MEMORANDUM August 10, Phillip Fielder, P.E., Permits and Engineering Group Manager Air Quality Division

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1 DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM August 10, 2016 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, P.E., Permits and Engineering Group Manager Air Quality Division Rick Groshong, Environmental Programs Manager, Compliance and Enforcement Richard Kienlen, P.E., Engineer Manager, New Source Permits Section Ryan Buntyn, E.I., Existing Source Permits Section Brandon Fanning, E.I, Engineering Section Evaluation of Permit Application No O (M-1) ETC Field Services, LLC Crossfield Station (Facility ID No. 1567) Latitude ºN; Longitude ºW Section 25, Township 19N, Range 4W, Logan County, Oklahoma Directions: From Marshall, OK, go south on Highway 74E for approximately 2.5 miles, turn east on Highway 51 for 2.0 miles, go south on N. Portland Ave. for 2.0 miles, and then turn east into facility. INTRODUCTION ETC Field Services, LLC (ETC) has requested a modified minor source operating permit for their Crossfield Station (SIC 1311). The facility is currently operating under Minor Source Operating Permit No O, issued March 21, The facility wants to resolve an enforcement case and update emission limits. On May 15, 2015, the Department of Environmental Quality, Air Quality Division ( DEQ ) received a voluntary disclosure for the Crossfield Station regarding actual emissions above the 40 tons per year ( TPY ) permit exempt threshold. The facility was historically permit exempt; however, beginning on March 1, 2014 the condensate production greatly increased from historical levels of 200 to 400 barrels per year. The hauling company could not accept the loads due to water being entrained in the condensate. To resolve the issue of removing the water, the condensate was eventually routed to atmospheric tanks to provide the ability for separation of water; however, this caused an excess emission of VOCs. Initially to remediate the problem a vapor combustor was installed September 10, Notice to Construct Permit No NOI was issued on May 19, The single vapor combustor stopped the excess emission event; however, it was not feasible for operation of the facility as it would take all day to handle the VOC vapors from the atmospheric tanks. Therefore, on January 6, 2016 the initial vapor combustor was shut down and replaced by two vapor combustors on January 8, A Notice of Modification to the NOI was received on

2 PERMIT MEMORANDUM O (M-1) DRAFT 2 January 19, With the installation of two vapor combustors the facility could handle the flashing emissions from the tanks. The uncontrolled VOC emissions lasted from April 1, 2014 to September 10, 2015 with resulting excess emission of TPY. The DEQ has determined that the submission met the requirements of OAC 252:4-9-5 and all eight of the necessary criteria for full credit for the mitigation of penalties. However, the DEQ believes that ETC operated as a Title V major source while the condensate emissions were uncontrolled. To resolve this issue, a Title V operating application and associated fees were submitted. DEQ will not require ETC to operate under the Title V program, but based off the information provided, DEQ will process the Title V operating application and issue this Minor Source Operating Permit Modification. A Title V operating permit fee of $7,500 was received on April 12, The enforcement case will be closed with the issuance of this permit. Emissions sources at the facility include two (2) 210-bbl condensate storage tanks, one (1) 100- bbl produced water storage tank, two (2) MMBtu/hr enclosed flares, and various support operations. The storage tanks located at this facility were constructed before August 23, Therefore the tanks are not subject to New Source Performance Standards (NSPS) Subpart OOOO. This facility qualifies for a synthetic minor permit because the controlled emissions of each of the criteria pollutants are below the major source threshold of 100 TPY and the HAP emissions are below the 10 TPY threshold for a single HAP and below the 25 TPY threshold for any combination of HAPs. FACILITY DESCRIPTION The Crossfield Station is responsible for the storage of condensate and produced water. The natural gas stream will enter the facility via the separator, where condensate will be removed from the inlet stream. The condensate will be transported to the pressurized condensate storage tank and the gas will be sent into a pipeline for transmission from the facility. From this point the facility will operate under two possible operating scenarios. Primary: In this scenario, the condensate will be removed from the pressurized condensate storage tank via pressurized tank trucks (PLOAD). The vapors from the tank trucks will be routed back to the tanks via a closed loop system. Due to the controls in place, PLOAD will have minimal emissions and will be an insignificant activity. Prior to loading, any produced water that has formed will need to be removed. The operators will use a manual dump valve to transfer produced water from the pressurized tank into the atmospheric produced water storage tank (TANK3). The produced water will then be removed via tank truck. Alternative: In this scenario, condensate and produced water are transferred from the pressurized storage tank to the atmospheric condensate storage tanks (TANK1 & TANK2) via an automatic dump valve. Any water that settles out is transferred to the produced water storage tank (TANK3).

3 PERMIT MEMORANDUM O (M-1) DRAFT 3 Source Condensate and produced water are removed via tank trucks. Vapors from TANK1 and TANK2 will be routed to two (2) enclosed flares. EQUIPMENT Storage Tanks EU ID # Contents Barrels Gallons Throughput (gal/yr) TANK1 Condensate 210 8,820 TANK2 Condensate 210 8,820 3,004,680 TANK3 Produced Water 100 4,200 1,001,310 Flares EU ID # Description Calculated Capacity/Size COMB1 Enclosed Condensate Flare MMBtu/hr COMB2 Enclosed Condensate Flare MMBtu/hr EMISSIONS Potential VOC emissions (breathing, working, and flash losses) from the two (2) 210-bbl condensate storage tanks were estimated using Promax and a combined throughput of 3,004,680 gallons/year. Throughput is only received during the alternative operating scenario. The breathing, working, and flash emissions from the condensate tanks are routed to the enclosed flares which have capture efficiencies of 98%. To allow for operational flexibility, it is conservatively estimated that the enclosed flares may be down up to 20% (1,752 hours) per 12 month period. Since flash emissions occur only during the transfer process, up to 458 bbl may be transferred without the enclosed flares in operation during a 12 month period. During the enclosed flares downtime the condensate tanks will vent to the atmosphere. Potential VOC emissions (breathing and working losses) from the one (1) 100-bbl produced water storage tank were estimated using Promax and a throughput of 1,001,310 gallons/year. During the primary operating scenario the produced water will flash since it is received directly from the pressurized storage tank. Flashing will not occur when operating under the alternative operating scenario. To be conservative, it is assumed that all water flashes and emissions were calculated using condensate, assuming 1% is emitted. Annual Throughput (gal/yr) Breathing and Working (TPY) Storage Tanks (VOC) Emissions Flare Capture Flash Efficiency (TPY) (%) Controlled VOC (TPY) Uncontrolled VOC (TPY) Total VOC (TPY) TANK1- TANK2 3,004, , (1) TANK3 1,001, (2) It is estimated that during flare downtime the throughput will be 19,256 gal/yr of condensate. Uncontrolled VOC = [(Breathing and working losses)*(20% downtime)] + [(Flash losses/annual throughput)*(19,256 gal/yr)]; 2 - To be conservative, it is assumed that all water flashes and emissions were calculated using condensate, assuming 1% is emitted.

4 PERMIT MEMORANDUM O (M-1) DRAFT 4 Potential NOx and CO emissions from the enclosed flares were calculated using the estimated burner rating of MMBtu/hr, 8,760 hours of operation per year, and the AP-42 (Chapter 13, Tables and ) factors listed below. Potential VOC emissions from the flares were calculated using a 98% capture efficiency and 98% control efficiency of the breathing, working, and flash emissions from the condensate tanks. Flare Emission Factors Source NOx CO (lb/mmbtu) (lb/mmbtu) COMB1 (18.44 MMBtu/hr) COMB2 (18.44 MMBtu/hr) Potential VOC emissions from the atmospheric condensate truck loading were estimated using Promax and a maximum annual condensate throughput of 3,004,680 gallons/year. Potential VOC emissions from the pressurized condensate truck loading were conservatively estimated using engineering estimations. Potential VOC emissions from the produced water truck loading were estimated using Promax, a maximum annual produced water throughput of 1,001,310 gallons/year, and assuming 1% of the water emissions are condensate. Emissions from fugitive equipment leaks are based on EPA s Protocol for Equipment Leak Emission Estimates (11/95, EPA-453/R ), an estimated number of components, and the VOC (C 3+ ) content of the materials handled. Fugitive VOC Emissions Equipment Emission VOC Type of Number % VOC Factor, Emissions Service of Items lb/hr/source lb/hr TPY Valves Gas/Vapor % Flanges Gas/Vapor % Relief Devices Gas/Vapor % Valves Light Liquid % Flanges Light Liquid % Pump Seals Light Liquid 6 100% Relief Valves Light Liquid 5 100% Total Fugitive VOC Emissions

5 PERMIT MEMORANDUM O (M-1) DRAFT 5 Total Facility-Wide Emissions ID # Source NOx CO VOC lb/hr TPY lb/hr TPY lb/hr TPY TANK1- Two (2) 210-bbl Condensate Storage TANK2 Tanks (1) TANK3 100-bbl Produced Water Storage Tank (2) COMB MMBtu/hr Enclosed Flare COMB MMBtu/hr Enclosed Flare LOAD Atmospheric Condensate Truck Loading PLOAD Pressurized Condensate Truck Loading PWLOAD Produced Water Truck Loading FUG1 Fugitives Total Emissions Total Emissions from Previous Permit ( ) Change in Emissions (205.31) Includes breathing, working, and flash losses. TANK1 and TANK2 are combined for permitting purposes. - Conservatively includes breathing, working, and flash losses. The facility has estimated that emissions of Hazardous Air Pollutants (HAPs) at this site are at negligible levels. OKLAHOMA AIR POLLUTION CONTROL RULES OAC 252:100-1 (General Provisions) Subchapter 1 includes definitions but there are no regulatory requirements. OAC 252:100-2 (Incorporation by Reference) 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) Primary Standards are in Appendix E and Secondary Standards are in Appendix F of the Air Pollution Control Rules. At this time, all of Oklahoma is in attainment of these standards. OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) 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. The facility is required to submit an emission inventory and pay annual fees after this operating permit is issued to the facility. OAC 252:100-7 (Permits for Minor Facilities) This facility (with controls listed in this permit) qualifies as a synthetic minor source after issuance of this permit because total controlled emissions of each criteria pollutant do not exceed 100 TPY and Hazardous Air Pollutants (HAP) emissions do not exceed the 10 TPY for any one HAP or 25 TPY for any aggregate of HAP.

6 PERMIT MEMORANDUM O (M-1) DRAFT 6 OAC 252:100-9 (Excess Emissions Reporting Requirements) Except as provided in OAC 252: (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: , 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: (Open Burning) 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: (Particulate Matter) Section 19-4 regulates emissions of PM from fuel-burning equipment. Particulate emission limits are based on maximum design heat input rating. Appendix C specifies a PM emission limitation of 0.60 lbs/mmbtu for equipment with a heat input rating of 10 MMBTUH or less. AP-42 (7/98) Table lists total PM emissions as lb/mmbtu for natural gas combustion. This permit requires the use of natural gas for all fuel-burning equipment to ensure compliance. OAC 252: (Visible Emissions and Particulates) 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: (Fugitive Dust) 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: (Sulfur Compounds) Part 5 limits sulfur dioxide emissions from new petroleum or natural gas process equipment (constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lb/mmbtu heat input averaged over 3 hours. For fuel gas having a gross calorific value of 1,000 Btu/SCF, this limit corresponds to fuel sulfur content of 1,203 ppmv. Gas produced from oil and gas wells having 343 ppmv or less total sulfur will ensure compliance with Subchapter 31. The permit requires the use of pipeline-grade natural gas or field gas with a maximum sulfur content of 343 ppmv for all fuel-burning equipment to ensure compliance with Subchapter 31.

7 PERMIT MEMORANDUM O (M-1) DRAFT 7 OAC 252: (Nitrogen Oxides) [Not Applicable] This subchapter limits NOx emissions from new fuel-burning equipment with rated heat input greater than or equal to 50 MMBTUH to emissions of 0.2 lb of NOx per MMBTU. There are no equipment items that exceed the 50 MMBTUH threshold. OAC 252: (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: (Volatile Organic Compounds) [Parts 3 and 7 are Applicable] Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing VOC with a vapor pressure above 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. The two (2) 210-bbl condensate storage tanks and the one (1) 100-bbl produced water storage tank are equipped with permanent submerged fill pipes, which meet this requirement. Part 3 requires loading facilities with a throughput equal to or less than 40,000 gallons per day to be equipped with a system for submerged filling 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. Therefore, this requirement is not applicable. Part 5 limits the organic solvent content of coating of parts and products. This facility will not normally conduct coating or painting operations except for routine maintenance of the facility and equipment, which is not an affected operation. Part 7 requires fuel-burning 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 effluent water separators, which receive water containing more than 200 gallons per day of any VOC, to be equipped with vapor control devices. There is no effluent water separator at this location. OAC 252: (VOC in Nonattainment and Former Nonattainment Areas) [Not Applicable] This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of organic materials from new and existing facilities in Tulsa and Oklahoma Counties. This facility is in Logan County so this subpart is not applicable. OAC 252: (Toxic Air Contaminants (TAC)) 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: (Testing, Monitoring, and Recordkeeping) 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

8 PERMIT MEMORANDUM O (M-1) DRAFT 8 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. FEDERAL REGULATIONS PSD, 40 CFR Part 52 [Not Applicable] Final total emissions are less than the major source threshold of 250 TPY of any single regulated pollutant and the facility is not one of the 26 specific industries with a threshold of 100 TPY. NSPS, 40 CFR Part 60 [Not Applicable] Subparts Kb, VOL Storage Vessels. Subpart Kb regulates hydrocarbon storage tanks larger than 19,813 gallons capacity and built after July 23, The largest tank has a capacity below the de minimis of 19,813 gal. This subpart is not applicable. Subpart GG, Stationary Gas Turbines. There are no turbines at this facility. Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing Industry. This facility is not a SOCMI plant. Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. This subpart applies to natural gas processing plants that commence construction, reconstruction, or modification after January 20, 1984 and prior to August 23, 2011, and include the following facilities located at on-shore natural gas processing plants: a compressor station, dehydration unit, underground storage tank, field gas gathering system, or liquefied natural gas unit located at an on-shore natural gas processing plant. "Natural gas processing plant" is defined as any site engaged in the extraction of natural gas liquids from field gas, fractionation of natural gas liquids, or both; "Natural gas liquids" are further defined as hydrocarbons such as ethane, propane, butane, and pentane. This site does not engage in this type of activity at this time. Therefore, this facility is not subject to Subpart KKK. Subpart LLL, Onshore Natural Gas Processing: SO 2 Emissions. There is no natural gas sweetening operation at this site at this time. Therefore, this facility is not subject to Subpart LLL. Subpart JJJJ, Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (SI-ICE), This subpart was published in the Federal Register on January 18, It promulgates emission standards for all new SI engines ordered after June 12, 2006, and all SI engines modified or reconstructed after June 12, 2006, regardless of size. The specific emission standards (either in g/hp-hr or as a concentration limit) vary based on engine class, engine power rating, lean-burn or rich-burn, fuel type, duty (emergency or non-emergency), and manufacture date. Engine manufacturers are required to certify certain engines to meet the emission standards and may voluntarily certify other engines. An initial notification is required only for owners and operators of engines greater than 500 HP that are non-certified. Emergency engines will be

9 PERMIT MEMORANDUM O (M-1) DRAFT 9 required to be equipped with a non-resettable hour meter and are limited to 100 hours per year of operation excluding use in an emergency (the length of operation and the reason the engine was in operation must be recorded). There are no engines at this facility. Subpart OOOO, Crude Oil and Natural Gas Production, Transmission, and Distribution. This subpart was promulgated on August 16, 2012, and affects the following sources that commence construction, reconstruction, or modification after August 23, 2011: 1. Each gas well affected facility, which is a single natural gas well. 2. Each centrifugal compressor affected facility, which is a single centrifugal compressor using wet seals that is located between the wellhead and the point of custody transfer to the natural gas transmission and storage segment. 3. Each reciprocating compressor affected facility, which is a single reciprocating compressor located between the wellhead and the point of custody transfer to the natural gas transmission and storage segment. 4. Each pneumatic controller affected facility, which is: a. For the oil production segment (between the wellhead and the point of custody transfer to an oil pipeline): a single continuous bleed natural gas-driven pneumatic controller operating at a natural gas bleed rate greater than 6 SCFH. b. For the natural gas production segment (between the wellhead and the point of custody transfer to the natural gas transmission and storage segment and not including natural gas processing plants): a single continuous bleed natural gasdriven pneumatic controller operating at a natural gas bleed rate greater than 6 SCFH. c. For natural gas processing plants: a single continuous bleed natural gas-driven pneumatic controller. 5. Each storage vessel affected facility, which is a single storage vessel located in the oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment, that contains an accumulation of crude oil, condensate, intermediate hydrocarbon liquids, or produced water and has the potential for VOC emissions equal to or greater than 6 TPY. 6. The group of all equipment, except compressors, within a process unit located at an onshore natural gas processing plant is an affected facility. 7. Sweetening units located at onshore natural gas processing plants that process natural gas produced from either onshore or offshore wells. For each reciprocating compressor the owner/operator must replace the rod packing before 26,000 hours of operation or prior to 36 months. If utilizing the number of hours, the hours of operation must be continuously monitored. Commenced construction is based on the date of installation of the compressor (excluding relocation) at the facility. There are no compressors at this facility. Storage vessels constructed, modified or reconstructed after August 23, 2011, with VOC emissions equal to or greater than 6 TPY must reduce VOC emissions by 95.0 % or greater. All of the storage tanks located at this facility were constructed before August 23, 2011 and are not subject to this subpart.

10 PERMIT MEMORANDUM O (M-1) DRAFT 10 A sweetening unit means a process device that removes hydrogen sulfide and/or carbon dioxide from the sour natural gas stream. There are no sweetening units at this facility. 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 benzene. Subpart J, Equipment Leaks of Benzene, only affects process streams, which contain more than 10% benzene by weight. All process streams at this facility are below this threshold. NESHAP, 40 CFR Part 63 [Not Applicable] Subpart HH, Oil and Natural Gas Production Facilities. This subpart applies to affected emission points that are located at facilities that are major or area sources of HAP and either process, upgrade, or store hydrocarbons prior to the point of custody transfer or prior to which the natural gas enters the natural gas transmission and storage source category. This facility is not a major source of HAP, and does not have a dehydrator that is the affected source under area source requirements. Subpart HHH, affects Natural Gas Transmission and Storage Facilities. Since this facility is a production facility, this subpart does not apply. Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart affects RICE with a site-rating greater than 500 brake horsepower that are located at a major source and new and reconstructed engines (after June 12, 2006) with a site rating less than or equal to 500 HP located at major sources, and located at area sources. Owners and operators of new or reconstructed engines at area sources and of new or reconstructed engines with a site rating equal to or less than 500 HP located at a major source (except new or reconstructed 4-stroke lean-burn engines with a site rating greater than or equal to 250 HP and less than or equal to 500 HP located at a major source) must meet the requirements of Subpart ZZZZ by complying with either 40 CFR Part 60 Subpart IIII (for CI engines) or 40 CFR Part 60 Subpart JJJJ (for SI engines). There are no engines at this facility. Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] The definition of a stationary source does not apply to transportation, including storage incident to transportation, of any regulated substance or any other extremely hazardous substance under the provisions of this part. The definition of a stationary source also does not include naturally occurring hydrocarbon reservoirs. Naturally occurring hydrocarbon mixtures, prior to entry into a natural gas processing plant or a petroleum refining process unit, including: condensate, crude oil, field gas, and produced water, are exempt for the purpose of determining whether more than a threshold quantity of a regulated substance is present at the stationary source. 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:

11 PERMIT MEMORANDUM O (M-1) DRAFT 11 COMPLIANCE Tier Classification and Public Review This application has been determined to be a Tier II based on being the application for an operating permit for a major source. The applicant published the Notice of Filing a Tier II Application in the Guthrie News Leader, a weekly newspaper published in Logan County, on July 30, The notice stated that the application was available for public review at the Guthrie Public Library, 201 North Division Street, Guthrie, OK 73044, or at the DEQ Air Quality Division s Main Office in Oklahoma City, 707 N Robinson, Oklahoma City, Oklahoma The applicant will also publish a Notice of Draft Tier II Permit. Information on all permit actions is available for review by the public in the Air Quality section of the DEQ Web Page: Comments Public Comments: EPA Comments: Performance Testing There are no units on location subject to performance testing requirements. Inspection On March 16, 2016 at 9:00am an initial compliance inspection was conducted at the facility. Aaron Gant represented ETC. Brandon Fanning represented the Air Quality Division. The facility appears to have been constructed and operating as described in the permit application. Fees Paid A fee of $7,500 for a Title V Authorization to Operate was paid on April 12, SECTION VII. SUMMARY The facility is operating as described in this memorandum. Ambient air quality standards are not threatened at this site. There are no active Air Quality compliance and enforcement issues concerning this facility. Issuance of the modified synthetic minor operating permit is recommended.

12 DRAFT PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS ETC Field Services LLC Crossfield Station Permit No O (M-1) The permittee is authorized to operate in conformity with the specifications submitted to the Air Quality Division on April 12, The Evaluation Memorandum dated August 10, 2016, explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain operating limitations or permit requirements. Continuing operations under this permit constitutes acceptance of, and consent to, the conditions contained herein: 1. Points of emissions and emissions limitations for each point: NOx CO VOC ID # Source lb/hr TPY lb/hr TPY lb/hr TPY TANK1- TANK2 Two (2) 210-bbl Condensate Storage Tank (1) TANK3 100-bbl Produced Water Storage Tank (2) COMB MMBtu/hr Enclosed Flare COMB MMBtu/hr Enclosed Flare LOAD Condensate Truck Loading PWLOAD Produced Water Truck Loading (1) - Includes breathing, working, and flash losses. TANK1 and TANK2 are combined for permitting purposes. (2) - Conservatively includes breathing, working, and flash losses. 2. The permittee shall be authorized to operate this facility continuously (24 hours per day, every day of the year). 3. The total facility throughput for the atmospheric tanks (TANK1-TANK3) shall not exceed the throughput limits as shown below: Source TANK1- TANK2 TANK3 Description Two (2) 210-bbl Atmospheric Condensate Storage Tank 100-bbl Atmospheric Produced Water Storage Tank Throughput Limits Gallons/year 3,004,680 1,001, Condensate loaded out of the pressurized storage tank directly into pressurized tank trucks will result in insignificant emissions and has no throughput limit and does not count towards the limits indicated in S.C. No. 3.

13 SPECIFIC CONDITIONS O (M-1) DRAFT 2 5. Condensate tanks (TANK1-TANK2) shall be vented to the flares (COMB1-COMB2) except during flare downtime up to 20% (1,752 hours) per 12 month period. Since flash emissions occur only during the transfer process, up to 458 bbl may be transferred without the enclosed flares in operation during a 12 month period. 6. The enclosed flares shall be operated as follows: a. The presence of flare pilot flames shall be monitored using a thermocouple or any other equivalent device to detect the presence of a flame. b. Records of pilot flames outages shall be maintained along with the time and duration of all periods during which the pilot flame is/are absent. c. Flares must be operating with minimum capture efficiency of 98%. d. Flares must be operating with minimum efficiency of 98% for VOC combustion. 7. The permittee shall maintain records of operations as listed below. These records shall be retained on-site or at a local field office for a period of at least five years following dates of recording, and shall be made available to regulatory personnel upon request. a. Total facility condensate throughput through the atmospheric tanks, TANK1 and TANK2 (monthly and 12-month rolling totals). b. Total facility produced water throughput through TANK3 (monthly and 12-month rolling totals). c. Flare downtime events and associated throughput and uncontrolled emissions. 8. This permit replaces and supersedes all previous Air Quality permits for this facility, which are now cancelled.

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15 MINOR SOURCE PERMIT TO OPERATE / CONSTRUCT AIR POLLUTION CONTROL FACILITY STANDARD CONDITIONS (July 12, 2012) A. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma Department of Environmental Quality (DEQ) in accordance with and under the authority of the Oklahoma Clean Air Act. The permit does not relieve the holder of the obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or ordinances. This specifically includes compliance with the rules of the other Divisions of DEQ: Land Protection Division and Water Quality Division. B. 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: (g)) 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: ] C. 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: (a)] D. Unless specified otherwise, the term of an operating permit shall be unlimited. E. Notification to the Air Quality Division of DEQ of the sale or transfer of ownership of this facility is required and shall be made in writing by the transferor within 30 days after such date. A new permit is not required. [OAC 252: (f)] F. The following limitations apply to the facility unless covered in the Specific Conditions: 1. No person shall cause or permit the discharge of emissions such that National Ambient Air Quality Standards (NAAQS) are exceeded on land outside the permitted facility. [OAC 252:100-3] 2. All facilities that emit air contaminants are required to file an emission inventory and pay annual operating fees based on the inventory. Instructions and forms are available on the Air Quality section of the DEQ web page. [OAC 252:100-5] 3. 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 252:100-9] 4. 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] 5. No particulate emissions from new fuel-burning equipment with a rated heat input of 10 MMBTUH or less shall exceed 0.6 lbs/mmbtu. [OAC 252:100-19] 6. No discharge of greater than 20% opacity is allowed except for short-term occurrences which consist of not more than one six-minute period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours. In no case shall the average of any six-minute period exceed 60% opacity. [OAC 252:100-25] 7. 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

16 MINOR SOURCE STANDARD CONDITIONS July 12, properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. [OAC 252:100-29] 8. No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2 lbs/mmbtu. No existing source shall exceed the listed ambient air standards for sulfur dioxide. [OAC 252:100-31] 9. 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 an organic material vapor-recovery system. [OAC 252: (b)] 10. All fuel-burning equipment shall at all times be properly operated and maintained in a manner that will minimize emissions of VOCs. [OAC 252: ] G. Any owner or operator subject to provisions of NSPS shall provide written notification as follows: [40 CFR 60.7 (a)] 1. A notification of the date construction (or reconstruction as defined under 60.15) of an affected facility is commenced postmarked no later than 30 days after such date. This requirement shall not apply in the case of mass-produced facilities which are purchased in completed form. 2. A notification of any physical or operational change to an existing facility which may increase the emission rate of any air pollutant to which a standard applies, unless that change is specifically exempted under an applicable subpart or in 60.14(e). This notice shall be postmarked 60 days or as soon as practicable before the change is commenced and shall include information describing the precise nature of the change, present and proposed emission control systems, productive capacity of the facility before and after the change, and the expected completion date of the change. The Administrator may request additional relevant information subsequent to this notice. 3. A notification of the actual date of initial start-up of an affected facility postmarked within 15 days after such date. 4. If a continuous emission monitoring system is included in the construction, a notification of the date upon which the test demonstrating the system performance will commence, along with a pretest plan, postmarked no less than 30 days prior to such a date. H. Any owner or operator subject to provisions of NSPS shall maintain records of the occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected facility or any malfunction of the air pollution control equipment. [40 CFR 60.7 (b)] I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all measurements and other information required by this subpart recorded in a permanent file suitable for inspection. This file shall be retained for at least five years following the date of such measurements, maintenance, and records. [40 CFR 60.7 (f)] J. Any owner or operator subject to the provisions of NSPS shall conduct performance test(s) and furnish to AQD a written report of the results of such test(s). Test(s) shall be conducted within 60 days after achieving the maximum production rate at which the facility will be operated, but not later than 180 days after initial start-up. [40 CFR 60.8]

17 DRAFT PERMIT AIR QUALITY DIVISION STATE OF OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY 707 NORTH ROBINSON, SUITE 4100 P. O. BOX 1677 OKLAHOMA CITY, OKLAHOMA Permit No O (M-1) ETC Field Services LLC having complied with the requirements of the law, is hereby granted permission to operate the Crossfield Station located in Section 25, Township 19N, Range 4W, in Logan County, Oklahoma, subject to Standard Conditions July 12, 2012, and Specific Conditions, both attached. Permits & Engineering Group Manager Date DEQ Form # Revised 10/20/2006

18 DRAFT ETC Field Services LLC Mr. David Hennessy, Environmental Director 800 E. Sonterra Blvd San Antonio, TX Re: Operating Permit No O (M-1) Crossfield Station Facility ID No Section 25, Township 19N, Range 4W Logan County, Oklahoma Dear Mr. Hennessy: Air Quality has received the permit application for the referenced facility and completed initial review. This application has been determined to be a Tier II application. In accordance with 27A O.S and 302 and OAC 252:4-7-13(c), the enclosed draft permit is now ready for public review. The requirements for public review of the draft permit include the following steps, which you must accomplish. 1. Publish at least one legal notice (one day) in at least one newspaper of general circulation within the county where the facility is located. (Instructions enclosed) 2. Provide for public review, for a period of 30 days following the date of the newspaper announcement, a copy of the application and draft permit at a convenient location (preferentially at a public location) within the county of the facility. 3. Send AQD a signed affidavit of publication for the notice(s) from Item #1 above within 20 days of publication of the draft permit. Any additional comments or requested changes you have for the draft permit or the application should be submitted within 30 days of publication. Thank you for your cooperation in this matter. If we may be of further service, please contact Brandon Fanning at bfanning@deq.ok.gov or (405) Sincerely, Phillip Fielder, P.E. Permits and Engineering Group Manager AIR QUALITY DIVISION