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OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY

AIR QUALITY DIVISION

MEMORANDUM February 22, 2010

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

THROUGH: Kendal Stegmann, Sr. Environmental Manager, Compliance and Enforcement

THROUGH: Phil Martin, P.E., Engineering Section

THROUGH: Peer Review, Hal Wright, ROAT

FROM: Herb Neumann, Regional Office at Tulsa (ROAT)

SUBJECT: Evaluation of Permit Application No. 2009-008-TVR

Southwest United Industries

Tulsa Facility

422 S. St. Louis, Tulsa, Tulsa County

I. INTRODUCTION

The facility has been in operation since 1953 and currently operates under Permit No. 2002-017-

TV, issued January 10, 2005. The facility now submits an application to renew the Part 70

permit. Several minor changes in the facility will be discussed at appropriate places in this

Memorandum.

II. PROCESS DESCRIPTION

While the description to follow concerns aircraft parts as the major activity at this facility, other

industry groups are involved. For instance, the facility processes such parts as fertilizer plungers

and washing machine pulleys. The facility does not manufacture parts, but is involved in the

production, rework, or repair of parts. Aircraft parts that come to the facility require various

treatments. Mechanical and chemical cleaning are the usual starting points in the process, but

the exact starting point for any specific part depends on what the final treatment is to be. After

cleaning, parts are taken to areas where surfaces are treated by anodizing or plating. Various

materials are used in these plating processes, but the desired result is typically related to hardness

and wear resistance. Non-destructive testing (NDT) may occur when parts are received and/or

before they are shipped. Finally, some parts are painted.

The facility consists of several large buildings and a few smaller support buildings. The large

buildings are divided into functional areas identified as Buildings 1 through 11, 5A, and 7A/7B.

Functional areas include mechanical cleaning, usually by grit blasting, anodizing, which requires

roughly twenty tanks, and chrome plating, with six tanks and related rectifiers. There is auxiliary

equipment close to the plating area, as well as a vapor degreaser, and a paint shop with several

PERMIT MEMORANDUM 2009-008-TVR DRAFT

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booths. Most (approximately 80%) of the machined aircraft parts the facility processes are

aluminum, with the remainder roughly evenly divided among titanium, stainless steel, and

various alloys. Most parts are first cleaned and then pretreated. Pretreatment can include non-

destructive inspection, degreasing, solvent wiping, acid or alkaline etch, zincating, shotpeening,

electrolytic striking, or desmutting. Parts are then processed through one or more of thermal

spray, anodizing, plating, passivating, conversion coating, or painting. Post treatment

possibilities include conversion coating, dyeing, sealing, stress relief baking, machining,

grinding, polishing, and non-destructive inspection. The exact steps followed by each part

depend on many variables, such as the type of part, customer requirements, and part

composition. Slightly more detailed descriptions of some of the processes used at the facility

follow this paragraph.

Electroplating

This is the application of a metallic coating on a conductive surface. Metal ions provided by

anodes or metal salts travel through electroplating solutions to the work piece (cathode) to be

coated. This may involve copper, nickel, cadmium, or other metals, but chrome is the metal

most commonly applied in this industry. Practically all of the chrome plating at this facility is

classified as hard chrome, which generally refers to a fairly thick coating applied at a high

current density.

Electroless nickel plating

This process is the autocatalytic chemical deposition of a metal coating on a work piece by

immersion in a solution, but without the use of electric current. It is used for corrosion and wear

resistance where precisely controlled coating thicknesses are required. This process uniformly

deposits a nickel-phosphorous alloy on outer and inner surfaces without special tooling.

Anodizing

This is an electrolytic process by which an oxide layer is produced on the surface of a base metal

for purposes such as corrosion resistance or electrical insulation. The part to be anodized acts as

the anode and the electrolyte is generally sulfuric acid or chromic acid. The depth of the oxide

layer formed is a function of time spent in solution. The facility typically uses this process on

aluminum parts.

Conversion coating

These coatings are usually applied to prepare a part for further surface activity. Three

conversion coatings used at this facility are chromating, phosphatizing, and oxiding. Chromating

involves applying a protective film of hexavalent chrome and active organic or inorganic

compounds to the surface of parts. At this facility, chromating is performed on aluminum parts

and on cadmium-plated parts. Phosphatizing involves the immersion of cadmium-plated, steel,

iron, or titanium parts in a hot solution of dilute phosphoric acid, along with other reagents.

Formation of hydrous crystals on the surface generally prepares the part for painting. Oxiding

puts an iron piece into a superheated hydroxide salt to produce ferrous oxides known as brown,

black, or blue oxide. These coatings must be protected by wax or oil to prevent corrosion.


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Passivation

This process removes unwanted iron from alloys to make the part less susceptible to corrosion

(passive). Typically, a stainless steel part is immersed in a nitric acid and/or sodium dichromate

solution.

Thermal spray

Various non-hazardous powdered metals can be applied at high temperatures to build up a metal

surface, somewhat similar to spray-painting. The facility uses high-velocity oxy fuel (HVOF),

plasma spray, and wire spray equipment to perform this operation.

III. EQUIPMENT

Emission units have been arranged into Emission Unit Groups (EUGs) as outlined following.

Emission units that emit the same regulated air pollutants, trigger the same applicable

requirements, share the same compliance demonstration methods, and share the same proposed

compliance assurance certifications are combined as one EUG.

EUG 1 Facility Wide

This emission unit group is facility-wide. It includes all emission units and is established to

discuss the applicability of those rules or compliance demonstrations that may affect all sources

within the facility.

EUG 2 Paint Booths

There are five booths. One is used for maskant operations, as well as for painting. These

maskants are not “chemical milling maskants,” as that term is defined in 40 CFR 63.742. Booths

#1 and #2 have been replaced and Booth #5 is new.

EU ID Point # Name Construction Date

PB 1 P 1 Paint Booth #1 2009



PB 4 P 4 Paint Booth #4 – Maskant Operations 1990


EUG 3 Chrome Plating

There are five tanks in hard chrome service. Aggregated, they have a capacity of 3,690 gallons,

122 square feet of surface area, and 11,500 amperes of current capacity. The tanks vary in size

to accommodate the various demands placed on the facility. Each tank has a mesh pad mist

eliminator, and ventilation hoods flow all exhaust to complex dry scrubbers. The anodizing tank

has 1,340 gallons capacity, 43 square feet of surface area, and 750 amperes of current capacity.

The anodizing tank utilizes a fume suppressant to control emissions.


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T-1 P 7 Tank #1111-Chromic anodizing 2009

T-2 P 8 Tank #268-Hard chrome 1955





EUG 4 Vapor Degreaser

The batch degreaser has a surface area of 14.2 square feet and uses perchloroethylene.


VD-1 P 5 Tank #300 – Vapor Degreaser 1992

EUG 5 Fugitives (Hand-wipe Cleaning)


FUG-1 P 6 Hand-wipe Cleaning N/A

Stack data for some of the emission points follow. The scrubbers associated with EUG 3 are

located on the roof.

Source Height above

grade Diameter Temperature

Exhaust

(acfm)

Boiler 1 20´ 8" 550°F 600

Boiler 2 20´ 10" 425°F 1,499

Paint booth 1 29´ 34" Ambient 3,600




IV. EMISSIONS

EUG 1 Facility Wide

There are no emissions directly associated with this EUG.

EUG 2 Paint Booths

The original operating permit for this facility analyzed 1994 data for coating operations and the

original Part 70 permit analyzed data for 2002. The original permit contained a VOC limit of

16.74 TPY, designed to allow for growth, and conservatively high assumptions made in

analyzing data for the original Part 70 permit resulted in granting a slightly higher emission limit

of 17.5 TPY for VOC. There have been no significant changes in operations at the facility and

review of emission data for the intervening five years shows that the 17.5 TPY limit is several

times larger than the highest actual VOC emissions for any year.


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EUG 3 Chrome Plating

The highest emission standard that could apply to this source is 0.030 mg/dscm, per 40 CFR

63.342(c)(1)(ii). Combined with the exhaust rate of 41,025 cfm for each scrubber, facility-wide

total emissions of chrome would be 80 lbs/yr or 0.04 TPY. Reference Method testing of the

scrubber exhausts shows actual emissions to be less than even the more stringent 0.015 mg/dscm

standard of 63.342(c)(1)(i).

EUG 4 Vapor Degreaser

The degreaser has a surface area of 14.2 square feet and uses perchloroethylene. The original

Part 70 permit limit is based on the MACT standard of 150 kg/m2/month, which is approximately

2.6 TPY. Actual emissions for 2008 were 1.73 TPY.

EUG 5 Fugitives (Hand-wipe Cleaning)

The original Part 70 permit authorized 2 TPY of VOC as a conservatively high estimate. Data

from 2008 show 0.50 TPY of VOC, all of which was HAP.

V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified on Part 1b of the forms in the application and

duplicated below were confirmed by the initial operating permit inspection. Records were

available to confirm the insignificance of the activities. Appropriate recordkeeping of activities

indicated below with an asterisk is specified in the Specific Conditions.

(1) Space heaters, boilers, process heaters and emergency flares less than or equal to 5

MMBTU/hr heat input (commercial natural gas). The facility has two boilers rated at less

than 5 MMBTUH each. It also has 12 small drying or curing ovens, each rated at less than 5

MMBTUH.

(2) *Emissions from fuel storage/dispensing equipment operated solely for facility owned

vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day

period. There is a single 30-gallon gasoline storage tank on-site that is filled between once a

week and once a month. This is far below the 2,175 gallons per day threshold, so only

annual recordkeeping will be required for this tank.

(3) Additions or upgrades of instrumentation or control systems that result in emissions increases

less than the pollutant quantities specified in OAC 252:100-8-3(e)(1).

(4) Cold degreasing operations utilizing solvents that are denser than air. There is a small tank

that uses a blend of aliphatic naphtha and aromatic naphtha. The facility used 110 gallons

(approx. 730 pounds) of naphtha blend during 2008.

(5) *Welding and soldering operations utilizing less than 100 pounds of solder and 53 tons per

year of electrodes. Most of this activity is a maintenance operation, but there is a small

amount of process-related activity. Total annual consumption of electrodes for both purposes

is approximately 0.3 tons.

(6) Torch cutting and welding of less than 200,000 tons of steel fabricated. Any torch cutting or

welding at this facility is a maintenance activity. As such, it is a trivial activity and no

recordkeeping is required.

(7) Hazardous waste and hazardous materials drum staging areas.


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(8) 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 (i.e., lift station). The only related activity is pretreatment of wastewater before

disposal to the POTW.

(9) *Activities having the potential to emit no more than 5 TPY (actual) of any criteria pollutant.

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 listed in OAC 252:100, Appendix Q. These requirements are addressed in

the “Federal Regulations” section.

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

Subchapter 3 enumerates the primary and secondary ambient air quality standards and the

significant deterioration increments. At this time, all of Oklahoma is in “attainment” of these

standards.

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

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

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

regulated pollutants. Emission inventories were submitted and fees paid for previous years as

required.

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

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

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

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

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

individual emission units either listed in Appendix I or whose actual calendar year emissions do

not exceed the following limits.

5 TPY of any one criteria pollutant

2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAP or 20%

of any threshold less than 10 TPY for a HAP that the EPA may establish by rule

Emission limitations and operational requirements necessary to assure compliance with all

applicable requirements for all sources are taken from the existing operating, from the permit

application, or are developed from the applicable requirement.

OAC 252:100-9 (Excess Emissions 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


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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)) [Applicable]

Section 19-4 regulates emissions of PM from new and existing fuel-burning equipment, with

emission limits based on maximum design heat input rating. The only fuel-burning equipment

items are insignificant activities. Appendix C specifies a PM emission limitation of 0.60

lbs/MMBTU for all equipment at this facility with a heat input rating of 10 Million BTU per

hour (MMBTUH) or less. AP-42 (7/98) Table 1.4-1 lists natural gas TPM emissions to be 7.6

lbs/million scf or about 0.0076 lbs/MMBTU, which is in compliance.

Section 19-12 regulates emissions of PM from industrial processes. All such emissions are

negligible.

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable]

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

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

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

period exceed 60% opacity. There are no units with emissions likely to exceed these 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 2 limits emissions of sulfur dioxide (SO2) from any one existing source or any one new

petroleum and natural gas process source subject to OAC 252:100-31-26(a)(1). Ambient air

concentrations of SO2 at any given point shall not be greater than 1,300 g/m3 in a 5-minute

period of any hour, 1,200 g/m3 for a 1-hour average, 650 g/m

3 for a 3-hour average, 130 g/m

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for a 24-hour average, or 80 g/m3

for an annual average. The two small boilers are insignificant

activities and burn commercial grade natural gas. SO2 emissions from these sources are

negligible.


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

This subchapter limits new fuel-burning equipment with rated heat input greater than or equal to

50 MMBTUH to fuel-specific emissions of NOx per MMBTU, three-hour average. There are no

equipment items that exceed the 50 MMBTUH threshold.

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

This subchapter affects gray iron cupolas, blast furnaces, basic oxygen furnaces, petroleum

catalytic cracking units, and petroleum catalytic reforming units. There are no affected sources.

OAC 252:100-37 (Volatile Organic Compounds) [Part 7 Applicable]

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

or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a

permanent submerged fill pipe or with an organic vapor recovery system. The only storage tank

the facility has is a 30-gallon gasoline tank for refilling the forklifts.

Part 5 limits the VOC content of coatings used in coating lines and operations. All of the paint

booths in the facility are “new,” as that is defined in Section 37-3. Compliance with OAC

252:100-39-47 and 40 CFR 63 Subpart GG satisfies the requirements of Part 5. The facility shall

use compliant coatings for sources not addressed in 39-47 or GG. Routine maintenance of the

facility and equipment is exempt.

Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize VOC

emissions. Temperature and available air must be sufficient to provide essentially complete

combustion. The small boilers are designed to provide essentially complete combustion of

organic materials.

OAC 252:100-39 (VOC in Nonattainment and Former Nonattainment Areas) [Applicable]

This subchapter imposes additional conditions beyond those of Subchapter 37 on emissions of

organic materials from new and existing facilities in Tulsa and Oklahoma Counties.

Part 7 covers Specific Operations.

Subsection 42(a) covers cold cleaning units, noting standards for construction and operation of

such equipment. Paragraph 1 outlines equipment standards, including doors or covers, closed

drainage, and conspicuous labeling. Paragraph 2 describes operating requirements; namely,

appropriate draining procedures and times, keeping the unit covered when not in use, proper

storage and disposal of waste solvent, and stipulates that spraying of VOC can only be in a solid

stream. Paragraph 3 outlines requirements for controls if the solvent’s vapor pressure exceeds

certain limits. Paragraph 4 lists compliance and recordkeeping criteria. The facility has two cold

units that comply with these requirements.

Subsection 42 (b) covers vapor type metal degreasers, noting standards for construction and

operation of such equipment. Paragraph 1 outlines equipment standards including doors and

covers in Subparagraph A; safety switches in Subparagraph B; equipment specifications such as

freeboard, chillers, etc., in Subparagraph C; and conspicuous labeling of the equipment in

Subparagraph D. Paragraph 2 describes the labeling information required to comply with

Subparagraph 1(D). Paragraph 3 lists compliance and recordkeeping criteria. The facility is in

compliance.

Section 46 covers the coating of parts and products, excluding architectural coating, aerospace

coating, and automobile refinishing. This facility processes parts for industries other than

aerospace and shall comply with the VOC content per gallon of as applied coating standards


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described in 39-46(d). VOC-containing materials used in cleanup shall be included in the

calculations of VOC content per gallon applied unless the “housekeeping” requirements of 39-

46(g) are met. The facility is in compliance.

Section 47 covers VOC emissions from aerospace industries coating operations, with requirements

specifically applicable to aerospace vehicle and component coating operations at aerospace

manufacturing, rework, or repair facilities located in Tulsa County that have the potential to emit

more than 10 TPY of VOC from coating operations. Coating operations include associated

cleaning operations and surface preparation. This section is modeled on, and closely tracks, the

Aerospace MACT found in federal NESHAP, 40 CFR 63 Subpart GG. With the exception of

“specialty coatings,” as that term is defined in §39-47(c)(5), standards and requirements for VOC

content, application equipment, control equipment, housekeeping measures, solvent cleaning

operations, and general standards reference appropriate sections of GG. Standards for specialty

coatings are addressed in §39-47(d). With the exception of specialty coatings, each of these areas

has been addressed in Section VII (Federal Regulations). Note that the low volume exemption is

modified in §39-47 to include specialty coatings in the 50-gallon/200 gallon standard. In similar

fashion, monitoring, recordkeeping, and test methods reference appropriate sections of GG,

excepting specialty coatings. These topics were also addressed in Section V. The compliance

date provisions of §39-47(h) also reference GG, stating that compliance with GG constitutes a

demonstration of compliance with §39-47, again with particular attention paid to specialty

coatings.

The VOC content of specialty coatings must meet the specifications listed in OAC 252:100

Appendix N. These standards shall be met by as-applied coatings, but do not apply to touch-up,

aerosol, or DOD “classified” coatings. Compliance with the specialty coating VOC limits may

be achieved through the use of control equipment, provided that the equipment has a combined

capture and control efficiency of 81% or greater by weight. If control equipment is used to

comply with the Appendix N standards, a monitoring plan describing the parameter and its range

shall be submitted, and the equipment must be installed, calibrated, operated and maintained

according to the manufacturer’s specifications. Monitoring records of the parameter(s) shall be

maintained. Spray gun cleaners used for specialty coatings shall be visually inspected for leaks

and all other potential sources of leaks at least once per month, while the cleaner is in operation.

The facility shall maintain a current list of all Appendix N coatings in use, showing category, as-

applied VOC content, and 12-month usage.

OAC 252:100-42 (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 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


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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 252:100-47 Landfills not type of source category

VII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Not Applicable]

PSD does not apply. Final total emissions are less than the threshold of 250 TPY of any single

regulated pollutant and the facility is not one of the listed stationary sources with an emission

threshold of 100 TPY.

NSPS, 40 CFR Part 60 [Not Applicable]

There are no affected facilities or sources at this site covered under any subpart.

NESHAP, 40 CFR Part 61 [Not Applicable]

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

coke oven emissions, mercury, radionuclides, or vinyl chloride.

NESHAP, 40 CFR Part 63 [Subparts N, T, and GG Applicable]

Subpart N (Chromium Emissions From Hard and Decorative Chromium Electroplating and

Chromium Anodizing Tanks) affects the chrome plating and anodizing tanks of EUG 4. All

affected hard chrome tanks (#268, #269, #270, #271, and #272) have mist eliminators in their

hoods, and are exhausted to one of two three-stage composite mesh pad scrubbers. Combined

capacity of these tanks is 11,500 amperes, yielding a maximum cumulative potential rectifier

capacity, as defined in §63.341(a), of 11,500 amps 8,400 hrs/yr 0.7 = 67.6 million amp-

hrs/yr. This capacity would qualify the facility as a “large hard chrome electroplating facility,”

but they have maintained records required under §63.342(c)(2)(i)(B) to demonstrate that the


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facility is “small.” The hard chrome tanks must meet the §63.342(c)(1)(i) chrome standard of

0.03 mg/dscm. The facility meets the anodizing tank standard found in §63.342(d)(2) for tanks

using fume suppressants, which requires that surface tension not exceed the standard of 45

dynes/cm at any time during tank operation. The facility shall also practice certain work practice

standards that must be described in a written operating and maintenance (O&M) plan. The

facility has such a plan.

Subpart T (Halogenated Solvent Cleaners) affects the perchloroethylene (perc or

tetrachloroethylene) vapor degreaser. Applicant demonstrates compliance using the alternative

standard of 40 CFR 63.464. Since the machine has a solvent/air interface, 464(a)(1) sets out the

relevant information. A log of solvent additions and deletions must be maintained, and these

data must be used to show that the emission limit of §464’s Table 5 is met. The Table 5 standard

for batch machines is a rolling three-month average not to exceed 150 kg/m2. Solvent

measurements and calculation methods are described in 40 CFR 63.465(b) & (c), and are

referenced in the Specific Conditions. Applicant is in compliance.

Subpart GG, (Aerospace Manufacturing and Rework Facilities), applies to facilities engaged,

either in whole or in part, in the manufacture or rework of commercial, civil, or military aerospace

vehicles or components and that are major sources as defined in §63.2. Note that this facility is not

a general aviation rework facility, as that term is defined in §63.742. Affected sources within the

facility are enumerated in §63.741(c) (1), (2), (3) & (7). A discussion of each follows.

§63.741(c) (1) Each cleaning operation is an affected source, specifically including all hand-wipe

cleaning operations, each spray gun cleaning operation, and all flush cleaning operations. Specific

standards covering cleaning operations are found in §63.744. Housekeeping measures described in

§744(a) affect all solvents not specifically exempted by Table 1 of the section. General measures

include keeping used solvent-laden materials in closed bags or containers, storing solvents in

closed containers, and handling solvents so as to minimize spills. Solvents used in hand-wipe

cleaning must meet one of three criteria described in §744(b). The criteria are to: (A) meet the

composition requirements of Table 1; (B) have a composite vapor pressure less than 45 mm Hg; or

(C) demonstrate a reduction of 60% in use of solvents over a 1996/97 baseline. The facility has

chosen method B to achieve compliance, including the use of acetone, which has been delisted as a

VOC and HAP, and is not controlled by GG. Four methods for spray gun cleaning are listed in

§744(c). These methods include: (i) an enclosed system; (ii) nonatomized cleaning; (iii)

disassembled spray gun cleaning; and (iv) atomizing cleaning. The facility uses (ii), forcing

cleaning solvent through the gun with the atomizing cap in place. All operations shall be inspected

monthly, and all leaks repaired as soon as practicable. If leaks cannot be repaired within 15 days

of detection, the unit shall be drained and shut down until repairs are performed.

§63.741(c) (2) The General Standards contain requirements for primer and topcoat operations.

These Specific Standards are found in §63.745. The facility is required to identify each coating as a

topcoat or primer. Further, some coatings may qualify as specialty coatings as defined in 40 CFR

63.472 and are not controlled under the restrictions on topcoats or primers, or a particular coating

may satisfy the low-use exemption of §63.741(g). Handling and transfer of primers and topcoats

must be performed in such a manner as to minimize spills. Further standards are specified at

§63.745(c), because VOC emissions at these paint booths were not designed to be subject to add-

on controls. Organic HAP emissions and VOC emissions from primers are limited to 2.9 pounds

per gallon (ppg) of coating, less water, as applied. Compliance may be shown by maintaining all

coatings below the specified limits or by using monthly weighted averages. The facility has

chosen the former, as described in §63.745(e)(1). The use of HVLP is one of the specified


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methods of application and hand-held spray cans for stenciling or for hard-to-reach spots are

specifically allowed per §63.745(f).

§63.741(c) (3) This discussion is essentially identical to that immediately preceding, except that

organic HAP emissions and VOC emissions from topcoats are limited to 3.5 pounds per gallon

(ppg) of coating, less water, as applied.

§63.741(c) (7) The standards for inorganic HAPs are described in §63.745(g), including provisions

requiring compliance with applicable portions of Subpart A; but exempt from compliance with the

start-up and shutdown provisions of §63.6 with the proviso that the dry filter is operated in

accordance with manufacturer’s specifications. Booths 3 and 4 are existing booths and booths 1, 2,

and 5 are new. All systems are downflow, with two-stage particulate filters that meet the challenge

criteria of Tables 1, 2, 3, and 4, and allow for continuous monitoring of pressure drop. Coating

must immediately cease whenever pressure drop falls outside a specified range. Per §744(g)(2)(iv)

all dry filter booths have differential pressure gauges, with readings taken at least once per shift.

Each booth is shut down and corrective action taken when readings fall outside the acceptable

range.

CAM, 40 CFR Part 64 [Not Applicable]

This part applies to any pollutant-specific emission unit at a major source that is required to

obtain an operating permit, for any application for an initial operating permit submitted after

April 18, 1998, that addresses “large emissions units,” or any application that addresses “large

emissions units” as a significant modification to an operating permit, or for any application for

renewal of an operating permit, if it meets all of the following criteria.

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

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

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

pollutant of 100 TPY

This facility contains no large emission units and is not subject.

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

This facility will not process or store more than the threshold quantity of any regulated substance

(Section 112r of the Clean Air Act 1990 Amendments). More information on this federal

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

Stratospheric Ozone Protection, 40 CFR Part 82 [Not Applicable]

These standards apply to Class I & II substances. This facility does not utilize any Class I & II

substances. To the extent it might use such substances in the future, it shall comply with

Standard Condition XX.

VIII. COMPLIANCE

Inspection

The most recent full compliance evaluation of this facility was performed by DEQ Regional Office

at Tulsa Environmental Specialist Helen King on February 13, 2008. Her report indicates that the

facility appeared to be in compliance at that time. Pamela Wood, Southwest’s EHS Coordinator

http://www.epa.gov/ceppo


13

and Marcy Klass-Jones, Southwest’s consultant, provided a walk-through of the facility for DEQ

ROAT permit writer Herb Neumann on November 24, 2009, viewing the new equipment. All

equipment was in place, but due to production requirements, most items did not have first

operation until mid-February, 2010. All visits have confirmed the proper installation of equipment

and that required records are being maintained.

Testing Performance testing required by the Chrome MACT was performed on May 14 and 15, 1997.

Details were provided in the memorandum associated with the initial TV permit. Reference

Method 319 testing required to show compliance with the Aerospace MACT standards for spray

booths with inorganic HAP is not performed by the facility, but the following data for the Camfil

Farr SF95 5-Pocket Bag Filters in current use have been provided by the manufacturer, based on

independent testing performed in March, 2003.

Table 3 liquid-phase requirements for new sources

Aerodynamic diameter Required filtration efficiency Observed efficiency

> 2.0 > 95% 98%

> 1.0 > 80% 94%

> 0.42 > 65% 84%

Table 4 solid-phase requirements for new sources

Aerodynamic diameter Required filtration efficiency Observed efficiency

> 2.5 > 95% 99%

> 1.1 > 85% 96%

> 0.70 > 75% 93%

Tier Classification And Public Review This application has been classified as Tier II based on the request for a renewal Part 70 operating

permit for an existing major source. Public notice of filing of this application was published in

the Tulsa World on July 30, 2009. The application was available for review at the DEQ

Regional Office at Tulsa, 3105 E. Skelly Drive, Tulsa, and at the AQD office in Oklahoma City.

Notice of the 30-day public review opportunity for the draft permit will be published in a

newspaper of general circulation in Tulsa County. Information on all permit actions is available

for review by the public in the Air Quality section of the DEQ Web page: www.deq.state.ok.us/.

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

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

applicant owns the real property. This site is not within 50 miles of the Oklahoma border.

Fee paid Renewal Title V operating permit fee of $1,000.

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


14

IX. SUMMARY

This facility was constructed as described in the application. There are no active Air Quality

compliance or enforcement issues that would affect the issuance of this permit. Issuance of the

operating permit is recommended, pending public comment and EPA review.

DRAFT

PERMIT TO OPERATE

AIR POLLUTION CONTROL FACILITY

SPECIFIC CONDITIONS

Southwest United Industries Permit No. 2009-008-TVR

Aviation Manufacturing and Rework Facility

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

Quality on July 23, 2009. The Evaluation Memorandum dated February 22, 2010, 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)]

a) EUG-1 Facility-Wide

There are no emissions directly associated with this EUG.

b) EUG 2 Paint Booths

There are five booths. One is used for maskant operations, as well as for painting. The EUG is

authorized VOC emissions of 17.5 TPY.


PB 1 P 1 Paint Booth #1 2009*

PB 2 P 2 Paint Booth #2 2009*


PB 4 P 4 Paint Booth #4 – Maskant Operations 1990

PB5 P 5 Paint Booth #5 2009

* Booths replaced in 2009.

c) EUG 3 Chrome Plating

The five tanks in hard chrome service have an aggregate capacity of 3,690 gallons, 122 square

feet of surface area, and 11,500 amperes of current capacity. The hard chrome tanks have mist

eliminators and flow their exhaust to one of two identical mesh pad scrubbers. Anodizing tank

#1111, has capacity of 1,578 gallons, 31 square feet of surface area, and is expected to average

800 amps. The anodizing tank utilizes a fume suppressant to control emissions.

SPECIFIC CONDITIONS 2009-008-TVR DRAFT 2


T-1 P 7 Tank #1111-Chromic anodizing 2009






No emission limits are set, but compliance with the MACT N limit of 0.03 mg/dscm is required

for the hard chrome scrubbers. Compliance with the MACT N surface tension standard of 45

dynes/cm is required for the anodizing tank. See Specific Condition #16 for more details.

d) EUG 4 Vapor Degreaser

The degreaser has a surface area of 14.2 square feet and uses perchloroethylene. Annual

authorized emissions are equivalent to those determined by compliance with a limit of 150

kg/m2/month , which is more stringent than the MACT T limit, and shall be demonstrated on a 3-

month-rolling basis. Also see Specific Conditions #14 and #15.


VD-1 P 5 Tank #300 – Vapor Degreaser 1992

e) EUG 5 Fugitives (Hand-wipe Cleaning)

A level of 2 TPY of VOC is authorized.


FUG-1 P 6 Hand-wipe Cleaning N/A

f) EUG 6 Insignificant Activities

1) Space heaters, boilers, process heaters and emergency flares less than or equal to 5

MMBTU/hr heat input (commercial natural gas). The facility has two boilers and 12

drying/curing ovens rated at less than 5 MMBTUH each.

2) *Emissions from fuel storage/dispensing equipment operated solely for facility owned

vehicles if fuel throughput is not more than 2,175 gallons/day, averaged over a 30-day

period. There is a single 30-gallon gasoline storage tank on site that is filled between once

a week and once a month. This is far below the 2,175 gallons per day threshold, so only

annual recordkeeping is required for this tank.

3) Additions or upgrades of instrumentation or control systems that result in emissions

increases less than the pollutant quantities specified in OAC 252:100-8-3(e)(1).

4) Cold degreasing operations utilizing solvents that are denser than air.

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

year of electrodes. Most of this activity is a maintenance operation, but there is a small

amount of process-related activity.


6) Torch cutting and welding of less than 200,000 tons of steel fabricated. Any torch cutting

or welding at this facility is a maintenance activity. As such, it is a trivial activity and no

recordkeeping is required.

7) Hazardous waste and hazardous materials drum staging areas.

8) 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 (i.e., lift station). There is only pretreatment of wastewater before disposal to

the POTW.

9) *Activities having the potential to emit no more than 5 TPY (actual) of any criteria

pollutant.

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. Fuel-burning equipment at this facility shall burn only commercial-grade natural gas.

[OAC 252:100-37-36]

4. Organic HAP emissions from primers shall be limited to an organic HAP content level of 2.9

pounds per gallon (ppg) as applied, less water. VOC emissions from primers shall be limited to

a VOC content level of 2.9 ppg (less water and exempt solvents) as applied. Organic HAP

emissions from topcoats and self-priming topcoats shall be limited to an organic HAP content

level of 3.5 ppg as applied, less water. VOC emissions from topcoats and self-priming topcoats

shall be limited to a VOC content level of 3.5 ppg (less water and exempt solvents) as applied.

The terms “primers,” “topcoats,” and “self-priming topcoats,” as used in this Specific Condition

(SC) and in SC #8 and SC #9 carry the definition of these terms found in OAC 252:100-39-47

and/or 40 CFR 63 Subpart GG. These HAP and VOC content standards do not apply to those

coatings that possess additional performance criteria beyond those of primers or topcoats. Such

coatings are identified as specialty coatings, and are addressed in Specific Condition No. 9 below.

[OAC 252:100-39-47(d)(1)(B), 40 CFR 63.745(c)]

5. The VOC content of specialty coatings, as specialty coating is defined in OAC 252:100-39-

47(c), with an equivalent definition in 40 CFR 63.742, shall not exceed the levels specified in OAC

252:100 Appendix N (as applied). [OAC 252:100-39-47(d)(1)(A)]

6. The requirements for primers, topcoats, specialty coatings, and chemical milling maskants

described in 40 CFR 63.745, 40 CFR 63.747, and OAC 252:100-39-47(d), do not apply to the

use of such coatings for which the annual total of each separate formulation used at the facility

does not exceed 50 gallons and the combined annual total of all such coatings does not exceed

200 gallons. Primers, topcoats, and specialty coatings exempted under §63.745(f)(3),

§63.745(g)(4), or §39-47(a) are not included in the 50- and 200-gallon limits. Since the

Oklahoma rule is more restrictive than the MACT, it is the primary citation.

[OAC 252:100-39-47(d)(1)(D)]

7. Primers and topcoats containing inorganic HAPs shall be sprayed only in booths meeting the

requirements of the Aerospace MACT, including the challenges of Tables 1 and 2 for booths #3

and #4 and of Tables 3 and 4 for booths #1, #2, and #5. More detail is found in the citation. The


dry particulate filter systems on these booths shall be maintained in good working order. The

differential pressure gauge across the filter banks shall be continuously monitored and the

pressure drop ( P) read and recorded at least once per shift. If P exceeds the filter

manufacturer’s recommended limit(s), the booth shall be immediately shut down and corrective

action taken. [40 CFR 63.745(g)]

8. Coating operations shall use HVLP spray guns or one of the alternate methods listed in 40

CFR 63.745(f)(1). Exemptions to this requirement are specified in (f)(3), and include limited

access areas, fillers that adversely affect atomization, thin film applications, stenciling, lettering,

other identification markings, hand-held spray can applications, and touch-up and repair

operations. [40 CFR 63.745(f)]

9. A list of all aerospace coating products in current use (none older than 12 months is required)

shall be maintained, showing the type of coating (primer, topcoat, or individual specialty as

identified in Appendix N), and any information necessary to classify it further as to possible

exemption under SC #7. [OAC 252:100-43]

10. Any coatings that are not subject to MACT GG or to OAC 252:100-39-47 are subject to

OAC 252:100-39-46. Such coatings shall demonstrate compliance with the standards of 39-

46(d) on a daily weighted-average basis. Cleanup materials may be exempted from this

calculation only if the conditions of 39-46(g) are met. [OAC 252:100-39-46]

11. All hand-wipe cleaning solvents shall have composite vapor pressure no greater than 45 mm

Hg at 20ºC or shall meet the composition requirements of Table 1 of 40 CFR 63.744. Good

housekeeping shall be observed, with measures detailing proper handling of fresh and spent

solvents and solvent-laden materials being described in 40 CFR 63.744(a). Cleaning solvents with

HAP and VOC content below the de minimis levels of §63.741(f) are exempt from these

requirements. Thirteen cleaning operations exempt from these requirements are listed in 40 CFR

63.744(e). [OAC 252:100-39-47(d)(4), 40 CFR 63.744(a & b)]

12. Only the following methods shall be used for spray gun cleaning.

a) an enclosed system. The enclosed system shall be open only while inserting or removing

the gun, and cleaning consist of forcing solvent through the gun. Monthly inspections

shall be performed while the system is in operation, with visual inspection of the seals

and other potential sources of leaks. Leaks must be repaired as soon as practicable, but

always within 15 days. If repairs cannot be effected within 15 days, the unit shall be

drained and use discontinued.

b) nonatomized cleaning. Place cleaning solvent in the pressure pot and force it through the

gun with the atomizing cap in place. No atomizing air is to be used. Direct the cleaning

solvent from the gun into a waste container that is closed when not in use.

c) disassembled spray gun cleaning When the guns are disassembled, they may be cleaned by

hand in a vat, which shall remain closed except while in use, or allowed to soak in a vat,

which shall be opened only while inserting or removing the parts.


d) atomizing cleaning. Force the cleaning solvent through the gun and direct the resulting

atomized spray into a waste container that is fitted with a device designed to capture the

atomized cleaning solvent emissions.

In all cases, good housekeeping shall be practiced, with measures detailing proper handling of

fresh and spent solvents and solvent-laden materials described in 40 CFR 63.744(a). Solvents with

HAP and VOC content below the de minimis levels of §63.741(f) are exempt from these

requirements. [OAC 252:100-39-47(d)(4), 40 CFR 63.744(a & c)]

13. Excluding those operations that use Table 1 or semi-aqueous solvents, the used cleaning

solvent from each cleaning of an aerospace part, assembly, or coating unit component (except

spray guns) shall be emptied into an enclosed container or collection system that is kept closed

while not in use. [40 CFR 63.744(d)]

14. The vapor degreaser of EUG 7 is subject to the Halogenated Solvent Cleaning MACT (40

CFR 63 Subpart T) and shall comply with the requirements of that subpart.

a) Standards are contained in §63.464 and require that a log of solvent additions and deletions

be maintained, and that the 3-month rolling average emissions not exceed 150 kg/m2/month.

b) Test methods described in §63.465 describe the method of measuring additions and deletions

and outline the formulas to be used in calculating the rolling average.

c) Recordkeeping described in §63.467 requires that all data recorded for use in the

calculations, as well as the calculations themselves, as these are described in (a) and (b)

preceding, be maintained in written or electronic form for a period of five years from the date of

recording.

Required reporting is described in §63.468. These reports include an initial notification of the

new machines, as detailed in §468(b), an initial statement of compliance, as detailed in §468(e),

and an annual solvent emission report, as detailed in §468(g). [40 CFR 63, Subpart T]

15. The permittee shall comply with the following outlined provisions for operation of the

degreaser, which are further detailed in OAC 252:100-39-42(b). [OAC 252:100-39-42]

a) The unit door shall operate easily and without disturbing the vapor zone.

b) The unit shall have safety switches to shut off sump heat if the coolant is not circulating

or exceeds the recommended level.

c) The unit shall have one or more of certain control devices or techniques, including a

freeboard ratio not less than 0.75, a chiller, enclosed design, carbon adsorption, or any

system whose efficiency is at least equal to any of the first four listed.

d) A conspicuous label summarizing the operating procedures shall be permanently

attached to the unit. At a minimum, this label shall include all of the provisions

described in OAC 252:100-39-42(b)(2).

16. This facility is subject to MACT N, Standards for Chromium Emissions from Hard and

Decorative Chromium Electroplating and Chromium Anodizing Tanks, as published in the

Federal Register on January 25, 1995. Records of capacity (amp-hrs) shall be maintained to

show that the facility continues to be a “small” existing source. Hard chrome tanks #268, 269,


270, 271, and 272 are subject to the 0.03 mg/dscm standard of 40 CFR 63.342(c)(1)(ii).

Performance testing of the composite mesh pad scrubbers demonstrates that this level of

emissions is accomplished when the pressure drop for Scrubber #1 is within the range P = 3.36

1 and when the pressure drop for Scrubber #2 is within the range P = 3.08 1 . Pressure

drop for each scrubber shall be recorded at least once during each day in which the scrubber is

operated.

Anodizing tank #1111 employs a chemical fume suppressant containing a wetting agent. The

surface tension of the tank shall not exceed 45 dynes/cm at any time during operation of the tank.

Testing with a stalagmometer or tensiometer per Reference Method 306B shall be performed

every four hours of operation. If no exceedances occur during the first 40 operating hours, the

frequency of testing may be relaxed to every eight operating hours. If no exceedances occur

during the next 40 operating hours, the frequency of testing may be further relaxed to every 40

hours. At any time an exceedance occurs, the frequency will again revert to every four hours.

Workplace standards described in 40 CFR 63.342(f) shall be followed, including adherence to

the operation and maintenance (O&M) plan as detailed in §63.342(f)(3). [40 CFR 63, Subpart N]

17. Cold cleaning units shall comply with the standards for construction and operation of such

equipment, including doors or covers, closed drainage, and conspicuous labeling, appropriate

draining procedures and times, keeping the unit covered when not in use, proper storage and

disposal of waste solvent, and spraying of VOC only in a solid stream. Such units shall also

comply with requirements for controls if the solvent’s vapor pressure exceeds certain limits and

with all compliance and recordkeeping criteria. [OAC 252:100-39-42(a)]

18. All records necessary to demonstrate compliance with permit conditions will be maintained

on-site or at a readily accessible location and will be available for review by regulatory personnel

during normal business hours. Records shall be retained for at least five years from the date of

recording. Such records include, but are not necessarily limited to, the following.

a) A listing of all coating products used at the facility, identified as to topcoats or primers

subject to MACT GG, the type of specialty coating per OAC 252:100 Appendix N, or the

type of coating per OAC 252:100-39-46 for each non-aerospace coating.

b) Material Safety Data Sheets for all coating and cleaning products used. MSD Sheets for

coating products shall show the VOC and HAP contents of each product as applied, less

water or exempt solvents, as appropriate. Information supplied shall be sufficient to

demonstrate compliance with the VOC pound per gallon requirements of SC #4, SC #5,

and SC #10. MSD sheets for hand-wipe solvents shall contain vapor pressure

information sufficient to demonstrate compliance with SC #11.

c) Calculations supporting the average kilogram per square meter per month demonstration

required by SC #14 (3-month rolling average).

d) Pressure drop readings for dry filter spray booths per SC #7 (each shift, when operating).

e) Pressure drop readings for each mesh pad scrubber per SC #16 (once each day, when

operating).

f) Capacity records for all hard chrome tanks per SC #16, showing amp-hrs used each

month and for each 12-month rolling period.

g) Surface tension measurements of Tank #1111 per SC #16 (according to the schedule

described in SC #16).


h) A copy of the operating and maintenance plan for the hard chrome plating operation, as

required by SC #16.

i) Records necessary to demonstrate the continued status of Insignificant Activities.

j) Records necessary to show compliance with the requirements for cold cleaning units, per

SC #17.

19. The Permit Shield (Standard Conditions, Section VI) is extended to the following

requirements that have been determined to be inapplicable to this facility.

[OAC 252:100-8-6(d)(2)]

OAC 252:100-7 Permits for Minor Facilities not in source category

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 252:100-47 Landfills not in source category

20. No later than 30 days after each anniversary date of the original Part 70 permit (January 10,

2005), the permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA,

Region 6, certification of compliance with the terms and conditions of this permit.

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

21. This permit supersedes all other existing permits for this facility and they are now null and

void.

MAJOR SOURCE AIR QUALITY PERMIT

STANDARD CONDITIONS

(July 21, 2009)

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, 2009

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)]


3

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)]


4

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)]


5

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,


6

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]


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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(18)

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)]


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(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


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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.


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(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


11

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


12

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]

PART 70 PERMIT


STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON STREET, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2009-008-TVR

Southwest United Industries,

having complied with the requirements of the law, is hereby granted permission to operate

the aerospace rework and repair facilities at 422 S. St. Louis, Tulsa, Tulsa County,

Oklahoma,

subject to standard conditions dated July 21, 2009, and specific conditions, both attached.

This permit shall expire five years from the date of issuance, except as Authorized under

Section VIII of the Standard Conditions.

_________________________________

Division Director Date

Pamela Wood, EHS Coordinator Permit Number: 2009-008-TVR

Southwest United Industries, Inc. Permit Writer: Herb Neumann

422 S. St. Louis Avenue Date:

Tulsa, OK 74120

Air Quality Division has completed the initial review of your permit application referenced

above. This application has been determined to be a Tier II. In accordance with 27A O.S. §2-

14-302 and OAC 252:004-7-13, the enclosed draft permit is now ready for public review. The

requirements for public review include the following steps that you must accomplish.

1. Publish at least one legal notice (one day) in at least one newspaper of general circulation

within the county where the facility is located. (Instructions enclosed)

2. Provide for public review (for a period of 30 days following the date of the newspaper

announcement) a copy of this draft permit and a copy of the application at a convenient location

within the county of the facility.

3. Send to AQD a copy of the proof of publication notice from Item #1 above together with any

additional comments or requested changes that you may have on the draft permit.

Thank you for your cooperation in this matter. If we may be of further service, please contact

our office at (918) 293-1600. Air Quality personnel are located at the DEQ Regional Office at

Tulsa, 3105 E. Skelly Drive, Suite 200, Tulsa, OK, 74105.

Sincerely,

Herb Neumann


Encl.

Pamela Wood, EHS Coordinator

Southwest United Industries, Inc.

422 S. St. Louis Avenue

Tulsa, OK 74120

Re: Part 70 Permit No. 2009-008-TVR

Dear Ms. Wood:

Enclosed is the permit authorizing operation of the referenced facility. Please note that this

permit is issued subject to certain 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 emissions inventory for this facility. An

emissions 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 Emissions Inventory Staff at 405-702-4100.

Thank you for your cooperation in this matter. If we may be of further service, please contact

our office at (918) 293-1600. Air Quality personnel are located in the DEQ Regional Office at

Tulsa, 3105 E. Skelly Drive, Suite 200, Tulsa, OK, 74105-6370.

Sincerely,

Herb Neumann


Encl.

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