MEMORANDUM June 30, Phillip Fielder, P.E., Permits and Engineering Group Manager

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1 DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM June 30, 2011 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, P.E., Permits and Engineering Group Manager Kendal Stegmann, Sr. Environmental Manager, Compliance & Enforcement Phil Martin, P.E., Engineering Section Peer Review Iftekhar Hossain, P.E., Engineering Section Evaluation of Permit Application No O Sunoco Pipeline L.P. Enid West Crude Oil Pipeline Station Latitude: N; Longitude: W Section 4,Township 22N, Range 6W, Garfield County, Oklahoma. Location: 2401 E. Willow Road, Enid, Oklahoma. SECTION I. INTRODUCTION Sunoco Pipeline L.P. (Sunoco) has requested a synthetic minor operating permit for the Enid West crude oil pipeline station (SIC 4612), which is currently operating under Part 70 operating permit # TVR2 issued on October 28, The facility was a major source for VOC emissions from the tanks. Since the issuance of the current permit, the applicant modified the third fixed roof tank (#603) to an internal floating roof tank which reduces the VOC emissions significantly. As a result, the facility-wide VOC emission has gone below the major source threshold of 100 TPY, thereby making the facility a synthetic minor source. It may be noted that there are three (3) grandfathered fixed roof storage tanks (T-601, T-602, and T-603) at the facility. These tanks have been upgraded to internal floating roof (IFR) storage tanks at different point and time. As the applicant is taking an enforceable limit of emissions to become and stay as a synthetic minor source, these tanks will lose the grandfathered status upon issuance of this permit. This permitting action will be reviewed as a significant modification of the current Part 70 operating permit; therefore, the permit will be processed under Tier II procedures. The permit has been updated to reflect the revised emissions and all current rules and regulations.

2 PERMIT MEMORANDUM O DRAFT Page 2 SECTION II. FACILITY DESCRIPTION The facility is a crude oil pipeline breakout station (SIC 4612) constructed in the 1950 s. There are three large grandfathered storage tanks, which temporarily store crude oil that enters the station from pipelines and the trucking station and exits the station via pipeline. The facility also has fugitive emissions from pumps, valves, flanges, and other components. The station pumps are driven by electric motors supplied with utility electric power. The facility has four pipeline pumps to pump a maximum of 16 million barrels per year of crude oil into the storage tanks. The facility only handles sweet crude oil, defined as having a total sulfur content of less than 0.5 wt%. The crude oil trucking station collocated with the pipeline facility has two 400-bbl crude oil storage tanks to handle 400,000 barrels of crude oil to the tank trucks. SECTION III. EQUIPMENT Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) in the following outline. EUG 1. Internal Floating Roof (IFR) Tanks EUG 1 consists of 3 active IFR tanks. EU ID# Point Capacity, Construction Modification Source ID# Gallons Date Date 5868 T-601 Internal Floating Roof A 3,176,880 Pre T-602 Internal Floating Roof B 3,176,840 Pre T-603 Internal Floating Roof C 3,176,840 Pre A. Internal floating roof with primary and secondary seals was installed in B. Internal floating roof with primary and secondary seals was installed in C. Internal floating roof with primary and secondary seals was installed in EUG 2. Fugitives EUG 2 consists of fugitive emissions from equipment components. EU ID# Point Estimated Number of Construction ID# Component Items Date F1 F1 Pump Seals 4 Pre 1972 F2 F2 Flanges/Fittings 160 Pre 1972 F3 F3 Valves 24 Pre 1972 F4 F4 Other 8 Pre 1972 EUG 3. Crude Oil Trucking Station (Collocated Facility) EUG 3 consists of two 400-bbl tanks at the collocated crude oil trucking station.

3 PERMIT MEMORANDUM O DRAFT Page 3 EU ID# Point ID# Source Capacity, Gallons Construction Date SMTP Vertical Fixed Roof 16, SMTP Vertical Fixed Roof 16, EUG 4. Total Site EUG 4 consists of the total site emissions from the pipeline breakout station and the collocated crude oil trucking station. SECTION IV. EMISSIONS Potential VOC emissions estimates for the three (3) IFR tanks were calculated using EPA TANKS 4.0 program, crude oil with a Reid vapor pressure (RVP) of 10.9 psia, and a maximum throughput of 16 million barrels per year. Normal operations are for all of the crude oil to be processed through the floating roof tanks T-601, T-602 and T-603. Fugitive VOC emissions were calculated using EPA s 1995 Protocol for Equipment Leak Emission Estimates (EPA- 453/R ). Potential emissions estimates for the 400-bbl tanks at the trucking station were calculated using EPA TANKS 4.0, a throughput of 200,000 barrels per year for each tank, and a maximum RVP of 10.9 psia. EUG 1. Internal Floating Roof (IFR) Tanks EU Point Maximum Throughput, Maximum VOC Emissions ID# ID# barrels per year RVP, psia lb/yr TPY 5868 T-601 5,333,333 7, T-602 5,333, , T-603 5,333,334 7, Total 16,000,000 * 21, * Total throughput for the whole facility. EUG 2. Fugitives Component Quantity Emission Factor, Potential Emissions, lb/hr/component TPY Pump Seals E Flanges/Fittings E Valves E Other E Total 1.983

4 PERMIT MEMORANDUM O DRAFT Page 4 EUG 3. CRUDE OIL TRUCKING STATION EU Point Maximum Throughput, RVP, psia VOC Emissions ID# ID# barrels per year lb/hr TPY SMTP , SMTP , Total TOTAL FACILITY-WIDE EMISSIONS Source VOC Emissions lb/hr TPY EUG EUG EUG Total Hazardous Air Pollutants (HAPs) Crude oil contains HAPs that are emitted from the storage tanks and from fugitive components. The HAP emissions estimates for the tanks are based on EPA TANK 4.0 program using the program s default HAP speciation for crude oil. EUG 1. IFR Tanks Pollutant CAS Number Wt% in Crude Oil Emissions lb/hr TPY N-Hexane Benzene Toluene Ethyl benzene Xylene EUG 2. Fugitives HAP emissions from fugitive components are negligible. EUG 3. Crude Oil Trucking Station Pollutant CAS Number Wt% in Crude Oil Emissions lb/hr TPY N-Hexane Benzene Toluene Ethyl benzene Xylene

5 PERMIT MEMORANDUM O DRAFT Page 5 Total Facility-wide HAP Emissions Pollutant CAS # Wt% in Emissions Crude Oil lb/hr TPY N-Hexane Benzene Toluene Xylene Ethyl benzene Total HAPs Individual HAP and total HAPs emissions are below major source levels. SECTION V. INSIGNIFICANT ACTIVITIES There were no insignificant activities identified in the application. SECTION VI. 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 of Air Contaminant Sources) 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 the past years. OAC 252:100-7 (Permits for Minor Facilities) Subchapter 7 sets forth the permit application fees and the basic substantive requirements of permits for minor facilities. This facility qualifies as a synthetic minor facility since total emissions of each criteria pollutant with controls do not exceed 100 TPY and (HAP) emissions do not exceed the 10/25 TPY threshold. OAC 252:100-9 (Excess Emission 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

6 PERMIT MEMORANDUM O DRAFT Page 6 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: (Visible Emissions and Particulates) This subchapter states that no person shall allow the discharge of any fumes, aerosol, mist, gas, smoke, vapor, particulate matter, or any combination thereof exhibiting greater than 20% opacity except for short term occurrences, which consist of not more than one six-minute (6) period in any consecutive 60 minutes, not to exceed three such periods in any consecutive 24-hour period. In no case shall the average of any six-minute period exceed 60% opacity. This facility has no fuel-burning equipment or other particulate matter emission source and, therefore, will be in compliance with this subchapter. 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 has negligible potential to violate this requirement; therefore, it is not necessary to require specific precautions to be taken. OAC 252: (Sulfur Compounds) Part 2 limits the ambient air impact of hydrogen sulfide emissions from any new or existing source to 0.2 ppm for a 24-hour average (equivalent to 280 g/m 3 ). The applicant has indicated that all crude oil handled is sweet crude oil, i.e. has total sulfur content of less than 0.5 wt%. Sweet crude oil in storage tanks does not typically emit enough H 2 S to violate the ambient air standards. OAC 252: (Volatile Organic Compounds) Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. This part applies to the two 400-bbl crude oil tanks at the collocated trucking station. These tanks are equipped with submerged fill. Part 3 requires storage tanks constructed after December 28, 1974, with a capacity greater than 40,000 gallons to be equipped with a floating roof or a vapor-recovery system capable of

7 PERMIT MEMORANDUM O DRAFT Page 7 collecting 85% or more of the uncontrolled VOC emissions. All of the tanks above 40,000- gallon capacity were constructed prior to December 28, 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 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. Therefore, this requirement is not applicable. Part 5 limits the VOC content of coating or other operations. This facility does not normally conduct coating or painting operations except for routine maintenance of the facility and equipment, which is exempt. Part 7 requires all effluent water separator openings or floating roofs to be sealed or equipped with an organic vapor recovery system. There are no separators at this site. Part 7 requires fuel-burning equipment to be operated and maintained to minimize emissions. Temperature and available air must be sufficient to provide essentially complete combustion. There is no fuel-burning equipment subject at this facility. OAC 252: (Toxic Air Contaminants (TAC)) 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 Area of Concern (AOC) has been designated anywhere in the state, 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 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.

8 PERMIT MEMORANDUM O DRAFT Page 8 The following Oklahoma Air Pollution Control Rules are not applicable to this facility: OAC 252: Alternative Emissions Reduction not requested OAC 252: Mobile Sources not in source category OAC 252: Incinerators not type of emission unit OAC 252: Cotton Gins not type of emission unit OAC 252: Grain, Feed, or Seed Operations not in source category OAC 252: Nitrogen Oxides not type of emission unit OAC 252: Carbon Monoxide not type of emission unit OAC 252: Nonattainment Areas not in area category OAC 252: Landfills not in source category SECTION VII. FEDERAL REGULATIONS PSD, 40 CFR Part 52 [Not Applicable] Final facility-wide 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 listed stationary sources defined as a major source at an emission level of 100 TPY. The proposed project reduces emissions to minor source levels. NSPS, 40 CFR Part 60 [Not Applicable] Subpart K, Ka, Kb, VOL Storage Vessels. All of the tanks, except for the two 400-bbl tanks, were constructed prior to the applicable dates of any of the subparts. Internal floating roofs (IFR) were installed in Tank T-601 in 1998, in Tank T-602 in 2006, and in Tank T-603 in These changes are not modifications as the term is defined in NSPS, 40 CFR Part 60, Subpart A. The applicant stated that the fixed capital cost of the installation of IFR to T-603 in this project cost less than 50% of the fixed capital cost that would be required to construct a comparable entirely new IFR tank. Therefore, the changes are not reconstruction as the term is defined in NSPS, 40 CFR Part 60, Subpart A. The 400-bbl tanks are below the threshold of 19,813 gallons for Subpart Kb applicability. As compliance assurance measure the applicant requests that the permit requires the compliance provisions of NSPS Subpart Kb for all IFR tanks. The tanks are not legally subject to NSPS Subpart Kb, because modifications or reconstruction as defined in NSPS, 40 CFR Part 60, has not occurred as a result of the changes made to these tanks. However, the VOC emissions of the IFR tanks are calculated using EPA s TANKS 4.0 program which is based on the NSPS Subpart Kb requirements to a great extent. It is therefore quite logical to use NSPS Subpart Kb requirements to assure compliance with the enforceable limits for VOC of the IFR tanks. NESHAP, 40 CFR Part 61 [Not Applicable] There are no emissions of any of the regulated pollutants: arsenic, asbestos, benzene, beryllium, coke oven emissions, mercury, radionuclides, or vinyl chloride except for trace amounts of benzene. Subpart J applies only to process streams that contain more than 10% benzene by weight. All process streams at this facility are below this threshold. No other pollutants subject to regulation under 40 CFR 61 are emitted.

9 PERMIT MEMORANDUM O DRAFT Page 9 NESHAP, 40 CFR Part 63 [Not Applicable] Subpart R, Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations). This subpart only applies to gasoline distribution facilities that are a major source of HAPs. This facility is not a gasoline distribution facility. Subpart EEEE, Organic Liquids Distribution (Non Gasoline). This subpart affects facilities that are defined as the collection of activities and equipment used to distribute organic liquids into, out of, or within a facility that is a major source of HAP. Facilities that store and distribute organic liquids either as the entire facility, or that are collocated with other operations at the same site, are affected facilities. Organic liquids are defined as crude oil or any liquid that contains 5% or more of HAP by weight. Affected facilities that are subject to another NESHAP standard are not an affected facility for Subpart EEEE. This facility has taken a federally enforceable limit on the facility s total pump capacity that will insure that the facility is not a major source of HAPs. Compliance Assurance Monitoring (CAM), 40 CFR Part 64 [Not Applicable] This part applies to any pollutant-specific emission unit at a major source that is required to obtain an operating permit, for any application for an initial operating permit submitted after April 18, 1998, that addresses large emissions units, or any application that addresses large emissions units as a significant modification to an operating permit, or for any application for renewal of an operating permit, if it meets all of the following criteria. It is subject to an emission limit or standard for an applicable regulated air pollutant It uses a control device to achieve compliance with the applicable emission limit or standard It has potential emissions, prior to the control device, of the applicable regulated air pollutant of 100 TPY of a criteria pollutant, 10 TPY of an individual HAP, or 25 TPY of total HAPs The facility is now a synthetic minor facility. CAM only applies to Part 70 permits and is no longer applicable. 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. SECTION VIII. COMPLIANCE Inspection A full compliance inspection was conducted at Enid West crude oil pipeline breakout station of Sunoco Pipeline Company, L.P. on March 25, Holly Taber and Garylee Walz, Environmental Program Specialists, Air Quality Division, conducted the inspection. Jeff Myers, Environmental Specialist for Sunoco Pipeline, L.P. represented the facility. The facility was constructed and was operating as described in the permit application. It was also confirmed that the crude oil trucking storage tanks (SMTP) are operated with submerged fill pipes. The

10 PERMIT MEMORANDUM O DRAFT Page 10 required records are up-to-date and maintained at the District Office located in Drumright, Oklahoma. Identification plates are on the tanks. Tier Classification and Public Review This application has been determined to be a Tier II based on being a request for a significant modification of an operating permit for a facility that is currently permitted as a major source of emissions. 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. The applicant will publish the DEQ Notice of Filing a Tier II Application and DEQ Notice of Tier II Draft Permit in a local newspaper where the facility is located. The notices will state that a copy of the notice of filing of the application and the draft permit will be available for public review at the local public library. The notices also will state that the application and the draft permit will be available for public review at the AQD main office in Oklahoma City and on the DEQ web page at This facility is located within 50 miles of the Oklahoma-Kansas border. The state of Kansas will be notified of the draft permit. The permit will then be sent as proposed to EPA Region VI for a 45-day review period. Fees Paid A significant modification to a Part 70 operating permit application fee of $1,000. SECTION IX. SUMMARY The facility was constructed and is operating as described in the permit application submitted by the applicant. Ambient air quality standards are not threatened at this site. There are no active compliance or enforcement Air Quality issues concerning this facility. Issuance of the permit is recommended, contingent on public and the EPA review.

11 PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS DRAFT Sunoco Pipeline L.P. Enid West Crude Oil Pipeline Station Permit Number O The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on June 1, The Evaluation Memorandum dated June 30, 2011, 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 limitations for each point: [OAC 252: (a)(1)] EUG 1. Internal Floating Roof (IFR) Tanks These units have the following specific limitations. EU ID# Point ID# Source Capacity, Gallons 5868 T-601 Internal Floating Roof 3,176, T-602 Internal Floating Roof 3,176, T-603 Internal Floating Roof 3,176,840 (a) (b) The maximum throughput of crude oil at the pipeline breakout station shall not exceed 16 million barrels in any 12-month rolling period. The tanks are not subject to NSPS, 40 CFR Part 60, Subpart Kb; however, the permittee shall comply with the appropriate requirements of NSPS Subpart Kb for internal floating roof (IFR) tanks. EUG 2. Fugitives Fugitive VOC emissions from pumps, valves, flanges, etc., are estimated based on existing equipment items, but do not have a specific limitation. EU ID# Point ID# Component Estimated No. of Items F1 F1 Pump Seals 4 F2 F2 Flanges/Fittings 160 F3 F3 Valves 24 F4 F4 Other 8 EUG 3. Crude Oil Trucking Station These units have the following emission limitations:

12 SPECIFIC CONDITIONS O DRAFT Page 2 EU ID# Point ID# Throughput (bbl/yr)* VOC (TPY)* SMTP ,000 SMTP The maximum throughput of crude oil at the trucking station shall not exceed 400,000 barrels in any 12-month rolling period. 2. The permittee shall be authorized to operate this facility continuously (24 hours per day, every day of the year). [OAC 252: (a)] 3. Each tank shall have a permanent means of identification that distinguishes it from other equipment. [OAC 252: (e)(3)(b)] 4. The permittee shall maintain records of operations as listed below. These records shall be retained on-site or at a local field office for at least five years from the date of recording, inspection, testing or repair, and shall be made available to regulatory personnel upon request. [OAC 252: (a)(3)(b)] (a) (b) (c) (d) (e) Type of liquid material, maximum Reid vapor pressure, and annual throughput through each storage tank, if other than crude oil. Annual calculations of VOC, total HAP, and individual HAP emissions for EUG 1 and EUG 3. Throughput for the crude oil storage tanks (monthly and rolling 12-month totals). Throughput for the crude trucking tanks (monthly and rolling 12-month totals). Records required by NSPS Subpart Kb for compliance assurance. 5. No later than 30 days after the issuance of this synthetic minor operating permit, 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 the Part 70 operating permit for the time period, which has not been covered by any previous certification of compliance and the issuance date of this permit. 6. This permit supercedes all previous air quality permits for this facility, and all previous Air Quality permits are now null and void.

13 PERMIT AIR QUALITY DIVISION STATE OF OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY 707 N. ROBINSON, SUITE 4100 P.O. BOX 1677 OKLAHOMA CITY, OKLAHOMA Permit No O Sunoco Pipeline L.P., having complied with the requirements of the law, is hereby granted permission to operate the Enid West Station, Section 4, T22N, R6W, Garfield County, Oklahoma, subject to standard conditions dated April 8, 2010, and specific conditions, both attached. Division Director, Air Quality Division Issuance Date DEQ Form # Revised 10/20/06

14 Sunoco Pipeline L.P. Attn: Mr. Jeff Myers Highway 19 Maysville, OK SUBJECT: Permit Application No O Facility: Enid West Crude Oil Pipeline Station Section 4,Township 22N, Range 6W, Garfield County, Oklahoma. Dear Mr. Myers: Air Quality Division has completed the initial review of your operating permit application referenced above. This application has been determined to be a Tier II. In accordance with 27A O.S and OAC 252: the enclosed draft permit is now ready for public review. The requirements for public review include the following steps which you must accomplish: 1. Publish at least one legal notice (one day) 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 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 or the permit writer at (405) Sincerely, Phillip Fielder, P.E. Permits & Engineering Group Manager AIR QUALITY DIVISION Enclosures

15 KDHE, BAR Title V Permitting Group Forbes Field, Building 283 Topeka, KS SUBJECT: Permit Application No O Facility: Enid West Crude Oil Pipeline Station Section 4,Township 22N, Range 6W, Garfield County, Oklahoma. Permit Writer: Iftekhar Hossain Dear Sir / Madam: The owner/operator of the above-referenced facility has applied to convert the referenced facility s Title V operating permit under 40 CFR Part 70 to a synthetic minor source permit. Air Quality Division has completed the initial review of the application and prepared a draft permit for public review. Since this facility is within 50 miles of the Oklahoma - Kansas border, a copy of the proposed permit will be provided to you upon request. Information on all permit actions and a copy of this draft permit are available for review by the public in the Air Quality Section of DEQ Web Page: Thank you for your cooperation. If you have any questions, please refer to the permit number above and contact me or the permit writer at (405) Sincerely, Phillip Fielder, P.E. Permits and Engineering Group Manager AIR QUALITY DIVISION

16 MINOR SOURCE PERMIT TO OPERATE / CONSTRUCT AIR POLLUTION CONTROL FACILITY STANDARD CONDITIONS (April 8, 2010) 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: (f)] C. The recipient of a construction permit shall apply for a permit to operate (or modified operating permit) within 60 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 10 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

17 MINOR SOURCE STANDARD CONDTIONS April 8, 2010 Page 2 adjacent 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]

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