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DRAFT/PROPOSED

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM March 1, 2016

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

THROUGH: Rick Groshong, Compliance and Enforcement Manager

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

THROUGH: Peer Review

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

SUBJECT: Evaluation of Permit Application No. 2016-0042-TVR3

Baker Petrolite Corporation

Barnsdall Manufacturing Facility (Facility ID: 1390)

820 Birch Lake Road, Barnsdall, Osage County

SE/4 18, T24 N, R11 E (Office at 36.55485 N, 96.16529 W)

West on OK 11 approximately one mile from its intersection with OK 123;

turn left (west) on Chestnut as OK 11 bends to the north entering Barnsdall, ¼

mile to 8th

Street (Birch Lake Road), turn left (south) ¼ mile to facility.

SECTION I. INTRODUCTION

Baker Petrolite Corporation (Baker) has submitted an application to renew their Title V operating

permit for their Barnsdall Manufacturing Facility (SIC Code: 2869). This facility started

operations as a petroleum refinery in 1907. By the 1950s, the facility had specialized in

microcrystalline waxes and most other activities were discontinued. A production line for the

manufacture of synthetic waxes was built in 1970, a second line was constructed in 1989, and a

third line was constructed in 2012. The three production lines, referred to as EP Units (for

Ethylene Polywax) or just Polywax Units, are identified as Unit A for the older area and Unit B

and Unit A2 for the newer areas. Microcrystalline wax manufacture ended in 1996. The facility

currently operates under Part 70 permit No. 2010-002-TVR2 (M-2), issued June 3, 2014.

With this permit application, Baker is requesting several updates to the permit to address newly

applicable regulations, to reflect current facility equipment and operations, and to correct errors in

the previous permit. The following outlines the requested updates:

1. Remove Tanks C-1003 and C-433 from EUG 1.

2. Remove the Air Attrition Unit that is not in operation and will not be operated in the future.

3. Add serial numbers for EUG 7 emergency generators authorized by Permit No. 2010-002-

TVR2 (M-2).

PERMIT MEMORANDUM 2016-0042-TVR3 DRAFT/PROPOSED

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4. Update the insignificant activity list to remove units that are subject to NSPS Subpart Dc

and Subpart JJJJ and NESHAP Subpart ZZZZ.

SECTION II. PROCESS DESCRIPTIONS

The Barnsdall Plant manufactures organic chemicals in three primary production units and

support operations. The three production units are Synthetic Wax Production Unit, Resin Unit,

and Oxidation Unit,. Miscellaneous Sources are listed following discussion of the production

units.

Synthetic Wax Production Unit

BAKER manufactures low molecular weight synthetic waxes, designated as ethylene polywax

(EP) products. The synthetic waxes are produced by polymerizing organic monomers,

principally ethylene and propylene. EP finished products are solids at ambient temperature and

have negligible volatility. Raw materials used in the EP process are the organic monomers,

reaction initiators, reaction catalyst, and carrier solvent. With the exception of the reaction

catalyst, raw materials are received and stored in bulk tanks. The plant operates two ethylene

bulk tanks that are nominally sized at approximately 30,000 gallons capacity, and one propylene

bulk tank nominally sized at 15,000 gallons capacity. Vented ethylene currently releases to

atmosphere or an ethylene flare. The reaction initiators and carrier solvent are stored and

dispensed from three separate bulk tanks. Major processing steps employed to produce synthetic

waxes follow.

Polymerization Reaction

The polymerization reaction is conducted in water-cooled agitated reactor vessels. In this

process, the carrier solvent (toluene, the principal HAP), initiator, and catalyst are fed to the

reactor, and then the monomer is added. Polymerization occurs, converting the monomer into a

long-chain synthetic wax. The reaction mass is fed to a surge tank or directly to a wash tank for

further processing. Cooling water is handled by an existing cooling tower identified as emission

point CT-1, although cooling tower emissions are considered to be trivial. The facility can also

route the reaction mass to an oxidization vessel to produce long chain alcohols. These alcohols

are very similar to the synthetic waxes, having negligible volatility. Emissions from the

oxidation vessel pass through a condenser associated with Plant A and identified as emission

point E-4351.

Hydrolysis and Aqueous Washing

The reaction mass is fed to a hydrolysis and washing system. Washing consists of sequential

water washes followed by phase separation, with the aqueous phase discharging to solvent

recovery and the organic phase routed to polymer recovery. As mentioned in the Introduction

(Section I above), the EP plant has three lines, “A” line, “B” line, and A2 line. Emissions from

this process are vented through the respective final vent condensers, identified as E-4350 for the

A-side and E-4310 for the B-side.


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Polymer Recovery

The organic phase discharged from the washing step is initially transferred to a flash

evaporator/condenser system. A stripping process then removes the residual carrier solvent from

the polymer product. Overheads from the stripping process are condensed and collected. The

condensed solvent streams discharge to “wet” solvent collection tanks. Polymer from the

stripping unit discharges to accumulation/storage tanks where it is tested and then pumped to

liquid product storage tanks or to the facility’s prilling tower, where wax beads are formed as the

final product.

Aqueous Phase Solvent Recovery

The aqueous phase material discharged from the washing system and from the phase separation

of the wet solvent is fed to a flash tank/condenser system or to a steam stripping

column/condenser to remove and recover the carrier solvent. The condensers, identified as

emission points C-4160 and C-4120, discharge to a solid/liquid separator and lagoon system, and

is ultimately pumped to a deep well injection system. The well is a Class 1 non-hazardous

injection well permitted by the EPA.

Solvent Purification/Drying

The recovered carrier solvent accumulated in the wet solvent collection tanks is allowed to phase

separate with the aqueous phase fed to the aqueous solvent recovery systems, and the organic

phase fed to a distillation column for purification. Overheads from the distillation column are

condensed and returned to the column as reflux. Water that is condensed is drawn off to the wet

solvent collection tanks. Purification residuals from the distillation column are accumulated in a

tank system and eventually sold to customers as Solvent 250. A side draw of the purified solvent

is routed to an accumulation tank. This tank feeds a second distillation column for removal of

any residual water. Solvent from this second drying column is fed to a molecular sieve bed that

further reduces the water content. Dried purified solvent is then routed to a 5,000-gal dry solvent

accumulation tank (C1029) that recycles the solvent back to the initial polymerization reaction

step.

Reactor Wash Processing

Material from reactor-cleaning is recycled in the reactor wash processing system. This system

recovers solvents from the material using a flash evaporator and condenser. The condenser

discharges recovered solvent back to the wet solvent collection tanks. Other material recovered

from the system is collected, allowed to solidify, and stored prior to landfill disposal off-site.

Any emissions from this process will be routed to the A-side final vent condenser, E-4350.

Long Chain Acid Production

This process manufactures long chain carboxylic acids, using high molecular weight alcohol wax

manufactured at the facility. Alcohol is pumped into a heated 4,000-gallon reactor, an aqueous

solution of caustic is added, and more heat is added to distill the water out. Water vapor is

condensed and routed to the existing aqueous handling system. The remaining material is heated

to reaction temperature, forming a viscous salt. Nitrogen is used to purge the system during the

reaction in order to remove minimal amounts of hydrogen generated. The salt is cooled and

toluene from the existing toluene recycle process is added as a solvent to reduce viscosity. The

salt/solvent mass is pushed into a glass-lined 4,000-gallon reactor containing acid. The resulting


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reaction forms potassium chloride (KCl) and the desired long chain acid. The only equipment in

this process is two 4,000-gallon reactors, two condensers, a gas-fired 1-MMBTUH oil heater,

two small pumps, and necessary piping components.

RESIN UNIT

The resin unit is a batch operation that manufactures various waxes through chemical reactions.

These reactions require catalysts and elevated temperature and/or pressure, will usually generate

heat, and generally use cooling water to maintain control of the reactions. The cooling water

from this process is recirculated to the facility’s non-contact cooling water tower. This system

consists of four reactors: one 750-gallon (Equipment ID No. C-6001), one 1,500-gallon (C-

6003), and two 8,500-gallon (C-6005 and C-6006). Volatile organic vapors are generated during

the chemical addition and reaction processes. These vapors are condensed and collected in four

storage tanks as a co-product. Vapors from each storage tank associated with a reactor are

routed to a vent condenser (E-6026A, E-6026B, E-6027, and E-6028). The vent condensers are

cooled with chilled water at approximately 40F in a closed-loop system, resulting in high

removal efficiency (> 70%) of organic compounds vented through the system. Vent parameters

are listed at the end of Section III of this Memorandum. The product waxes from the resin unit

are shipped in bulk, packaged into drums or pails, or transferred to the packaging unit systems.

Cold Flow Description

A product line manufactured at the Resin Unit is a Cold Flow Improver (CFI) used for

depressing the pour points of crude oil has no appreciable effect on emissions, and is described

here only for completeness. These CFIs are produced in existing equipment in the Resin Unit

and use reactions similar to those for other current products. The changes include the addition of

a small reflux condenser on reactor C-6005 and an associated decanter that collects liquid and

returns it to the reactor while venting any vapors to existing condenser E-6005. This condenser

is installed prior to the vacuum receiver leading to condenser E-6010, where some emissions

from the resin process are vented to the atmosphere through emission point EP-6010. The

product also requires use of a solvent referred to as Aromatic 100 Solvent, which is stored in a

8,000-gallon tank before being added to the process. This tank is vented to condenser E-6028,

described in the preceding paragraph. Products from this process are transferred directly to a

tank truck for shipment or to totes for storage.

OXIDATION UNIT

The oxidation unit consists of two approximately 7,500-gallon vessels (C-6101 and C-6105),

which are equipped to treat polymer by forcing air through spargers at the bottom of each

oxidizer. The air is supplied from two 2,000-scfm blowers (G-6111A and G-6111B) and is used

as the source of oxygen for agitation of the polymer during the oxidation process and to maintain

control of the oxidation rates at specific temperatures. The excess air exits the oxidation units

through a knockout pot and is then burned in a catalytic oxidizer, Emission Point V-6101. Steam

and cooling water are also used to assist in temperature control for the oxidation units. The

steam condensate is returned to the facility feed water system and the cooling water is routed to

the non-contact cooling water tower. One of the oxidation units is outfitted as a pressure vessel

(C-6105) and contains a vacuum jet that removes vapors. This vacuum jet operates


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approximately 12 hours per month and results in discharges containing an aromatic substitute of

urea through the catalytic oxidizer. The oxidizer vents to the atmosphere through a 1.5 diameter

stack, exhausting a maximum 4,000 scfm at 1,000 F at 58 above grade. The product polymers

(oxidized polymers) can be transferred directly to the packaging unit systems or to storage tanks,

pending final packaging.

OTHER PROCESSES

Emulsions Production

Emulsions are produced by dispersing polymer products in water. The generic materials for the

process are polymer, water, surfactant, and biocide, which is optional. Emulsion processing uses

several different procedures, namely polymer to water, water to polymer, heat/mix, and finally

blend/homogenize.

Equipment for the emulsion system consists of two stainless steel vessels with approximately

2,000-gallon working capacity. The vessels are pressure rated to 150 psi, and have internal coils

and agitators. The homogenizer pumps approximately 15 gpm, and is rated for about 15,000 psi.

A small gear pump is installed before the homogenizer to maintain positive suction pressure.

De-ionized water is produced using an off-the-shelf ion exchange system. Because the water-

based emulsions are non-hazardous, packaging is accomplished by simply transferring the

product to a container through a bag type filter and a hose. The container may be a drum, pail or

tote. The proper amount of product is weighed as it is added to the container, and then sealed for

shipment. The emissions from this process are negligible, so this process has been added to the

insignificant activity list.

Microcrystalline Wax Packaging

Packaging of microcrystalline waxes is accomplished by pastilling, or slabbing. “Slabbing” is the

molding of liquid wax into block form.

Packaging and Shipping

Both liquid and solid products are shipped from BAKER to customers. Liquids are shipped via

tanker truck, or in packages such as drums, bulk bags, and pails. Solid waxes are sized and

packaged into various bags, totes, and drums for shipment.

Spray Micronizer

This is a process that atomizes wax into extremely fine particles. Molten wax and steam are

injected into a “micronizing” nozzle. The exiting wax particles are air cooled and captured in a

baghouse, from which they are removed with compressed air. They are sorted through a sizing

shaker screen and drummed or bagged as a product. Oversized particles are melted and returned to

feedstock. Moisture content and particle size are partially controlled with elevated temperatures

and occasional use of nitrogen. A 2,500-scfm blower induces heated air through the ductwork and

baghouse. The baghouse is integral to production, and applicant does not consider it a piece of

pollution control equipment. It has an efficiency of 99.99%. The baghouse exhausts 2,500 scfm at

120 F through a 10 diameter stack identified as emission point G-6303, venting at 39 above

grade.


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Sandvik Belt Unit

This process produces small wax beads called pastilles. Molten wax is pumped through

pastillating heads to produce small drops of wax, which fall onto a stainless steel conveyor belt.

Chilled and/or cooling water is sprayed on the underside of the belt, causing the drops to solidify

upon contacting the belt surface. A scraper blade separates the pastilles from the belt; they are

sorted on a screen shaker, and packaged as product. Oversized drops are returned to feedstock.

There are two lines, identical in operation and length, but with different widths.

Prilling Tower

Molten synthetic wax is pumped from storage to the top of the prilling tower and sprayed

downward. Ambient air is pulled upwards through the tower and the resulting countercurrent heat

transfer allows the droplets of polymer to form into hard beads. The beads are screened for size,

with the larger beads being returned to the heated storage tanks. The reverse air is fed to cyclones

for recovery of polymer fines, which are also returned to the heated storage tanks. Although the

cyclones act as pollution control devices, they are integral to the process and recover valuable

material for processing. The emission point for the prilling tower is identified as CYVENT.

Mini-Prill Description

Mini-Prilling (MP) is similar to prilling. The primary differences between prilling and MP are

that: MP produces a much smaller bead; MP uses different geometry, spraying the liquid up into

the air, and allowing it to fall back down into the bed; MP allows the potential to recirculate air

back into the MP system; MP uses a cooling exchanger and a filter cloth to prepare the cooling

air before re-using it; and a refrigeration unit is used to help chill the air that flows through the

unit. Very small polymer dust particles that do not agglomerate onto the larger spherical

particles rise to the top of the spray chamber. At the top of the spray chamber, the air is sucked

through a cotton cloth by a fan with an adjustable shutter, which regulates the air velocity in the

spray chamber. As the air goes through the cotton cloth, polymer dust is collected and the

filtered air is either released through shutters in the ductwork or recirculated through the air

cooler. The device in which the fluidized bed and air separation system are contained is called a

granulator. The polymer particles exit the granulator by overflowing a dam above the perforated

plate. A pneumatic conveyor moves the particles to a large hopper that feeds a standard bagger.

The Mini-Prill process and the Prill Tower operation are both currently active, but MP emissions

are so slight as to be considered an insignificant activity. The production limit set for the tower

satisfies compliance requirements for both activities.

SUPPORT OPERATIONS

Support operations at the facility include utilities, wastewater collection and treatment, other

maintenance activities, and a staging area for oil well field treatment activities.

Utilities

The plant operates three boilers to generate steam used in the production areas. Boilers #1 and

#2 have maximum design firing rates of 72.2 MMBTUH and Boiler #3 has a maximum design

firing rate of 52.5 MMBTUH. The primary fuel for the boilers is pipeline grade natural gas.


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Emergency Generator Engines

The facility now has three natural gas-fired generator engines: two 477-hp Generac MG300s

engines and one 453-hp Generac SG250 engine.

SECTION III. EQUIPMENT

There are many process vessels in this facility, but only those vessels capable of emitting to the

atmosphere through a vent or control device are listed.

EUG 1 Polywax Units (EP A & B)

Point Service Capacity Const Date

C-1005 Reaction Initiator Tank & Weigh Cell 10,000 gal 1970


C-1002 Carrier Solvent Storage Tank 9,800 gal 1970

E-4351 Oxidation Vessel Condenser (Plant A) N/A 1993

E-4350 Final Vent Condenser (Plant A) N/A 1993

E-4310 Final Vent Condenser (Plant B) N/A 1989

F-0000 Fugitives (Plants A & B)1 N/A 1989

TBD Ethylene Flare2 3,000 lb/hour Pending

1) Fugitives include storage tanks, wastewater basin and lagoons, as well as piping, flanges, etc.

2) The flare is listed only for completeness. It is a control device, not process equipment.

EUG 2 Prilling Tower

Point Make/Model Construction Date

CYVENT Buffalo Type L-39 1975

EUG 3 Older Boilers

Point Make/Model Serial # Capacity Const Date

BLR1 Trane/Coen 10837 72.2 MMBTUH 1978


EUG 4 Resin Unit

Point Service Const Date

E-6010 Condenser vent 2004

E-6026A Co-product storage tank condenser vent 1989

E-6026B Co-product storage tank condenser vent 2004

E-6027 Co-product storage tank condenser vent 2004



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EUG 5 Oxidation Unit


V-6101 Catalytic oxidizer exhaust 1999

EUG 6 Dc Boiler


BLR3 Superior/Super Seminole 16849 67.2 MMBTUH 11/2010

EUG 7 Emergency Generators

Two (2) 477-hp Generac MG300 generators and one 453-hp Generac SG250 generator installed

in 2014 authorized by Permit No. 2010-002-TVR2 (M-2).

EUG 8 Firewater Pump Engine

One existing 267-hp Caterpillar 3306 diesel fire water pump engine is subject to NESHAP

Subpart ZZZZ. The Unit was previously listed as an insignificant activity.

EUG 9 Hot Oil Heater

One existing 1.0 MMBTUH hot oil heater is subject to NESHAP Subpart DDDDD. The Unit

was previously listed as an insignificant activity.

EUG ALL Facility Wide

This EUG is established to consider all rules and regulations that apply to the entire facility.

The following table shows pertinent information about each of the stacks. Note that all flow and

temperature data reflect maximum conditions. For instance, vents flow only under certain

pressure conditions and the point identified as E-4351 has flow only when the polymer oxidizer

is processing material.


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STACK PARAMETERS

Point Height

(Feet)

Diameter

(Inches)

Flow

(ACFM)

Temperature

(F)

C-1005* 0 1 240 Ambient

C-3020* 0 1 240 Ambient

C-1002 22 4 25 Ambient

E-4351 48 2 116 100

E-4350 43 3 116 100

E-4310 59 6 66 100

CYVENT 28 47 80,000 100

BLR1 30 42 7,392 290

BLR2 30 42 8,477 290

BLR3 31.5 36 11,796 297

E-6010 22 2 15 70

E-6026A 18 2 5 70

E-6026B 18 2 5 70

E-6027 19 2 5 70

E-6028 16 2 15 70

V-6101 58 18 4,000 1000

G-6303 39 10 2,500 120

AAM -0- 4 105 100 * Emissions from tank C-1005 flow through a seal pot (D-1002) and are emitted

there. Similarly, emissions from C-3020 actually vent through D-3022.

SECTION IV. AIR EMISSIONS

Polymer Production

Calculation of emissions from the various units involved in producing the synthetic waxes

require the use of proprietary data that the permittee requests be kept confidential. The process

used by permittee is in the public domain, but stating actual amounts of solvent and raw

materials used could reveal the specific techniques used. Only a description of the calculation

technique will be presented in this public document. The actual calculations may be found in the

confidential permit application package and will be required under a Specific Condition of the

permit for compliance demonstrations.

Emissions of solvent to atmosphere are based on material balance. The difference between

purchases of solvent and all known outputs is assumed to represent emissions. Following is a list

of outputs.

Synthetic waxes have been analyzed to determine the amount of solvent present. This

amount is multiplied by the quantity of product manufactured.

Wastes injected at the disposal well are analyzed for solvent content in ppm. A simple

calculation yields the total amount of solvent disposed.

Some material is also shipped off-site and is considered by the permittee to be a co-

product. This material is analyzed for solvent content per barrel.


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Other waste solvent is collected in drums, analyzed for solvent content, and then shipped

off-site for disposal.

Emissions of raw materials are also based on material balance. Since ethylene is the principal

raw material, the calculation process analyzes the other components first. Calculating the ratio

of all waste (which may be off-spec product or material washed out of reactors) solids to total

production forms an approximation of solid losses. This ratio is assumed to apply equally to

each raw material. Each propylene co-polymer manufactured has a known theoretical content of

propylene. Total quantity of each propylene co-polymer is multiplied by this theoretical value to

generate the total amount of propylene actually present. This number is then multiplied by the

solid loss ratio discussed earlier. Both numbers are subtracted from the quantity of propylene

consumed and this result represents emissions. The process performed for propylene is

duplicated for hexene and the stage is set for calculating ethylene emissions.

Ethylene emissions are considered to be the difference between total consumption of raw

materials (ethylene, propylene and hexene) and the sum of total production, propylene and

hexene emissions, solid losses, and flared material. Calculation of propylene and hexene

emissions has been described. Solid losses include solids accumulating in the “1017 Pit,” wax

picked up from the ground, spilled, leaked, or recovered in any other way, and solids collected in

the weir section of the 1017 Pit. These various solids have ethylene content estimated by using

the ratio of propylene co-polymers manufactured combined with estimates of their rate of

accumulation.

Because of the great difficulty involved in determining the exact location of each emission, the

facility has used a single emission point to represent the net effect of all mass balance

calculations as outlined above. That point is identified in annual emission inventory reports as

“Sequence 6: Ethylene Unloading and Storage Tanks.” Permittee has a facility-wide limit of 550

TPY for VOC, which includes, but is not limited to, toluene, ethylene, propylene and hexene.

Specific Conditions #1 and #4 shall be used to demonstrate compliance with the limit.

Prilling Tower

There are no emissions of VOC from this source. Particulate emissions are calculated based on

material balance and assume a conservatively low cyclone collection efficiency of 91%. These

assumptions allow the calculation of an emission factor of 2.50 pounds of PM10 per ton of liquid

wax throughput. Maximum production is 3.45 TPH and the facility has accepted a voluntary limit

of 13,500 TPY on production.

3.45 TPH 2.50 lbs/ton = 8.63 lbs/hr or 16.9 TPY

Mini-Prill Process

The MP process does not use cyclones for product recovery, as is the case with the tower

operation, and the fabric filters are much more efficient at product recovery. Assuming the filters

to be at least 99.9% efficient and using the engineering calculations for the tower operation yields

an estimated rate 0.42 TPY. Air from the unit is filtered and emissions are expected to be below

the significant activity threshold of 5 TPY. Sufficient recordkeeping is required to demonstrate

that it remains an Insignificant Activity.


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Boilers

All emission factors are taken from Tables 1.4-1 & 2 of AP-42 (7/98), except for the NOX value for

Boiler 3. Filterable and condensable PM factors are combined. The NOX factor for Boiler 3 is a

manufacturer’s guarantee plus 25% safety factor. AP-42 assumes heat content of natural gas to be

1,020 BTU/CF.

BOILERS

Pollutant Factor

(Lb/MMCF)

Emissions (#1 & #2, each)

Lb/hr TPY

PM10 7.6 0.54 2.36

NOX 100 7.08 31.0

CO 84 6.26 27.4

VOC 5.5 0.41 1.80

SO2 0.6 0.05 0.20

Pollutant Factor Emissions (#3 only)

Lb/hr TPY

PM10 7.6 Lb/MMCF 0.50 2.19

NOX 0.125 lb/MMBTU 8.40 36.8

CO 84 Lb/MMCF 5.53 24.2

VOC 5.5 Lb/MMCF 0.36 1.59

SO2 0.6 Lb/MMCF 0.04 0.17

The following table totals emissions from all boilers.

BOILERS - POTENTIAL TO EMIT

Pollutant Lb/hr TPY

PM10 1.58 6.91

NOX 22.6 98.8

CO 17.4 76.3

VOC 1.14 5.00

SO2 0.12 0.55

Resin Unit

There are emissions from the resin unit vacuum receiver water tank serving the four tanks in this

process. Another condenser serves the storage tank vents. The applicant has performed an

engineering study of losses in conjunction with the Texas Natural Resources Conservation

Commission (TNRCC). Approximately 3% of all material charged to the reactors is trapped in the

equipment, is flashed overhead and collected as co-products. Evaporative losses (VOC) have been

calculated at 0.25%, but have conservatively been assumed to be 1% losses for this analysis. The

chilled water vapor condensers are estimated to have 70% recovery or removal efficiency.

Although operating hours are typically estimated to be 6,240 hours per year, the following

calculations assume 8,760 hours per year.

10,400,000 lbs/yr 1% (1 – 70%) 1 ton/2,000 lbs = 15.60 TPY VOC

3,120 lbs/hr 1% (1 – 70%) = 9.36 lbs/hr VOC


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Emissions from the condenser vent associated with the storage tanks are calculated based on EPA-

approved Tanks3.1 computer model and the assumed 70% efficiency of the condenser. Two tanks

are pressure vessels, 7 feet high by 6.5 feet in diameter, with capacity of 2,000 gallons each. The

third tank is a fixed cone roof tank, 15 feet high by 12 feet in diameter, with a capacity of 10,000

gallons. Combined VOC emissions from all tanks are 0.01 lbs/hr and 0.03 TPY.

Oxidation Unit

VOC-laden air emissions from the three vessels are routed through a knockout pot, and then to the

catalytic oxidizer. As in the case of the resin reactors, 3% of the material loaded is trapped in

various parts of the equipment, is flushed out, and ultimately sold as off-spec product. Also as

above, evaporative losses of 0.25% are increased to a conservatively high 1% for these

calculations. The manufacturer of the oxidizer guarantees 95% destruction efficiency, but the

applicant assumes a conservatively low value of 90% for these calculations. Although operating

hours are typically estimated to be 6,240 hours per year, the following calculations assume 8,760

hours per year.

6,240,000 lbs/yr 1% (1 – 90%) 1 ton/2,000 lbs = 3.12 TPY VOC

3,120 lbs/hr 1% (1 – 90%) = 3.12 lbs/hr VOC

Packaging Units

1. Spray Micronizer

Fine particles of wax are captured in a baghouse, whose capture efficiency is guaranteed by the

manufacturer at 99.99%. For a maximum production of 1,000 tons per year, emissions are

calculated based on an input of 604.8 lbs/hr or 1,008 TPY, yielding

604.8 lbs/hr (1 – 99.99%) = 0.06 lbs/hr PM or 1,008 TPY (1 – 99.99%) = 0.10 TPY PM

No significant VOC emissions are anticipated.

2. Sandvik Belt Unit

This process produces neither VOC nor PM emissions. Maximum annual capacity for this unit is

approximately 12,000 tons of product.

Storage Tanks

Tanks have been considered as part of the emissions contemplated from the Polywax plants.

Emergency Generators

Emission factors for both 477-hp engines and for the 453-hp engine are taken from the

requirements of NSPS Subpart JJJJ. Emissions of SO2 and PM are negligible, and are not

presented here. Annual operating hours are estimated to be 500 each.

Pollutant Factor

g/hp-hr

477-hp Engine Emissions

Lb/hr TPY (each) TPY (total)

NOX 2.0 2.10 0.53 1.05

CO 4.0 4.21 1.05 2.10

VOC 1.0 1.05 0.26 0.53


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Pollutant Factor

g/hp-hr

453-hp Engine Emissions lb/hr TPY

NOX 2.0 2.00 0.50

CO 4.0 4.00 1.00

VOC 1.0 1.00 0.25

Facility-Wide Emissions (TPY)

Source NOX CO SO2 VOC PM10

Polymer Production *

Prilling Tower 16.9

Resin Unit 15.6

Boilers 98.8 76.3 0.55 5.00 6.91

Oxidation Unit 3.12

Packaging 0.10

Emergency Generators 1.55 3.10 - 0.78 -

Totals 100 79.4 0.55 550 23.9

* Emissions included in facility-wide total.

HAP emissions

This facility is a major source for HAPs. Since the percentages attached to each process could

reveal proprietary process information, details may be found in the confidential application packet.

Greenhouse Gases (GHG)

The applicant estimated potential GHG emissions at the facility to be 109,481 tons per year of

CO2-equivalent.

SECTION V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified on Part 1b of the forms in the application and

duplicated below were confirmed by the initial operating permit inspection. Records are

available which confirm the insignificance of the activities. Appropriate recordkeeping is

required for those activities indicated below with an asterisk.

* 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 has two 564-gallon gasoline storage tanks. According to a full compliance

evaluation performed May 5, 2009, the maximum monthly fuel purchase in the preceding year

was 1,871 gallons in October of 2008, well below the threshold.

* 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. Permittee

has two 564-gallon, one 1,034-gallon and one 9,800-gallon #2 fuel oil tanks. None of these

tanks is subject to NSPS or to state permitting rules, and all store liquids with vapor pressure

well below the 1.5 psia threshold. Other tanks may be added in the future.

* Non-commercial water washing operations (less than 2,250 barrels/year) and drum

crushing operations of empty barrels less than or equal to 55 gallons with less than 3% by

volume of residual material. Less than 150 drums per year are crushed.


14

Hazardous waste and hazardous materials drum staging areas. Up to eight drums of

hazardous waste are stored at any time. Hazardous materials are staged routinely.

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

hazardous waste satellite (accumulation) areas. The facility has such sources and may add others

in the future.

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.

A number of sources may be considered as insignificant because their emissions are below 5

TPY and they are not subject to NSPS, NESHAP, or State rules.

a) Less than 14 laboratory hoods and vents.

b) Pyrolysis of laboratory glassware.

c) Particulate emissions from bagging units.

d) The Miniprill process.

e) The Emulsion process.

f) Microcrystalline packaging.

g) Long chain acid process

SECTON VI. 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 that result in emissions not authorized in the permit and

that exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior


15

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

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

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

Emission limitations and operational requirements necessary to assure compliance with all

applicable requirements for all sources are taken from the existing Part 70 operating permit, from

the modification application, or are developed from the applicable requirement.

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 affirmative defense, as

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

reporting may be required in the case of ongoing emission events and in the case of excess

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

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

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

specific examples and under the conditions listed in this subchapter.

OAC 252:100-19 (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, as shown in Appendix C. Fuel-

burning equipment is defined in OAC 252:100-19 as any internal combustion engine or gas

turbine, or other combustion device used to convert the combustion of fuel into usable energy.

Thus, the three boilers are subject to the requirements of this subchapter. AP-42 (7/98) Table

1.4-2 lists natural gas TPM emissions to be 7.6 lbs/MMSCF or about 0.0076 lbs/MMBTU, which

is in compliance. The three emergency generator engines and the diesel fire pump engine are also

subject, with PM emissions of 0.0194 lb/MMBTU taken from Table 3.2-3 of AP-42 (7/00) for the

gas-fired engines and 0.31 lb/MMBTU taken from Table 3.3-1 of AP-42 (10/96).


16

Equipment

Maximum

Heat Input

Appendix C Emission

Limit, (lbs/MMBTU)

Potential Emission

Rate, (lbs/MMBTU)

BLR1 72.2 MMBTUH 0.38 0.008

BLR2 72.2 MMBTUH 0.38 0.008

BLR3 67.2 MMBTUH 0.38 0.008

Generac 1 4.7 MMBTUH 0.60 0.019



Fire Pump Engine

Engine

267 hp 0.60 0.31

Section 19-12 limits particulate emissions from emission points in an industrial process based on

process weight rate, as specified in Appendix G. As shown in the following table, all emission

points are in compliance with Subchapter 19.

Equipment Process

Rate, TPH

Appendix G Emission

Limit, lbs/hr

Potential Emission

Rate, lbs/hr

Micronizer 0.302 1.84 0.06

Prilling tower 3.45 9.40 8.63

Mini-prill 3.45 9.40 0.10

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. Filters used to conserve product prevent most PM emissions. When

burning natural gas there is very little possibility of exceeding these standards.

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

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

property line on which the emissions 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 The new (constructed after July 1, 1972) equipment standard for emissions of oxides of

sulfur measured as sulfur dioxide from gas-fired fuel-burning equipment is 0.2 lbs/MMBTU heat

input, maximum three-hour average. Boilers 1 and 2 were installed in 1978 and are new

equipment, as is Boiler 3, added in 2010. AP-42, Table 1.4-2 (3/98), lists natural gas SO2

emissions to be 0.6 lbs/MMft3 or about 0.0006 lbs/MMBTU, which is in compliance. The

emergency generator engines are new. Table 3.2-3 of AP-42 (7/00) lists natural gas SO2 emissions

as 5.88 × 10-4

lbs/MMBTU, which is in compliance.


17

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

This subchapter limits new (constructed after July 1, 1972) gas-fired or liquid-fired fuel-burning

equipment with rated heat input greater than or equal to 50 MMBTUH to emissions of 0.20 or

0.30 lbs of NOx per MMBTU, three-hour average, respectively. The three boilers were installed

in 1978 and are new sources. Their rated heat inputs of 72.2, 72.2 and 67.2 MMBTUH all

exceed the 50 MMBTUH threshold and they are affected sources. The AP-42 factor for natural

gas is approximately 0.1 lb/MMBTU, and the requested factor for Boiler 3 is 0.125 lb/MMBTU,

both of which are in compliance.

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. The vapor pressures of

diesel, kerosene, and toluene are all less than 1.5 psia; therefore, Part 3 does not apply to the

storage of these liquids. The two 564-gallon gasoline tanks are properly equipped.

Part 5 limits the VOC content of coating 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 not an affected operation.

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

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

combustion.

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


18

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 Quality Rules are not applicable to this facility.

OAC 252:100-11 Alternative Reduction not requested

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

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

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

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

OAC 252:100-39 Organic Materials Nonattainment not in control area

OAC 252:100-47 Landfills not in source category

SECTION VII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Applicable]

This facility is a PSD-major stationary source and future increases of any emissions above the

significance level for each pollutant will require PSD review.

NSPS, 40 CFR Part 60 [Subparts Dc and JJJJ 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 MMBTUH.

Two existing boilers in EUG 3 were constructed before the effective date, and have not been

modified or reconstructed. The boiler in EUG 6 is rated at 67.2 MMBTUH and is an affected

facility. Because this boiler uses only natural gas as fuel, there are no requirements except for

initial notification requirements of §48c(a) and the recordkeeping and reporting requirements of

40 CFR 60.48c, as further described in 40 CFR 60.7.

Subpart Kb (VOL Storage Vessels) regulates volatile organic liquid storage tanks larger than

75m3 capacity for which construction, modification or reconstruction occurred after July 23,

1984. The facility has no tanks above the threshold capacity, so there are no affected facilities.

Subpart VV (VOC Leaks from SOCMI) affects synthetic organic chemical manufacturing

operations that commenced construction, reconstruction, or modification after January 5, 1981

and on or before November 7, 2006. The facility does not produce, as intermediates or final

products, any of the chemicals listed in 40 CFR 60.489, and is not an affected source.

Subpart VVa (VOC Leaks from SOCMI) affects synthetic organic chemical manufacturing

operations that commenced construction, reconstruction, or modification after November 7,

2006. The facility does not produce, as intermediates or final products, any of the chemicals

listed in 40 CFR 60.489, and is not an affected source.

Subpart DDD (VOC from Polymer Manufacturing) affects facilities involved in the manufacture

of polypropylene, polyethylene, polystyrene, or ethylene terephthalate. Effective dates depend

on the material and process being used, however standards for process equipment apply to

continuous processes only, per 40 CFR 60.560(a)(1). This facility manufactures polyethylene as

part of the ethylene polywax production process, but it does so in a batch process, so process

equipment is not affected by Subpart DDD. Requirements for leak detection and repair (LDAR)

identified in §560(a)(4) are not restricted to continuous operations and may be applicable. The


19

facility is also subject to NESHAP Subpart FFFF, which addresses “overlap” conditions with

other federal rules. In particular, 40 CFR 63.2535(h) allows the facility to elect to demonstrate

compliance with NSPS Subpart DDD by complying with the MACT, including the specific

language of §2535(h).

Subpart III (VOC from SOCMI Air Oxidation Processes) affects facilities that produce any of the

chemicals listed in §60.617 as a product, co-product, or intermediate and that were constructed,

modified, or reconstructed after October 31, 1983. The facility does not produce any of the

listed chemicals and is not an affected source.

Subpart NNN (VOC from SOCMI Distillation Units) affects distillation units in the synthetic

organic chemical manufacturing industry that commenced construction, reconstruction, or

modification after December 30, 1983. The facility does not produce any of the chemicals listed

in §60.667 and is not an affected source.

Subpart IIII (Stationary Compression Ignition Internal Combustion Engines) affects stationary

compression ignition (CI) internal combustion engines (ICE) based on power and displacement

ratings, depending on date of construction, beginning with those constructed after July 11, 2005.

The fire pump engine was constructed before July 11, 2005 and is not an affected facility.

Subpart JJJJ (Stationary Spark Ignition Internal Combustion Engines (SI-ICE)) affects

manufacturers, owners, and operators of SI-ICE. The emergency generator engines installed

under this permit are affected SI engines. The two 477-hp engines have Certificate of

Conformity No. DGNXB12.92C3-041, the 453-hp engine has Certificate of Conformity No.

EGNXB12.92C2-039, and each shall maintain operating and maintenance records. Performance

testing is not required.

NESHAP, 40 CFR Part 61 [Not Applicable]

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

oven emissions, mercury, radionuclides, or vinyl chloride, except for a trace of benzene.

Subpart J (Equipment Leaks of Benzene) This facility is not an affected source because none of

the equipment is in benzene service, as that term is defined in 40 CFR 61.111.

Subpart V (Equipment Leaks of Volatile HAPs) This facility is not an affected source because

none of the equipment is in VHAP service, as that term is defined in 40 CFR 61.241.

NESHAP, 40 CFR Part 63 [Subparts FFFF, ZZZZ, and DDDDD Applicable]

Subpart F (SOCMI) applies to chemical manufacturing process units that meet the applicability

criteria of §63.100(b)(1)(i) or (1)(ii) and are located at major sources of HAP emissions. The

facility does not manufacture as a primary product any of the chemicals listed in Table 1 of the

subpart, nor does it use as a reactant or manufacture as a product or co-product any of the

chemicals listed in Table 2 of the subpart. Therefore, the facility is not an affected source.

Subpart G (SOCMI) Not an affected source per 40 CFR 63.100 and 110.

Subpart H (SOCMI) Not an affected source per 40 CFR 63.100 and 160.

Subpart I (SOCMI) Not an affected source per 40 CFR 63.100 and 190.

Subpart U (Polymers & Resins, Part I) affects new and existing elastomer product process units

located at major sources of HAP emissions. The facility does not own or operate any such units

and is not an affected source.

Subpart W (Polymers & Resins, Part II) affects existing, new, and reconstructed manufacturers

of wet strength resins located at major sources of HAP emissions. The facility does not

manufacture basic liquid epoxy resins or wet strength resins and is not an affected source.


20

Subpart JJJ (Polymers & Resins, Part III & IV) affects new and existing thermoplastic product

process units located at major sources of HAP emissions. The facility does not own or operate

any such units and is not an affected source.

Subpart FFFF (Miscellaneous Organic Chemical Manufacturing, or MON) affects facilities that

manufacture miscellaneous organic chemicals and that are located at major sources of HAP, as

that is defined in 40 CFR 63.2. Baker Petrolite is a major source of HAP and is an affected

facility per 40 CFR 63.2435(b)(1)(i). This MACT applies to miscellaneous organic chemical

manufacturing process units (MCPUs), which include assigned storage tanks, product transfer

racks, open systems conveying wastewater-like material, and components, such as valves,

connectors, etc. Work practice standards and limits are described for continuous process vents,

batch process vents, storage tanks, transfer racks, equipment leaks, and wastewater streams, inter

alia. Various monitoring methods are allowed, including CEMs and parametric monitoring.

Standards generally include percentage reductions, requiring performance testing to establish

baselines and reduction efficiencies, but design evaluations may also be acceptable. Since the

facility is an existing source, compliance with the MACT standards was required by May 10,

2008.

Equipment leak standards can be met by utilizing the standards described in either 40 CFR 65

Subpart F or 40 CFR 63 Subpart UU. The facility has chosen Subpart UU and has established a

leak detection and repair (LDAR) program. All sources that might require control under the

subpart have been reviewed. No tanks, racks, or open conveying systems are affected. All

process vents were determined to be Group 2 vents, requiring no control, with the exception of

Unilin System vent EP-E-4351 in EUG 1. This Group 1 vent was already controlled by a

condenser, but engineering studies indicated that emissions were not sufficiently controlled.

Subpart FFFF requires 95% control, so an additional condenser was added in series. Design

criteria require that the exhaust temperature of this second condenser not exceed 48°F. An initial

compliance report documenting all of these activities was submitted October 7, 2008.

Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart affects any

existing, new, or reconstructed stationary RICE at a major or area source of HAP emissions,

except if the stationary RICE is being tested at a stationary RICE test cell/stand. The two 477-

hp and one 453-hp emergency generator engines are new units (constructed after 6/12/2006), and

the only requirement is to comply with NSPS Subpart JJJJ requirements.

The 267-hp fire pump engine was constructed before June 12, 2006 and is an existing source. An

existing stationary RICE with a site rating of equal to or less than 500 brake HP located at a

major source of HAP emissions must comply with the applicable emission limitations and other

requirements in Table 2c to this subpart as listed in the following table.

Engine Category Requirements

From Table 2c to Subpart ZZZZ of Part 63

Emergency stationary SI RICE and black

start stationary SI RICE.

a. Change oil and filter every 500 hours of

operation or annually, whichever comes first;

b. Inspect spark plugs every 1,000 hours of

operation or annually, whichever comes first, and

replace as necessary;

c. Inspect all hoses and belts every 500 hours of

operation or annually, whichever comes first, and

replace as necessary.


21

Subpart DDDDD, Industrial, Commercial and Institutional Boilers and Process Heaters. On

January 31, 2013, the EPA took final action on its reconsideration of certain issues in the

emission standards for the control of HAP from industrial, commercial, and institutional boilers

and process heaters at major sources of HAP. The compliance dates for the rule are January 31,

2016, for existing sources and, January 31, 2013, or upon startup, whichever is later, for new

sources.

A boiler or process heater is new or reconstructed if construction or reconstruction of the boiler

or process heater commenced on or after June 4, 2010. Boilers and process heaters designed to

burn gas 1 fuels are not subject to the emission limits in Tables 1 and 2 or 11 through 13 or the

operating limits in Table 4 of Subpart DDDDD. Unit(s) designed to burn gas 1 fuels includes

any boiler or process heater that burns only natural gas, refinery gas, and/or other gas 1 fuels.

The two boilers in EUG 3, the Dc boiler in EUG 6, and the hot oil heater in EUG 9 are affected

sources. The Dc boiler was constructed after June 4, 2010 and is a new source. The other units

are existing sources. Because all boilers and heaters at this facility burn commercial natural gas,

they are within the Unit(s) designed to burn gas 1 subcategory and are only subject to

requirements listed in the following table.


22

Source Category Requirements

From Table 3 to Subpart DDDDD of Part 63

A new or existing boiler or process heater with a

continuous oxygen trim system that maintains an

optimum air to fuel ratio, or a heat input capacity of

less than or equal to 5 million Btu per hour in any of

the following subcategories: unit designed to burn

gas 1; unit designed to burn gas 2 (other); or unit

designed to burn light liquid, or a limited use boiler

or process heater

Conduct a tune-up of the boiler or process heater every 5

years as specified in §63.7540.

A new or existing boiler or process heater without a

continuous oxygen trim system and with heat input

capacity of 10 million Btu per hour or greater

Conduct a tune-up of the boiler or process heater annually

as specified in §63.7540. Units in either the Gas 1 or Metal

Process Furnace subcategories will conduct this tune-up as

a work practice for all regulated emissions under this

subpart. Units in all other subcategories will conduct this

tune-up as a work practice for dioxins/furans.

An existing boiler or process heater located at a

major source facility, not including limited use units

Must have a one-time energy assessment performed by a

qualified energy assessor. An energy assessment completed

on or after January 1, 2008, that meets or is amended to

meet the energy assessment requirements in this table,

satisfies the energy assessment requirement. A facility that

operated under an energy management program developed

according to the ENERGY STAR guidelines for energy

management or compatible with ISO 50001 for at least one

year between January 1, 2008 and the compliance date

specified in §63.7495 that includes the affected units also

satisfies the energy assessment requirement. The energy

assessment must include the following with extent of the

evaluation for items a. to e. appropriate for the on-site

technical hours listed in §63.7575:

a. A visual inspection of the boiler or process heater

system.

b. An evaluation of operating characteristics of the

boiler or process heater systems, specifications of

energy using systems, operating and maintenance

procedures, and unusual operating constraints.

c. An inventory of major energy use systems

consuming energy from affected boilers and

process heaters and which are under the control of

the boiler/process heater owner/operator.

d. A review of available architectural and

engineering plans, facility operation and

maintenance procedures and logs, and fuel usage.

e. A review of the facility's energy management

program and provide recommendations for

improvements consistent with the definition of

energy management program, if identified.

f. A list of cost-effective energy conservation

measures that are within the facility's control.

g. A list of the energy savings potential of the energy

conservation measures identified.

h. A comprehensive report detailing the ways to

improve efficiency, the cost of specific

improvements, benefits, and the time frame for

recouping those investments.


23

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 or 10/25 TPY of a HAP

The particulate control devices in use are considered integral pieces of production equipment

since they return collected particles to the production process streams. Therefore, CAM does not

apply. In addition, the requirements of MACT FFFF, effective for this facility after May 10,

2008, satisfy CAM.

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

The facility does process or store more than the threshold quantity of ethylene and propylene

(Section 112r of the Clean Air Act 1990 Amendments). A Risk Management Plan (RMP) was

submitted to EPA Region 6 on June 18, 1999, and deemed to be complete on June 24, 1999. An

updated RMP was submitted to Region 6 on June 9, 2009. More information on this federal

program is available on the web page: www.epa.gov/ceppo.

Stratospheric Ozone Protection, 40 CFR Part 82 [Subpart A and F Applicable]

These standards require phase out of Class I & II substances, reductions of emissions of Class I

& II substances to the lowest achievable level in all use sectors, and banning use of nonessential

products containing ozone-depleting substances (Subparts A & C); control servicing of motor

vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations

which meet phase out requirements and which maximize the substitution of safe alternatives to

Class I and Class II substances (Subpart D); require warning labels on products made with or

containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon

disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds

under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons

(Subpart H).

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.

Subpart F requires that any persons servicing, maintaining, or repairing appliances except for


24

motor vehicle air conditioners; persons disposing of appliances, including motor vehicle air

conditioners; refrigerant reclaimers, appliance owners, and manufacturers of appliances and

recycling and recovery equipment comply with the standards for recycling and emissions

reduction.

The Standard Conditions of the permit address the requirements specified at §82.156 for persons

opening appliances for maintenance, service, repair, or disposal; §82.158 for equipment used

during the maintenance, service, repair, or disposal of appliances; §82.161 for certification by an

approved technician certification program of persons performing maintenance, service, repair, or

disposal of appliances; §82.166 for recordkeeping; § 82.158 for leak repair requirements; and

§82.166 for refrigerant purchase records for appliances normally containing 50 or more pounds

of refrigerant.

SECTION VIII. COMPLIANCE

Tier Classification

This application has been determined to be a Tier II based on the request for renewal of a Part 70

operating permit. The permittee has submitted an affidavit that they are not seeking a permit for

land use or for any operation upon land owned by others without their knowledge. The affidavit

certifies that the applicant owns the property.

Public Review The applicant will publish a “Notice of Filing a Tier II Application” and a “Notice of Tier II

Draft Permit” in a local newspaper for a 30 day public review. The draft permit will also be

available on the DEQ web at http://www.deq.state.ok.us. The facility is within 50 miles of the

Oklahoma border with the state of Kansas, which will be notified.

EPA Review

The draft permit will also be proposed to EPA for a concurrent review.

Inspection

Full compliance evaluations are performed at this facility, usually annually, with the most recent

having been performed by Drake Hanna and Corey Gum, Environmental Programs Specialists

with the Oklahoma Department of Environmental Quality, on December 7, 2015. Billy Moles,

HSE Specialist, represented BAKER throughout the inspection. No violations were found.

Fee Paid

Title V operating permit renewal fee of $7,500.

SECTION IX. SUMMARY

This facility was constructed as described in the application. There are no active Air Quality

compliance or enforcement issues that would affect the issuance of this permit. Issuance of the

permit is recommended, contingent on public and EPA review.

http://www.deq.state.ok.us/

DRAFT/PROPOSED

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Baker Petrolite Polymers Division Permit No. 2016-0042-TVR3

Barnsdall Manufacturing Facility

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

Quality on January 11, 2016. The Evaluation Memorandum dated March 1, 2016, 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. Emission points and authorized emissions are tabulated as follows. [OAC 252:100-8-6(a)]

EUG 1 Polywax Units (EP A & B)




C-1002 Carrier Solvent Storage Tank 9,800 gal 1970

C-1029 Dry Solvent Storage Tank 5,000 gal 2009

C-4303 Solvent 250 Storage Tank 6,800 gal 1987

C-4304 Solvent 250 Storage Tank 8,800 gal 1969

E-4351 Oxidation Vessel Condenser (Plant A) N/A 1993

E-4350 Final Vent Condenser (Plant A) N/A 1993

E-4310 Final Vent Condenser (Plant B) N/A 1989

C-4120,C-4160 Wastewater Vessels N/A 1987

Solvent 125 Transfer Rack N/A 1999

FL-2110 Ethylene Unloading and Storage Flare 3,000 lb/hr 2011

F-0000 *Fugitives (Plants A & B) N/A 1989, 2011

*Fugitives include storage tanks, wastewater basin and lagoons, as well as piping,

flanges, etc.

Various items in the preceding table are subject to 40 CFR 63 Subpart FFFF.

a) C-1002, C-4303, and C-4304 are existing Group 2 storage tanks, C-1029 is a new Group

2 storage tank, E-4351 is a Group 1 vent condenser, E-4350 and E-4310 are Group 2 vent

condensers, C-4120 and C-4160 are Group 2 wastewater vessels, and Solvent 125 is a

Group 2 transfer rack.

b) Group 2 items must maintain sufficient records to demonstrate that they are not eligible

for Group 1.

c) The outlet temperature of E-4351 shall be monitored continuously when in operation.

The average operating day recorded temperature shall not exceed 48°F, where operating

day is defined as midnight to midnight. It is not necessary to record more than one

measurement per one-minute interval, but values should be recorded no less frequently

than every 15 minutes. If no recorded value in a single operating day exceeds 48°F, the

SPECIFIC CONDITIONS 2016-0042-TVR3 DRAFT/PROPOSED

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operator may record that fact without averaging the values. Individual values must be

retained.

d) Fugitives are subject to leak detection and repair (LDAR) monitoring, Permittee has

elected to use the standards of 40 CFR 63 Subpart UU to demonstrate compliance, as

allowed by 40 CFR 63.2480(a).

e) Generic statements concerning FFFF compliance are listed in Specific Condition #8.

EUG 2 Prilling Operation

The only point is the cyclone vent, CYVENT, constructed in 1975. This point is for the prilling

tower.

Unit Source Pollutant Emissions

Lb/hr TPY

Prilling tower Cyclone PM 8.63 37.78

EUG 3 Older Boilers

Point Make/Model Serial Number Capacity Const Date



The following table authorizes emissions for the combined three units of EUG 3 (2 units) and

EUG 6 (1 unit) based on continuous operation while burning natural gas. Compliance with the

limits shall be demonstrated by monthly and 12-month rolling calculations of emissions, based

on current AP-42 factors, except for Boiler 3 NOX, which is based on manufacturer’s data with a

safety factor.

Pollutant Lb/hr TPY

PM10 1.58 6.91

NOX 22.6 98.8

CO 17.4 76.3

VOC 1.14 5.00

SO2 0.12 0.55

EUG 4 Resin Unit


E-6010 Condenser vent 2004

E-6026A Co-product storage tank condenser vent 1989

E-6026B Co-product storage tank condenser vent 2004



Cold Flow Decanter Wastewater Vessel 2004

FUG Fugitives 2004

Various items in the preceding table are subject to 40 CFR 63 Subpart FFFF.


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a) C-6026A, C-6026B, C-6027, C-6028 are existing Group 2 storage tanks, E-6010, E-

6026A, E-6026B, E-6027, and E-6028 are Group 2 vent condensers, and Cold Flow

Decanter is a Group 2 wastewater vessel.

b) Group 2 items must maintain sufficient records to demonstrate that they are not eligible

for Group 1.

c) Fugitives are subject to leak detection and repair (LDAR) monitoring, Permittee has



d) Generic statements concerning FFFF compliance are listed in Specific Condition #8.

EUG 5 Oxidation Unit


V-6101 Catalytic oxidizer exhaust 1999

FUG Fugitives 1999

All items in the preceding table are subject to 40 CFR 63 Subpart FFFF.

a) V-6101 is a Group 2 batch process vent and must maintain sufficient records to

demonstrate that it is not eligible for Group 1.

b) Fugitives are subject to leak detection and repair (LDAR) monitoring, Permittee has



c) Generic statements concerning FFFF compliance are listed in Specific Condition #8.

EUG 6 Dc Boiler


BLR3 Superior/Super Seminole 16849 67.2 MMBTUH 2010

Emission limits for this unit are included in EUG-3.

EUG 7 Emergency Generators Subject to NSPS Subpart JJJJ


1 Generac MG300

South Unit

8624576 477 HP 2014

2 Generac MG300

North Unit

8624575 477 HP 2014

3 Generac SG250

Control room

8756821 453 HP 2014

EUG 8 Diesel Firewater Pump Engine Subject to NESHAP Subpart ZZZZ


1 Caterpiller Model

3306

64Z32146 267 HP Pre-2006


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EUG 9 Hot Oil Heater Subject to NESHAP Subpart DDDDD


1 Hot Oil Heater 1.0 MMBTUH 2006

A facility-wide limit of 550 TPY (12-month rolling) of VOC applies to all sources in the facility,

regardless of their having been specifically named elsewhere in this Specific Condition. Toluene,

ethylene, propylene, hexene, and tert-butyl alcohol are included as VOC for the purposes of

determining compliance with this limit.

Toluene may be emitted in any amount less than or equal to 550 TPY, providing that the limit of

550 TPY of VOC is not exceeded.

2. Compliance with the PM limits established in Specific Condition 1 (SC #1) shall be

demonstrated by production, with limits of 5,000 TPY of on-spec product from the resin unit

(excluding the emulsions process), 3,120 TPY of on-spec product from the oxidation unit

(excluding microcrystalline blending), and throughput of 13,500 TPY at the prilling tower. No

production limit is set for the Micronizer, or the Sandvik belt unit, because they have insignificant

emissions. Emulsions produce negligible VOC and PM emissions, and shall not be considered in

any of these throughput limits. [OAC 252:100-8-6(a)]

3. Cyclones controlling emissions from the prilling tower may be replaced only by devices of

equal or greater efficiency. The nitrogen blanket used in controlling vapor emissions from various

equipment on the Polywax units may be replaced only by a method of equal or greater efficiency.

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

4. Compliance with the VOC limits established in SC #1 shall be demonstrated by material

balance calculations as performed in the confidential permit application package, mirrored in the

annual emission inventory (Turnaround Document) analysis, and described as follows.

Emissions of solvent to atmosphere are based on material balance, which is the difference

between purchases of solvent and all measurable outputs. These outputs include solvent bound

in the synthetic wax product, solvent content of wastes injected underground at the disposal well,

and solvent contained in waste or co-product shipped off-site.

In addition, volatile HAP emissions from units affected by MACT FFFF (see SC #8 below) shall

be calculated using the procedures specified in 40 CFR 63.127(d)(2).

[OAC 252:100-43 and 100-5, 40 CFR 63 Subpart FFFF]

5. Emissions of raw materials are also based on material balance. Propylene and hexene

emissions shall be calculated by taking the difference between consumption of each material and

the amount of each contained in measurable outputs. One output is the theoretical amount of

propylene or hexene included in the various products. Another is the proportion of each included

in waste, such as off-spec product or material flushed out of production lines. Ethylene

emissions are considered to be the difference between total consumption of raw materials

(ethylene, propylene and hexene) and the sum of total production, propylene and hexene


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emissions, solid losses, and flared material. Additional outputs considered in this calculation

include solids accumulating in the “1017 Pit,” wax picked up from the ground, spilled, leaked, or

recovered in any way, and solids collected in the weir section of the 1017 Pit. [OAC 252:100-43]

6. All pollution control equipment shall be maintained in proper working order per the

manufacturers’ specifications. Outlet temperature set point of the catalytic oxidizer shall be

maintained at or above 600 F and the process shall be shut down if the actual temperature drops

below 550 F when oxidation is occurring. The catalyst shall be sampled and tested at intervals no

longer than three years. Temperature records shall be maintained on circular or strip charts or by

other methods. [OAC 252:100-43, 40 CFR 63 Subpart FFFF]

7. The permittee shall use only commercial-quality natural gas in boilers #1, #2, and #3.

[OAC 252:100-31]

8. The facility is subject to federal NESHAP for Miscellaneous Organic Chemical Manufacturing

(FFFF), and shall comply with the following requirements. [40 CFR 63, Subpart FFFF]

§63.2430 Purpose of this subpart

§63.2435 Am I subject to the requirements in this subpart?

§63.2440 What parts of my plant does this subpart cover?

§63.2445 Compliance dates

§63.2450 General compliance requirements

§63.2455, 2460,

2465, 2470, 2475,

2480, 2485, & 2490

Requirements for: continuous process vents; batch process

vents; process vents that emit hydrogen halide and halogen

HAP or HAP metals; storage tanks; transfer racks; equipment

leaks; wastewater streams and liquid streams in open systems

within an MCPU; heat exchange systems.

§63.2495, 2500, & 2505 Compliance with: the pollution prevention standard;

emissions averaging; the alternative standard.

§63.2515, 2520, & 2525 Notifications, reports, and recordkeeping

§63.2535 Overlap options

§63.2540 General Provisions

§63.2545 Implementation and enforcement

§63.2550 Definitions

Appendices Tables 1 – 12

9. Boiler 3 in EUG 6 is subject to NSPS Subpart Dc and shall demonstrate compliance through

recordkeeping, consisting of recording the daily fuel type and amount. If only natural gas is

used, only monthly use amounts are required. [40 CFR 60.48c(g)]

10. Boilers of EUGs 3 and 6 and the heater of EUG 9 are subject to NESHAP Subpart DDDDD

and shall comply with the requirements of the subpart. [40 CFR 63.7480 et seq]

§63.7480 – 7495 Purpose, subject, affected source, compliance dates.

§63.7499 – 7501 Emission Limitations and Work Practice Standards

§63.7505 General Compliance Requirements

§63.7510 - 7533 Testing, Fuel Analyses, and Initial Compliance Requirements

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§63.7535 – 7541 Continuous Compliance Requirements

§63.7545 – 7560 Notification, Reports, and Records

§63.7565 – 7575 Other Requirements and Information

Tables 1 – 12 to Subpart DDDDD of Part 63

11. Emergency generator engines in EUG 7 are affected sources under NSPS Subpart JJJJ and

shall comply with the requirements of the subpart. [40 CFR 60.4230 et seq]

a. §60.4230 Am I subject?

b. §60.4233 Emissions standards

c. §60.4234 How long must I meet emission standards?

d. §60.4243 Compliance requirements

e. §60.4244 Test methods and procedures

f. §60.4245 Notification, reporting and recordkeeping

12. Emergency generator engines in EUG 7 and the emergency fire pump engine in EUG 8 are

affected sources under NESHAP Subpart ZZZZ and shall comply with the requirements of the

subpart. [40 CFR 63.6580 et seq]

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?

13. The following records shall be maintained on-site to verify insignificant activities.

[OAC 252:100-43]

a) Throughput for fuel storage/dispensing equipment operated solely for facility owned

vehicles, if throughput is less than 2,175 gallons per day, averaged over a 30-day period.

b) Records of capacity of all storage tanks with a capacity of 39,894 gallons or less storing a

fluid with a true vapor pressure less than 1.5 psia, and for each delivery of fluid, the type

and quantity.

c) Gallons of coatings, thinners and clean-up solvents used (annual)

d) Amount of cold flow improver product(s) manufactured and the associated amount of

Aromatic 100 used (monthly)

e) Records sufficient to demonstrate the continued insignificance of any other activity,

including, but not necessarily limited to, the micronizer, and mini-prill units.

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14. The following records shall be maintained on-site. All such records shall be made available

to regulatory personnel upon request. These records shall be maintained for a period of at least

five years after the time they are made. [OAC 252:100-43]

a) Production records for the Polywax, resin, oxidation, and micronizer units (monthly and

12-month rolling total).

b) Quantities of raw materials used (monthly and 12-month rolling total).

c) Emission calculations as described in SC #4.

d) Pollution control equipment maintenance records required by SC #6.

e) Boiler natural gasfuel use (monthly and 12-month rolling total).

f) LDAR records required by 40 CFR 63 Subpart FFFF, per SC #8.

g) Records of exhaust temperature for the second condenser (EP-E-4351) in the Unilin

process at MCPU-1, as required by 40 CFR 63 Subpart FFFF, per SC #8.

h) Records required by OAC 252:100-8-36.2(c).

i) Records required by 40 CFR 63 Subpart DDDDD, per SC #10.

j) Records required by 40 CFR 60 Subpart JJJJ, per SC #11.

k) Records required by 40 CFR 63 Subpart ZZZZ, per SC #12.

l) Records necessary to demonstrate compliance with NSPS Dc for Boiler 3.

15. 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 requested

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

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

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

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

OAC 252:100-39 Organic Materials Nonattainment not in control area

OAC 252:100-47 Landfills not in source category

16. This permit supersedes all previous Air Quality permits for this facility, which are now

cancelled. Upon issuance, Permit No. 2016-0042-TVR3 replaces and supersedes Permit No.

2010-002-TVR (M-2).

TITLE V (PART 70) PERMIT TO OPERATE / CONSTRUCT

STANDARD CONDITIONS

(July 21, 2009)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with the federal

Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act

and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma

Department of Environmental Quality (DEQ). The permit does not relieve the holder of the

obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or

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

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance

shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement

action, permit termination, revocation and reissuance, or modification, or for denial of a permit

renewal application. All terms and conditions are enforceable by the DEQ, by the

Environmental Protection Agency (EPA), and by citizens under section 304 of the Federal Clean

Air Act (excluding state-only requirements). This permit is valid for operations only at the

specific location listed.

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

D. It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

conditions of the permit. However, nothing in this paragraph shall be construed as precluding

consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for

noncompliance if the health, safety, or environmental impacts of halting or reducing operations

would be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from an emergency and/or posing an imminent and substantial

danger to public health, safety, or the environment shall be reported in accordance with Section

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported

consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

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

C. Every written report submitted under this section shall be certified as required by Section III

(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

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

MAJOR SOURCE STANDARD CONDITIONS July 21, 2009

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)]


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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)]


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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)]


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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,


6

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]


7

E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that

are not specifically approved by this permit are prohibited. [OAC 252:100-8-6(c)(6)]

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of credentials and other documents as may be required by law, the

permittee shall allow authorized regulatory officials to perform the following (subject to the

permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18)

for confidential information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a

source is located or emissions-related activity is conducted, or where records must be

kept under the conditions of the permit;

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

conditions of the permit;

(3) inspect, at reasonable times and using reasonable safety practices, any facilities,

equipment (including monitoring and air pollution control equipment), practices, or

operations regulated or required under the permit; and

(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit.

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

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later

than 4:30 p.m. on the next working day after the permittee first becomes aware of the

exceedance. This notice shall contain a description of the emergency, the probable cause of the

exceedance, any steps taken to mitigate emissions, and corrective actions taken.

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

B. Any exceedance that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to AQD as soon as is practicable; but under no circumstance shall

notification be more than 24 hours after the exceedance. [OAC 252:100-8-6(a)(3)(C)(iii)(II)]

C. An "emergency" means any situation arising from sudden and reasonably unforeseeable

events beyond the control of the source, including acts of God, which situation requires

immediate corrective action to restore normal operation, and that causes the source to exceed a

technology-based emission limitation under this permit, due to unavoidable increases in

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)]


8

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

emergency;

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

(3) during the period of the emergency the permittee took all reasonable steps to minimize

levels of emissions that exceeded the emission standards or other requirements in this

permit.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an

emergency shall have the burden of proof. [OAC 252:100-8-6(e)(3)]

F. Every written report or document submitted under this section shall be certified as required

by Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

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

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop

and register with the appropriate agency a risk management plan by June 20, 1999, or the

applicable effective date. [OAC 252:100-8-6(a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate individual emissions units that are either on the list in Appendix I to OAC Title 252,

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.

Any activity to which a State or Federal applicable requirement applies is not insignificant even

if it meets the criteria below or is included on the insignificant activities list.

(1) 5 tons per year of any one criteria pollutant.

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

aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year

for single HAP that the EPA may establish by rule.

[OAC 252:100-8-2 and OAC 252:100, Appendix I]

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate any individual or combination of air emissions units that are considered inconsequential

and are on the list in Appendix J. Any activity to which a State or Federal applicable

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


9

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.


10

(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


11

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


12

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. 2016-0042-TVR3

Baker Petrolite Corporation,

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

the Barnsdall Manufacturing Facility at Section 18, T24N, R11E, Barnsdall, Osage County,

Oklahoma, subject to standard conditions dated July 21, 2009 and specific condtions, both

attached.

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

Section VIII of the Standard Conditions.

______________________________ ___

Division Director, Air Quality Division Date

Jimmy Vaughan, Plant Manager


800 Birch Lake Road

Barnsdall, OK 74002

Re: Title V Renewal Permit No. 2016-0042-TVR3



SE/4 18, T24 N, R11 E

Dear Mr. Vaughan:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this

permit is issued subject to the certain 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 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. If you have any questions, please refer to the permit number

above and contact the permit writer at (405) 702-4100.

Sincerely,

Jian Yue, P.E.

Engineering Section


Enclosures

Jimmy Vaughan, Plant Manager


800 Birch Lake Road

Barnsdall, OK 74002




SE/4 18, T24 N, R11 E

Dear Mr. Vaughan:

Air Quality Division has completed the initial review of your permit application referenced

above. This application has been determined to be a Tier II. In accordance with 27A O.S. § 2-

14-301 & 302 and OAC 252:4-7-13(c) the application and enclosed draft permit are now ready

for public review. The requirements for public review include the following steps which you

must accomplish:

1. Publish at least one legal notice (one day) of a “Notice of Filing a Tier II

Application” and a “Notice of Tier II Draft Permit” in at least one newspaper of

general circulation within the county where the facility is located. (Instructions

enclosed).

2. Provide for public review (for a period of 30 days following the date of the

newspaper announcement) a copy of this draft permit and a copy of the application

at a convenient location (preferably a public location) within the county of the

facility.

3. Send to AQD a copy of the proof of publication notice from Item #1 above together

with any additional comments or requested changes which you may have on the

draft permit.


above and contact me at (405) 702-4100 or the permit writer, Jian Yue, at (405) 702-4205.

Sincerely,

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

AIR QUALITY DIVISION Enclosures

KDHE, BAR

Forbes Field, Building 283

Topeka, KS 66620




SE/4 18, T24 N, R11 E

Dear Sir / Madame:

The subject facility has requested a Title V Permit Renewal. Air Quality Division has completed

the initial review of the application and prepared a draft permit for public review. Since this

facility is within 50 miles of the Oklahoma - Kansas border, a copy of the proposed permit will

be provided to you upon request. Information on all permit and a copy of this draft permit are

available for review by the public in the Air Quality Section of DEQ Web Page:

http://www.deq.state.ok.us.


above and contact me or the permit writer at (405) 702-4100.

Sincerely,

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


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