MEMORANDUM May 28, Phillip Fielder, P.E., Permits and Engineering Group Manager. Kendal Stegmann, Senior Environmental Manager

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1 DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM May 28, 2009 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, P.E., Permits and Engineering Group Manager Kendal Stegmann, Senior Environmental Manager Phil Martin, P.E., Engineering Section Peer Review, Herb Neumann/Hal Wright, ROAT David Pollard, ROAT Evaluation of Permit Application No TVR2 Enogex LLC Allen Compressor Station Section 19, T3N, R9E, Coal County (Lat /Long ) Directions: From Allen, 12 miles south on SH 48, 2-1/2 miles east, north into location. From Lula, 0.5 miles north on SH 48, 2-1/2 miles east, north into location. SECTION I. INTRODUCTION Enogex LLC (applicant), submitted an application, dated May 8, 2009, and received by the Department of Environmental Quality (DEQ), Air Quality Division (AQD on May 8, 2009, for renewal of the Title V. The facility is a natural gas transmission station (SIC 4922). The facility emits more than 100 TPY each of NO X, CO, and VOC, and is subject to Title V permitting requirements. It is currently operating under Permit No TVR. The station was originally built in 1985 under Permit No C, with two compressor packages. The applicant requests that emission limits for the condensate storage tank be changed to reflect an update in emissions calculations based on the HYSYS Process Simulation method, replacing the Vasquez-Beggs method. Loading emissions will be added as an insignificant activity. Finally, the applicant requests to correct minor discrepancies in the memorandum and the permit, including a change in emissions calculations for the condensate tank. The facility remains a major source. SECTION II. FACILITY / PROCESS DESCRIPTION The facility has two 2,600-hp Ingersoll-Rand 412K VSR-1 compressor units that compress natural gas from a gas plant to pipeline pressure. Pipeline quality natural gas is the primary fuel with the engines being operated continuously.

2 PERMIT MEMORANDUM TVR2 DRAFT 2 SECTION III. EQUIPMENT Internal Combustion Engines EU Point Make/Model hp Serial # Const. Date E-C1 P-C1 Ingersoll-Rand 412K VSR-1 2,600 A210AP 1985 E-C2 P-C2 Ingersoll-Rand 412K VSR-1 2,600 A211AP 1985 Tanks EU Point Contents Barrels Gallons Tanks TK-1 Condensate ,800 TK-2 Water 100 4,200 TK-3 Ambitrol 101 4,250 TK-4 Used Oil 210 8,820 TK-5 Lube Oil 72 3,000 TK-6 Lube Oil TK-7 Used Oil 24 1,000 Fugitives EU Number Items Type of Equipment Fugitives 34 Valves 48 Flanges 12 Open Ended Lines 10 Other Stack Parameters EU Source (make/model) Height (feet) Diameter (inches) Flow (ACFM) Velocity (FPS) Temp. (deg F) E-C1 Ingersoll-Rand KVSR , E-C2 Ingersoll-Rand KVSR , SECTION IV. EMISSIONS Combustion Emissions estimates for the engines are based on continuous operation and manufacturer s emission data (NO X : 3.9 g/hp-hr, CO: 3.9 g/hp-hr, VOC: 1.74 g/hp-hr). Contingency factors were incorporated. Emissions from VOC Storage Emissions of Volatile Organic Compounds (VOCs) from the condensate/wastewater storage tank as a result of breathing and working losses were estimated to be 4,612 pounds per year using the Tanks 4.0 Program, Gasoline RVP 10, and an annual throughput of 420,000 gallons. This is an

3 PERMIT MEMORANDUM TVR2 DRAFT 3 increase from the previously estimated 1,340 pounds per of VOC emissions. The application states that there are also tanks having de minimis or negligible emissions at the facility. Flash Emissions from Storage Tank Flash gas was estimated by the applicant using the HYSYS Process Simulation method, version 3.2. Flash emissions are calculated using the calculated emission factor of 8.64 lbs-voc/bbl and a condensate throughput of 420,000 gallons per year, resulting in flash emissions of 43.2 tons per year, a decrease in VOC emissions from the 62.7 tons per year using the previous calculation based on the Vasquez-Beggs Gas/Oil Correlation. Condensate lb/hr VOC limits are not included in the permit because the nature of condensate production and thus flash emissions is not typically at a constant rate. Normal operating conditions result in slugs of condensate production and associated flash emissions occurring during short periods of time. Loading Losses Loading loss emissions from truck loading of condensate were calculated by the applicant using an annual throughput of 420,000 gallons and AP-42, Equation (1), Section (rev. 1/95), with constants and values from AP-42, Table (rev. 1/95) and Table (rev. 9/97), to calculate the emission factor as follows: L L = x (SPM)/T where: L L = emission factor, pounds per 1,000 gallons of liquid loaded S = a saturation factor, Table P = true vapor pressure of liquid, psia, Table M = molecular weight of vapors, lb/lb-mole T = temperature of bulk liquid loaded, degrees Rankine The following table illustrates the results of the calculated emissions. S (constant) P (psia) M (lb/lb-mole) T (ºR) L L (lb/1,000 gal) Throughput (GPY) Emissions (TPY) , Fugitives - Valves/Seals/Flanges/Connections Emissions of VOCs for process piping fugitives from valves, seals, flanges, and connections were estimated using EPA s 1995 Protocol for Equipment Leak Emission Estimates (EPA- 453/R ), estimates of the number of process components, and an estimated fraction of C 3+. Fugitive VOC Emissions Emission Equipment %C3+ Factor (lb/hr) TPY 34 Valves Flanges

4 PERMIT MEMORANDUM TVR2 DRAFT 4 12 Open Ended Lines Other Total Fugitive Emissions Emissions Summary Existing Permit No TVR Total Facility Potential Emissions NO X CO VOC EU lb/hr TPY lb/hr TPY lb/hr TPY E-C E-C TK-1 (1) Fugitives TOTAL (1) Includes VOC emissions from Tanks 4.0 calculation for breathing/working/flash losses. Requested Under Permit No TVR2 Total Facility Potential Emissions NO X CO VOC EU lb/hr TPY lb/hr TPY lb/hr TPY E-C E-C TK-1 (1) (2) Loading NA 1.20 Fugitives (3) TOTAL (1) - Includes breathing/working/flash losses. (2) - Tanks do not have an hourly limit in the permit due to the fluctuating contribution from working and breathing losses as well as the nature of pigging operations which results in batch production of condensate and associated flash emissions. (3) Fugitives are included in the permit as Insignificant but have no limits. Hazardous Air Pollutants The internal combustion engines have emissions of hazardous air pollutants (HAP), the most significant being formaldehyde. Uncontrolled emissions of formaldehyde were calculated by the applicant using the 4-stroke lean-burn factor of lbs/mmbtu from AP-42 (7/00), Section 3.2, with a heat input of MMBTUH. The following table lists estimated formaldehyde emissions for the compressor engines. As shown, total formaldehyde emissions are not above the 10 TPY major source threshold for HAP emissions. Based on this and details of the HYSYS flash emissions calculations, the total facility-wide HAP emissions would not exceed 25 TPY.

5 PERMIT MEMORANDUM TVR2 DRAFT 5 Formaldehyde Emissions Sources Formaldehyde lbs/hr TPY Ingersoll-Rand 412K VSR Ingersoll-Rand 412K VSR Total SECTION V. INSIGNIFICANT ACTIVITIES The insignificant activities identified and justified in the application are duplicated below. Records must be available to confirm the insignificance of the activities. Appropriate recordkeeping of activities indicated below with * is specified in the Specific Conditions. 1. * Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel which are either used exclusively for emergency power generation or for peaking power service not exceeding 500 hours/year. A 152-hp emergency-power generating reciprocating engine is located on-site and others may be used in the future. 2. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBTU/hr heat input (commercial natural gas). Two 75 MBTUH and seven 30 MBTUH natural gas fired building heaters, a water heater, and a 0.25 MMBTUH in-line gas heater are located on-site and all are rated less than 5 MMBTUH. Other space heaters, boilers, and emergency flares may be used in the future. 3. Gasoline and aircraft fuel handling facilities, equipment, and storage tanks except those subject to New Source Performance Standards and standards in 252: , 252: , 252: , and 252: No fuel handling equipment is located on-site but there may be in the future. 4. Emissions from crude oil and condensate marine and truck loading equipment operations at crude oil and natural gas production sites where the loading rate does not exceed 10,000 gallons per day averaged over a 30-day period. None on-site; chosen for future use. 5. * Emissions from storage tanks constructed with a capacity less than 39,894 gallons which store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. The ambitrol, lube oil, and waste water tanks have capacities less than 39,894 gallons and store products having a vapor pressure less than 1.5 psia. 6. Cold degreasing operations utilizing solvents that are denser than air. A parts washer is located on-site and uses solvents that are denser than air; others may be used in the future. 7. Site restoration and/or bioremediation activities of < 5 years duration. No site restoration or bioremediation is currently being performed at the site but may be conducted in the future.

6 PERMIT MEMORANDUM TVR2 DRAFT 6 8. Hydrocarbon-contaminated soil aeration pads utilized for soils excavated at the facility only. No hydrocarbon-contaminated soil aeration pads are currently located at the facility but may be used in the future. 9. Hazardous waste and hazardous materials drum staging areas. No drum staging areas are currently located at the facility but may be used in the future. 10. * Surface coating operations which do not exceed a combined total usage of more than 60 gallons/month of coatings, thinners, and clean-up solvents at any one emission unit. None identified but may be used in the future. 11. Exhaust systems for chemical, paint, and/or solvent storage rooms or cabinets, including hazardous waste satellite (accumulation) areas. Two storage cabinets are located on-site and others may be used in the future. 12. 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. None identified but may be used in the future. 13. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria pollutant. Process piping fugitives and condensate truck loading have emissions less than 5 TPY as estimated in the memorandum. SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES OAC 252:100-1 (General Provisions) Subchapter 1 includes definitions but there are no regulatory requirements. [Applicable] OAC 252:100-2 (Incorporation by Reference) [Applicable] This subchapter incorporates by reference applicable provisions of Title 40 of the Code of Federal Regulations listed in OAC 252:100, Appendix Q. These requirements are addressed in the Federal Regulations section. OAC 252:100-3 (Air Quality Standards and Increments) [Applicable] Subchapter 3 enumerates the primary and secondary ambient air quality standards and the significant deterioration increments. At this time, all of Oklahoma is in attainment of these standards. OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable] Subchapter 5 requires sources of air contaminants to register with Air Quality, file emission inventories annually, and pay annual operating fees based upon total annual emissions of regulated pollutants. Emission inventories were submitted and fees paid for previous years as required.

7 PERMIT MEMORANDUM TVR2 DRAFT 7 OAC 252:100-8 (Permits for Part 70 Sources) [Applicable] Part 5 includes the general administrative requirements for Part 70 permits. Any planned changes in the operation of the facility that result in emissions not authorized in the permit and that exceed the Insignificant Activities or Trivial Activities thresholds require prior notification to AQD and may require a permit modification. Insignificant activities refer to those individual emission units either listed in Appendix I or whose actual calendar year emissions do not exceed the following limits. 5 TPY of any one criteria pollutant 2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAP or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule Emission limitations and operational requirements necessary to assure compliance with all applicable requirements for all sources are taken from the operating permit application, or developed from the applicable requirement. OAC 252:100-9 (Excess Emissions Reporting Requirements) [Applicable] In the event of any release that results in excess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10) working days after the immediate notice is given, the owner or operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. In addition, if the owner or operator wishes to be considered for the exemption established in 252: , a Demonstration of Cause must be submitted within 30 calendar days after the occurrence has ended. OAC 252: (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: (Particulate Matter (PM)) [Applicable] Section 19-4 regulates emissions of PM from the combustion of fuel in any new and existing fuel-burning unit, with emission limits based on maximum design heat input rating. Fuelburning unit is defined in OAC 252: as any internal combustion engine or gas turbine, or other combustion device used to convert the combustion of fuel into usable energy. Thus, the compressor engines are subject to the requirements of this subchapter. Appendix C specifies PM emission limitations based on heat input rating. 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, all engines listed in the Equipment section are subject to the requirements of this subchapter. For the two compressor engines having a rating of MMBTUH, the limit is 0.49 lbs/mmbtu. AP-42 (7/00), Sec. 3.2 lists the total PM emissions from 4-stroke lean burn natural gas-fired engines to be lbs/mmbtu. The permit requires the use of natural gas for all fuel-burning equipment to ensure compliance with Subchapter 19.

8 PERMIT MEMORANDUM TVR2 DRAFT 8 OAC 252: (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: (Fugitive Dust) [Applicable] No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originated in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or to interfere with the maintenance of air quality standards. Under normal operating conditions, this facility has negligible potential to violate this requirement; therefore it is not necessary to require specific precautions to be taken. OAC 252: (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 of approximately 1,200 ppmv. The permit requires the use of gaseous fuel with sulfur content less than 343 ppmv to ensure compliance with Subchapter 31. OAC 252: (Nitrogen Oxides) [Not Applicable] This subchapter limits new gas-fired fuel-burning equipment with rated heat input greater than or equal to 50 MMBTUH to emissions of 0.20 lbs of NO x per MMBTU, three-hour average. 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: (Organic Materials) [Applicable] Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. The condensate tank is equipped with a submerged fill pipe. 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. The facility is subject to this requirement. Part 5 limits the VOC content of coating used in coating lines or operations. This facility will not normally conduct coating or painting operations except for routine maintenance of the facility and equipment, which is not an affected operation. Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize VOC emissions. Temperature and available air must be sufficient to provide essentially complete

9 PERMIT MEMORANDUM TVR2 DRAFT 9 combustion. The compressor engines are designed to provide essentially complete combustion of organic materials. Part 7 also regulates effluent water separators that receive water containing more than 200 gallons per day of VOC. There is no effluent water separator at this location. OAC 252: (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: (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 252:100-7 Permits for Minor Facilities not in source category OAC 252: Alternative Reduction not eligible 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: Feed & Grain Facility not in source category OAC 252: Nonattainment Areas not in a subject area OAC 252: Landfills not type of source category

10 PERMIT MEMORANDUM TVR2 DRAFT 10 SECTION VII. FEDERAL REGULATIONS PSD, 40 CFR Part 52 [Not Applicable] PSD does not apply. Final total emissions are less than the threshold of 250 TPY of any single regulated pollutant and the facility is not one of the 26 specific industries with an emission threshold of 100 TPY. NSPS, 40 CFR Part 60 [Not Applicable] Subparts K, Ka, Kb, VOL Storage Vessels. The 16,800-gallon condensate storage tank is less than the applicable threshold for any of these rules and is therefore not subject. Subpart GG affects stationary gas turbines. There are none at this facility. Subpart KKK sets standards for natural gas processing plants which are defined as any site engaged in the extraction of natural gas liquids from field gas, fractionation of natural gas liquids, or both. This site does not engage in this type of activity. Subpart LLL, Onshore Natural Gas Processing: SO 2 Emissions. This subpart affects sweetening units and sweetening units followed by sulfur recovery units. This facility does not have a sweetening unit. Subpart JJJJ, Stationary Spark Ignition Internal Combustion Engines (SI-ICE), 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 engines were installed in 1985, have not been modified or reconstructed, and are therefore not subject to this rule. 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, Equipment Leaks of Benzene, concerns only process streams that contain more than 10% benzene by weight. Analysis of Oklahoma natural gas indicates a maximum benzene content of less than 1%. NESHAP, 40 CFR Part 63 [Not Applicable] Subpart HH, Oil and Natural Gas Production Facilities. This subpart applies to triethylene glycol (TEG) dehydration units at area sources and affected emission points that are located at facilities that are major sources of HAP emissions 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. For the purposes of this subpart, natural gas enters the natural gas transmission and storage source category after the natural gas processing plant, when present. If no natural gas processing plant is present, natural gas enters the natural gas transmission and storage source category after the point of custody transfer. The facility is not a major source of HAP emissions and there are no triethylene glycol dehydration units. Subpart HHH, Natural Gas Transmission and Storage. This subpart affects Natural Gas Transmission and Storage Facilities. It applies to emission points that are located at facilities that are major sources of HAP emissions, as defined in this subpart, and that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final end user. The affected source is each glycol dehydration unit. The owner or operator of a facility that does not contain an affected source is not subject to the requirements of this subpart. The facility is considered a production facility and would be subject to Subpart HH if there were affected

11 PERMIT MEMORANDUM TVR2 DRAFT 11 sources. Regardless, the facility is not a major source of HAP emissions, therefore, this subpart (HHH) also would not apply. Subpart EEEE, Organic Liquids Distribution (Non-Gasoline). This subpart was proposed on April 2, 2002, and affects organic liquid distribution (OLD) operations only at major sources of HAPs with an organic liquid throughput greater than 7.29 million gallons per year (173,571 barrels/yr). Any condensate produced from the facility will be in very low volumes. The tanks at this facility are less than the threshold capacities. Therefore, there are no affected tanks or processes at this facility. Subpart ZZZZ, This subpart affects RICE that are located at sources that are major and area sources of HAP emissions. The facility is an existing area source of HAP emissions and is therefore an affected source under this subpart. However, at this time, the only requirements for area sources are those incorporated from other subparts, including NSPS JJJJ. For engines with a maximum engine power greater than or equal to 500 HP (except lean burn engines with a maximum engine power greater than or equal to 500 HP and less than 1,350 HP) that were manufactured prior to July 1, 2007, or that commenced construction after June 12, 2006, Subpart JJJJ has no requirements applicable to engines. The subject engines at this facility are lean-burn rated at 2,600-hp but were manufactured and installed prior to the affected dates. Therefore, there are no requirements for this facility under either this Subpart ZZZZ or NSPS JJJJ. 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 No active control devices, as defined by this part, are used at this facility. Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] This facility will 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: Stratospheric Ozone Protection, 40 CFR Part 82 [Not 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

12 PERMIT MEMORANDUM TVR2 DRAFT 12 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). This facility does not utilize any Class I & II substances. SECTION VIII. COMPLIANCE Inspection Since no physical changes are being made, an inspection is not needed. A full compliance evaluation was performed by Austin Hawkins of AQD on April 22, The facility is still equipped as permitted. Two electric powered compressors have been added but they have no additional emissions. A disclosure report has been submitted by the applicant for excess emissions resulting from unexpected condensate produced into the facility from line pigging operations. Tier Classification and Public Review This application has been determined to be a Tier II based on the request for renewal of a Title V operating permit. The applicant 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 real property. The applicant published the Notice of Filing a Tier II Application in The Allen Advocate, a weekly newspaper in Pontotoc County, on May 14, The notice stated that the application was available for public review at the Allen Public Library located at 214 East Broadway, Allen, Oklahoma, or at the AQD main office. Another notice will be published in a newspaper of general circulation in Pontotoc County upon availability of a Draft permit, stating the location at which the Draft will be available for public review and comment. This facility is not located within 50 miles of the border of Oklahoma and any other state. Information on all permit actions is available for review by the public in the Air Quality section of the DEQ Web page at Fee Paid Title V renewal fee of $1,000. SECTION IX. SUMMARY There are no active Air Quality compliance or enforcement issues that would affect the issuance of this permit. Issuance of the operating permit is recommended, contingent on public and EPA reviews.

13 DRAFT PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS Enogex LLC Allen Compressor Station Permit Number: TVR2 The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on May 8, 2009, and supplemental information submitted on May 7 and 8, The Evaluation Memorandum, dated May 28, 2009, explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain operating limitations or permit requirements. Continuing operations under this permit constitutes acceptance of, and consent to, the conditions contained herein: 1. Points of emissions and emissions limitations for each point: [OAC 252: (a)(1)] a. Emission limitations for Emission Units (EUs) E-C1, E-C2, and TK-1. NO X CO VOC EU lb/hr TPY lb/hr TPY lb/hr TPY E-C E-C Tank TK NA b. Condensate throughput shall not exceed 420,000 gallons per year, 12-month rolling cumulative. c. Insignificant Activities. The insignificant activities identified and justified in the application requiring records are duplicated below. Records must be available to confirm the insignificance of the activities. i. Stationary reciprocating engines burning natural gas, gasoline, aircraft fuels, or diesel fuel which are either used exclusively for emergency power generation or for peaking power service not exceeding 500 hours/year. A 152-hp emergency-power generating reciprocating engine is located on-site and others may be used in the future. ii. Emissions from storage tanks constructed with a capacity less than 39,894 gallons which store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. The ambitrol, lube oil, and waste water tanks have capacities less than 39,894 gallons and store products having a vapor pressure less than 1.5 psia. iii. Surface coating operations which do not exceed a combined total usage of more than 60 gallons/month of coatings, thinners, and clean-up solvents at any one emission unit. None identified but may be used in the future. iv. Activities that have the potential to emit no more than 5 TPY (actual) of any criteria pollutant. At this time the following activities have been identified. 1) Fugitive VOC emissions are estimated based on existing equipment items but do not have a specific limitation.

14 SPECIFIC CONDITIONS TVR2 DRAFT 2 2) Emissions from loading condensate for trucking offsite. 2. The fuel-burning equipment shall be fired with gaseous fuel having 343 ppmv or less total sulfur. Compliance can be shown by the following methods: for gaseous fuel, a current gas company bill, lab analysis, stain-tube analysis, gas contract, tariff sheet, or other approved methods. Compliance shall be demonstrated at least once annually. [OAC 252: (a)(1)], [OAC 252:100-31] 3. The permittee shall be authorized to operate this facility continuously (24 hours per day, every day of the year). [OAC 252: (a)] 4. Each engine/turbine at the facility shall have a permanent identification plate attached, which shows the make, model number, and serial number. [OAC 252: (a)(3)(b)], [OAC 252:100-43] 5. At least once per calendar quarter, the permittee shall conduct tests of NO X and CO emissions from the engine(s) and from each replacement engine/turbine when operating under representative conditions for that period. Testing is required for any engine/turbine that runs for more than 220 hours during that calendar quarter. A quarterly test may be conducted no sooner than 20 calendar days after the most recent test. Testing shall be conducted using a portable analyzer in accordance with a protocol meeting the requirements of the latest AQD Portable Analyzer Guidance document, or an equivalent method approved by Air Quality. When four consecutive quarterly tests show the engine/turbine to be in compliance with the emissions limitations shown in the permit, then the testing frequency may be reduced to semi-annual testing. A semi-annual test may be conducted no sooner than 60 calendar days nor later than 180 calendar days after the most recent test. Likewise, when the following two consecutive semi-annual tests show compliance, the testing frequency may be reduced to annual testing. An annual test may be conducted no sooner than 120 calendar days nor later than 365 calendar days after the most recent test. Upon any showing of noncompliance with emissions limitations or testing that indicates that emissions are within 10% of the emission limitations, the testing frequency shall revert to quarterly. Testing performed under a previous permit may be used to justify a reduced monitoring frequency, i.e., quarterly to semiannual or annual, and may be used in lieu of testing required by this permit for an applicable reporting period, i.e., quarter, six-month, or annual period coinciding with issuance of this permit. Reduced testing frequency does not apply to engines with catalytic converters. Any reduction in the testing frequency shall be noted in the next required semiannual monitoring and deviation report. [OAC 252: (a)(3)(a)], [OAC 252:100-43] 6. When periodic compliance testing shows engine exhaust emissions in excess of the lb/hr limits in Specific Condition Number 1, the permittee shall comply with the provisions of OAC 252:100-9 for excess emissions during start-up, shutdown, and malfunction of air pollution control equipment. Requirements of OAC 252:100-9 include immediate notification and written notification of Air Quality and demonstrations that the excess emissions meet the criteria specified in OAC 252: [OAC 252:100-9]

15 SPECIFIC CONDITIONS TVR2 DRAFT 3 7. Replacement (including temporary periods of 6 months or less for maintenance purposes), of the internal combustion engines/turbines with emissions specified in this permit with engines/turbines of lesser or equal emissions of each pollutant (in lbs/hr and TPY) are authorized under the following conditions. [OAC 252: (a)(3)(A)] a. The permittee shall notify AQD in writing at least 7 days in advance of start-up of the replacement engine(s)/turbine(s). Said notice shall identify the old engine/turbine and shall include the new engine/turbine make, model, serial number, horsepower rating, fuel usage, stack flow (ACFM), stack temperature ( F), stack height (feet), stack diameter (inches), and pollutant emission rates (g/hp-hr, lb/hr, and TPY) at maximum horsepower for the altitude/location. b. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to confirm continued compliance with NO X and CO emissions limitations. A copy of the first quarter testing shall be provided to AQD within 60 days of start-up of each replacement engine/turbine. The test report shall include the engine/turbine fuel usage, stack flow (ACFM), stack temperature ( o F), stack height (feet), stack diameter (inches), and pollutant emission rates in units of g/hp-hr at normal operating conditions with emissions calculated in units of lbs/hr and TPY at maximum rated horsepower for the altitude/location. c. Replacement equipment and emissions are limited to equipment and emissions which are not subject to NSPS, NESHAP, or PSD, except that turbines that are only subject to the requirements for recordkeeping and sulfur limits in the fuel found in NSPS Subpart GG can be replaced. [OAC 252: (f)] 8. The following records shall be maintained on-site to verify Insignificant Activities. No recordkeeping is required for those operations which qualify as Trivial Activities. [OAC 252: (a)(3)(b)] a. For stationary reciprocating engines used exclusively for emergency power generation or for peaking power service: Records of the size of engines, type of fuel used, and number of hours operated (annual). b. For fluid storage tanks with a capacity of less than 39,894 gallons and a true vapor pressure less than 1.5 psia: Records of capacity of the tanks and contents. c. For surface coating and degreasing operations: Records of the number of gallons of coatings, thinners, and solvent used (annual). d. For activities that have the potential to emit less than 5 TPY (actual) of any criteria pollutant: The type of activity and the amount of emissions from that activity (annual). 9. The permittee shall keep records of operations as listed below. These records shall be maintained on-site or at a local field office for at least five years following the dates of recording and shall be made available to regulatory personnel upon request. [OAC 252: (a)(3)(B)] a. Periodic emissions testing required by Specific Condition No. 5 for the engine(s) and each replacement engine.

16 SPECIFIC CONDITIONS TVR2 DRAFT 4 b. For the fuel(s) burned, the appropriate document(s) as described in Specific Condition No. 2, updated annually. c. Operating hours of engines/turbines that operated less than 220 hours and were not tested in a quarter. d. O&M records for any engine/turbine not tested in each 3-month period. e. Facility condensate throughput (monthly and 12-month rolling total). 10 No later than 30 days after each anniversary date of the issuance of the original Title V permit, which was December 28, 1998, the permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region 6, certification of compliance with the terms and conditions of this permit. [OAC 252: (c)(5)(A), (C), & (D)] 11. This permit supersedes all previous Air Quality permits for this facility which are now null and void.

17 PART 70 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 TVR2 Enogex LLC, having complied with the requirements of the law, is hereby granted permission to operate the Allen Compressor Station located approximately 12 miles south of Allen on SH 48 and 2-1/2 miles east, the legal description which is Section 19-3N-9E, Coal County, Oklahoma, subject to standard conditions dated December 22, 2008, and specific conditions, both attached. This permit shall expire five (5) years from the date below, except as authorized under Section VIII of the Standard Conditions. Eddie Terrill, Director Date

18 MAJOR SOURCE AIR QUALITY PERMIT STANDARD CONDITIONS (December 22, 2008) 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 ] 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 ] 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: and OAC 252: (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: (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: (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: (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: (a)(3)(C)(iv)]

19 MAJOR SOURCE STANDARD CONDITIONS December 22, 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: (a)(3)(b)(ii), OAC 252: (c)(1), and OAC 252: (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: (a)(3)(B)(i)] C. No later than 30 days after each six (6) month period, after the date of the issuance of the original Part 70 operating permit, the permittee shall submit to AQD a report of the results of any required monitoring. All instances of deviations from permit requirements since the previous report shall be clearly identified in the report. 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: (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: (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]

20 MAJOR SOURCE STANDARD CONDITIONS December 22, F. Any document 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. However, an exceedance report that must be submitted within ten days of the exceedance under Section II (Reporting Of Deviations From Permit Terms) or Section XIV (Emergencies) may be submitted without a certification, if an appropriate certification is provided within ten days thereafter, together with any corrected or supplemental information required concerning the exceedance. [OAC 252: (f), OAC 252: (a)(3)(C)(iv), OAC 252: (c)(1) and OAC 252: (c)] 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 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: (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: (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: (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 (PM 10 ). NSPS may allow reporting of only particulate matter emissions caught in the filter (obtained using Reference Method 5).

21 MAJOR SOURCE STANDARD CONDITIONS December 22, 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: (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, 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: (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: (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: (f) and OAC 252: (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: (e)(8)(B) and OAC 252: (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: (c)(6)]