DRAFT. MEMORANDUM April 15, Phillip Fielder, P.E., Permits and Engineering Group Manager

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1 DRAFT OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION MEMORANDUM April 15, 2013 TO: THROUGH: THROUGH: THROUGH: FROM: SUBJECT: Phillip Fielder, P.E., Permits and Engineering Group Manager Kendal Stegmann, Sr. Environmental Mgr., Compliance & Enforcement Phil Martin, P.E., Existing Source Permits Section Manager Peer Review, Anthony Maxwell, DEQ Regional Office at Tulsa Herb Neumann, DEQ Regional Office at Tulsa Evaluation of Permit Application No O Bizjet International 3515 N. Sheridan (various tracts in Sec 23, T20N, R13E) (Driveway at N, W) Tulsa, Tulsa County I. INTRODUCTION The applicant operates an aerospace maintenance and repair facility (SIC 4581) at the Tulsa International Airport under Part 70 Operating Permit No TVR, issued June 24, Facility activities are located on three contiguous tracts comprising approximately 10 acres in the NW/4 of Section 23 and on two contiguous tracts comprising approximately 10 acres in the NE/4 and SE/4 of Section 23. The two ten acre pieces of land do not share a common boundary. Hangars 32, 33, 34, and 37 are located in the NW/4 area, which is where the facility office is found. Hangars 29 and 30 are located in the E/2 area. The facility services and repairs turbinepowered business aircraft. The work of this facility is based entirely on customer demand, so no normal process rates or production rates can be assigned to activities. The facility was originally permitted under TV, issued February 3, The facility had been the subject of a Consent Order, under which the facility agreed to Part 70 permitting, because it had emissions of at least one HAP in sufficient quantity to make it a major source subject to Aerospace MACT GG. Applicant now proposes to become a synthetic minor source, requiring a significant modification of its Part 70 permit. The reasons for this request are found in the discussions of 40 CFR 63 Subpart GG and of OAC 252: II. PROCESS DESCRIPTION The facility refurbishes, repairs, depaints, and coats aircraft and aircraft assemblies. It also tests jet engines. Spray painting occurs in various hangars. One of the buildings identified as a hangar contains offices. While the facility does not operate continuously, the permit memorandum for TVR was structured to allow for 8,760 hours of operation per year.

2 PERMIT MEMORANDUM O DRAFT 2 III. EQUIPMENT There have been no changes at the facility since issuance of the current operating permit, so the EUG descriptions in the memorandum associated with TVR remain valid. Two applicability determinations issued in the interim addressed questions of co-location and major source status. The EUGs are listed as shown in the existing Part 70 operating permit. EUG 1 Facility-Wide This emission unit group is facility-wide. It includes all emission units and is established to discuss the applicability of those rules or compliance demonstrations that may affect all sources within the facility. No alternative operating scenarios are described. EUG 2 Paint Booths TABLE 1 Point ID Booth Location Booth Dimensions Stack Diam. Height above grade Const. Date* P 1 Hangar deep 6 wide 4 high P 2a Hangar deep 10 wide 8 high P 2b Hangar deep 10 wide 8 high P 3 Hangar deep 140 wide 54 high (5) 1998 P 4 Hangar 32 6 deep 7 wide 7 high P 5 Hangar deep 140 wide 54 high (5) 1998 *The construction dates shown reflect the installation dates of the filter banks currently in place. The hangars were constructed before EUG 3 Cleaning These emissions are fugitive in nature and are identified as Point ID P 7 for hand-wipe cleaning and Point ID P 8 for spray gun cleaning. They occur when and where needed. EUG 5 Engine Test Cells TABLE 2 Point ID Name Stack Dim. & Height Const. Date P 9 Jet Engine Test Cell (2) 1988 P 10 Jet Engine Test Cell (2) 2/04 EUG 6 Depainting Operations The facility uses both chemical and abrasive depainting methods. Chemical operations commenced in 1996, are defined as Point ID P 6, and occur in Hangar 34. A blast booth is located in Hangar 32, and dates from The booth is filtered and the exhaust is internal to the building, so the source is Trivial. There is a possibility that this booth will be reworked and the exhaust may vent to atmosphere in the future. Emissions have been so small that the booth did not have emissions exceeding the Insignificant threshold under Subchapter 8 and will probably be de minimis under Subchapter 7.

3 PERMIT MEMORANDUM O DRAFT 3 EUG 7 Waste Storage and Handling This EUG is established to cover all activities affected by the waste handling provisions of NESHAP Subpart GG; specifically 40 CFR The list of insignificant activities addressed in the Part 70 permit memorandum contained items that were trivial under Subchapter 8 and that will negligible or de minimis under Subchapter 7. IV. EMISSION CALCULATIONS EUG 1 Facility-Wide There are no emissions directly associated with this EUG. EUG 2 Paint Booths The facility uses numerous coating products, most of which are categorized as specialty coatings under OAC 252: , standards for which reference the Aerospace MACT (Subpart GG). The most recent data in the application for TVR on use of these various coatings suggests a weighted average VOC content of 5.5 pounds per gallon (ppg). Coupled with the 4,260 gallons per year (gpy) maximum use of non-exempt coatings proposed by the facility, VOC emissions are calculated to be 11.7 TPY. Certain topcoats exceed the MACT standard, but may be used under an exemption stating that no more than 50 gpy of any individual coating or 200 gpy of all such coatings may be used. Assuming a worst-case VOC content of 5 ppg, these coatings could have annual VOC emissions of 0.5 TPY. Assuming a conservatively high value of 10 ppg of solids in all 4,460 gallons reviewed for VOC, a conservatively low transfer efficiency of 40%, and a conservatively low filter efficiency of 98% yields 4,460 gpy 10 ppg (1 40%) (1 98%) = 535 lbs/yr or 0.27 TPY of particulate emissions. EUG 3 Cleaning Hand-wipe cleaning uses material identified as DC-1, which is mostly acetone. Based on actual quantities used in the past, the facility estimated 1,000 gallons per year (gpy) as a reasonable future expectation. The solvent weighs 7.59 pounds per gallon (ppg) and its MSDS states that it is 100% volatile. Noting that both EPA and DEQ have delisted acetone as a VOC, the VOC content should be recognized at a maximum level of 3.95 ppg. Coupled with the 1,000 gpy use proposed above, VOC emissions are calculated to be 1.97 TPY. The current Part 70 permit memorandum shows that the facility used only 13 gallons of Naked Gun Cleaner during the preceding year (2008). Assuming a conservatively high use of 30 gallons per year yields 210 pounds or 0.11 TPY of VOC emissions. This estimate relies on the conservatively high assumption that all VOC is emitted, which is highly unlikely under proper operation of the cleaners. EUG 5 Engine Test Cells The facility used 28,573 gallons of fuel in the small engine test cell (#1) during the period from September 2003 to August 2004, with a maximum of 3,524 gallons during October. It also used 8,659 gallons of fuel in the large engine test cell (#2) during the period from April to August

4 PERMIT MEMORANDUM O DRAFT , with a maximum of 3,960 gallons during April. Taking the highest months as the basis for a worst-case analysis yields 7,484 gals/month, or 89,808 gpy. Pratt & Whitney has developed emission factors for various engines. The following table uses the highest of all possible values for each engine, including fuel flow rate ( kg/sec) to get the lb/hr values; assumes that particulate emissions are negligible; and further assumes that sulfur is present in Jet A in concentrations of approximately 0.07% W. The TPY values assume a maximum fuel usage of 90,000± gallons per year. Jet A has a density of 6.74 ppg. TABLE 3 Pollutant Emission factor Emissions Lb/hr TPY NO X g/kg CO 2.65 g/kg NMHC 0.09 g/kg SO 2 Full conversion EUG 6 Depainting Operations The facility anticipated a maximum consumption of 3,000 gpy of paint remover PR This product contains 3.3 ppg of VOC, so total annual emission of VOC is 4.95 TPY. Although the entire product is not considered to be VOC, none of it is solid, so PM emissions are not considered. EUG 7 Waste Storage and Handling There are no emissions directly associated with this EUG. Other Activities Combustion emissions from the eight heaters in Hangars 33 and 34 are calculated as a single entry, with a combined heat input of 47.6 MMBTUH. The following table uses emission factors from Tables & 2 of AP-42 (3/98), assuming 1,020 BTU/CF. TABLE 4 Factor Emissions Pollutant (Lb/MMCF) Lb/hr TPY PM SO VOC NO X CO Hazardous Air Pollutants (HAP) The analysis used in the original Part 70 operating permit application was a supercoat approach, in which every coating product is assumed to have a concentration of each HAP in the same ratio as present in the worst-case coating. Despite this approach, no HAP exceeded 10 TPY of emissions and aggregate HAP emissions did not exceed 25 TPY. In fact, following the delisting of MEK, the new HAP total is approximately 19 TPY. Additionally, the earlier memorandum pointed out that the detailed constituent analysis implied emissions of VOC nearly five times the amount expected from simply performing a mass balance on VOC content of each gallon of

5 PERMIT MEMORANDUM O DRAFT 5 coating used. It is not unreasonable to suggest that these HAP estimates are similarly overinflated. V. FEDERAL REGULATIONS PSD, 40 CFR Part 52 [Not Applicable] PSD does not apply. Final facility-wide total emissions are less than the threshold of 250 TPY of any single regulated pollutant and the facility is not one of the listed stationary sources with a threshold of 100 TPY. NSPS, 40 CFR Part 60 There are no subparts affecting the operation of this facility. [Not Applicable] NESHAP, 40 CFR Part 61 [Not Applicable] There are no emissions of any of the regulated pollutants: asbestos, benzene, beryllium, coke oven emissions, inorganic arsenic, mercury, radionuclides, and vinyl chloride. NESHAP, 40 CFR Part 63 [Not Applicable] Subpart GG (Aerospace Manufacturing and Rework Facilities) applies to facilities engaged, either in whole or in part, in the manufacture or rework of commercial, civil, or military aerospace vehicles or components and that are major sources as defined in Although this facility is not currently a major source of HAP as that term is defined in 40 CFR 63.2, and has not been such for nearly a decade, it has been subject to this MACT as the result of a Consent Order. MEK, the solvent that caused applicant to be identified as a major source under GG, has been delisted. Because they are now well below both the 10 TPY individual HAP threshold and the 25 TPY aggregate HAP threshold, they are no longer a major source and their original designation as subject to the MACT is void. EPA Region 1 has supported this argument in its Determination M040001, dated July 24, Although the Subpart in question was not GG, the EPA made the argument that if a facility made a commitment to stop using a solvent that had made the facility subject to the MACT, then it would no longer be subject to the MACT. In the current instance, by delisting MEK as a HAP, EPA has implicitly made the necessary commitment for Bizjet. The referenced Determination separates out the issues of MACT applicability and major source status, because the MACT involved in that issue applies to all sources, regardless of Part 70 applicability. Further discussion on this topic may be found in the Subchapter 8 discussion in Section VI following. Subpart PPPPP (Engine Test Cells/Stands) applies to new and existing engine test cells and stands at facilities that are major sources as defined in As noted in the discussion of MACT GG, this facility does not meet the definition of major source. A discussion of PTE is necessary, because this issue has not been fully addressed. The original Part 70 permit for this facility, as well as the only modification to that permit, set a federally enforceable limit of 30 TPY for all VOC from MACT GG activities. An inconsequential amount of VOC is added from test cell operations, so volatile HAP PTE may be analyzed using the federally enforceable limit as a bound on HAP emissions. The analysis shown near the end of Section IV above indicates that no single HAP exceeded 10 TPY and that the aggregate of all HAPs did not exceed 25 TPY. It further pointed out that this was a worst-case analysis, in that each product in a given category (topcoat, thinner, etc.) contained the highest concentration of each HAP as found in any of the products in that category.

6 PERMIT MEMORANDUM O DRAFT 6 This clearly limits PTE to less that the thresholds necessary for the facility to be considered a major source for the purposes for MACT PPPPP. Therefore, this Subpart does not apply. Subpart HHHHHH (Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources) affects three types of facilities; paint stripping operations that involve the use of chemical strippers containing methylene chloride, autobody refinishing operations that encompass motor vehicle and mobile equipment spray-applied surface coating operations, and spray application of coatings containing target HAP to any part or product made of metal or plastic that is not a motor vehicle or mobile equipment. Applicant has activities that satisfy the third category commonly called miscellaneous surface coating. Each owner or operator of an affected miscellaneous surface coating source must ensure and certify that all new and existing personnel, including contract personnel, who spray apply surface coatings are trained in the proper application of surface coatings as required by paragraph (e)(1). Initial notification and annual updates of the notification are required. CAM, 40 CFR Part 64 [Not Applicable] This part may apply to any pollutant-specific emission unit at a major source. Because this memorandum indicates that the source is no longer to be considered major, Part 64 does not apply. Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable] This facility does not process or store more than the threshold quantity of any regulated substance (Section 112r of the Clean Air Act 1990 Amendments). More information on this federal program is available on the web page: Stratospheric Ozone Protection, 40 CFR Part 82 [Not Applicable] These standards apply to Class I & II substances. This facility does not utilize any Class I & II substances. 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 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) 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) 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

7 PERMIT MEMORANDUM O DRAFT 7 regulated pollutants. Emission inventories were submitted and fees paid for previous years as required. 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. Since criteria pollutant emissions are less than 100 TPY for each pollutant, and emissions of Hazardous Air Pollutants (HAP) will not exceed 10 TPY for any one HAP or 25 TPY for any aggregate of HAP, the facility is defined as a minor source. As such, BACT is not required. Upon issuance of this significant modification, Bizjet will be subject to Subchapter 7. OAC 252:100-8 (Permits for Part 70 Sources) [Not 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 HAPs or 20% of any threshold less than 10 TPY for a HAP that the EPA may establish by rule Emission limitations and operational requirements necessary to assure compliance with all applicable requirements for all sources are taken from the Part 70 renewal operating permit, from information in the application for modification, or are developed from the applicable requirement. Because the source is no longer major and because EPA has determined that it is no longer subject to 40 CFR 63 Subpart GG, the facility is no longer subject to Subchapter 8. Upon issuance of this significant modification, the facility will be subject to Subchapter 7, instead of to Subchapter 8. 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.

8 PERMIT MEMORANDUM O DRAFT 8 OAC 252: (Particulate Matter (PM)) Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with emission limits based on maximum design heat input rating. Fuel-burning equipment 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. Appendix C specifies a PM emission limitation of 0.60 lbs/mmbtu for all equipment with a heat input rating of 10 MMBTUH or less. The 5.95 MMBTUH heaters in Hangars 33 and 34, as well as any space heaters at the facility, are rated at less than this threshold, so all are subject to the 0.6 lbs/mmbtu standard. AP-42 (7/98) Table lists natural gas TPM emissions to be 7.6 lbs/million scf or about lbs/mmbtu, which is in 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. Based on experience with this facility, the potential for violating the standards is negligible. 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 Oxides) Part 5 The new equipment standard for emissions of oxides of sulfur measured as sulfur dioxide from gas-fired fuel-burning equipment is 0.2 lbs/mmbtu heat input and the standard for liquidfired equipment is 0.8 lbs/mmbtu, each as a maximum three-hour average. Table of AP-42 (3/98) lists natural gas SO 2 emissions to be 0.6 lbs/mmft 3 or about lbs/mmbtu, which is in compliance. The Pratt-Whitney table value for Jet-A fuel used in engine testing equates to approximately 0.15 lbs/mmbtu, which is in compliance. 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 0.2 lbs of NO X per MMBTU, three-hour average. The limit for liquid-fired equipment is 0.3 lbs/mmbtu. There are no equipment items that exceed the 50 MMBTUH threshold. Note that the maximum firing rate for the various engines ( kg/s) is roughly equivalent to 15.3 MMBTUH. OAC 252: (Carbon Monoxide) [Not Applicable] This subchapter affects gray iron cupolas, blast furnaces, basic oxygen furnaces, petroleum catalytic cracking units, and petroleum catalytic reforming units. There are no affected sources.

9 PERMIT MEMORANDUM O DRAFT 9 OAC 252: (Volatile Organic Compounds) Part 5 limits the VOC content of coatings used in coating lines and operations. Coating of parts and products is considered under Section Coating products not subject to the standards of Subchapter 39 are subject to these standards if emissions of VOC exceed 100 pounds per day. Sufficient records will be maintained to show that the coatings used in the new interiors booth satisfy the requirements of or that emissions are so low as to provide exemption from Note that requires that use of clean-up solvents be included in the calculations. Compliance with the requirements of Section (Aerospace Industries Coatings) for coatings subject to those rules and regulations will be considered demonstrations of compliance with this section. 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 combustion. All insignificant combustion equipment is designed to provide essentially complete combustion of organic materials. OAC 252: (VOC in Nonattainment and Former Nonattainment Areas) This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of organic materials from new and existing facilities in Tulsa County. Section 47 covers requirements specifically applicable to aerospace vehicle and component coating operations at aerospace manufacturing, rework, or repair facilities located in Tulsa County that have the potential to emit more than 10 TPY of VOC from coating operations. Coating operations include associated cleaning operations and surface preparation. This section is modeled on, and closely tracks, the Aerospace MACT found in federal NESHAP, 40 CFR 63 Subpart GG. With the exception of specialty coatings, as that term is defined in 39-47(c)(5), standards and requirements for VOC content, application equipment, control equipment, housekeeping measures, solvent cleaning operations, and general standards reference appropriate sections of GG. The VOC content of specialty coatings must now meet the specifications listed in OAC 252:100 Appendix N. These standards shall be met by as-applied coatings, but do not apply to touch-up, aerosol, or Department of Defense classified coatings. Compliance with the specialty coating VOC limits may be achieved through the use of control equipment, provided that the equipment has a combined capture and control efficiency of 81% or greater by weight. If control equipment is used to comply with the Appendix N standards, a monitoring plan describing the parameter and its range shall be submitted, and the equipment must be installed, calibrated, operated and maintained according to the manufacturer s specifications. Monitoring records of the parameter(s) shall be maintained. Spray gun cleaners used for specialty coatings shall be visually inspected for leaks and all other potential sources of leaks at least once per month, while the cleaner is in operation. The facility shall maintain a current list of all Appendix N coatings in use, showing category, as-applied VOC content, and 12-month usage. 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.

10 PERMIT MEMORANDUM O DRAFT 10 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. VII. COMPLIANCE Tier Classification And Public Review This application has been classified as Tier II based on the request for a significant modification to a Title V Operating permit for an existing major source that will result in a minor source operating permit. Public notice of filing of this application was published in The Tulsa World on February 16, The notice stated that material was available for review at the Bizjet facility, 3515 N. Sheridan Road, Tulsa, at the AQD Office in Oklahoma City, and at the DEQ website: A notice will be published in a paper of general circulation in Tulsa County when a draft of this permit is available for public review. This facility is not located within 50 miles of the border with a contiguous state. 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. Fees Fee of $6,000 paid for significant modification of a Title V operating permit resulting in a minor source permit. VIII. SUMMARY This facility was constructed as described in the application. There are no active Air Quality compliance or enforcement issues concerning this facility. Issuance of the permit is recommended, pending public comment and EPA review.

11 PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS Bizjet International General Aviation Rework Facility Permit No O The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on January 11, The Evaluation Memorandum dated April 15, 2013, 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. EUG-1 Facility-Wide There are no emissions directly associated with this EUG. EUG 2 Paint Booths Point ID Booth Location Booth Dimensions Const. Date P 1 Hangar deep 6 wide 4 high 1993 P 2a Hangar deep 10 wide 8 high 1993 P 2b Hangar deep 10 wide 8 high 1993 P 3 Hangar deep 140 wide 54 high 1998 P 4 Hangar 32 6 deep 7 wide 7 high 1990 P 5 Hangar deep 140 wide 54 high 1998 Coating emissions are authorized as follows. Compliance with these limits is demonstrated through product use, not to exceed 4,460 gallons of coating per year or 750 gallons per month. The 4,460 gallon total includes 200 gallons per year of coatings that do not comply with the standards of OAC 252: The total also includes all components of each painting system, as well as any thinners added by the facility. Pollutant Lb/hr TPY VOC PM EUG 3 Cleaning Cleaning operations occur throughout the facility and emissions are not confined to identifiable stacks. These emissions are fugitive in nature and are identified as Point ID P 7 for hand-wipe cleaning and Point ID P 8 for spray gun cleaning. Authorized emissions are 1.97 TPY of VOC for hand-wipe cleaning and 0.11 TPY of VOC for gun cleaning operations.

12 SPECIFIC CONDITIONS O DRAFT 2 EUG 5 Engine Test Cells Point ID Name Const. Date P 9 Jet Engine Test Cell P 10 Jet Engine Test Cell 2 2/04 Authorized emissions are shown in the following table. Compliance with these limits shall be demonstrated by calculating emissions for each engine tested, through use of engine and fuel parameters, in combination with Pratt & Whitney emission factors for each engine. Pollutant Emissions Lb/hr TPY NO X CO NMHC SO EUG 6 Depainting Operations The chemical operation is defined as Point ID P 6 and occurs in Hangar 34. Compliance with the emission limit of 4.95 TPY of VOC shall be demonstrated by recording gallons used and VOC content of each gallon. EUG 7 Waste Storage and Handling This EUG was established to cover all activities that had been affected by the waste handling provisions of NESHAP Subpart GG; specifically 40 CFR There are no emissions directly connected to this EUG. Most of the previously identified Insignificant Activities are negligible under Subchapter 7, and are not specifically named. Activities formerly classified as insignificant in Part 70 permit TVR shall continue in compliance with OAC 252:100 Regulations and shall continue to be identified on required emission inventory reporting. 2. The permittee shall be authorized to operate this facility continuously (24 hours per day, every day of the year). 3. Emissions of HAP shall not equal or exceed 10 TPY for any individual HAP or 25 TPY for any aggregate of HAPs. 4. Organic HAP emissions from primers shall be limited to an organic HAP content level of 4.5 pounds per gallon (ppg) as applied, less water. VOC emissions from primers shall be limited to a VOC content level of 4.5 ppg (less water and exempt solvents) as applied. Organic HAP emissions from topcoats and self-priming topcoats shall be limited to an organic HAP content level of 4.5 ppg as applied, less water. VOC emissions from topcoats and self-priming topcoats shall be limited to a VOC content level of 4.5 ppg (less water and exempt solvents) as applied. This standard does not apply to those coatings that possess additional performance criteria beyond

13 SPECIFIC CONDITIONS O DRAFT 3 those of primers or topcoats. Such coatings are identified as specialty coatings, and are addressed in Specific Condition No. 5 below. 5. The VOC content of specialty coatings, as specialty coating is defined in OAC 252: (c) shall not exceed the levels specified in OAC 252:100 Appendix N (as applied). [OAC 252: (d)(1)(A)] 6. The requirements for primers, topcoats, specialty coatings, and chemical milling maskants described in OAC 252: (d) do not apply to the use of such coatings for which the annual total of each separate formulation used at the facility does not exceed 50 gallons and the combined annual total of all such coatings does not exceed 200 gallons. Primers, topcoats, and specialty coatings exempted under 39-47(a) are not included in the 50- and 200-gallon limits. 7. The dry particulate filter systems on all booths shall be maintained in good working order. The differential pressure gauge across the filter banks shall be continuously monitored and the pressure drop ( P) read and recorded at least once per shift. If P exceeds or falls below the filter manufacturer s recommended limit(s) shown in the following plan, the booth shall be immediately shut down and corrective action taken. The following plan establishes the limits to be used for each booth. a) Upon installation of a new primary filter or new filter system, an initial measurement of P across the new (clean) filter system shall be recorded. This P will represent the low end of the acceptable pressure drop for operation of the filter system until the filter is replaced. b) An alarm, or point at which the facility should contemplate replacement, is determined by multiplying the initial P by two. Exceeding this value is not an exceedance or violation of any rule or regulation. c) The upper end of the acceptable range is determined by calculating twice the initial P plus 0.2 inches w.c., with such total value not to exceed 1 inch w.c. d) Replacing only the prefilter does not require repeating step (a). 8. A list of all aerospace coating products in current use (none older than 12 months is required) shall be maintained, showing the type of coating (primer, topcoat, or individual specialty as identified in Appendix N), and any information necessary to classify it further as to possible exemption under SC #6. [OAC 252:100-45] 9. All hand-wipe cleaning solvents shall have composite vapor pressure no greater than 45 mm Hg at 20 ºC or shall meet the composition requirements of Table 1 of 40 CFR Good housekeeping shall be observed, with measures detailing proper handling of fresh and spent solvents and solvent-laden materials being described in 40 CFR (a). Cleaning solvents with HAP and VOC content below the de minimis levels of (f) are exempt from these requirements. Thirteen cleaning operations exempt from these requirements are listed in 40 CFR (e). [OAC 252: (d)(4)] 10. Only the following methods shall be used for spray gun cleaning. a) an enclosed system. The enclosed system shall be open only while inserting or removing the gun, and cleaning consist of forcing solvent through the gun. Monthly inspections

14 SPECIFIC CONDITIONS O DRAFT 4 shall be performed while the system is in operation, with visual inspection of the seals and other potential sources of leaks. Leaks must be repaired as soon as practicable, but always within 15 days. If repairs cannot be effected within 15 days, the unit shall be drained and use discontinued. b) nonatomized cleaning. Place cleaning solvent in the pressure pot and force it through the gun with the atomizing cap in place. No atomizing air is to be used. Direct the cleaning solvent from the gun into a waste container that is closed when not in use. c) disassembled spray gun cleaning. When the guns are disassembled, they may be cleaned by hand in a vat, which shall remain closed except while in use, or allowed to soak in a vat, which shall be opened only while inserting or removing the parts. d) atomizing cleaning. Force the cleaning solvent through the gun and direct the resulting atomized spray into a waste container that is fitted with a device designed to capture the atomized cleaning solvent emissions. In all cases, good housekeeping shall be observed, with measures detailing proper handling of fresh and spent solvents and solvent-laden materials described in 40 CFR (a). Solvents with HAP and VOC content below the de minimis levels of (f) are exempt from these requirements. [OAC 252: (d)(4)] 11. The facility is subject to Paint Stripping and Miscellaneous Surface Coating Operations at Area Sources, 40 CFR 63 Subpart HHHHHH and shall comply with all work practice standards and notice requirements of the Subpart. 12. All records necessary to demonstrate compliance with permit conditions shall be maintained on-site or at a readily accessible location and shall be available for review by regulatory personnel during normal business hours. Records shall be retained for at least five years from the date of recording. Such records include, but are not necessarily limited to, the following. a) Gallons of coating used in each category, per SC #1, EUG 2 and EUG 3 (monthly and 12-month rolling). b) Gallons of exempt coating used, per SC #6 (monthly and 12-month rolling). c) Current Material Safety Data Sheets for all coating and cleaning products used. MSD Sheets for coating products shall show the VOC and HAP contents of each product as applied, less water or exempt solvents, as appropriate. MSD sheets for hand-wipe solvents shall contain vapor pressure information sufficient to demonstrate compliance with Condition #9. d) Gallons or weight of all solvents used for cleaning operations (monthly and 12-month rolling). e) Pressure drop readings for dry filter spray booths to demonstrate compliance with SC #7 (each shift, when operating). f) Monthly leak inspection reports for enclosed gun cleaning systems. g) Documentation showing that alternative coatings used comply with the requirements of Condition #5. h) Records and notices demonstrating compliance with 40 CFR 63 Subpart HHHHHH.

15 SPECIFIC CONDITIONS O DRAFT Reporting under Section IV of the Major Source Standard Conditions of your Part 70 Permit TVR must be submitted for the period between your last submitted report and the issue date of the current minor source permit. 13. This permit supersedes all other operating permits for this facility and they are now null and void.

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17 Mr. Doug Bressler, Director of Safety Permit Number: O Bizjet International Permit Writer: Herb Neumann 3515 N. Sheridan Date: Tulsa, OK Re: Bizjet International 3515 N. Sheridan Road, Tulsa, OK Dear Mr. Bressler: Air Quality Division has completed the initial review of your permit application referenced above. This application has been determined to be a Tier II. In accordance with 27A O.S and OAC 252:4-7-13(c), the enclosed draft permit is now ready for public review. The requirements for public review include the following steps that 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 this draft permit and a copy of the application at a convenient location within the county of the facility. 3) Send AQD a written affidavit of publication for the notice from Item #1 above together with any additional comments or requested changes which you may have for the permit application within 20 days of publication. 4) At the end of the public review period, send AQD a written notice of any public comments that you may have received from the public. Thank you for your cooperation. If you have any questions, please refer to the permit number above and contact the permit writer at (918) Sincerely, Phillip Fielder AIR QUALITY DIVISION

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19 Mr. Doug Bressler, Director of Safety Bizjet International 3515 N. Sheridan Tulsa, OK Re: Operating Permit No O Dear Mr. Bressler: Enclosed is minor source operating permit No O for the Bizjet facility referenced above. Please note that reporting under Section IV of the Major Source Standard Conditions of your Part 70 Permit TVR must be submitted for the period between your last submitted report and the issue date of the current minor source permit. Also note that you are required to annually submit an emissions inventory for this facility. An emissions inventory must be completed on approved AQD forms and submitted (hardcopy or electronically) by April 1 st of every year. Any questions concerning the form or submittal process should be referred to the Emissions Inventory Staff at Thank you for your cooperation in this matter. If we may be of further service, please contact our office at (918) Air Quality personnel are located in the DEQ Regional Office at Tulsa, 3105 E. Skelly Drive, Suite 200, Tulsa, OK, Sincerely, Phillip Fielder AIR QUALITY DIVISION

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21 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 Bizjet International, having complied with the requirements of the law, is hereby granted permission to operate their facility at 3515 N. Sheridan Road, Tulsa, Tulsa County, Oklahoma, subject to standard conditions dated July 12, 2012, and specific conditions, both attached. Phillip Fielder, P.E. Permits & Engineering Group Manager Date