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OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITYAIR QUALITY DIVISION

MEMORANDUM June 30, 2005

TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality Division

THROUGH: Grover Campbell, P.E., Existing Source Permits Section

THROUGH: Ing Yang, P.E., New Source Permits Section

THROUGH: Peer Review

FROM: Kha Mach, E.I., Existing Source Permits Section

SUBJECT: Evaluation of Permit Application Number 2002-532-TVRNorthern Natural Gas CompanyBeaver County Compressor StationSection 24, T2N, R24E, IM, Beaver CountyLocated 4 miles east of Elmwood on SH 3

SECTION I. FACILITY DESCRIPTION

Northern Natural Gas (NNG) has requested a renewal of the Title V operating permit for the Beaver County Compressor Station. The facility (SIC 4922) is currently operated under Permit No. 97-148-TV, issued on June 23, 1998. This facility has several stationary internal combustion engines onsite: five 1,326-hp Worthington 4-cycle lean-burn engines (inoperable) and two 1,515-hp Worthington 4-cycle lean-burn engines (inoperable); six 1,894-hp Worthington 2-cycle lean-burn engines, five 1,998-hp Ingersol-Rand KVS 4-cycle lean-burn engines, two 6,000-hp Clark TCVA 2-cycle lean-burn engines, and a 8,000-hp Clark TCVC 2-cycle lean-burn engine, all of which are in compressor service. Five Ingersol-Rand PVG 4-cycle rich burn generators have been replaced by a 1,818-hp Caterpillar G3516B engine (A-6). Heaters located at this facility include: (a) five regeneration heaters: 4.0 MMBTUH (H1), 8.4 MMBTUH dry-bead dehydration (H3), 5.2 MMBTUH (H4), 8.0 MMBTUH (H5), and 6.3 MMBTUH (H8); (b) a 1.0 MMBTUH glycol dehydration regeneration heater (H9); (c) two 0.45 MMBTUH condensate heaters (H10 & H11); and (d) two 5.0 MMBTUH Kewanee fire-tube steam boilers (H6 & H7).

The station was originally built in 1944 with four 1,326-hp Worthington engines (inoperable now) and two 275-hp Ingersol-Rand PVG engines (removed from site). Most of the remaining engines were installed between 1950 to 1967 (See SECTION II). The 98-hp Waukesha engine was installed in 1977 and removed in 1998. The regeneration heaters were installed between 1957 and 1977 (See SECTION II). The two 5.0 MMBTUH Kewanee fire-tube steam boilers were installed in 1993.

DRAFTPERMIT MEMORANDUM 2002-532-TVR 2

Most of the engines are grandfathered sources which were constructed before May 31, 1972 as defined in the Title V Permit Application Guide (3/96).

The three regeneration heaters (H1, H4, and H5), and the 1.0 MMBTUH glycol regeneration heater (H9) are also grandfathered because they were constructed prior to May 31, 1972. The 8.4 MMBTUH heater (H3), the 5.2 MMBTUH heater (H8), and the two 0.45 MMBTUH condensate heaters (H10 & H11) built in 1973 were exempted from permitting because their emissions were below 1 lb/hr. The two 5.0 MMBTUH Kewanee steam boilers (H6 & H7) built in 1993 were also never permitted because their emissions were below 1 lb/hr.

Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) in the following outline. Field-grade natural gas is the primary fuel with the engines and dehydrators are operated continuously. The facility has a maximum capacity of 2 billion SCF/day.

The applicant has requested that the Title V renewal permit incorporate the following changes to facility equipment and operations: (1) updating horsepower of the engines and heater ratings based on site conditions, (2) updating the emission factors with the current AP-42 factors, and (3) updating removed/added equipment.

EU ID # Old Description Type of

ChangeDate of Change New Description Reason for Change

ENG14 1,915-hp Ingersoll-Rand KVS-12 Modified 1,998-hp Ingersoll-Rand 412-KVS

Updating hp based on site conditions & correcting

model numbers



model numbers



model numbers



model numbers



model numbers

BV15 98-hp Waukesha F817GU Removed 1998 Engine removed from site in 1998

AUX1 275-hp Ingersoll-Rand PVG Removed 2003 Engine removed from siteAUX2 275-hp Ingersoll-Rand PVG Removed 2003 Engine removed from siteAUX3 275-hp Ingersoll-Rand PVG Removed 2003 Engine removed from siteAUX4 306-hp Ingersoll-Rand PVG Removed 2003 Engine removed from siteAUX5 370-hp Ingersoll-Rand PVG Removed 2003 Engine removed from site

A-6 1,818-hp Caterpillar G3516B Added 2004New emergency engine

to replace AUX1 – AUX5

H1 5.0 MMBTUH Dehydrator Regeneration heater Modified 4.0 MMBTUH Dehydrator

Regeneration heaterUpdating heater rating

based on site conditions


Regeneration heater

Updating heating rating based on most current

data


EU ID # Old Description Type of

ChangeDate of Change New Description Reason for Change







H2 5.0 MMBTUH Dehydrator Regeneration heater Removed Heater removed from site

T-1 30,000-gallon Condensate Tank Modified 52,000-gallon Condensate Tank

Updating tank capacity based on most current

data

T-2 30,000-gallon Condensate Tank Modified 52,000-gallon Condensate Tank

Updating tank capacity based on most current

data

T-3 4,030-gallon Ethylene Glycol Tank Removed EG storage tank removed

from site.T-13 Propane Tank Removed Removed from site

SECTION II. EQUIPMENT

EUG 1 Grandfathered/Exempted Internal Combustion Engines EU Point Make/Model hp Serial # Const. Date

ENG8 8 Worthington UTC-10 1,894 G-2196 1954ENG9 9 Worthington UTC-10 1,894 G-2197 1954ENG10 10 Worthington UTC-10 1,894 G-2198 1954ENG11 11 Worthington UTC-10 1,894 G-2208 1954ENG12 12 Worthington UTC-10 1,894 G-2209 1954ENG13 13 Worthington UTC-10 1,894 G-2210 1954ENG14 14 Ingersoll-Rand 412 KVS 1,998 412CT183 1956ENG15 15 Ingersoll-Rand 412 KVS 1,998 412CT238 1957ENG16 16 Ingersoll-Rand 412 KVS 1,998 412DT241 1957ENG17 17 Ingersoll-Rand 412 KVS 1,998 412ET292 1959ENG18 18 Ingersoll-Rand 412 KVS 1,998 412ET337 1960ENG19 19 Clark TCVA-16 6,000 115003 1966ENG20 20 Clark TCVA-16 6,000 115005 1966ENG21 21 Clark TCVC-16 8,000 120501 1967


EUG 2 HeatersEU Point Make/Model MMBTUH Const. Date

H1 28 Dehydrator Regeneration heater 4.0 1960H3 30 Dehydrator Regeneration heater 8.4 1973H4 31 Dehydrator Regeneration heater 5.2 1973H5 32 Dehydrator Regeneration heater 8.0 1966H6 33 Kewanee Steam Boiler 5.0 1993H7 34 Kewanee Steam Boiler 5.0 1993H8 35 Dehydrator Regeneration heater 6.3 1966H9 36 Glycol Regenerator 1.0 1957H10 37 Condensate Heater 0.45 1973H11 38 Condensate Heater 0.45 1973

EUG 3 TanksEU Point Contents Barrels Gallons Const. Date

Tanks T1 Condensate (pressurized) 1,238 52,000 1940T2 Condensate (pressurized) 1,238 52,000 1940T4 Ethylene Glycol 143 6,000 1971T5 Methanol 420 17,625 1971T6 Lube Oil 197 8,272 1967T7 Lube Oil 197 8,272 1967T8 Lube Oil 310 13,000 1960T9 Lube Oil 283 12,000 1960T10 Lube Oil 12 500 1977T11 Used Oil (UST) (Drain Tank) 210 8,800 1990T12 Cooling Water (UST) 210 8,800 1990T14 Gasoline 12 500 1978T15 Diesel 12 500 1978T16 Water 400 16,800 1981T17 Water 400 16,800 1981T18 Oily waste water 210 8,800 1990T19 Used oil 210 8,800 1990T20 Condensate 48 2,000 1998T21 Oily waste water 210 8,800 1990T22 Oily waste water 210 8,800 1990T23 Lube oil transfer tank 12 500 No dateT24 Methanol transfer tank 12 500 No dateT25 Used oil tank (basement bdlg 1) 5.6 235 ---T26 Ethylene Glycol 24 1025 ---T27 Used oil tank 9 375 ---T28 Used oil (vent) 2.5 105 ---T29 BTEX Vent tank (fiberglass) 2004


EUG 4 FugitivesEU Number Items Type of Equipment

Fugitives 500 Valves2000 Flanges

39 Other

Stack Parameters

EU Source(make/model)

Height(feet) (1)

Diameter(feet) (2)

ENG8 Worthington UTC-10 28 1.67ENG9 Worthington UTC-10 28 1.67ENG10 Worthington UTC-10 28 1.67ENG11 Worthington UTC-10 28 1.67ENG12 Worthington UTC-10 28 1.67ENG13 Worthington UTC-10 28 1.67ENG14 Ingersoll-Rand 412 KVS 28 1.67ENG15 Ingersoll-Rand 412 KVS 28 1.67ENG16 Ingersoll-Rand 412 KVS 28 1.67ENG17 Ingersoll-Rand 412 KVS 30 1.67ENG18 Ingersoll-Rand 412 KVS 30 1.67ENG19 Clark TCVA-16 36 3.33ENG20 Clark TCVA-16 36 3.33ENG21 Clark TCVC-16 38 4.67H1 Dehydrator Regeneration Heater 20 0.83H3 Dehydrator Regeneration Heater 30 1.00H4 Dehydrator Regeneration Heater 12 1.33H5 Dehydrator Regeneration Heater 12 0.67H6 Kewanee Steam Boiler 15 1.00H7 Kewanee Steam Boiler 15 1.00H8 Dehydrator Regeneration Heater 12 0.67H9 Glycol Regenerator 20 0.83H10 Condensate Heater 15 0.83H11 Condensate Heater 15 0.83

(1) Stack heights of Engines obtained from actual field measurements by Benham(2) Data obtained from NNG

SECTION III. EMISSIONS

Emissions estimates for the engines are based on continuous operation and AP-42 (7/00) Chapter 3.2. Estimated emissions for the regeneration heaters are based on AP-42 (7/98) Chapter 1.4. Emission estimates for the glycol reboiler are based on AP-42 (7/98) Chapter 1.4. Emissions for the condensate tanks with a condensate throughput of 7,680,000 gallons per year are negligible since the condensate tanks are pressurized. Fugitive VOC emissions are based on EPA’s 1995 Protocol for Equipment Leak Emission Estimates (EPA-453/R-95-017), an estimated percent


C3+, and an estimated number of components. Loadout emissions are estimated using AP-42 (1/95), Section 5.2.

Emission Factors (AP-42 (7/00) Chapter 3.2)

EU EngineHorsepower (hp)

Engine Type

Fuel Consumption (Btu/hp-hr)

NOx(lb/MMBTU)

CO(lb/MMBTU)

VOC(lb/MMBTU)

ENG8 – ENG13

Worthington UTC-10 1,894 2SLB 8,415 3.17 0.386 0.12

ENG14 -

ENG18

Ingersoll-Rand 412 KVS 1,998 4SLB 8,030 4.08 0.317 0.118

ENG19 -

ENG20Clark TCVA-16 6,000 2SLB 7,480 3.17 0.386 0.12

ENG21 Clark TCVC-16 8,000 2SLB 7,480 3.17 0.386 0.12

EUG 3 Tanks

EU Point Contents GallonsThrough

put (gal/hr)

VOC Emissions

(TPY)Tanks T1 Condensate (pressurized) (1) 52,000 3,840,000 ---

T2 Condensate (pressurized) (1) 52,000 3,840,000 ---T4 Ethylene Glycol 6,000 72,000 ---T5 Methanol 17,625 211,500 0.23T6 Lube Oil 8,272 99,264 ---T7 Lube Oil 8,272 99,264 ---T8 Lube Oil 13,000 144,000 ---T9 Lube Oil 12,000 144,000 ---T10 Lube Oil 500 6,000 ---T11 Used Oil (UST) 8,800 105,600 ---T12 Cooling Water (UST) 8,800 105,600 ---T14 Gasoline 500 6,000 0.06T15 Diesel 500 6,000 ---T16 Water 16,800 201,600 ---T17 Water 16,800 201,600 ---


EUG 3 Tanks

EU Point Contents GallonsThrough

put (gal/hr)

VOC Emissions

(TPY)T18 Oily waste water (2) 8,800 ---T19 Used oil 8,800 ---T20 Condensate 2,000 ---T21 Oily waste water 8,800 ---T22 Oily waste water 8,800 ---T23 Lube oil transfer tank 500 ---T24 Methanol transfer tank 500 ---T25 Used oil tank (basement bdlg

1)235 ---

T26 Ethylene Glycol 1025 ---T27 Used oil tank 375 ---T28 Used oil (vent) 105 ---T29 BTEX Vent tank (fiberglass) ---

Total 0.29(1) The condensate tanks are the pressurized tanks as informed by NNG at the inspection.(2) Emissions from tanks T18 – T29 are insignificant.

EUG 4 Fugitive VOC Emissions

Equipment Mole %C3+

Emission Factor (lb/hr) TPY

500 Valves 0.33 0.00992 0.02 0.072000 Flanges 0.33 0.00086 0.01 0.02

39 Other 0.33 0.01940 0.00 0.01TOTAL 0.03 0.11

Total Potential Emissions

EU NOx CO VOClb/hr TPY lb/hr TPY lb/hr TPY

ENG8 50.52 221.29 6.15 26.95 1.91 8.38ENG9 50.52 221.29 6.15 26.95 1.91 8.38ENG10 50.52 221.29 6.15 26.95 1.91 8.38ENG11 50.52 221.29 6.15 26.95 1.91 8.38ENG12 50.52 221.29 6.15 26.95 1.91 8.38ENG13 50.52 221.29 6.15 26.95 1.91 8.38ENG14 65.46 286.71 5.09 22.28 1.89 8.29ENG15 65.46 286.71 5.09 22.28 1.89 8.29ENG16 65.46 286.71 5.09 22.28 1.89 8.29ENG17 65.46 286.71 5.09 22.28 1.89 8.29ENG18 65.46 286.71 5.09 22.28 1.89 8.29ENG19 142.27 623.14 17.32 75.88 5.39 23.59ENG20 142.27 623.14 17.32 75.88 5.39 23.59


Total Potential Emissions

EU NOx CO VOClb/hr TPY lb/hr TPY lb/hr TPY

ENG21 189.69 830.85 23.10 101.17 7.18 31.45H1 0.40 1.75 0.34 1.47 0.02 0.10H3 0.84 3.66 0.70 3.08 0.05 0.28H4 0.52 2.27 0.44 1.91 0.03 0.12H5 0.80 3.49 0.67 2.93 0.04 0.19H6 0.50 2.18 0.42 1.83 0.03 0.12H7 0.05 2.18 0.42 1.83 0.03 0.12H8 0.63 2.75 0.53 2.31 0.03 0.15H9 0.10 0.44 0.08 0.37 0.01 0.02

H10 0.05 0.20 0.04 0.16 <0.01 0.01H11 0.05 0.20 0.04 0.16 <0.01 0.01

Tanks --- --- --- --- --- 0.29Fugitives --- --- --- --- 0.03 0.11

Loadout (1) 2.65 11.60TOTAL 1,108.59 4,857.54 123.77 542.08 41.81 183.48

(1) Estimated annual throughput of 7,680,000 gallons at 61.98F, 3.06 psia, and 69 lb/lb-mol.

Brake-specific fuel consumption for 1,894-hp Worthington UTC-10 engines (ENG8 – ENG13) is listed at 8,415 BTU/hp-hr for a fuel consumption of 15,875 SCFH. Air emissions will be discharged through a stack 1.67 foot in diameter, 28 feet above grade, at a rate of 8,471 ACFM and 800F. Moisture content of the stack gases has been estimated at 15% from fuel usage and the stoichiometric ratio of two SCF of water per SCF of natural gas fuel.

Brake-specific fuel consumption for 1,998-hp Ingersoll-Rand 412 KVS engines (ENG14 – ENG16) is listed at 8,030 BTU/hp-hr for a fuel consumption of 15,980 SCFH. Air emissions will be discharged through a stack 1.67 foot in diameter, 28 feet above grade, at a rate of 11,816 ACFM and 740F. Moisture content of the stack gases has been estimated at 10% from fuel usage and the stoichiometric ratio of two SCF of water per SCF of natural gas fuel.

Brake-specific fuel consumption for 6,000-hp Clark TCVA-16 engines (ENG19 – ENG20) is listed at 7,480 BTU/hp-hr for a fuel consumption of 44,701 SCFH. Air emissions will be discharged through a stack 3.33 foot in diameter, 36 feet above grade, at a rate of 52,200 ACFM and 750F. Moisture content of the stack gases has been estimated at 6% from fuel usage and the stoichiometric ratio of two SCF of water per SCF of natural gas fuel.

Brake-specific fuel consumption for 8,000-hp Clark TCVC-16 engine (ENG21) is listed at 7,480 BTU/hp-hr for a fuel consumption of 59,602 SCFH. Air emissions will be discharged through a stack 4.67 foot in diameter, 38 feet above grade, at a rate of 76,300 ACFM and 750F. Moisture content of the stack gases has been estimated at 6% from fuel usage and the stoichiometric ratio of two SCF of water per SCF of natural gas fuel.


The internal combustion engines have emissions of HAPs, the most significant being formaldehyde, acrolein, and benzene. Emission estimates for formaldehyde, acrolein, benzene and acetaldehyde based on emission factors from AP-42, (7/00), Section 3.2, Table 3.2-1 and Table 3.2-2, are listed in the tables below.

AP-42 Emission Factors (7/00), Section 3.2, Table 3.2-1 and Table 3.2-2.HAPs 2SLB (lb/MMBtu) 4SLB (lb/MMBtu)

Acetaldehyde 7.76E-3 8.36E-3Acrolein 7.78E-3 5.14E-3Benzene 1.94E-3 4.40E-4

Formaldehyde 5.52E-2 5.28E-2

HAP Emissions

EU ID# Source Acetaldehyde Acrolein Benzene Formaldehyde

lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPYENG8 Worthington UTC-10 (2SLB) 0.12 0.54 0.12 0.54 0.03 0.14 0.88 3.85ENG9 Worthington UTC-10 (2SLB) 0.12 0.54 0.12 0.54 0.03 0.14 0.88 3.85ENG10 Worthington UTC-10 (2SLB) 0.12 0.54 0.12 0.54 0.03 0.14 0.88 3.85ENG11 Worthington UTC-10 (2SLB) 0.12 0.54 0.12 0.54 0.03 0.14 0.88 3.85ENG12 Worthington UTC-10 (2SLB) 0.12 0.54 0.12 0.54 0.03 0.14 0.88 3.85ENG13 Worthington UTC-10 (2SLB) 0.12 0.54 0.12 0.54 0.03 0.14 0.88 3.85

ENG14 Ingersoll-Rand 412 KVS (4SLB) 0.13 0.59 0.08 0.36 0.01 0.03 0.85 3.71





ENG19 Clark TCVA-16 (2SLB) 0.35 1.53 0.35 1.53 0.09 0.38 2.48 10.85ENG20 Clark TCVA-16 (2SLB) 0.35 1.53 0.35 1.53 0.09 0.38 2.48 10.85ENG21 Clark TCVC-16 (2SLB) 0.46 2.03 0.46 2.04 0.12 0.51 3.30 14.47

Total 2.57 11.28 2.32 10.16 0.51 2.24 17.79 77.82


ISC-PRIME modeling results were presented by the applicant. Each individual stack was modeled and the ambient concentrations were combined to determine compliance with the MAAC.

Year

Maximum Modeled

Acetaldehyde Concentration

s (g/m3)

Maximum Modeled Acrolein

Concentrations (g/m3)

Maximum Modeled Benzene

Concentrations (g/m3)

Maximum Modeled

Formaldehyde Concentration

s (g/m3)1986 16.71 15.06 3.32 115.391987 16.65 15.01 3.31 115.001988 17.87 16.11 3.55 123.381990 13.54 12.20 2.69 93.491991 13.57 12.23 2.69 93.69

Maximum 17.87 16.11 3.55 123.38MAAC (g/m3) 3,600 2 32 12

Compliance Demonstrated? Yes No Yes No

The above table demonstrates maximum impacts of acetaldehyde, acrolein, benzene and formaldehyde. Maximum 24-hour average impacts of acrolein (16.11 µg/m3) and formaldehyde (123.38 µg/m3) are not in compliance with the MAAC of 2 µg/m3 and 12 µg/m3 (24-hour average), respectively.

Dehydration units using glycol desiccants will emit benzene, toluene, ethyl benzene, xylenes (BTEX) and n-hexane from the glycol reboiler vapor stack. These compounds are regulated as HAPs. The applicant performed a gas analysis for the concentration of BTEX and n-hexane for the TEG glycol dehydrator inlet gas on May 6, 2000. The emissions were calculated using GLYCalc 4.0 based on a maximum gas throughput of 27.2 MMSCFD, a maximum glycol circulation rate of 4 gpm, and with a condenser. The following table lists estimates of HAPs.

Uncontrolled and Controlled HAP Emissions for TEG unit

Pollutant Toxicity Category

Uncontrolled Emissions

Controlled Emissions

lb/hr TPY lb/hr TPYBenzene A 0.47 2.07 0.01 0.04Toluene C 0.84 3.69 0.01 0.04

Ethyl benzene C 0.06 0.27 0.01 0.01Xylenes C 0.32 1.41 0.01 0.01

n-Hexane C 0.24 1.05 0.01 0.03Total 8.49 0.13


SECTION IV. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application are duplicated below. Appropriate record keeping of activities indicated below with “*”, is specified in the Specific Conditions.

1. * Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel which are either used exclusively for emergency power generation or for peaking power service not exceeding 500 hours/year. Caterpillar G3516B engine (A-6) is used for emergency power generation.

2. Space heaters, boilers and emergency flares less than or equal to 5 MMBTUH heat input (commercial natural gas). Emission units H1, H6, H7, H9, H10, and H11 are heaters which are less than or equal to 5 MMBTUH.

3. Emissions from stationary internal combustion engines rated less than 50 hp output. None identified but may be used in the future.

4. * Emissions from fuel storage/dispensing equipment operated solely for facility owner vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day period. Fuel for facility owned equipment is stored in tanks T14 (gasoline), and T15 (diesel). No propane is currently being used and gasoline and diesel have an approximate annual throughput of 2000 gallons.

5. Gasoline, diesel fuel, aircraft fuel, and fuel oil handling facilities, equipment, and storage tanks except those subject to new source performance standards and standards in OAC 252:100-37-15, 39-30, 39-41, 39-48, or with a capacity greater than 400 gallons. None identified but may be used in the future.

6. Emissions from crude oil or condensate marine and truck loading equipment operations at crude oil and natural gas production sites where the loading rate does not exceed 10,000 gallons per day averaged over a 30-day period. Unloading of tank T-1 into tank trucks is less than 10,000 gallons per day. Tanks T1 and T2 have an annual turnover rate of 2 times a year (328 gallons/day average).

7. * Emissions from crude oil and condensate storage tanks with a capacity of less than or equal to 420,000 gallons that store crude oil and condensate prior to custody transfer. Tanks T1 and T2 store condensate prior to custody transfer and each has a capacity of 52,000 gallons.

8. * Emissions from storage tanks constructed with a capacity less than 39,894 gallons which store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. Tanks T4, T6, T7, T8, T9, T10, T11, T12, T16, and T-17 have capacities less than 39,894 gallons and store products having a vapor pressure less than 1.5 psia.


9. Additions or upgrades of instrumentation or control systems that result in emission increases less than the pollutant quantities specified in OAC 252:100-8-3(e)(1). None identified but may be conducted in the future.

10. Cold degreasing operations utilizing solvents that are denser than air. Five parts washers are located at the facility and they use a solvent that is denser than air.

11. Site restoration and/or bioremediation activities of <5 years duration. Site remediation is currently being conducted but is not expected to exceed 5 years.

12. Hydrocarbon-contaminated soil aeration pads utilized for soils excavated at the facility only. None identified but may be used in the future.

13. Emissions from groundwater remediation wells including but not limited to emissions from venting, pumping, and collecting activities subject to de minimis limits for toxics (OAC 252:100-41-43) and HAP’s (112(b) of CAAA90). None identified but may be used in the future.

14. Emissions from landfills and land farms unless otherwise regulated by an applicable state or federal regulation. None identified but may be used in the future.

15. Surface coating and degreasing operations which do not exceed a combined total usage of more than 60 gallons/month of coatings, thinners, clean-up solvents, and degreasing solvents at any one emission unit. None identified but may be used in the future.

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

17. Hand wiping and spraying of solvents from containers with less than 1 liter capacity used for spot cleaning and/or degreasing in ozone attainment areas. Not normally conducted but may be used in the future.

18. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria pollutant. None identified but may have some in the future.

SECTION V. OKLAHOMA AIR QUALITY RULES

OAC 252:100-1 (General Provisions) [Applicable]Subchapter 1 includes definitions but there are no regulatory requirements.


OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]Subchapter 3 enumerates the primary and secondary ambient air quality standards and the significant deterioration increments. At this time, all of Oklahoma is in attainment of these standards.

OAC 252:100-4 (New Source Performance Standards) [Not Applicable]Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on July 1, 2002, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix G. These requirements are covered in the “Federal Regulations” section.

OAC 252:100-5 (Registration, Emission Inventory, and Annual 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 establishes general administrative requirements for Part 70/Title V Permits. Any changes in the operation of the facility which could potentially result in emissions not authorized in the permit and which do not meet the definitions of “Insignificant Activities” or “Trivial Activities” may require prior notification to AQD and/or a permit modification. Insignificant Activities refer to individual emission units that either are specifically identified in Appendix I (OAC 252:100) or for which actual calendar year emissions do not exceed the following limits:

5 TPY of any one criteria pollutant; 2 TPY of any one 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, 0.6 TPY of any one Category A toxic substance, 1.2 TPY of any one Category B toxic substance, 6.0 TPY of any one Category C toxic substance.

Emissions estimates are from the application.

OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable]In the event of any release which results in excess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10) working days after the immediate notice is given, the owner or operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. Part 70/Title V sources must report any exceedance that poses an imminent and substantial danger to public health, safety, or the environment as soon as is practicable. Under no circumstances shall notification be more than 24 hours after the exceedance.


OAC 252:100-13 (Prohibition of Open Burning) [Applicable]Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter.

OAC 252:100-19 (Particulate Matter (PM)) [Applicable]Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with emission limits based on maximum design heat input rating. Appendix C specifies a PM emission limitation of 0.60 lb/MMBTU for all equipment at this facility with a heat input rating of 10 Million BTU per hour (MMBTUH) or less. Fuel-burning equipment is defined in OAC 252:100-1 as “combustion devices used to convert fuel or wastes to usable heat or power.” Thus, the compressor engines are subject to the requirements of this subchapter.For 2 cycle/4 cycle engines, AP-42 (7/00), Section 3.2 lists the total PM emissions to be 0.0091 lbs/MMBTU, which is in compliance.This permit requires the use of natural gas for all fuel-burning equipment to ensure compliance with Subchapter 19. This subchapter also limits emissions of PM from industrial processes. Per AP-42 factors, there are no significant PM emissions from any industrial activity at this facility.

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]No discharge of greater than 20% opacity is allowed except for short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. When burning natural gas, this facility has negligible potential to violate this requirement.

OAC 252:100-29 (Fugitive Dust) [Applicable]This subchapter states that no person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. Under normal operating conditions, this facility has negligible potential to violate this requirement, therefore it is not necessary to require specific precautions to be taken.

OAC 252:100-31 (Sulfur Compounds) [Applicable]Part 5 limits sulfur dioxide emissions from new equipment (constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lb/million BTU heat input. This is equivalent to approximately 0.2 weight percent sulfur in the fuel gas which is equivalent to 2,000 ppm sulfur. Thus, a limitation of 159 ppm sulfur in a field gas supply will be in compliance. The permit requires the use of pipeline-grade natural gas or field gas with a maximum sulfur content of 159 ppm for all fuel-burning equipment to ensure compliance with Subchapter 31. The Gas Research Institute (GRI) has determined that only 12% of all of Oklahoma’s (and other states common to the Anadarko Basin) natural gas production exceeds 4 ppm sulfur as H2S. Therefore, compliance with the standard of 159 ppm is assured by requiring initial compliance testing of the fuel sulfur content and further testing whenever the gas supplier or gas field is changed.


OAC 252:100-33 (Nitrogen Oxides) [Not Applicable]This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or equal to 50 MMBTUH to emissions of 0.2 lb of NOx per MMBTU. There are no equipment items that exceed the 50 MMBTUH threshold.

OAC 252:100-35 (Carbon Monoxide) [Not Applicable]This facility has none of the affected sources: gray iron cupola, blast furnace, basic oxygen furnace, petroleum catalytic reforming unit or petroleum catalytic cracking unit.

OAC 252:100-37 (Organic Materials) [Applicable]Part 3 requires VOC storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. The methanol tank, and the condensate tanks are pressurized and were constructed prior to the effective date of this standard and are “grandfathered.” The gasoline tank is equipped for submerged fill.Part 3 sets emission controls for loading of volatile organic compounds at facilities that have a throughput greater than 40,000 gallons/day. The amount of condensate throughput per year is much less than this level and qualifies as an insignificant activity.Part 5 limits the VOC content of coatings used in coating lines or operations. This facility will not normally conduct coating or painting operations except for routine maintenance of the facility and equipment, which is exempt.Part 7 requires fuel-burning and refuse-burning equipment to be operated to minimize emissions of VOC. The equipment at this location is subject to this requirement.Part 7 requires all effluent water separator openings, which receive water containing more than 200 gallons per day of any VOC, to be sealed or the separator to be equipped with an external floating roof or a fixed roof with an internal floating roof or a vapor recovery system. No effluent water separators are located at this facility.Part 7 also requires all reciprocating pumps and compressors handling VOCs to be equipped with packing glands that are properly installed and maintained in good working order and rotating pumps and compressors handling VOCs to be equipped with mechanical seals. The equipment at this location is subject to this requirement.

OAC 252:100-41 (Hazardous Air Pollutants and Toxic Air Contaminants) [Applicable]Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted by reference as they exist on July 1, 2003, with the exception of Subparts B, H, I, K, Q, R, T, W and Appendices D and E, all of which address radionuclides. In addition, General Provisions as found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, J, L, M, N, O, Q, R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS, TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO, PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, GGGG, HHHH, JJJJ, NNNN, OOOO, QQQQ, RRRR, SSSS, TTTT, UUUU, VVVV, WWWW, XXXX, BBBBB, CCCCC, FFFFF, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP, QQQQQ, and SSSSS are hereby adopted by reference as they exist on July 1, 2003. These standards apply to both existing and new sources of HAPs. These requirements are covered in the “Federal Regulations” section.Part 5 is a state-only requirement governing toxic air contaminants. Part 5 regulates sources of


toxic air contaminants that have emissions exceeding a de minimis level. However, Part 5 of Subchapter 41 has been superseded by OAC 252:100-42. The Air Quality Council approved Subchapter 42 for permanent rulemaking on April 20, 2005. The Environmental Quality Board approved Subchapter 42 as both a permanent and emergency rule on June 21, 2005. The emergency Subchapter 42 was sent for Gubernatorial signature on June 30, 2005, and will become effective by emergency no later than August 13, 2005. Subchapter 42 is expected to become permanently effective on June 15, 2006. Because Subchapter 41, Part 5 has been superseded, the requirements of Part 5 will not be reviewed in this memorandum. Should Subchapter 42 fail to take effect, this permit will be reopened to address the requirements of Subchapter 41, Part 5.

Dehydration units using glycol desiccants will emit benzene, toluene, ethyl benzene, xylenes and n-hexane from the glycol reboiler vapor stack. These compounds are regulated as toxic air contaminants. OAC 252:100-41-40 provides classifications of air toxics According to these classifications, Benzene is a Category A toxic while the others are Category C toxics. The emissions from the glycol regeneration still vent were calculated using GLYCalc 4.0 based on a maximum gas throughput of 27.2 MMSCFD, a maximum glycol circulation rate of 4 gpm, and with a condenser. BACT is present in the form of a condenser installed on the glycol reboiler still vent with the uncondensed vapors being routed to the reboiler for destruction. With the condenser in operation, all emissions of toxics will be below the de minimis levels. The permit will require the glycol reboiler to be operated with the condenser or an alternative control device provided that it meets the same or better control of emissions.

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 to demonstrate compliance with any federal or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or monitoring not conducted in accordance with the provisions of this subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.


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

OAC 252:100-11 Alternative Reduction not requestedOAC 252:100-15 Mobile Sources not in source categoryOAC 252:100-17 Incinerators not type of emission unitOAC 252:100-23 Cotton Gins not type of emission unitOAC 252:100-24 Feed & Grain Facility not in source categoryOAC 252:100-39 Nonattainment Areas not in a subject areaOAC 252:100-47 Landfills not type of source category

SECTION VI. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable]Final total facility emissions are greater than the PSD major source threshold of 250 TPY for regulated pollutants NOx & CO. The facility is considered an existing major source for PSD and any future emission increases must be evaluated for PSD if they exceed a significance level (40 TPY for NOx, 100 TPY for CO, 40 TPY for VOC, 40 TPY for SO2, 25 TPY for TSP, 15 TPY for PM, 0.6 TPY for Pb, and 10 TPY for TRS).

NSPS, 40 CFR Part 60 [Not Applicable]Subpart Kb, VOL Storage Vessels. This subpart regulates hydrocarbon storage tanks larger than 19,812 gallons capacity and built after July 23, 1984. The two 1,238-barrel (52,000) condensate tanks at the site are not subject because they were constructed prior to the effective date of Subpart K, they are pressurized tanks with an operating pressure of 20 psia, and they store condensate prior to custody transfer as defined by Subpart K.Subpart GG, Stationary Gas Turbines. There are none at this facility.Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing Industry. The equipment is not in a SOCMI plant.Subpart LLL sets standards for natural gas sweetening units. There is no natural gas sweetening operation at this site.Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. The facility does not engage in natural gas processing.

NESHAP, 40 CFR Part 61 [Not Applicable]There are no emissions of any of the regulated pollutants: arsenic, asbestos, beryllium, benzene, coke oven emissions, mercury, radionuclides or vinyl chloride except for trace amounts of benzene. Subpart J, Equipment Leaks of Benzene, only affects process streams which contain more than 10% benzene by weight. All process streams at this facility are below this threshold.

NESHAP, 40 CFR Part 63 [Applicable]Subpart HH, Oil and Natural Gas Production Facilities. This subpart applies to affected emission points that are located at facilities which are major sources of HAPs and either process, upgrade, or store hydrocarbons prior to the point of custody transfer or prior to which the natural gas enters the natural gas transmission and storage source category. This facility is not a major source of HAPs as defined in this subpart.


Subpart HHH, Natural Gas Transmission and Storage. This subpart was published in the Federal Register on June 17, 1999, and affects Natural Gas Transmission and Storage Facilities. It applies to affected emission points that are located at facilities that are major sources of HAPs, as defined in this subpart, and that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final end user. A compressor station that transports natural gas prior to the point of custody transfer, or to a natural gas processing plant (if present) is considered a part of the oil and natural gas production source category. The compressed gas leaving this facility is not processed until it goes North to Bushton facility; therefore, the facility is not subject to this subpart.

Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE), This subpart was published in the Federal Register on June 15, 2004 and would affect the following RICE with a site rating greater than 500 brake horsepower and which are located at a major source of HAP emissions: existing, new, and reconstructed spark ignition 4 stroke rich burn (4SRB) RICE, any new or reconstructed spark ignition 2 stroke lean burn (2SLB) or 4 stroke lean burn (4SLB) RICE, or any new or reconstructed compression ignition (CI) RICE. This facility is a major source of formaldehyde, which is a HAP. Consequently, the 1,818 hp Caterpillar G3516B emergency generator (A-6) is subject to this subpart. NNG submitted initial notification form to ODEQ and EPA Region VI on December 10, 2004 as a limited requirement for new emergency stationary RICE (§63.6590(b)(1)(i)).

Compliance Assurance Monitoring, 40 CFR Part 64 [Not Applicable]This part applies to any pollutant-specific emission unit at a major source that is required to obtain an operating permit, for any application for an initial operating permit submitted after April 18, 1998, that addresses “large emissions units,” or any application that addresses “large emissions units” as a significant modification to an operating permit, or for any application for renewal of an operating permit, if it meets all of the following criteria.

It is subject to an emission limit or standard for an applicable regulated air pollutant It uses a control device to achieve compliance with the applicable emission limit or standard It has potential emissions, prior to the control device, of the applicable regulated air

pollutant of 100 TPY or 10/25 TPY of a HAP.

Since potential pre-control emissions from the TEG dehydration unit not exceed major source levels (10/25 TPY of a HAP), the TEG dehydration unit with a condenser is not subject to CAM.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable]The definition of a stationary source does not apply to transportation, including storage incident to transportation, of any regulated substance or any other extremely hazardous substance under the provisions of this part. The definition of a stationary source also does not include naturally occurring hydrocarbon reservoirs. Naturally occurring hydrocarbon mixtures, prior to entry into a natural gas processing plant or a petroleum refining process unit, including: condensate, crude oil, field gas, and produced water, are exempt for the purpose of determining whether more than a threshold quantity of a regulated substance is present at the stationary source.


Stratospheric Ozone Protection, 40 CFR Part 82 [Applicable]These standards require phase out of Class I & II substances, reductions of emissions of Class I & II substances to the lowest achievable level in all use sectors, and banning use of nonessential products containing ozone-depleting substances (Subparts A & C); control servicing of motor vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations which meet phase out requirements and which maximize the substitution of safe alternatives to Class I and Class II substances (Subpart D); require warning labels on products made with or containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons (Subpart H).Subpart A identifies ozone-depleting substances and divides them into two classes. Class I controlled substances are divided into seven groups; the chemicals typically used by the manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform (Class I, Group V). A complete phase-out of production of Class I substances is required by January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs. Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances, scheduled in phases starting by 2002, is required by January 1, 2030.

This facility does not utilize any Class I & II substances.

SECTION VII. COMPLIANCE

InspectionAn inspection was conducted on March 8, 2005. The inspection was conducted by Kha Mach of Air Quality who was accompanied David Kinney, Plant Environmental Coordinator, and Mr. Michael Reidel, Environmental Specialist for NNG. The facility was as described in the permit application. The plant was operated around 776 MMSCFD of natural gas with 6 inlets and 5 outlets. All 5 Worthington UTC-10, five Ingersoll-Rand 412 KVS, two 6,000-hp Clark TCVA-16, 8,000-hp Clark TCVC-16, and an emergency generator have a permanent identification plate attached which shows the make, model number, and serial number. All auxiliary engines (Ingersoll-Rand PVG) were removed and replaced by CAT emergency generator. ENG1 through ENG7 are horizontal piston engines that are abandoned in place and inoperative. Heaters, tanks and TEG unit were also constructed as described in the permit application. The methanol tank and condensate tanks were pressurized and are not required to be equipped for submerged. The gasoline tank was equipped for bottom fill. O&M records will be kept onsite.


Tier Classification and Public ReviewThis application has been determined to be a Tier II based on the request for a renewal TV operating permit for a major source.

The permittee has submitted an affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without their knowledge. The affidavit certifies that the applicant owns the land which will be used to accomplish the permitted purpose.

The applicant published the “Notice of Filing a Tier II Application” in The Herald-Democrat, a weekly newspaper, in Beaver County, on October 23, 2003. The Notice stated that the application was available for public review at the facility or at the Air Quality Division’s main office. The applicant will publish the “Notice of Tier II Draft Permit.”

This facility is located within 50 miles of the Kansas-Oklahoma border and the Texas-Oklahoma border. The states of Kansas and Texas will be notified of the draft permit.

Fees PaidThe Part 70 operating permit renewal application fee of $1,000 has been paid.

SECTION VIII. SUMMARY

The facility is constructed as described in the permit application. Ambient air quality standards are not threatened at this site. There are no active compliance or enforcement Air Quality issues concerning this facility. Issuance of the permit is recommended, contingent on public and EPA review.

DRAFT

PERMIT TO OPERATEAIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Northern Natural Gas Company Permit Number 2002-532-TVRBeaver County Compressor Station

The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on December 23, 2002, and subsequent supplemental materials on December 14, 2004, and March 8, 2005. The Evaluation Memorandum, dated June 30, 2005, explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain operating limitations or permit requirements. Continuing operations under this permit constitutes acceptance of, and consent to, the conditions contained herein:

1. Points of emissions and emissions limitations for each point: [OAC 252:100-8-6(a)(1)]

EUG 1: Emission Units (EUs) ENG8 through ENG21 are grandfathered. There are no emission limits applied to these units under Title V but they are limited to the existing equipment as they are.

EU Point Make/Model hp Serial #ENG8 8 Worthington UTC-10 1,894 G-2196ENG9 9 Worthington UTC-10 1,894 G-2197ENG10 10 Worthington UTC-10 1,894 G-2198ENG11 11 Worthington UTC-10 1,894 G-2208ENG12 12 Worthington UTC-10 1,894 G-2209ENG13 13 Worthington UTC-10 1,894 G-2210ENG14 14 Ingersoll-Rand 412

KVS1,998 412CT183

ENG15 15 Ingersoll-Rand 412 KVS

1,998 412CT238


1,998 412DT241


1,998 412ET292


1,998 412ET337

ENG19 19 Clark TCVA-16 6,000 115003ENG20 20 Clark TCVA-16 6,000 115005ENG21 21 Clark TCVC-16 8,000 120501

DRAFTSPECIFIC CONDITIONS 2002-532-TVR 2

EUG 2: Emission units H1, H5, H8, and H9 are grandfathered. Emission units H3, H4, H6, H7, H10, and H11 have emissions below the de minimis amounts. There are no emission limits applied to these units under Title V but they are limited to the existing equipment as they are.

EU Point Make/Model MMBTUHH1 Dehydrator Regeneration heater 4.0H5 Dehydrator Regeneration heater 8.0H8 Dehydrator Regeneration heater 6.3H9 Glycol Regenerator 1.0

H3 Dehydrator Regeneration heater 8.4H4 Dehydrator Regeneration heater 5.2H6 Kewanee Steam Boiler 5.0H7 Kewanee Steam Boiler 5.0H10 Condensate Heater 0.45H11 Condensate Heater 0.45

EUG 3: Storage tank VOC emissions are estimated based on existing equipment items but do not have a specific limitation.

EU Contents Barrels GallonsTanks Condensate 714 30,000

Condensate 714 30,000Ethylene Glycol 143 6,000Methanol 420 17,625Lube Oil 197 8,272Lube Oil 197 8,272Lube Oil 310 13,000Lube Oil 283 12,000Lube Oil 12 500Used Oil (UST) (Drain Tank) 210 8,800Cooling Water (UST) 210 8,800Gasoline 12 500Diesel 12 500Water 400 16,800Water 400 16,800

EUG 4: Fugitive VOC emissions are estimated based on existing equipment items but do not have a specific limitation.

EU Number Items Type of EquipmentFugitives 500 Valves

2000 Flanges39 Other


2. The fuel-burning equipment shall use pipeline-grade natural gas or field gas with a maximum sulfur content of 159 ppm. [OAC 252:100-31]

3. The permittee shall be authorized to operate this facility continuously (24 hours per day, every day of the year). [OAC 252:100-8-6(a)]

4. Each engine/turbine at the facility shall have a permanent identification plate attached which shows the make, model number, and serial number. [OAC 252:100-45]

5. Replacement (including temporary periods of 6 months or less for maintenance purposes), of the internal combustion engines with emissions specified in this permit with engines/turbines of lesser or equal emissions of each pollutant (in lbs/hr and TPY) are authorized under the following conditions. [OAC 252:100-8-6 (f)]

a. The permittee shall notify AQD in writing within 10 days of start-up of the replacement engine(s)/turbine(s). Said notice shall identify the old engine/turbine and shall include the new engine/turbine make and model, horsepower rating, fuel usage, stack flow (ACFM), stack temperature (F), stack height (feet), stack diameter (inches), and pollutant emission rates (g/hp-hr, lb/hr, and TPY) at maximum horsepower for the altitude/location.

b. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to confirm continued compliance with NOx and CO emission limitations. A copy of the first quarter testing shall be provided to AQD within 60 days of start-up of each replacement or additional engine/turbine. The test report shall include the engine/turbine fuel usage, stack flow (ACFM), stack temperature (oF), stack height (feet), stack diameter (inches), and pollutant emission rates (g/hp-hr, lb/hr, and TPY) at maximum rated horsepower for the altitude/location.

c. Replacement of equipment and emissions are limited to equipment and emissions that are not subject to NSPS, NESHAP, or PSD. Replacement engines/turbines for “Grandfathered” emission units become subject to emission limitations.

6. The permittee shall continue to operate and maintain a condenser on the glycol dehydrator still vent when the dehydration unit is in operation. The system shall condense and contain the overhead still vapors, then route uncondensed vapors to the reboiler for destruction. An alternative system to control emissions may be utilized provided that it achieves a minimum level of 95% efficiency. [OAC 252:100-8-6(a)]

7. The permittee shall keep operation and maintenance (O&M) records for those “grandfathered/exempted” emission units identified in EUG 1 which have not been modified and for those replacement or additional engines/turbines which do not conduct quarterly testing. Such records shall at a minimum include the dates of operation, and maintenance, type of work performed, and the increase, if any, in emissions as a result.

[OAC 252:100-8-6 (a)(3)(B)]


8. At least once per calendar quarter, the permittee shall conduct tests of NOx and CO emissions in exhaust gases from each permitted engine and from each replacement engine/turbine when operating under representative conditions for that period. Testing is required for any engine/turbine that runs for more than 220 hours during that calendar quarter. Engines/turbines shall be tested no sooner than 20 calendar days after the last test. Testing shall be conducted using a portable analyzer in accordance with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method approved by Air Quality. When four consecutive quarterly tests show the engine/turbine to be in compliance with the emissions limitations shown in the permit, then the testing frequency may be reduced to semi-annual testing. Likewise, when the following two consecutive semi-annual tests show compliance, the testing frequency may be reduced to annual testing. Upon any showing of non-compliance with emissions limitations or testing that indicates that emissions are within 10% of the emission limitations, the testing frequency shall revert to quarterly. Any reduction in the testing frequency shall be noted in the next required compliance certification. Reduced testing frequency does not apply to engines with catalytic converters. [OAC 252:100-8-6 (a)(3)(A)]

9. The permittee shall maintain records of operations as listed below. These records shall be maintained on site or at a local field office for at least five years after the date of recording and shall be provided to regulatory personnel upon request. [OAC 252:100-8-6 (a)(3)(B)]

a. Operation, maintenance, and inspection log for the grandfathered/exempted engines and for any replacement or additional engine/turbine not tested in each 6 month period.

b. Periodic emission testing for each replacement or additional engine/turbine.c. Analysis of current fuel gas sulfur content (updated whenever the supply changes).

10. All new volatile organic compound tanks with a capacity of 400 gallons or more and storing a liquid which has a vapor pressure of 1.5 psia or greater shall be equipped with a permanent submerged fill pipe or an organic vapor recovery system. [OAC 252:100-37]

11. The Triethylene Glycol dehydration unit shall be installed and operated as follows:

a. The natural gas throughput of the glycol dehydration unit shall not exceed 27.2 MMSCFD (annual average).

b. The glycol dehydration unit shall be equipped with a flash tank and a condenser. Emissions from the flash tank shall be routed to the glycol dehydration unit’s reboiler firebox or equally effective control device of 95% control efficiency. Emissions from the glycol dehydration units still vent shall be routed through the condenser or an equally effective control device (VOC control efficiency of at least 95%) prior to being emitted to the atmosphere.

c. The condenser shall be equipped with a properly functioning thermometer to measure the outlet temperature of the condenser.

d. The discharge temperature of the dehydration unit’s condenser shall not exceed 120F.

e. The permittee shall record the outlet temperature of the condenser at least monthly during daylight hours.


12. The following records shall be maintained on site to verify Insignificant Activities. No recordkeeping is required for those operations which qualify as Trivial Activities.

[OAC 252:100-8-6 (a)(3)(B)]

a. For stationary reciprocating engines used exclusively for emergency power generation or for peaking power service: Records of the size of engines, type of fuel used, and number of hours operated (annual).

b. For fuel storage/dispensing equipment operated solely for facility owned vehicles: Records of the type and amount of fuel dispensed (annual).

c. For crude oil and condensate storage tanks with a capacity of less than or equal to 420,000 gallons that store crude oil and condensate prior to custody transfer: Records of capacity of the tanks and the amount of throughput (annual).

d. For fluid storage tanks with a capacity of less than 39,894 gallons and a true vapor pressure less than 1.5 psia: Records of capacity of the tanks and contents.

e. For activities that have the potential to emit less than 5 TPY (actual) of any criteria pollutant: The type of activity and the amount of emissions from that activity (annual).

13. No later than 30 days after each anniversary date of the issuance of the original Title V permit (June 23, 1998), the permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of this permit. The following specific information for the past year is required to be included: [OAC 252:100-8-6 (c)(5)(A) & (D)]

a. Operation, and maintenance reports for grandfathered/exempted engines.b. Periodic emission testing for each replacement or additional engine/turbine.c. Testing results for each engine/turbine which is not grandfathered/exempted

(quarterly or other applicable period).d. Operating hours of engines/turbines which are not grandfathered, which are

operated less than 220 hours, and are not tested in a quarter.

This information shall also be submitted to the Air Quality Division no later than 30 days after each six month period following the issuance of this permit.

14. This permit supersedes all previous Air Quality permits for this facility, which are now null and void.

DRAFT

PART 70 PERMIT

AIR QUALITY DIVISIONSTATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY707 N. ROBINSON, SUITE 4100

P.O. BOX 1677OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2002-532-TVR

Northern Natural Gas Company,

having complied with the requirements of the law, is hereby granted permission to operate

the Beaver Compressor Station, located at Section 24, T2N, R24E, IM, Beaver County,

Oklahoma.

subject to the following conditions attached:

[x] Standard Conditions dated March 9, 2005

[x] Specific Conditions

This permit shall expire five (5) years from the date below, except as authorized under

Section VIII of the Standard Conditions.

DEQ Form #100-890 Revised 2/14/05

Division Director, Air Quality Division Date

DRAFT

Northern Natural Gas CompanyAttn: Mr. Steven Mitchell451 S. Country Estates RoadLiberal, Kansas 67901

Re: Permit Application No. 2002-532-TVRBeaver Compressor StationSection 24, T2N, R24E, IM, Beaver County, Oklahoma

Dear Mr. Mitchell:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this permit is issued subject to standards and specific conditions, which are attached. These conditions must be carefully followed since they define the limits of the permit and will be confirmed by periodic inspections.

Also note that you are required to annually submit an emissions inventory for this facility. An emissions inventory must be completed on approved AQD forms and submitted (hardcopy or electronically) by March 1st of every year. Any questions concerning the form or submittal process should be referred to the Emissions Inventory Staff at 405-702-4100.

Thank you for your cooperation in this matter. If we may be of further service, please contact our office at (405) 702-4100.

Sincerely,

Kha Mach, E.I.Existing Source Permits SectionAIR QUALITY DIVISION

Enclosure

cc: Beaver County DEQ Office

TITLE V (PART 70) PERMIT TO OPERATE / CONSTRUCTSTANDARD CONDITIONS

(March 9, 2005)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with Title V of the federal Clean Air Act (42 U.S.C. 7401, et seq.) and under the authority of the Oklahoma Clean Air Act and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma Department of Environmental Quality (DEQ). The permit does not relieve the holder of the obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or ordinances. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement action, for revocation of the approval to operate under the terms of this permit, or for denial of an application to renew this permit. All terms and conditions (excluding state-only requirements) are enforceable by the DEQ, by EPA, and by citizens under section 304 of the Clean Air Act. This permit is valid for operations only at the specific location listed.

[40 CFR §70.6(b), OAC 252:100-8-1.3 and 8-6 (a)(7)(A) and (b)(1)]

D. It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of the permit. [OAC 252:100-8-6 (a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from emergency conditions and/or posing an imminent and substantial danger to public health, safety, or the environment shall be reported in accordance with Section XIV. [OAC 252:100-8-6 (a)(3)(C)(iii)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

[OAC 252:100-8-6 (a)(3)(C)(iv)]

C. Oral notifications (fax is also acceptable) shall be made to the AQD central office as soon as the owner or operator of the facility has knowledge of such emissions but no later than 4:30 p.m. the next working day the permittee becomes aware of the exceedance. Within ten (10) working days after the immediate notice is given, the owner operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. Every written report submitted under OAC 252:100-8-6 (a)(3)(C)(iii) shall be certified by a responsible official. [OAC 252:100-8-6 (a)(3)(C)(iii)]

TITLE V PERMIT STANDARD CONDITIONS March 9, 2005 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. Unless a different retention period or retention conditions are set forth by a specific term in this permit, these records, including monitoring data and necessary support information, shall be retained on-site or at a nearby field office for a period of at least five years from the date of the monitoring sample, measurement, report, or application, and shall be made available for inspection by regulatory personnel upon request. Support information includes all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Where appropriate, the permit may specify that records may be maintained in computerized form.

[OAC 252:100-8-6 (a)(3)(B)(ii), 8-6 (c)(1), and 8-6 (c)(2)(B)]

B. Records of required monitoring shall include:(1) the date, place and time of sampling or measurement;(2) the date or dates analyses were performed;(3) the company or entity which performed the analyses;(4) the analytical techniques or methods used;(5) the results of such analyses; and(6) the operating conditions as existing at the time of sampling or measurement.

[OAC 252:100-8-6 (a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the original Part 70 operating permit, the permittee shall submit to AQD a report of the results of any required monitoring. All instances of deviations from permit requirements since the previous report shall be clearly identified in the report. [OAC 252:100-8-6 (a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or operator shall comply with the provisions of Section II of these standard conditions.

[OAC 252:100-8-6 (a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this permit, monitoring and reporting may be required under the provisions of OAC 252:100-43, Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean Air Act or Oklahoma Clean Air Act.

F. Submission of quarterly or semi-annual reports required by any applicable requirement that are duplicative of the reporting required in the previous paragraph will satisfy the reporting requirements of the previous paragraph if noted on the submitted report.

G. Every report submitted under OAC 252:100-8-6 and OAC 252:100-43 shall be certified by a responsible official.

[OAC 252:100-8-6 (a)(3)(C)(iv)]


H. Any owner or operator subject to the provisions of NSPS shall maintain records of the occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected facility or any malfunction of the air pollution control equipment. [40 CFR 60.7 (b)]

I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all measurements and other information required by the subpart recorded in a permanent file suitable for inspection. This file shall be retained for at least two years following the date of such measurements, maintenance, and records. [40 CFR 60.7 (d)]

J. The permittee of a facility that is operating subject to a schedule of compliance shall submit to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for achieving the activities, milestones or compliance required in the schedule of compliance and the dates when such activities, milestones or compliance was achieved. The progress reports shall also contain an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventative or corrective measures adopted. [OAC 252:100-8-6 (c)(4)]

K. All testing must be conducted by methods approved by the Division Director under the direction of qualified personnel. All tests shall be made and the results calculated in accordance with standard test procedures. The use of alternative test procedures must be approved by EPA. When a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated in accordance with the manufacturer’s instructions and in accordance with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method approved by AirQuality. [40 CFR §70.6(a), 40 CFR §51.212(c)(2), 40 CFR § 70.7(d), 40 CFR §70.7(e)(2), OAC 252:100-8-6 (a)(3)(A)(iv), and OAC 252:100-43]

L. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required by 40 CFR Part 60, 61, and 63, for all equipment constructed or operated under this permit subject to such standards. [OAC 252:100-4-5 and OAC 252:100-41-15]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70 operating permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of this permit and of any other applicable requirements which have become effective since the issuance of this permit. The compliance certification shall also include such other facts as the permitting authority may require to determine the compliance status of the source.

[OAC 252:100-8-6 (c)(5)(A), (C)(v), and (D)]

B. The certification shall describe the operating permit term or condition that is the basis of the certification; the current compliance status; whether compliance was continuous or intermittent; the methods used for determining compliance, currently and over the reporting period; and a statement that the facility will continue to comply with all applicable requirements.

[OAC 252:100-8-6 (c)(5)(C)(i)-(iv)]


C. Any document required to be submitted in accordance with this permit shall be certified as being true, accurate, and complete by a responsible official. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the certification are true, accurate, and complete.

[OAC 252:100-8-5 (f) and OAC 252:100-8-6 (c)(1)]

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions units or stationary sources that are not in compliance with all applicable requirements. This schedule shall include a schedule of remedial measures, including an enforceable sequence of actions with milestones, leading to compliance with any applicable requirements for which the emissions unit or stationary source is in noncompliance. This compliance schedule shall resemble and be at least as stringent as that contained in any judicial consent decree or administrative order to which the emissions unit or stationary source is subject. Any such schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the applicable requirements on which it is based, except that a compliance plan shall not be required for any noncompliance condition which is corrected within 24 hours of discovery.

[OAC 252:100-8-5 (e)(8)(B) and OAC 252:100-8-6 (c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the permit term and that are applicable to the facility. Compliance with all new requirements shall be certified in the next annual certification. [OAC 252:100-8-6 (c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions established for alternate operating scenarios, emissions trading, and emissions averaging, but excluding terms and conditions for which the permit shield is expressly prohibited under OAC 252:100-8) shall be deemed compliance with the applicable requirements identified and included in this permit. [OAC 252:100-8-6 (d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific Conditions of this permit. Those requirements that the applicant requested be determined as not applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6 (d)(2)]

SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees based on emissions inventories. The methods used to calculate emissions for inventory purposes shall be based on the best available information accepted by AQD.

[OAC 252:100-5-2.1, -5-2.2, and OAC 252:100-8-6 (a)(8)]


SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date of issuance. [OAC 252:100-8-6 (a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely and complete renewal application has been submitted at least 180 days before the date of expiration. [OAC 252:100-8-7.1 (d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction is not commenced within 18 months after the date the permit or authorization was issued, or if work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

[OAC 252:100-8-6 (a)(6)]

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege.[OAC 252:100-8-6 (a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon which the equipment is located and does not release the permittee from any liability for damage to persons or property caused by or resulting from the maintenance or operation of the equipment for which the permit is issued. [OAC 252:100-8-6 (c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty (60) days of the request unless the DEQ specifies another time period, any information that the DEQ may request to determine whether cause exists for modifying, reopening, revoking, reissuing, terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the DEQ copies of records required to be kept by the permit.

[OAC 252:100-8-6 (a)(7)(E)]


B. The permittee may make a claim of confidentiality for any information or records submitted pursuant to 27A O.S. 2-5-105(18). Confidential information shall be clearly labeled as such and shall be separable from the main body of the document such as in an attachment.

[OAC 252:100-8-6 (a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and shall be made in writing within 10 days after such date.

[Oklahoma Clean Air Act, 27A O.S. § 2-5-112 (G)]

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause. Except as provided for minor permit modifications, the filing of a request by the permittee for a permit modification, revocation, reissuance, termination, notification of planned changes, or anticipated noncompliance does not stay any permit condition.

[OAC 252:100-8-6 (a)(7)(C) and OAC 252:100-8-7.2 (b)]

B. The DEQ will reopen and revise or revoke this permit as necessary to remedy deficiencies in the following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source category three or more years prior to the expiration date of this permit. No such reopening is required if the effective date of the requirement is later than the expiration date of this permit.

(2) The DEQ or the EPA determines that this permit contains a material mistake or that the permit must be revised or revoked to assure compliance with the applicable requirements.

(3) The DEQor the EPA determines that inaccurate information was used in establishing the emission standards, limitations, or other conditions of this permit. The DEQ may revoke and not reissue this permit if it determines that the permittee has submitted false or misleading information to the DEQ.

C. If “grandfathered” status is claimed and granted for any equipment covered by this permit, it shall only apply under the following circumstances: [OAC 252:100-5-1.1]

(1) It only applies to that specific item by serial number or some other permanent identification.

(2) Grandfathered status is lost if the item is significantly modified or if it is relocated outside the boundaries of the facility.

D. To make changes other than (1) those described in Section XVIII (Operational Flexibility), (2) administrative permit amendments, and (3) those not defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII), the permittee shall notify AQD. Such changes may require a permit modification. [OAC 252:100-8-7.2 (b)]


E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that are not specifically approved by this permit are prohibited. [OAC 252:100-8-6 (c)(6)]

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of credentials and other documents as may be required by law, the permittee shall allow authorized regulatory officials to perform the following (subject to the permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18) for confidential information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a source is located or emissions-related activity is conducted, or where records must be kept under the conditions of the permit;

(2) have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit;

(3) inspect, at reasonable times and using reasonable safety practices, any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit; and

(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the permit.

[OAC 252:100-8-6 (c)(2)]

SECTION XIV. EMERGENCIES

A. Any emergency and/or exceedance that poses an imminent and substantial danger to public health, safety, or the environment shall be reported to AQD as soon as is practicable; but under no circumstance shall notification be more than 24 hours after the exceedance.

[OAC 252:100-8-6 (a)(3)(C)(iii)(II)]

B. An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under this permit, due to unavoidable increases in emissions attributable to the emergency. [OAC 252:100-8-2]

C. An emergency shall constitute an affirmative defense to an action brought for noncompliance with such technology-based emission limitation if the conditions of paragraph D below are met.

[OAC 252:100-8-6 (e)(1)]

D. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs or other relevant evidence that:

(1) an emergency occurred and the permittee can identify the cause or causes of the emergency;

(2) the permitted facility was at the time being properly operated;


(3) during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in this permit;

(4) the permittee submittedtimely notice of the emergency to AQD, pursuant to the applicable regulations (i.e., for emergencies that pose an “imminent and substantial danger,” within 24 hours of the time when emission limitations were exceeded due to theemergency; 4:30 p.m. the next business day for all other emergency exceedances). See OAC 252:100-8-6(a)(3)(C)(iii)(I) and (II). This notice shall contain a description of the emergency, the probable cause of the exceedance, any steps taken to mitigate emissions, and corrective actions taken; and

(5) the permittee submitted a follow up written report within 10 working days of first becoming aware of the exceedance.

[OAC 252:100-8-6 (e)(2), (a)(3)(C)(iii)(I) and (IV)]

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency shall have the burden of proof. [OAC 252:100-8-6 (e)(3)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop and register with the appropriate agency a risk management plan by June 20, 1999, or the applicable effective date. [OAC 252:100-8-6 (a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate individual emissions units that are either on the list in Appendix I to OAC Title 252, Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below. Any activity to which a State or federal applicable requirement applies is not insignificant even if it meets the criteria below or is included on the insignificant activities list. [OAC 252:100-8-2]

(1) 5 tons per year of any one criteria pollutant.(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an

aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year for single HAP that the EPA may establish by rule.

(3) 0.6 tons per year for any one category A substance, 1.2 tons per year for any one category B substance or 6 tons per year for any one category C substance as defined in 252:100-41-40.

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate any individual or combination of air emissions units that are considered inconsequential and are on the list in Appendix J. Any activity to which a State or federal applicable requirement applies is not trivial even if included on the trivial activities list. [OAC 252:100-8-2]


SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the need for any permit revision or any notification to the DEQ (unless specified otherwise in the permit). When an operating scenario is changed, the permittee shall record in a log at the facility the scenario under which it is operating. [OAC 252:100-8-6 (a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

(1) result in no net emissions increases,(2) are not modifications under any provision of Title I of the federal Clean Air Act, and(3) do not cause any hourly or annual permitted emission rate of any existing emissions

unit to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required below in advance of the proposed changes, which shall be a minimum of 7 days, or 24 hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such change, the written notification required above shall include a brief description of the change within the permitted facility, the date on which the change will occur, any change in emissions, and any permit term or condition that is no longer applicable as a result of the change. The permit shield provided by this permit does not apply to any change made pursuant to this subsection. [OAC 252:100-8-6 (f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility unless elsewhere covered by a more restrictive requirement:

(1) No person shall cause or permit the discharge of emissions such that National Ambient Air Quality Standards (NAAQS) are exceeded on land outside the permitted facility.

[OAC 252:100-3](2) Open burning of refuse and other combustible material is prohibited except as authorized

in the specific examples and under the conditions listed in the Open Burning Subchapter.[OAC 252:100-13]

(3) No particulate emissions from any fuel-burning equipment with a rated heat input of 10 MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(4) For all emissions units not subject to an opacity limit promulgated under 40 CFR, Part 60, NSPS, no discharge of greater than 20% opacity is allowed except for short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. [OAC 252:100-25]

(5) No visible fugitive dust emissions shall be discharged beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of


adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. [OAC 252:100-29]

(6) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2 lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur dioxide. [OAC 252:100-31]

(7) Volatile Organic Compound (VOC) storage tanks built after December28, 1974, and with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or greater under actual conditions shall be equipped with a permanent submerged fill pipe or with a vapor-recovery system. [OAC 252:100-37-15(b)]

(8) All fuel-burning equipment shall at all times be properly operated and maintained in a manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

(9) Except as otherwise provided, no person shall cause or permit the emissions of any toxic air contaminant in such concentration as to cause or to contribute to a violation of the MAAC. (State only) [OAC 252:100-41]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of ozone-depleting substances. [40 CFR 82, Subpart A]

1. Persons producing, importing, or placing an order for production or importation of certain class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the requirements of §82.4.

2. Producers, importers, exporters, purchasers, and persons who transform or destroy certain class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping requirements at §82.13.

3. Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons, HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane (Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term “motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions reduction except as provided for MVACs in Subpart B. [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to § 82.156.

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must


comply with the standards for recycling and recovery equipment pursuant to § 82.158.(3) Persons performing maintenance, service, repair, or disposal of appliances must be

certified by an approved technician certification program pursuant to § 82.161.(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must

comply with record-keeping requirements pursuant to § 82.166.(5) Persons owning commercial or industrial process refrigeration equipment must comply

with leak repair requirements pursuant to § 82.158.(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant

must keep records of refrigerant purchased and added to such appliances pursuant to § 82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is not inconsistent with Federal requirements, to provide for incorporation of requirements established through construction permitting into the Sources’ Title V permit without causing redundant review. Requirements from construction permits may be incorporated into the Title V permit through the administrative amendment process set forth in Oklahoma Administrative Code 252:100-8-7.2(a) only if the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the procedures set forth in 40 Code of Federal Regulations (CFR) § 70.7 (h)(1). This public notice shall include notice to the public that this permit is subject to Environmental Protection Agency (EPA) review, EPA objection, and petition to EPA, as provided by 40 CFR § 70.8; that the requirements of the construction permit will be incorporated into the Title V permit through the administrative amendment process; that the public will not receive another opportunity to provide comments when the requirements are incorporated into the Title V permit; and that EPA review, EPA objection, and petitions to EPA will not be available to the public when requirements from the construction permit are incorporated into the Title V permit.

(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR § 70.8(a)(1).

(3) A copy of the draft construction permit is sent to any affected State, as provided by 40 CFR § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period as provided by 40 CFR § 70.8(a) and (c).

(5) The DEQ complies with 40 CFR § 70.8 (c) upon the written receipt within the 45-day comment period of any EPA objection to the construction permit. The DEQ shall not issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 CFR § 70.8 (d). (7) A copy of the final construction permit is sent to EPA as provided by 40 CFR §

70.8 (a).


(8) The DEQ shall not issue the proposed construction permit until any affected State and EPA have had an opportunity to review the proposed permit, as provided by these permit conditions.

(9) Any requirements of the construction permit may be reopened for cause after incorporation into the Title V permit by the administrative amendment process, by DEQ as provided in OAC 252:100-8-7.3 (a), (b), and (c), and by EPA as provided in 40 CFR § 70.7 (f) and (g).

(10) The DEQ shall not issue the administrative permit amendment if performance tests fail to demonstrate that the source is operating in substantial compliance with all permit requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any provision of the Oklahoma implementation plan, nothing shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.

[OAC 252:100-43-6]

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