oklahoma department of environmental quality department of environmental quality ... issued on may...

DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM October 26, 2012

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

THROUGH: Kendal Stegmann, Senior Environmental Manager

Compliance and Enforcement

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

THROUGH: Peer Review

FROM: Mark Chen, P.E., New Source Permits Section

SUBJECT: Evaluation of Title-V Permit Renewal Application No. 2010-618-TVR2

PowerSmith Cogeneration Project, LP

PowerSmith Cogeneration Plant

7425 SW 29th

Street, Oklahoma City 73179

Latitude N 35.44185, Longitude W 97.64761

SW ¼ of Section 8, Township 11N, Range 4W

Oklahoma County, Oklahoma

Directions: From downtown OKC, take I-40 west 6 miles to MacArthur

Blvd. Travel south on MacArthur for 2 miles to SW 29th and turn right.

Then, travel 1.5 miles and turn right into Will Rogers Business Park and

go to the end of the road to the facility.

SECTION I. INTRODUCTION

PowerSmith Cogeneration Project, LP (PowerSmith), has requested a renewal of the Part 70

Title V operating permit for their Oklahoma City facility (SIC Code 3999, NAICS Code

339999). The facility is currently operated under Permit No. 2003-145-TVR (M-2), which was

issued on May 21, 2010. This power plant was constructed under Permit No. 85-031-C, issued

on November 20, 1985, and started operation under Permit No. 85-031-O, issued on December

9, 1988. The original Title-V Permit, Permit No. 96-283-TV (PSD), was issued on October 30,

1998. The first Title-V Permit renewal, Permit No. 2003-145-TVR, was issued on June 7, 2006.

Both Title V Operating Permit No. 2003-145-TVR and its modification No. 2003-145-TVR (M-

2) expired on June 7, 2011 and PowerSmith submitted the renewal application, which was

received by AQD on November 29, 2010. All updated operations and modified emissions from

June 7, 2006 are included in this Title V renewal permit.

Permit No. Issue Date Permit Details

2003-145-TVR (M-1) 8/5/08 Allowed the use of landfill gas as a fuel

2003-145-TVR (M-2) 5/21/10 Modification to incorporate startup and shutdown limits

and BACT for the combustion turbine

Air Quality Division (AQD) also uses this opportunity to update applicable state rules and

federal regulations related to the facility.

PERMIT MEMORANDUM 2010-618-TVR2 DRAFT 2

SECTION II. FACILITY DESCRIPTION

This cogeneration plant generates a design output capacity of approximately 120 megawatts

(MW) of electricity, which is sold to Oklahoma Gas and Electric (OG&E), and has the ability to

provide steam at an annual average rate of approximately 60,000 pounds per hour to adjacent

facilities. The plant is a combined cycle and topping cycle plant, which consists of a gas turbine,

a supplementary fired Heat Recovery Steam Generator (HRSG), and a single automated

extraction condensing steam turbine generator.

The gas turbine generates a maximum 75 MW of electricity and the steam turbine generates a

maximum 45 MW of electricity. Exhaust gases from the gas turbine flow through either a

bypass stack or the HRSG inlet. The HRSG duct burner may fire natural gas to supplement the

gas turbine exhaust heat. The combined exhaust gases then exit the common main stack. When

the bypass stack is open, the duct burner will not fire. The gas turbine is equipped with a

separate steam injection system. This system injects steam into the combustion chamber as a

direct means of controlling NOx below the desired level and was considered as BACT in the

Permit No. 96-283-TV (PSD).

Permit No. 2003-145-TVR (M-1) included an allowance to utilize landfill gas in addition to

natural gas as fuel. Utilizing landfill gas results in no net emissions increases of criteria

pollutants and a small increase in gaseous hydrogen chloride (HCl) and hydrogen fluoride (HF)

emissions (both are Hazardous Air Pollutants (HAPs)), but required changing the permit

restriction of using pipeline-quality natural gas only and required adding monitoring of fuel

sulfur and chlorine/fluorine contents. These compounds are regulated as HAPs but are also

extremely corrosive to plant equipment, therefore, the landfill gas used as fuel must be treated to

remove most halogens before it can be utilized at PowerSmith.

Permit No. 2003-145-TVR (M-2) included start-up and shutdown limits due to a technological

limitation. OAC 252:100-33 was recently revised to require BACT for start-up/shutdown if a

unit cannot meet 0.2 lb NOx/MMBTU and if there are technological limitations which result in

failure to meet 0.2 lb NOx/MMBTU. For this facility, emissions from the combustion turbine

are controlled by steam injection; injecting steam prior to warm-up would quench the flame and

damage the turbine. A limit of 0.35 lb NOx/MMBTU during 4-hour start-up/shutdown periods

was incorporated.

In addition, NSPS Subpart GG limits NOx emissions from the turbine to 75 ppmdv @ 15%

oxygen, with a 4-hour averaging period. This is equivalent to 0.277 lb NOx /MMBTU.

Manufacturer information indicates 0.5 lb NOX/MMBTU during cold starts for the first 1 – 1.5

hours (times depend on ambient air temperatures). During normal operations, performance

testing showed 0.11 lb/MMBTU. For a theoretical four-hour cold start in cold weather, worst-

case NOx emissions would be 1.5 hours of 0.5 lb NOx/MMBTU followed by 2.5 hours of 0.11

lb NOx/MMBTU, or 0.256 lb NOx/MMBTU. If a 3-hour time frame is used (the averaging time

in OAC 252:100-33), 3-hour average NOx emissions would be 0.305 NOx lb/MMBTU, just

under the limit, 0.35 lb NOx/MMBTU.


SECTION III. EQUIPMENT

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

EUG-1 Facility-Wide Emissions Unit Groups

This emission unit group is facility-wide. It includes all emission units and is established to

discuss the applicability of those rules or compliance demonstrations which may affect all

sources within the facility.

EUG-2 Gas Turbine

EU Point Description Heat Capacity

(MMBTUH)

Serial

#

Const.

Date

300 409 General Electric Frame 7 Gas Turbine

Model 7001E - Main Stack 1,009.00

(Peak Firing) 282625 1988

300 408 General Electric Frame 7 Gas Turbine

Model 7001E – Bypass

EUG-3 Duct Burner

EU Point Description Burner Size

(MMBTUH)

Construction

Date

400 409 Davis Combustion System Duct Burner

Project #EP-052 - Main Stack 145.80 1988

EUG-4 Diesel Fire Pump

EU Point Description Heat Capacity

(MMBTUH) Serial #

Const.

Date

100 105 Diesel Fire Pump, Cummins

Engine, Model V504F2 0.52* C99623 1987

*Includes a 8.8% safety factor to allow full operation of the facility. Capacity rated at 187 hp.

EUG-5 Cooling Towers

EU Point Description Pumping Rate Construction Date

500 101 Cooling Tower Cell 9,750 1988




EUG-6 Fugitive Emissions

Fugitive emissions at this facility are insignificant.


STACK PARAMETERS

Point Height (feet) Diameter (feet) Flow (ACFM) Temperature (F)

409 78 14.2 2,451,000 Approx. 275

SECTION IV. EMISSIONS

The main emission point at the facility is the main stack, Emission Point No. 409, which is 78

feet high and 14.2 feet in diameter. The gas turbine and duct burner share the stack. The criteria

pollutants emissions from the main stack are revised based on the latest AP-42 emission factors

and OAC 252:100-33-2(a) emission limit for NOX. To allow variance in operation of the plant, a

safety factor of 9% is included in the emission estimations resulting in a heat input capacity of

1,154.80 MMBTUH. The NOX emissions from the gas turbine and duct burner are based on the

emission factor in OAC 252:100-33-2(a) since previous permits limited NOX emissions by that

emission factor and stack testing performed in 1989 and 1996 were based on that limit. The CO,

VOC, and PM10 emissions from the gas turbine are based on the emission factors in AP-42

(4/00), Tables 3.1-1 and 3.1-2a, Section 3.1, “Stationary Gas Turbine for Electricity Generation.”

The emission factor for CO is a controlled emission factor with steam injection. The CO, VOC,

and PM10 emissions from the duct burner are based on the emission factors in AP-42 (7/98),

Tables 1.4-1 and 1.4-2, Section 1.4, “Natural Gas Combustion”. Both are estimated based on the

8,760 hr/yr continuous operation, and 1,000 BTU/SCF average heating value. To ensure the

plant’s full operation, safety factors of 15% for CO and PM10 and 200% for VOC are included in

the emission factors. The varying safety factors are used because the AP-42 factors differ

significantly from the stack testing results of 1989 and 1996. Additionally, manufacturer

guarantees exceed AP-42 by varying amounts. Table 1 shows the AP-42 emission factors (in

units of lb/MMBTU) including the corresponding safety factors. Table 2 presents the final

emission limits for criteria pollutants from the main stack, No. 409.

Table 1. Emission Factors for Combustion Process (lb/MMBTU)

Source NOx CO2 VOC

3 PM10

2

Gas Turbine 0.21 0.0345

1 0.0063 0.00759

Duct Burner 0.2 0.0966 0.0165 0.00874 1Controlled by steam injection

2 Includes a 15% safety factor.

3 Includes a 200% safety factor.

In addition to the above factors, a 0.35 lb/MMBTU NOx factor will be used for 4-hour start-up

and 1-hour shutdown periods. This yields 353 lb/hr NOx, or 1,412 lbs per start-up event and 353

lbs per shutdown event.

Table 2. Criteria Pollutants Emissions Estimates from Stack No. 409 (Normal Operations)

Pollutants NOx CO VOC PM10

Source MMBTUH lb/hr TPY lb/hr TPY lb/hr TPY lb/hr TPY

Turbine 1,009.00 201.80 883.89 34.81 152.47 6.36 27.84 7.66 33.54

Burner 145.80 29.16 127.71 14.08 61.69 2.41 10.54 1.27 5.58

Total 1,154.80 230.96 1,011.61 48.89 214.16 8.76 38.38 8.93 39.12


Since Permit No. 96-283-TV (PSD) used the NOx emission factor of 0.20 lb/MMBTU for the

gas turbine during normal operations and the duct burner, the same factor will be used for

permitting purposes in this permit to correspond with the stack tests conducted in 1989 and 1996.

The maximum heat input of 1,154.80 MMBTUH can be translated to a monthly fuel

consumption of 859,174 MMBTU/month, assuming continuous operation of 31 days in a month

in a worst-case scenario. Emissions for the diesel fire pump engine are based on AP-42 (10/96)

Table 3.3-1, Section 3.3, “Gasoline and Diesel Industrial Engines,” and include a 10% safety

factor to the fuel consumption and 15% safety factor to CO and PM10 emissions and a 200% safety

factor for VOC emissions. All emissions are based on continuous operation (8760 hrs/yr). There

is also one cooling tower on site with four cells. AP-42 (1/95) Section 13.4-1, “Wet Cooling

Towers,” lists PM10 emission factor for wet cooling towers as 0.019 lb/1000 gallons based on total

dissolved solids (TDS) content of 11,500 ppm. The applicant estimated that the TDS content in

this cooling tower is 1,280 ppm which results in 0.002 lb/1000 gallons. The total maximum

pumping rate of the four cooling tower cells is 34,120 gal/min.

Table 3. Total Facility-Wide Emissions – Normal Operations

Point NOx CO VOC PM10

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

409 230.96 1011.61 48.89 214.16 8.76 38.38 8.93 39.12

105 2.33 10.20 0.58 2.53 0.55 2.43 0.19 0.82

101 -- -- -- -- -- -- 1.28 5.60

102 -- -- -- -- -- -- 1.28 5.60

103 -- -- -- -- -- -- 1.28 5.60

104 -- -- -- -- -- -- 0.64 2.79

Totals 233.29 1021.81 49.47 216.69 9.31 40.81 13.60 59.53

The HAP emissions from the duct burner are based on the emission factors in AP-42 (7/98),

Tables 1.4-3 and 1.4-4, Section 1.4, “Natural Gas Combustion”. Table 4 shows the HAP

emissions from the duct burner, which are estimated based on the maximum capacity plus a 9%

safety factor, 145.80 MMBTUH, continuous operation at 8,760 hr/yr, and 1,000 BTU/SCF

average heating value.

Landfill gas may contain trace amounts of Freon-12 (CCl2F2). Most of this gas is release from

refrigerators which are deposited in landfills. However, the Freon-12 is inert, therefore not

removed by treatment, and releases small amount of HCl and HF upon combustion of the landfill

gas. There are no AP-42 factors for these emissions; HCl and HF emissions were estimated

based on 2 ppm Freon-12 in landfill gas. Both HCl and HF emissions were included in Table 4

in the next page.


Table 4. HAP Emissions from the Duct Burner

HAP E.F. Emissions

lb/MMBTU lb/hr TPY

Acenaphthene 1.80E-09 0.00 0.00

Acenaphthylene 1.80E-09 0.00 0.00

Anthracene 2.40E-09 0.00 0.00

Benzo-a-anthracene 1.80E-09 0.00 0.00

Benzene 2.10E-06 0.00 0.00

Benzo-a-pyrene 1.20E-09 0.00 0.00

Benzo-a-fluoranthene 1.80E-09 0.00 0.00

Benzo-(g,h,i)-perylene 1.20E-09 0.00 0.00

Benzo-k-fluoranthene 1.80E-09 0.00 0.00

Chrysene 1.80E-09 0.00 0.00

Dibenzo-(a,h)-anthracene 1.20E-09 0.00 0.00

Dichlorobenzene 1.20E-06 0.00 0.00

Fluoranthene 3.00E-09 0.00 0.00

Fluorene 2.80E-09 0.00 0.00

Formaldehyde 7.50E-05 0.01 0.05

Hexane 1.80E-03 0.27 1.16

Indeno-(1,2,3-cd)-pyrene 1.80E-09 0.00 0.00

Naphthalene 6.10E-07 0.00 0.00

Phenanthrene 1.70E-08 0.00 0.00

Pyrene 5.00E-09 0.00 0.00

Toluene 3.40E-06 0.00 0.00

Arsenic 2.00E-07 0.00 0.00

Beryllium 1.20E-08 0.00 0.00

Cadmium 1.10E-06 0.00 0.00

Chromium 1.40E-06 0.00 0.00

Cobalt 8.40E-08 0.00 0.00

Hydrogen Chloride -- 0.21 0.92

Hydrogen Fluoride -- 0.12 0.51

Manganese 3.80E-07 0.00 0.00

Mercury 2.60E-07 0.00 0.00

Nickel 2.10E-06 0.00 0.00

Selenium 2.40E-08 0.00 0.00

Total 0.61 2.64

The hazardous air pollutant (HAP) emissions from the gas turbine are based on the emission

factors in AP-42 (4/00), Tables 3.1-3, Section 3.1, “Stationary Gas Turbine for Electricity

Generation.” Table 5 shows the HAP emissions from the gas turbine, which are estimated based

on the peak firing rate plus a 9% safety factor, 1,009 MMBTUH, and continuous operation at

8,760 hr/yr.


Table 5. HAP Emissions from the Gas Turbine

HAP E.F. Emissions

lb/MMBTU lb/hr TPY

1,3-Butadiene 4.30E-07 0.00 0.00

Acetaldehyde 4.00E-05 0.04 0.18

Acrolein 6.40E-06 0.01 0.03

Benzene 1.20E-05 0.01 0.05

Ethylbenzene 3.20E-05 0.03 0.14

Formaldehyde 7.10E-04 0.72 3.17

Hydrogen Chloride -- 0.21 0.92

Hydrogen Fluoride -- 0.12 0.51

Napthalene 1.30E-06 0.00 0.01

PAH 2.20E-06 0.00 0.01

Propylene Oxide 2.90E-05 0.03 0.13

Toluene 1.30E-04 0.13 0.58

Xylenes 6.40E-05 0.07 0.29

Total 1.38 6.02

The sum of the HAP emissions from the gas turbine and the duct burner, 1.99 lb/hr and 8.67

TPY, are the emissions from the stack at the combined heat input capacities of 1,155 MMBTUH

which includes the embedded safety factor of 9%. The facility-wide HAP emissions do not

exceed the major source threshold, 10 TPY.

Potential Greenhouse Gas (GHG) emissions from the facility were estimated using engineering

calculations and gas analysis data (mole % value of gas component) from the facility. GHG

emissions are expressed as CO2e. All CO2e emissions from combustion of natural gas are based

on the default factors for natural gas combustion from 40 CFR Part 98, Subpart C, Tables C-1

and C-2, and the related global warming potential factors from 40 CFR Part 98, Subpart A, Table

A-1 regarding CO2, CH4, and N2O emissions. The natural gas combustion equipment includes a

gas turbine, duct burner and diesel fire pump. Potential VOC fugitive emissions are estimated

using emission factors from Subpart W, Table W-1A, the final rule issued on 12/23/2011, of 40

CFR Part 98. The potential emissions of SF6 -containing equipment, such as circuit breakers, are

estimated using emission factors from Subpart A, Table A-1, of 40 CFR Part 98. The gas

analysis was made on November 10, 2010. Table 6 lists annual potential facility-wide GHG

emissions.

Table 6. Facility-Wide Greenhouse Gas Emissions

Emissions Source Total CO2e

MTPY TPY

No. 409, Gas Turbine, 1,009.00 MMBTUH 469,094.98 517,083.40

No. 409, Duct Burner, 145.80 MMBTUH 67,784.16 74,718.48

No. 105, Diesel Fire Pump, 0.52 MMBTUH 338.04 372.62

Fugitive VOC Emissions 582.92 642.55

Circuit Breaker 11.39 12.55

Total 537,811.49 592,829.60


Based on Table 6, the GHG emissions are estimated as metric ton per year (MTPY). The GHG

emissions exceed a PTE of 100,000 MTPY CO2e. This facility is a major source of GHG

emissions.

SECTION V. INSIGNIFICANT ACTIVITIES

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

8, Appendix I, are listed below. Record-keeping for activities indicated with “*” is required in

the Specific Conditions.

1. * Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel,

which are either used exclusively for emergency power generation or for peaking power

service not exceeding 500 hours per year. The plant operates one diesel-fired water pump

which is in this category. The plant operates one diesel-fired water pump which is in this

category; however, the diesel fire pump engine is an affected facility under 40 CFR 63

Subpart ZZZZ. Following the applicable compliance date for this rule, the diesel fire pump

engine will no longer be considered an insignificant source. However, no specific emission

limitations will apply.

2. Gasoline and aircraft fuel, handling facilities, equipment, and storage tanks except those

subject to New Source Performance Standards and standards in OAC 252:100-37-15, 39-30,

39-41, and 39-48, or with a capacity greater than 400 gallons.

3. Hazardous waste and hazardous materials drum staging areas. There is one hazardous

material storage room and one drum staging area on site.

4. Sanitary sewage collection and treatment facilities other than incinerators and Publicly

Owned Treatment Works (POTW). Stacks or vents for sanitary sewer plumbing traps are

also included (i.e., lift station). There is one sewer lift station (including a vent) and one vent

on the underground city sewer line casing on site.

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

hazardous waste satellite (accumulation) areas. There is at least one chemical storage room

on site.

6. 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. There is one maintenance shop

on site.

SECTION 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. 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, Oklahoma is in attainment with these

standards.

OAC 252:100-5 (Registration of Air Contaminant Sources) [Applicable]

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

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

regulated pollutants. Emission inventories have been submitted and fees paid for past years.

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

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

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

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

notification to AQD and may require a permit modification. Insignificant activities mean

individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual

calendar year emissions do not exceed the following limits:

5 TPY of any one criteria pollutant;

2 TPY of any one HAP or 5 TPY of multiple HAPs or 20% of any threshold less than 10

TPY for single HAP that the EPA may establish by rule;

Emission limits for the facility are based on the previous Title V permit, No. 96-283-TV (PSD),

dated 10/30/1998, the permit renewal application received by AQD on 11/29/2010, and the

applicability determination, No. 96-283-AD, dated 8/16/2004.

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

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

emission limits based on maximum design heat input rating. Appendix C specifies a PM

emission limitation of 0.60 lb/MMBTU for all equipment at this facility with a heat input rating

of 10 MMBTUH or less. Fuel-burning equipment is defined in OAC 252:100-1 as “combustion

devices used to convert fuel or wastes to usable heat or power.” Thus, the following are subject


to the requirements of this subchapter. Emission factors shown in Section III (Emissions) above

indicate that all Units are in compliance.

Equipment Maximum Heat

Input, (MMBTUH)

Appendix C Emission

Limit, (lb/MMBTU)

Potential Emission

Rate, (lb/MMBTU)

Gas Turbine* 1,009 0.20 0.0098

HRSG Duct Burner* 145.8 0.32 0.0068

Diesel Fire Pump** 0.52 0.60 0.31

* Potential emission rate determined from manufacturing data.

** Potential emission rate determined from AP-42 Table 3.3-1 (10/96) emission factor for PM10.

This subchapter also limits emissions of PM from industrial processes. Per AP-42 factors, there

are no significant PM emissions from any other industrial activities at this facility.

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

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

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

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

period exceed 60% opacity. When burning natural gas there is little possibility of exceeding the

opacity standards.

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

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

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

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

maintenance of air quality standards. Under normal operating conditions, this facility will not

cause a problem in this area, therefore it is not necessary to require specific precautions to be

taken.

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

Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1,

1972). For gaseous fuels, the limit is 0.2 lb/MMBTU heat input averaged over 3 hours. For fuel

gas having a gross calorific value of approximately 1,000 Btu/scf, this limit corresponds to fuel

sulfur content approximately 1,203 ppmv. For liquid fuels, the limit is 0.8 lb/MMBTU. The

permit limits fuel to commercial-grade natural gas or fuel oil with a maximum sulfur content of

0.75 % sulfur by weight. AP-42 (9/98), Chapter 1.3, Table 1.3-1, gives an emission factor of

142*S pound of SO2 per 1,000 gallons which is approximately 0.76 lb/MMBTU when S =

0.75% by weight sulfur in the fuel oil. This emission rate is in compliance with the limitation of

0.8 lb/MMBTU.

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

This subchapter limits NOx emissions from any new gas-fired fuel-burning equipment with rated

heat input of 50 MMBTUH or more to 0.2 pound per million BTUs, 3 hour average with the

exception of subject equipment with a technological limitation which prohibits subject

equipment from meeting the appropriate standard during startup and/or shutdown events. During

startup and/or shutdown events, the subject equipment with a technological limitation must meet

BACT during startup and/or shutdown events and cannot contribute to exceeding NAAQS or

PSD increment. This standard sets the emission limit for the total emissions from the main stack.


Stack testing results demonstrated compliance with this limit. This permit incorporates recent

changes dealing with compliance with limits during start-up and shutdown.

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

None of the following affected processes are located at this facility: gray iron cupola, blast

furnace, basic oxygen furnace, petroleum catalytic cracking unit, or petroleum catalytic

reforming unit.

OAC 252:100-37 (Volatile Organic Compounds) [Part 7 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 at maximum storage

temperature to be equipped with a permanent submerged fill pipe or with an organic vapor

recovery system. This facility does not involve any VOC storage tanks with a vapor pressure of

1.5 psia or more.

Part 3 requires VOC loading facilities with a throughput equal to or less than 40,000 gallons per

day to be equipped with a system for submerged filling of tank trucks or trailers if the capacity of

the vehicle is greater than 200 gallons. This facility does not have the physical equipment

(loading arm and pump) to conduct this type of loading and is not subject to this requirement.

Part 5 limits the VOC content of coatings from any coating line or other coating operation. This

facility does not normally conduct coating or painting operations except for routine maintenance

of the facility and equipment.

Part 7 requires fuel-burning and refuse-burning equipment to be operated to minimize emissions

of VOC. The equipment at this location is subject to this requirement.

Part 7 requires all effluent water separator openings which receive water containing more than

200 gallons per day of any VOC, to be sealed or the separator to be equipped with an external

floating roof or a fixed roof with an internal floating roof or a vapor recovery system. No

effluent water separators are located at this facility.

OAC 252:100-39 (Volatile Organic Compounds in Non-attainment Areas) [Not Applicable]

Part 3 affects petroleum refinery operations, none of which occur at this facility.

Part 5 affects petroleum liquid storage in external floating roof tanks, none of which occurs at

this facility.

Part 7 contains rules affecting specific processes. The only section that might affect this facility

is 39-41. Section 39-4 exempts the facility from Section 39-41 for those tanks storing liquids

with vapor pressures below 1.5 psia. All liquids stored at this facility have vapor pressure well

below the 1.5-psia threshold. In the event that pipeline drip in the condensate tanks owned by

the natural gas pipeline companies exceeds the 1.5 psia standard, such tanks satisfy the condition

that tanks with capacity between 400 and 40,000 gallons be bottom-filled. Oklahoma is still an

“attainment” area.

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

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

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

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

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

specific requirements for this facility at this time.

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


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

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

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

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

operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant

source. All required testing must be conducted by methods approved by the Air Quality Director

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

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

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

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

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

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

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

use, of any credible evidence or information relevant to whether a source would have been in

compliance with applicable requirements if the appropriate performance or compliance test or

procedure had been performed.

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

OAC 252:100-11 Alternative Emissions Reduction not requested

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

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

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

OAC 252:100-24 Grain Elevators not in source category

OAC 252:100-47 Municipal Solid Waste Landfills not in source category

SECTION VII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable At This Time]

Final total facility emissions are greater than the PSD major source threshold of 250 TPY for

regulated pollutant NOx. The facility is considered an existing major source for PSD and any

future emission increases must be evaluated for PSD if they exceed a significance level (40 TPY

for NOx, 100 TPY for CO, 40 TPY for VOC, 40 TPY for SO2, 25 TPY for TSP, 15 TPY for PM,

0.6 TPY for Pb, and 10 TPY for TRS).

NSPS, 40 CFR Part 60 [Subpart Db and GG are Applicable]

Subpart Db, Electric Utility Steam Generating Units. Subpart Db regulates each steam

generating unit that commences construction, modification, or reconstruction after June 19,

1984, and that has a heat input capacity from fuels combusted in the steam generating unit of

greater than 100 MMBTUH. The duct burner is permitted at 145.8 MMBTUH, thus is subject to

this subpart. This subpart sets NOx limit for natural gas burning unit as 0.2 lb/MMBTU.

Paragraph 60.48b(h) exempts a duct burner used in a combined cycle system from installing or

operating a continuous monitoring system to measure nitrogen oxide emissions.

Subpart GG, Stationary Gas Turbines. Subpart GG affects all stationary gas turbines which

commenced construction, reconstruction, or modification after October 3, 1977, with heat input

at peak load of greater than or equal to 10 MMBTUH based on the lower heating value of the

fuel. The gas turbine has a permitted peak firing heat input capacity of 1,009 MMBTUH and

therefore is subject to this subpart. This subpart specifies a NOx emissions limitation corrected


to 15% oxygen with equation of 60.332(a)(1) for turbines of heat input greater than 100

MMBTUH:

FY

14.40.0075NOx

This subpart requires that the owner or operator using steam injection to control NOx emissions

to install and operate a continuous monitoring system to monitor and record the fuel

consumption and the ratio of steam to fuel being fired in the turbine. NOx emissions are limited

to 75 ppmdv or less. Sulfur dioxide standards specified in Subpart GG are that no fuel shall be

used which exceed 0.8% by weight sulfur nor shall exhaust gas contain in excess of 150 ppm

SO2. Monitoring of the sulfur content is required for gaseous fuels, using methods outlined in

§60.334(h)(1). If the fuel meets the definition of natural gas found in §60.331(u), the

owner/operator is not required to monitor the sulfur content. The facility has supplied gas

analysis data demonstrating that the fuel meets the definition of natural gas, i.e., it contains 20

grains or less of total sulfur per 100 scf and either is composed of at least 70% methane by

volume or has gross calorific value between 950 and 1,100 BTU/scf. Test methods and

procedures for this subpart are listed in detail in §60.335.

Subpart Kb, VOL Storage Vessels. Subpart Kb regulates hydrocarbon storage tanks larger than

19,813 gallons capacity and built after July 23, 1984. All VOL tanks on site are below the

threshold, 19,813 gallons. This subpart is not applicable.

Subpart LLL, Onshore Natural Gas Processing: SO2 Emissions. This subpart affects sweetening

units and sweetening units followed by sulfur recovery units. This facility does not have a

sweetening unit.

Subpart HHHH, Coal-Fired Electric Steam Generating Units. This subpart was promulgated in

the Federal Register on May 18, 2005, and affects new and existing coal-fired steam generating

units at electric utilities. This facility does not burn coal, and therefore, this facility is not subject

to this subpart.

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.

For the purposes of this subpart, the date that construction commences is the date the engine is

ordered by the owner or operator. The diesel fire pump, powered by an emergency generator

engine, was constructed prior to the effective date of Subpart IIII.

Subpart KKKK, Stationary Combustion Turbines. This subpart establishes emission standards

and compliance schedules for the control of emissions from stationary combustion turbines with

a heat input at peak load equal to or greater than 10.7 gigajoules (10 MMBTU) per hour, based

on the higher heating value of the fuel, that commenced construction, modification, or

reconstruction after February 18, 2005. Stationary combustion turbines regulated under this

subpart are exempt from the requirements of Subpart GG of this part. Heat recovery steam

generators and duct burners regulated under this subpart are exempted from the requirements of

Subparts Da, Db, and Dc of this part. (§60.4310 lists additional exemptions.) Powersmith’s

turbine was constructed prior to this regulation.

NESHAP, 40 CFR Part 61 [Not Applicable]

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

coke oven emissions, mercury, radionuclides or vinyl chloride except for trace amounts of

benzene.


Subpart J, Equipment Leaks of Benzene, only applies to process streams, which contain more

than 10% benzene by weight. Analysis of Oklahoma natural gas indicates a maximum benzene

content of less than 1%.

Subparts N, O, and P (Inorganic Arsenic from Glass Manufacturing, Primary Copper Smelters

and Arsenic Trioxide and Metallic Arsenic Production). Electric generating facilities are not an

affected source under any of these subparts.

Subparts J, Y, BB, and FF (Benzene Fugitives, Benzene Storage, Benzene Transfer, and Benzene

Waste). Electric generating facilities are not an affected source under any of these subparts.

Subparts C and D (Beryllium and Beryllium Rocket Motor Firing). Electric generating facilities

are not an affected source under either of these subparts.

Subpart E (Mercury). Electric generating facilities are not an affected source under this subpart.

NESHAP, 40 CFR Part 63 [Subpart ZZZZ Applicable]

Subpart YYYY, Combustion Turbines. This subpart affects turbines that are located at a major

source of hazardous air pollutants (HAPs) emissions. The stationary combustion turbine

category is divided into eight subcategories, including lean premix gas-fired turbines, diffusion

flame gas-fired turbines, diffusion flame oil-fired turbines, emergency turbines, turbines with a

rated peak power output of less than 1.0 megawatt (MW), turbines burning landfill or digester

gas, and turbines located on the North Slope of Alaska. The subpart affects only major sources

of HAPs. HAP emission calculations have shown that the facility is a minor source of HAPs.

This subpart does not apply.

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 following

table differentiates existing, new, or reconstructed units based on their construction dates.

Construction/Reconstruction Dates

Engines >500 hp Engines ≤ 500 hp

Existing Unit

Located at Major HAP Source Before 12/19/02 Before 6/12/06

Located at Area HAP Source Before 6/12/06

New or Reconstructed Unit

Located at Major HAP Source On and After 12/19/02 On and After 6/12/06

Located at Area HAP Source On and After 6/12/06

The following table lists the status of the emergency generator engine at this facility:

EU ID# Make/Model Size (HP) Construction Date Status

100 Diesel Fire Pump, Cummins

Engine, Model V504F2 187 1987 Existing

As an emergency and existing CI engine located at a minor source of HAP emissions, the engine

is subject to this subpart. A summary of the applicable requirements are shown below.

Engine Category Normal Operation**

Existing Emergency CI & Black Start CI*

Change oil and filter every 500 hours of operation or

annually, whichever one comes first;

Inspect air cleaner every 1,000 hours of operation or

annually, whichever one comes first; and

Inspect all hoses and belts every 500 hours of operation

or annually, whichever one comes first and replace as


Engine Category Normal Operation** necessary.

*Black Start engine means an engine whose only purpose is to start up a combustion turbine.

** During Startup - Minimize the engine’s time spent at idle and minimize the engine’s startup time at startup to a

period needed for appropriate and safe loading of the engine, not to exceed 30 minutes, after which time the

non-startup emission limitations apply.

Sources have the option to utilize an oil analysis program in order to extend the specified oil

change requirements of this subpart. Initial compliance demonstrations must be conducted

within 180 days after the compliance date. Owners and operators of a non-operational engine

can conduct the performance test, as required, when the engine is started up again.

Other applicable requirements include:

1) The owner/operator must operate and maintain the stationary RICE and after-treatment

control device (if any) according to the manufacturer’s emission-related written

instructions or develop their own maintenance plan which must provide to the extent

practicable for the maintenance and operation of the engine in a manner consistent with

good air pollution control practice for minimizing emissions.

2) Existing emergency stationary RICE located at an area source of HAP emissions must

install a non-resettable hour meter if one is not already installed.

Existing stationary CI RICE located at an area source of HAP emissions must comply with the

applicable emission limitations and operating limitations no later than May 3, 2013. The permit

will require the facility to comply with all applicable requirements by the initial compliance date.

Subpart DDDDD, Industrial, Commercial and Institutional Boilers and Process Heaters at major

sources of HAPs emissions. EPA has published various actions regarding implementation of this

rule as detailed following:

- September 13, 2004 EPA promulgated standards for major sources.

- June 19, 2007 US Court of Appeals for the district of Columbia vacated and remanded

the standards.

- March 21, 2011 EPA promulgated new standards.

- May 18, 2011 EPA published notice of delay of the effective dates until judicial review

or EPA reconsideration is completed, whichever is earlier.

- January 9, 2012 DC Circuit Court vacated EPA’s May 18, 2011, stay of the regulation.

EPA will use its enforcement discretion to send new and existing sources a “no action

assurance letter” indicating that they are not required to submit administrative

notifications to permitting agencies signifying that they are subject to the Boiler MACT

as issued on March 21, 2011.

- July 18, 2012 EPA announced that it is extending the “No Action Assurance” issued on

March 13, 2012, to apply to the deadline for submitting the “Notification of Compliance

Status” regarding initial tune-ups in the final Boiler Area Source rule. The agency

emphasized that this applies only to the requirement to submit the Notification of

Compliance Status for the initial tune up and not to any other provisions of the area

source rule. EPA also announced that it is amending the expiration date of the March 13,

2012, “No Action Assurance” so that it will expire when the final Boiler Area Source


reconsideration rule is issued and becomes effective or December 31, 2012, whichever is

earlier.

Section 112(j) of the Clean Air Act addresses situations where EPA has failed to promulgate a

standard as required under 112(e) (1) and (3). 112(j) requires case-by-case MACT determination

applications to be submitted to the permitting authority within specified time frames. Since

112(j) appears to only address situations where EPA has failed to promulgate standards and not

situations in which complete rules are subsequently vacated, confusion existed as to the

requirements for these sources. On March 30, 2010, EPA proposed a rule to amend 112(j) to

clarify what applies under 112(j). In the proposed rule, EPA clarifies that the intent was that

vacated sources should be treated similar to sources where EPA has failed to promulgate a

standard. The rule, as proposed, will require case-by-case MACT applications to be submitted to

the permitting authority within 90 days after promulgation of these amendments or by the date

which the source’s permitting authority requests such application. Compliance with this subpart

will be determined based on the requirements of the amended 112(j). HAP emission calculations

have shown that the facility is a minor source of HAPs. This subpart does not apply.

Subpart JJJJJJ, Industrial, Commercial and Institutional Boilers at area sources of HAPs

emissions. This subpart affects each new, reconstructed, and existing boiler, which uses coal,

biomass, or oil as its fuel. The boiler in this facility uses natural gas as its fuel, and does not use

any coal, biomass, or oil as its fuel; therefore, this subpart does not apply.

CAM, 40 CFR Part 64 [Not Applicable]

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

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

Title V permit, if it meets all 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; and

It has potential emissions, prior to the control device, of the applicable regulated air

pollutant of 100 TPY.

The turbine is the only affected unit at this facility. The steam injection technology to reduce the

nitrogen oxide emission is not considered “a control device” under CAM. The effect of steam

injection is to increase the thermal mass by dilution and thereby to absorb the latent heat of

vaporization from the flame zone and to reduce the peak temperature in the flame zone. It does

not meet the definition of “a control device” to remove/destroy the pollutants after the pollutants

are generated. Therefore, this facility is not subject to this regulation.

Acid Rain, 40 CFR Parts 72 to 78 [Not Applicable]

This is not an “affected source” since it is a qualifying cogeneration facility (FER C#QF86-36-

001).

Accidental Release Prevention, 40 CFR Part 68 [Not Applicable]

This facility does not process or store more than the threshold quantity of any regulated

substance (Section 112r of the Clean Air Act 1990 Amendments). More information on this

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

http://www.epa.gov/ceppo


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

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

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

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

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

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

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

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

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

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

(Subpart H).

Subpart A identifies ozone-depleting substances and divides them into two classes. Class I

controlled substances are divided into seven groups; the chemicals typically used by the

manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform

(Class I, Group V). A complete phase-out of production of Class I substances is required by

January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are

hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs.

Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances,

scheduled in phases starting by 2002, is required by January 1, 2030. The facility does not

utilize any Class I and II substances.

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

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

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

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

reduction.

The standard conditions of the permit address the requirements specified at § 82.156 for persons

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

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

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

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

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

refrigerant.

SECTION VIII. COMPLIANCE

Inspection

On April 27, 2012, from 1435 to 1535 hours, an Air Quality full compliance evaluation (FCE)

was conducted at PowerSmith Cogeneration Project, LP, Oklahoma City Cogeneration Plant.

The compliance inspection and evaluation was conducted by Ms. Keely Dolan, Environmental

Programs Specialist, Air Quality Division of the Oklahoma Department of Environmental

Quality. PowerSmith was represented by Gary Meyers, Plant Engineer, and Michael Sisk, Plant

Manager. In this FCE, no violation was found. In addition, there are no enforcement cases,

which have been opened against the facility in the last three years. Since there are no physical

changes at the facility from April 27, 2012 to August 27, 2012, there is no need to inspect the

facility again.


Testing

Performance testing of the turbine per NSPS Subpart GG was conducted in August 1989 after

the initial start up, which showed that SO2 emissions were non-detected and NOx emissions were

in compliance with Subpart GG standard at 75 ppmdv. However, the applicable requirements of

NSPS Subpart Db for the duct burner were inadvertently missed in the original permitting. The

applicant then conducted performance testing for NOx emissions from the turbine and the duct

burner on June 4 and 5, 1996. The applicant also conducted a test for firing the turbine at peak

rating. The test was conducted by Cubix Corporation, and ODEQ personnel Nora Melton and

Jerry Goochey observed the test. The test measured NOx by Method 20, CO by Method 10, and

flow by Method 19. The average emissions from the turbine and HRSG duct burners are listed

in the following table and are in compliance with both Subpart GG and Subpart Db standards.

Operation Mode

NOx

ppmdv @ 15%

O2

NOx

lbs/hr

NOx

lbs/MMBTU

Normal Load

Turbine Only 29.8 95.12 0.109

Joint Fired 27.8 101.85 0.102

Duct Burner On Not required 6.73 0.052

Peak Firing

Turbine Only 42.5 138.46 0.157

Joint Fired 42.49 138.46 0.157

Duct Burner Off - - -

Method 9 opacity test was also conducted for the main stack on June 4, 1996 by Cubix

Corporation. No visible emissions were observed.

Tier Classification and Public Review

This application has been determined to be 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 land, which will be used to accomplish the permitted purpose.

The applicant published the “Notice of Filing a Tier II Application” in The Journal Record of

Oklahoma City, Oklahoma, a daily newspaper printed and published in the City of Oklahoma

City, in Oklahoma County, on January 26, 2011. The notice stated that the application was

available for public review at the DEQ Air Quality Division’s Main Office in Oklahoma City,

707 N Robinson, Oklahoma City, Oklahoma 73101. A draft of this permit will also be made

available for public review for a period of 30 days as stated in another newspaper announcement

and will be available on the AQD Section of the DEQ Web site. This facility is not located

within 50 miles of the border of Oklahoma. Information on all permit actions is available for

review by the public in the Air Quality section of the DEQ Web Page: http://www.deq.state.ok.us.


Fees Paid

Part 70 operating permit renewal application fee of $1,000.

SECTION IX. SUMMARY

The facility was constructed and is operating as described in the permit application. Ambient air

quality standards are not threatened at this site. There are no active Air Quality compliance or

enforcement issues concerning this facility. Issuance of the operating permit is recommended,

contingent on EPA and public review.

DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

PowerSmith Cogeneration Project, LP Permit Number 2010-618-TVR2

PowerSmith Cogeneration Plant

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

Quality on November 29, 2010, and additional information received on March 16, 2011, and

February 17, 2012. The Evaluation Memorandum dated October 26, 2012, explains the

derivation of applicable permit requirements and estimates of emissions; however, it does not

contain operating limitations or permit requirements. Continuing operations under this permit

constitutes acceptance of, and consent to, the conditions contained herein.

1. Points of emissions and emissions limitations are detailed below. [OAC 252:100-8-6(a)]

EUG-2 and EUG-3: The gas turbine and the duct burner share one stack.

Point NOx* CO VOC PM10

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

409 230.96 1011.61 48.89 214.16 8.76 38.38 8.93 39.12

*Limits during all operations except start-up and shutdown.

a. NOx emission limit is set at 0.20 lb/MMBTU of heat input, 3-hour average, except during

start-up and shutdown. [OAC 252:100-33-2(a)]

b. Start-up shall be considered to occur between beginning of operation of the turbine

(supplying fuel to the unit) and when injection of steam/water for NOx control reaches

required levels. Shut-down shall be considered to occur between cessation of steam/water

injection and cessation of operation. During periods of start-up not to exceed four hours

and shutdown not to exceed one hour, NOx emissions from the turbine shall not exceed

1,412 lbs per start-up prior to injection of required amounts of steam/water for NOx

control during start-up or 353 lbs NOx following cessation of steam/water injection

during shutdown.

c. Per 40 CFR Part 60.334(j)(1)(A), an “excess emission” remains any operating hour for

which the average steam or water to fuel ratio falls below the acceptable ratio needed to

demonstrate compliance with 60.332 as established during the performance testing.

EUG-4: Emissions for the emergency fire pump were calculated based on AP-42 (10/96) Table

3.3-2 but do not have a specific limitation.

EUG-5: Four cooling tower cells.

Point PM10

lb/hr TPY

101 1.28 5.60

102 1.28 5.60

103 1.28 5.60

104 0.64 2.79

SPECIFIC CONDITIONS 2010-618-TVR2 DRAFT

2

EUG-6: Fugitive emissions at this facility are insignificant and do not have a specific limitation.

2. The permittee shall be authorized to operate the facility continuously (24 hours per day,

every day of the year). [OAC 252:100-8-6(a)]

3. The turbine and duct burner shall be fueled only with pipeline-quality natural gas or landfill

gas. The 187-hp Cummins Engine shall be fueled with diesel with a maximum sulfur content

of 0.75% by weight. Compliance can be shown by the following methods: for pipeline grade

natural gas, a current gas company bill; for other gaseous fuel, a current lab analysis, stain-

tube analysis, gas contract, tariff sheet, or other approved methods. Compliance shall be

demonstrated at least once annually. [OAC 252:100-31]

4. The turbine and Cummins engine shall have a permanent identification plate attached which

shows the make, model number, and serial number. [OAC 252:100-43]

5. The permittee shall comply with the Standards of Performance for Stationary Gas Turbines

NSPS Subpart GG, for the gas turbine. [40 CFR Part 60 Subpart GG]

a. The turbine shall not discharge into the atmosphere any gases which contain nitrogen

oxides in excess of the limitation of 60.332(a)(1).

b. The turbine shall either comply with the sulfur dioxide emission limitation of 60.333(a) or

the fuel sulfur content limitation of 60.333(b).

c. Emissions monitoring for NOX per §60.334.

d. Monitoring of the sulfur and nitrogen content of the turbine fuel pursuant to

§60.334(h)(1) and (2), and §60.334(i). Per §60.334(h)(2), monitoring of the fuel nitrogen

content is not required if the owner or operator does not take a NOX allowance for fuel-

bound nitrogen. Monitoring of fuel sulfur content is not required when a gaseous fuel is

fired in the turbine and the owner or operator demonstrates that the gaseous fuel meets

the definition of "natural gas" using one of the methods in §60.334(h)(3)(i) or (ii).

§60.331 defines natural gas as containing 20 grains or less of total sulfur per 100 standard

cubic feet (SCF) and is either composed of at least 70 percent methane by volume or has

a gross caloric value between 950 and 1100 BTU/SCF.

6. The permittee shall comply with the Standards of Performance for Industrial-Commercial-

Institutional Steam Generating Units NSPS Subpart Db, for the duct burner including but not

limited to:

a. The duct burner shall not discharge into the atmosphere any gases which contain nitrogen

oxides in excess of the limitation of 60.44b (a)(4).

b. The owner or operator shall keep records as required by 60.49b(d) and 60.49b(h).

7. Fuel consumption and steam/water-to-fuel ratio shall be continuously monitored. The actual

steam-to-fuel ratio shall be greater than or equal to the required ratio to maintain NOx

emissions below the standard of 0.2 lb/million BTU, 3-hour average, during normal operations.

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


3

8. The chlorine and fluorine content of landfill gas shall be measured at least annually when

landfill gas is used at this facility. [OAC 252:100-43]

9. Following the applicable compliance deadline, the permittee, or the owner/operator (O/O),

shall comply with all applicable requirements in 40 CFR Part 63, National Emission Standard

for Hazardous Air Pollutants (NESHAP), Subpart ZZZZ, for any existing, new, or

reconstructed reciprocating internal combustion engines (RICE) including, but not limited to,

the following: [40 CFR §§ 63.6580 to 63.6675]

What This Subpart Covers

a. § 63.6580 What is the purpose of subpart ZZZZ?

b. § 63.6585 Am I subject to this subpart?

c. § 63.6590 What parts of my plant does this subpart cover?

d. § 63.6595 When do I have to comply with this subpart?

Emission and Operating Limitations

e. § 63.6603 What emission limitations and operating limitations must I meet if I own or

operate an existing stationary RICE located at an area source of HAP emissions?

General Compliance Requirements

f. § 63.6605 What are my general requirements for complying with this subpart?

Testing and Initial Compliance Requirements

g. § 63.6625 What are my monitoring, installation, operation, and maintenance

requirements?

h. § 63.6630 How do I demonstrate initial compliance with the emission limitations and

operating limitations?

Continuous Compliance Requirements

i. § 63.6635 How do I monitor and collect data to demonstrate continuous compliance?

j. § 63.6640 How do I demonstrate continuous compliance with the emission limitations

and operating limitations?

Notifications, Reports, and Records

k. § 63.6655 What records must I keep?

l. § 63.6660 In what form and how long must I keep my records?

Other Requirements and Information

m. § 63.6665 What parts of the General Provisions apply to me?

n. § 63.6670 Who implements and enforces this subpart?

o. § 63.6675 What definitions apply to this subpart?

10. At least once every five years (during the permit term), the permittee shall conduct tests of

NOX and CO emissions from Emission Unit Point 409, Main Stack, when operating under

representative conditions for that period. Testing shall be conducted using approved

reference methods listed below. [OAC 252:100-8-6 (a)(3)(A)]

a. The following reference methods shall be used (including applicable methods):

(i) Method 1: Sample and Velocity Traverses for Stationary Sources.

(ii) Method 2: Determination of Stack Gas Velocity and Volumetric Flow Rate.

(iii) Method 3: Gas Analysis for CO2, Excess Air, and Dry Molecular Weight.

(iv) Method 4: Determination of Moisture in Stack Gases.

(v) Method 7A-7E: Determination of NOX Emissions from Stationary Sources.

(vi) Method 10A-10B: Determination of CO Emissions from Stationary Sources.


4

(vii) Method 20: Determination of NOX and O2 Emissions from Stationary Gas

Turbines.

b. Performance testing shall be conducted while the unit is operating under representative

conditions within 10% of the maximum production rate.

c. A protocol describing the testing plan shall be submitted to the Air Quality Division at

least 30 days prior to the testing.

d. A written report documenting the results of emissions testing shall be submitted within

60 days of completion of on-site testing.

11. The permittee shall maintain records of operations as listed below. These records shall be

maintained on site or at a local field office for at least five years after the date of recording

and shall be provided to regulatory personnel upon request. [OAC 252:100-43]

a. Steam-to-fuel ratio or water-to-fuel ratio (hourly).

b. Fuel consumption (monthly and 12-month rolling total).

c. For the fuel(s) burned, the appropriate document(s) as described in Specific Condition

No. 3.

d. Records as required by 40 CFR Part 60, NSPS, Subparts Db and GG.

e. Records as required by 40 CFR Part 63, NESHAP, Subpart ZZZZ.

f. Landfill gas chlorine/fluorine content (annual average) when landfill gas is utilized.

g. Records of durations of start-up and shutdown events (monthly).

12. No later than 30 days after each anniversary date of the issuance of the original Title V

operating permit (October 30, 1998), the permittee shall submit to Air Quality Division of

DEQ, with a copy to the US EPA, Region 6, a certification of compliance with the terms and

conditions of this permit. [OAC 252:100-8-6 (c)(5)(A) & (D)]

13. This permit supersedes all previous Air Quality operating permits for this facility, which are

now null and void.

Mr. Hugh Bereman, General Manager


7425 SW 29th

Street

Oklahoma City, Oklahoma 73179

SUBJECT: Title V Operating Permit Renewal No. 2010-618-TVR2


SW ¼ of Section 8, T11N, R4W

Oklahoma City, Oklahoma County, Oklahoma

Dear Mr. Bereman:

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

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

14-302 and OAC 252:002-31 the enclosed draft permit is now ready for public review. The

requirement for public review include the following steps which you must accomplish:

1. Publish at least one legal notice (one day) in at least one newspaper of general circulation

within the county where the facility is located. (Instruction 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.

Thank you for your cooperation. If you have any questions, please refer to the permit number

above and contact me at (405) 702-4100 or the permit writer at (405) 702-4196.

Sincerely,

Phillip Fielder, P.E.

Permits and Engineering Group Manager

AIR QUALITY DIVISION

Enclosures

MAJOR SOURCE AIR QUALITY PERMIT

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)]


G. Any owner or operator subject to the provisions of New Source Performance Standards

(“NSPS”) under 40 CFR Part 60 or National Emission Standards for Hazardous Air Pollutants

(“NESHAPs”) under 40 CFR Parts 61 and 63 shall maintain a file of all measurements and other

information required by the applicable general provisions and subpart(s). These records shall be

maintained in a permanent file suitable for inspection, shall be retained for a period of at least

five years as required by Paragraph A of this Section, and shall include records of the occurrence

and duration of any start-up, shutdown, or malfunction in the operation of an affected facility,

any malfunction of the air pollution control equipment; and any periods during which a

continuous monitoring system or monitoring device is inoperative.

[40 C.F.R. §§60.7 and 63.10, 40 CFR Parts 61, Subpart A, and OAC 252:100, Appendix Q]

H. The permittee of a facility that is operating subject to a schedule of compliance shall submit

to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for

achieving the activities, milestones or compliance required in the schedule of compliance and the

dates when such activities, milestones or compliance was achieved. The progress reports shall

also contain an explanation of why any dates in the schedule of compliance were not or will not

be met, and any preventive or corrective measures adopted. [OAC 252:100-8-6(c)(4)]

I. All testing must be conducted under the direction of qualified personnel by methods

approved by the Division Director. All tests shall be made and the results calculated in

accordance with standard test procedures. The use of alternative test procedures must be

approved by EPA. When a portable analyzer is used to measure emissions it shall be setup,

calibrated, and operated in accordance with the manufacturer’s instructions and in accordance

with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document

or an equivalent method approved by Air Quality.

[OAC 252:100-8-6(a)(3)(A)(iv), and OAC 252:100-43]

J. The reporting of total particulate matter emissions as required in Part 7 of OAC 252:100-8

(Permits for Part 70 Sources), OAC 252:100-19 (Control of Emission of Particulate Matter), and

OAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing

or calculation procedures, modified to include back-half condensables, for the concentration of

particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of only

particulate matter emissions caught in the filter (obtained using Reference Method 5).

K. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required

by 40 C.F.R. Part 60, 61, and 63, for all equipment constructed or operated under this permit

subject to such standards. [OAC 252:100-8-6(c)(1) and OAC 252:100, Appendix Q]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70

operating permit or alternative date as specifically identified in a subsequent Part 70 operating

permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a

certification of compliance with the terms and conditions of this permit and of any other

applicable requirements which have become effective since the issuance of this permit.

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


B. The compliance certification shall describe the operating permit term or condition that is the

basis of the certification; the current compliance status; whether compliance was continuous or

intermittent; the methods used for determining compliance, currently and over the reporting

period. The compliance certification shall also include such other facts as the permitting

authority may require to determine the compliance status of the source.

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

C. The compliance certification shall contain a certification by a responsible official as to the

results of the required monitoring. This certification shall be signed by a responsible official,

and shall contain the following language: “I certify, based on information and belief formed

after reasonable inquiry, the statements and information in the document are true, accurate, and

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

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions

units or stationary sources that are not in compliance with all applicable requirements. This

schedule shall include a schedule of remedial measures, including an enforceable sequence of

actions with milestones, leading to compliance with any applicable requirements for which the

emissions unit or stationary source is in noncompliance. This compliance schedule shall

resemble and be at least as stringent as that contained in any judicial consent decree or

administrative order to which the emissions unit or stationary source is subject. Any such

schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the

applicable requirements on which it is based, except that a compliance plan shall not be required

for any noncompliance condition which is corrected within 24 hours of discovery.

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

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the

permit term and that are applicable to the facility. Compliance with all new requirements shall

be certified in the next annual certification. [OAC 252:100-8-6(c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions

established for alternate operating scenarios, emissions trading, and emissions averaging, but

excluding terms and conditions for which the permit shield is expressly prohibited under OAC

252:100-8) shall be deemed compliance with the applicable requirements identified and included

in this permit. [OAC 252:100-8-6(d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific

Conditions of this permit. Those requirements that the applicant requested be determined as not

applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6(d)(2)]


SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees

based on emissions inventories. The methods used to calculate emissions for inventory purposes

shall be based on the best available information accepted by AQD.

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

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date

of issuance. [OAC 252:100-8-6(a)(2)(A)]

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely

and complete renewal application has been submitted at least 180 days before the date of

expiration. [OAC 252:100-8-7.1(d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and

become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction

is not commenced within 18 months after the date the permit or authorization was issued, or if

work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified

operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application

of any provision of this permit to any circumstance, is held invalid, the application of such

provision to other circumstances, and the remainder of this permit, shall not be affected thereby.

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

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege.

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

B. This permit shall not be considered in any manner affecting the title of the premises upon

which the equipment is located and does not release the permittee from any liability for damage

to persons or property caused by or resulting from the maintenance or operation of the equipment

for which the permit is issued. [OAC 252:100-8-6(c)(6)]


SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty

(60) days of the request unless the DEQ specifies another time period, any information that the

DEQ may request to determine whether cause exists for modifying, reopening, revoking,

reissuing, terminating the permit or to determine compliance with the permit. Upon request, the

permittee shall also furnish to the DEQ copies of records required to be kept by the permit.

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

B. The permittee may make a claim of confidentiality for any information or records submitted

pursuant to 27A O.S. § 2-5-105(18). Confidential information shall be clearly labeled as such

and shall be separable from the main body of the document such as in an attachment.

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

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and

shall be made in writing within thirty (30) days after such sale or transfer.

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

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause.

Except as provided for minor permit modifications, the filing of a request by the permittee for a

permit modification, revocation and reissuance, termination, notification of planned changes, or

anticipated noncompliance does not stay any permit condition.

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

B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the

following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source

category three or more years prior to the expiration date of this permit. No such

reopening is required if the effective date of the requirement is later than the expiration

date of this permit.

(2) The DEQ or the EPA determines that this permit contains a material mistake or that the

permit must be revised or revoked to assure compliance with the applicable requirements.

(3) The DEQ or the EPA determines that inaccurate information was used in establishing the

emission standards, limitations, or other conditions of this permit. The DEQ may revoke

and not reissue this permit if it determines that the permittee has submitted false or

misleading information to the DEQ.

(4) DEQ determines that the permit should be amended under the discretionary reopening

provisions of OAC 252:100-8-7.3(b).

C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-8-

7.3(d). [OAC 100-8-7.3(d)]


D. The permittee shall notify AQD before making changes other than those described in Section

XVIII (Operational Flexibility), those qualifying for administrative permit amendments, or those

defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The

notification should include any changes which may alter the status of a “grandfathered source,”

as defined under AQD rules. Such changes may require a permit modification.

[OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]

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

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

SECTION XIII. INSPECTION & ENTRY

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

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

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

(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

permit). When an operating scenario is changed, the permittee shall record in a log at the facility

the scenario under which it is operating. [OAC 252:100-8-6(a)(10) and (f)(1)]

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

(1) result in no net emissions increases,

(2) are not modifications under any provision of Title I of the federal Clean Air Act, and

(3) do not cause any hourly or annual permitted emission rate of any existing emissions unit

to be exceeded;

provided that the facility provides the EPA and the DEQ with written notification as required

below in advance of the proposed changes, which shall be a minimum of seven (7) days, or

twenty four (24) hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the

DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such

change, the written notification required above shall include a brief description of the change

within the permitted facility, the date on which the change will occur, any change in emissions,

and any permit term or condition that is no longer applicable as a result of the change. The

permit shield provided by this permit does not apply to any change made pursuant to this

paragraph. [OAC 252:100-8-6(f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facility

unless elsewhere covered by a more restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized

in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-13]

(2) No particulate emissions from any fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an opacity limit promulgated under 40 C.F.R., Part

60, NSPS, no discharge of greater than 20% opacity is allowed except for:

[OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any

consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours.

In no case shall the average of any six-minute period exceed 60% opacity;

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7;

(c) An emission, where the presence of uncombined water is the only reason for failure

to meet the requirements of OAC 252:100-25-3(a); or

(d) Smoke generated due to a malfunction in a facility, when the source of the fuel

producing the smoke is not under the direct and immediate control of the facility and


the immediate constriction of the fuel flow at the facility would produce a hazard to

life and/or property.

(4) No visible fugitive dust emissions shall be discharged beyond the property line on which

the emissions originate in such a manner as to damage or to interfere with the use of

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

maintenance of air quality standards. [OAC 252:100-29]

(5) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2

lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur

dioxide. [OAC 252:100-31]

(6) Volatile Organic Compound (VOC) storage tanks built after December 28, 1974, and

with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia

or greater under actual conditions shall be equipped with a permanent submerged fill pipe

or with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of

ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an order for production or importation of certain

class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the

requirements of §82.4;

(2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain

class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping

requirements at §82.13; and

(3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,

HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane

(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an

ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air

conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the

vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the

air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger

buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions

reduction except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]


(1) Persons opening appliances for maintenance, service, repair, or disposal must comply

with the required practices pursuant to § 82.156;

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

comply with the standards for recycling and recovery equipment pursuant to § 82.158;

(3) Persons performing maintenance, service, repair, or disposal of appliances must be

certified by an approved technician certification program pursuant to § 82.161;

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply

with record-keeping requirements pursuant to § 82.166;

(5) Persons owning commercial or industrial process refrigeration equipment must comply

with leak repair requirements pursuant to § 82.158; and

(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant

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

82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is

not inconsistent with Federal requirements, to provide for incorporation of requirements

established through construction permitting into the Source’s Title V permit without causing

redundant review. Requirements from construction permits may be incorporated into the Title V

permit through the administrative amendment process set forth in OAC 252:100-8-7.2(a) only if

the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the

procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to

the public that this permit is subject to EPA review, EPA objection, and petition to

EPA, as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit

will be incorporated into the Title V permit through the administrative amendment

process; that the public will not receive another opportunity to provide comments when

the requirements are incorporated into the Title V permit; and that EPA review, EPA

objection, and petitions to EPA will not be available to the public when requirements

from the construction permit are incorporated into the Title V permit.

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

70.8(a)(1).

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

C.F.R. § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period

as provided by 40 C.F.R.§ 70.8(a) and (c).

(5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day

comment period of any EPA objection to the construction permit. The DEQ shall not

issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 C.F.R. § 70.8(d).

(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).

(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these

permit conditions.


(9) Any requirements of the construction permit may be reopened for cause after

incorporation into the Title V permit by the administrative amendment process, by

DEQ as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40

C.F.R. § 70.7(f) and (g).

(10) The DEQ shall not issue the administrative permit amendment if performance tests fail

to demonstrate that the source is operating in substantial compliance with all permit

requirements.

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

Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing

shall preclude the use, including the exclusive use, of any credible evidence or information,

relevant to whether a source would have been in compliance with applicable requirements if the

appropriate performance or compliance test or procedure had been performed.

[OAC 252:100-43-6]

oklahoma department of environmental quality department of environmental quality ... issued on may...

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