs/MMBtu. Both figures are

in compliance with their respective limits.

OAC 252:100-35 (Carbon Monoxide) [Not Applicable]

This subchapter affects gray iron cupolas, blast furnaces, basic oxygen furnaces, petroleum

catalytic cracking units, and petroleum catalytic reforming units. There are no affected sources.

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. Only the 10,000-gallon gasoline

storage tank T-4 (EP-99) has vapor pressure greater than 1.5 psia. It is filled through a permanent

submerged fill pipe, and thus is in compliance.

Part 5 limits the VOC content of coatings used in coating lines and operations. No owner or operator

of any coating line or coating operation with VOC emissions shall use coatings that as applied

contain VOCs in excess of the amounts listed below. OAC 252:100-37-25(a), limits are expressed

in pounds of VOC per gallon of coating, excluding the volume of any water and exempt organic

compounds.

(1) Alkyd primer - 4.8

(2) Vinyls - 6.0

(3) NC lacquers - 6.4

(4) Acrylics - 6.0

(5) Epoxies - 4.8

(6) Maintenance finishes - 4.8

(7) Custom products finish - 6.5

Emissions from the clean-up with VOCs of any article, machine, or equipment used in applying

coatings shall be counted in determining compliance with this rule.

American is subject to this rule. American is an aerospace maintenance and rework facility that is

also subject to the coating limits under OAC 252:100-39-47. American currently uses five hundred

and fifty coatings, of which four categories, epoxies, maintenance finishes, nitrocellulose lacquer

and vinyl can be identified under Subchapter 37. Three hundred and eighty-two coatings are

identifiable in the Appendix N Specialty Coatings Limits of Subchapter 39 and are in compliance

with those limits. The remaining one hundred and sixty-eight coatings are categorized as topcoat

or primer as defined in the aerospace NESHAP 40 CFR 63 Subpart GG and are in compliance with

those limits. The lack of cross-referencing and common terminology to categorize coatings

between Subchapters 37 and 39 has resulted in problems determining whether compliance is

achieved with both rules for facilities such as American that use mostly aerospace coatings.


21

Because of this, it is also difficult to ascertain which rule has the stricter limits. The stricter limits

in Subchapter 39 apply to the more general categories under Subchapter 39 for topcoats and

primers, which are lower than any Subchapter 37 limit. The topcoats and primers in use at

American at this time are subject to and compliant with Subchapter 39’s limit for the general

category of topcoats and primers referred to in §63.745(c) which limits VOC emissions from

primers and topcoats to 2.9 lb/gal and 3.5 lb/gal of VOC content of coating (less water and exempt

solvents) as applied, for primers and topcoats that are not specialty coatings. The AQD is in the

process of reviewing and proposing changes to Subchapter 37 to address unintended

inconsistencies between it and Subchapter 39. In the interim, compliance with OAC 252:100-39-

47 coating limitations shall be deemed to satisfy the requirements of Subchapter 37.

Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize VOC

emissions. Temperature and available air must be sufficient to provide essentially complete

combustion. The boilers and furnaces are designed to provide essentially complete combustion of

organic materials.

OAC 252:100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Part 7 Applicable]

This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of

organic materials from new and existing facilities in Tulsa and Oklahoma Counties.

Section 39-41 requires storage tanks 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. Only gasoline storage tank T-4 (EP-99) has vapor pressure

greater than 1.5 psia. It is bottom filled, and thus in compliance. Subparagraph 39-41(e)(2)(E)

also requires owners/operators of such tanks to obtain a certification from the owner/operator of

the transport/delivery vessels as to compliance with OAC 252:100-39-41(e)(4). The facility has

current certificates to this effect.

Subsection 39-42(a) covers cold cleaning units, noting standards for construction and operation of

such equipment. Paragraph 1 outlines equipment standards, including doors or covers, closed

drainage, and conspicuous labeling. Paragraph 2 describes operating requirements; namely,

appropriate draining procedures and times, keeping the unit covered when not in use, proper storage

and disposal of waste VOC, and stipulates that spraying of VOC can only be in a solid stream.

Paragraph 3 outlines requirements for controls if the VOC’s vapor pressure exceeds certain limits.

Paragraph 4 lists compliance and recordkeeping criteria. Subsection 39-42(a) was not intended to

be applicable to parts washers that utilize aqueous solvents (i.e., cleaning solvents in which water is

the primary ingredient (≥ 80 percent of cleaning solvent solution as applied must be water).

Detergents, surfactants, and bioenzyme mixtures and nutrients may be combined with the water

along with a variety of additives, such as organic solvents (e.g., high boiling point alcohols),

builders, saponifiers, inhibitors, emulsifiers, pH buffers, and antifoaming agents. Aqueous

solutions must have a flash point greater than 93 °C (200 °F) (as reported by the manufacturer),

and the solution must be miscible with water. Accordingly, the various aqueous parts washers (e.g.,

dip tanks, buckets, cans, etc.) intermittently used throughout the facility for various cleaning

purposes (including both metal and non-metal parts, tools, and equipment) are not subject to OAC

252:100-39-42(a).

The facility has requested “preauthorization” for two new units, to be installed as needs arise. The

two units are likely to be well below the 5 TPY threshold for such sources. ODEQ does not require

construction permits for these small sources, but they are subject to the standards of construction and


22

operation outlined earlier in this paragraph. Specific Condition No.1 – Insignificant Activities

describes appropriate procedures to be followed in installing these two proposed units.

Subsection 39-42(b) covers vapor type metal degreasers, noting standards for construction and

operation of such equipment. Paragraph 1 outlines equipment standards including doors and covers

in Subparagraph A; safety switches in Subparagraph B; equipment specifications such as freeboard,

chillers, etc., in Subparagraph C; and conspicuous labeling of the equipment in Subparagraph D.

Paragraph 2 describes the labeling information required to comply with Subparagraph 1(D).

Paragraph 3 lists compliance and recordkeeping criteria. The facility has chosen the control device

identified in (b)(C)(v), stating that compliance with the Halogenated Solvent Cleaning MACT (40

CFR 63, Subpart T) demonstrates efficiency greater than or equal to any of the other options. Further

discussion of the compliance method may be found in Section VI below. All other listed standards

are met for each of the machines.

The facility has requested “preauthorization” for two new units, to be installed as needs arise. Vapor

degreasers typically have emissions in excess of the 2 TPY Subchapter (SC) 8 HAP threshold and

likely in excess of SC 8’s 5 TPY criteria pollutant threshold. If the units are constructed to the

specifications of 40 CFR 63 Subpart T and do not exceed any other threshold that prevent their

consideration as minor modifications to the Part 70 permit, authorization to construct is granted

subject to the requirements of Specific Condition #1, EUG 5.

Section 39-46 concerns coating of metal parts and products of industries located in Tulsa County.

Aerospace activities are specifically excluded per §39-46(a).

Section 39-47 covers requirements specifically applicable to aerospace vehicle and component

coating operations at aerospace manufacturing, rework, or repair facilities located in Tulsa County

that have the potential to emit more than 10 TPY of VOC from coating operations. Coating

operations include associated cleaning operations and surface preparation. This section is modeled

on, and closely tracks, the Aerospace MACT found in federal NESHAP, 40 CFR 63 Subpart GG.

Standards and requirements for VOC content, application equipment, control equipment,

housekeeping measures, solvent cleaning operations, and general standards reference appropriate

sections of GG. Each of these areas will be addressed in greater detail in Section VI. In similar

fashion, monitoring, recordkeeping, and test methods reference appropriate sections of GG. These

will also be addressed in Section VI. The compliance date provisions of §39-47(h) also reference

GG, stating that compliance with GG constitutes a demonstration of compliance with §39-47.

Specialty coatings not covered by GG are covered by 47(d)(1)(A) and Appendix N.

The facility has requested “preauthorization” for two new spray booths and nineteen new gun-

cleaning stations, to be installed as needs arise. Note that the requirements of this section do not

affect the size or shape of any booth, nor do they directly affect what is sprayed in the booth. The

only requirement subject to demonstration is a MACT inorganic HAP requirement that is irrelevant

to this subchapter. A given level of VOC emissions is authorized without regard to the location in

which the various coatings are sprayed. Thus, under the cap granted in this permit, booths may be

constructed under the condition that they satisfy the requirements of other subchapters. Similar logic

applies to the addition of new gun-cleaning stations. Specific Conditions 1 - EUG 2 and 1 - EUG 8

describe appropriate procedures to be followed in installing these proposed units.


23

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable]

This subchapter regulates toxic air contaminants (TAC) that are emitted into the ambient air in

areas of concern (AOC). Any work practice, material substitution, or control equipment required

by the Department prior to June 11, 2004, to control a TAC, shall be retained, unless a modification

is approved by the Director. Since no AOC has been designated there are no specific requirements

for this facility at this time.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable]

This subchapter provides general requirements for testing, monitoring and recordkeeping and

applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To

determine compliance with emissions limitations or standards, the Air Quality Director may

require the owner or operator of any source in the state of Oklahoma to install, maintain and operate

monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All

required testing must be conducted by methods approved by the Air Quality Director and under

the direction of qualified personnel. A notice-of-intent to test and a testing protocol shall be

submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions

and other data required to demonstrate compliance with any federal or state emission limit or

standard, or any requirement set forth in a valid permit shall be recorded, maintained, and

submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any

required testing or monitoring not conducted in accordance with the provisions of this subchapter

shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any

credible evidence or information relevant to whether a source would have been in compliance with

applicable requirements if the appropriate performance or compliance test or procedure had been

performed.

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

OAC 252:100-7 Permits For Minor Facilities not in source category

OAC 252:100-11 Alternative Reduction not eligible

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Feed & Grain Facility not in source category

OAC 252:100-35 Control of Emissions of CO not in source category

OAC 252:100-47 Landfills not in source category


24

SECTION VI. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable]

Final total emissions for the facility are less than the threshold of 250 TPY of a single regulated

pollutant, and the facility is not one of the listed stationary sources with a threshold of 100 TPY.

NSPS, 40 CFR Part 60 [Subpart Dc Applicable]

Subpart Dc (Small Industrial-Commercial-Institutional Steam Generating Units) affects steam

generating units constructed after June 9, 1989, and with capacity between 10 and 100 MMBtu/hr.

Boilers EPs-48 and 49 are affected facilities. If the boilers continue to use only natural gas as fuel,

they are exempt from all requirements of the subpart except for the recordkeeping and reporting

requirements of 40 CFR 60.48c, as further described in 40 CFR 60.7. In the event that these two

boilers are fueled with Jet-A, additional requirements apply. Particulate matter monitoring and

testing are not required for liquid fuels, but opacity must be monitored. Paragraphs 43c(c) and (d)

require that opacity not exceed 20% (6-minute average) with the exception of one 6-minute period

in any hour that may not exceed 27%, at all times except during startup, shutdown, or malfunction.

An initial compliance demonstration requires Reference Method 9 testing. The SO2 emission

limits of §42c(d) include either demonstrating emissions of 0.5 lbs or less of SO2 per MMBtu or

showing that the liquid fuel contains no greater than 0.5%W sulfur. Supplier certification may be

used for this purpose.

Subpart Kb applies to storage vessels constructed or modified after July 23, 1984, which have a

capacity of 75 m3 or more. Tanks T-1, T-2, and T-3 (EPs-96, 97, and 98) are of sufficient capacity

to be affected facilities under Subpart Kb. These three tanks have capacity of 50,000 gallons each

and store Jet-A. These tanks are between 75 m3 and 151 m3 in capacity and the maximum vapor

pressure of Jet-A is well below 15 kPa, thus, per §110b(b), they are not affected facilities.

Subpart IIII (Stationary Compression Ignition Internal Combustion Engines (CI-ICE)) affects

manufacturers, owners, and operators of CI-ICE. The emergency generators and fire pump

engines are all compression ignition (CI-ICE). According to 40 CFR 60.4200(a)(2), affected

sources include “Owners and operators of stationary CI ICE that commence construction after July

11, 2005, where the stationary CI ICE are:

(i) Manufactured after April 1, 2006, and are not fire pump engines; or

(ii) Manufactured as a certified National Fire Protection Association (NFPA) fire pump engine

after July 1, 2006.”

Engines for the existing generators and fire pumps were installed well before 2005 and are not

affected facilities.

Subpart JJJJ, Stationary Spark Ignition Combustion Engines (SI ICE) promulgates emission

standards for all SI engines constructed, modified, or reconstructed after June 12, 2006, regardless

of size. The Waukesha engine for emergency generator EP-112 is the only SI engine potentially

subject to JJJJ. It was constructed/last modified in 1987, and is not an affected facility.


25

NESHAP, 40 CFR Part 61 [Not Applicable]

There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium,

coke oven emissions, mercury, radionuclides, or vinyl chloride.

NESHAP, 40 CFR Part 63 [Subparts N, T, GG, ZZZZ, DDDDD and PPPPP Applicable]

Subpart N (Chromium Emissions from Hard and Decorative Chromium Electroplating and

Chromium Anodizing Tanks). The chrome plating and anodizing tanks of EUG 4 are affected

sources under this MACT. American is considered a large, hard chromium electroplating facility,

which means it performs hard chromium electroplating and has a maximum cumulative potential

rectifier capacity greater than or equal to 60 million ampere-hours per year (amp-hr/yr). All

affected tanks have two stage eliminators in their hoods, and are exhausted to one of two three-

stage composite meshpad scrubbers. The new hard chrome tanks must meet the §63.342(c)(1)(i)

chrome standard of 0.011 mg/dscm, and the anodizing tank must meet the §63.342(d)(1) standard

of 0.007 mg/dscm. Performance testing has shown that both standards are met. On February 13,

2002, Scrubber #6 tested at 0.000816 mg/dscm, in compliance with 0.011. On February 14, 2002,

Scrubber #7 tested at 0.000505 mg/dscm, in compliance with 0.007. The facility shall also practice

certain work practice standards that must be described in a written operating and maintenance

(O&M) plan. The facility has such a plan, prepared by ScrubAir Vent Systems and submitted as

Appendix P of their Part 70 permit application.

Subpart T (Halogenated Solvent Cleaning). Facility vapor degreasers (EPs-59 through 64) are

batch vapor cleaning machines and utilize either perchloroethylene or trichloroethylene,

halogenated HAP solvents specifically named in §63.460(a). All initial notifications, testing, and

reporting were accomplished in a timely manner. Criteria in three areas are considered in

demonstrating compliance, including equipment design, monitoring, and work practices. All units

satisfy the design requirements of §63.463(a), including mode covers, freeboard ratios, automated

parts handling, and automatic switches controlling the sump heater in the event of high or low

liquid levels. All units have primary and secondary condensers and no unit has a lip exhaust.

Monitoring requirements flow from the facility’s intention to comply with §63.463(b)(2)(ii) for

units with solvent/air interface greater than 13 ft2. Idling emission tests were performed according

to RM 307, and temperature is used as the parameter that demonstrates continued compliance. The

hoist speed has been monitored according to §63.466(f), and all other requirements have been met.

Work practices are described in some detail in §63.463(d) and the facility maintains instruction

manuals at hand and trains its operators as to the requirements of this MACT. The facility has

requested pre-approval to install two (2) additional vapor degreasers. Such units are subject to

permitting as individual units, with various notifications and tests required for each unit. The

requested pre-approval is granted, subject to compliance with the requirements of Specific

Condition 1, EUG 5.

Subpart GG (Aerospace Manufacturing and Rework Facilities) applies to facilities that are engaged,

either in part or in whole, in the manufacture or rework of commercial, civil, or military aerospace

vehicles or components and that are major sources as defined in §63.2. The compliance date for the

General Standards is September 1, 1998; however, the MACT standards are applicable upon start-

up for new equipment. Using the numbering convention of 40 CFR 63.741(c), the facility contains

the following affected sources.


26

(1)(i) hand-wipe cleaning operations

All cleaning operations are subject to the “housekeeping” measures of §63.744(a). These

measures include proper disposal of solvent-laden cloths, papers, etc., in closed bags or

containers that are designed to contain the vapors, keeping the containers closed, storing fresh

and spent solvent cleaners in closed containers, and conducting the handling and transfer of

cleaning solvents in a manner that minimizes spills. The facility meets the specific standard

of §63.744(b)(2) that all hand-wipe solvents have a composite vapor pressure of 45 mm Hg

or less at 20ºC. Solvents with HAP/VOC content below 0.1% for carcinogens or 1% for non-

carcinogens are exempt per §63.741(f), as are a number of operations specified in §63.744(e).

(1)(ii) spray gun cleaning operations

Four techniques are approved for use, of which the facility uses two. First is an enclosed

system, where the system is open only while inserting or removing the gun, and cleaning

consists of forcing solvent through the gun. Monthly inspections shall be performed while

the system is in operation, with visual inspection of the seals and other potential sources of

leaks, per §751(a). The second method is to disassemble the guns and either clean them by

hand in a vat, which remains closed except while in use, or by allowing them to soak in a vat

that is opened only while inserting or removing the parts. The housekeeping measures of

§63.744(a) and the exemptions of §63.741(f) apply.

The facility has requested “preauthorization” for nineteen (19) new gun-cleaning stations, to

be installed as needs arise. The requirements of this section do not affect the quantity of

emissions or the location of any gun-cleaning station. Each individual station has emissions

that would probably qualify it as an Insignificant activity in the absence of the MACT

provisions. Finally, the nature of emissions is constant from one station to the next.

Construction of new stations will not require permitting. Specific Condition 1 - EUG 8

describes appropriate procedures to be followed in installing these proposed units.

(1)(iii) flush cleaning operations

Except for spray guns, each time aerospace parts or assemblies or components of a coating

unit are flush cleaned, the used cleaning solvent shall be emptied into an enclosed container

or collection system that is kept closed while not in use. Table 1 or semi-aqueous solvents

are exempt. The facility currently uses only exempt materials, but shall follow these

requirements in the event that non-exempt solvents are used in the future. Housekeeping

measures of §63.744(a) will apply in such an instance.

(2) primer application operations

None of the facility’s spray booth VOC emissions are controlled, so VOC and organic HAP

emissions from all primers are limited to 2.9 lbs/gal (less water and exempt solvents).

Compliance may be shown by maintaining all coatings below the specified limits or by using

monthly weighted averages. The applicant has chosen the former, as described in

§63.745(e)(1). GG lists nine acceptable methods of applying coatings in §63.745(f)(1), of

which the facility uses four: roll coating, brush coating, cotton-tipped swab, and HVLP.

Numerous exemptions to the requirements implicit in these methods are described in

§63.745(f)(3), including limited access spaces, coatings with fillers that adversely affect

coating equipment, certain very thin coatings, airbrush methods for identification markings,

hand-held spray cans, and touch-up or repair.

The facility has requested “preauthorization” for two new spray booths, to be installed as

needs arise. Note that the requirements of this section do not affect the size or shape of any

booth, nor do they directly affect what is sprayed in the booth. The only requirement subject


27

to demonstration is an inorganic HAP requirement, which is required of all booths that may

be used for spraying materials containing inorganic HAPs. VOC emissions are authorized

without regard to the location in which the various coatings are sprayed. Thus, under the cap

granted in this permit, booths may be constructed under the conditions that they satisfy the

requirements of other subchapters. As noted in the discussion of OAC 252:100-39, Specific

Condition 1 - EUG 2 describes appropriate procedures to be followed in installing these

proposed units.

(3) topcoat application operations

VOC and organic HAP emissions from all topcoats are limited to 3.5 lbs/gal (less water and

exempt solvents). Compliance may be shown by maintaining all coatings below the specified

limits or by using monthly weighted averages. The applicant has chosen the former, as

described in §63.745(e)(1), but retains the option of using other methods. Application

methods and exemptions are identical to those listed for primers in paragraph (2) above.

The facility has requested “preauthorization” for two new spray booths, to be installed as

needs arise. See the discussion in (2) immediately preceding. As noted in the discussion of

OAC 252:100-39, Specific Condition 1 - EUG 2 describes appropriate procedures to be

followed in installing these proposed units.

(5) depainting operations

The standards apply only to facilities that depaint more than six completed aerospace

vehicles per year, and to only the depainting of the outer surface areas of the fuselage, wings,

and vertical and horizontal stabilizers. It does not apply to parts normally removed from

the vehicle, but it always applies to wings. Certain exemptions are described in §63.746(a).

The facility complies with §63.746(b)(3), in that it averages less than 26 gallons of organic

HAP-containing solvents or 190 pounds of organic HAP per commercial aircraft depainted.

The standards for military aircraft are 50 gallons and 365 pounds, respectively.

(7) waste storage and handling operations

Per §63.748, except for those wastes subject to RCRA, which are exempt from GG per

§63.741(e), the facility shall conduct the handling and transfer of all wastes that contain HAP

to or from containers, tanks, vats, vessels, and piping systems in such a manner that minimizes

spills.

(8) inorganic HAP emissions

All but nine of the spray booths are considered to be “existing” for purposes of GG. The

booth identified as EP-4 was constructed in 1997, booths EP-245, EP-246, and EP-247 were

constructed in May 2003, booth EP-248 was constructed in December 2006, booth EP-249

was constructed in January 2007, and EP-253 was constructed in January 2009. All seven

booths are “new.” Booths EP-3 and EP-6 were constructed in the interval after 6/6/94 and

before 10/29/96, and have certain options available. EP-19, the “bottle” booth, is used for

coating small objects, and uses only spray cans. Because this is one of the exempt methods,

it does not require filters as described in §63.745(g). EP-39 through EP-44 are emission

points assigned to the various hangar docks. Coating at these locations is either of

components that cannot reasonably be expected to be coated in a booth or uses methods that

are exempt, such as touch-up or hand-held spray cans. These EPs do not require filter

systems. Similar conditions apply at new booths EP-250, 251, and 252. Given these

exceptions, any booth in which coating products containing inorganic HAPs are to be sprayed

must have its airflow directed downward onto or across the part being coated and exhausted

through one or more outlets. For existing booths, the air stream must flow through a dry


28

particulate filter system before exhausting to the atmosphere. The system must be certified

using methods described in §63.750(o) to meet or exceed the efficiency data points of Tables

1 and 2 of §63.745. For new booths, the same design criteria hold, but the certification must

meet the standards of Tables 3 and 4 of §63.745. As noted in the table included in the

equipment description in Section III, all booths that would be required to meet one or the

other of these sets of criteria do so. The facility has opted to treat EP-6 as a new booth,

subject to the same standards as EP numbers 4, 245, 246, 247, 248, 249, and 253. For EP-

3, the facility has opted for the “in lieu” requirements of §63.745(g)(2)(iii), which allow the

use of a two-stage filter. Although this allows the use of inorganic HAPs, coatings

containing chromium or cadmium may be used only if the booth has a HEPA filter or meets

the efficiency requirements of Tables 3 and 4. Since it does not meet these last two

standards, EP-3 may not spray coatings containing cadmium or chromium. Any new booths

constructed per (2) and (3) preceding shall meet the standards of Tables 3 and 4, as well as

all other construction requirements outlined above and below.

In all cases where inorganic HAPs are to be sprayed, dry particulate filters must have a differential

pressure gauge across the filter banks, with the pressure drop monitored continuously and recorded

at least once per shift. Corrective action must be taken if the pressure falls outside the

manufacturer’s recommended range. All booths currently have differential pressure gauges, and

pressure drops (P) are recorded for all booths to provide information for preventive maintenance.

The only regulatory or permit requirement has been to record this information when spraying

inorganic HAPs. The facility will maintain records identifying the manner in which each booth is

used. This will include identification as to whether “critical” parts are being coated, the type of

coating applied, whether a touch-up operation, the presence of inorganic HAPs, and P where

necessary.

Subpart EEEE (Organic Liquids Distribution [Non-Gasoline]) was issued February 3, 2004. The

subpart defines organic liquids as “…any non-crude oil liquid or liquid mixture that contains 5%

by weight or greater of the organic HAP listed in Table 1 of this subpart…” A later portion of this

definition (all of which is found in §63.2406) specifically excludes gasoline (including aviation

fuel) and diesel, inter alia, as well as those fuels that are consumed or dispensed on the property.

Based on these definitions, the facility is not an affected source under EEEE.

Subpart MMMM (Miscellaneous Metal Parts and Products) was promulgated on January 2, 2004.

This coating MACT could affect processes at the facility. Those activities covered by the

Aerospace MACT, including activities requiring MACT standards and those discussed, but not

requiring MACT standards, are specifically exempted from MMMM. Note that this exclusion is

specific as to primers, topcoats, specialty coatings, and methods of application, inter alia, per 40

CFR §63.3881(c)(10 and 11). The facility has stated that all of the activities potentially affected

by MMMM are activities specifically identified in the Aerospace MACT (GG) as affected or

exempt activities, and thus not affected by MMMM. Further, in the event that some future activity

at the facility may be affected by MMMM, §63.3881(i) shows that a facility that has 90% of all

coating activities affected by another coating MACT may use compliance with the terms of that

“predominant” MACT to serve as a demonstration of compliance with MMMM. The latter

demonstration requires the facility to show that 90% of all coating solids used (in gallons) are

affected under the predominant coating MACT. A Specific Condition is not required, but any


29

future activity that is affected by MMMM must be identified, the resulting demonstration be

performed annually thereafter, and the results included in the semi-annual compliance

certification.

Subpart PPPP (Plastic Parts and Products) was issued April 19, 2004. Those activities covered by

the Aerospace MACT, including activities requiring MACT standards and those discussed, but not

requiring MACT standards, are specifically exempted from PPPP. Note that this exclusion is

specific as to primers, topcoats, specialty coatings, and methods of application, inter alia, per 40

CFR 63.4481(c)(11 and 12). The facility has stated that all of the activities potentially affected by

PPPP are activities specifically identified in the Aerospace MACT (GG) as affected or exempt

activities, and thus not affected by PPPP. Further, in the event that some future activity at the

facility may be affected by PPPP, §4481(e)(2) shows that a facility that has 90% of all coating

activities affected by another coating MACT may use compliance with the terms of that

“predominant” MACT to serve as a demonstration of compliance with PPPP. The latter

demonstration requires the facility to show that 90% of all coating solids used (in gallons) are

affected under the predominant coating MACT. A Specific Condition is not required, but any

future activity that is affected by PPPP must be identified, the resulting demonstration be

performed annually thereafter, and the results included in the semi-annual compliance

certification.

Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE) affects new and existing

engines at major and area sources. The 13 emergency engines (EP-105 through 112 and 301

through 305) are existing engines. According to 40 CFR 63.6590(b)(3)(iii), compression ignition

engines EP-105, 107, 108, 109, and 110, all rated at 500 bhp or greater, are not subject to the

requirements of ZZZZ nor to the requirements of Subpart A of Part 63. No initial notification is

required. All other engines shall comply with the work practice standards described in Table 2c

of the subpart, and with the recordkeeping, reporting, and notification requirements of 40 CFR

63.6645, 6650, 6655, and 6660. Table 2c requirements are specifically Item 1 for SI engine EP-

106, and Item 6 for all CI engines.

Subpart DDDDD (Industrial, Commercial and Institutional Boilers and Process Heaters) affects

boilers and heaters located at, or part of, major sources of HAPs. Boilers identified as water heaters

are specifically exempted from the subpart, per 40 CFR 63.7491(d). Autoclaves are specifically

excluded from the definition of “process heater,” per 40 CFR 63.7575. All other boilers and

process heaters are subject to the subpart. Because all units are described as “Units designed to

burn Gas 1 fuels,” no emission limitations apply. Except for normal recordkeeping and

notification requirements, only work practice standards apply, as found in Item 4 of Table 3. These

include one-time energy assessments and a number of inspections, evaluations, reviews, and

reports detailed in paragraphs a through h of Item 4. Compliance with all provisions was required

by January 31, 2016.

Subpart PPPPP (Engine Test Cells/Stands) affects the three existing test cells at the facility.

Existing affected facilities are not subject to any of the requirements of the subpart, per 40 CFR

63.9290(b). The facility has been granted pre-approval to install an additional test cell, subject to

compliance with the requirements of Specific Condition #1 EUG 6.


30

Subpart BBBBBB (Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities)

affects the named equipment at area sources. American is not an area source of HAP and

equipment at the facility does not fit the definitions contained in 40 CFR 63.11100.

Subpart CCCCCC (Gasoline Dispensing Facilities) affects the named equipment at area sources.

American is not an area source of HAP.

CAM, 40 CFR Part 64 [Not Applicable]

This part applies to any pollutant-specific emission unit at a major source that is required to obtain

an operating permit, for any application for an initial operating permit submitted after April 18,

1998, that addresses “large emissions units,” or any application that addresses “large emissions

units” as a significant modification to an operating permit, or for any application for renewal of an

operating permit, if it meets all of the following criteria.

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

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

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

of 100 TPY

The facility is subject to emission limits and uses some pollution control devices to achieve

compliance, but none of the individual units controlled by the devices has the potential to emit 100

TPY. While two of the HCl tanks addressed in the Insignificant Activities list are indicated to have

uncontrolled emissions in excess of 100 TPY, this calculation was performed using a model suggested

by EPA. Note that the EPA model assumes a continuous supply of unsaturated air at the tank surface,

essentially positing an infinite sink. Calculation of emissions for identical tanks in other American-

operated facilities is done by material balance, which is a more reliable estimate of emissions.

Although none of the tanks in the other facilities is controlled by a scrubber, none reaches the major

source CAM level for HAP (10 TPY), much less the 100 TPY criterion for non-HAP. Since material

balance calculations for the present tanks show less than 1 TPY of emissions and since the scrubbers

are 99% efficient, it seems unlikely that the uncontrolled values could be as high as the EPA model

suggests. These two tanks are not considered to be subject to CAM.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable]

This facility does not process or store more than the threshold quantity of any regulated substance

(Section 112r of the Clean Air Act 1990 Amendments). More information on this federal program

is available on the web page: www.epa.gov/rmp.

Stratospheric Ozone Protection, 40 CFR Part 82 [Applicable]

These standards require phase out and reductions of emissions of Class I & II substances, and other

actions. Compliance with applicable requirements is required pursuant to Section XX of the

Standard Conditions.

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=72950136f92c6bca6f748cca239c55ba&rgn=div6&view=text&node=40:14.0.1.1.1.14&idno=40

http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=72950136f92c6bca6f748cca239c55ba&rgn=div6&view=text&node=40:14.0.1.1.1.14&idno=40

http://www.epa.gov/rmp


31

SECTION VII. COMPLIANCE

Inspection

On Thursday, June 15, 2017, between the hours of 0945 and 1200, an unannounced air quality full

compliance evaluation was conducted at the facility. Helen King, Environmental Programs

Specialist with the Oklahoma Department of Environmental Quality – Air Quality Division in

Tulsa conducted the evaluation. Ms. Thelma Latimer-Davis, Manager Environmental

Engineering, and Mr. Donald Pugh, Engineer E&S Department, represented the facility. No

violations were indicated in the July 10, 2017, inspection report.

Tier Classification and Public Review

This application has been determined to be a Tier II based on the request for renewal of a Part 70

permit for an existing major source. Public notice of filing of this application was published in the

Tulsa Daily Commerce & Legal News on March 24, 2014. The notice stated that the application

was available for review at the DEQ Regional Office at Tulsa and at the Oklahoma City office of

the Air Quality Division. Public notice of the 30-day public review opportunity for the draft permit

will be published in a newspaper with general circulation in Tulsa. Copies of the draft will be

made available at the DEQ Regional Office at Tulsa and at the Oklahoma City office of the Air

Quality Division. This site is not within 50 miles of the Oklahoma border.

The applicant has submitted an affidavit that they are not seeking a permit for land use or for any

operation upon land owned by others without their knowledge. The affidavit certifies that the

applicant has provided legal notice to those that do own the property. Information on all permit

actions is available for review by the public in the Air Quality section of the DEQ Web page:

www.deq.state.ok.us/.

Fee Paid

Major source operating permit renewal fee of $7,500.

SECTION VIII SUMMARY

There are no compliance or enforcement issues concerning this facility that would prevent the

issuance of this permit. Issuance of the renewal Part 70 operating permit is recommended, pending

public and EPA review.

http://www.deq.state.ok.us/

DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

American Airlines, Inc. Permit No. 2014-0382-TVR2

Tulsa Maintenance and Engineering Center

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

on March 14, 2014. The Evaluation Memorandum dated March 8, 2019, explains the derivation of

applicable permit requirements and estimates of emissions; however, it does not contain operating

limitations or permit requirements. Continuing operations under this permit constitutes acceptance

of, and consent to, the conditions contained herein.

1. Points of emissions and emission limitations for each point. Note that the facility has requested

facility-wide caps on emissions, so limits are not applied to individual EUGs.

[OAC 252:100-8-6(a)]

EUG 1 Facility-Wide

The following TPY emission limits apply facility-wide. [OAC 252:100-8-6(a)]

NOX VOC CO SO2 PM10

249 249 178 148 26

Advance Approval. The permittee is granted advance approval to implement specific proposed

activities (see EUGs 2, 5, 6, 7, 8, and 10) for which additional, modified, or deleted monitoring,

recordkeeping, and reporting (MRR) requirements are provided within each affected EUG section.

Operational Flexibility Changes. In addition to the above advance approvals, the permittee is also

authorized to implement the following types of “operational flexibility” at the facility subject to

the following restrictions. Such changes shall not require a construction permit or change to the

existing operating permit but will be incorporated administratively into the next regular Title V

permit update.

Types of Operational Flexibility Changes:

a. Addition of new sources (units) of emissions is allowed. Examples include natural

gas fired boilers and process heaters individually under 10 MMBtu/hr input heat

capacity, internal combustion engines (such as emergency and non-emergency

generators), calibration test stands, and emission units engaged in cleaning,

depainting, surface coating operations (including paint booths), and petroleum

storage.

b. Modification of existing sources (units) of emissions and control devices is

allowed.

c. Substitution or introduction of new materials and production of new products is

allowed.

SPECIFIC CONDITIONS 2014-0382-TVR2 DRAFT 2

Restrictions:

a. All Operational Flexibility Changes shall result in compliance with the above-

referenced facility-wide emission limits.

b. An Operational Flexibility Change shall not result in the creation of a new major

source by itself. This means that the increase in emissions from any individual

source shall not exceed the threshold of 100 tpy for any criteria pollutant or an

increase of Hazardous Air Pollutant (HAP) emissions beyond the 10/25 tpy

threshold.

c. A record of each Operational Flexibility Change and its associated emissions shall

be maintained on-site. The record shall be maintained for at least five years after

the date of the Operational Flexibility Change.

d. No Operational Flexibility Change shall be classified as reconstruction of a major

affected source under 40 CFR Part 63. “Reconstruction” shall mean the

replacement of components of an affected or previously unaffected stationary

source to the extent that:

(1) The fixed capital cost of the new components exceeds 50 percent of the fixed

capital cost that would be required to construct a comparable new source.

(2) It is technologically and economically feasible for the reconstructed source to

meet the relevant standard(s) established by the Administrator (or Oklahoma

DEQ) pursuant to section 112 of the Act. Upon reconstruction, an affected

source, or stationary source that becomes an affected source, is subject to

relevant standards for new sources, including compliance dates, irrespective of

any change in emissions of hazardous pollutants from that source.

e. An Operational Flexibility Change shall not be considered a physical change that

would be a “significant” modification under OAC 252:100-8-7.2(b)(2). Significant

modification procedures shall be used for applications requesting permit

modifications that:

(1) Involve any significant changes in existing monitoring requirements.

(2) Relax any reporting or recordkeeping requirements.

(3) Change any permit condition that is required to be based on a case-by-case

determination of an emission limitation or other standard, on a source-specific

determination of ambient impacts, or on a visibility or increment analysis.

(4) Seek to establish or change a permit term or condition for which there is no

corresponding underlying applicable requirement or state-only requirement

which the source has assumed to avoid some other applicable requirement or

state-only requirement to which the source would otherwise be subject.

(5) Are modifications under any provision of Title I of the Act. Such changes

would be “modifications” as defined under NSPS, NESHAP, PSD, and non-

attainment areas.

(6) Do not qualify as minor permit modifications or administrative amendments.


All booths have dry particulate filter systems. The PM numbers refer to the facility’s preventive

maintenance system, while the alphanumeric groups in parentheses are used in a coordinate system

for locating each piece of equipment. The “GG Tables” column refers to the particulate standards

that must be met per 40 CFR 63.745(g).


EU ID#

EP #

Booth name

Preventive Maintenance

# and location

Const./Mod

Date

GG Table

TEO-PB3 3 Hydraulic shop PM7862445 [g4(mez)] 10/25/94 In lieu

TEO-PB4 4 Landing gear shop PM7862447 (c4) 1/17/97 3 & 4

TEO-PB5 5 Metal spray PW PM7862438 (j4) 12/4/91 1 & 2

TEO-PB6 6 GE blade & vane PM9666962 [g24(mez)] 9/60 – 6/96 3 & 4

TEO-PB8 8 Sub-support PM7862413 [c33(mez)] 1987 1 & 2

TEO-PB11 11 CF6-80 cold shop/

LP fan

PM7862444 (d44) 11/1/90 1 & 2

TEO-PB12 12 GE metal spray PM7862419 (j45) 1987 1 & 2

CAM-PB13 13 Miscellaneous valves PM7861041 (b2) 1/1/59 1 & 2



CAM-PB16 16 Thrust reverser paint PM7860814 (d4) 3/88 1 & 2

CAM-PB17 17 CSD/ Generator PM7862412 (a7) 1988 1 & 2

CAM-PB18 18 WB seat shop PM7861699 (f8) 1988 1 & 2





CAM-PB24 24 Auto Pilot, Nav &

Radar

PM7862453 (c15) 1988 1 & 2


Radar

PM7861033 (f15) 1988 1 & 2


Radar

PM7862454 (f15) 1988 1 & 2

CAM-PB27 27 Elec. & Flt. Instr. PM7861061 (a17) 7/58 1 & 2

CAM-PB28 28 Gyroscope PM7861062 (a17) 1958 1 & 2

CAM-PB29 29 Electric accessories PM7862452 (f18) 1988 1 & 2

TC1/2-PB30 30 NB thrust reverser PM7862436 (b8) 1958 1 & 2

H1/2-PM32 32 NB door & structure PM7862449 (c1) 1990 1 & 2

H1/2-PB33 33 Structures shop PM7861207 [c6(mez)] 1/1/90 1 & 2

H3/4-PB35 35 Flight controls PM7860812 (a1) 3/11/85 1 & 2

H3/4-PB36 36 Interior PM7862423 (c6) 1988 1 & 2

H6-PB38 38 HGR 6 Paint &

fiberglass

PM7862437 (b7) 2/15/91 1 & 2

H1-D39 39 Not applicable (N/A) Hangar #1 Dock Area(s) N/A N/A






TEO-PB A 245 Heat treat & paint PM9666974 (g4s) May 2003 3 & 4

TEO-PB B 246 Heat treat & paint PM9666973 (g4s) May 2003 3 & 4

TEO-PB C 247 Heat treat & paint PM9666972 (g4s) May 2003 3 & 4

H1/2-PB248 248 HGR 2 Paint &

fiberglass PM7865443(a21) 12/13/06 3 & 4

H1/2-PB249 249 HGR 2 Paint &

fiberglass PM7865444(a21) 1/11/07 3 & 4


EU ID#

EP #

Booth name

Preventive Maintenance

# and location

Const./Mod

Date

GG Table

TEO-PB250 250 Tool and Die

Touchup

PM7861100 2004 Exempt*

TEO-PB251 251 Bearing PM7862460 2004 Exempt*

HE-PB252 252 Tool and Die

Touchup

PM7865426 2004 Exempt*

TEO-PB253 253 Landing Gear Small

Part

PM7865753 2/1/09 3 & 4

TBD TBD Proposed TBD TBD TBD

TBD TBD Proposed TBD TBD TBD

* The only spraying done is with aerosol cans.

The facility has been authorized to install two additional spray booths subject to MACT GG in

EUG 2. These booths, as well as others as needed in the future, may be constructed without further

or prior notice to DEQ, provided that the following conditions are met.

a) The booth shall be capable of meeting the standards of MACT GG and shall not have the

potential to emit (PTE) any inorganic HAP that equals or exceeds 10 TPY or for which the

aggregate PTE of all inorganic HAP equals or exceeds 25 TPY. Other conditions are

described in Specific Condition #12.

b) Recordkeeping, as described in Specific Condition #22 (i) and (j), shall be maintained from

the day of first operation.

c) The DEQ shall be notified of the construction of each new emission unit affected MACT

GG no later than the next March 1 following the construction date, per 40 CFR

63.743(a)(10).

d) Information about the location, preventive maintenance number, filter system, Emission

Point number and other descriptive information shall be included in the notice of first

operation and shall be added to the Part 70 permit at renewal.

EUG 3 – Boilers

EU ID# EP #

Preventive

Maintenance #

Capacity,

MMBTUH Const/Mod Date

TEO-B1 45 PM2149214 72.8 6/28/88

TEO-B2 46 PM2149215 72.8 6/28/88

H6-B4 48 PM2149216 72.8 1/15/91

H6-B5 49 PM2149217 72.8 1/15/91

EUG 4 – Chrome Plating

Scrubber #6 is identified as EP-57 and Scrubber #7 is EP-58.

EU ID# Scrubber # Tank # and service Const/Mod Date

PS T80 6 80 – Anodize 8/26/93

NCR 105 6 105 – Chromic acid 2002

NT 4 6 4 –Chrome reverse etch 2002

NCR 6 6 6 –Chrome plate 2002


EU ID# Scrubber # Tank # and service Const/Mod Date














PS 143a 6 143a – Out-of-tank chrome pad 2002

PS 143b 6 143b – Out-of-tank chrome pad 2002

PS 143c 6 143c – Out-of-tank chrome pad 2002


PS 144a 6 144a – Out-of-tank chrome cabinet 2002

EUG 5 – Halogenated Vapor Degreasers

EU ID# EP # Preventive Maintenance # and Service Const/Mod Date

PS-VD1 59 PM7899882 (T158)(Non-VOC) 3/89 / 2/98

PS-VD2 60 PM7899879 (T159) (Non-VOC) 8/94

PS-VD3 61 PM7899869 (T160) (Non-VOC) 3/89

PS-VD4 62 PM7899878 (T161) (Non-VOC) 8/94

TEO-VD5 63 PM7899883 (landing gear) 1990 / 2/98

TEO-VD6 64 PM7899884 (blade and vane) 1990 / 2/98

TBD TBD TBD TBD

TBD TBD TBD TBD

The facility is authorized to install two additional vapor degreasers in EUG 5. These vapor

degreasers may be installed without additional DEQ approval and without modification of this

permit, provided the following conditions are met.

(a) Each vapor degreaser shall be capable of meeting the standards specified in 40 CFR Part

63, Subpart T.

(b) Recordkeeping, as described in Specific Condition #22(g) shall be maintained from the day

of first operation.

(c) The DEQ shall be notified of the construction of each vapor degreaser at least seven days

before construction commences and shall be notified of first operation within ten days of

such event.

(d) Information about the location, preventive maintenance number, emission point number,

and any other helpful information shall be included in the notice of first operation and shall

be added to the Part 70 permit at renewal.


EUG 6 – Engine Test Cells

EU ID# EP # EU Name Const/Mod Date




TBD TBD TBD TBD

The facility is authorized to install an additional test cell in EUG 6. This test cell may be installed

without further DEQ approval and without modification of this permit, provided the following

conditions are met.

(a) The new test cell shall be capable of meeting the standards specified in 40 CFR Part 63,

Subpart PPPPP, including recordkeeping and reporting requirements.

(b) All required notifications as described in 40 CFR 63.9345 shall be submitted to the DEQ.

In particular, notification of first operation of the new cell shall be provided no less than

120 days after such event.

(c) Information about the location, preventive maintenance number, emission point number,



EUG 7 – Coating Operations Not Subject To Aerospace Standards


FM-PB1 71 Paint Booth – PM7860813 May 1989

FUG-1 72 Fugitive coatings throughout the Center N/A

TBD TBD TBD TBD

The facility is authorized to install an additional unit without further DEQ approval and without

modification of this permit, subject to the following conditions.

a) The unit shall be used for maintenance coating activities only. Any other non-aerospace

purpose for either the proposed booth or the existing booth may require compliance with the

standards of OAC 252:100-37-25 (Coating of Parts and Products) and will require an

Applicability Determination as a minimum requirement before construction.

b) The DEQ shall be notified of the construction of the booth at least seven days before

construction commences and shall be notified of first operation within ten days of such

event.

c) Information about the location, preventive maintenance number, Emission Point number,



EUG 8 – Spray Gun Cleaning

EU ID# EP # Preventive Maintenance No. and Location

TEO-PG1 75 PM9605164 (C3)

TEO-PG2 76 PM9605820 (C3)

TEO-PG4 78 PM9605218 (g45)


EU ID# EP # Preventive Maintenance No. and Location

CAM-PG3 81 PM9633117 (f11)

TC-PG1 82 PM9633120

TC-PG2 83 PM9633121

H 1/2-PG1 85 PM9633115 (a21)

H 1/2-PG2 86 PM9605174

H 3/4-PG1 87 PM9605176 (c6mez)

H6-PG1 91 PM9633119 (b7)

FUG 91A Disassembled Spray Gun Cleaning

TBD (19) TBD TBD (19)

The facility is authorized to install up to 19 additional units that may be added without further DEQ

approval and without modification of this permit. Such units shall be subject to the following

conditions.

a) Each unit shall meet the design criteria, work practice standards, and inspection requirements

described in Specific Condition #17.

b) Recordkeeping, as described in Specific Condition #22 (m), shall be maintained from the

day of first operation.

c) The DEQ shall be notified of the construction of each unit in the semiannual report

following construction of the unit, per 40 CFR 63.753.

d) Information about the location, preventive maintenance number, Emission Point number,



EUG 9 – Hand-wipe Solvent Cleaning

EU ID# Emission Point EU Name Const/Mod Date

FUG-2 EP-92 Hand-wipe Solvent

Cleaning

N/A

EUG 10 – Flush Cleaning Operations


FUG-3 93 Flush Cleaning Operations N/A

CAM-OS2 74 Organic Solvent Cleaning (Isopropyl Alcohol) N/A

TBD TBD TBD TBD

The facility is authorized to install two additional cold metal organic solvent flush cleaning units

without further DEQ approval and without modification of this permit, except that DEQ shall be

notified of the construction of any static, non-movable unit in the semi-annual report following

construction of the unit.

EUG 11 – Aircraft Depainting

EU ID# Emission Point EU Name Const/Mod Date

FUG-5 EP-95 Depainting Operations N/A


EUG 12 – Fuel Storage


96 Jet-A Fuel Tank 1 (T-1) 50,000 1988

97 Jet-A Fuel Tank 2 (T-2) 50,000 1988

98 Jet-A Fuel Tank 3 (T-3) 50,000 1988

99 Unleaded Gasoline Tank 4 (T-4) 10,000 1988

102 Jet-A Fuel Tank 8 (T-8) 13,000 1988

EUG 13 - Emergency Engines

Emission Point Manufacturer HP/MMBTUH Serial Number Construction

Diesel-fueled Emergency Generator Engines


EP-106 Onan 390/0.85 TUL084 1989

EP-107 Caterpillar 610/1.20 8576 1987


EP-109 Caterpillar 890/2.05 20723 2000

EP-110 Caterpillar 671/1.71 20880 2000

EP-111 Cummins 168/0.43 10036 1988

EP-112 Waukesha 216/0.55 TUL137 1987

Jet A-fueled Fire Pump Engines






*1.5 MMBTUH is a conservatively high estimate of heat input.


Space heaters and emergency flares less than or equal to 5 MMBTU/hr heat input (commercial natural

gas). The facility has numerous space heaters.

*Emissions from dispensing equipment operated solely for facility-owned vehicles if fuel throughput

is not more than 2,175 gallons per day, averaged over a 30-day period. Records of fuel dispensed per

month shall be maintained.

*Storage tanks with less than or equal to 10,000 gallons capacity that store volatile organic liquids

with a true vapor pressure (TVP) less than or equal to 1.0 psia at maximum storage temperature.

Records of type of material stored and its TVP shall be maintained.


100 Jet-A Tank 6 (T-6) 3,000 1988

101 Jet-A Tank 7 (T-7) 8,000 1988

TBD Used Oil (T-5) 2,000 Unknown

Alkaline/phosphate washers and associated burners.

Cold degreasing operations utilizing solvents that are denser than air.


Wood chipping operations not associated with the primary process operation.

Hazardous waste and hazardous materials drum staging areas.

Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous

waste satellite (accumulation) areas.

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

Sufficient records and/or calculations to show the continued insignificant status of each of the

following shall be maintained.

a) metal spray booths

b) tanks containing acid solutions, nickel and other materials

c) welding and soldering

d) plasma arc cutting booth

3. The facility is authorized to operate continuously, or 24 hours per day, every day of the year.

[OAC 252:100-8-6(a)]

4. The fuel-burning equipment shall be fired with pipeline natural gas as defined in Part 72 having

0.5 grains/100 scf or less total sulfur. Compliance can be shown by a current gas company

bill, lab analysis, gas contract, tariff sheet, or other approved methods. Boilers EP-45, 46, 48,

and 49 are authorized to burn Jet-A fuel a combined total of 48 hours during any calendar year

for periodic testing, maintenance, or operator training and may burn Jet-A fuel during periods

of gas curtailment or gas supply interruptions. In the event that Jet-A is used as an alternate or

emergency fuel, the sulfur content may not exceed 0.5%W. Compliance can be shown by the

supplier’s latest delivery ticket(s). Compliance for each fuel shall be demonstrated at least

once per calendar year. [OAC 252:100-31]

5. The facility shall record and maintain records of the amount of each type of fuel combusted by

boilers EP-48 and 49 daily. In the event that no fuel other than natural gas is combusted, there

are no further requirements. If these two boilers are fueled with Jet-A, opacity and SO2

emissions shall be monitored. Opacity shall not exceed 20% (6-minute average) with the

exception of one 6-minute period in any hour that may not exceed 27%, at all times except

during start-up, shutdown, or malfunction. Initial compliance shall be demonstrated by

Reference Method (RM) 9 testing. Daily visible emission monitoring using RM 22 shall be

performed during all periods of combusting Jet-A. If visible emissions are observed, RM 9

will be used to verify compliance. Compliance with the SO2 emission limits shall be

demonstrated by compliance with Specific Condition #4.

[OAC 252:100-2, 40 CFR 60.40c, et seq.]

6. Scrubber #6 and Scrubber #7 chrome emissions shall not exceed 0.011 mg/dscm. When

anodizing Tank 80 is operating, chrome emissions of Scrubber #6 shall not exceed 0.007

mg/dscm. Initial performance testing has shown that both standards are met for each scrubber.

Continued compliance shall be demonstrated by maintaining the pressure drop across scrubber

#6 within a range of 2.22 2, and maintaining the pressure drop across scrubber #7 within a

range of 2.14 2. Pressure drop shall be recorded at least once each day that the units are

operating. The facility shall also practice certain work practice standards that must be


described in a written operating and maintenance (O&M) plan as detailed in 40 CFR 63.342(f).

Actions taken under the O&M plan shall be documented. [40 CFR 63.340, et seq.]

7. Facility vapor degreasers (EPs-59 through 64) shall maintain compliance with equipment

design criteria, including mode covers, freeboard ratios, automated parts handling, automatic

switches controlling the sump heater in the event of high or low liquid levels, and a

conspicuous label summarizing operating requirements. Work practices or operating

requirements are described in detail in both 40 CFR 63.463(d) and OAC 252:100-39-42(b)(2).

Monitoring requirements include visual inspections of equipment, such as the cover, and

certain measurements. The facility tested idling emissions to demonstrate initial compliance,

so temperature shall be measured once each week at the center of the air blanket during idling

mode. The table below shows the maximum acceptable temperatures determined by initial

performance testing. Maximum hoist speed shall not exceed 11 feet per minute (fpm).

Periodic testing of hoist speed at the time of this renewal application is quarterly. An

exceedance of the 11 fpm standard at any time shall cause testing to revert to monthly. Upon

completion of a full year of monthly testing without an exceedance, testing frequency may

return to quarterly. [OAC 252:100-39-42, 40 CFR 63.460, et seq.]

EP # Temperature

59 67F

60 78F

61 82F

62 81F

63 69F

64 64.7F

8. The facility contains the following affected sources subject to the Aerospace MACT Standard

(40 CFR 63, Subpart GG) and shall comply with applicable provisions of Subpart GG subject

to the exemptions and exclusions specified in 40 CFR § 63.741(f) through (j).

[40 CFR 63, Subpart GG]

A. Each cleaning operation, exclusive of the use of strippers and cleaning solvents that meet

the definition of “non-HAP material” per 40 CFR § 63.742.

i. All hand-wipe cleaning operations

ii. Each spray gun cleaning operation

iii. All flush cleaning operations

B. Organic HAP or VOC emissions.

i. Each primer application operation (total of all primer applications at the facility),

exclusive of primers meeting the definition of “non-HAP material” or “classified

national security information” per 40 CFR § 63.742 and low-volume primers for which

the annual total of each separate formulation used at the facility does not exceed 50

gallons, and the combined annual total of all such primers, topcoats, specialty coatings,

and chemical milling maskants used at the facility does not exceed 200 gallons;

ii. Each topcoat application operation (total of all topcoat applications at the facility),

exclusive of topcoats meeting the definition of “non-HAP material” or “classified


national security information” per 40 CFR § 63.742 and low-volume topcoats for which

the annual total of each separate formulation used at the facility does not exceed 50

gallons, and the combined annual total of all such primers, topcoats, specialty coatings,

and chemical milling maskants used at the facility does not exceed 200 gallons;

iii. Each specialty coating application operation (total of all specialty coating applications

at the facility), exclusive of specialty coatings meeting the definition of “non-HAP

material” or “classified national security information” per 40 CFR § 63.742 and low-

volume specialty coatings for which the annual total of each separate formulation used

at the facility does not exceed 50 gallons, and the combined annual total of all such

primers, topcoats, specialty coatings, and chemical milling maskants used at the facility

does not exceed 200 gallons; and

iv. Each depainting operation (total of all depainting at the facility).

C. Each chemical milling maskant application operation, exclusive of chemical milling

maskants that meet the definition of “non-HAP material” and low-volume chemical milling

maskants for which the annual total of each separate formulation used at the facility does

not exceed 50 gallons, and the combined annual total of all such primers, topcoats, specialty

coatings, and chemical milling maskants used at the facility does not exceed 200 gallons;

D. Each waste storage and handling operation, which is the total of all waste handling and

storage at the facility; and

E. Inorganic HAP emissions.

i. Each spray booth, portable enclosure, or hanger that contains a primer, topcoat, or

specialty coating application operation subject to Subpart GG; or

ii. A depainting operation subject to 40 CFR § 63.746(b)(4).

F. Waterborne coatings with reduced organic HAP and VOC contents are exempt from certain

requirements pursuant to 40 CFR § 63.741(i).

9. Pursuant to § 63.749(a)(3), American’s existing specialty coating application operations shall

comply with the applicable specialty coating requirements of Subpart GG no later than

December 7, 2018. For any specialty coating application operation that begins construction or

reconstruction after February 17, 2015, American shall comply with the applicable specialty

coating requirements of Subpart GG upon startup. [40 CFR 63, Subpart GG]

10. The following organic HAP and VOC limits apply for the indicated coatings that are

uncontrolled unless such coatings are excluded pursuant to Specific Condition 12:

Organic HAP emissions from primers shall be limited to an organic HAP content level of 2.9

pounds per gallon (ppg) of primer as applied, less water. VOC emissions from primers shall

be limited to a VOC content level of 2.9 ppg of primer (less water and exempt solvents) as

applied. Organic HAP emissions from topcoats and self-priming topcoats shall be limited to

an organic HAP content level of 3.5 ppg of topcoat as applied, less water. VOC emissions

from topcoats and self-priming topcoats shall be limited to a VOC content level of 3.5 ppg of

topcoat (less water and exempt solvents) as applied. Organic HAP emissions from specialty

coatings shall be limited to an organic HAP content level not to exceed the HAP content limit

specified in Table 1 of 40 CFR § 63.745 for the applicable specialty coating. VOC emissions

from specialty coatings shall be limited to a VOC content level not to exceed the VOC content

limit specified in Table 1 of 40 CFR § 63.745 for the applicable specialty coating type. For


purposes of demonstrating compliance, American may use VOC data as a surrogate for HAP

content less and excepting those situations when HAP content exceeds VOC content.

a) Compliance with applicable HAP and VOC content limits shall be accomplished by using

the following methods either by themselves or in conjunction with one another.

(1) Use of primers, topcoats (including self-priming topcoats), and specialty coatings with

HAP and VOC content levels equal to or less than the limits specified in 40 CFR §

63.745(c)(1) through (c)(6); or

(2) Use the averaging provisions described in 40 CFR § 63.743(d). Note that this method

is accomplished on a calendar-month basis.

b) If American elects to comply with the organic HAP and VOC content limits specified in

40 CFR § 63.745(c)(1) through (c)(6), American shall record the following information, as

appropriate, utilizing its master inventory system:

(1) The name and VOC content as received and as applied of each primer, topcoat, and

specialty coating used at the facility.

(2) For uncontrolled primers, topcoats, and specialty coatings that meet the organic

HAP and VOC content limits without averaging:

(A) Mass of organic HAP emitted per unit volume of coating as applied (less water)

(Hi) and the mass of VOC emitted per unit volume of coating as applied (less water and

exempt solvents) (Gi) for each coating formulation within each coating category used

each month (calculated using the procedures specified in § 63.750(c) and (e));

(B) All data, calculations, and test results used in determining the values of Hi and Gi;

and

(C) The volume (gal) of each coating formulation within each coating category used

each month.

(3) For “low HAP content” uncontrolled primers with organic HAP content less than

or equal to 2.1 lb/gal (less water) as applied and VOC content less than or equal to 2.1

lb/gal (less water and exempt solvents) as applied:

(A) Annual purchase records of the total volume of each primer purchased; and

(B) All data, calculations, and test results used in determining the organic HAP and

VOC content as applied. These records shall consist of the manufacturer’s certification

when the primer is applied as received, or the data and calculations used to determine Hi

if not applied as received.

c) For primers and topcoats complying with the organic HAP and VOC content level by

averaging, all provisions of §63.743(d) shall be followed. Specifically, the facility shall

calculate the monthly volume-weighted average masses of organic HAP emitted per unit

volume of coating as applied (less water) (Ha) and of VOC emitted per unit volume of coating

as applied (less water and exempt solvents) (Ga) for all coatings (as determined by the

procedures specified in §63.750(d) and (f)), and shall retain all data, calculations, and test

results used to determine the values of Ha and Ga.

11. For any future use of controlled coatings, each control system shall reduce the organic HAP and

VOC emissions to the atmosphere by 81% or greater, taking into account capture and destruction

or removal efficiencies.


12. Unless exempted pursuant to §63.745(f)(3), primers, topcoats (including self-priming topcoats),

and specialty coating application operations subject to Subpart GG and in which any of the

coatings contain organic HAP or VOC shall comply with the provisions of §63.745(f)(1) and

(2). [OAC 252:100-39-47(d)(1)(B), 40 CFR 63.745]

13. All coatings not subject to the requirements of 40 CFR 63 Subpart GG or OAC 252:100-39-

47 are subject to the requirements of OAC 252:100-37. Standards for VOC content of various

types of coatings are specified in OAC 252:100-37-25(a); however, if less than 100 pounds per

day of VOC are emitted from such operations, all coatings are exempt from Section 37-25.

Adequate records shall be maintained to demonstrate either exemption from the section or

adherence to the standards of OAC 252:100-37-25(a). [OAC 252:100-37-25]

14. Except as provided in §63.745(g)(4), primer, topcoat, or specialty coating application

operations subject to Subpart GG in which any of the coatings that are spray-applied and

contain inorganic HAPs shall comply with the applicable requirements of §63.745(g)(1)

through (3). All booths are currently capable of meeting these requirements, noting that

differential pressure (ΔP) readings are required when spraying such coatings. Coatings

containing cadmium or chromium shall not be sprayed in booth #3 (EP-3). Current systems

and any new systems installed shall have sufficient documentation to demonstrate that the

standards have been met and that recordkeeping shows compliance with the appropriate P for

the system. [40 CFR 63.745(g)]

15. The requirements for primers, topcoats, specialty coatings, and chemical milling maskants

described in 40 CFR 63.745, 40 CFR 63.747, and OAC 252:100-39-47(d), do not apply to the

use of low volume coatings for which the annual total of each separate formulation used at the

facility does not exceed 50 gallons and the combined annual total of all such coatings does not

exceed 200 gallons. Primers, topcoats, and specialty coatings exempted under §63.745(f)(3),

§63.745(g)(4), or OAC 252:100-39-47(a) are not included in the 50- and 200-gallon limits.

Chemical milling maskants exempted under §63.747(c)(3) are also not included in these limits.

Since the Oklahoma rule is more restrictive than the MACT, it is the primary citation.

[OAC 252:100-39-47(d)(1)(D)]

16. Requirements applicable to facility cleaning operations are specified in §63.744 and include

the following: [40 CFR 63.744]

A. Good housekeeping shall be observed, with measures detailing proper handling of fresh

and spent solvents and solvent-laden materials being described in 40 CFR 63.744(a).

B. Unless exempted pursuant to §63.744(e) or cleaning solvents meeting the definition of

“non-HAP material” per 40 CFR §63.741(f) are utilized, hand-wipe cleaning solvent

solutions shall meet one of the following:

i. Meet one of the composition requirements in Table 1 of §63.744,

ii. Have composite vapor pressure of 45 mm Hg or less at 20ºC, or

iii. Demonstrate the volume of hand-wipe solvents used in cleaning operations has been

reduced by at least 60% from a baseline adjusted for production in accordance with

§63.744(b)(3).


17. Unless exempted in §63.744(c)(5), spray gun cleaning operations shall use one or more of the

following techniques or their equivalents:

[OAC 252:100-39-47(d)(4), 40 CFR 63.744(a & c)]

A. Clean the spray-gun in an enclosed system that is closed at all times except when inserting

or removing the gun. Cleaning shall consist of forcing solvent through the gun. Monthly

inspections per §63.751(a) shall be performed while the system is in operation, with visual

inspection of the seals and other potential sources of leaks. Leaks must be repaired as soon

as practicable, but no later than 15 days after the leak was found. If repairs cannot be effected

within 15 days after detection, the cleaning solvent shall be removed, and the enclosed

cleaner shall be shut down until the leak is repaired or its use is permanently discontinued.

B. Clean the spray gun by placing cleaning solvent in the pressure pot and forcing it through

the gun with the atomizing cap in place. No atomizing air is to be used. Direct the cleaning

solvent from the spray gun into a vat, drum, or other waste container that is closed when not

in use.

C. Disassemble the spray gun and clean the components by hand in a vat, which shall remain

closed at all times except when in use, or alternatively, soak the components in a vat, which

shall be opened only while inserting or removing the parts.

D. Clean the spray gun by forcing the cleaning solvent through the gun and direct the resulting

atomized spray into a waste container that is fitted with a device designed to capture the

atomized cleaning solvent emissions.

E. Cleaning solvents that meet the definition of “non-HAP material” in §63.742 pursuant to

§63.741(f) are exempt from these requirements.

18. Excluding those operations that use Table 1 or semi-aqueous cleaning solvents, the facility

shall empty used cleaning solvent from a flush cleaning operation subject to Subpart GG each

time aerospace parts, assemblies, or components of a coating unit (except spray guns) are flush

cleaned into an enclosed container or collection system that is kept closed while not in use or

into a system with equivalent emission control. [40 CFR 63.744(d)]

19. Depainting operations shall consume no more than 26 gallons of organic HAP-containing

chemical strippers or alternatively no more than 190 pounds of organic HAP per commercial

aircraft depainted and no more than 50 gallons of organic HAP-containing chemical strippers

or 365 pounds of organic HAP per military aircraft depainted. Parts removed shall be described

and depainting operations shall clearly identify those parts depainted subject to this

requirement, including the outer surfaces of fuselage, wings, and vertical and horizontal

stabilizers. This standard applies on an annual average basis, with each rolling average

consisting of two consecutive semi-annual compliance periods. Depainting of radomes and

parts, subassemblies, and assemblies normally removed from the primary aircraft structure

before depainting are exempt from the above requirements. [40 CFR 63.746(a & b(3))]

20. The boilers currently listed in EUG 3 are existing gas 1 subcategory units at a major source,

subject to NESHAP Subpart DDDDD, and shall comply with all requirements of the subpart

no later than January 31, 2016. [40 CFR 63 Subpart DDDDD]

§§63.7480, 7485, 7490, 7491, 7495 What This Subpart Covers

http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&SID=81768ee648b87e605fd831023340fceb&rgn=div6&view=text&node=40:14.0.1.1.1.5&idno=40#40:14.0.1.1.1.5.137.1



§§63.7499, 7500, 7501 Emission Limitations and Work Practice Standards

§63.7505 General Compliance Requirements

§§63.7510, 7515, 7520, 7521, 7522, 7525, 7530, 7533 Testing, Fuel Analyses, and Initial

Compliance Requirements

§§63.7535, 7540, 7541 Continuous Compliance Requirements

§§63.7545, 7550, 7555, 7560 Notification, Reports, and Records

§§63.7565, 7570, 7575 Other Requirements and Information

Tables 1 through 13

Specific requirements that apply to only those boilers present at the facility on the date of

issuance of this permit include Items 3 and 4 of Table 3, §§7500(a)(3), 7510(e), 7515(d),

7530(d, e, & f), 7540(a)(10), 7545(a, e, f, & h), and 7555(a, h, i, & j).

21. Engines associated with the emergency generators and fire pumps of EUG 13 are affected

facilities under NESHAP Subpart ZZZZ and shall comply with all sections including, but not

necessarily restricted to, the following. [40 CFR 63 Subpart ZZZZ]

a. §63.6580, 6585, 6590 Applicability.

b. §63.6595 When do I have to comply with this subpart?

c. §63.6600, 6601,6605 What emission limitations and operating limitations apply?

d. §63.6610, 6611, 6615, 6620 Performance tests and procedures.

e. §63.6625 What are my monitoring, installation, operation, and

maintenance requirements?

f. §63.6630, 6635, 6640 Demonstrating initial and continuous compliance with

emission and operating limitations.

g. §63.6645, 6650, 6655, 6660 Notifications, reporting, and recordkeeping

h. §63.6665 What parts of the General Provisions apply to me?

i. §63.6670 Who implements and enforces this subpart?

j. §63.6675 What definitions apply to this subpart?

Engines associated with emission points EP-106, -111, -112, -301, -302, -303, -304, and -305

are existing RICE rated at less than 500 hp, and are subject to the operating requirements of

Item 1 of Table 2c. Engines associated with emission points EP-105, -107, -108, -109, and -

110 are existing RICE rated at greater than 500 hp, and are not subject to any of the emission

limits or operating requirements of Tables 1a, 1b, 2a, 2b, 2c, or 2d.

22. All records necessary to demonstrate compliance with permit conditions shall be maintained

on-site or at a readily accessible location and shall be available during normal business hours.

Records shall be retained for at least five years after their date of creation. Such records may

include, but are not necessarily limited to the following. [OAC 252:100-43]

a) Facility-wide emissions of all criteria pollutants (monthly, 12-month rolling total).

Calculation of emissions from combustion sources shall be performed using manufacturers’

guarantees where available, factors derived from performance testing, or current AP-42 factors.

b) Fuel type and use at boilers EP-45, 46, 48, & 49 (daily for EP-48 & 49, all others monthly,

12-month rolling total).




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c) Reference Method 9 and visible emission readings and results for boilers EP-48 & 49 (initial

test for RM 9 and daily VE during Jet-A firing).

d) Sulfur content of Jet-A, when used as an alternate fuel.

e) Pressure drop measurements at Scrubbers #6 and #7.

f) Operating and maintenance actions for Scrubbers #6 and #7.

g) Vapor degreaser EP-59, 60, 61, 62, 63, and 64 inspection records, temperature readings

(weekly), and hoist speed measurements (monthly or quarterly, as required). Records as

appropriate for any new degreasers added under the terms of Specific Condition #1, EUG 5.

h) Coating application information, including location, type (primer, topcoat, specialty, other),

and HAP and VOC content of each coating as applied.

i) Differential pressure readings for all booths in which inorganic HAPs are sprayed (each use,

but not more than once per day).

j) Documentation of low use exemptions for those coatings exceeding specific HAP or VOC

standards, but used in quantities no greater than 50 gallons for any one formulation and no

greater than 200 gallons for all such formulations (12-month rolling).

k) MSD sheets for all coatings, solvents, and other materials, documenting the composition of

each.

l) Documentation or calculation of the vapor pressure of each hand-wipe solvent.

m) Monthly inspection reports of all enclosed spray gun cleaning systems.

n) Calculations demonstrating the quantity of organic HAP-containing strippers used per

aircraft (gals/plane) and/or the amount of organic HAP used per aircraft (lbs/plane), for each

six-month semi-annual reporting period and for rolling annual periods consisting of two

consecutive semi-annual periods.

o) Records required by 40 CFR 63 Subpart ZZZZ, per SC 21.

p) Records required by 40 CFR 63 Subpart DDDDD, per SC 20.

q) All data and calculations required for the compliance demonstration described in SC 9, and

a monthly log identifying the compliance method selected for each month.

r) All data necessary to document the continued status of various items as insignificant

activities. This category includes, but is not necessarily limited to the following activities.

i) Fuel dispensed for facility-owned vehicles (daily averages calculated monthly).

ii) Contents and true vapor pressure of volatile organic liquids stored in tanks with less than

or equal to 10,000 gallons capacity.

iii) Emissions from the metal spray booths.

iv) Emissions from tanks containing acid solutions, nickel and other materials.

v) Emissions from welding.

23. The permittee has requested and been granted a “permit shield” for this facility. All applicable

air pollution control rules and regulations are listed in the Specific Conditions or in the

Standard Conditions. Compliance with the terms and conditions of this permit shall be deemed

compliance with the applicable requirements identified and included in this permit. Rules and

regulations, which have been determined inapplicable are also listed and discussed in the

Evaluation Memorandum.


24. The Permit Shield (Standard Conditions, Section VI) is extended to the following requirements

that have been determined to be inapplicable to this facility. [OAC 252:100-8-6(d)(2)

OAC 252:100-7 Permits For Minor Facilities not in source category

OAC 252:100-11 Alternative Reduction not eligible

OAC 252:100-15 Mobile Sources not in source category

OAC 252:100-17 Incinerators not type of emission unit

OAC 252:100-23 Cotton Gins not type of emission unit

OAC 252:100-24 Feed & Grain Facility not in source category

OAC 252:100-35 Control of Emissions of CO not in source category

OAC 252:100-47 Landfills not in source category

25. Aqueous parts washers (e.g., dip tanks, buckets, cans, etc.) that are intermittently used

throughout the American Airlines facility for various cleaning purposes (including both metal

and non-metal parts, tools, and equipment), are not subject to OAC 252:100-39-42(a).

American shall maintain an MSD sheet for each aqueous solution.

26. No later than 30 days after each anniversary date of the issuance of the original Part 70 permit

(March 24, 2004), the permittee shall submit to Air Quality Division of DEQ, with a copy to

the US EPA, Region 6, certification of compliance with the terms and conditions of this permit.

[OAC 252:100-8-6 (c)(5)(A) & (D)]

27. This Part 70 permit supersedes and replaces all other Air Quality operating permits issued by

the DEQ or predecessor agencies.

MAJOR SOURCE AIR QUALITY PERMIT

STANDARD CONDITIONS

(June 21, 2016)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with the federal Clean

Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act and the

rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma

Department of Environmental Quality (DEQ). The permit does not relieve the holder of the

obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or

ordinances. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance shall

constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement action,

permit termination, revocation and reissuance, or modification, or for denial of a permit renewal

application. All terms and conditions are enforceable by the DEQ, by the Environmental

Protection Agency (EPA), and by citizens under section 304 of the Federal Clean Air Act

(excluding state-only requirements). This permit is valid for operations only at the specific

location listed.

[40 C.F.R. §70.6(b), OAC 252:100-8-1.3 and OAC 252:100-8-6(a)(7)(A) and (b)(1)]

D. It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

conditions of the permit. However, nothing in this paragraph shall be construed as precluding

consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for

noncompliance if the health, safety, or environmental impacts of halting or reducing operations

would be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from an emergency and/or posing an imminent and substantial

danger to public health, safety, or the environment shall be reported in accordance with Section

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported

consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

[OAC 252:100-8-6(a)(3)(C)(iv)]

C. Every written report submitted under this section shall be certified as required by Section III

(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

MAJOR SOURCE STANDARD CONDITIONS June 21, 2016 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. These records, including

monitoring data and necessary support information, shall be retained on-site or at a nearby field

office for a period of at least five years from the date of the monitoring sample, measurement,

report, or application, and shall be made available for inspection by regulatory personnel upon

request. Support information includes all original strip-chart recordings for continuous monitoring

instrumentation, and copies of all reports required by this permit. Where appropriate, the permit

may specify that records may be maintained in computerized form.

[OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:100-8-6(c)(1), and OAC 252:100-8-6(c)(2)(B)]

B. Records of required monitoring shall include:

(1) the date, place and time of sampling or measurement;

(2) the date or dates analyses were performed;

(3) the company or entity which performed the analyses;

(4) the analytical techniques or methods used;

(5) the results of such analyses; and

(6) the operating conditions existing at the time of sampling or measurement.

[OAC 252:100-8-6(a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the

original Part 70 operating permit or alternative date as specifically identified in a subsequent Part

70 operating permit, the permittee shall submit to AQD a report of the results of any required

monitoring. All instances of deviations from permit requirements since the previous report shall

be clearly identified in the report. Submission of these periodic reports will satisfy any reporting

requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the

submitted report. [OAC 252:100-8-6(a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or

operator shall comply with the provisions of Section II (Reporting Of Deviations From Permit

Terms) of these standard conditions. [OAC 252:100-8-6(a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this permit,

monitoring and reporting may be required under the provisions of OAC 252:100-43, Testing,

Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean Air Act or

Oklahoma Clean Air Act. [OAC 252:100-43]

F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report,

Excess Emission Report, and Annual Emission Inventory submitted in accordance with this permit

shall be certified by a responsible official. This certification shall be signed by a responsible

official, and shall contain the following language: “I certify, based on information and belief

formed after reasonable inquiry, the statements and information in the document are true, accurate,

and complete.”

[OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC

252:100-9-7(e), and OAC 252:100-5-2.1(f)]


G. Any owner or operator subject to the provisions of New Source Performance Standards

(“NSPS”) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants

(“NESHAPs”) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other

information required by the applicable general provisions and subpart(s). These records shall be

maintained in a permanent file suitable for inspection, shall be retained for a period of at least five

years as required by Paragraph A of this Section, and shall include records of the occurrence and

duration of any start-up, shutdown, or malfunction in the operation of an affected facility, any

malfunction of the air pollution control equipment; and any periods during which a continuous

monitoring system or monitoring device is inoperative.

[40 C.F.R. §§60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q]

H. The permittee of a facility that is operating subject to a schedule of compliance shall submit to

the DEQ a progress report at least semi-annually. The progress reports shall contain dates for

achieving the activities, milestones or compliance required in the schedule of compliance and the

dates when such activities, milestones or compliance was achieved. The progress reports shall

also contain an explanation of why any dates in the schedule of compliance were not or will not

be met, and any preventive or corrective measures adopted. [OAC 252:100-8-6(c)(4)]

I. All testing must be conducted under the direction of qualified personnel by methods approved

by the Division Director. All tests shall be made and the results calculated in accordance with

standard test procedures. The use of alternative test procedures must be approved by EPA. When

a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated in

accordance with the manufacturer’s instructions and in accordance with a protocol meeting the

requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method

approved by Air Quality. [OAC 252:100-8-6(a)(3)(A)(iv), and OAC 252:100-43]

J. The reporting of total particulate matter emissions as required in Part 7 of OAC 252:100-8

(Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and

OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing or

calculation procedures, modified to include back-half condensables, for the concentration of

particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of only

particulate matter emissions caught in the filter (obtained using Reference Method 5).

K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required

by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit

subject to such standards. [OAC 252:100-8-6(c)(1) and OAC 252:100, Appendix Q]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70

operating permit or alternative date as specifically identified in a subsequent Part 70 operating

permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a certification

of compliance with the terms and conditions of this permit and of any other applicable

requirements which have become effective since the issuance of this permit.

[OAC 252:100-8-6(c)(5)(A), and (D)]


B. The compliance certification shall describe the operating permit term or condition that is the

basis of the certification; the current compliance status; whether compliance was continuous or

intermittent; the methods used for determining compliance, currently and over the reporting

period. The compliance certification shall also include such other facts as the permitting authority

may require to determine the compliance status of the source. [OAC 252:100-8-6(c)(5)(C)(i)-(v)]

C. The compliance certification shall contain a certification by a responsible official as to the

results of the required monitoring. This certification shall be signed by a responsible official, and

shall contain the following language: “I certify, based on information and belief formed after

reasonable inquiry, the statements and information in the document are true, accurate, and

complete.” [OAC 252:100-8-5(f) and OAC 252:100-8-6(c)(1)]

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions

units or stationary sources that are not in compliance with all applicable requirements. This

schedule shall include a schedule of remedial measures, including an enforceable sequence of

actions with milestones, leading to compliance with any applicable requirements for which the

emissions unit or stationary source is in noncompliance. This compliance schedule shall resemble

and be at least as stringent as that contained in any judicial consent decree or administrative order

to which the emissions unit or stationary source is subject. Any such schedule of compliance shall

be supplemental to, and shall not sanction noncompliance with, the applicable requirements on

which it is based, except that a compliance plan shall not be required for any noncompliance

condition which is corrected within 24 hours of discovery.

[OAC 252:100-8-5(e)(8)(B) and OAC 252:100-8-6(c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the

permit term and that are applicable to the facility. Compliance with all new requirements shall be

certified in the next annual certification. [OAC 252:100-8-6(c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions

established for alternate operating scenarios, emissions trading, and emissions averaging, but

excluding terms and conditions for which the permit shield is expressly prohibited under OAC

252:100-8) shall be deemed compliance with the applicable requirements identified and included

in this permit. [OAC 252:100-8-6(d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific

Conditions of this permit. Those requirements that the applicant requested be determined as not

applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6(d)(2)]


SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees

based on emissions inventories. The methods used to calculate emissions for inventory purposes

shall be based on the best available information accepted by AQD.

[OAC 252:100-5-2.1, OAC 252:100-5-2.2, and OAC 252:100-8-6(a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date of

issuance. [OAC 252:100-8-6(a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely and

complete renewal application has been submitted at least 180 days before the date of

expiration. [OAC 252:100-8-7.1(d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and

become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction

is not commenced within 18 months after the date the permit or authorization was issued, or if

work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified operating

permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application

of any provision of this permit to any circumstance, is held invalid, the application of such

provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

[OAC 252:100-8-6 (a)(6)]

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege.

[OAC 252:100-8-6(a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon which

the equipment is located and does not release the permittee from any liability for damage to persons

or property caused by or resulting from the maintenance or operation of the equipment for which

the permit is issued. [OAC 252:100-8-6(c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty (60)

days of the request unless the DEQ specifies another time period, any information that the DEQ

may request to determine whether cause exists for modifying, reopening, revoking, reissuing,


terminating the permit or to determine compliance with the permit. Upon request, the permittee

shall also furnish to the DEQ copies of records required to be kept by the permit.

[OAC 252:100-8-6(a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted

pursuant to 27A O.S. § 2-5-105(18). Confidential information shall be clearly labeled as such and

shall be separable from the main body of the document such as in an attachment.

[OAC 252:100-8-6(a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and shall

be made in writing within thirty (30) days after such sale or transfer.

[Oklahoma Clean Air Act, 27A O.S. § 2-5-112(G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause. Except

as provided for minor permit modifications, the filing of a request by the permittee for a permit

modification, revocation and reissuance, termination, notification of planned changes, or

anticipated noncompliance does not stay any permit condition.

[OAC 252:100-8-6(a)(7)(C) and OAC 252:100-8-7.2(b)]

B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the

following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source

category three or more years prior to the expiration date of this permit. No such reopening

is required if the effective date of the requirement is later than the expiration date of this

permit.

(2) The DEQ or the EPA determines that this permit contains a material mistake or that the

permit must be revised or revoked to assure compliance with the applicable requirements.

(3) The DEQ or the EPA determines that inaccurate information was used in establishing the

emission standards, limitations, or other conditions of this permit. The DEQ may revoke

and not reissue this permit if it determines that the permittee has submitted false or

misleading information to the DEQ.

(4) DEQ determines that the permit should be amended under the discretionary reopening

provisions of OAC 252:100-8-7.3(b).

C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-8-

7.3(d). [OAC 100-8-7.3(d)]

D. The permittee shall notify AQD before making changes other than those described in Section

XVIII (Operational Flexibility), those qualifying for administrative permit amendments, or those

defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The

notification should include any changes which may alter the status of a “grandfathered source,” as

defined under AQD rules. Such changes may require a permit modification.

[OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]


E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that

are not specifically approved by this permit are prohibited. [OAC 252:100-8-6(c)(6)]

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of credentials and other documents as may be required by law, the permittee

shall allow authorized regulatory officials to perform the following (subject to the permittee's right

to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(17) for confidential

information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a

source is located or emissions-related activity is conducted, or where records must be kept

under the conditions of the permit;

(2) have access to and copy, at reasonable times, any records that must be kept under the

conditions of the permit;

(3) inspect, at reasonable times and using reasonable safety practices, any facilities, equipment

(including monitoring and air pollution control equipment), practices, or operations

regulated or required under the permit; and

(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit.

[OAC 252:100-8-6(c)(2)]

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later

than 4:30 p.m. on the next working day after the permittee first becomes aware of the exceedance.

This notice shall contain a description of the emergency, the probable cause of the exceedance,

any steps taken to mitigate emissions, and corrective actions taken.

[OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)]

B. Any exceedance that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to AQD as soon as is practicable; but under no circumstance shall

notification be more than 24 hours after the exceedance. [OAC 252:100-8-6(a)(3)(C)(iii)(II)]

C. An "emergency" means any situation arising from sudden and reasonably unforeseeable events

beyond the control of the source, including acts of God, which situation requires immediate

corrective action to restore normal operation, and that causes the source to exceed a technology-

based emission limitation under this permit, due to unavoidable increases in emissions attributable

to the emergency. An emergency shall not include noncompliance to the extent caused by

improperly designed equipment, lack of preventive maintenance, careless or improper operation,

or operator error. [OAC 252:100-8-2]

D. The affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8-6 (e)(2)]

(1) an emergency occurred and the permittee can identify the cause or causes of the emergency;


(2) the permitted facility was at the time being properly operated;

(3) during the period of the emergency the permittee took all reasonable steps to minimize

levels of emissions that exceeded the emission standards or other requirements in this

permit.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an

emergency shall have the burden of proof. [OAC 252:100-8-6(e)(3)]

F. Every written report or document submitted under this section shall be certified as required by

Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop and

register with the appropriate agency a risk management plan by June 20, 1999, or the applicable

effective date. [OAC 252:100-8-6(a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate individual emissions units that are either on the list in Appendix I to OAC Title 252,

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below. Any

activity to which a State or Federal applicable requirement applies is not insignificant even if it

meets the criteria below or is included on the insignificant activities list.

[OAC 252:100-8-2 and OAC 252:100, Appendix I]

(1) 5 tons per year of any one criteria pollutant.

(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an aggregate

of two or more HAP's, or 20 percent of any threshold less than 10 tons per year for single

HAP that the EPA may establish by rule.

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate any individual or combination of air emissions units that are considered inconsequential

and are on the list in Appendix J. Any activity to which a State or Federal applicable requirement

applies is not trivial even if included on the trivial activities list.

[OAC 252:100-8-2 and OAC 252:100, Appendix J]

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the

need for any permit revision or any notification to the DEQ (unless specified otherwise in the

permit). When an operating scenario is changed, the permittee shall record in a log at the facility

the scenario under which it is operating. [OAC 252:100-8-6(a)(10) and (f)(1)]


B. The permittee may make changes within the facility that:

(1) result in no net emissions increases,

(2) are not modifications under any provision of Title I of the federal Clean Air Act, and

(3) do not cause any hourly or annual permitted emission rate of any existing emissions unit

to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required

below in advance of the proposed changes, which shall be a minimum of seven (7) days, or twenty

four (24) hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the DEQ, and

the EPA shall attach each such notice to their copy of the permit. For each such change, the written

notification required above shall include a brief description of the change within the permitted

facility, the date on which the change will occur, any change in emissions, and any permit term or

condition that is no longer applicable as a result of the change. The permit shield provided by this

permit does not apply to any change made pursuant to this paragraph. [OAC 252:100-8-6(f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility unless

elsewhere covered by a more restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized

in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-13]

(2) No particulate emissions from any fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an opacity limit promulgated under 40 C.F.R., Part

60, NSPS, no discharge of greater than 20% opacity is allowed except for:

[OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any

consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours.

In no case shall the average of any six-minute period exceed 60% opacity;

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7;

(c) An emission, where the presence of uncombined water is the only reason for failure to

meet the requirements of OAC 252:100-25-3(a); or

(d) Smoke generated due to a malfunction in a facility, when the source of the fuel

producing the smoke is not under the direct and immediate control of the facility and

the immediate constriction of the fuel flow at the facility would produce a hazard to

life and/or property.

(4) No visible fugitive dust emissions shall be discharged beyond the property line on which

the emissions originate in such a manner as to damage or to interfere with the use of

adjacent properties, or cause air quality standards to be exceeded, or interfere with the

maintenance of air quality standards. [OAC 252:100-29]


(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2

lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and with

a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or

greater under actual conditions shall be equipped with a permanent submerged fill pipe or

with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of

ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an order for production or importation of certain

class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the

requirements of §82.4;

(2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain

class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping

requirements at §82.13; and

(3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,

HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane

(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an

ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air

conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the

vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the air-

tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger buses

using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions reduction

except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply with

the required practices pursuant to § 82.156;

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must

comply with the standards for recycling and recovery equipment pursuant to § 82.158;

(3) Persons performing maintenance, service, repair, or disposal of appliances must be

certified by an approved technician certification program pursuant to § 82.161;

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply

with record-keeping requirements pursuant to § 82.166;

(5) Persons owning commercial or industrial process refrigeration equipment must comply


with leak repair requirements pursuant to § 82.158; and

(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must

keep records of refrigerant purchased and added to such appliances pursuant to § 82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is not

inconsistent with Federal requirements, to provide for incorporation of requirements established

through construction permitting into the Source’s Title V permit without causing redundant

review. Requirements from construction permits may be incorporated into the Title V permit

through the administrative amendment process set forth in OAC 252:100-8-7.2(a) only if the

following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the

procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to

the public that this permit is subject to EPA review, EPA objection, and petition to EPA,

as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit will be

incorporated into the Title V permit through the administrative amendment process; that

the public will not receive another opportunity to provide comments when the

requirements are incorporated into the Title V permit; and that EPA review, EPA

objection, and petitions to EPA will not be available to the public when requirements

from the construction permit are incorporated into the Title V permit.

(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR §

70.8(a)(1).

(3) A copy of the draft construction permit is sent to any affected State, as provided by 40

C.F.R. § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period as

provided by 40 C.F.R.§ 70.8(a) and (c).

(5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day

comment period of any EPA objection to the construction permit. The DEQ shall not

issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 C.F.R. § 70.8(d).

(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).

(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these permit

conditions.

(9) Any requirements of the construction permit may be reopened for cause after

incorporation into the Title V permit by the administrative amendment process, by DEQ

as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40 C.F.R.

§ 70.7(f) and (g).

(10) The DEQ shall not issue the administrative permit amendment if performance tests fail

to demonstrate that the source is operating in substantial compliance with all permit

requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the

Title V review process.


SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing shall

preclude the use, including the exclusive use, of any credible evidence or information, relevant to

whether a source would have been in compliance with applicable requirements if the appropriate

performance or compliance test or procedure had been performed. [OAC 252:100-43-6]

PART 70 PERMIT


STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2014-0382-TVR2

American Airlines, Inc.,

having complied with the requirements of the law, is hereby granted permission to operate

all the sources within the boundaries of the Tulsa Maintenance and Engineering Center at

3800 North Mingo Road, Tulsa, Tulsa County,

subject to standard conditions dated June 21, 2016, and specific conditions, both attached.

This permit shall expire five years from the date below, except as authorized under Section

VIII of the Standard Conditions.

_________________________________

Eddie Terrill, Division Director Date

William J. Collins III, VP Base Maintenance and Engineering

American Airlines, Inc.

P.O. Box 582809, MD 508

Tulsa, OK 74158-2089

Re: Part 70 Renewal Permit No. 2014-0382-TVR2

Tulsa Maintenance and Engineering Center

DEQ Facility ID # 20

3800 North Mingo Road, Tulsa

Dear Mr. Collins:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this permit

is issued subject to certain standard and specific conditions, which are attached. These conditions

must be carefully followed since they define the limits of the permit and will be confirmed by

periodic inspections.

Also note that you are required to annually submit an emissions inventory for this facility. An

emissions inventory must be completed on approved AQD forms and submitted (hardcopy or

electronically) by April 1st of every year. Any questions concerning the form or submittal process

should be referred to the Emissions Inventory Staff at (405) 702-4100.

Thank you for your cooperation in this matter. If we may be of further service, please contact our

office at (405) 702-4100.

Sincerely,

Phillip Fielder, P.E.

Chief Engineer


Enclosure

draft oklahoma department of environmental … · aircraft or on a product basis. thus, rework...

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