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DRAFT

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM April 10, 2017

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

THROUGH: Rick Groshong, Sr. Environmental Manager, Compliance and Enforcement

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

THROUGH: Jian Yue, P.E., New Source Permits Section

FROM: Iftekhar Hossain, P.E., New Source Permits Section

SUBJECT: Evaluation of Permit Application No. 2012-232-TVR2

Colorado Interstate Gas Company, LLC

Keyes Compressor Station (Facility ID: 269)

Section 17, Township 5N, Range 7E CM, Cimarron County, Oklahoma

Latitude: 36.89576oN and Longitude: 102.31963

oW

Directions: From Keyes, go 5.5 miles north on SH 171, turn west on

Country Road E0080 and go 4 miles to facility.

SECTION I. INTRODUCTION

The Colorado Interstate Gas Company, LLC (CIG), a subsidiary of the Kinder Morgan Inc

(Kinder Morgan), has submitted an application for a renewal of the Title V permit for the Keyes

Compressor Station. The facility is currently operating under Permit No. 2002-470-TVR (M-1),

issued on August 24, 2011. As required by Major Source Standard Conditions Section VIII, an

application for renewal of initial Part 70 Operating Permit was submitted within 180 days prior

to the date of expiration. The facility is a natural gas compressor station (SIC 4922, NAICS

486210) and is located in an attainment area.

The applicant has requested that the following changes be incorporated into the renewal of the

Title V operating permit:

An emergency generator engine (EG-3) was manufactured in 1970 and was considered

grandfathered. Now it is considered to be an existing stationary source and is subject to

NESHAP, Subpart ZZZZ.

CIG requested permission to maintain records electronically. The option to maintain

records electronically has been incorporated into the recordkeeping portion of the permit.

Two tanks (T-6 and T-7) that were identified in the previous permit as being out of

service have been removed from the facility. Tanks T-6 (10,000-gallone gasoline tank)

and T-7 (10,000-gallon diesel tank) have been removed from the list of emission units in

PERMIT MEMORANDUM NO. 2012-232-TVR2 DRAFT

the memorandum and requirements associated with those tanks have been removed from

the permit.

Previously designated condensate storage tanks, V-33 and V-27, are now used as inlet

filter scrubbers (to remove compressor oils from the inlet natural gas to the station prior

to compression). They are sealed vessels with Over Pressure Protection (OPP) valves to

prevent build of pressure. They are vented to the atmosphere through OPP valves only

when it is required. Therefore, V-33 and V-27 are not condensate storage tanks anymore.

Those tanks have been removed from the list of emission units in the memorandum and

requirements associated with those tanks have been removed from the permit.

The changes requested in association with the issuance of this permit renewal will result in an

increase of 2.29 TPY NOX, 3.76 TPY CO, and 0.03 TPY VOCs.

Since the facility emits more than 100 TPY of a regulated pollutant, it is subject to Part 70

permitting requirements and will go through Tier II permitting process. Therefore, public notice

and EPA review will be required.

SECTION II. FACILITY DESCRIPTION

The facility was formerly operated as two separate facilities with different owners: the Keyes

Compressor Station was owned and operated by the El Paso Corporation and the Keyes Air Plant

was owned and operated by Midstream Energy Services, LLC (MES). The facilities are

adjacent. The El Paso Corporation purchased the Keyes Air Plant on November 10, 2009.

Before that purchase, the Keyes Compressor Station operated under Permit No. 2002-470-TVR.

The Keyes Air Plant is an air blending facility that operated under Permit No. 2006-146-O (M-2)

prior to the purchase. After the purchase, CIG requested that the two permits be merged and that

all requirements be incorporated into a single Title V permit for the combined facility which

would be named the “Keyes Compressor Station.” The facilities have operated under a single

permit since the issuance of Permit No. 2002-470-TVR (M-1) on August 24, 2011. The El Paso

Corporation was acquired by Kinder Morgan in 2012.

The Keyes Compressor Station was constructed in 1953. This facility currently contains four

1,200-hp Cooper-Bessemer compressor engines (CG-1, CG-2, CG-3, and CG-4), one 4,450-hp

turbocharged Caterpillar G3616 compressor engine (CG-5), and two 268-hp Ingersoll-Rand

engines (EG-1 and EG-2) used for electrical generation. All of these engines, except unit CG-5,

were part of the original construction and are exempt from emissions limits based on their

“grandfathered” status. Unit CG-5, the 4,450-hp Caterpillar G3616 Caterpillar engine, was

installed under Permit No. 96-380-C, issued on April 29, 2001. That permit was not considered

to be a major modification due to the installation of a catalytic converter to limit CO emissions

from the new engine below PSD significance levels. The facility also includes a 4,000-gallon

lube oil tank, a 2,300-gallon cooling water tank, and other equipment items considered to be

insignificant sources of air pollution.

The Keyes Air Plant is an air blending facility designed to control BTU levels in an associated

natural gas pipeline. The plant was constructed in 2006. Air is compressed, dehydrated, and


injected into the pipeline at approximately 800 to 1,100 pounds per square inch. This facility

compresses up to ten million cubic feet of air per day. Dehydration is accomplished through the

use of a mole sieve. Regeneration of the mole-sieve element is accomplished using hot air. The

facility contains one 880-hp Waukesha L36GL engine (LP3), two 440-hp Waukesha F18GL

engines (HP3 and HP4), a 340-hp Detroit Diesel 60G engine (GEN4) which powers a standby

generator, the mole-sieve dehydration unit, and an engine oil tank. Engines LP3, HP3, HP4, and

GEN4 are emission-limited engines.

CIG installed catalysts in October 2013 on engines HP3 and HP4 to ensure compliance with

NESHAP, Subpart ZZZZ. On August 24, 2014, CIG installed a catalyst on engine LP3 for the

same purpose.

The engines are fueled by pipeline quality natural gas; the facility is operated as needed

throughout the year. Please note the emission units within the Keyes Air Plant only operate from

approximately November through April of each year. Emission units (EUs) have been arranged

into Emission Unit Groups (EUGs) in the next section.

SECTION III. EQUIPMENT

Specific equipment items that are sources of emissions and other activities that yield emissions

are divided into emission unit groups (EUGs) as follows.

EUG 1 “Grandfathered” Internal Combustion Engines

EU ID # Point Make/Model hp Serial # Const. Date

CG-1 EP1 Cooper-Bessemer GMVA10 1 1,200 43387 1953




1 2-stroke, lean-burn

EUG 2 Emission-Limited Internal Combustion Engines


CG-5 EP16 Caterpillar G3616 1 4,450 4CG00216 2001

LP3 LP3 Waukesha L36GL 1 880 C16783/1 2006

HP3 HP3 Waukesha F18GL 1 440 C16784/1 2006

HP4 HP4 Waukesha F18GL 1 440 C16784/2 2006

1 4-stroke, lean-burn, with oxidation catalyst

EUG 3 Generator Engines 1


EG-1 EP5 Ingersoll-Rand 2 268 6HP2749 1953

EG-2 EP6 Ingersoll-Rand 2 268 6HP2747 1953

EG-3 EG-3 Cummins GTA-28 2 505 721153 1970

GEN4 GEN4 Detroit Diesel 60G 3 340 2114562 2006

1 Emergency generators, operated less than 500 hours per year.

2 4-stroke, rich-burn.

3 4-stroke, lean-burn.


EUG 4 Tanks

New EU

ID #†

Old EU

ID # Point

† Contents

Capacity

(gallons)

Throughput

(gallons/year) Const. Date

T-1 T-3 EP9 Scrubber Liquid 10,000 2,000 Post-1984

T-2 T-4 EP10 Floor Drain Waste 10,000 2,100 Post-1984

T-3 T-5 EP11 Used Engine Oil 10,000 1,500 Post-1984

T-8 T-1 EP12 Cooper Engine Oil 6,248 4,000 Post-1984

--- --- EP14 Water 10,000 4,000 1953

T-7 T-9 EP15 Cooper Ambitrol 6,206 1,200 Post-1984

T-6 T-10 EP17 Caterpillar Lube Oil 4,231 100 2001

T-5 T-11 EP18 Norkool (Caterpillar) 2,300 100 2001 †

EU ID # and Emissions Points have been redesignated to represent field conditions.

EUG 5 Condensate Loading

EU ID # Point ID# Emission Unit Throughput (gal/yr) Const. Date

LOAD LOAD Condensate Loading 2,000 Post-1984

EUG 6 Fugitives

EU ID # Point Type of Equipment Const. Date

FUG FUG Valves, flanges, miscellaneous – Keyes Compressor Station 1953

Valves, flanges, miscellaneous – Keyes Air Plant 2006

SECTION IV. AIR EMISSIONS

The applicant estimated emissions from the reciprocating engines located at the site based on the

procedures and assumptions described below. The criteria pollutant emission factors for the

engines are presented in Table 1. Table 2 lists the engine stack parameters.

For engines CG-1, CG-2, CG-3, and CG-4, the applicant used factors from AP-42 (1/95),

Chapter 3.2. The engines were assumed to run continuously. These engines are

uncontrolled.

For engines EG-1 and EG-2, the applicant used factors from AP-42 (1/95), Chapter 3.3.

The engines were assumed to be operated for 500 hours per year. These engines are

uncontrolled.

For engine CG-5, the applicant used manufacturer’s data with a safety factor. This engine

is equipped with a catalytic converter with the following control efficiencies: 44% for CO

and formaldehyde and 50% for VOCs. This engine was assumed to operate continuously.

For engines LP3, HP 3, and HP4, the applicant used manufacturer’s data with a safety

factor. The engines were assumed to run continuously. Emissions from these engines were

estimated without taking into consideration of the catalysts installed to comply with

NESHAP, Subpart ZZZZ.

For engine GEN4, the applicant used manufacturer’s data with a safety factor. This engine

was assumed to be operated for 500 hours per year. The engine is uncontrolled.


For engine EG-3, the applicant used factors from AP-42 (7/00), Chapter 3.2. The engine

was assumed to be operated for 500 hours per year. The engine is uncontrolled.

Table 1. Engine Emissions Factors

Engine Type Qty NOx

(g/hp-hr)

CO

(g/hp-hr)

VOC

(g/hp-hr)

CG-1, CG-2, CG-3, CG-4 4 12.0 1.6 0.72

EG-1, EG-2 2 14.1 3.03 1.12

CG-5 1 0.70 1.5 0.15

LP-3 1 7.29 3.31 1.09

HP-3, HP-4 2 7.29 3.40 1.10

GEN4 1 38.95 2.22 1.63

EG-3 1 8.24 13.50 0.11

1 Catalysts were installed to ensure compliance with NESHAP, Subpart ZZZZ. However, the emission

factors shown in this table do not reflect controlled emissions.

Table 2. Engine Stack Parameters

EU

ID #

Source

(make/model)

Height

(feet)

Diameter

(inches)

Flow

(ACFM)

Temp.

(deg F)

CG-1 Cooper-Bessemer GMVA10 24 15 12,000 700 CG-2 Cooper-Bessemer GMVA10 24 15 12,000 700 CG-3 Cooper-Bessemer GMVA10 24 15 12,000 700 CG-4 Cooper-Bessemer GMVA10 24 15 12,000 700 EG-1 Ingersoll-Rand 16 8 1,480 1,000 EG-2 Ingersoll-Rand 16 8 1,480 1,000 EG-3 Cummins GTA-28 10 2 3,671 1,219 CG-5 Caterpillar G3616 24

1 16

1 29,210 838

LP3 Waukesha L36GL 16.25 12 5,377 876 HP3 Waukesha F18GL 16.25 12 2,570 879 HP4 Waukesha F18GL 16.25 12 2,570 879

GEN4 Detroit Diesel 60G 12 4 2,005 1,008

1 Two exhaust stacks.

The facility produces very little condensate and the condensate collected is from the scrubbers

for the compressor intercoolers. Condensate is stored in tank T-1. The applicant, however,

estimated VOC emissions from tank T-1 using the Vasquez-Beggs correlation, a maximum

condensate throughput of 2,000 gallons/year, and the DEQ defaults for the remaining

parameters. The applicant estimated condensate truck loading emissions using the procedures

described in AP-42 (1/95), Tables 5.2-1 and 7.1-2 and a throughput of 2,000 gallons/year.

Emissions from the remaining tanks were determined to be negligible and are not included in the

facility-wide emissions table.

Process piping fugitive emissions were based on Table 2-4 of “1995 Protocol for Equipment

Leak Emission Estimates (EPA 453/R-95-017),” Oil and Gas Production Operations Average

Emission Factors. Table 3 presents facility-wide criteria pollutant emissions.


Table 3. Facility-Wide Criteria Pollutant Emissions

EU ID Source NOx CO VOC

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

CG-1 1,200-hp Cooper-Bessemer GMVA10 31.75 139.07 4.23 18.53 1.90 8.32




CG-5 4,450-hp Caterpillar G3616 6.87 30.08 14.72 64.46 1.47 6.45

EG-1 268-hp Ingersoll-Rand 1 8.27 2.07 1.79 0.45 0.66 0.17

EG-2 268-hp Ingersoll-Rand 1 8.27 2.07 1.79 0.45 0.66 0.17

EG-3 505-hp Cummins GTA-28 1 9.17 2.29 15.03 3.76 0.12 0.03

LP3 880-hp Waukesha L36GL 14.15 61.97 6.43 28.16 2.11 9.26

HP3 440-hp Waukesha F18GL 7.07 30.97 3.30 14.45 1.07 4.67

HP4 440-hp Waukesha F18GL 7.07 30.97 3.30 14.45 1.07 4.67

GEN4 340-hp Detroit Diesel 60G 1 29.17 7.29 1.66 0.42 1.22 0.31

T-1 Scrubber Liquid Tank (EUG 4) -- -- -- -- -- 0.80

FUG Fugitive Emissions -- -- -- -- -- 0.60

LOAD Condensate Truck Loading -- -- -- -- -- 0.01

Total Emissions 2 217.03 723.97 64.93 200.69 15.98 60.42

Facility-Wide Emissions from the Existing

Permit [from Permit No. 2002-470-TVR (M-1)] 207.86 721.68 49.90 196.93 15.86 60.39

Net Change 3 +9.17 +2.29 +15.03 +3.76 +0.12 +0.03

1 The emissions estimates from the Ingersoll-Rand, Detroit Diesel, and Cummins engines are based on

500 hours of operation for each engine per year. 2

Totals do not necessarily add up exactly due to rounding. 3

The increase in emissions is due to the inclusion of the 505-hp Cummins engine which has remained

at the facility for more than 12 months and is now considered to be a stationary source.

Hazardous Air Pollutant Emissions (HAPs)

The primary hazardous air pollutant (HAP) emitted from the engines is formaldehyde (HCHO).

Table 4 presents estimates of the formaldehyde emissions from the engines as well as the

emission factors used. Engine CG-5 is equipped with an oxidation catalyst with a formaldehyde

control efficiency of 44%. Engines LP3, HP3, and HP4 are also equipped with oxidation

catalysts to ensure compliance with NESHAP, Subpart ZZZZ. However, the emissions in this

table do not reflect controlled formaldehyde emissions from these units and should be considered

conservative. The formaldehyde emissions estimates were prepared based on the same hours

operation used to estimate criteria pollutant emissions.


Table 4. Engine Formaldehyde Emissions

Emission

Unit ID Source

Emission Factor

(g/hp•hr)

Emissions

lb/hr TPY

CG-1 1,200-hp Cooper-Bessemer GMVA10 0.2024 0.535 2.345




CG-5 4,450-hp Caterpillar G3616 0.1456 3 1.428 6.256

EG-1 268-hp Ingersoll-Rand 1 0.0994 0.059 0.015

EG-2 268-hp Ingersoll-Rand 1 0.0994 0.059 0.015

EG-3 505-hp Cummins GTA-28 1 0.0744 0.083 0.021

LP3 880-hp Waukesha L36GL 0.171 0.332 1.453

HP3 440-hp Waukesha F18GL 0.171 0.166 0.727

HP4 440-hp Waukesha F18GL 0.171 0.166 0.727

GEN4 340-hp Detroit Diesel 60G 1 0.192 0.144 0.036

Totals 2 4.58 18.63

1 The emissions estimates from the Ingersoll-Rand, Detroit Diesel, and Cummins engines are based on

500 hours of operation for each engine per year. 2

Totals do not necessarily add up exactly due to rounding. 3

This emission factor includes a control efficiency of 44%.

In addition to formaldehyde, the applicant reported emissions of acetaldehyde (5.26 TPH) and

acrolein (2.17 TPY). Including those additional HAPs, total HAP emissions equal 24.40 TPY,

which is below the 25 TPY threshold. However, the facility is classified as a major source of

HAPs due to the magnitude of formaldehyde emissions (18.63 TPY).

Greenhouse Gas (GHG) Emissions

The applicant estimated potential annual greenhouse gas (GHG) emissions from combustion

sources in accordance with 40 CFR 98, Subpart C. The operating assumptions (hours of

operation per year, etc.) were the same as those used to estimate emissions of criteria pollutants

and HAPs. Total annual maximum potential GHG emissions were estimated to be 45,030 US

tons per year.

SECTION V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application are duplicated below.

Appropriate recordkeeping on activities indicated below with “*” is specified in the permit.

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. All emergency engines (EG-1, EG-2, EG-3, and

GEN4) are subject to NESHAP, Subpart ZZZZ and are, therefore, no longer considered

insignificant activities.

2. * Storage tanks with less than or equal to 10,000 gallons capacity that store volatile organic

liquids with a true vapor pressure less than or equal to 1.0 psi at maximum storage


temperature. Tanks T-1 thru T-4 and T-8 thru T-11 store miscellaneous materials including

lube oil and antifreeze. These tanks have capacities equal or less than 10,000 gallons and

the vapor pressures of the materials stored are less than 1.0 psi and other tanks may be added

in the future.

3. * 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. All

tanks under #2 are also covered here.

4. Emissions from condensate tanks with a design capacity of 400 gallons or less in ozone

attainment areas. None identified but may be required in the future.

5. Welding and soldering operations utilizing less than 100 pounds of solder and 53 tons per

year of electrodes. The facility only conducts these activities for maintenance purposes,

which is a ‘trivial activity’; therefore, no recordkeeping is required.

6. * Torch cutting and welding of under 200,000 tons of steel fabricated. None identified but

may be required in the future.

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

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

also included. None identified but may be required in the future.

8. Surface coating and degreasing operations which do not exceed a combined total usage of

more than 60 gallons/month of coatings, thinners, clean-up solvents, and degreasing solvents

at any one emission unit. One 30 gallon degreasing solvent tank is located at the facility.

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

hazardous waste satellite (accumulation) areas. None identified but may be required in the

future.

10. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria

pollutant. Emissions from EG-3 will have actual emissions of less than 5 TPY. Other

activities may be used and identified in the future.


SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable]

Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-2 (Incorporation by Reference) [Applicable]

This subchapter incorporates by reference applicable provisions of Title 40 of the Code of

Federal Regulations. These requirements are addressed in the “Federal Regulations” section.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable]

Primary Standards are in Appendix E and Secondary Standards are in Appendix F of the Air

Pollution Control Rules. At this time, all of Oklahoma is in attainment of these standards.

OAC 252:100-5 (Registration, Emissions Inventory and Annual Operating Fees) [Applicable]

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

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

regulated pollutants. Emission inventories have been submitted for this facility as required.

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

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

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

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

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

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

calendar year emissions do not exceed the following limits:

5 TPY of any one criteria pollutant; and

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 limits for the facility are based on the previous Title V permit and the permit

application.

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

Except as provided in OAC 252:100-9-7(a)(1), the owner or operator of a source of excess

emissions shall notify the Director as soon as possible but no later than 4:30 p.m. the following

working day of the first occurrence of excess emissions in each excess emission event. No later

than thirty (30) calendar days after the start of any excess emission event, the owner or operator

of an air contaminant source from which excess emissions have occurred shall submit a report

for each excess emission event describing the extent of the event and the actions taken by the

owner or operator of the facility in response to this event. Request for affirmative defense, as

described in OAC 252:100-9-8, shall be included in the excess emission event report. Additional

reporting may be required in the case of ongoing emission events and in the case of excess

emissions reporting required by 40 CFR Parts 60, 61, or 63.


OAC 252:100-13 (Open Burning) [Applicable]

Open burning of refuse and other combustible material is prohibited except as authorized in the

specific examples and under the conditions listed in this subchapter.

OAC 252:100-19 (Particulate Matter (PM)) [Not Applicable]

This subchapter specifies particulate matter (PM) emissions limitations for new and existing

fuel-burning equipment based on the maximum design heat input rating. Appendix C presents

the specific PM limits: 0.6 lb/MMBTU for fuel-burning equipment with a rated heat input of 10

MMBTUH or less and a limit of 0.10 lb/MMBTU for fuel-burning equipment with a rated heat

input of 10,000 MMBTUH or more. For equipment with a rated heat input that is between those

values, there are two equations used to compute the allowable PM emissions. For units with a

maximum heat input that is greater than 10 MMBTUH, but less than 1,000 MMBTUH, the

following equation is used.

E = 1.0428080 • X -0.238561

Where E = the allowable total particulate matter emissions in pounds per MMBTU

X = the maximum heat input in MMBTU per hour

For natural-gas fired engines, AP-42 (7/00), Table 3.2-1 lists the total PM emissions (filterable

plus condensable) to be 0.0483 lb/MMBTU for two-stroke, lean-burn engines; Table 3.2-2 lists the

total PM emissions to be 0.0100 lb/MMBTU for four-stroke, lean-burn engines; and Table 3.2-3

lists the total PM emissions to be 0.0194 lb/MMBTU for four-stroke rich-burn engines. For diesel

engines, AP-42 (10/96), Table 3.3-1 lists the total PM emissions to be 0.31 lb/MMBTU for diesel

industrial engines. The table presented below summarizes the data, showing that the engines

comply with the limits computed from the applicable equation in Appendix C. In addition, the

permit requires the use of natural gas for the engines to ensure compliance with Subchapter 19.

Quant. Equipment Heat Input

(MMBTUH)

Appendix C

Emission Limit

(lb/MMBTU)

AP-42 Emission

Rate 1

(lb/MMBTU)

4 CG-1, CG-2, CG-3, CG-4 10.15 0.600 0.0483

2 EG-1, EG-2 2.14 0.600 0.0194

1 CG-5 30.26 0.462 0.0100

1 LP-3 6.29 0.600 0.0100

2 HP-3, HP-4 3.14 0.600 0.0100

1 GEN4 2.72 0.600 0.0100

1 EG-3 4.20 0.600 0.0100 1

Filterable plus condensable PM-10 emissions.

OAC 252:100-25 (Visible Emissions and Particulates) [Not Applicable]

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

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

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

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

opacity standards.


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

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

property line on which the emissions 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 252:100-31 (Sulfur Compounds) [Applicable]

Part 5 limits sulfur dioxide emissions from new petroleum or natural gas process equipment

(constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lb/MMBTU heat input

averaged over 3 hours. For fuel gas having a gross calorific value of 1,000 Btu/SCF, this limit

corresponds to fuel sulfur content of 1,203 ppmv. Gas produced from oil and gas wells having

343 ppmv or less total sulfur will ensure compliance with Subchapter 31. The permit requires

the use of pipeline-grade natural gas or field gas with a maximum sulfur content of 343 ppmv to

ensure compliance with Subchapter 31.

OAC 252:100-33 (Nitrogen Oxides) [Not Applicable]

This subchapter limits NOx emissions from new fuel-burning equipment with rated heat input

greater than or equal to 50 MMBTUH to emissions of 0.2 lb of NOx per MMBTU. There are no

equipment items that exceed the 50 MMBTUH threshold.

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

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

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

reforming unit.

OAC 252:100-37 (Volatile Organic Compounds) [Applicable]

Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons

or more and storing a VOC with a vapor pressure greater than 1.5 psia at maximum storage

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

recovery system. The condensate/scrubber liquid tank (T-1) is subject to this requirement.

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

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

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

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

Part 5 limits the VOC content of coatings used in coating lines or operations. Any painting

operation will involve maintenance coating of buildings and equipment and emit less than 100

pounds per day of VOCs and is exempt.

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

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

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

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

Areas of Concern (AOC). Any work practice, material substitution, or control equipment


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

modification is approved by the Director. Since no AOC has been designated anywhere in the

state, there are no specific requirements for this facility at this time.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

procedure had been performed.

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

OAC 252:100-11 Alternative Reduction not eligible

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

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

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

OAC 252:100-24 Feed & Grain Facility not in source category

OAC 252:100-39 Nonattainment Areas not in a subject area

OAC 252:100-47 Landfills not type of source category


SECTION VI. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable]

For NOx and CO, total facility emissions exceed the PSD major source threshold of 250 TPY.

Therefore, the facility is considered to be an existing major source for PSD and any future emissions

increase may be required to undergo a PSD evaluation if threshold levels are exceeded. The PSD

significance levels are 40 TPY NOx, 100 TPY CO, 40 TPY SO2, 40 TPY VOCs, 15 TPY PM-10,

10 TPY Total Reduced Sulfur, or 0.6 TPY lead.

NSPS, 40 CFR Part 60 [Not Applicable]

Subparts K, Ka, Kb, VOL Storage Vessels. The tanks on-site are not subject to Subparts K and

Ka since their capacities do not exceed the threshold size of 40,000 gallons. The tanks are also

not subject to Kb since their capacities are less than the smallest threshold level (19,812 gallons)

of this subpart. This subpart is not applicable.

Subpart GG, Stationary Gas Turbines. There are no turbines at this facility.

Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemicals Manufacturing

Industry. This facility is not a SOCMI plant.

Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. The

facility does not engage in natural gas processing.

Subpart LLL, Onshore Natural Gas Processing: SO2 Emissions. There is no natural gas

sweetening operation at this site.

Subpart IIII, Stationary Compression Ignition Internal Combustion Engines, affects stationary

compression ignition (CI) internal combustion engines (ICE) based on power and displacement

ratings, depending on date of construction, beginning with those constructed after July 11, 2005.

There are no CI ICE on site.

Subpart JJJJ, Stationary Spark Ignition Internal Combustion Engines (SI-ICE). This subpart was

published in the Federal Register on January 18, 2008. It promulgates emission standards for

new SI engines ordered after June 12, 2006, that are manufactured after certain dates, and for SI

engines modified or reconstructed after June 12, 2006. The specific emission standards (either in

g/hp-hr or as a concentration limit) vary based on engine class, engine power rating, lean-burn or

rich-burn, fuel type, duty (emergency or non-emergency), and manufacture date. Engine

manufacturers are required to certify certain engines to meet the emission standards and may

voluntarily certify other engines. The following table identifies the SI ICE located at the site,

their date of manufacture, and whether or not they are subject to any requirements under this

subpart.

Engine Type Qty Date of

Manufacture Regulatory Status

CG-1, CG-2, CG-3, CG-4 4 1953 Manufactured before 1/1/2008. Not subject.

EG-1, EG-2 2 1953 Manufactured before 7/1/2008. Not subject.

CG-5 1 2001 Manufactured before 7/1/2007. Not subject.

LP-3 1 2006 Manufactured before 1/1/2008. Not subject.


Engine Type Qty Date of

Manufacture Regulatory Status

HP-3, HP-4 2 2006 Manufactured before 7/1/2008. Not subject.

GEN4 1 2006 Manufactured before 7/1/2008. Not subject.

EG-3 1 1970 Manufactured before 7/1/2007. Not subject.

As indicated, all of the engines located at this facility were manufactured prior to the dates that

would have made them subject to this subpart.

Subpart OOOO, Crude Oil and Natural Gas Production, Transmission, and Distribution. This

subpart establishes emission standards and compliance schedules for the control of VOC and

SO2 emissions from affected facilities that commence construction, modification, or

reconstruction after August 23, 2011. Emission sources which are subject to this subpart include

single gas wells, centrifugal compressors, reciprocating compressors, pneumatic controllers,

storage vessels, and equipment associated with natural gas processing plants and sweetening

units. All of the equipment items located at this site were manufactured (and/or installed) prior

to August 23, 2011 and, therefore, are not subject.

NESHAP, 40 CFR Part 61 [Not Applicable]

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

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

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

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

benzene content of less than 1%. Subpart M, Asbestos, in the case of asbestos demolition,

Subpart M would be applicable.

NESHAP, 40 CFR Part 63 [Subpart ZZZZ Applicable]

Subpart HH, Oil and Natural Gas Production Facilities. According to the applicant, no extraction

of natural gas liquids has ever been conducted at this facility. It, therefore, would be defined as a

“transmission facility” rather than a “production facility.”

Subpart HHH, Natural Gas Transmission and Storage Facilities. This subpart was published in

the Federal Register on June 17, 1999. This subpart applies to owners and operators of natural

gas transmission and storage facilities that transport or store natural gas prior to entering the

pipeline to a local distribution company or to a final end user (if there is no local distribution

company), and that are major sources of hazardous air pollutant (HAP) emissions as defined in

§63.1271. For the purposes of determining whether a facility is a “major source,” only the

emissions from the affected units (glycol dehydration units) are counted. The facility does not

have a glycol dehydration unit and, therefore, is not subject to the subpart.

Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart affects RICE

that are located at area and major sources of HAP emissions. Prior to the issuance of Permit No.

2002-470-TVR (M-1), both the Keyes Air Plant and the Keyes Compressor Station were

classified as minor sources of HAPs and each facility operated under a separate permit. On

August 24, 2011, Permit No. 2002-470-TVR (M-1) was issued and the combined facility became

a major source of HAPs. In accordance with §63.6595(b)(2), the owner/operator was required to

come into compliance with the major source requirements of this subpart within three years of


that date. The applicability of this subpart to the engines located at the site is addressed as

follows.

Four 1,200-hp Cooper-Bessemer GMVA10, 2-stroke, lean-burn engines (CG-1, CG-2, CG-3,

and CG-4): these engines were manufactured in 1953 and are “existing” engines under this

subpart. In accordance with § 63.6590(b)(3)(i), there are no requirements for these engines

under this subpart.

Two 268-hp Ingersoll-Rand, 4-stroke, rich-burn engines (EG-1 and EG-2): these engines were

manufactured in 1953 and are “existing” engines under this subpart. Table 2c to this subpart

summarizes the requirements for emergency, stationary RICE as (a) requiring a change of oil and

filter every 500 hours or annually (whichever comes first), (b) inspection of spark plugs every

1,000 hours or operation or annually (whichever comes first), and (c) inspection of all hoses and

belts every 500 hours of operation or annually (whichever comes first).

One 4,450-hp Caterpillar G3616, 4-stroke, lean-burn engine equipped with an oxidation catalyst

(CG-5): this engine was manufactured in 2001 and is considered to be an “existing” engine under

this subpart. In accordance with § 63.6590(b)(3)(ii), there are no requirements for this engine

under this subpart.

One 880-hp Waukesha L36GL, 4-stroke, lean-burn engine (LP3): this engine was constructed in

2006 and, with a rating greater than 500 hp, it is considered to be a “new” engine under this

subpart. (See § 63.6590(a)(2)(i)). Table 2a of this subpart summarizes the requirements for new

4SLB stationary RICE (with hp ≥ 250) as (a) reducing CO emissions by 93 percent or more or

(b) limiting the concentration of formaldehyde in the engine exhaust to 14 ppmvd or less at 15%

O2. CIG installed a catalyst on this unit in August 2014.

Two 440-hp Waukesha F18GL, 4-stroke, lean-burn engines (HP3 and HP4): these engines were

constructed in 2006 and, with a rating less than 500 hp, are considered to be “existing” engines

under this subpart. (See § 63.6590(a)(2)(ii)). Table 2c to this subpart summarizes the

requirements for existing non-emergency, non-black start 4SLB stationary RICE (100 ≤ hp ≤

500) as limiting the concentration of CO in the exhaust to 47 ppmvd or less at 15% O2. CIG

installed catalysts on these units in October 2013.

One 340-hp Detroit Diesel 60G, 4-stroke, lean-burn engine (GEN4): this engine was constructed

in 2006 and is considered to be an “existing” engine under this subpart. Table 2c to this subpart

summarizes the requirements for emergency, stationary RICE as (a) changing the oil and filter

every 500 hours of operation or annually, whichever comes first, (b) inspecting spark plugs every

1,000 hours of operation or annually, whichever comes first, and (c) inspecting all hoses and

belts every 500 hours of operation or annually, whichever comes first, and replacing that

equipment as necessary.

One 505-hp Cummins GTA-28, 4-stroke, rich-burn engine (EG-3): this engine was constructed

in 1970 and it is considered to be an “existing” engine under this subpart. In accordance with

§63.6590(b)(3)(iii), this engine is an existing emergency stationary RICE with a site rating of

more than 500 brake HP located at a major source of HAP emissions that does not operate or is

not contractually obligated to be available for more than 15 hours per calendar year for the


purposes specified in §63.6640(f)(2)(ii) and (iii). As such, it does not have to meet the

requirements of this subpart.

The permit includes specific conditions requiring compliance with the applicable portions of this

subpart. The applicant should consult the rule proper for a more detailed description of

notification, testing, monitoring, operation, maintenance, and recordkeeping requirements

applicable to the engines subject to this subpart.

CAM, 40 CFR Part 64 [Applicable]

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

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

Title V permit, if it meets all of the following criteria:

It is subject to an emission limit or standard for an applicable regulated air pollutant.

It uses a control device to achieve compliance with the applicable emission limit or

standard.

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

pollutant of at least 100% of the amount required to be defined as a major source.

The exempted (grandfathered) units located at this source are not subject to an emission limit or

standard for any regulated air pollutant. Engine CG-5 has uncontrolled CO emissions of 161

TPY which is greater than the major source threshold. Therefore, the engine is subject to the

CAM. The CAM plan submitted for the engine requires monitoring of pressure drop and

temperature difference across the catalytic converter. All applicable requirements are

incorporated into the permit.

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Not Applicable]

The definition of a stationary source does not apply to transportation, including storage incident

to transportation, of any regulated substance or any other extremely hazardous substance under

the provisions of this part. The definition of a stationary source also does not include naturally

occurring hydrocarbon reservoirs. Naturally occurring hydrocarbon mixtures, prior to entry into

a natural gas processing plant or a petroleum refining process unit, including: condensate, crude

oil, field gas, and produced water, are exempt for the purpose of determining whether more than

a threshold quantity of a regulated substance is present at the stationary source. More

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

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

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

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

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

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

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

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

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

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

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

(Subpart H).


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

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

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

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

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

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

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

scheduled in phases starting by 2002, is required by January 1, 2030.

This facility does not utilize any Class I & II substances.

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

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

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

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

reduction.

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

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

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

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

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

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

of refrigerant.

SECTION VII. COMPLIANCE

Tier Classification and Public Review

The permittee has submitted an affidavit that they are not seeking a permit for land use or for any

operation upon land owned by others without their knowledge. The affidavit certifies that the

application involves only land owned by the applicant (or applicant business).

This application has been classified as Tier II, because it requests the renewal of a Part 70

operating permit. Information on all permit actions is available for review by the public on the

Air Quality section of the DEQ web page at http://www.deq.state.ok.us.

The applicant will be required to publish both a “Notice of Filing a Tier II Application” and a

“Notice of Tier II Draft Permit” in a newspaper local to the facility. The notices will state that

the application and the draft permit will be available for public review at the Soutar Memorial

Library in Boise City or at the Air Quality Division’s (AQD’s) main office in Oklahoma City. In

addition, the draft permit will be available for review on the AQD web page. The public

comment period will end 30 days after the date of publication of these notices.

State Review

This facility is located within 50 miles of the Oklahoma border with the states of Colorado, New

Mexico, Kansas, and Texas. Those states were notified of the draft permit.

http://www.deq.state.ok.us/


EPA Review

After the close of the public comment period, the “proposed” permit will be submitted to EPA

Region 6 for a 45-day review period.

Inspection

A full compliance inspection of the Keyes Compressor Station was conducted on June 10, 2015.

The inspection was performed by Alex McCumber (Air Quality) and he was accompanied by

David Bieda, Jimmy Williams, and Scott Hanna (CIG). The facility appeared to be operating as

described in the application. One compliance issue and one area of concern were discovered

during the inspection. The noncompliance issue was a failure to continuously record the catalyst

inlet temperatures for the engines that are subject to NESHAP, Subpart ZZZZ. The cause of this

instance of noncompliance was a failure of the continuous parameter monitoring system (CPMS)

to restart after a power failure. This data monitoring program was replaced with a program that

restarts automatically after a power loss and the enforcement case was closed. The area of

concern was an incorrect submission to Emissions Inventory for the 2013 operating year. This

error has been corrected. Since no equipment changes have been made to the facility since that

time, an additional inspection was deemed unnecessary for this permitting action.

Testing

The four 1,200-hp Cooper-Bessemer GMVA10 engines (CG-1, CG-2, CG-3, and CG-4) are

“grandfathered” and are not subject to emission limits as long as the equipment is maintained at

the site as is. The two 268-hp Ingersoll-Rand engines (EG-1 and EG-2) retain “grandfathered”

status and are not required to be tested. The 505-hp Cummins engine (EG-3) is an insignificant

activity and it is not required to be tested. The 340-hp Detroit Diesel engine is only required to

be tested if it is operated for more than 220 hours in any quarter. It has not exceeded that

threshold and has not been tested. The results of periodic engine testing (for the additional

engines which are subject to emissions limits) were provided and these results show compliance

with the applicable emission limits.

Table 5. Engine Emission Test Results

Source

PERMIT LIMITS TEST RESULTS

Test Date NOx

lb/hr

CO

lb/hr

NOx

lb/hr

CO

lb/hr

CG-5: 4,450-hp Caterpillar G3616 Engine

w/OC1, Serial Number: 4CG00216

6.87 14.72 2.68 6.23 3

rd Quarter

2013*

LP3: 880-hp Waukesha L36GL Engine

Serial Number: C16783/1 14.14 6.42 6.59 0.08

1st Quarter

2017

HP3: 440-hp Waukesha F18GL Engine

Serial Number: C16784/1 7.07 3.30 2.44 <0.01

1st Quarter

2017

HP4: 440-hp Waukesha F18GL Engine

Serial Number: C16784/2 7.07 3.30 1.69 <0.01

1st Quarter

2017 1

w/OC = with oxidation catalyst. *CG-5 has not run over 220 hours/quarter since 3rd

quarter 2013

when it was last tested.


Fees Paid

The applicant submitted application fees in the amount of $2,000. The appropriate fee for the

renewal of a Title V permit was $1,000 on the date that the application was submitted. The

excess fees have been refunded.

SECTION VIII. SUMMARY

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

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

enforcement issues. Issuance of the permit is recommended, contingent on public and the EPA

review.

DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Colorado Interstate Gas Company, LLC Permit No. 2012-232-TVR2

Keyes Compressor Station

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

Quality on February 14, 2012 and supplemental information submitted after that date. The

Evaluation Memorandum, dated April 10, 2017, 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 252:100-8-6(a)(1)]

EUG 1: Units CG-1, CG-2, CG-3, and CG-4 are “grandfathered” internal combustion engines

based on DEQ regulations enacted from 1972 to 1979. There are no hourly or annual emission

limits applied to these units under Title V, but they are limited to the existing equipment as it is.

EU ID Point Make/Model Hp Serial # Const. Date

CG-1 EP1 Cooper-Bessemer GMVA10 1,200 43387 1953




EUG 2: The following internal combustion engines are limited to the emission rates shown:

EU ID Description NOX CO VOC


CG-5 4,450-hp Caterpillar G3616 Engine 6.87 30.08 14.72 64.46 1.47 6.45

LP3 880-hp Waukesha L36GL Engine 14.14 61.95 6.42 28.13 2.11 9.26

HP3 440-hp Waukesha F18GL Engine 7.07 30.97 3.30 14.45 1.07 4.67

HP4 440-hp Waukesha F18GL Engine 7.07 30.97 3.30 14.45 1.07 4.67

Engines LP3, HP3, and HP4 are also subject to emission limits, operating limits, and work

practice standards under NESHAP, Subpart ZZZZ. Engine CG-5 shall be operated such that its

exhaust gases pass through a properly functioning catalytic converter. [OAC 252:100-8-6(a)]

SPECIFIC CONDITIONS 2012-232-TVR2 DRAFT Page 2

EUG 3: The following engines are emergency engines used to power generators:

EU ID Description NOX CO VOC


EG-1 268-hp Ingersoll-Rand Engine 1 -- -- -- -- -- --

EG-2 268-hp Ingersoll-Rand Engine 1 -- -- -- -- -- --

EG-3 505-hp Cummins Engine 1 -- -- -- -- -- --

GEN4 340-hp Detroit Diesel 60G Engine 2 29.17 7.29 1.66 0.42 1.22 0.31

1 Engines EG-1 thru EG-3 have “grandfathered” status. There are no limits associated with these

emission units, but the permittee is required to record estimated emissions. These units are also

subject to work practice standards under NESHAP, Subpart ZZZZ. 2

Engine GEN4 is limited to the emissions rates shown. The engine shall be tested in accordance

with Specific Condition Number 5 in any calendar quarter in which it is operated for more than 220

hours. This engine is also subject to work practice standards under NESHAP, Subpart ZZZZ.

Engines EG-1, EG-2, EG-3, and GEN4 shall each be equipped with a non-resettable hour meter.

Engines EG-3 and GEN4 shall be limited to a maximum of 500 hours of operation in any 12-

month period. For all four of these engines, the permittee shall record hours of operation

monthly and provide 12-month rolling totals.

EUG 4: VOC emissions from storage tanks are estimated based on existing equipment items but

do not have a specific limitation.

New EU

ID #†

Old EU

ID # Point

† Contents

Capacity

(gallons)

Throughput

(gallons/year)

Const.

Date

T-1 T-3 EP9 Scrubber Liquid 10,000 2,000 Post-1984

T-2 T-4 EP10 Floor Drain Waste 10,000 2,100 Post-1984

T-3 T-5 EP11 Used Engine Oil 10,000 1,500 Post-1984

T-8 T-1 EP12 Cooper Engine Oil 6,248 4,000 Post-1984

--- --- EP14 Water 10,000 4,000 1953

T-7 T-9 EP15 Cooper Ambitrol 6,206 1,200 Post-1984

T-6 T-10 EP17 Caterpillar Lube Oil 4,231 100 2001

T-5 T-11 EP18 Norkool (Caterpillar) 2,300 100 2001 †

EU ID # and Emissions Points have been redesignated to represent field conditions.

EUG 5: Fugitive VOC and condensate truck loading emissions are estimated based on existing

equipment items but do not have a specific limitation.

EU ID Description Construction Date

LOAD Condensate Truck Loading --

FUG

Valves, Flanges, and Miscellaneous –

Keyes Compressor Station 1953

Valves, Flanges, and Miscellaneous –

Keyes Compressor Station 2006

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

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


3. The fuel-burning equipment shall be fired with pipeline grade natural gas or other gaseous

fuel with a sulfur content less than 343 ppmv. Compliance can be shown by the following

methods: for pipeline grade natural gas, a current gas company bill; for other gaseous fuel, a

current lab analysis, stain-tube analysis, gas contract, tariff sheet, or other approved methods.

Compliance shall be demonstrated at least once per calendar year. [OAC 252:100-31]

4. Each engine/turbine at the facility shall have a permanent identification plate attached, which

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

5. At least once per calendar quarter, the permittee shall conduct tests of NOx and CO

emissions in exhaust gases from each permitted engine with emission limits 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. Engines/turbines shall be tested no sooner than 20 calendar days after the

last test. Testing shall be conducted using a portable analyzer in accordance with a protocol

meeting the requirements of the “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. Likewise, when the following

two consecutive semi-annual tests show compliance, the testing frequency may be reduced to

annual testing. Upon any showing of non-compliance with emissions limitations or testing

that indicates that emissions are within 10% of the emission limitations, the testing frequency

shall revert to quarterly. Any reduction in the testing frequency shall be noted in the next

required compliance certification. Reduced testing frequency does not apply to engines with

catalytic converters. [OAC 252:100-8-6 (a)(3)(A)]

6. The permittee shall keep operation and maintenance (O&M) records for those

engines/turbines with emission limits which do not conduct quarterly testing. Such records

shall at a minimum include the dates of operation, and maintenance, type of work performed,

and the increase, if any, in emissions as a result. [OAC 252:100-8-6 (a)(3)(A)]

7. 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. [OAC 252:100-9]

8. The permittee shall at all times properly operate and maintain all engines/turbines with

emission limits in a manner that will minimize emissions of hydrocarbons or other organic

materials. [OAC 252:100-37-36]

9. Replacement (including temporary periods of 6 months or less for maintenance purposes), of

the internal combustion engines 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 252:100-8-6 (f)]

(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 and model, horsepower rating, fuel usage,


stack flow (ACFM), stack temperature (oF), 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 NOx and CO emission limitations. A copy of

the first quarter testing shall be provided to AQD within 60 days of start-up of each

replacement or additional engine/turbine. The test report shall include the

engine/turbine fuel usage, stack flow (ACFM), stack temperature (oF), stack height

(feet), stack diameter (inches), and pollutant emission rates (lb/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 a modification under NSPS or NESHAP, or a significant modification under

PSD. For existing PSD facilities, the permittee shall calculate the PTE or the net

emissions increase resulting from the replacement to document that it does not exceed

significance levels and submit the results with the notice required by (a) of this

Specific Condition.

(d) Permanent replacement of an exempted/grandfathered engine/turbine shall subject the

new engine/turbine to emission limits and shall require a permit modification.

(e) Engines installed as allowed under the replacement allowances in this Specific

Condition that are subject to 40 CFR Part 63, Subpart ZZZZ and/or 40 CFR Part 60,

Subpart JJJJ shall comply with all applicable requirements.

10. All volatile organic compound (VOC) tanks with a capacity of 400 gallons or more and

storing a liquid which has a vapor pressure of 1.5 psia or greater shall be equipped with a

permanent submerged fill pipe or an organic vapor recovery system. [OAC 252:100-37]

11. Engine CG-5 is subject to Compliance Assurance Monitoring (CAM) and shall comply with

all applicable requirements and provide information as required in Appendix A of this

permit. [40 CFR Part 64]

APPENDIX A MONITORING APPROACH

Indicator No. 1 Indicator No. 2

I. Indicator Pressure drop across the catalyst. Temperature of exhaust gas

into catalyst.

Measurement

Approach

Pressure drop across the catalyst

beds shall be measured monthly

using a differential pressure gauge.

The exhaust gas temperature

into the catalyst shall be

measured continuously using

an in-line thermocouple.

II. Indicator Range The indicator range is a pressure

drop deviation of less than 2 in. H2O

from the benchmark. Excursions

trigger corrective action, logging and

reporting in semiannual report

The indicator range is above

450ºF, but lower than 1,350ºF.

Excursions trigger corrective

action, logging and reporting

in semiannual report.

Performance Criteria

A. Data

Representativeness

Pressure drop across the catalyst

shall be measured at the catalyst inlet

and exhaust. The minimum accuracy

Temperature shall be

measured at the inlet to the

catalyst by a thermocouple.


Indicator No. 1 Indicator No. 2

of the device shall be ±0.25 in. H2O. The minimum accuracy shall

be ±5ºF.

B. QA/QC Practices

and Criteria

The pressure gauge shall be

calibrated quarterly. Pressure taps

shall be checked monthly for

plugging.

Thermocouple shall be

visually checked quarterly and

verified annually.

C. Monitoring

Frequency

Pressure drop shall be measured at

least monthly.

The temperature shall be

measured continuously.

D. Data Collection

Procedures

Records shall be maintained to

document the monthly readings and

any required maintenance.

Temperature data shall be

recorded once per day. No

observation is required when

the engine is not operational.

E. Averaging period None, not to exceed maximum. None

Inspection and Preventive Maintenance Plan

The following is an inspection and preventive maintenance plan for the engines equipped with an

oxidation catalyst. The plan is designed to ensure optimum operation of the catalyst, avoid

situations that could cause the catalyst damage and identify problems in a timely manner.

I. Engine Operations

Proper engine operation is critical to the performance of an oxidation catalyst. If an engine

misfires, it produces high catalyst temperatures because the unburned air/fuel mixture burns

when it contacts the catalyst. Several misfiring cylinders can produce enough heat to cause

permanent damage to the catalyst.

II. Preventive Maintenance:

Each engine shall be checked weekly for proper operation and for misfiring conditions. Any

problem identified during inspection shall be corrected in a timely manner.

12. The following records shall be maintained on-site to verify Insignificant Activities. No

recordkeeping is required for those operations that qualify as Trivial Activities.

[OAC 252:100-8-6 (a)(3)(B)]

(a) For the 505-hp Cummins engine (EG-3), records of operating hours (monthly and 12-

month rolling totals).

(b) For fluid storage tanks with a capacity of less than 39,894 gallons and a true vapor

pressure less than 1.5 psia at maximum storage temperature, records of capacity of the

tanks, monthly throughput, and true vapor pressure of contents.

(c) For torch cutting and welding of under 200,000 tons of fabricated steel, the amount of

steel cut and welded (cumulative annual).

(d) For activities having the potential to emit no more than 5 TPY (actual) of any criteria

pollutant, the type of activity and the amount of emissions from that activity

(cumulative annual).


13. The permitte shall abide by all applicable requirements of NESHAP, 40 CFR Part 63,

Subpart ZZZZ affecting any of the engines subject to these requirements, including, but not

limited to, the following. [40 CFR 63.6585 through 63.6675]

(a) § 63.6585 Am I subject to this subpart?

(b) § 63.6590 What parts of my plant does this subpart cover?

(c) § 63.6595 When do I have to comply with this subpart?

(d) § 63.6600 What emission limitations and operating limitations must I meet if I own or

operate a stationary RICE with a site rating of more than 500 brake HP located at a

major source of HAP emissions?

(e) § 63.6601 What emission limitations must I meet if I own or operate a new or

reconstructed 4SLB stationary RICE with a site rating of greater than or equal to 250

brake HP and less than or equal to 500 brake HP located at a major source of HAP

emissions?

(f) § 63.6602 What emission limitations must I meet if I own or operate an existing

stationary RICE with a site rating of equal to or less than 500 brake HP located at a

major source of HAP emissions?

(g) § 63.6605 What are my general requirements for complying with this subpart?

(h) § 63.6610 By what date must I conduct the initial performance tests or other initial

compliance demonstrations if I own or operate a stationary RICE with a site rating of

more than 500 brake HP located at a major source of HAP emissions?

(i) § 63.6611 By what date must I conduct the initial performance tests or other initial

compliance demonstrations if I own or operate a new or reconstructed 4SLB SI

stationary RICE with a site rating of greater than or equal to 250 and less than or equal

to 500 brake HP located at a major source of HAP emissions?.

(j) § 63.6612 By what date must I conduct the initial performance tests or other initial

compliance demonstrations if I own or operate an existing stationary RICE with a site

rating of less than or equal to 500 brake HP located at a major source of HAP

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

(k) § 63.6615 When must I conduct subsequent performance tests?

(l) § 63.6620 What performance tests and other procedures must I use?

(m) § 63.6625 What are my monitoring, installation, collection, operation, and

maintenance requirements?

(n) § 63.6630 How do I demonstrate initial compliance with the emission limitations and

operating limitations?

(o) § 63.6635 How do I monitor and collect data to demonstrate continuous compliance?

(p) § 63.6640 How do I demonstrate continuous compliance with the emission limitations

and operating limitations?

(q) § 63.6645 What notifications must I submit and when?

(r) § 63.6650 What reports must I submit and when?

(s) § 63.6655 What records must I keep?

(t) § 63.6660 In what form and how long must I keep my records?

(u) § 63.6665 What parts of the General Provisions apply to me?

(v) § 63.6675 What definitions apply to this subpart?

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

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


and shall be provided to regulatory personnel upon request. Some or all of these records may

be maintained electronically. [OAC 252:100-8-6(a)(3)(B)]

(a) Operating hours for engines EG-1, EG-2, and GEN4 (monthly and 12-month rolling

totals).

(b) Periodic testing for engines CG-5, LP3, HP3, HP4, and GEN4 and any replacement/

additional engines/turbines or hours of operation.

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

Number 3.

(d) O&M records for any engine/turbine not tested in each 6 month period.

(e) Summary of O&M records for “grandfathered” engines.

(f) CAM records for engine CG-5 in accordance with Specific Condition Number 11.

(g) Records as required by 40 CFR Part 63, NESHAP, Subpart ZZZZ.

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

operating permit (April 27, 1998), the permittee shall submit to the Air Quality Division of

the DEQ, with a copy to the USEPA Region 6, a certification of compliance with the terms

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

16. This permit supersedes and replaces all existing Air Quality operating permits for this facility

which are now cancelled.

MAJOR SOURCE AIR QUALITY PERMIT

STANDARD CONDITIONS

(June 21, 2016)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with the federal

Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act

and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

B. The issuing Authority for the permit is the Air Quality Division (AQD) of the Oklahoma

Department of Environmental Quality (DEQ). The permit does not relieve the holder of the

obligation to comply with other applicable federal, state, or local statutes, regulations, rules, or

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

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance

shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement

action, permit termination, revocation and reissuance, or modification, or for denial of a permit

renewal application. All terms and conditions are enforceable by the DEQ, by the

Environmental Protection Agency (EPA), and by citizens under section 304 of the Federal Clean

Air Act (excluding state-only requirements). This permit is valid for operations only at the

specific location listed.

[40 C.F.R. §70.6(b), OAC 252:100-8-1.3 and OAC 252:100-8-6(a)(7)(A) and (b)(1)]

D. It shall not be a defense for a permittee in an enforcement action that it would have been

necessary to halt or reduce the permitted activity in order to maintain compliance with the

conditions of the permit. However, nothing in this paragraph shall be construed as precluding

consideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for

noncompliance if the health, safety, or environmental impacts of halting or reducing operations

would be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from an emergency and/or posing an imminent and substantial

danger to public health, safety, or the environment shall be reported in accordance with Section

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported

consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

[OAC 252:100-8-6(a)(3)(C)(iv)]

C. Every written report submitted under this section shall be certified as required by Section III

(Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

MAJOR SOURCE STANDARD CONDITIONS June 21, 2016 Page 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. These records, including

monitoring data and necessary support information, shall be retained on-site or at a nearby field

office for a period of at least five years from the date of the monitoring sample, measurement,

report, or application, and shall be made available for inspection by regulatory personnel upon

request. Support information includes all original strip-chart recordings for continuous

monitoring instrumentation, and copies of all reports required by this permit. Where appropriate,

the permit may specify that records may be maintained in computerized form.

[OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:100-8-6(c)(1), and OAC 252:100-8-6(c)(2)(B)]

B. Records of required monitoring shall include:

(1) the date, place and time of sampling or measurement;

(2) the date or dates analyses were performed;

(3) the company or entity which performed the analyses;

(4) the analytical techniques or methods used;

(5) the results of such analyses; and

(6) the operating conditions existing at the time of sampling or measurement.

[OAC 252:100-8-6(a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the

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

70 operating permit, the permittee shall submit to AQD a report of the results of any required

monitoring. All instances of deviations from permit requirements since the previous report shall

be clearly identified in the report. Submission of these periodic reports will satisfy any reporting

requirement of Paragraph E below that is duplicative of the periodic reports, if so noted on the

submitted report. [OAC 252:100-8-6(a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or

operator shall comply with the provisions of Section II (Reporting Of Deviations From Permit

Terms) of these standard conditions. [OAC 252:100-8-6(a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this

permit, monitoring and reporting may be required under the provisions of OAC 252:100-43,

Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean

Air Act or Oklahoma Clean Air Act. [OAC 252:100-43]

F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report,

Excess Emission Report, and Annual Emission Inventory submitted in accordance with this

permit shall be certified by a responsible official. This certification shall be signed by a

responsible official, and shall contain the following language: “I certify, based on information

and belief formed after reasonable inquiry, the statements and information in the document are

true, accurate, and complete.”

[OAC 252:100-8-5(f), OAC 252:100-8-6(a)(3)(C)(iv), OAC 252:100-8-6(c)(1), OAC

252:100-9-7(e), and OAC 252:100-5-2.1(f)]


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

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

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

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

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

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

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

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

continuous monitoring system or monitoring device is inoperative.

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

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

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

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

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

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

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

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

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

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

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

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

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

or an equivalent method approved by Air Quality.

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

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

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

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

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

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

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

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

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

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

SECTION IV. COMPLIANCE CERTIFICATIONS

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

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

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

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

SECTION VI. PERMIT SHIELD

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

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

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

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

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

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

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

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


SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

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

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

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

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

SECTION VIII. TERM OF PERMIT

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

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

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

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

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

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

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

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

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

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

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

SECTION IX. SEVERABILITY

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

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

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

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

SECTION X. PROPERTY RIGHTS

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

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

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

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

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

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

SECTION XI. DUTY TO PROVIDE INFORMATION

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

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

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


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

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

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

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

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

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

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

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

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

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

SECTION XII. REOPENING, MODIFICATION & REVOCATION

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

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

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

anticipated noncompliance does not stay any permit condition.

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

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

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

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

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

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

date of this permit.

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

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

requirements.

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

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

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

or misleading information to the DEQ.

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

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

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

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

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

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

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

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

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


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

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

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

SECTION XIII. INSPECTION & ENTRY

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

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

permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(17)

for confidential information submitted to or obtained by the DEQ under this section):

(1) enter upon the permittee's premises during reasonable/normal working hours where a

source is located or emissions-related activity is conducted, or where records must be

kept under the conditions of the permit;

(2) have access to and copy, at reasonable times, any records that must be kept under the

conditions of the permit;

(3) inspect, at reasonable times and using reasonable safety practices, any facilities,

equipment (including monitoring and air pollution control equipment), practices, or

operations regulated or required under the permit; and

(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit.

[OAC 252:100-8-6(c)(2)]

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later

than 4:30 p.m. on the next working day after the permittee first becomes aware of the

exceedance. This notice shall contain a description of the emergency, the probable cause of the

exceedance, any steps taken to mitigate emissions, and corrective actions taken.

[OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)]

B. Any exceedance that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to AQD as soon as is practicable; but under no circumstance shall

notification be more than 24 hours after the exceedance. [OAC 252:100-8-6(a)(3)(C)(iii)(II)]

C. An "emergency" means any situation arising from sudden and reasonably unforeseeable

events beyond the control of the source, including acts of God, which situation requires

immediate corrective action to restore normal operation, and that causes the source to exceed a

technology-based emission limitation under this permit, due to unavoidable increases in

emissions attributable to the emergency. An emergency shall not include noncompliance to the

extent caused by improperly designed equipment, lack of preventive maintenance, careless or

improper operation, or operator error. [OAC 252:100-8-2]

D. The affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8-6 (e)(2)]


(1) an emergency occurred and the permittee can identify the cause or causes of the

emergency;

(2) the permitted facility was at the time being properly operated;

(3) during the period of the emergency the permittee took all reasonable steps to minimize

levels of emissions that exceeded the emission standards or other requirements in this

permit.

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an

emergency shall have the burden of proof. [OAC 252:100-8-6(e)(3)]

F. Every written report or document submitted under this section shall be certified as required

by Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:100-8-6(a)(3)(C)(iv)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop

and register with the appropriate agency a risk management plan by June 20, 1999, or the

applicable effective date. [OAC 252:100-8-6(a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate individual emissions units that are either on the list in Appendix I to OAC Title 252,

Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.

Any activity to which a State or Federal applicable requirement applies is not insignificant even

if it meets the criteria below or is included on the insignificant activities list.

(1) 5 tons per year of any one criteria pollutant.

(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an

aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per

year for single HAP that the EPA may establish by rule.

[OAC 252:100-8-2 and OAC 252:100, Appendix I]

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate any individual or combination of air emissions units that are considered inconsequential

and are on the list in Appendix J. Any activity to which a State or Federal applicable

requirement applies is not trivial even if included on the trivial activities list.

[OAC 252:100-8-2 and OAC 252:100, Appendix J]

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the

need for any permit revision or any notification to the DEQ (unless specified otherwise in the


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

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

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

(1) result in no net emissions increases,

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

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

to be exceeded;

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

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

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

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

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

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

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

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

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

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

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

unless elsewhere covered by a more restrictive requirement:

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

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

[OAC 252:100-13]

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

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

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

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

[OAC 252:100-25]

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

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

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

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

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

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

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

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

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

life and/or property.


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

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

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

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

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

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

dioxide. [OAC 252:100-31]

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

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

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

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

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

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

SECTION XX. STRATOSPHERIC OZONE PROTECTION

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

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

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

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

requirements of §82.4;

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

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

requirements at §82.13; and

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

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

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

HCFCs.

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

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

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

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

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

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

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

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

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

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

with the required practices pursuant to § 82.156;

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


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

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

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

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

with record-keeping requirements pursuant to § 82.166;

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

with leak repair requirements pursuant to § 82.158; and

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

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

82.166.

SECTION XXI. TITLE V APPROVAL LANGUAGE

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

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

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

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

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

the following procedures are followed:

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

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

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

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

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

process; that the public will not receive another opportunity to provide comments when

the requirements are incorporated into the Title V permit; and that EPA review, EPA

objection, and petitions to EPA will not be available to the public when requirements

from the construction permit are incorporated into the Title V permit.

(2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR §

70.8(a)(1).

(3) A copy of the draft construction permit is sent to any affected State, as provided by 40

C.F.R. § 70.8(b).

(4) A copy of the proposed construction permit is sent to EPA for a 45-day review period

as provided by 40 C.F.R.§ 70.8(a) and (c).

(5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day

comment period of any EPA objection to the construction permit. The DEQ shall not

issue the permit until EPA’s objections are resolved to the satisfaction of EPA.

(6) The DEQ complies with 40 C.F.R. § 70.8(d).

(7) A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).

(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these

permit conditions.

(9) Any requirements of the construction permit may be reopened for cause after

incorporation into the Title V permit by the administrative amendment process, by


DEQ as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40

C.F.R. § 70.7(f) and (g).

(10) The DEQ shall not issue the administrative permit amendment if performance tests fail

to demonstrate that the source is operating in substantial compliance with all permit

requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the

Title V review process.

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing

shall preclude the use, including the exclusive use, of any credible evidence or information,

relevant to whether a source would have been in compliance with applicable requirements if the

appropriate performance or compliance test or procedure had been performed.

[OAC 252:100-43-6]

DEQ Form #100-890 Revised 2/6/08

PART 70 PERMIT


STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 NORTH ROBINSON, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2012-232-TVR2

Colorado Interstate Gas Company, LLC,

having complied with the requirements of the law, is hereby granted permission to operate

the Keyes Compressor Station, located in Section 17, Township 5N, Range 7E of the

Cimarron Meridian, in Cimarron County, Oklahoma, subject to the Standard Conditions

dated June 21, 2016, and Specific Conditions, both of which are attached.

This permit shall expire five years from the date below, except as authorized under Section

VIII of the Standard Conditions.

_________________________________

Director, Air Quality Division Issuance Date

DRAFT

Mr. David J. Bieda


2 North Nevada Avenue

Colorado Springs, CO 80903

SUBJECT: Renewal of the Title V Operating Permit No. 2012-232-TVR2


DEQ Facility ID: 269


Dear Mr. Bieda:

Enclosed is the permit authorizing continued operation of the referenced facility. Please note

that this permit is issued subject to standard and specific conditions, which are attached. These

conditions must be carefully followed since they define the limits of the permit and will be

confirmed by periodic inspections.

Also note that you are required to annually submit an emission inventory for this facility. An

emission inventory must be completed on approved AQD forms and submitted (hardcopy or

electronically) by April 1st of every year. Any questions concerning the form or submittal process

should be referred to the Emission Inventory Staff at 405-702-4100.

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

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

Sincerely,

Phillip Fielder, P.E.

Permits & Engineering Group Manager


Enclosure

DRAFT

Mr. David J. Bieda


2 North Nevada Avenue

Colorado Springs, CO 80903

SUBJECT: Title V Operating Permit No. 2012-232-TVR2




Permit Writer: Iftekhar Hossain

Dear Mr. Bieda:

Air Quality has completed initial review of the permit application for the referenced facility and

completed a draft permit for public review. This application has been determined to be a Tier II

application. In accordance with 27A O.S. 2-14-302 and OAC 252:4-7-13(c) the enclosed draft

permit is ready for public review. The requirements for public review of the draft permit include the

following steps, which you must accomplish:

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

within the county where the facility is located. (Instructions enclosed)

2. Provide for public review (for a period of 30 days following the date of the newspaper

announcement) a copy of the application and draft permit at a convenient location

(preferentially at a public location) within the county of the facility.

3. Send AQD a written affidavit of publication for the notices 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.


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

Sincerely,


Permits & Engineering Group Manager


Enclosure

Texas Commission on Environmental Quality

Operating Permits Division (MC 163)

P.O. Box 13087

Austin, TX 78711-3087

SUBJECT: Permit Number: 2012-232-TVR2

Facility: Colorado Interstate Gas Company, LLC



Location: Section 17, T5N, R7E of the Cimarron Meridian

Cimarron County, Oklahoma


Dear Sir / Madam:

The owner/operator of the above-referenced facility has applied to renew the facility’s Title V

operating permit under 40 CFR Part 70. Air Quality Division has completed the initial review of

the application and prepared a draft permit for public review. Since this facility is within 50 miles

of the Oklahoma - Texas border, a copy of the proposed permit will be provided to you upon

request. Information on all permit actions and a copy of this draft permit are available for review by

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



Sincerely,


Permits and Engineering Group Manager



KDHE, Bureau of Air

Title V Permitting Group

1000 SW Jackson, Suite 310

Topeka, KS 66612-1366








Dear Sir / Madam:




of the Oklahoma - Kansas border, a copy of the proposed permit will be provided to you upon





Sincerely,





New Mexico Environment Department

Air Quality Bureau

Title V Permitting Section

525 Camino de los Marquez, Suite 1

Santa Fe, NM 87505-1816








Dear Sir / Madam:




of the Oklahoma – New Mexico border, a copy of the proposed permit will be provided to you upon





Sincerely,





Colorado Department of Public Health and Environment

Air Pollution Control Division – Operating Permits Unit

APCD-SS-B1

4300 Cherry Creek Drive South

Denver, CO 80246-1530








Dear Sir / Madam:




of the Oklahoma - Colorado border, a copy of the proposed permit will be provided to you upon





Sincerely,





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